Marathon House, 200 Marylebone Road, London, NW1 5PW

Objection to Appeal

PINS Ref: APP/X5990/W/17/3187332

LPA Ref:

17/01608/FULL & 17/00376/TPREF

29 March 2018

© 2018 Nathaniel Lichfield & Partners Ltd, trading as Lichfields. All Rights Reserved. Registered in England, no. 2778116. 14 Regent’s Wharf, All Saints Street, London N1 9RL Formatted for double sided printing. Plans based upon Ordnance Survey mapping with the permission of Her Majesty’s Stationery Office. © Crown Copyright reserved. Licence number AL50684A 14779/BK/BK 15678066v1

Marathon House, 200 Marylebone Road, London, NW1 5PW

Contents

1.0 Introduction 1

2.0 Background 2

3.0 Existing Opposition to the Appeal Scheme 4

4.0 Residents Objections to the Appeal Scheme 6 Harm to the Integrity and Character of Marathon House 6 Harm to the Area’s Townscape and Heritage Assets 8 Parking Provision 10 Inability to Access and Implement the Proposals 11 Procedural Matters 12

5.0 Response to Appellant’s Statement of Case 15 Harm to the Appearance of the Building 15 Proposed Amendments 15 Failure to Maintain or Improve (Preserve or Enhance) the Character and Appearance of the Dorset Square Conservation Area and the Setting of Nos. 29-40 Dorset Square 16 Failure to Maintain or Improve the Setting of the neighbouring Portman Estate Conservation Area and Regent’s Park Conservation Area 17 Excessive Size of the Proposed Flat 17

6.0 Overall Conclusions 18

Marathon House, 200 Marylebone Road, London, NW1 5PW

1.0 Introduction

1.1 This report has been prepared on behalf of the Marathon House (Residents’) Association to outline our clients’ objections to the following planning appeal at Marathon House, 200 Marylebone Road, London, NW1 5PW submitted on behalf of Proxima GR Properties Ltd.:

‘Erection of sheer rooftop extension on existing tower to provide an additional residential unit, incorporating terraces and a plant enclosure (LPA reference: 17/01608/FUL and 17/00376/TPREF) (PINS reference: APP/X5990/W/17/3187332)’.

1.2 The Marathon House Association was formed by Marathon House leaseholders in 2010, in order to advocate the interests of the building’s leaseholders against the owner of the freehold who had for years mismanaged the building. In November 2011, the leaseholders went on to form the Marathon House RTM Company Ltd., which took over the responsivity to manage the building in April 2012. It is a ‘Right to Manage’ company that represents the interests of the existing leaseholders who own long (979 year) leases on the 106 residential units within the building since its conversion from office to residential use in 1998/9. The objections to the appeal outlined in this report are made collectively on behalf of the leaseholders.

1.3 We note that the appellant has recently suggested the extension could be delivered as two new units rather than a single unit; however this material change has not been subject to consultation and cannot reasonably be introduced at the appeal stage. For the avoidance of doubt our client opposes this amendment and respectfully suggests it should not be accepted by the Inspector.

1.4 This report is structured as follows:

x Section 2: Background to Application;

x Section 3: Existing Opposition to Appeal Proposal;

x Section 4: General Principles of the Objection Against the Appeal;

x Section 5: Response to Appellants Statement of Case; and

x Section 6: Summary and Conclusions.

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2.0 Background

2.1 Marathon House is located on the north side of Marylebone Road, between Balcombe Street and Gloucester Place, as shown at Appendix 1. The building comprises a three level podium arranged around a central courtyard with a 12 storey tower located at its western end. The building contains 106 residential units. All are currently occupied. Photographs of the existing building are included at Appendix 2.

2.2 In February 2017, Proxima GR Properties Ltd, submitted three parallel planning applications to the City of Westminster for various extensions to the building. All were firmly refused. The applicant has decided to appeal one of the three refused applications, for the following development:

‘Erection of sheer rooftop extension on existing tower to provide an additional residential unit, incorporating terraces and a plant enclosure (LPA reference: 17/01608/FUL)’.

2.3 The background to this proposed extension (and the two parallel proposals which were similarly refused by Westminster) is that the owner of the freehold of the building is seeking to establish the notional development value that would be generated if the proposal was granted planning permission as part of the process of the leaseholders’ efforts (via a nominee purchaser, Marathon House Freehold Company Ltd.) to purchase the freehold of the building.

2.4 The application received a number of objections, which are discussed at Section 3 of this report, including from 94 residents within the building’s 106 residential units. The application was recommended for refusal at Committee on the basis it caused ‘design harm to heritage assets and failure to optimise the number of residential units on site’ 1. The application was then subsequently refused at Committee in August 2017 for the following reasons 2: 1 Because of its size, design and location, the extension would harm the appearance of this building and fail to maintain or improve (preserve or enhance) the character and appearance of the Dorset Square Conservation Area, would harm the setting of the Grade 1 listed Church of St Mary on Wyndham Place and the setting of nos. 29-40 Dorset Square, and would fail to maintain or improve (preserve or enhance) the setting of the neighbouring Portman Estate Conservation Area and Regent's Park Conservation Area. This would not meet S25, S26 and S28 of Westminster's City Plan (November 2016) and DES 3, DES 6, DES 9, DES 10, DES 12 and DES 1 and paras 10.108 to 10.128 of our Unitary Development Plan that we adopted in January 2007. (X16AD); and 2 The proposed flat is excessive in size and fails to optimise the number of residential units on site, contrary to policy S14 of the City Plan that we adopted in November 2016.

2.5 In October 2017, the applicant lodged an appeal against the refusal. In March 2018, The Planning Inspectorate reviewed the case file and concluded that a Hearing would be the most appropriate format of appeal in this case; ‘as there were a large number of objections to the original application and there are matters in respect of setting which would benefit testing via questioning’ 3. We support the elevation of the appeal to a Hearing as it provides an opportunity

1 City of Westminster, Sub Committee Report, August 2017, available from: http://idoxpa.westminster.gov.uk/online- applications/files/0F5D3D131285C418B5C8C92C7D76BB09/pdf/17_01608_FULL-SUBCOMMITTEE_REPORT-5047451.pdf [Last accessed: 20/03/2018] 2 City of Westminster, Decision Notice, August 2017, available from: http://idoxpa.westminster.gov.uk/online- applications/files/9B8FB58C8FB4857B8B1BB1FF2B7AC853/pdf/17_01608_FULL-REFUSAL-FULL_PP__PE_-5080734.pdf [Last accessed: 20/03/2018] 3 Letter from The Planning Inspectorate to City of Westminster Council, March 2018, available from: http://idoxpa.westminster.gov.uk/online-applications/files/1D6C847CCF3575A0D347F07202B1EAA4/pdf/17_00376_TPREF- LETTER_TO_WCC_FROM_PINS_REGARDING_CHANGE_IN_APPEAL_PROCEDURE-5361309.pdf [Last accessed: 20/03/2018].

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for the existing leaseholders and residents of the building to engage directly with the Inspector and the appellant.

2.6 Our client supports the City of Westminster’s reasons for refusal and requests the Inspector dismisses the appeal on these grounds and the objections later discussed at Section 4 of this report.

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3.0 Opposition to the Appeal Scheme

3.1 In addition to the objection prepared by Lichfields on behalf of the Marathon House leaseholders, the appeal scheme (LPA reference: 17/01608/FUL) was subject to a number of further objections at the application stage; including: 1 An objection from The St. Marylebone Society; and 2 94 objections from adjoining owners/occupiers and other representations (including residents of neighbouring buildings, heritage organisations and writers of modern architecture) 4.

3.2 The Sub-Committee Report, prepared by the City of Westminster, provides a summary of the key issues raised by the objectors (pages 6-9),which included: The St. Marylebone Society

x Proposals being made by the freeholder against wishes of the leaseholders;

x Increase in height not as little as suggested within application drawings;

x Practical problems relating to construction; making existing flats unliveable;

x No off street parking provided;

x The Council has already considered the current height to be the limit for this building;

x Concerns regarding cladding; piecemeal alteration to fenestration is visually unacceptable;

x An increase in height of Marathon House makes it more likely that further increases in height for other buildings in the area will be sought; and

x Impact on the Dorset Square Conservation Area and Regents Park. Adjoining Owners/Occupiers and Other Representations

x An increase in height would harm the character and appearance of the building (which is an iconic building, an early UK example of ‘International Style’ architecture), its surrounding context, the Dorset Square Conservation Area, the setting of the Old Town Hall and/or views from Regents Park;

x Precedent of the City Council resisting previous height extension plans – In addition the Dorset Square Conservation Area Audit explicitly identifies Marathon House as a building where a roof extension is unlikely to be acceptable;

x Potential amenity impacts on existing properties;

x Issues with construction compromising the health and safety of the existing residents and impacts on the heating/cooling system and lifts;

x Increase in traffic and parking congestion within the surrounding area; and

x Permitting the application would set precedent for future alterations to other important buildings in the area.

3.3 The Inspector will have sight of the extensive objectives received from residents of the building which are contained with Westminster’s Appeal Questionnaire.

4 Source: City of Westminster Sub-Committee Report (08/08/2018): http://idoxpa.westminster.gov.uk/online- applications/files/0F5D3D131285C418B5C8C92C7D76BB09/pdf/17_01608_FULL-SUBCOMMITTEE_REPORT-5047451.pdf (last accessed 20/03/2018).

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3.4 Given that the extensive existing opposition amongst the building’s residents is maintained, we trust the Inspector will afford the objections submitted in respect of the application (LPA reference: 17/01608/FUL) full consideration when assessing the appeal.

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4.0 Residents Objections to the Appeal Scheme

4.1 The general principles on which the Marathon House Association objects to the appeal are based on the following core areas of concern : 1 Harm to the integrity and character of Marathon House ; 2 Harm to the area’s townscape and heritage assets; 3 Parking provision; 4 Access and inability to implement the proposals; and 5 Procedural matters.

4.2 These matters are expanded upon in turn below: Harm to the Integrity and Character of Marathon House

4.3 Marathon House, No. 200 Marylebone Road (formerly Castrol House) was designed by Gollins, Melvin and Ward Architects, in association with Casson, Conder and Partners in the late 1950s. Permission was granted for the redevelopment of the site in 1957, and construction completed and the building opened in 1960. Relevant papers relating to the 1957 permission are contained at Appendix 3. Details of other planning applications for the site, dating from 1949 are included in the Table at Appendix 4.

4.4 The permission for the re-development of the site in the late 1950s was controversial at the time. The original November 1955 scheme for a two-storey podium with a 24 storey tower was extensively revised and altered through a number of submissions before the 1957 scheme was approved. The design ultimately granted planning permission was the result of considerable design evolution and negotiation between the applicant and the City Council to ensure its acceptability in relation to its surrounding context.

4.5 This historical position is an important consideration when appraising the acceptability of alterations and additions to the building today. The proposed alterations will have a direct effect on the integrity, appearance and character of Marathon House itself, which are a function of the building’s historic and architectural significance.

4.6 The form and massing of the building granted consent in 1957 was also considered the maximum massing acceptable, in terms of the acceptability of the building’s impact on its immediate context, surrounding heritage assets, and significant views. The significance and sensitivity of the surrounding assets has since only increased. As such, the scale, height and form of the existing building surely remains the maximum reasonable development envelope at the site.

4.7 Marathon (then Castrol) House was widely recognised in the early 1960s as a pioneering 5 example of International style architecture in London . The Sub-Committee report (page 13) recognises Marathon House as one of the first significant curtain walled office tower on podium structures in Britain. Its role as an early example of this style continues to be recognised, and while the exterior appearance of the original building has altered as a result of the re-cladding undertaken at the time of the conversion of the building to residential use, the massing and form of the building remains intact.

4.8 There is extensive historic literature regarding the origin and architectural significance of Castrol (now Marathon) House and, upon its completion in 1960, the building’s pioneering

5 The Architect and Building News - 09.03.1960; The Architectural Journal - 24.03.1960; and Architectural Design - April 1960.

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architecture was lauded in the architectural press. Articles relating to the building are attached at Appendix 5 . Salient extracts are cited/referenced below.

4.9 The Architect and Building News (09.03.1960) [Appendix 5.1] described the new building as follows:

“This uncompromising design, already a familiar London landmark is the result of a number of years’ experimentation by the architects with curtain wall design…It is significant in that it gives fresh evidence of the possibility of good twentieth century design in this country.”

4.10 The Architectural Journal (24.03.1960) [Appendix 5.2] concurred:

“[Castrol House] can be considered as one of the most elegant and sophisticated prestige buildings to appear in Central London in recent months.”

4.11 Architectural Design (April 1960) [Appendix 5.3] was similarly effusive:

“The fact that the tower block obtrudes itself dramatically upon the skyline is a distinct asset, as viewed along Marylebone Road in both directions.

Castrol House combines the positive features of a fully curtained walled glass tower, and is certainly one of the best representatives of this approach.

[Castrol House is a] distinguished forerunner of a large number of other tall buildings in course of erection or proposed, and one hopes that these too will be ‘outstanding’ in every respect.”

4.12 More recently (though before the building’s conversion/re-cladding) Pevsner (2003) discusses the significance of Marathon House [Appendix 5.4]:

“The earliest London example of the very influential slab-and-podium massing of Lever House, New York. All curtain-walled, the podium with black and white detail, the tower with green spandrel panels, with no visual breaks of any kind, and optically a little disturbing.”

4.13 It is clear that the building was recognised by a number of architectural journals in the early 1960s as a pioneering example of International style architecture in London. Its role as an early example of this style continues to be recognised. In addition Marathon House is believed to be the oldest surviving building of its type (slab and podium), as well as the first ‘skyscraper’ with a fully-glazed wall.

4.14 The proposal seeks to increase the height of the tower and alter its appearance in a manner that was considered to be unacceptable at the time of its original construction, and is no less unacceptable today. This would result in harm to the form, character and intended design and massing of the original building.

4.15 This sits against the context of an increased level of heritage protection in the vicinity including the designation of several statutorily listed buildings, two conservation areas (Dorset Square CA and The Portman Estate CA), and longer views of the site from heritage assets like the Grade I listed Regent’s Park, which is located within the Regent’s Park CA. The harm to the area’s townscape and heritage assets is later discussed within this section of the report.

4.16 The proposal would result in overdevelopment of the site and change the carefully considered form and massing of the building. Adding additional height to the tower has successively been considered harmful by the decision making authorities and heritage bodies since the original proposals for the building. There is clear evidence demonstrating consistent resistance to the

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introduction of any additional height to the building’s tower throughout the building’s history 6. It is not clear why the appellant considers that the building’s integrity and context is now materially different. This disregard for the long established principles that have guided development in this sensitive location only serves to emphasise the lack of appreciation of the context apparent within the proposal.

4.17 As such, our view is that the harm generated by the proposal is not in accordance with Policies 7.4 (Local Character) and 7.6 (Architecture) of the London Plan and draft policies D1 (London’s Form and Characteristics), D2 (Delivering Good Design) and D8 (Tall Buildings) of the Emerging Local Plan. The proposed extension seeks, at best, to imitate the existing architectural treatment of the building. It fails to preserve or enhance the building’s integrity and character and conflicts directly with the requirements of City Plan Strategic Policy S28 – Design and Saved Unitary Development Plan (UDP) Policy DES 1. Harm to the Area’s Townscape and Heritage Assets

4.18 As discussed in the preceding section, the original design of Marathon House was subject to extensive alteration to render it acceptable before the 1957 scheme was granted permission. Notably an initial reduction in height from 24 to 20 storeys, followed by a further reduction in the height of the tower to 16 storeys. Permission was achieved for a 9 storey building in 1956, but the applicant returned with a suite of proposals in 1957, finally securing permission for a three storey podium with a 12 storey slab set above (i.e. 14 storeys in total) in a north-south orientation situated towards the western end of the building 7.

4.19 The other key considerations at the time (with modern heritage designations in brackets), as detailed at Appendix 3 - were considered to be:

x its potentially intrusive effect on the skyline (visible from Grade I listed Regent’s Park and neighbouring conservation areas);

x its effects on views of the late 18th Century terraces to the north (Grade II listed);

x its overshadowing of Dorset Square (within the Dorset Square CA and surrounded by listed buildings); and,

x its dominance of the Town Hall tower (Grade II listed).

4.20 The importance of the latter is noted historically, and the primacy of the former Town Hall in terms of its role as a civic landmark was, and remains an important consideration. In its commentary on the building, the Architect (1960) noted at the time that:

“The height of the tower block was restricted owing to the neighbouring Marylebone Town Hall tower.”

4.21 That the building’s height was dictated by the Town Hall tower was echoed in articles in Light and Lighting (1960) [Appendix 6.1], Interior Design (1960) [Appendix 6.2] and also a monograph of the work of Gollins Melvin and Ward (1974) [Appendix 6.3]. The latter stated:

6 The Architect 1960 – “The height of the tower block was restricted owing to the neighbouring Marylebone Town Hall tower.” Gollins Melvin and Ward (1974) –“The restrictions imposed by the town planning authorities and the ground landlord largely dictated the form of this building inasmuch as they required that the Marylebone Road frontage should be continuous and not less than two storeys high, that no part of the building was to be higher than the tower of the Marylebone Town Hall opposite…The floor to site area [plot ratio] was not to exceed 3.5:1.” 7 London County Council – Town Planning Committee –T.P. 170 Item. 41 – 8 July 1957.

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“The restrictions imposed by the town planning authorities and the ground landlord largely dictated the form of this building inasmuch as they required that the Marylebone Road frontage should be continuous and not less than two storeys high, that no part of the building was to be higher than the tower of the Marylebone Town Hall opposite…The floor to site area [plot ratio] was not to exceed 3.5:1.”

4.22 The datum imposed by the height of the Town Hall remains applicable today in considering any prospective additions to the tower.

4.23 While there were additional amendments and alterations to the building post its 1960 completion through to 1979, these were minor, mostly internal alterations, and none appear of relevance to the current proposals before the City Council.

4.24 The next relevant series of proposals in the site’s planning history relate to those brought forward in the 1990s prior to, and around the time the building was recommended for statutory listing, as detailed at Appendix 7. Consistently the consideration of proposals for the redevelopment or alteration of the site emphasised the sensitivity of the design of any development at the site, the constraints in terms of bulk and massing, and the potential impacts arising on local conservation areas and listed buildings as well as the wider townscape (presumably including longer views) The conversion of the building to residential use and its recladding was first permitted in 1996 (96/06764/FULL), and a further amended application approved in 1997.

4.25 The negotiations during the 1990s re-emphasised the importance of the relationship of the extant form and height of the building with the listed Town Hall. Officers at Westminster confirmed that “[t]he existing building height should be viewed as a not to be exceeded maximum.” Relevant papers relating to the proposed redevelopment opportunities within the 1990s are contained at Appendix 8. Again, there is no reason why the position should have changed, particularly given the increased level of heritage protection in the vicinity in the intervening period. As such, any additional height above that of the Town Hall tower should remain a key reason to resist the current proposals as any incremental and uncoordinated additions to the building would clearly be harmful to the townscape and settings of local heritage assets.

4.26 Most recently Marathon House was included within the Dorset Square Conservation Area when the area was expanded in 2008. The building is located to close to the southern boundary of the Conservation Area as shown at Appendix 9. The importance of the building in the wider context of the development of the area is described within the Dorset Square Audit, as follows:

“Marathon House by Collins, Melvin and Ward (1958-1960), originally home to Castrol, was one of the first UK examples of slab-and-podium massing and was based on Lever House and the UN secretariat tower in New York. The building, while it has little in common with the Georgian core of the Conservation Area to the north, forms an important part of the story of development along Marylebone Road. It is also an important example of a curtain walled slab and podium building, although its appearance has been altered through recladding.”

4.27 As a consequence of this significance, the Dorset Square Conservation Area Audit identifies Marathon House as an unlisted building of merit, confirming that the building contributes positively to the Conservation Area’s character and appearance. Planning authorities are required (under Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990) to pay special attention in exercising their planning functions to the desirability of preserving or enhancing the character and appearance of a conservation area, and on this basis Marathon House should be afforded a higher degree of protection than exists under normal planning control for extensions and alterations.

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4.28 The Dorset Square Conservation Area Audit contains guidance relating to alterations and extensions to buildings within the Conservation Area. It states that alterations to buildings are required to respect their scale, period and integrity, and appropriate materials should be used. Roof profiles are described as being fundamental to the architectural character of buildings. While this could be construed primarily to concern historic terraced properties, the upper termination and roof profile of a prominent tall building such as Marathon House is clearly an important consideration and the building is not only expressly included in the guidance, but the sensitivities as regards any additional height or massing on this building are well understood.

4.29 Importantly, Westminster’s Dorset Square Conservation Area Audit, includes a Roof Extensions Map (Figure 88) Appendix 10, which defines buildings in the Conservation Area where roof extensions may or may not be deemed acceptable. The map clearly identifies the Marathon House tower under “Buildings with a distinctive roof form where roof extensions are unlikely to be considered acceptable.”

4.30 It is clear then from the Council’s Dorset Square Conservation Area Audit that the proposed addition to the building’s tower are directly in conflict with the prescriptive guidance on extensions to the building. If the appeal were to be approved, it would be fundamentally at odds with the Council’s guideline for the building.

4.31 The appeal scheme would result in harm to the form, character and intended design and massing of the building. This adversely impacts on not only the settings of nearby heritage assets, but also on views from highly significant and more distant heritage asset, including sensitive views from the Grade I Listed Regent’s Park (in terms of both proposed forms of addition to the tower). Photographs of the surrounding area are included at Appendix 11.

4.32 Whatever the level of harm the Inspector ultimately attributes to the extension of the existing building under the National Planning Policy Framework (NPPF) , any ‘harm’ arising is a high barrier to justify in terms of the general duty set out under Sections 66 (1) and 72 (1) of the Planning (Listed Buildings and Conservation Areas) Act 1990. The proposal offers no substantive public benefits that would outweigh the harm under Paragraph 134 of the NPPF, nor would they go any way towards an acceptable case under Paragraph 133 of the NPPF.

4.33 The harm generated by the proposal is not in accordance with Policy 7.8 (Heritage Assets and Archaeology) of the London Plan and would not be compliant with the aims and principles of Westminster’s City Plan Strategic Policies S25 – Heritage and S26 – Views, with particular emphasis on the impacts of this proposal as it relates to a tall building. Given the importance of the form of the existing building, its visibility in both local and longer views, it is also clear that the intrusive nature of the proposal fails to meet the tests set out in Saved UDP Policies DES 6, and is also harmful to the character and appearance of the local conservation areas (rendering the proposals non-compliant with DES 9 – Conservation Areas) and the setting of listed buildings (rendering the proposals non-compliant with DES 10 – Listed Buildings). Indeed, Westminster’s Sub-Committee (page 14) report recognises the proposal is not supported by primary legislation or the NPPF and would be contrary to DES6, DES9 and DES10 UDP and policies S25 and S26 of the City Plan. Parking Provision

4.34 The appeal scheme would introduce a new residential unit. There is no scope to service the new residential unit within the existing parking area or within the site, and as such the proposal would, if not secured via a car-free agreement would lead to additional on street pressure for parking via uplift in demand for residents parking permits. While the development is located in a highly sustainable location close to Marylebone, and Baker Street Stations, it is also an area that has a both high demand for parking and suffers from poor air quality (as a result of heavy traffic on Marylebone Road). London Plan Policy 6.1 seeks to encourage cycling and provision of

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minimum levels of cycle parking for new residential units, while Policy 6.13 seeks to ensure that an appropriate balance is achieved between new development and preventing excess car parking provision. The proposals with unrestricted access to on street parking via residents permits would fail to comply with the general aims of these polices and would also fail to satisfy the strategic goal of Westminster City Plan Strategic Policy S41 which seeks to reduce reliance on private cars.

4.35 While we appreciate that the City of Westminster does not usually seek to restrict the provision of access to on-street parking to new residential units, in this instance, as there is not scope to accommodate additional parking on site, and the access of the new units to on street parking would put additional stress on parking for extant occupiers in an area where additional cars are undesirable we would ask that the Inspector dismiss the appeal on this basis or at a minimum impose car-free restrictions on the additional residential unit.

4.36 While not strictly a planning matter, given (as outlined below) that it is suspected that the proposal is in practice about the notional development value it would generate, rather than any true intention to implement them, we would ask that if the Inspector is minded to approve the appeal, that permission is subject to a car-free agreement and appropriate contributions to car club membership etc. via a Section 106 legal agreement so that the value of the units is not artificially elevated by reason of their ability to also apply for on-street residents parking. Inability to Access and Implement the Proposals

4.37 The background to the appeal proposal for the tower extension to Marathon House is that the owner of the freehold of the building is seeking to establish the notional development value that would be generated if the proposal were to be granted planning permission as part of the process of the leaseholders’ efforts (via a nominee purchaser, Marathon House Freehold Company Ltd.) to purchase the freehold of the building. The proposal therefore appears to have been designed to maximise a notional development value if granted planning permission but with little actual regard to how or if the proposals shown could actually be constructed practically if the appeal was granted.

4.38 Given it is suspected there is little, or no, intention on the part of the freeholder to actually implement the proposal as submitted, the degree of accuracy and consistency under which the proposal has been prepared is limited. The proposal contains numerous errors and omissions in terms of the detailed layout of the building, its demise to individual leaseholders of existing residential units, and a clear lack of understanding of the extant operational requirements of the building in terms of servicing and essential mechanical plant required to support the existing (and proposed new) residential units.

4.39 Importantly, we understand that given there is no agreement between the owner of the freehold and the existing residents to vacate the building to allow actual construction works to take place; the existing residents would need to remain in place during all construction works necessary to implement the scheme should the appeal be granted. It is challenging to envisage how in these circumstances the extension of operational lift shafts and stairs, the replacement of operational lift equipment, and the relocation of essential operational roof level plant could be achieved, and the proposed roof level addition constructed while the existing residents remain in situ within the building below. The construction impacts in terms of unacceptable noise, environmental and safety concerns would surely render implementation impractical.

4.40 Where other extant tall buildings (and other multi-occupancy residential buildings generally) are being extended at roof level, the process of extension, and associated works to structure and services typically form part of a wider restoration or enhancement of the building undertaken when the building has been vacated or the former residents decanted. This would not be the case at Marathon House, where the prospect of a negotiated settlement being reached to decant

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residents is unlikely given the entire process for achieving permission is linked to extracting an uplift in development value from those same residents as part of the freehold purchase.

4.41 The accompanying Engineering Report by RHB Partnership LLP M+E Consulting Engineers provides a technical assessment of the potential impacts and issues that would arise for existing residents if the proposals as submitted were implemented. Indeed the report concludes that it is not possible to implement the proposal as shown as this would remove key mechanical plant and services that would render the extant units uninhabitable during construction, and both the extant and proposed units similarly uninhabitable post construction given the submitted drawings for the proposed scheme provide no realistic alternative route for the existing plant removed to be relocated (see RHB Partnership Report at Appendix 12).

4.42 The following key points are raised by RHB Partnership: 1 The application contains no analysis to demonstrate that the existing building services can support the additional residential unit proposed in terms of electrical servicing and load. 2 There is no analysis to demonstrate that the existing communal cooling system can be expanded to accommodate the additional flat without adverse impact on extant ones. 3 Gas boiler services are proposed – the existing building is not serviced by gas, and has no supply. The application does not show how such a supply would be introduced to the existing building to service the new apartments. 4 The application does not demonstrate how the current building control or C02 reduction targets can be met without gas boilers or other alternative means of meeting sustainability and energy targets relevant for new development. 5 The proposals show the tower with three lifts. Only two lifts have been extant since the conversion of the building to residential, the third lift being given over to services and plant to support the extant residential units. No alternative means or location for these services and plant runs is shown in relation to the reinstatement of the third lift in the application. The removal of these services would render the tower apartments uninhabitable, and the new proposed residential unit would similarly be uninhabitable. 6 There is no phasing of works to show how the existing lifts would be extended and remain at least in part operational during the works. 7 The sizes of the plant areas are insufficient to meet the needs of the existing building and are smaller than the existing recently installed replacement services on the tower roof.

4.43 Ultimately, there would be no practical way to implement the proposal as submitted with the existing residents in occupation of the building, even if a solution to overcome the issue of the resulting permanent removal of essential services was to be found. The construction would not ensure the safety of all occupants which is contrary to draft policy D8 of the emerging London Plan. In addition Appellant proposes to extend the existing lift in the tower and install a flight of stairs to access the additional storey; draft policy D3 of the emerging London Plan requires design to incorporate safe and dignified emergency evacuation and in the instance lifts are installed, they should be capable of evacuating people, during a fire, who require level access. The appeal proposal includes no information on how emergency evacuation would be achieved and whether the lift extension would allow for level access evacuation. The appeal should therefore be dismissed as a result. Procedural Matters

4.44 The following procedural matters relating to the appeal are described below:

Pg 12 Marathon House, 200 Marylebone Road, London, NW1 5PW

Screening for Environmental Impact Assessment (EIA)

4.45 There is no indication from the planning application submission whether the application has been screened for EIA. Whilst the proposed application does not cumulatively result in ‘major development’ (i.e., over 10 new units or over an additional 1,000sq.m of new floor space), the proposal does have the potential to cause significant heritage impacts on numerous designated heritage assets.

4.46 These impacts would add to the existing impact of the building, especially the proposed additions to the tower of Marathon House which is visible from Regent’s Park, a Grade I Listed Park on the National Register of Historic Parks and Gardens for its special historic interest. The proposal would also impact on the character and appearance of the Dorset Square Conservation Area (including views within the Conservation Area). The settings of several nearby listed buildings would also be affected by the proposal, in particular the setting of the Grade II listed former Westminster Council House opposite which has always been a significant consideration in discussion and determination of proposals at this site, with particular sensitivity as regards views of and the relationship of Marathon House to the Council House Clock Tower.

4.47 We would urge The Planning Inspectorate to dismiss the appeal as the potential significant impacts resulting to heritage assets particularly the settings of listed buildings, views within and from conservation areas, and the setting of the Grade 1 listed park (and conservation area) Regent’s Park have not been sufficiently assessed.

Matters Arising from the Submitted Application Form Waste Storage and Collection (Application Form – Section 7)

4.48 The application form states that no provision has been made for areas to store or aid the collection of waste, and no arrangements are made for the separate storage and collection of recyclable material. This would render the proposals non-compliant with the Council’s policies and guidance on waste and recycling. While this is an existing building where extant policies for the collection and storage of waste and recyclables already exist, there is no additional explanation as to whether individually or cumulatively the additional servicing demands for waste and recyclables storage can be incorporated into the existing system operating within Marathon House.

Vehicle Parking (Application Form – Section 10)

4.49 The proposals would result in an additional residential unit at the site, however the application form submitted does not address what the proposed vehicle parking provisions are for the new unit, nor does it specify that the additional units would be subject to a car free agreement. Foul Sewage (Application Form – Section 11)

4.50 The applicant states that foul sewage is to be disposed of via the ‘mains sewer’, but in relation to whether the application proposed to connect to the existing drainage system, the answer provided is ‘unknown’. There is no clarity in the application as to whether the extant sewerage infrastructure of the building is of sufficient capacity to allow the construction of the proposed extension – or whether this could be accomplished in terms of the already occupied residential building and its associated demise to individual leaseholders. Numbers of Residential Units (Application Form – Section 17)

4.51 The submitted application form detailed the number of residential units ‘proposed’, but the number of ‘existing’ residential units at the site is left incomplete. This provides an inaccurate picture of the number of occupied units that are present at the site and would be directly affected by the delivery/implementation of the proposal.

Pg 13 Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Industrial or Commercial Processes and Machinery (Application Form – Section 22)

4.52 The application form states that the proposal requires the ‘relocation [of] existing mechanical plant’, but no explanation is provided within the submitted application documentation about how these essential mechanical services to be relocated are to be maintained during the construction process for the existing residents of the building who are under no obligation to move or to provide access to allow the proposed works to be undertaken.

Pg 14 Marathon House, 200 Marylebone Road, London, NW1 5PW

5.0 Response to Appellant’s Statement of Case

5.1 Section 4 of this report, provides a comprehensive overview of our client’s substantive objections to the appeal. We have also reviewed the Appellants Statement of Case; in particular Section 3 ‘Appellant’s Response to Reasons for Refusal’. We set out our client’s response under relevant headings below: Harm to the Appearance of the Building

5.2 The Appellant claims that the features which contribute to defining Marathon House as a ‘building of historic merit’ were ‘irrevocably changed during its transition to a residential building when the original cladding material was removed’ (paragraph 3.1). We disagree with this position. The clarity of the original architectural form of the building is still very much readily apparent, notwithstanding its recladding. This view which is also noted within the Sub Committee Report (page 13), prepared by City of Westminster Officers.

5.3 Marathon House is still recognised, today, as one of the first significant curtain walled office tower on podium structures in Britain, the proposed increase in height would break from the existing original form of the building and create an unacceptable proportionate relationship between the podium and the tower. The Council has been clear since the original permission was granted in the 1950s that the current form of the tower was the maximum acceptable massing and height in this sensitive context. The additional height proposed would be disruptive and is unacceptable in this regard.

5.4 Our client firmly disagrees with the appellant that the proposed extension to the roof proposes a sensitive upgrade to the building. Instead, we concur with the views of the City of Westminster’s Officers as noted within the Sub Committee report (page 14) that the proposals are contrary to DES 1, DES 3, DES 6, DES 9, DES 10 and DES 12 of the UDP and policies S25, S26 and S28 of the City Plan.

5.5 The Appellant claims that the existing facades of Marathon House are of poor quality and proposes to replace some existing windows and cladding on the existing top floor in addition to cladding the proposed extension with a similar material to the existing. However the proposal to only replace some existing windows on the top floor will result in a discordant elevation on the four sides of the building. For example; as noted within The St.Marylebone Society’s original objection to the proposals; there will be a visual difference between new and existing panels and glazing bars. As such our client believes that the piecemeal approach adopted within the proposal to fenestration is visually unacceptable and will have detrimental harm to the appearance of the building.

5.6 In addition, our client supports the view as noted within the Sub-Committee report that finding an exact match for the existing cladding materials would be likely to prove difficult. This reinforces the concerns in regards to visual differences between the proposed extension, the amendments to the cladding of the floor below and the existing cladding which will be retained. Proposed Amendments

5.7 We note from paragraph 3.4 of the Appellant’s statement that amendments to the scheme are proposed to address the reasons for refusal, including: 1 Roofing over the open courtyard; and 2 Sub-dividing the new floorplate to create two residential units rather than one.

5.8 The proposed amendments to the scheme materially alter the nature of the application and are contrary to the guidance in Annexe M of The Planning Inspectorate’s, Procedural Guide,

Pg 15 Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Planning Appeals – England (January, 2018). On this basis, the Inspector should dismisses the offer of securing such amendments via planning conditions. In addition, draft policy D2 of the Emerging Local Plan states that the design quality of a development should not be the consideration of planning conditions.

5.9 Although the proposed roofing over of the open courtyard would better reflect the original form of the building i.e. a solid an unbroken roof line, it does not elevate the concerns regarding the impact of the additional storey upon the existing architectural character, relationship between the podium and tower and impact upon views from the surrounding area.

5.10 The proposal to sub-divide the floor to create two residential units increases our clients concern in relation to; parking provision, access and the inability to implement the proposals, as previously discussed at Section 4 of this report. In addition, the provision of two flats is minimal in the context of the Council’s annual housing target of 1068 units; and as such should not be considered to offer substantive benefits and outweigh the substantial harm to the architectural form of the building. Failure to Maintain or Improve (Preserve or Enhance) the Character and Appearance of the Dorset Square Conservation Area and the Setting of Nos. 29-40 Dorset Square

5.11 Our client strongly disagrees with the Appellant’s observation that an additional storey will accrue only a minimal visual impact on the setting of numbers 29-40 Dorset Square. As outlined in the Sub Committee Report (page 13), the tower of Marathon House is already prominent in views from Dorset Square above the roofline. The visual impression it gives both in terms of the character and outlook from the square and in terms of the setting of the buildings on the south side of the square (nos. 29-40) is already harmful. The addition of a further storey would accentuate the harm, giving rise to a more prominent and intrusive feature and ultimately the setting and character of the Dorset Square Conservation Area.

5.12 The Dorset Square Conservation Area Audit includes a Roof Extensions Map (Figure 88) which defines buildings in the Conservation Area where roof extensions may or may not be deemed acceptable. The map clearly identifies the Marathon House tower and the western section of its podium as “Buildings with a distinctive roof form where roof extensions are unlikely to be considered acceptable.” As such the proposed extension to the tower is directly in conflict with the prescriptive guidance on extensions to the building; if the appeal was approved, this would be fundamentally at odds with the Council’s guidelines for this building. This key concern has not been adequately addressed in the Appellants evidence.

5.13 As outlined above, whatever the level of harm the Inspector ultimately attributes to the extension of the existing building under the National Planning Policy Framework (NPPF) 8, any ‘harm’ arising is a high barrier to justify in terms of the general duty set out under Sections 66 (1) and 72 (1) of the Planning (Listed Buildings and Conservation Areas) Act 1990. The proposal offers no substantive public benefits that would outweigh the harm under Paragraph 134 of the NPPF, nor would they go any way towards an acceptable case under Paragraph 133 of the NPPF; and therefore we ask this appeal be dismissed.

8 Either ‘substantial harm – NPPF - Para. 133’ or ‘less than substantial harm – NPPF – Para. 134’.

Pg 16 Marathon House, 200 Marylebone Road, London, NW1 5PW

Failure to Maintain or Improve the Setting of the neighbouring Portman Estate Conservation Area and Regent’s Park Conservation Area

5.14 We note the Appellant’s argument that the proposed development will form an enhancement to the setting of the neighbouring Portman Estate CA and Regent’s Park Conservation Area through the removal of window cleaning equipment on the roof. However, our client disagrees with this, as the window cleaning equipment is proposed to be replaced by an additional storey of accommodation; which would increase the already existing prominence of the building within the setting of the CAs. The additional height of the building would have an adverse impact on the setting of the Portman Estate CA and Regent’s Park CA and would harm the setting of heritage assets and a number of existing key views; principally from the Grade I Listed Regent’s Park. Excessive Size of the Proposed Flat

5.15 We note the Appellant’s proposals to reconfigure the residential unit into two residential units to address reason for refusal 2. However we respectfully suggest that the Inspector should not consider the amended proposal to create two residential units in accordance with the guidance at Annexe M of The Planning Inspectorate’s, Procedural Guide, Planning Appeals – England (January, 2018). The guidance states the proposed change materially alters the nature of the application and the views of interested people/parties, such as our client, have not been effectively sought.

5.16 The provision of either one or two units would make only a minor contribution to the Council’s housing need. This contribution does not outweigh the harm the proposals would cause on the existing building, the Dorset Square CA, the Portman Estate CA, Regent’s Park CA and numerous heritage assets and therefore we respectfully suggest that the Inspector should afford very limited weight to the developments minimal contribution towards local housing provision.

Pg 17 Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

6.0 Overall Conclusions

6.1 For the detailed reasons set out within this report, we consider that the appeal (reference: APP/X5990/W/17/3187332) currently before The Planning Inspectorate for the extension to Marathon House Marylebone Road should be dismissed because of its unacceptable impacts in planning and heritage terms.

6.2 The Council has been clear since the original permission for the building was granted in the 1950s that the current form at both tower and podium level was the maximum acceptable massing and height in the sensitive development and heritage context of the site.

6.3 This position was firmly reiterated in the 1990s during proposals to not only replace the building (subsequently abandoned), but also to convert the building to residential use which also resulted in the building being re-clad to its current appearance.

6.4 This position remains apposite today particularly given that the building is now recognised to make a positive contribution to the Dorset Square Conservation Area and is explicitly identified by the Council as being unsuitable for roof extensions in its Conservation Area Audit.

6.5 The proposal to extend the tower by a storey would have adverse effects on the integrity and original composition of the building and would harm the local townscape, settings of heritage assets in the immediate vicinity and longer views from a range of designated heritage assets within Regent’s Park, and from the Grade I listed park itself.

6.6 For these reasons, we are firmly of the view that the proposal is contrary to the NPPF and relevant development plan policy, notably City Plan Policies S25 Heritage, S26 Views and S28 Design, and Policies DES1, DES3 particularly parts (A) (2) and (3), DES6, DES9 particularly parts (B) and (F), and DES10 particularly part (D). As such we respectfully encourage the Inspector to dismiss the appeal.

Pg 18 Marathon House, 200 Marylebone Road, London, NW1 5PW

Appendix 1: Site Location Plan

Pg 19 Appendix 1: Site Location Plan/Aerial Photos

Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Appendix 2: Photos of Existing Building

Pg 20 Balcombe Street Page 1 Page Photos of Existing Buildings Dorset Square Page 2 Page Photos of Existing Buildings Gloucester Place Page 3 Page Photos of Existing Buildings Gloucester Place Page 4 Page Photos of Existing Buildings Ivor Place Page 5 Page Photos of Existing Buildings Marathon House Page 6 Page Photos of Existing Buildings Marylebone Road Page 7 Page Photos of Existing Buildings Marylebone Road Page 8 Page Photos of Existing Buildings Marylebone Road Page 9 Page Photos of Existing Buildings DĂƌǇůĞďŽŶĞ^ƚĂƟŽŶ Page 10 Page Photos of Existing Buildings Melcombe Street Page 11 Page Photos of Existing Buildings Montagu Square Page 12 Page Photos of Existing Buildings Regents Park Regents Page 13 Page Photos of Existing Buildings Regents Park Regents Page 14 Page Photos of Existing Buildings Regents Park Regents Page 15 Page Photos of Existing Buildings Regents Park Regents Page 16 Page Photos of Existing Buildings Regents Park Regents Page 17 Page Photos of Existing Buildings Regents Park Regents Page 18 Page Photos of Existing Buildings Regents Park Bridge Page 19 Page Photos of Existing Buildings Thornton Place Page 20 Page Photos of Existing Buildings York Street Page 21 Page Photos of Existing Buildings Marathon House, 200 Marylebone Road, London, NW1 5PW

Appendix 3: 1957 Permission – Erection of part 15 storey, part 3 storey building with offices or showrooms on the ground floor and offices on floors above

Pg 21

Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Appendix 4: Planning History Table

Pg 22 Appendix – Site Planning History

Date of Outcome Description Decision 27.11.1998 Approve Details of podium elevations, location of artwork and canopy entrance, pursuant to condition 2 of planning permission dated 20.12.96 09.11.1998 Approve Erection of conservatory on second floor roof terrace of Flat 59 16.07.1998 Approve Details of public art to podium elevation pursuant to condition 8 for permission dated 20.12.96 12.09.1997 Approve Additional flat at first floor level, being an alteration to a scheme in course of implementation pursuant to planning permission granted 20.12.1996 for use of building as 106 flats 16.05.1997 Approve Details of statement/methodology for salvage and reuse of existing artwork, relating to planning permission dated 20.12.96 13.05.1997 Approve Details of facing materials pursuant to condition 7 for permission dated 20.12.96 29.04.1997 Approve Details, sections and profiles of curtain walling, relating to planning permission dated 20.12.96 20.12.1996 Approve External alterations, including new cladding, and change of use from offices to residential, including 106 flats with basement car parking 02.12.1996 Approve Replacement of curtain walling 06.10.1994 Refuse 7 storey building to provide office space (two different options applied for) (amended 23.05.1995) Associated appeal withdrawn on 27.11.1996 03.12.1979 Approve Erection of extract duct between inner courtyard and second floor level 10.10.1973 Approve Erection of new plant room with ventilating extract system 27.07.1973 Approve Erection of radio mast on roof of Leyland house 10.08.1960 Approve Erection of a viewing tower on roof 30.07.1958 Approve Formation of transformer chamber in sub-basement 29.04.1957 Approve Erection of part 15 storey, part 3 storey building with offices or showrooms on the ground floor and offices on floors above 29.05.1956 Approve Office building with offices/showrooms on ground floor (basement, ground and 8 floors over) 21.02.1956 Refuse Office building comprising two basement, ground, mezzanine and first floors with a tower block on the west side of the site 28.05.1954 Approve Erection if 7 storey office building 22.06.1949 Approve Erection of a 6 storey block of offices with basement and sub-basement at No. 176-204 Marylebone Road Marathon House, 200 Marylebone Road, London, NW1 5PW

Appendix 5: Journals relating to Architectural Significance of Marathon House

Pg 23 .1: Architect and Building News (09.03.1960)

.2: The Architectural Journal (03.1960)

.3: Architectural Design (04.1960)

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Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Appendix 6: Journals Relating to the Height of Marathon House

Pg 24 : Light and Lighting (03.1960)

: Interior Design (05-06.1960)

: Gollins Melvin Ward Partnership, 1974, Architecture of Gollins Melvin, First Edition, Land Humphries Publishers Limited, London

Marathon House, 200 Marylebone Road, London, NW1 5PW

Appendix 7: Recommendation for Statutory Listing

Pg 25

Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Appendix 8: Proposed Redevelopment Opportunities – Pre-Application Advice

Pg 26

Marathon House, 200 Marylebone Road, London, NW1 5PW

Appendix 9: Location of Marathon House within the Dorset Square Conservation Area

Pg 27 Appendix : Location of Marathon House within the Dorset Square Conservation Area Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Appendix 10: Roof Extensions Map

Pg 28 Appendix : Roof Extensions Map Marathon House, 200 Marylebone Road, London, NW1 5PW

Appendix 11: Photographs of Surrounding Area

Pg 29 ŽƌƐĞƚŚŽƵƐĞŇĂƚƐͲůŽĐĂƚĞĚĞĂƐƚ͕ŽŶƚŚĞŽƉƉŽƐŝƚĞƐŝĚĞŽĨ'ůŽƵĐ ĞƐƚĞƌWůĂĐĞ Page 1 Page Photos of Surrounding Buildings sŝĞǁƐŽƵƚŚĞĂƐƚĨƌŽŵƐŝƚĞ Page 2 Page Photos of Surrounding Buildings sŝĞǁŽĨKůĚDĂƌǇůĞďŽŶĞdŽǁŶ,Ăůů Page 3 Page Photos of Surrounding Buildings sŝĞǁůŽŽŬŝŶŐĞĂƐƚĨƌŽŵƌŽŽĨŽĨĞǆŝƐƟŶŐďƵŝůĚŝŶŐ Page 4 Page Photos of Surrounding Buildings sŝĞǁůŽŽŬŝŶŐƐŽƵƚŚĞĂƐƚĨƌŽŵƐŝƚĞ Page 5 Page Photos of Surrounding Buildings ZĞĂƌŽĨďƵŝůĚŝŶŐƐŽŶŽƌƐĞƚ^ƋƵĂƌĞ;ůŽĐĂƚĞĚŶŽƌƚŚŽĨƐŝƚĞͿ Page 6 Page Photos of Surrounding Buildings ƵŝůĚŝŶŐǁĞƐƚŽĨƐŝƚĞ;ŽŶŽƚŚĞƌƐŝĚĞŽĨĂůĐŽŵďĞ^ƚƌĞĞƚͿ Page 7 Page Photos of Surrounding Buildings sŝĞǁŽĨďƵŝůĚŝŶŐĨƌŽŵĐŽƌŶĞƌŽĨĂůĐŽŵďĞ^ƚƌĞĞƚͬŽƌƐĞƚ^ƋƵĂƌĞ; ůŽŽŬŝŶŐƐŽƵƚŚĞĂƐƚͿ Page 8 Page Photos of Surrounding Buildings ƵŝůĚŝŶŐƐŽŶĂůĐŽŵďĞ^ƚƌĞĞƚ Page 9 Page Photos of Surrounding Buildings Marathon House, 200 Marylebone Road, London, NW1 5PW : Objection to Appeal PINS Ref: APP/X5990/W/17/3187332

Appendix 12: RHB Partnership Report – Dated 28 March 2017

Pg 30