planning report PDU/2671/01 8 September 2010 Tote House, Upper Richmond Road in the London Borough of planning application no. 2010/2916

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal Erection of a part four, part eight and part eleven-storey hotel containing 140 bedrooms, associated restaurant and bar, car parking and off-street servicing.

The applicant The applicant is Wicklow Enterprise Limited, and the architect is David Millar Architects.

Strategic issues The principle of providing a hotel in this town centre location is supported and in the interest of good strategic planning in London. However, further information and discussion on urban design, access, climate change and transport are needed to ensure the proposal complies with London Plan policy.

Recommendation

That Wandsworth Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 57 of this report; but that the possible remedies set out in paragraph 59 of this report could address these deficiencies.

Context

1 On 29 July 2010 the Mayor of London received documents from Wandsworth Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 8 September 2010 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 1C of the Schedule to the Order 2008: ”Development which comprises or includes the erection of a building more than 30 metres high and is outside of the City of London”.

page 1 3 Once Wandsworth Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

5 The site is located towards the edge of town centre on the northern side of the Upper Richmond Road, at the junction with Woodlands Way and Oakhill Road to the east of Putney High Street and East Putney tube station. The site is bounded by Wandsworth County Court to the west, offices to the north and residential uses to the east and south.

6 The site has a public transport accessibility level of 6a, on a scale where 1 is low and 6 is high, reflecting the fact that it is well served by a wide variety of public transport modes. The nearest station to the site is East Putney station which is approximately 115 metres from the site. A total of twelve bus routes can be accessed from a range of bus stops within 640 metres of the site. Rail services are provided from Putney Station which is located approximately 600 metres to the west of the site.

Details of the proposal

7 Erection of a part four, part eight and part eleven-storey hotel containing 140 bedrooms, associated restaurant and bar, car parking and off-street servicing. Case history

8 No relevant planning history. Strategic planning issues and relevant policies and guidance

9 The relevant issues and corresponding policies are as follows:

 Principle of development London Plan; PPS1  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Climate change London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport London Plan; the Mayor’s Transport Strategy; PPG13

10 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Wandsworth Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

11 The draft replacement London Plan, published in October 2009 for consultation, and the Wandsworth Core Strategy, due to be adopted in October 2010, are also material considerations.

page 2 Principle of development

12 Policy 3D.1 of the London Plan seeks to strengthen the wider role of town centres by supporting retail, leisure and other associated town centre uses. Policy 5E.1 of the London Plan sets the strategic priorities for south-west London; it seeks to encourage sensitive restructuring of some town centres to reflect changes in the office market and the need for a range of economic activities. Paragraph 5.134 states that Putney “can gain from significant growth in retail demand and put in place environmental improvements, increases in housing and a wider range of activities”.

13 Policy 2.15 of the draft replacement London Plan also seeks to support and enhance the competitiveness, quality and diversity of town centre retail, leisure and other consumer services.

14 Policy 3D.7 of the London Plan and policy 4.5 of the draft replacement London Plan seeks to improve the quality, variety and distribution of visitor accommodation and facilities in London. Beyond the Central Activities Zone, new visitor facilities should be provided in town centres with good public transport access to London.

15 The proposal will result in a loss of employment floorspace; however, the site is not designated as strategic industrial land. As such it is not protected by policies within the London Plan. Provided Wandsworth Council is satisfied the land is not required to meet local employment needs, the principle of a hotel development in this town centre close to the East Putney tube station and direct links to central London is supported. Tall buildings / views

16 London Plan policies 4B.8 and 4B.9, which relate to the specific design issues associated with tall and large-scale buildings, are of particular relevance to the proposed scheme. These policies set out specific additional design requirements for tall and large-scale buildings, which are defined as buildings that are significantly taller than their surroundings and/or have a significant impact on the skyline and are larger than the threshold sizes set for the referral of planning applications to the Mayor. Policy 7.7 of the draft replacement London Plan states that tall buildings should be part of a strategic approach to changing or developing an area, and should not have an unacceptably harmful impact on their surroundings.

17 The building will not impact on any strategic views as defined within the London View Management Framework. The nearest protected corridor, from Richmond Park to St Paul’s Cathedral, passes a significant distance to the west, and the site is significantly removed from defined river prospects, so as to not affect these views.

18 The height of the building is likely to have local impacts, and these are explored in more detail within the next section. Urban design

19 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the Blue Ribbon Network. The draft replacement London Plan reinforces these principles, with new development

page 3 required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (policy 7.1).

20 The building is a tall building of eleven storeys, on a site defined within Wandsworth Council’s emerging site allocations development plan document as being capable of accommodating a tall building, subject to detailed design considerations. The proximity of conservation areas to the east and south is an important consideration.

21 The approach to the external elevation, with the use of corrugated aluminium and brick could be very striking and give the building a distinctive presence on the high street. Often with hotel developments, the design tends towards the bland, and the applicant’s willingness to explore something more distinctive is welcomed and would add positively to the very mixed and variable character of the town centre.

22 The overall massing has two main elements: an eleven-storey semi-circular tower facing orientated onto Upper Richmond Road, and a smaller four-storey building projecting to the rear of the site. It is recognised that there is good reason for having a taller element on the corner as it helps to articulate and define the corner site, and in principle this approach is important in this location. The older Edwardian mansion building on the adjacent corner uses a similar approach, with its turret defining the corner. At eleven storeys, the scheme is one storey higher than the nearest tall building, to the southwest (the SWISH building). There are concerns that the submitted visualisations may be underestimating the height of the building in relation to its neighbours and this is something that we would like to discuss further with the applicant, to ensure that the scale and relationship between this and surrounding older properties within the conservation area is appropriate and that their character and appearance is preserved. Impacts on conservation area views need to be balanced against the town centre/urban context, and as identified by Wandsworth Council in its core strategy, a building in this location does not necessarily have to match that of its neighbours.

23 Both the relationship to the neighbouring residential block on the corner of Oakhill Road and the definition of the proposed tower element would be improved if the four-storey stepped element were removed from the back of the tower. The applicant should also consider the north elevation of the tower, which although clearly visible in views from the north, has virtually no articulation at all.

24 Although the form of the building addresses the corner location and there will be visual interaction between the ground floor restaurant use and the street, the main entrance to the hotel and restaurant faces a secondary street. Visitors approaching from the underground station or town centre would need to walk around the frontage to find the main entrance, and this will not appear immediately obvious. The ground floor layout should be revisited to provide a more appropriate ‘public’ entrance to the building. Access

25 Policy 4B.5 of the London Plan and 7.2 of the draft replacement London Plan expects all future development to meet the highest standard of accessibility and inclusion. This, together with the London Plan’s supplementary planning guidance ‘Accessible London: achieving an inclusive environment’, underpins the principles of inclusive design and the aim to achieve an accessible and inclusive environment consistently across London.

26 Policy 3D.7 of the London Plan seeks to increase the quantity and quality of wheelchair accessible accommodation in London. Policy 4.5 of the draft replacement London Plan relates to the provision of visitor accommodation and facilities and it supports an increase in the quality and

page 4 quantity of fully wheelchair accessible accommodation. The draft policy asks for at least 10% of new hotel bedrooms to be wheelchair accessible and for applicants to submit an Accessibility Management Plan which sets out how the continuing management of the hotel will ensure the accessible rooms are maintained and managed, helping inclusive access to become part of the overall operation and business of the hotel (in a similar way that travel plans can ensure a commitment to sustainable travel patterns after occupation). A research study undertaken by Grant Thornton on behalf of the GLA and the LDA has looked at how inclusive design principles can be applied to London's hotel accommodation and has assessed that less than 2% of existing stock is accessible to disabled people which makes it difficult for disabled people to find an accessible hotel, particularly when linked to other access barriers such as location near accessible public transport facilities or the availability of blue badge parking provision. This is particularly pertinent given the likely number of disabled visitors to London in 2012 for the Olympic and Paralympic Games.

27 The design and access statement states that the proposal will provide 5% of the rooms as wheelchair accessible, this is disappointing. Given the stacked formation of the bedrooms, GLA officers consider that the proposal is capable of providing more that 5% wheelchair accessible rooms. However, no explanation or justification has been submitted by the applicant to support the proposed offer. The applicant should investigate increasing the proposed offer of wheelchair accessible units to at least 10%. Details of the new floor plans should be submitted along with the above mentioned accessibility management plan before the application is referred back to the Mayor. Climate change mitigation

28 The climate change policies as set out in chapter 4A of the London Plan and chapter 5 of the draft replacement London Plan collectively require developments to make the fullest contribution to the mitigation and adaptation to climate change and to minimise carbon dioxide emissions (policy 4A.1).

Baseline carbon dioxide emissions

29 Combined regulated and unregulated carbon dioxide emissions of the proposed development, based on a 2006 Building Regulations compliant development, have been estimated to be 209 tonnes of carbon dioxide per annum.

30 The applicant should provide a breakdown of the total regulated and unregulated emissions for the baseline and each tier of the energy hierarchy.

Be lean

31 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum requirements set by building regulations. Other features include low energy light fittings, heat recovery ventilation systems and A rated appliances.

32 On a whole energy basis, the development is estimated to emit 174 tonnes of carbon dioxide emissions per annum after the application of passive design and energy efficiency measures. A reduction in carbon dioxide emissions of 17% compared to a 2006 Building Regulations compliant building will be achieved through this first element of the energy hierarchy.

33 Based on best practice, a reduction in regulated carbon dioxide emissions of 20% compared to the target emissions rate of a 2006 Building Regulations compliant building can be achieved

page 5 through this first element of the energy hierarchy. The applicant should investigate scope for any additional savings.

34 The applicant should also provide a table of the proposed building parameters e.g. air permeability, U-values, etc, against the values used for the 2010 Building Regulations Notional Building.

Be clean

35 The applicant should investigate whether there are existing or proposed heat networks within the vicinity of the development. If there are no existing networks or if timescales with the development are incompatible with connecting to planned networks then the applicant should commit to ensuring the development is equipped with the provision for future connection to a district-heating scheme, should one be installed locally.

36 The applicant should confirm that the space heating for the hotel bedrooms will be provided in a way which is compatible with connection to a district-heating network. For the avoidance of doubt, electrical heating is not compatible with such a connection and should not be adopted.

37 A 30kWe unit is proposed for the development sized to meet the domestic hot water requirements. Thermal load profiles have been provided. The size of the combined heat and power should be optimised to provide both domestic hot water and a proportion of the space heating.

38 The development is estimated to emit 149 tonnes of carbon dioxide emissions per annum after the application of combined heat and power. A further reduction in carbon dioxide emissions of 14% will be achieved through this second part of the energy hierarchy.

39 The applicant states that a small amount of cooling is included for the café area which will be provided by air source heat pumps.

40 Details on how the air source heat pump will work alongside the CHP should also be provided. The applicant should also provide further details of the cooling strategy which sets out measures that aim to minimise the need for active cooling systems.

Be green

41 The proposal includes 40 sq.m. of solar thermal panels providing 18,160kWh of heat per annum. If this technology were pursued, a reduction in carbon dioxide emissions of 3% would be achieved through this third element of the energy hierarchy.

42 Solar thermal is not compatible with combine heat and power as both are heat-generating technologies and would compete for the base loads. The applicant should re-consider allocating the 40 sq.m. of roof space identified to photovoltaic panels. Further details of the potential for photovoltaic panels should be provided. The applicant should provide drawings showing the amount of roof area available that could be used to install photovoltaic modules. An estimate of the electricity that would be generated and the resulting carbon saving should also be provided.

Overall acceptability

43 The estimated carbon emissions of the development are 145 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account. This equates to a reduction of 31% compared to a 2006 Building

page 6 Regulations compliant building. However, further clarifications detailed above are required before the scheme can be said to comply with strategic planning policy.

Climate change adaptation

44 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water. These policies have also been carried over into the draft replacement London Plan.

45 The design and access statement states the proposal will provide living roofs on all three of the tiered roofs. This provision is welcomed and should be secured by condition. Along with the provision of water metering and low flow appliances.

Comments from

46 The proposal includes no coach or taxi parking on site. Further information on coach trip generation is required to determine the impact of potential coach trips on the Transport for London road network and if a dedicated coach parking space is justified. If a need for dedicated facilities is identified then the applicant should demonstrate where/how this can be provided.

47 TfL considers that the nearby bus stop (number 8867) should be upgraded and requests a contribution of £5,000 towards this. This will ensure consistency with London Plan Policy 3C.20 ‘Improving conditions for buses and draft replacement London Plan policy 6.7 Buses, bus transits and trams’.

48 TfL welcomes the car free nature of the development and the provision of six blue badge holder’s parking spaces. On-site car parking should be provided with electric vehicle charging points in line with emerging best practice and draft replacement London Plan policy 6.13 Parking. TfL expects a minimum of one space to be equipped with a charging point; this should be secured by planning condition.

49 A total of six cycle parking spaces are provided for staff; TfL expects the applicant to provide additional at-grade cycle parking near to the main entrance to cater for short stay visitors to the site. These must be safe, covered and secure with good lighting and CCTV. Showering and changing facilities need to be provided for all employees on site to ensure general conformity with London Plan policy 3C.22 Improving conditions for cycling and draft replacement London Plan policy 6.9 Cycling.

50 The travel plan has narrowly failed the ATTrBuTE assessment; therefore there are a number of small changes that need to be made before the travel plan can be deemed acceptable. The travel plan assessment has been forwarded to the applicant. The travel plan must be secured, enforced, monitored, reviewed and funded through the Section 106 agreement.

51 Both a construction logistics plan and a delivery and servicing plan need to be submitted. If the requested trip generation does not justify a dedicated coach parking facility it is expected that the delivery service plan will identify areas/locations within the vicinity of the site where occasional coach drop off/pick-up could occur. It is important that these areas do not conflict with the operation of the Transport for London road network.

page 7 52 Both the construction logistic plan and delivery servicing plan should be secured by planning conditions. This will ensure general conformity with London Plan policies 3C.17 Tackling congestion and reducing traffic and 3C.25 Freight strategy and draft replacement London Plan policy 6.14 Freight. Local planning authority’s position

53 The application is likely to be considered by Wandsworth Council’s planning committee in September 2010. Legal considerations

54 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

55 There are no financial considerations at this stage. Conclusion

57 London Plan policies on the principle of development, tall buildings/views, urban design, access, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Principle of development: The existing office development is not protected by strategic policy. Subject to the Council’s confirmation that the site is not needed to meet local employment needs the provision of a hotel is supported in this location. As such the proposal complies with policies 3D.1, 5E.1and 3D.7 of the London Plan.  Views/tall buildings: The building will not impact on any strategic views as defined within the London View Management Framework. As such it complies with policies 4B.8 and 4B.9 of the London Plan.  Urban design: The standard of design is not of sufficient quality to comply with London Plan policy 4B.1. The applicant needs to address a number of design issues and provide clarification about the views of the building.

 Access: The applicant has not justified the proposed offer of wheelchair accessible bedrooms. An accessibility management plan has not been submitted or secured by condition. As such it is not possible to ascertain whether the proposal complies fully with policies 4B.5 and 3D.7 of the London Plan.

 Climate change mitigation: Further technical information is required to assess the proposal against the energy policies contained in chapter 4A of the London Plan.

page 8  Climate change adaptation: The proposal includes three living roofs to increase biodiversity and water attenuation. As such the proposal complies with policy 4.9, 4A.11 and 4A.14 of the London Plan.

 Transport: Further technical information is required to assess the proposal against the Mayor’s transport policies. A section 106 contribution to improve the local bus stop needs to be agreed, along with conditions to secure electrical vehicle charging points, a delivery service plan and a construction and logistic plan.

58 Whilst the application is broadly acceptable in strategic planning terms. On balance, the application does not comply with the London Plan.

59 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Urban design: The rear of the tower and northern facade and visitor entrance should be redesigned as set out in the above report. Conservation area views should be balanced against the town centre/urban context and the applicant should provide further clarity regarding the indicative perspective views provided with the application.  Access: The applicant should increase the number of wheelchair accessible rooms to 10% and submit an accessibility management plan before the application is referred back to the Mayor.  Climate change mitigation: The additional information identified in this report should be submitted before the application is referred back to the Mayor.

 Climate change adaptation: The proposed green roofs should be secured by condition along with the provision of water metering and low flow appliances.

 Transport: A Section 106 contribution of £5,000 is requested in order to improve the accessibility of the nearby 8867 bus stop. Further information on the number of coaches expected is required. A construction and logistics plan, delivery servicing plan and a minimum of one electrical vehicle charging points is required and should be secured by planning condition. Visitor bicycle parking and showering and changing facilities need to be provided for all employees on site. The travel plan requires a number of improvements in order for it to be deemed acceptable.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Kim Hoffman, Case Officer 020 7983 6589 email [email protected]

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