Malcolm House - PDU Case Report XXXXYY_date_

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					                                                           planning report PDU/2273/02
                                                                           17 December 2008

                                                                   Malcolm House
                                              in the London Borough of Brent Council
                                                        planning application no. 08/2633


Strategic planning application stage II 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
This is a detailed planning application for the comprehensive redevelopment of this site to
provide a hotel with 262 bedrooms in a part 7, part 11-storey building.

The applicant
The applicant is Summit Hotels Ltd, and the architect is Ica Architects.

Strategic issues
The principle of providing a hotel on this location within the Wembley Opportunity Area is
acceptable in strategic planning policy terms. The Mayor previously raised concerns with
regards energy, climate change building adaptation, transport and employment relocation and
training. These strategic planning issues have now been satisfactorily been resolved.

Recommendation
That Brent Council be advised that the Mayor is content for it to determine the case itself,
subject to any action that the Secretary of State may take, and does not therefore wish to
direct refusal or direct that he is to be the local planning authority.

Context
1       On 29 September 2008 the Mayor of London received documents from Brent Council
notifying him of a planning application of potential strategic importance to develop the above
site for the above uses. This was referred to the Mayor under Category 1C(c) of the Schedule
to the Order 2008: “Development which comprises or includes the erection of a building that is more
than 30 metres high and outside the City of London”.

2       On 30 October 2008 the Mayor considered planning report PDU/2273/01, and
subsequently advised Brent Council that the application did not comply with the London
Plan, for the reasons set out in paragraph 60 of the above-mentioned report; but that the
possible remedies set out in paragraph 62 of that report could address these deficiencies.



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3       A copy of the above-mentioned report is attached. The essentials of the case with
regard to the proposal, the site, case history, strategic planning issues and relevant policies and
guidance are as set out therein, unless otherwise stated in this report. Since then, the
application has been revised in response to the Mayor’s concerns (see below). On 9 December
2008 Brent Council agreed a dual recommendation resolving to grant permission but giving
delegated authority to officers to refuse permission if the Section 106 agreement is not signed,
and on 12 December 2008 the Council advised the Mayor of this decision. Under the
provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the
Mayor may allow the draft decision to proceed unchanged, direct Brent Council under Article 6
to refuse the application or issue a direction to Brent Council under Article 7 that he is to act as
the Local Planning Authority for the purposes of determining the application. The Mayor has
until 25 December 2008 to notify the Council of his decision and to issue any direction.

4     The decision on this case, and the reasons will be made available on the GLA’s website
www.london.gov.uk.

Update
5       At the consultation stage Brent Council was advised that the application did not comply
with the London Plan, for the reasons set out in paragraph 60 of the above-mentioned report;
but that the possible remedies set out in paragraph 62 of that report could address these
deficiencies:

       Energy: The applicant must provide further information on a range of areas including;
        the baseline emissions of the building, modelling of energy efficiency carbon savings
        using approved software, the application site is located adjacent to the identified
        Wembley Energy Action Area and the applicant must assess the potential of linking to
        the proposed district energy system, the applicant must assess the potential of installing
        a centralised (communal) energy system, the viability of a combined heat and power
        plant, and further information on the potential to increase the amount of photovoltaic
        panels and the potential to use ground source heat pumps.
       Building adaptation: The applicant must assess the potential of installing living roofs
        and sustainable urban drainage techniques.
       Transport: The applicant must provide further detailed modelling information as set
        out in the transport section of this report. The applicant must provide a freight and
        servicing management strategy, a construction management plan and a travel plan.

       Employment: A relocation strategy for the existing businesses and a local training and
        employment initiative

Section 106 agreement
6       The local planning authority is proposing the following draft section 106 agreement:

       Financial contribution of £385,500 to improve sustainable transport infrastructure in
        the local area, improvements to open space and sports facilities in the local area.
       Improvements to the junction of Empire Way and Fulton Way.
       Offset of 20% carbon dioxide emissions through the use of on-site renewable energy.
        If proven to the Council’s satisfaction that it is unfeasible, provide it off site through


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        an in-lieu payment to the council who will provide that level of offset renewable
        generation.
       The scheme should include an optimally sized combined heat and power plant unless
        it can be satisfactorily demonstrated that the thermal load of the building would not
        feasibly support the installation of a combined heat and power plant, in which case
        the energy strategy as submitted through the original application can be
        implemented.
     A relocation strategy for existing businesses.

7       These section 106 measures address the Mayor’s previous concerns.

Energy
8      Following detailed discussions between the Greater London Authority, the local
planning authority and the applicant, the applicant has now provided detailed modelling work
demonstrating that this scheme will achieve a 15% reduction in carbon dioxide emissions
beyond Part L of the 2006 Building Regulations through the use of energy efficiency measures,
which is acceptable.

9      In addition, the applicant has now also committed to the installation of a 100 kilowatt
combined heat and power plant that will further carbon emissions by a further 16% beyond the
proposed energy efficiency measures. This has been secured through a section 106 agreement.
This system will also be designed to allow future connections to the Wembley Energy Action
Area decentralised energy system.

10      Finally, the applicant has provided a detailed assessment into the feasibility of installing
a variety of renewable energy systems. Due to the installation of the combined heat and power
plant, the applicant is proposing the installation of 250 sq.m. of photovoltaic panels that achieve
a 4.5% reduction in carbon emissions. The applicant has provided sufficiently robust
information, and plans, justifying that this is maximum reasonable carbon saving that can be
achieved through renewable energy on this site, which is acceptable.

Climate change building adaptation
11      As previously requested by the Mayor, the building now includes a number of climate
change building adaptation measures, including; 150 sq.m of living roof covering the first floor
communal space and a 162 cubic metre excess water storage tank to minimise the impacts of
surface water run off. These sustainable drainage techniques will help manage drainage water
as close to the site as possible and will reduce surface water run off from the site. In addition,
the applicant is also proposing to utilise a range of water conservation measures such as a
water meter for each unit, a water leak detection system, water saving features and is also
proposing to use rain water run off for use on-site. The proposed measures now comply with
London Plan drainage, water conservation and living roof policies.

Transport
12    The Mayor previously raised a number of transport issues and requested that additional
information with regard to the transport assessment and cycling and servicing be provided.




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13      A final version of the travel plan, a construction management plan, and a delivery and
servicing plan were also requested. TfL advised the local planning authority to seek a financial
contribution towards footway and crossing facility improvements.

14     A construction management plan and a delivery and servicing plan have been secured as
a planning condition, which complies with London Plan Policy 3C.25 Freight Strategy. The
applicant has also submitted a map illustrating the local cycle network in relation to this site.

15     Swept path diagrams have been submitted to TfL by the applicant who has addressed
concerns about servicing of the site. TfL considers that the local planning authority has now
included sufficient conditions to make provision for the safety of pedestrians and cyclists
accessing the car park.

16     The local planning authority has secured a section 106 financial contributions of
£385,500, which will partly be used to improve sustainable transport measures in the local
area including improvements to fund footway and crossing facility improvements to mitigate
the impact of this development on the surrounding area, which is acceptable.

17     A final version of the travel plan has yet to be submitted to TfL. However, this has been
secured by a planning condition.

18    The transport issues previously raised have been satisfactorily addressed through the
submission of additional information and planning conditions.

Employment
19      Further to the Mayor’s previous requests, the LDA is now pleased to learn that the
applicant and Quintain have offered existing tenants the opportunity to relocate to a variety of
floor spaces in the local area, including York House and Rutherford Way, both buildings are
within 500 metres of the existing site. Furthermore, Quintain has offered all existing tenants a
relocation package.

20      In line with London Plan policy 3B.11 the LDA previously recommended that the local
planning authority and applicant secure an employment and training strategy. In particular the
LDA suggested that the Brent Council secure a commitment from the applicant to use
the ‘Brent in2 Work’ project as a way of ensuring local people are awarded jobs. This
employment and training initiative has now been secured as part of a section 106 agreement.
Part of this training initiative should focus on hospitality training.

Article 7: Direction that the Mayor is to be the local planning authority
21      Under Article 7 of the Order the Mayor could take over this application provided the
policy tests set out in that Article are met. In this instance the Council has resolved to grant
permission with conditions and a planning obligation which satisfactorily addresses that
matters raised at stage I, therefore there is no sound planning reason for the Mayor to take
over this application.

Response to consultation
22      In response to the public consultation process, the local planning authority received two
letters of objection, which raised a number of local planning concerns about the potential loss
of sunlight to the adjoining properties, loss of privacy, these issues are local planning issues
and have been satisfactorily addressed by the local planning authority. In addition, the public

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responses also raised strategic planning concerns with regards the impacts on the transport
network and increased traffic congestion. Transport for London has not raised any strategic
concerns about the impacts of this proposal on the transport network.

Legal considerations
23      Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor
of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning
authority to refuse permission for a planning application referred to him under Article 4 of the
Order. He also has the power to issue a direction under Article 7 that he is to act as the local
planning authority for the purpose of determining the application. The Mayor may also leave
the decision to the local authority. In directing refusal the Mayor must have regard to the
matters set out in Article 6(2) of the Order, including the principal purposes of the Greater
London Authority, the effect on health and sustainable development, national policies and
international obligations, regional planning guidance, and the use of the River Thames. The
Mayor may direct refusal if he considers that to grant permission would be contrary to good
strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out
his reasons, and the local planning authority must issue these with the refusal notice. If the
Mayor decides to direct that he is to be the local planning authority, he must have regard to the
matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also
have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to
issue a direction under Articles 6 or 7.

Financial considerations
24     Should the Mayor direct refusal, he would be the principal party at any subsequent
appeal hearing or public inquiry. Government guidance in Circular 8/93 („Award of Costs in
Planning and Other (including Compulsory Purchase Order) Proceedings‟) emphasises that parties
usually pay their own expenses arising from an appeal.

25      Following an inquiry caused by a direction to refuse, costs may be awarded against the
Mayor if he has either directed refusal unreasonably; handled a referral from a planning
authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding
whether the Mayor has acted unreasonably will be the extent to which he has taken account of
established planning policy.

26      Should the Mayor take over the application he would be responsible for holding a
representation hearing and negotiating any planning obligation. He would also be responsible
for determining any reserved matters applications (unless he directs the council to do so) and
determining any approval of details (unless the council agrees to do so).

Conclusion
27      The principle of providing a 262-bedroom hotel on this site in the Wembley
Opportunity Area is acceptable in strategic planning policy terms. The application proposes a
good quality building design that fits into the emerging context for the Wembley stadium area
as set out in Brent Council’s existing 2004 Wembley Masterplan and proposed 2008 Wembley
Masterplan.

28     The Mayor previously raised a number of strategic planning concerns including energy,
the need to include a range of climate change building adaptation measures, transport
measures, provision of a relocation strategy and a local training and employment imitative. The

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applicant and local planning authority have now satisfactorily addressed the Mayor’s original
concerns.

for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email giles.dolphin@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Colin Wilson, Strategic Planning Manager (Planning Frameworks)
020 7983 4783 email colin.wilson@london.gov.uk
Michael Mulhern, Case Officer
020 7983 4310 email michael.mulhern@london.gov.uk




                                                          planning report PDU/2273/01
                                                                           30 October 2008

                                                                  Malcolm House
                                                         in the London Borough of Brent
                                                       planning application no. 08/2633


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
This is a detailed planning application for the comprehensive redevelopment of this site to
provide a hotel with 262 bedrooms in a part 7, part 11-storey building.

The applicant
The applicant is Summit Hotels Ltd, and the architect is Ica Architects.

Strategic issues
The principle of providing a hotel on this site in the Wembley Opportunity Area is acceptable
in strategic planning policy terms. However, there are a number of planning issues that will
need to be resolved before this application can be considered to fully comply with London
Plan policy including: energy and climate change measures; transport modelling; securing a
freight and service management plan, a travel plan and a construction management plan.
Recommendation
That Brent Council be advised that the application does not currently comply with the
London Plan policy, for the reasons set out in paragraph 60 of this report; but that the
possible remedies set out in paragraph 62 of this report could address these deficiencies.


                                                                                             page 6
Context
1 On 29 September 2008 the Mayor of London received documents from Brent 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 7 November 2008 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(c) of the Schedule of the Order 2008:
”Development which comprises or includes the erection of a building that is more than 30 metres high
and outside the City of London.”

3 Once Brent 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 application site is located south-west of the junction of Empire Way and Fulton Road
and north-west of the Wembley National Stadium, and it is within the London Plan identified
Wembley Opportunity Area.

6 The site is 0.21 hectares and is currently occupied by two office buildings (Fulton House
and Malcolm House) that total 2,284 square metres of office floorspace. These existing
buildings are 1970’s low-rise, 3-storey, brick buildings, set back from Fulton Road and Empire
Way with car parking in front of them.

7 The site has a public transport accessibility level of 5 (on a scale where 1 is very low and 6
is very high). The nearest London underground station is Wembley Park (on the Metropolitan
and Jubilee lines) approximately one kilometre north-east of the site. Wembley Central and
North Wembley are also located a short distance from the site, providing access to the London
Underground and British Rail services. There are three main bus routes accessible from this
site, providing services to Ealing, Brent Cross and Willesden Junction.

Details of the proposal
8 This is a detailed planning application. The applicant is proposing to replace the existing
buildings with a hotel with 262 bedrooms with a total floorspace of 11,301 square metres. The
building includes a ground floor reception area with bar and restaurant, 53 car parking spaces
(including 3 blue badge spaces), 12 secure cycle spaces with shower and changing facilities and
a range of associated landscaped works. The building is arranged as a ‘U’ shaped building
around an internal courtyard and is a part 7, part 11-storey building.

Case history
9   There is no strategic planning case history for this site.



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Strategic planning issues and relevant policies and guidance
10 The relevant issues and corresponding policies are as follows:

   Urban design                  London Plan; PPS1
   Parking                       London Plan; the Mayor‟s Transport Strategy; PPG13
   Employment                    London Plan; PPG4; draft PPS4; Industrial Capacity SPG
   Access                        London Plan; PPS1; Accessible London: achieving an inclusive
                                  environment SPG;
 Tall buildings/views            London Plan; View Management Framework SPG
 Sustainable development         London Plan; PPS, PPS Planning and Climate Change
                                  Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor‟s Energy
                                  Strategy; Sustainable Design and Construction SPG
 Tourism/leisure                 Good Practice Guide on Planning for Tourism (DCLG)

11 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 2004 Unitary Development Plan and the 2004
London Plan (with 2006 Alterations).

Land use principle
12 The proposed site is in the identified Wembley Opportunity Area as set out in London Plan
policy 2A.5 on ‘Opportunity Areas’. In accordance with London Plan policies 5F.1 and 5F.2 the
Wembley Opportunity Area has the potential to provide approximately 5,500 new jobs and
5,000 new homes. Development within this area should exceed minimum guidelines for
housing and employment requirements, should maximise public transport access, deliver social
and economic inclusion and promote high quality design. The area should be optimised as a
nationally and internationally significant sports, leisure and business location. In this regard,
the proposal to provide a new hotel development on this site is in line with these London Plan
policy objectives.

13 London Plan policy 3D.4 on ‘Development and promotion of arts and culture’ identifies
Wembley as a Strategic Cultural Area, whereby development should support and promote
London’s major tourist attractions, in this case Wembley stadium. The provision of a new hotel
facility on this site would help promote Wembley as a major tourist destination. The hotel use
will also support existing employment and industrial uses in the surrounding area. The
applicant should give consideration to providing accessible conference facilities within the hotel
space.

14 The proposal to provide a 262-room hotel is in line with London Plan policy 3D.7 on
‘Visitor accommodation and facilities’ and will contribute towards the Mayor's target of 40,000
net additional hotel rooms by 2026. This area is identified as one of the three most promising
locations for hotel development in London.

15 In 2003 Brent Council adopted the ‘Destination Wembley’ supplementary planning
guidance that sets out development objectives for Wembley Stadium and the surrounding area,
which the former Mayor subsequently endorsed. The document identifies this area of Wembley
for comprehensive redevelopment. The principle aim of this guidance is the regeneration of the
area by promoting mixed-use schemes and medium to high value development. It states that
the area surrounding the stadium is appropriate for leisure, retail, hotel and office space. In



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particular this area could accommodate a range of hotel types and approximately 1,500 and
2,000 hotel beds spaces.

16 This guidance led to the preparation of the Wembley Masterplan, which was adopted by
Brent Council in 2004. A key principle of this Masterplan is to promote Wembley as a major
visitor destination. The application site is identified as being within the north-west district of
that masterplan, where hotel development is appropriate. In addition, Brent Council is
currently consulting on an updated draft Masterplan supplementary document for the
Wembley Stadium area. This masterplan does not specifically set a development proposal for
this site, but the masterplan does set out design parameters and uses that would be appropriate
on this site. The building uses and massing are broadly in line with these draft requirements.

17 Brent Council’s 2004 UDP identifies the wider Wembley area as the ‘National Stadium
Policy Area’, where uses that promote and attract large numbers of visitors to the area would
be supported. In addition, high-density residential development will be promoted and the
design and layout must take account of crowd movement and crowd control measures.

18 In summary, the principle of providing residential and hotel development on this site is
acceptable at a strategic level. These uses are in line with the objectives of the Wembley
Opportunity Area and the London Plan policy to promote Wembley as a major tourist
destination. Brent Council, however, must be content that the proposal sits within the adopted
policy context set out in the 2003 ‘Destination Wembley’ supplementary planning guidance.

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.

20 The proposed building would make efficient use of the site and provides a clear built edge
to Empire Way and Fulton Road. It would bring the building line on Empire Way forward
(westwards) from that of the existing building on the site, which serves to align the proposed
building with the television studio building to the north on the opposite side of Fulton Road.
This is positive in terms of the improved enclosure to Empire Way and is likely to be repeated
in the sites to the south, which are currently set back from the road. In the interim the south-
west corner of the building will be particularly prominent in views north along Empire Way.
This elevation currently includes a series of what appear to be faux windows on the corner that
could be changed to real windows with little or no change to internal arrangements of the
rooms and without necessarily prejudicing the redevelopment of the adjacent site to the south.
This would offer greater visual interaction with Empire Way and additional natural light to
these rooms. The applicant should discuss this with Brent Council design officers.

21 The ground floor of the building would substantially fill the plot and introduce active
frontages in the form of fully glazed bar, restaurant and lobby areas to both Empire Way and
Fulton Road. This is a positive contribution to the animation of these routes. The upper floors
of the hotel adopt a ‘U’ shape layout, oriented to the south, around a podium level amenity
space, which is positive. The southerly orientation will appropriately maximise sunlight in the
amenity space and hotel rooms. The layout also incorporates a heavily glazed corridor



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overlooking this space at each level of the north wing of the building, which would be beneficial
in terms of surveillance and maximising natural light in the building.

22 The building will act as a marker in views along Fulton Road from Olympic Way and
views along Empire Way. The proposed scale and massing responds appropriately to this, as
well as to the corner site and the wider context. The ground floor of the building would be
predominately glazed and slightly set back, giving it the appearance of a plinth on which the
upper floors sit. The elevations as a whole are treated simply, in a limited palette of white and
terracotta ceramic cladding, buff brick and light grey cladding with generously proportioned
windows set within deep reveals. This modest approach is appropriate given the Wembley
context where the stadium and buildings on Olympic Way are, or will be, of more extravagant
architecture and those to the fringes distinctly less ostentatious.

23 The proposed design is consistent with strategic design policy but Brent Council and the
applicant should discuss the comments above.

Access
24 The applicant has submitted a detailed access statement demonstrating how the principles
of inclusive design have informed the overall design and access arrangements of this hotel and
the associated restaurant spaces.

25 The London Plan identifies a strategic London wide shortage of wheelchair accessible hotel
bedrooms. Consideration should be given to increasing the number of fully wheelchair
accessible bedrooms above the minimum 5%, required under the Building Regulations, to 10%
if possible. The access statement demonstrates how the design of the hotel includes sixteen
accessible hotel bedrooms, which is equivalent to 6%. These hotel rooms are generously sized,
located adjacent to lift cores and each accessible room has a career room attached. The
quantum, design and location of these wheelchair accessible rooms is in line with London Plan
policy 3D.6 which seeks to increase the quality and quantity of fully wheelchair
accommodation.

Transport
26 The application proposes a total of 53 car parking spaces this level of parking is in line with
Policy 3C.23 Parking Strategy (including Annex 4) of the London Plan. The scheme also
includes three blue badge accessible car parking spaces located adjacent to the lift core, which
equates to 5.5% of overall parking provision and is in line with the minimum building
regulation requirements.

27 The development proposes twelve cycle parking spaces, which equates to 1 per 10 staff.
This is in accordance with TfL’s cycle parking standards. The provision of shower and
changing facilities is also supported by TfL. TfL expects all new developments to be fully
integrated into the local cycle network. To ensure compliance with London Plan policy 3C.22
the applicant should provide a map indicating local cycle routes and how this scheme would
connect.

28 The delivery and servicing activity for the proposed hotel is likely to be similar to the
existing site use. However, to ensure compliance with London Plan policy 3C.25 on ‘Freight
strategy’, TfL requests the provision of additional information including a commitment
ensuring that delivery activity will take place outside of the peak periods; the provision of
swept path analysis; a delivery and servicing plan; and a construction management plan.

                                                                                         page 10
29 TfL supports the provision of a footway adjacent to the coach/servicing lay-by. Dropped
kerbs and tactile paving should also be provided at the cross-over at the car park entrance. TfL
considers that the development is likely to generate additional pedestrian and cycle trips and
consequently the local planning authority should seek a financial contribution to fund
improvements to footways and crossing facilities.

30 The provision of coaches for this development is welcomed by TfL. However, TfL
recommends that there is provision for access and manoeuvring for a 15-metre coach.

31 TfL notes that the survey sites for the trip generation are over five years old. TfL
recommends that the applicant considers conducting its own surveys using either TRICS or
TRAVL. Using the trip generation information submitted as part of the Transport Assessment,
TfL concludes that the development is likely to generate a 5% increase in vehicular trips on
Fulton Road during the peak periods. This would give rise to the need for a junction capacity
analysis.

32 The Transport Assessment states that traffic flow data was obtained in the school summer
holidays and therefore should be subject to an adjustment factor. However, this information has
not been used to ascertain the potential impact the proposed development will have on the
surrounding network.

33 Should this application be granted planning permission, the applicant is reminded that this
does not discharge the requirements under the Traffic Management Act 2004. Formal
notifications and approval may be needed for both the permanent highway scheme and any
temporary highway works required during the construction phase of the development.

34 The Travel Plan submitted is only in draft form. TfL recommends the submission of a final
Travel Plan. This should be prepared in accordance with TfL’s guidance for workplace travel
planning for development and this should be secured through an appropriate planning
condition

35 In summary, in transport terms TfL is satisfied that the principle of this planning
application is acceptable, however further information is required on a range of issues to ensure
this applicant complies with London Plan transport policies.

Climate change measures
36 The London Plan climate change policies as set out in chapter 4A collectively require
developments to make the fullest contribution to tackling climate change by minimising carbon
dioxide emissions, adopting sustainable design and construction measures, prioritising
decentralised energy supply, and incorporating renewable energy technologies with a target of
20% carbon reductions from on-site renewable energy. The policies set out ways in which
developers must address mitigation of and adaptation to the effects of climate change. Policies
4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon
dioxide reduction targets that are necessary across London to achieve this.

Energy assessment and sustainable design and construction (Policy 4A.2 and 4A.4)

37 The baseline emissions have been calculated using benchmarks figures. It is therefore not
possible to relate the baseline emissions to building regulations 2006 minimum requirements.
The applicant must calculate baseline emissions using approved building regulations 2006
approved software. The baseline emissions should be representative of a hotel that complies


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with building regulations 2006 minimum equipments. Total energy, i.e. unregulated energy
usages such equipment, should be also accounted for.

38 The applicant has suggested a range of suitable energy efficient design measures (passive
and active), which is welcomed. However, the applicant is required to model the carbon dioxide
savings arising form the proposed demand reduction measures and to relate the resultant
emissions to building regulations 2006. The applicant is required to use building regulations
approved software to model the carbon emissions that arise as a result of the proposed energy
efficient design (active and passive) measures. This modelling work must show how these
proposed measures are able to decrease carbon emissions beyond the 2006 building regulations
minimum requirements, i.e. the building emission rate is smaller that the target emission rate.

Decentralised energy and combined heat and power (Policies 4A.5 and 4A.6)

39 This application site is in close proximity to the identified Wembley Energy Action Area.
The applicant must assess the potential of linking to the proposed decentralised energy system
that is proposed for that area, evidence of this assessment and discussions must be provided.

40 The heating strategy adopted by the applicant disregards the use of a centralised
(communal) approach and proposes the use of air source heat pumps to provide the required
heating and cooling for the hotel rooms. Whilst the use of air source heat pumps can be
considered as acceptable for the space heating provision of the hotel, domestic hot water should
be provided using centralized (communal) plant.

41 The applicant needs to demonstrate that the proposed heating strategy offers enough
flexibility for connection to an external heat network should a scheme be developed in the
future. In addition, the applicant needs to give consideration to the space requirements that the
final choice of technologies will require.

42 The suitability of installing a 100-kilowatt combined heat and power plant has been
investigated and the applicant has concluded that there is insufficient heat demand during the
summer months for such a plant to operate efficiently and as a consequence a combined heat
and power plant has been deemed unsuitable. The applicant is required to revisit the combined
heat and power option. The use of CHP for domestic hot water provision should be further
investigated. The suitability of using combined heat and power in hotels is supported by the
existing installations.

43 There is a limited on-site cooling demand. The applicant is proposing to use air source heat
pumps to provide the cooling requirements of the hotel. As stated in the renewable section, the
applicant should investigate further the suitability of using ground source heat pumps to
contribute to both cooling and space heating requirements of the hotel.



Renewable energy (Policy 4A.7)

44 The applicant is proposing the use of 250 square metres of photovoltaic panels that would
achieve a carbon saving of approximately 4%. The applicant has concluded that due to the site
constraints no additional savings can be achieved.

45 The applicant is required to provide supportive information (drawings) illustrating the total
amount of suitable area available for the installation of photovoltaic panels and to demonstrate
that no additional panels could be allocated in a suitable location.

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46 The applicant should revisit the possibility of using ground source heat pumps to
contribute to the space heating and cooling requirements of the hotel. Ground source heat
pumps could operate along with the proposed air source heat pumps. The applicant should
explore this option in more detail.

Living roofs (Policy 4A.11)

47 The applicant is not proposing to install living (green or brown) roofs onto the roof of the
building. In line with the requirements of London Plan policy 4A.11 the applicant is requested
to assess the potential of installing living roofs.

Flood risk assessment and drainage (Policies 4A.12 4A.13 and 4A.14)

48 The site is within Flood Zone 1 and consequently does not require the preparation of a
flood risk assessment other than for the consideration of surface water run-off. The applicant
has submitted a flood risk assessment but does not specify the degree to which sustainable
drainage techniques will be applied across this site. The submitted information lists a range of
options but does not commit to the provision of any of these proposals. The sustainable
drainage proposals for this application do not currently comply London Plan policy 4A.14 on
‘Sustainable drainage’.

Summary

49 In summary the climate change proposals, including the energy strategy and the building
adaptation measures, do not comply with London Plan energy policies and considerable work is
required to bring this application in line with these policies.




Waste
50 The mitigation measures to manage the predicted waste streams set out in this application
are in line with the waste policies set out in the London Plan. The site waste management plan
should allow for efficient materials and waste handling, for wastes to be removed from the site,
and for materials to be brought to the site, by water or rail transport wherever that is
practicable.

51 The London Plan requires major developments to provide suitable waste and recycling
storage facilities. The applicant should consult with Brent Council on its plans to install
suitable (or improve existing) recycling facilities where appropriate to accept paper/magazines,
cardboard, glass, plastic bottles, and aluminium tins/cans. Options should also be explored to
allow for the collection of food waste separately for composting where possible.

Employment
52 In accordance with the London Plan and the Economic Development Strategy, the London
Development Agency (LDA) seeks to maintain London as a top tourist destination for visitors
and investment.

53 In accordance with London Plan policy 3B.11 on ‘Improving Employment Opportunities
for Londoners’ the LDA is pleased to learn that the applicant has already offered to include

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employment and training initiatives as part of the s106 agreement. The training offered should
be tailored to provide the necessary hospitality and service sector training needed in order to
successfully work in a hotel environment. The recruitment of local businesses and people for
the construction phase is encouraged, and advertisements should be made accordingly (Job
Centre notices, leaflet drops, adverts in local papers etc). The LDA suggest that the Council
secures a commitment to use the ‘Brent in2 Work’ project as a way of ensuring local people are
secure employment.

54 It is also important to highlight that due to the nature of jobs in this industry (unsociable
hours) consideration should be given to the provision of appropriate and affordable childcare
facilities in the area to ensure that access to childcare is not a barrier to employment. The
Council may find it appropriate to secure a financial contribution through the section 106
agreement. Such a contribution would ensure that objectives set out in London Plan policies
3B.1and 3B.11 are met

Local planning authority’s position
55 The view of the local planning authority is not known at the time of writing this report.

Legal considerations
56 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. 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
57 There are no financial considerations at this stage.

Conclusion
60      London Plan policies on Opportunity Areas, tourism and leisure, hotels, design and
access, climate change and energy, transport, waste and employment are relevant to this
application. The application complies with some of these policies but not with others, for the
following reasons:
        Climate change: the energy strategy and building adaptation measures do not comply
         with London Plan energy policies.
        Transport: the applicant is required to provide further technical, modelling and
         framework information to ensure this application complies with London Plan transport
         policies.

61       On balance, the application does not comply with the London Plan.


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62     The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
      Climate change: The applicant must provide further information on a range of areas
       including; the baseline emissions of the building, modelling of energy efficiency carbon
       savings using approved software, the application site is located adjacent to the identified
       Wembley Energy Action Area and the applicant must assess the potential of linking to
       the proposed district energy system, the applicant must assess the potential of installing
       a centralised (communal) energy system, the viability of a combined heat and power
       plant, and further information on the potential to increase the amount of photovoltaic
       panels and the potential to use ground source heat pumps.
      Building adaptation: The applicant must assess the potential of installing living roofs
       and sustainable urban drainage techniques.
      Transport: The applicant must provide further detailed modelling information as set
       out in the transport section of this report. The applicant must provide a freight and
       servicing management strategy, a construction management plan and a travel plan.

      Employment: Due to unsociable working hours the Council should seek a contribution
       towards local childcare for the employees of this development.




for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email giles.dolphin@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Colin Wilson, Strategic Planning Manager (Planning Frameworks)
020 7983 4783 email colin.wilson@london.gov.uk
Michael Mulhern, Case Officer
020 7983 6535 email michael.mulhern@london.gov.uk




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