planning report PDU/1417a/01
15 July 2008
157-183 Waterloo Road, SE1
in the London Borough of Lambeth
planning application no. 08/02096/FUL
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
Redevelopment to provide a part-4; part-9 and part-12 storey building for hotel use.
The applicant is CPSL Ltd, and the architect is KSS
Hotel use is acceptable in principle. The design is unsatisfactory for a site of this prominence.
The application is unacceptable in relation to various transport matters. Additional information
is required in relation to climate change mitigation and adaptation. Access/equal
opportunities implications are acceptable.
That Lambeth Council be advised that the application does not comply with the London Plan, for
the reasons set out in paragraph 21 of this report; but that the possible remedies set out in
paragraph 23 of this report could address these deficiencies.
1 On 5 June 2008, the Mayor of London received documents from Lambeth 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 21 July 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 of the Schedule of the Order 2008:
“Development which comprises or includes the erection of a building….more than 30 metres high
and is outside the City of London.”
3 Once Lambeth 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
5 The application site is located close to the centre of Waterloo just south of Waterloo
Station. It is just south of The Cut and the Old Vic Theatre and opposite Millennium Green.
6 The site is currently occupied by Partnership House – a vacant 7-storey 1960s office
7 The site is bounded by the A301 Waterloo Road to the southwest, which is part of the
Strategic Road Network (SRN). The nearest Transport for London Road Network (TLRN), the
A201 Blackfriars Road, is less than 250m away, with Westminster Bridge Road/St George’s Circus
and the Waterloo roundabout also nearby, within 550m of the site.
8 The site has a public transport accessibility level (PTAL) of 6 on a scale of 1 to 6, where 6 is
most accessible. The site is within 300m of Waterloo rail and Underground stations, providing
access to Jubilee, Waterloo and City, Northern, and Bakerloo line Underground services. Numerous
mainline rail services to southwest London and beyond are also available. Waterloo Road is a major
bus corridor served by 8 routes; a further 8 routes are available within walking distance on
Westminster Bridge Road and Blackfriars Road. The nearest bus stop is at the northwest corner of
the site on Waterloo Road. National Cycle Network route 4 runs along Belvedere Road/Upper
Ground within 750m of the site. Other cycle routes run in the vicinity, including one along Gray
Street adjacent to the site.
Details of the proposal
9 Planning permission is sought for demolition of the existing building and its replacement
with a part-4; part-9 and part-12 storey building for hotel use. The operator of the hotel will be
‘Hampton by Hilton’.
10 The hotel will have 327 bedrooms; a restaurant; a bar; meeting and conference facilities
and a gym.
11 There is no relevant case history.
Strategic planning issues and relevant policies and guidance
12 The relevant issues and corresponding policies are as follows:
• Tourism/leisure London Plan; Good Practice Guide on Planning for Tourism
• Urban design London Plan; PPS1
• Transport London Plan; the Mayor’s Transport Strategy; PPG13; Land for
Transport Functions SPG
• Climate change mitigation
and adaptation London Plan; PPS, PPS Planning and Climate Change
Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy
Strategy; Sustainable Design and Construction SPG
• Access/equal opportunities London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a
good practice guide (ODPM); Planning for Equality and Diversity
in Meeting the spatial needs of London’s diverse communities
SPG; Diversity and Equality in Planning: A good practice guide
13 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 2007 Lambeth Unitary Development Plan and the
London Plan (Consolidated with Alterations since 2004).
14 The Waterloo Opportunity Area Planning Framework (October 2007) is also a relevant
15 Policy 3D.7 (Visitor accommodation and facilities) of the London Plan states that: “The
Mayor will work with strategic partners to implement his Tourism Vision and to achieve 40,00
additional net bedrooms by 2026 to improve the quality, variety and distribution of visitor
accommodation and facilities.”
16 The Policy also states that within the CAZ, strategically important new visitor provision
should be focussed on its Opportunity Areas
17 The development of the 327-bedroom hotel would accord with the above policy objective.
18 In accordance with supporting text to the policy set out in the London Plan, the hotel
operator should give consideration to providing staff accommodation and providing training for
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. Policy 4B.1 sets out overarching design principles for London and states that the
Mayor will seek to ensure that new developments maximise site potential, enhance the public
realm, provide a mix of uses, are accessible, legible, sustainable, safe, inspiring, exciting and
respect London’s natural and built heritage. Other policies include general design principles, which
should be reflected in developments, relate to the promotion of world-class design, maximising the
potential of sites, ensuring appropriate development densities, improving the public realm and
creating accessible environments.
20 London Plan policies 4B.9 and 4B.10, 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.
21 According to the applicant’s Design and Access Statement, the existing building has
shortcomings in the building structure that rules out a financially viable refurbishment for hotel use
or to meet current British Council of Offices guidelines. Pursuant to policy 4B.4, it would be
useful to test refurbishment options for other uses. Although the existing free standing church
block and the ground floor look outdated and defensive, the main building is a good example of
1960s office architecture. The curved shape, the extensive use of windows (including on the
corners) and the composition of the facade give the building an elegant appearance. Its
demolition will be regretted and will only be accepted if the new development is of equal or higher
22 The general height of the proposal is accepted but the overall design and architecture is
poor and contrary to policy 4B.1. There is scope for a tall element on the corner of Waterloo Road
and Gray Street but the proposed tower is not suited to its wider context in terms of proportion
and composition and in terms of its relationship with other buildings and the public open space
around it, contrary to policy 4B.10. Due to its proportion, design of its facades and choice of
materials it is not an attractive city element as viewed from all angles. The south façade in
particular, on Gray Street and very visible for northbound traffic on Waterloo Road, is dull and
defensive and adds little visual quality to the Waterloo area.
23 The Design and Access Statement states that the main facades cannot contain more than
25% glazing because of the acoustic requirements but this is as much a result of the choice for the
type and quality of the glass than of the noise standards. A higher grade glass could absorb more
noise. There is no specific requirement for the Waterloo Road facade to contain a certain
percentage of glazing but the current design results in a dull and uninviting visual appearance, and
this should be revised before the application is referred back to the Mayor.
24 At the rear of the development the height is brought down in storey height with the
intention to relate to the Stage Door public house and the residential environment. Due to the
lack of design quality, however, the north-eastern elevation, as seen from Webber Street and the
Mitre Road and Ufford Street Conservation Area, lacks the elegance and attention to detail of the
pub. Similarly, the proposed design does not relate well to the Grade II listed Wellington House.
25 The architect has shown in the design statement alternative approaches to the design and
detailing and these may need to be revisited.
26 London Plan Policy 3C.3 seeks to ensure that there is sufficient transport capacity to allow
for travel generated by this development, which shall be determined by a transport assessment.
The assessment accompanying this application is considered unacceptable as it does not provide a
sufficient evaluation of the proposed development’s travel demands.
27 TfL considers that the use of a single site, the Thistle Victoria Hotel, from which to derive
trip generation and modal split to be unacceptable as it does not provide a sufficiently robust
result. Further sites should be consulted or an alternative methodology should be developed to
enable a robust assessment.
28 The transport assessment claims that there will be little or no coach activity generated by
the proposed hotel. Based on experience of other central London Hotels it is TfL’s view that this
assumption is inaccurate. TfL expects further analysis regarding coach trip generation generated
by this development and to investigate the provision of coach parking facilities within the vicinity
of the site.
29 Therefore, TfL will be unable to determine whether the proposals accord with London Plan
policy 3C.3 until the transport assessment is revised in accordance with the above information.
30 The proposed arrangements for coach and taxi servicing envisage the Waterloo Road
frontage being used for loading and unloading passengers and luggage. TfL is concerned about
the adverse effect this would have on the Waterloo Road bus U-turn facility and the associated bus
stand. Coaches and taxis loading in the bus feeder lane for the U-turn facility would prevent bus
services from performing this manoeuvre. Loading in the bus stand northwest of the entrance
would also have an adverse effect on bus services. TfL considers these arrangements to be
unacceptable and contrary to London Plan policies 3C.23 and 3C.20.
31 Therefore, taxi and coach arrangements for the development should be amended. TfL
requests that an off-street coach bay to accommodate at least one vehicle of 15 metres in length
be provided at this development. Furthermore, restrictions on Waterloo Road should be upgraded
to prevent loading “at any time” throughout the bus U-turn facility at the developer’s cost.
32 TfL welcomes the car-free nature of the development in an area of excellent public
transport accessibility and considers this aspect to be in line with London Plan policy 3C.23.
However, TfL is concerned that the provision of 2 disabled car parking spaces for 327 rooms is
likely to be insufficient and therefore contrary to London Plan policy 3C.23. Justification for this
level of disabled parking should be provided. Furthermore, it is noted that the present layout of
the disabled bays do not comply with the Disability Discrimination Act 1995 standards and should
33 The development proposals note that secure, covered cycle parking would be provided for
staff and guests in the service area, but do not indicate the quantity. In order to comply with
policy 3C.22 of the London Plan, provision for each element will be required in line with TfL’s cycle
parking standards. In addition, a few spaces should be provided on-street for restaurant
customers. The provision of lockers and showering facilities for staff are welcomed. The cycle
parking should be secured as part of any planning agreement.
34 TfL supports the production of a draft travel plan to promote and encourage sustainable
travel behaviour. However, the current plan is considered to be incomplete and therefore not in
accordance with policy 3C.2 of the London Plan. A full travel plan that covers all elements of the
proposal will be required and should include information on objectives, targets, management,
marketing, measures and monitoring. All travel surveys should be iTRACE compliant. TfL requests
that the travel plan be secured, enforced, monitored and reviewed as part of the Section 106
35 It is proposed that servicing and refuse collection for the development will occur off-street
within the servicing area, which is welcomed. However, no consideration has been given to
waiting areas if two or more servicing vehicles arrive at the same time – accordingly, further details
are requested. In line with London Plan policy 3C.25 and the London Freight Plan, TfL requires
that the applicants produce a servicing management plan (SMP) with a goal of rationalising
servicing and delivery trips, particularly at peak times, in order to minimise the impact of this type
of traffic on the adjacent SRN as it is a major bus corridor. The SMP should be prepared and
agreed with the local highway authority and TfL requests that the borough condition this as part of
any planning permission for this scheme.
36 In line with London Plan policy 3C.25 and the London Freight Plan, TfL requests that the
applicants produce a construction management plan (CMP) in order to minimise the impact of
construction traffic, particularly at peak times, on the adjacent SRN as it is a major bus corridor.
The CMP should be prepared and agreed with TfL and the local highway authority. This should be
conditioned as part of any planning permission.
Climate change mitigation and adaptation
Climate change mitigation
37 The London Plan requires developments to make the fullest contribution to the mitigation
of, and adaptation to, climate change and to minimise carbon dioxide emissions (Policy 4A.1).
38 Policies 4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change, and the
carbon reduction targets that are necessary across London to achieve this. Developments are
required to be adaptable to the climate they will face over their lifetime and address the five
principles set out in policy 4A.9 of the London Plan.
39 London Plan policies 4A.4 and 4A.7 require the submission of an energy demand
assessment along with the adoption of sustainable design and construction, demonstration of how
heating and cooling systems have been selected in accordance with the hierarchy and how the
development will minimise carbon dioxide emissions, maximise energy efficiencies, prioritise
decentralised energy supply, and incorporate renewable energy technologies, with a target of 20%
carbon reductions from on-site renewable energy.
40 An energy statement has been submitted, which provides details and estimates for the
energy consumption and carbon emission production for the proposed development. Whilst the
energy proposals are acceptable in principle, additional detail is required.
41 The energy strategy suggests a series of demand reduction measures including high
performance glazing, improved U-values and air tightness. It is stated that this will achieve 10-20%
CO2 reduction below 2006 Building Regulation requirements. Whilst this is welcomed, the
supportive modelling with a breakdown between heating, cooling and electricity energy
consumption and related carbon emission for a hotel that just complies with 2006 minimum
requirements and for the building after demand reduction have been specified are required.
42 In order to calculate the overall site baseline emissions and the renewable target, carbon
emissions from all the hotel’s energy requirements need to be included not just those covered by
43 The LDA’s Decentralised Energy Team and the South Bank Employers' Group are looking at
opportunities for an area-wide district heating network in Waterloo. The applicant should ensure
the development is ‘future-proofed’ for connection into a site-wide strategy, i.e. centralised plant
should allow for future connection to an area wide district heating scheme. The applicant should
advise how this will be achieved in the development.
44 A CHP is proposed, but no specific plant size is given. In addition, there does not seem to be
a conclusive statement to whether CHP will be finally installed or not. The CHP plant size needs to
be identified and load profiles need to be included to justify the proposed CHP capacity. In
addition, the proposed arrangement for the selling of the electricity will need to be understood.
45 The applicant needs to explain how heating will be provided to the development and to
detail how the CHP will be integrated within the overall heating system.
46 The applicant needs to explain how the cooling requirements of the hotel will be provided.
Additionally, the applicant needs to clarify whether or not absorption chillers are recommended as
a suitable solution or not.
47 In relation to renewable energy, the applicant needs to revisit the renewable options
considering the priority for the use of CHP as indicated above.
48 The energy strategy suggests the use ground source heat pumps for heating and cooling and
solar thermal for the site. These are technologies that are initially not suited to operate along with
CHP. The suitability of those technologies needs to be revisited and consideration need to be given
to how they would be integrated with the heating system after CHP is implemented. Consideration
should be given to the suitability of using photo voltaics as a complement to the use of CHP.
Climate change adaptation
49 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 contribution to
heat island effects, minimise solar gain in summer, contribute to flood risk reductions, including
applying sustainable drainage principles, minimise water use and protect and enhance green
infrastructure. Specific policies cover overheating, living roofs and walls and water.
Overheating (Policy 4A.10)
50 No information has been provided by the applicant in relation to this matter.
Living roofs and walls (Policy 4A.11)
51 The policy seeks that green and brown roofs and walls are included where these are feasible.
Accordingly, the applicant needs to address this matter.
Flooding (Policy 4A.13) and sustainable drainage (Policy 4A.14)
52 No information has been provided by the applicant in relation to this matter.
Water use (Policy 4A.16)
53 No information has been provided by the applicant in relation to this matter.
54 London Plan Policy 3D.7 (‘Visitor accommodation and facilities’) states that boroughs
should support an increase in the quality and quantity of fully wheelchair accessible
55 At least one DDA compliant bedroom is available on each floor. DDA compliant rooms are
provided at an overall level of 1 per 20 bedrooms. This will provide approximately 16 bedrooms.
The applicant should also ensure that some of these rooms are connecting to their neighbours so
that carers are nearby. The DDA compliant rooms should be safeguarded by condition.
56 In relation to internal and external circulation, the access statement advises that the ground
floor will have step free access and entrance is by automatic doors. Step free circulation routes are
available at all levels for guests, public and staff.
London Development Agency’s comments
57 This application is supported in principle given the regeneration benefits to this part of the
London Borough of Lambeth. The scheme seeks to contribute to objectives set out in London's
Economic Development Strategy to maintain and develop London as a top international
destination and principle UK gateway for visitors, tourism and investment.
58 This part of the CAZ has become an important accommodation cluster as it provides
approximately 1,000 bed spaces and this is set to increase, adding to the visitor spend within the
area. The LDA's Tourism Development Manager for this part of London suggests that there may
be only one other 3 star in the vicinity – therefore, this development would add to the breadth of
accommodation offered in this part of London.
59 In accordance with London Plan policy 3B.11, the Council should seek to ensure that local
residents and businesses benefit from jobs created by this proposal, in particular those related to
the hospitality industry. Initiatives to create training and employment opportunities for local people
and address other barriers to employment, should be formalised through a section 106 agreement.
This should also include local opportunities for residents and businesses during construction as well
as within the completed development, including the supply of goods and services and sub-
60 The LDA would therefore welcome a discussion with Lambeth Council with regards to the
inclusion of employment and training initiatives within the proposal.
Local planning authority’s position
61 The application may be considered by Lambeth Council on 13 August. The recommendation
is unknown at present.
62 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.
63 There are no financial considerations at this stage.
21 London Plan policies on tourism/leisure; urban design; transport; climate change mitigation
and adaptation; and access/equal opportunities are relevant to this application. The application
complies with some of these policies but not with others, for the following reasons:
• Tourism/leisure: Compliance with London Plan Policy 3D.7 (Visitor accommodation and
• Urban design: Non compliance with Policies 4B.1 (Design principles for a compact city);
Policy 4B.2 (Promoting world-class architecture and design); 4B.9 (Tall buildings –
location) and 4B.10 (Large-scale buildings –design and impact).
• Transport: Non-compliance with Policies 3C.2 (Matching development to transport
capacity); 3C.3 (Sustainable transport in London); 3C.20 (Improving conditions for buses);
3C.22 (Improving conditions for cycling); 3C.23 (Parking strategy) and 3C.25 (Freight
• Climate change mitigation and adaptation: Non compliance with Policies 4A.1 (Tackling
climate change); 4A.4 (Energy assessment); 4A.7 (Renewable Energy); 4A.9 (Adaptation to
Climate Change); 4A.10 (Overheating); 4A.11 (Living Roofs and Walls); 4A.13 (Flood risk
management); 4A.14 (Sustainable drainage) and 4A.16 (Water supplies and resources).
• Access/equal opportunities: Compliance with Policies 3D.7 (Visitor accommodation and
facilities) and 4B.5 (Creating an inclusive environment)
22 On balance, the application does not comply with the London Plan.
23 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
• A re design of the hotel accommodation.
• Transport matters as set out at paragraphs 26-36 of this report.
• Additional information in relation to climate change mitigation and adaptation as set out
at paragraphs 37-53 above.
for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email firstname.lastname@example.org
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email email@example.com
Colin Wilson, Strategic Planning Manager (Planning Frameworks)
020 7983 4783 email firstname.lastname@example.org
Martin Scholar, Case Officer
020 7983 5750 email email@example.com