Agenda item

Report of the Chief Planning Officer and Development Director.

The Committee considered a report of the Chief Planning Officer and Development Director relative to Snow Hill Police Station, 5 Snow Hill London EC1A 2DP – specifically, external and internal alterations together with demolition and new build and associated change of use of existing building from police station (sui generis) to hotel with ancillary uses (Class C1) including: (i) refurbishment of façade to Snow Hill and the retained façade to Cock Lane; (ii) partial demolition, rebuilding and extension to provide a building ranging from 6 to 8 storeys, plus new plant at roof level; (iii) extension of existing sub-basement; (iv) provision of cycle storage; (v) highway works; (vi) greening and other ancillary works.

The Town Clerk introduced the report and referenced the Officer presentation pack and two further addendums containing late representations, adding to the list of planning policies referenced at Appendix B and providing further clarification as to service and deliveries that had also been published and circulated.

Officers presented the applications highlighting that the concerned a site comprising 5 Snow Hill – a former City of London police station built in the 1920s and vacated in 2019 – which had frontages to both Snow Hill and Cock Lane. It was reported that the building was Grade II listed and sat within the Smithfield Conservation Area. Members were informed that the building was separated into two blocks, albeit linked at ground floor and basement level. It was noted that the surrounding area was predominantly commercial in character but that there were a number of residential premises on the opposite side of Cock Lane. It was highlighted that the application sought permission for the partial demolition, rebuilding and extension of the building to provide a 219 bedroom hotel. Block A fronting on to Snow Hill would be retained with a modest extension added at roof level with Block B to be largely demolished with the rear façade retained alongside key heritage elements including the historic staircase and the reading room. The building would also be increased in height from a part 5 and part 6-storey building to an eight-storey building. A dramatic atrium space would also be created in the existing light well to link the two buildings with an application for listed building consent also under consideration today for all of these works as well as for the proposed internal alterations (at Item 4a).

In terms of representations, Officers reported that five objections had been received from nearby residents at 32 Cock Lane, 10 Hosier Lane and also  8-9 Giltspur Street with the main grounds for objection relating to the impact on daylight and sunlight, noise from the roof plant and construction noise and disturbance. It was noted that the owner of the adjoining commercial building at 6 Snow Hill had also objected citing loss of daylight to offices, noise and disruption from construction, prejudice to possible redevelopment of 6 Snow Hill and the impact upon the listed building.

The Committee were shown plans of the building (existing and proposed). It was noted that a restaurant was proposed for the first floor and that this area would also incorporate the historic reading room. Officers went on to report that the proposals for hotel use were considered acceptable in policy terms and it was noted that there was an identified demand for hotel bed spaces, with the draft City Plan identifying a projected increase in visitor numbers and demand for hotel accommodation in the north-west of the City, in synergy with the Culture Mile. Furthermore, the hub model proposed by Premier Inn would provide compact and more affordable rooms and would therefore create a more diverse and inclusive offer of overnight accommodation for visitors to the Square Mile, whether that be for tourism or for business. It was reported that the proposals also included a cultural offer which would enable public access to the historic building through a series of curated spaces that would create a visitor experience through the former police station reception areas to the new, dynamic atrium space to ascend the historical staircase to the reading room. Within these areas there would be permanent exhibition space, charting the history of the police building  and narratives of the local area referencing the surrounding historic context such as the Old Bailey, Newgate Prison and other local landmarks/history such as the ghost of Cock Lane and the Golden Boy of Pie Corner statue. It was underlined that this exhibition would be free and publicly accessible  and contribute to the Culture Mile as well as providing access to reveal the history and significance of this heritage asset.

In terms of design, Officers commented that the overall design approach was considered to be a contextual response and heritage-led with distinct but complimentary insertions. The Snow Hill façade would be repaired and cleaned and the proposed, modest mansard extension would sit comfortably within the immediate townscape and reflect the surrounding heights in character. The building would have an atrium joining the two blocks and an increased height for block b which was considered appropriate and compatible with the scale and character of surrounding buildings. It was reported that the proposed atrium would have a perforated brick skin adding interest to the streetscape and that there was also a proposed green wall on the flank which would improve the aspect from both the street and surrounding properties on Cock Lane.

In terms of heritage impact, Officers commented that the proposal was considered to be a heritage-led approach to adapt and extend the building to enable a continued viable use, servicing the long-term conservation of the building. The scheme would preserve key areas of high heritage significance and would include a number of physical enhancements such as the replacement of windows, sensitive refurbishments, cleanable, historic elevations and the removal of unsightly modern interventions to better reveal internal features. It was reported that the partial demolition of black b was required to achieve a better relationship of level floor to ceiling heights, improve circulation and provide step-free access. Members were informed that the majority of the demolition of block b would cause no harm to the significance of the listed building - there would be some loss of historic fabric, however, this harm was considered to be less than substantial and outweighed by the wider public benefits of the scheme which included the sensitive re-use of the building, securing long-term conservation including enhancements to the historic fabric, provision of public access to the historic areas of the building and public exhibition spaces, contribution to a vibrant City offer and accommodation of visitors to the Culture Mile.

Members were shown images which illustrated the complexity of the existing building, the multiple levels between both block a and block b and also multiple levels within block b itself – hence the required demolition of the majority of that building to achieve level access throughout.

In terms of residential amenity, Officers reported that a full BRE daylight and sunlight assessment including a radiance analysis had been submitted to address the impacts of the proposal on surrounding residential premises, the closest being at 32, 35 and 37 Cock Lane. Members were informed that, at 32 Cock Lane, the majority of windows would be BRE compliant with just a few experiencing a minor adverse impact. It was highlighted that the two ground floor rooms would experience a moderate and a major reduction in vertical sky component but that this was due to the existing low level of VSC by reason of the substantial recess of the windows such that the absolute reductions varied between 0.2 and 0.7 and considered minimal. In respect of 35 Cock Lane, only one of the 36 windows assessed would be affected in excess of BRE guidance and would experience a minor adverse impact which was, again, a recess room at ground floor level where the absolute VSC reduction was only 0.6. In terms of 37 Cock Lane, all windows would meet BRE guidance. Officers added that the radiance assessments submitted also demonstrated that the absolute reductions to the most affected ground floor rooms would be minimal with a maximum average daylight factor reduction of 0.3. Members were informed that a cumulative impact assessment was also undertaken to also take into account the impact of the already approved City Cape House and demonstrated that the additional impact of this scheme at 5 Snow Hill would not be significant.

With regard to the adjacent commercial building at 6 Snow Hill, it was reported that the applicant had also undertaken a radiance assessment here which demonstrated that there would be no significant impact in terms of daylight to the office building and that these proposals would therefore not prejudice its continued use for commercial purposes. It was highlighted that the office plates at 6 Snow Hill did get light in from other principal aspects and not just the corner facing the application site.

In terms of transportation and highways, it was reported that the proposal would provide on-site long-stay and short-stay cycle parking in accordance with London Plan standards with the applicant also agreeing to fund additional short-stay cycle spaces to be provided in the public realm on Snow Hill. With regard to servicing, given that the applicant operated a consolidated servicing operation, the number of deliveries would be limited to an average of only two per day including waste collection. Members were informed that there would be restrictions within the Delivery and Servicing Plan secured by a legal agreement to a maximum of  14 deliveries per week and a maximum of three in any one day as highlighted within the late addendum published and circulated to all prior to this meeting. Given the constraints of the site and the retention of the facades of the listed building, it was reported that these deliveries would take place on-street which Officers considered to be acceptable directly from Snow Hill. Officers went on to draw Members’ attention to the fact that an amendment was required to condition 48 set out within the papers which currently restricted servicing to Monday-Saturday only. However, the hotel would require servicing seven days per week and it was suggested that the condition therefore be amended accordingly which was considered acceptable given the limited number of deliveries required and the fact that these were to take place on Snow Hill, away from any residents on Cock Lane. It was underlined that the overall number of vehicle trips generated by the new hotel would be less than that generated by the former police station which would have a beneficial impact on the highway network in general. Similarly, the pedestrian movements generated by the hotel use would not be significant with an estimated 63 trips in the morning peak and 91 in the evening peak – as such, the generous footways together with the existing levels of footfall could adequately accommodate the pedestrian movement arising from the proposed hotel use.

In terms of sustainability, Officers reported that the scheme proposed a highly sustainable energy system incorporating air source heat pumps and pv panels on the roof, resulting in a 68% reduction in carbon emissions. Members were informed that a 100% carbon offset payment would be secured through Section 106 in accordance with policy. The report commented that this would equate to £204,000 based on  the current design and carbon reduction but it was highlighted that this should be updated and amended to £362,000 based on the current carbon reduction proposed. It was reported that details of the payment would be finalised once the development was complete and the carbon reduction had been calculated and agreed. Officers went on to state that the proposal would achieve a BREAM ‘excellent’ rating in accordance with policy requirements and it was noted that there were challenges in meeting ‘outstanding’ due to the amount of existing building being retained. With regard to circular economy, Members were informed that 30-35% of the building was to be retained which was considered to be the optimal extent due to the complexity and multiple level changes in the existing block b building which would prohibit the delivery of a level access development through refurbishment alone. Conditions would be attached to ensure that 95% of excavation and construction waste be used for beneficial use in line with London Plan requirements and, similarly, the whole life cycle carbon emissions for the development were in line with GLA aspirational benchmarks and would also be secured by condition.

Officers went on to note that the proposal would also exceed the required urban greening factor of 0.3, incorporating a green and blue roof and a green wall and would also result in a biodiversity net gain as set out in the report. Members were informed that there had been late discussions about energy generators required on the site which were still ongoing as to whether these could be diesel generated or battery operated. Officers underlined that this was still a very new and evolving sector and that they would be looking at how emergency generators could be provided. An additional condition requiring the approval of details for the emergency generator would need to be submitted to and approved by the Local Planning Authority to explore all relevant options.

In conclusion, Officers reported that it was therefore considered that the proposal would provide a successful and sensitive reuse of this listed building to secure its long-term future. The provision of public access to the building and creation of an exhibition space will provide a valuable cultural offer and the provision of a new hotel delivering more diverse and affordable overnight accommodation for both tourists and business visitors would be a welcome addition to the Culture Mile and the Square Mile as a whole.

The Town Clerk invited Mr James Adam to address the Committee in objection to the proposals. Mr Adam began by stating that he was speaking out of care for the neighbourhood, the street, his property and the 25  businesses that had returned to work in it. He went on to state that he did not agree with the planning officers comments and felt that their conclusions often appeared to not match the analysis or the information that he had provided. Mr Adams clarified that four of the reasons why he asked that this application be refused, or at least deferred, were that firstly they failed to comply with too many government policies, that there was no demonstrable need for another hotel in this location, there were numerous documented cases of amenity harm and the scheme could not be delivered as drafted. Mr Adams felt that planning officers were dismissive of the loss of the existing police station uses justifying this by stating that it was sui generis, however, he was of the view that this had not been properly assessed or interrogated. Notwithstanding a use class, Mr Adam stressed that it was important for the Committee to consider what land uses were actually happening inside the building. He added that the contents of the building set out within the officers report could only be described as social and community or offices and that the officers conclusion of this being a sui generis use was therefore neither a reasonable, logical nor legal one to reach. However, reaching this conclusion enabled the planning officers to entirely overlook key important planning policies. Mr Adam argued that surely a police station’s function as its primary purpose was to serve the community and that it then followed logically that it must be a social and community use at present. With this in mind, Mr Adams felt that the officers report should address much more fully Policy DM22.1 but it failed to do so with this policy not even being listed in Appendix 2.

Mr Adam went on to argue that similarly, and applying the same logic, a substantial part of the building was in office use for police staff and this application therefore constituted a change of use and should address Policy DM1.1 which had, again, not been considered or included within Appendix 2. Even if these policy hurdles were to be overcome, Mr Adam noted that the City had clear targets as set out in policy CS1 of the Local Plan to substantially increase office floorspace in the City. However, once again, officers appeared to be dismissive of this key policy. Mr Adam was of the view that, for these reasons, it was not appropriate for the City to permit a change of use to C1. Further to this, Mr Adam affirmed that he was of the view that another hotel was not needed in this small corner of the City. He shared a map with Members on-screen showing four other hotels surrounding the site which had recently been approved and provided over a thousand rooms between them. He added that if any of these were not consented it would merely be further evidence that the market was saying that more hotels were not needed. Planning officers and other City reports noted that there was a strong likelihood that the City would meet its hotel requirements under the London Plan. Given this and the high density of hotels in the immediate area,  Mr Adam argued that this scheme compromised the balance and mix of uses in the immediate locality, putting the proposals in conflict with policy DM 11.3.Mr Adam continued by stating that this scheme, which required Members to overlook too many policies breaches was surplus to requirements and wrong for the community. He recognised that the officers report set out many illustrations of harm to local neighbours but concluded with the blanket statement that these were acceptable.

Mr Adam underlined that one of his many amenity worries was servicing – noting that the Snow Hill front was extremely tight but would be expected to cope with all guests, staff, goods and waste movement. As an experienced hotelier, Mr Adam questioned whether limiting goods and waste to three movements per day was even remotely achievable. In addition, policy 16.5 of the Local Plan required on-site servicing and, as most of the Cock Lane building was to be demolished, Mr Adam felt that this policy should have been examined much more rigorously. He argued that there was no justification for this highly unusual servicing arrangement. Finally, Mr Adam argued that the proposals as currently drafted could not be constructed as this would require trespass on or over his land. He added that planning officers had been advised of this and had responded  to suggest that this was not a planning concern and that this could be resolved by use of abseiling (which would still constitute trespass)  or new construction methods which he had been advised were simply not feasible. He stated that it would surely not be reasonable or in the City’s best interests to grant planning permission for a scheme that could not be achieved. Mr Adam drew Members’ attention to the site location plan included within the officer report, noting that there was a similar map contained within the Construction Environment Management Plan which showed that officers and the applicant considered the entire Snow Hill frontage of his building to be part of the development site. Mr Adams underlined that to obstruct the front of his building for a potential two year period would cause immense harm to his operations and to all of the SME’s within the property – SMEs that were the foundation of the City’s future and contributed in so many ways to the vibrancy and life of the area. Mr Adam reported that he operated flexible occupancy agreements and that this proposal would cause many businesses to leave and cause long-term harm. Mr Adam concluded by asking that this application be refused or at the very least deferred to ensure that officers had properly assessed and considered these proposals against additional key relevant policies that had so far been dismissed or ignored.

Seeing no questions of Mr Adam, the Town Clerk invited Mr Jonathan Langdon of Whitbread to address the meeting on behalf of the applicant. Mr Langdon introduced himself as being responsible for property acquisitions in central London for Whitbread and stated that he was pleased to present today’s plans to sensitively redevelop the former police station at 5 Snow Hill into a 219 bedroom Hub by Premier Inn hotel. Mr Langdon reported that he was joined today by key members of the project team who would assist in responding to any technical or operational questions.

As a brief introduction, Mr Langdon highlighted that Whitbread was a focused hospitality business listed on the London Stock Exchange and the UK’s largest hotelier that owned and operated two major brands – Premier Inn and a sister brand, Hub by Premier Inn which was what was proposed here. He went on to  talk of the core offer of Premier Inn – affordable, well-managed hotel accommodation and underlined that the Hub by Premier Inn brand shared the same ethos in terms of standards, service and affordability but was highly technology led and focused on the most central and connected city locations. As such, it offered guests a smaller bedroom and lighter touch food and beverage offering compared to Premier Inn and primarily targeted business travellers and leisure guests wanting to make the most of their time in the City. The Committee were informed that there were currently 11 Hub by Premier Inn hotels in London, two of which were in the City with the brand looking to continue to grow their network in select locations where it was believed that there would be long-term demand for this style of affordable and accessible accommodation. Mr Langdon stated that the application to redevelop Snow Hill was a Whitbread led development and one which would be realised if granted today. He reported that the site had been purchased from the City Corporation in January 2020 and that, since then, the applicant team had been working diligently, openly and in close consultation with City planning and heritage officers, with their neighbours, Historic England and other relevant stakeholders on the proposals.

Mr Langdon reported that the team had noted the issues raised by the objectors and that they would be happy to address these today. Furthermore, at the request of officers and as already touched upon today, a detailed radiance study had been produced which further confirmed and supported the conclusions set out within the daylight/sunlight report. He added that the heritage-led design process pushed Whitbread as a business to create a hotel which went beyond its brand standards. Architecturally, the proposed hotel would retain the most significant architectural features of the historic Snow Hill block and the sensitive extension that Axiom Architects had designed would sit comfortably against the listed building and local context. It was proposed that the fabric of the existing building be re-used  wherever possible and it was reported that the team had worked hard to engineer an energy and water efficient building.

Mr Langdon closed with some words on the proposed contribution of the hotel to the City  and on the need for a new hotel in this location. He reported that, on opening, the hotel expected to directly employ approximately 50 team members that would be recruited locally through relationships with Job Centre Plus and via other local agencies, networks and channels. He added that Whitbread were committed to providing training and apprenticeship opportunities both during construction and operational phases. He added that the hotel would provide an opportunity for the building to be opened to the public for the first time and would also have a significant economic impact on the City as guests to the hotel went out to meet, eat, drink, do business, visit attractions, appreciate culture and generally enjoy everything that the City had to offer. As well as being a use that would support the City’s Culture Mile initiative, Whitbread were also pleased that they would be playing an active role in this through their proposed exhibition facility within the hotel. The economic assessment submitted as part of the application calculated the potential benefit t £8.5 million per annum of which approximately £3.6million was expected to be spent in the local neighbourhood. Occupancy wise, Whitbread had originally appraised the hotel as achieving 84% occupancy and, although Mr Langdon reported that hotel occupancy rates were not currently at these levels, evidence from Whitbread’s customer bookings and web searches showed that demand for their hotels in central London and in the City was returning, especially amongst leisure users. He added that visits to the company’s website were, in fact, currently up by 15% when compared with 2019 levels with specific enquiries around central London. Mr Langdon stated that there was no doubt in his mind that the affordable and accessible hotel designed for Snow Hill would appeal to both leisure and business guests.

In closing Mr Langdon thanked officers for their guidance and professionalism over the past 18 months which had been challenging for all. He reported that the applicant was now in the final stages of agreeing the Section 106 and that their objective was to commence as soon as possible to realise this fantastic scheme.

The Chair thanked Mr Langdon for his contribution and welcomed any questions that Members might now have of him and the applicant team.

A Member noted that Mr Adam had suggested that it was not possible to proceed with the development without trespassing/encroaching upon an adjoining curtilage. He asked the applicant to comment on this and to demonstrate how it would be possible to avoid this. The applicant team responded to assure Members that they had no intention of trespassing and that the buildability of the scheme was subject to a neighbourly agreement for which negotiations were still underway.

Another Member asked if the applicant team could comment further on the site compound which the Committee were told was going to block 6 Snow Hill. The applicant team highlighted that the Environmental Management Plan showed a compounded area to the front and to the rear with one on Snow Hill and one on Cock Lane. It was reported that the compound to the front on Snow Hill would be subject to all City of London permits and permissions and that there was no intention to impact upon other businesses. It was reported that, if the applicant were successful in their negotiations with BeauMont Business Centre, then the compound would be moved off of Cock Lane in so far as possible to allow vehicle and pedestrian traffic to pass.

Another Member referred to the servicing plan and questioned how many vehicle trips this hotel alone would generate, if the applicant were not to consolidate deliveries with their existing hotel nearby. She also asked what would happen in terms of the consolidation of deliveries should the applicant sell the nearby hotel they currently owned. Neil Rowe of RGP reported that he had worked hard with both the City and the hotel operator to ensure that deliveries could be fully consolidated and that, as a result of these detailed discussions, there would not be any additional delivery vehicle movements servicing the proposed hotel, with all deliveries to be synchronised and consolidated/co-ordinated with the West Smithfield Premier Inn hotel which was under the same hotel operator. Deliveries would form part of existing vehicle routing within the City to both the West Smithfield hotel and other hotels operated by Whitbread in the City. Mr Rowe added that this detail had been put forward as part of the planning application with deliveries to the new hotel averaging at two per day and a maximum of 14 per week. Members were informed that full details would be put forward as part of the Delivery and Servicing Management Plan which would be secured through the Section 106 agreement. The applicant team wen ton to state that, in the event that the hotel operator were to change at the West Smithfield site, the operator would be required to submit a revised Delivery and Servicing Plan that would propose and secure a consolidated delivery and servicing strategy. The team added that there were clearly other Whitbread operated hotels within central London and the City with whom a consolidated delivery and servicing regime could be established even if this could mean avoiding peak hours to comply with relevant policies. In these circumstances, the applicant was still satisfied that a maximum of 14 deliveries per week would be sufficient.

A Member questioned what would happen if the applicant were unable to achieve/negotiate an agreement with neighbours. The applicant reported that they had explored a number of options to avoid trespass on neighbouring land which included the use of crane-hung screening to enable demolition as well as oversail which, again, would be subject to neighbourly agreement. 

Seeing no further questions of the applicant team, the Chair invited questions of officers and for Members to now debate the applications.

The Deputy Chairman questioned whether officers could deal with the points raised by Adam as to policies such as DM 22.1 and how they would argue that these proposals were not in breach of these. Officers responded to highlight that reference to this particular policy was contained within paragraph 113 of the report which set out clearly that this was not considered to be a community use and that there was therefore no breach of this policy. Officers noted that Mr Adam had also made reference to policy DM 1.1 which concerned loss of office floorspace and underlined that, again, this was identified within the report (at paragraph 86) which set out that this scheme would not actually result in the loss of any office accommodation and was therefore compliant with policy in this respect.

Another Member spoke to note that the officer report suggested that this proposed development would result in ‘less than substantial harm’ from a heritage perspective – an assessment which he felt was correct on this occasion. He went on to state that a few police cells dating from 1926 and altered since then were of limited historical interest and unusable as part of any new scheme. He felt that their loss was therefore plainly justified, especially in view of the conservation benefits of the new scheme as clearly articulated by the Corporation’s Conservation Officer during recent site visits. The Member recognised that the report assessed the loss of light to neighbouring buildings as being acceptable and, in the case of the application being considered today, he also felt that this was correct. He remarked that the radiance studies clearly showed that the loss of light resulting from this development when compared with the present situation was marginal. The Member went on to comment that he felt that this application differed from others by not including pointless permeability or other gimmicks contrived to create non-existent public benefits which could be used to ignore planning policies. He described this proposed development as a sensible reuse of a difficult site which did not contravene policy and one which he felt able to support on its merits.

Another Member spoke to state that he was pleased that the previous speaker recognised the planning merits of this application and felt that he articulated these well, however, he disagreed with the generalities of his opinion around the City’s planning processes. He went on to state that he was of the view that this application would allow the building to be imaginatively reborn in a way that would hugely benefit the City of London and its economy going forward. He commented that the growth in the Culture Mile and the demand for this type of value for money hotel was well known. He commented that the current building was outmoded, outdated and not suitable for other purposes but in a good location from the point of view of servicing the City. He concluded by stating that he would therefore be supporting this application. 

Another Member questioned whether the issue around whether this building could actually be constructed if granted was a relevant planning consideration. The Comptroller and City Solicitor commented that the deliverability issue in terms of whether there may still be outstanding/unresolved neighbourly matters was not in itself a relevant planning consideration (even if these ended up not being resolved and the scheme was not capable of being built). Members were informed that there was case law to clarify this point.

Having fully debated the application and the associated listed building consent at Item 4a, the Committee proceeded to vote on the recommendations before them. The vote was conducted by rollcall led by the Town Clerk with those Members present and eligible to vote asked to also confirm that they had been present for and able to hear the entirety of this item.

Votes were cast as follows:    IN FAVOUR –  24 Votes

                                                OPPOSED –    0 Votes.

                                               There were no abstentions.

RESOLVED –

1. That planning permission be granted for the above proposal in accordance with the details set out in the attached schedule subject to:

(a)  Planning obligations and other agreements being entered into under Section 106 of the Town & Country Planning Act 1990 and Section 278 of the Highways Act 1980 in respect of those matters set out in the report, the decision notice not to be issued until the Section 106 obligations have been executed.

2.  That Officers be instructed to negotiate and execute obligations in respect of those   matters set out in ‘Planning Obligations’ under Section 106 and any necessary agreements under Section 278 of the Highway Act 1980.

3. That the accompanying application for listed building consent is granted (ref. 20/00933/LBC).