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To: sarah.considine@london.gov.uk 

Cc: jon.sheldon@london.gov.uk

From: andy.slaughter.mp@parliament.uk 

Re: Former magistrates' court site, 181 Talgarth Road, London W6.  

Planning Application 2020/00915/FUL 

12th September 2020 

Dear Ms Considine, 

I am writing in respect of the above application which was approved by the Hammersmith & Fulham Planning Committee in July (Application no2020/00915/FUL).  I believe it will shortly be before the Mayor to allow him the option of exercising his call-in powers given the significance of the site. I would encourage the Mayor to call in the application and to determine that it should not proceed. I attach a note of my submission to the H&F Committee which summarises my objections. I would add the following observations which I think are relevant to the Mayor’s judgement on the issue. 

The site is small and heavily constrained. Allowing a development of this scale has implications for traffic including on strategic roads, for the townscape in central Hammersmith and for the effect on neighbouring residential areas. The site is immediately alongside a complex junction on the very busy A4 trunk road as it passes through Hammersmith. Hammersmith Flyover and Broadway are adjacent to the site and are already subject to heavy and slow-moving traffic if not gridlock. Air quality for the residential buildings and schools along this part of the A4 is very poor and a growing cause for concern. 

The developers see the building as a landmark or gateway access to Hammersmith. With respect, neither is needed. Hammersmith centre has its own character, determined by well-known building such as St Paul’s Church, the Ark and indeed the Flyover, it does not need a tall hotel building of undistinguished appearance to define it. The town centre is predominantly defined by low or medium-rise buildings. It is substantial commercial centre with a high proportion of residential buildings of all tenures but there are only a few buildings over ten storeys – these are the exceptions and there is no wish to see them proliferate. 

This development is on the edge of the town centre. Therefore it is very close to – and looms over – a number of Victorian residential streets and other non-commercial areas, notably Margravine Cemetery. It is the widely held view of residents that it destroys the character of the area and is oppressive in its influence. 

For these and the reasons given in my attached submissions I ask that the Mayor refuse the application. 

Yours sincerely, 

Andy Slaughter MP  

 E.mail: mayor@london.gov.uk and Deputy Mayor for Planning, Regeneration and Skills, Jules.pipe@london.gov.uk

8th September 2020

Dear Mr Khan,

Re: Hammersmith and Fulham planning application 2020/00915/FUL

181 Talgarth Road, W6 – West London Magistrates Court site

I am writing to ask you to call in the above planning application, approved by Hammersmith and Fulham Council at a hearing on 21st July.

The objections have been well explained in letters to you from Ludolph van Hasselt of the Margravine Gardens and St Dunstan's Road Residents' Association, the Hammersmith Society and well over 100 local residents. 

I support the arguments in their letters summarized as follows:

(1) The proposed blocks are excessive in height. The 23 storey block will tower over the Broadway Centre buildings, which are supposed to be the tallest of all according to the (developing) Urban Development plan for Hammersmith town centre, as well as hundreds of residences.

(2) The massing of the blocks on this site is excessive, similar to the density of office blocks in parts of the City of London and Croydon. 

(3) There is no “breathing space” around this scheme, which is hemmed in by Talgarth Road and residential streets to the north, with Victorian 2 and 3-storey residential houses to the south.

(4) The Victorian houses, which include the conservation area of Barons Court and Margravine Cemetery are totally overwhelmed by the intrusive new blocks. It is an eyesore when viewed from the surrounding residential roads which are comprised by at least 1000 residential homes, churches, schools and public spaces.

(5) The Urban Development plan for Hammersmith calls for a “mixed use” plan for the site, offices and residential. Two hotels do not correspond to “mixed use”.

(6) The traffic movements and access to the site have not been properly considered and will grossly compound an already severe traffic problem in the area.

(7) As a result of the excessive height, excessive massing and cheek-by-jowel position of the proposed blocks there will be a large reduction in quality of life and residential valuefor the neighbouring houses. The houses will be overlooked, and overwhelmed by their tall new neighbouring blocks.

(8) Additional environmental impacts:

(9) The noise from the trains on the railway line will be reflected back to the residential roads on the south side. The reflection of light from windows of the north tower could intrude into the houses as well.

(10) Contrary to Hammersmith Council's policy to reduce the use of the internal combustion engine vehicles and in general all motor vehicles, this proposal will lead to a large increase in movements of cars, coaches, vans and lorries to and from the site. 

(11) There are already a great number of hotels in Hammersmith, including the Novotel aimed at the same market literally a stone's throw away, across the Talgarth Road.

(12) The employment opportunities offered by the hotels are not the kind of secure, high-value ones which Hammersmith Council would like to create. On the contrary they are low-paid, precarious jobs, often on zero hours contracts. We should not be encouraging an expansion of such jobs, particularly with Covid still sweeping through the UK, and likely to stay until a vaccine is found, if that does happen.

(13) Pedestrian access to and from the site is very bad. 

For the above reasons can I please ask you to call in the proposed plans for your own determination in the context of development in the whole of London?

Thank you for your kind attention to this crucial matter.

Yours sincerely,

Peter Wilson 

Planning Department 

Hammersmith & Fulham 

Council Town Hall 

King Street London W6 9JU 

Our Ref. 

Your Ref. 2020/00915/FUL 

20 May 2020

Dear Mr. Wilson 

Representations to Planning Application ref: 2020/00915/FUL at Hammersmith Magistrates Court. 

Landsec and their operating tenant AccorInvest, hereby submit representations in relation to the above planning application. 

The application proposes the erection of two hotel buildings (5no. to 23 storeys), to provide 842 hotel rooms; alongside ancillary facilities, including meeting rooms, restaurants, a bar, a gym and viewing platform. 

Planning application ref: 2020/00915/FUL is for: 

“Comprehensive redevelopment and erection of two buildings comprising hotel use (Use Class C1) with ancillary facilities; ancillary plant; servicing; cycle parking; creation of a public realm; wider landscaping improvements and enabling works” 

Background 

The current application is effectively a duplication of application 2019/00195/FUL which was submitted in January 2019, and following its removal from planning committee agenda in October 2019, remains undetermined. 

Our client submitted representations in relation to ref: 2019/00195/FUL on 15th March 2019 and 1st August 2019 (following a series of amendments to the scheme). Representations predominately focused on concerns regarding the size and scale of the proposed hotel development, in consideration of both hotel need, and of the Council’s strategic land use priorities. A number of technical queries regarding traffic impacts, affordable workspace and hotel management were also raised. 

As planning application ref: 2020/00915/FUL remains largely unchanged from planning application ref: 2019/00195/FUL, many of the above concerns remain.  

Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper 

Representations 

Having reviewed the application material available on the Council’s website, we have serious concerns regarding the application and wish to object to the above proposal. The grounds for making this objection are set out in detail below, and can be summarised as: 

— The Site should be considered for full or partial use as other forms of social infrastructure in the first instance, in accordance with London Plan Policy 3.16 and Draft London Plan Policy S1(G); — The proposed development does not include an element of housing, which is considered the Council’s “priority land use”; 

— There is insufficient need for a hotel of this size and scale; 

— The proposed development would have adverse traffic impacts; and 

— The application lacks sufficient information regarding how the hotel will be managed. 

Principle of Hotel Development 

Whilst the Site is located within the Town Centre, where there is “in principle” support for visitor accommodation; the Site currently comprises a piece of “social infrastructure” (as defined by London Plan Policy 3.16 and Draft London Plan Policy S1(G)) meaning that the Site should be “considered for full or partial use as other forms of social infrastructure before alternative developments are considered” (Draft London Plan Policy S1(G)). 

The definition of social infrastructure covers a range of services and facilities including: health provision, education, play, youth, recreation, sports, faith and emergency facilities. Whilst the applicant is proposing to provide meeting rooms, a viewing deck and a gym, these provisions are insufficient for the following reasons: 

— These provisions are ancillary to the primary use of the site as a hotel. There is no evidence to show that the applicant has explored social infrastructure uses “in the first instance”; rather, it appears that the applicant has retrospectively tried to incorporate some ancillary “social infrastructure” uses into the proposed hotel. Further information is required to demonstrate that the applicant has considered full or partial social infrastructure use in the first instance.

 — At present, it is challenging to establish whether ancillary spaces such as meeting rooms, the viewing deck and gym, can actually be considered “social infrastructure”. Insufficient information is provided as to these spaces will be publicly accessible (i.e. how will members of the local community access/book meeting rooms? Will these services be free of charge? How will these areas be managed to deal both with members of the public and hotel guests?). 

— If the Council are satisfied that these spaces are indeed pieces of “social infrastructure”, these areas equate to a very small portion of the overall development. An Area Schedule, outlining the areas of each ancillary use, should be provided so that this can be analysed in full detail. 

Lack of Housing 

Planning policy at the national, regional and local level seeks to optimise housing delivery, and provide housing within mixed use developments. Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper Throughout the Local Plan, housing is referred to as a “priority land use”, and it is clear that the Council has a Strategic Objective to increase the supply and choice of high-quality housing (including affordable housing) for local residents to rent or buy. 

Local Plan Policy HRA2 allocates the Site for: “mixed-use redevelopment, including office, retail, arts, cultural and leisure facilities and supporting infrastructure to help retain a strong commercial role for the Town Centre and increase its vitality and viability, and include the provision of housing for local people across a range of tenures and affordabilities” [our emphasis]. 

Draft London Plan Policy H1 explains that boroughs should: “optimise the potential for housing delivery on all suitable and available brownfield sites though their Development Plans and planning decisions”. Policy GG2 further states that “Local Planning Authorities must proactively explore the potential to intensify the use of land, including public land, to support additional homes and workspaces”. 

The proposed development seeks to provide an 842-bed hotel (with ancillary uses). For a site of this size, and a scheme of this scale, it is considered that the site should provide a greater mix of uses, particularly residential uses (including affordable housing) in accordance with Local Plan Policy HRA2 and Draft London Policies H1 and GG2. 

This is a Town Centre Site, making it a highly suitable location for high-density residential accommodation, with substantial affordable housing provision, in accordance with Draft London Plan Policy H1. 

Whilst the applicant has suggested that the site would be unsuitable for residential development (on the basis of it having poor air quality and high levels of background noise), no evidence has been submitted to support these claims. If it is determined by the Council that residential uses are not acceptable on this site, for the reasons outlined above, we contend that other uses should be explored (e.g. office or education), so that a truly mixed-use scheme is brought forward, as per the Site’s allocation. 

This latest proposal does not provide a true mix of uses; does not contribute to the Council’s strategic aim of maximising housing supply; and does not provide the residential accommodation required by Strategic Policy Area HRA2. The application therefore represents a missed opportunity to deliver much needed housing in the borough. 

Lack of Demand for Hotel Accommodation 

The 2017 GLA Report “Projections of demand and supply for visitor accommodation in London to 2050” (which forms part of the New London Plan evidence base) states that Hammersmith and Fulham has a demand for 1,430 hotel rooms between 2015 and 2041), which equates to 55 hotel rooms per year. This proposal, which seeks to provide 842 hotel beds, would provide 59% of the Councils’ need for hotel rooms over a 26-year period. 

The planning application is submitted alongside a Hotel Needs Assessment, prepared by PKF hotelexpert, which concludes that there is currently an undersupply of hotel accommodation in the area. However, the Needs Assessment does not take a number of consented schemes, and live planning applications into consideration. 

The Site is located in close proximity to a number of hotels, including the 630-bed Novotel London West, which is located immediately to the north of the Site (on the opposite side of Talgarth Road). Planning permission was granted in August 2017 for the redevelopment of Landmark House (approx. 400m from  Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper the Site), which will deliver up to 400 hotel rooms. There is also a pending planning application (ref: 2020/00150FUL) for the redevelopment of 3 Shortlands (approx. 160m from the Site), which could deliver 240 hotel rooms. If the latter is approved, these 3 schemes would deliver 1,482 hotel bedrooms (which equates to 103% of the LPA’s hotel demand up until 2041), within a very close proximity (as shown in Figure 1). 

Should this application be approved, there would be an over-concentration of visitor accommodation in the area. Hotel demand in the Borough should be met through a range of schemes, in various locations (within the three town Centres, Earl’s Court and West Kensington Opportunity Area and White City Opportunity Area (as per Local Plan Policy E3)), and not concentrated within just one of the Borough’s centres. Furthermore, the Borough’s overall hotel offer should be diverse, to meet varying needs and budgets. 

This over-concentration of hotel uses is particularly concerning given the current economic climate, and the impact of Covid-19 on the hospitality industry. As the submitted Hotel Needs Assessment predates the onset of the pandemic, it does not take it, or its long-term implications on the hotel market, into consideration.

In summary, the proposed development proposes a use for which there is insufficient need, at the expense of providing housing (including affordable housing), which is the Council’s priority land use. The submitted Hotel Needs Assessment does not include a thorough assessment of hotel developments under construction, hotels recently granted planning permission or applications that are currently pending determination; and therefore, fails to accurately assess existing, and upcoming, hotel supply. 

Figure 1: Hotels in Hammersmith Town Centre Hammersmith Magistrates Court (842 beds) (proposed) Landmark House (400 beds) (under construction) 3 Shortlands (240 beds) (pending determination) Novotel London West (630 beds) (operational) Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper Impact on 

Traffic 

The slip road from Talgarth Road going past the Site is already heavily congested at peak times, and with the addition of a hotel (and ancillary restaurants/bars), this is only going to increase, impacting upon access to the Broadway and ultimately access to our property and the local area. 

Hotel Management 

It is considered that a Hotel Management Plan should be submitted alongside this application, in order to ensure that the hotel is appropriately managed, with no adverse impact on residential amenity, in accordance with Local Plan Policy E1. This is particularly relevant given that the planning application proposes a publicly accessible viewing deck at roof level. Measures need to be put in place to ensure that this space is appropriately managed, to safeguard the amenity of both hotel guests and surrounding neighbours. Clarity is also sought as to how this space will be publicly accessible, and how arrangements will be made to facilitate members of the public accessing this space through the hotel. 

Conclusion 

In conclusion of the above, Landsec/Accor Invest are concerned that the proposals for the former Magistrates Court fail to accord with the development plan, insofar that the proposed development does not provide an appropriate or desirable mix of uses. As such, the application should be refused. We trust these representations have been duly made, but should you wish to discuss any of the issues raised, please do not hesitate to contact me. 

Yours sincerely, 

Nick Bates For and on behalf of LS Director Limited in its capacity as Director of Land Securities (Hotels) Limited 

 Tony Devenish AM 

(LB Hammersmith & Fulham, RB Kensington & Chelsea London SE1 2AA and City of Westminster) 

To:  Rt Hon Robert Jenrick MP Secretary of State for Housing, Communities and Local Government Ministry of Housing, Communities and Local Government 2 Marsham Street London SW1P 4DF 

Date: 3 August 2020

Re: Request for Call-In: Planning Application at West London Magistrates Court, 181 Talgarth Road, London Borough of Hammersmith and Fulham (local planning ref: 2020/00915/FUL) 

Dear Minister, 

I am writing with regards to the above application, and in support of the excellent submission by local residents (copy attached), to request you to call-in the above application. A resolution to approve the application, subject to referral to the Mayor of London, was recently passed by Hammersmith and Fulham planning committee on a split vote, in defiance of local, regional and national planning policy. There has understandably been substantial and cross-party opposition to this scheme from local residents, amenity groups, the London Forum, local MP Andy Slaughter, and ward councillors from both main parties. The proposal is an overdevelopment of this site, with excessive height, scale and density which will overwhelm the local area. Of particular concern is the proposed height of 23 storeys, when is even taller than the previously-submitted scheme. 

It will cause substantial harm to a number of important heritage assets, including the Barons Court Conservation Area, The Mall Conservation Area, locally listed The Ark and the Hammersmith Margravine Cemetery. It will also harm the amenities of homes south of the site in Margravine Gardens and St Dunstan’s Road, and north of the site in Shortlands, Linacre Court and Colet Gardens. It is unclear how such a small site with poor access will be able to accommodate the scale of this proposed scheme, with 842 hotel rooms. There is particular concern about coaches parking on local residential streets, whilst the additional traffic could cause significant strain on the Hammersmith gyratory. 

The proposed use of this site is also contrary to its local designation of a mixed use development with a presumption of ground floor commercial and much-needed housing on the upper floors. The current application therefore removes the opportunity to provide new homes for Londoners and to help meet London’s housing crisis. For these reasons I would therefore urge you to give strong consideration to this request from myself and local residents, and to call-in this application. 

Thank you for considering my submission. 

Yours faithfully, 

Tony Devenish 

Peter Wilson 

Planning Department 

Hammersmith & Fulham 

Council Town Hall 

King Street London W6 9JU 

Our Ref. 

Your Ref. 2020/00915/FUL 

20 May 2020

Dear Mr. Wilson 

Representations to Planning Application ref: 2020/00915/FUL at Hammersmith Magistrates Court. 

Landsec and their operating tenant AccorInvest, hereby submit representations in relation to the above planning application. 

The application proposes the erection of two hotel buildings (5no. to 23 storeys), to provide 842 hotel rooms; alongside ancillary facilities, including meeting rooms, restaurants, a bar, a gym and viewing platform. 

Planning application ref: 2020/00915/FUL is for: 

“Comprehensive redevelopment and erection of two buildings comprising hotel use (Use Class C1) with ancillary facilities; ancillary plant; servicing; cycle parking; creation of a public realm; wider landscaping improvements and enabling works” 

Background 

The current application is effectively a duplication of application 2019/00195/FUL which was submitted in January 2019, and following its removal from planning committee agenda in October 2019, remains undetermined. 

Our client submitted representations in relation to ref: 2019/00195/FUL on 15th March 2019 and 1st August 2019 (following a series of amendments to the scheme). Representations predominately focused on concerns regarding the size and scale of the proposed hotel development, in consideration of both hotel need, and of the Council’s strategic land use priorities. A number of technical queries regarding traffic impacts, affordable workspace and hotel management were also raised. 

As planning application ref: 2020/00915/FUL remains largely unchanged from planning application ref: 2019/00195/FUL, many of the above concerns remain.  

Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper 

Representations 

Having reviewed the application material available on the Council’s website, we have serious concerns regarding the application and wish to object to the above proposal. The grounds for making this objection are set out in detail below, and can be summarised as: 

— The Site should be considered for full or partial use as other forms of social infrastructure in the first instance, in accordance with London Plan Policy 3.16 and Draft London Plan Policy S1(G); — The proposed development does not include an element of housing, which is considered the Council’s “priority land use”; 

— There is insufficient need for a hotel of this size and scale; 

— The proposed development would have adverse traffic impacts; and 

— The application lacks sufficient information regarding how the hotel will be managed. 

Principle of Hotel Development 

Whilst the Site is located within the Town Centre, where there is “in principle” support for visitor accommodation; the Site currently comprises a piece of “social infrastructure” (as defined by London Plan Policy 3.16 and Draft London Plan Policy S1(G)) meaning that the Site should be “considered for full or partial use as other forms of social infrastructure before alternative developments are considered” (Draft London Plan Policy S1(G)). 

The definition of social infrastructure covers a range of services and facilities including: health provision, education, play, youth, recreation, sports, faith and emergency facilities. Whilst the applicant is proposing to provide meeting rooms, a viewing deck and a gym, these provisions are insufficient for the following reasons: 

— These provisions are ancillary to the primary use of the site as a hotel. There is no evidence to show that the applicant has explored social infrastructure uses “in the first instance”; rather, it appears that the applicant has retrospectively tried to incorporate some ancillary “social infrastructure” uses into the proposed hotel. Further information is required to demonstrate that the applicant has considered full or partial social infrastructure use in the first instance.

 — At present, it is challenging to establish whether ancillary spaces such as meeting rooms, the viewing deck and gym, can actually be considered “social infrastructure”. Insufficient information is provided as to these spaces will be publicly accessible (i.e. how will members of the local community access/book meeting rooms? Will these services be free of charge? How will these areas be managed to deal both with members of the public and hotel guests?). 

— If the Council are satisfied that these spaces are indeed pieces of “social infrastructure”, these areas equate to a very small portion of the overall development. An Area Schedule, outlining the areas of each ancillary use, should be provided so that this can be analysed in full detail. 

Lack of Housing 

Planning policy at the national, regional and local level seeks to optimise housing delivery, and provide housing within mixed use developments. Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper Throughout the Local Plan, housing is referred to as a “priority land use”, and it is clear that the Council has a Strategic Objective to increase the supply and choice of high-quality housing (including affordable housing) for local residents to rent or buy. 

Local Plan Policy HRA2 allocates the Site for: “mixed-use redevelopment, including office, retail, arts, cultural and leisure facilities and supporting infrastructure to help retain a strong commercial role for the Town Centre and increase its vitality and viability, and include the provision of housing for local people across a range of tenures and affordabilities” [our emphasis]. 

Draft London Plan Policy H1 explains that boroughs should: “optimise the potential for housing delivery on all suitable and available brownfield sites though their Development Plans and planning decisions”. Policy GG2 further states that “Local Planning Authorities must proactively explore the potential to intensify the use of land, including public land, to support additional homes and workspaces”. 

The proposed development seeks to provide an 842-bed hotel (with ancillary uses). For a site of this size, and a scheme of this scale, it is considered that the site should provide a greater mix of uses, particularly residential uses (including affordable housing) in accordance with Local Plan Policy HRA2 and Draft London Policies H1 and GG2. 

This is a Town Centre Site, making it a highly suitable location for high-density residential accommodation, with substantial affordable housing provision, in accordance with Draft London Plan Policy H1. 

Whilst the applicant has suggested that the site would be unsuitable for residential development (on the basis of it having poor air quality and high levels of background noise), no evidence has been submitted to support these claims. If it is determined by the Council that residential uses are not acceptable on this site, for the reasons outlined above, we contend that other uses should be explored (e.g. office or education), so that a truly mixed-use scheme is brought forward, as per the Site’s allocation. 

This latest proposal does not provide a true mix of uses; does not contribute to the Council’s strategic aim of maximising housing supply; and does not provide the residential accommodation required by Strategic Policy Area HRA2. The application therefore represents a missed opportunity to deliver much needed housing in the borough. 

Lack of Demand for Hotel Accommodation 

The 2017 GLA Report “Projections of demand and supply for visitor accommodation in London to 2050” (which forms part of the New London Plan evidence base) states that Hammersmith and Fulham has a demand for 1,430 hotel rooms between 2015 and 2041), which equates to 55 hotel rooms per year. This proposal, which seeks to provide 842 hotel beds, would provide 59% of the Councils’ need for hotel rooms over a 26-year period. 

The planning application is submitted alongside a Hotel Needs Assessment, prepared by PKF hotelexpert, which concludes that there is currently an undersupply of hotel accommodation in the area. However, the Needs Assessment does not take a number of consented schemes, and live planning applications into consideration. 

The Site is located in close proximity to a number of hotels, including the 630-bed Novotel London West, which is located immediately to the north of the Site (on the opposite side of Talgarth Road). Planning permission was granted in August 2017 for the redevelopment of Landmark House (approx. 400m from  Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper the Site), which will deliver up to 400 hotel rooms. There is also a pending planning application (ref: 2020/00150FUL) for the redevelopment of 3 Shortlands (approx. 160m from the Site), which could deliver 240 hotel rooms. If the latter is approved, these 3 schemes would deliver 1,482 hotel bedrooms (which equates to 103% of the LPA’s hotel demand up until 2041), within a very close proximity (as shown in Figure 1). 

Should this application be approved, there would be an over-concentration of visitor accommodation in the area. Hotel demand in the Borough should be met through a range of schemes, in various locations (within the three town Centres, Earl’s Court and West Kensington Opportunity Area and White City Opportunity Area (as per Local Plan Policy E3)), and not concentrated within just one of the Borough’s centres. Furthermore, the Borough’s overall hotel offer should be diverse, to meet varying needs and budgets. 

This over-concentration of hotel uses is particularly concerning given the current economic climate, and the impact of Covid-19 on the hospitality industry. As the submitted Hotel Needs Assessment predates the onset of the pandemic, it does not take it, or its long-term implications on the hotel market, into consideration.

In summary, the proposed development proposes a use for which there is insufficient need, at the expense of providing housing (including affordable housing), which is the Council’s priority land use. The submitted Hotel Needs Assessment does not include a thorough assessment of hotel developments under construction, hotels recently granted planning permission or applications that are currently pending determination; and therefore, fails to accurately assess existing, and upcoming, hotel supply. 

Figure 1: Hotels in Hammersmith Town Centre Hammersmith Magistrates Court (842 beds) (proposed) Landmark House (400 beds) (under construction) 3 Shortlands (240 beds) (pending determination) Novotel London West (630 beds) (operational) Land Securities (Hotels) Limited Registered in England & Wales no. 6046966 | Registered Office: 100 Victoria Street London SW1E 5JL | Printed on recycled paper Impact on 

Traffic 

The slip road from Talgarth Road going past the Site is already heavily congested at peak times, and with the addition of a hotel (and ancillary restaurants/bars), this is only going to increase, impacting upon access to the Broadway and ultimately access to our property and the local area. 

Hotel Management 

It is considered that a Hotel Management Plan should be submitted alongside this application, in order to ensure that the hotel is appropriately managed, with no adverse impact on residential amenity, in accordance with Local Plan Policy E1. This is particularly relevant given that the planning application proposes a publicly accessible viewing deck at roof level. Measures need to be put in place to ensure that this space is appropriately managed, to safeguard the amenity of both hotel guests and surrounding neighbours. Clarity is also sought as to how this space will be publicly accessible, and how arrangements will be made to facilitate members of the public accessing this space through the hotel. 

Conclusion 

In conclusion of the above, Landsec/Accor Invest are concerned that the proposals for the former Magistrates Court fail to accord with the development plan, insofar that the proposed development does not provide an appropriate or desirable mix of uses. As such, the application should be refused. We trust these representations have been duly made, but should you wish to discuss any of the issues raised, please do not hesitate to contact me. 

Yours sincerely, 

Nick Bates For and on behalf of LS Director Limited in its capacity as Director of Land Securities (Hotels) Limited