20/02385/FUL

The proposed development, by reason of the sites location outside of a town centre, opportunity area, CAZ or CAZ fringe location results in the inappropriate intensification of the existing hotel use and fails to meet the locational requirements of Policy 4.5 of the London Plan (2017). The extended hotel would fail to constitute a 'smaller scale' hotel use and is therefore contrary to Policy ED12 of the Lambeth Plan (2015).The proposed scale of the hotel use situated in this predominately residential, out of centre location, would result in harm the vitality and viability of the town centres, contrary to Policies 2.15 and 4.7 of the London Plan (2016), Policies ED6 and ED12 and the Lambeth Local Plan (2015), Draft Policies SD6 and E10 of the Draft London Plan (2019) and Draft Policy ED14 of the Draft Revised Lambeth Local Plan (Proposed Submission Version January 2020). In addition, the applicant has failed to demonstrate that there are no sequentially preferable town centre sites, and therefore has failed to demonstrate the suitability of this out of centre site for the proposed town centre use, contrary to the NPPF (2019).

The proposed basement level hotel accommodation, due to the limited size of the rooms, their poor levels of daylight, lack of outlook and poor levels of privacy would be substandard and would fail to deliver high quality indoor spaces or a high standard of amenity for future users. The proposal would therefore fail to meet the requirements for delivering high quality design. The rooms are not of sufficient quality to be able to be accredited for the National Quality Assessment Scheme. As such, the proposal is contrary to Policies ED12 and Q2 of the Lambeth Local Plan (2015), Policies 4.5 and 7.6 of the London Plan(2016), Policies ED14 and Q2 of the Draft Revised Lambeth Local Plan (2020) and paragraphs 124 and 127 of the NPPF (2019).

A hotel of the scale proposed (205 rooms) is not supported in this location and would result in significant and unacceptable additional activity and result in unacceptable harm to the existing balance and mix of uses though the introduction of a highly intensive commercial hotel use that is out of keeping with the current, predominantly residential character. The applicant has failed to adequately assess the likely amenity impacts arising from off-site pedestrian movements, taxi pick up and drop off, parking and servicing activities or to demonstrate that the noise generating events that are identified in the submitted Noise Assessment can be adequately managed to ensure the assumptions set out in the submitted assessment are met. It has therefore not been demonstrated that the proposal would sustain the existing stable neighbourhood in the vicinity of the site and its high quality, liveable residential environment nor respect local amenity, contrary to Strategic Objective 13 of the Lambeth Local Plan (2015). The proposal is therefore contrary to Strategic Objective 13 and Policies ED12 and Q2 of the Lambeth Local Plan (2015), Policy 4.5 and Policy 7.15 of the London Plan (2016), Draft Policy D14 of the Draft London Plan (2019) and Policies ED14 and Q2 of the Draft Revised Lambeth Local Plan (Proposed Submission Version January 2020).

The proposed development by way of increased car and van trips which would need to park on street during operation and the loss of 8 parking bays during construction would result in unacceptable impacts to on- street parking and exacerbate parking stress in the area. In addition, the proposed shared loading bay would result in a conflict between users seeking to access the bay thereby adversely impacting on traffic flows and leading to congestion on the local highway network. The proposal is therefore contrary to Policies T1, T6 and T8 of Lambeth's Local Plan (2015).

Insufficient evidence has been submitted to demonstrate the likely impacts of the excavation and construction of the proposed basement development can be adequately mitigated or that the mitigation measures that will be necessary to make them acceptable are acceptable in planning terms. It has therefore not been demonstrated that the construction impacts of the proposal in terms of noise would have an acceptable impact on the health and quality of life of neighbouring occupiers, contrary to Policies Q2 and T8 of the Lambeth Local Plan (2015), Policy 7.15 of the London Plan (2016) and Policy D14 of the Draft London Plan (2019) and Paragraph 180 of the NPPF (2019).

In the absence of a Unilateral Undertaking or a Section 106 Legal Agreement to secure the necessary mitigation measures identified in relation to impact on trees, highway and transport, carbon offset and employment and skills contribution, the proposal is contrary to Policies D4, T1, T2, T3, T6, T7 and T8 of the Lambeth Local Plan (2016), Policy 5.2 of the London Plan (2016), Policy SI 2 of the Draft London Plan (2019) and the Employment and Skills SPD (adopted 2018).