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    Planning Statement

    Challenger House, 42 Adler Street

    Prepared for

    Bridges Ventures Hotel Property Ltd

    June 2012

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    Contents1 Introduction 32 Site Description 53 Application Proposals 94 Planning History 125 Planning Policy 136 Planning Assessment 217 Conclusions 29

    AppendicesAppendix 1 - PhotographsAppendix 2 - Pre-Application Response LetterAppendix 3 - Letter issued to Residents/Adjoining Landowners

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    1 IntroductionThis Planning Statement is submitted on behalf Bridges Ventures in support oftheir application for a hotel development at Challenger House, 42 Adler Street.

    The proposal seeks the change of use of the existing office building to a hotel(Use Class C1) with associated external alterations including the provision ofrooftop plant, ground floor entrance canopy, and replacement windows anddoors, with car and cycle parking and servicing to rear.

    The site is located in a central position in the heart of Whitechapel, on theeastern side of the City Fringe, a mixed use area which is undergoing changeand regeneration.

    1.1 Application Content

    The planning application submission is comprised of the following material:

    Completed and signed 1APP application form including certificates. OS site plan with red at a scale of 1:1250 (ref. P_100 Rev D). Existing floor plans and elevation drawings (ref. P_101 Rev A, P_102 Rev

    A, P_103 Rev A, P_104 Rev A, P_105 Rev A, P_106 Rev A, P_107 Rev A,P_108 Rev A, P_109 Rev B, P_110 Rev B, and P_111 Rev A).

    Proposed site plan (ref. P_120 Rev D), floor plans and elevation drawings(ref. P_200 Rev A, P_201 Rev A, P_202 Rev A, P_203 Rev A, P_204 RevA, P_205 Rev A, P_206 Rev A, P_207 Rev C, P_208 Rev C, and P_209Rev A).

    Design and Access Statement. Planning Statement including draft Heads of Terms in Section 5. Transport Assessment. Energy and Sustainability Report.

    Environmental Noise Survey Report. Marketing and Employment Report. Servicing Management Plan. BREEAM Pre-Assessment Report. CIL Declaration form

    In this Planning Supporting Statement, the site context is described in section 2;the proposals for the site are outlined in section 3; the planning policy context insection 4; the planning assessment in section 5; and the conclusions in section6. Supporting material is provided in the appendices as listed.

    1.2 Bridges Ventures

    Bridges Ventures Hotel Property Ltd is financially backed by Bridges VenturesLLP. Bridges Ventures LLP (Bridges), which celebrates its 10th anniversarythis year, is an innovative specialist fund manager dedicated exclusively tousing an impact-driven investment approach to create superior returns for bothinvestors and society at-large. Since launch, the firm has raised funds totallingalmost 275m, which invest in growth businesses, sustainable property andsocial enterprises. The launch of its most recent fund, Sustainable GrowthFund III, in December 2011 attracted 72m for its first closing; this figurematched the final close for Bridges Sustainable Growth Fund II. BridgesVentures Hotel Property Ltd will be funded from the Bridges Sustainable GrowthFund III.

    The Bridges Sustainable Growth Funds back ambitious management teams

    and invest in growth businesses across the four impact themes of UnderservedAreas, Education & Skills, Environment and Health & Well-being. The Funds

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    typically invest up to 10m at a time in ambitious, entrepreneurial businessesincluding early stage, growth capital and buyouts / buy-ins. Since 2002, theseFunds have made equity investments totalling over 75m in 34 businesses. Arecent exited investment from these funds was the Hoxton Hotel on GreatEastern Street which Bridges supported at inception and which delivered

    13.3m to Sustainable Growth Fund I (IRR 47%, 8.8x total investment) and1.9m to Sustainable Growth Fund II (IRR 35%, 3.4x total investment).

    Bridges have made one other investment in the Whitechapel area BridgesSustainable Property Fund invested in The Curve on Fieldgate Street, a 65mstudent-led development opportunity in partnership with Chancerygate AssetManagement. Construction has now been completed and the developmentopens in summer 2012. It contains 339 student rooms, 9 private apartmentsand a Tesco Express.

    In June 2012 Bridges was announced as the winner of the 2012 FT/IFCSustainable Finance Award for Excellence in Sustainable Finance and as jointwinner of the Sustainable Investor of the Year category. The FT/IFC

    Sustainable Finance Awards are the major global awards for environmentallyand socially responsible banking and investment and this year attracted 161entries from 145 financial institutions and 36 non-financial groups in 67countries.

    1.3 Qbic Hotels

    Qbic Hotels was established in Amsterdam where the first hotel wasestablished. The Qbic Hotel World Trade Centre Amsterdam was opened on 1July 2007 in order to test out the Qbic Hotel concept. The hotel was recentlyextended from 35 to 55 rooms in July 2009.

    Qbic Hotels have an ambitious business plan. By the end of 2019, Qbic Hotels

    intend to have a base of 18 low-cost, modular and flexible design hotels inmajor cities in the Netherlands, Belgium, Germany and the UK. By 2030, QbicHotels will have extended its leading position in the rapidly growing market ofinnovative budget-boutique hotels to over 150 hotels globally.

    Qbic Hotels have received the following awards:

    Best New Hotel Concept Venuez Awards 2007 Nominated Worldwide Hospitality Award MKG Group 2008 Audience winner 'Hotel of the Year' 2008 Green Globe 2012

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    2 Site Description

    2.1 Site Description

    The site comprises a self contained office building known as Challenger Housewhich is located at 42 Adler Street, arranged over lower ground, ground andfour upper floors with circa 7,227 (GEA) sq m and 6,691 sq.m (GIA) of floorspace. The building was constructed in the 1960s and refurbished in the 1980sand comprises an L shape form. The site area measures approximately 0.14 ha(1,470 sq.m).

    Figure 1: Site location plan extract (not to scale)

    Challenger House adjoins Cityside, an office building located at 40 Adler Street.Both properties share the car parking and servicing area to the rear.

    The property is not statutorily listed but it is located within Whitechapel HighStreet Conservation Area. The Bell Foundry building which is Grade II* listed.is located to the north east of the site on the corner of Whitechapel Road andPlumbers Row. Photographs of the site are included within Appendix 1.

    The property is partly vacant and is under utilised. The third and fourth floorshave been vacant since 2008 and the ground floor has been vacant sinceOctober 2011. The property has been subject to a comprehensive marketing

    exercise to find new tenants for the building since 2008. This exercise hasproved to be unsuccessful.

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    2.2 Surrounding Area

    The site is located within Whitechapel, off Whitechapel Road which is adesignated Red Route managed by Transport for London.

    To the north of the site is the Cityside offices building and beyond thisWhitechapel High Street. To the east of the site is Plumbers Row andresidential uses, to the south of the site is Mulberry Street with residential uses,and some businesses. To the west is Altab Ali Park and further residentialdevelopment with the Whitechapel Gallery located along the High Street.

    The area is characterised by a mix of uses including offices, education uses,student housing, retail, residential and hotel uses (refer to plan below).

    We are aware that planning permission has also recently been granted in March2011 for a new mixed use scheme in the near locality at 57-59 WhitechapelRoad & 85 Whitechapel Road (comprising Magenta House). The planningpermission is for:

    Demolition of the existing buildings at Magenta House and 57-59Whitechapel Road to provide 187 rooms of student accommodation withancillary facilities in three separate blocks ranging in height from 5 to 6storeys; erection of 2 x four storey commercial buildings frontingWhitechapel Road (adjoining nos 63 and 83 respectively) to provide A1(retail) use on ground floor & B1 (office) uses on 1st-3rd floors & provisionof two disabled car parking spaces.

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    There are a number of hotels located in the surrounding area, which aredetailed on the map below.

    Figure 2: site and nearby hotels

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    Key

    Application Site

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    2.3 Transportation

    The site is served by a number of nearby transportation links including accessto the Metropolitan, Circle, Hammersmith and City, and District undergroundlines via Aldgate and Aldgate East stations, overground rail services via

    Whitechapel Station and access to mainline national rail networks via LiverpoolStreet, London Fenchurch and Shadwell Stations (see Figure 2 below- with sitemarked with blue rectangle).

    Figure 3: Map illustrating transport links

    Whitechapel will become a key station due to the 10 billion Crossrail projectwhich will enhance Londons transport network providing a rapid east-west trainline through Central London from Maidenhead to Shenfield. The link willdramatically reduce journey times as well as bringing a welcome boost to theLondon economy.

    The site is located within a level 6a public transportation accessibility level(PTAL) area, which means that the site benefits from extremely goodaccessibility levels.

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    3 Application ProposalsThe proposal is for the conversion of the existing building to provide a fivestorey hotel development providing 187 bedrooms.

    Aside from the change of use and the internal reconfiguration of space, theapplication also proposes the following external works to the building andservicing areas:

    Replacement and provision of rooftop plant; Provision of a glazed canopy at ground floor level; Replacement/creation of windows and doors; Infilling of some existing windows on the courtyard-facing elevations; Provision of 14 cycle parking spaces in servicing area to rear; and Provision of 10 car parking spaces to rear including 1 disabled car parking

    space.

    The scheme is being branded with the following characteristics:

    Boutique-hotel, offering very affordable, clean, secure and best basicshotel amenities for both business users and tourists.

    Easy to book and use, offered at convenient locations in larger urbanenvironments.

    Several unique and proprietary concepts (e.g. Cubi TLC rooms, Q-loungewith social hosts, active social networking interaction).

    People-focused approach, building around several unique, guest orientedcornerstone concepts like the Cubi furniture pod and the Q-loungeconcept.

    3.1.1 Cubi Room

    The use of local material will be sourced and used where possible. However,the design of Qbic Hotel is based on the use of the Cubi Room concept. TheCubi Room itself is a pre-fabricated unit which can be easily transported andassembled on site and dismantled and reused. The Cubi Room is a highlyversatile and sustainable product in its own right.

    The Cubi concept is based on a cubically shaped living unit that combines avariety of features. On a limited surface area, the Cubi can integrate sleeping,hygiene, working and cooking. The composition of elements like kitchen, bed,bathroom, storage, and working space can be selected by the client. Becauseof its unique design, the Cubi remains recognisable, irrespective of the versionchosen. The Cubis design is variable and units can be installed anywhere. In

    addition, elements are easy to disassemble and reassemble elsewhere.

    The units are made from high-quality, durable and easy to maintain materials,which allow for easy repair should it be required.

    The Cubi unit is easy to connect to the main infrastructure of an (existing)building, requires minimal adaptation, and is quickly installed, including serviceconnections. This results in major savings from significantly reducedconstruction time.

    A passage with a door that meets the minimal dimensions is required fordelivery, after which construction of the Cubi in the room is completed withineight hours. The dimensions of the Cubi depend on the selected type and the

    number of 'elements'.

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    The Cubi is used in both permanent and semi-permanent constructions. TheCubi is a patented product.

    3.2 Pre-Application Discussions

    Pre-application discussions have been held with the Council to discuss theacceptability of the proposals.

    A meeting took place on 18 January with the following Officers in attendance:

    Mary OShaughnessy Planning Officer Richard Murrell Deputy Team Leader Matthew Lawes Highways Officer

    The follow-up advice letter from Mary OShaughnessy is provided at Appendix2.

    A brief summary of the discussions is set out below:

    3.2.1 Introduction to Qbic Hotels:

    Qbic has had an operational hotel in Amsterdam for c.4 years. The business model is to utilise vacant office space to convert to hotel use

    using the Cubi units, meaning the build can take 4-5 months. Reservations are taken over the internet. Sales are focussed on individual

    bookings rather than group bookings.

    3.2.2 Principle of Land Use:

    The site is within the Central Activities Zone. The loss of the existing office use needs to be justified by evidencing the

    lack of demand for the ongoing use of the building for offices. Specifically,the Council will require a marketing report that:i Clearly outlines what marketing of the building has taken place to date,

    which states the rental level the space was advertised at and how thiscompares to prevailing market rental levels.

    ii Reference to vacancy rates in the area.iii The availability of office space in the area.

    The marketing report should draw clear conclusions that there is nodemand for the office space offered by Challenger House based on theevidence presented.

    The proposed hotel use is acceptable in principle being an acceptable usewithin the Central Activities Zone with good transport links; and given thatthe site is not designated as a preferred office location.

    3.2.3 Transport and Highways:

    A Transport Statement will be required in support of the planningapplication.

    The application will need to provide details of the existing and proposedservicing arrangements.

    The proposal is that servicing will take place in the yard to the rear of thebuilding, though the exact demise is currently being confirmed.

    The car parking provision will need to be in accordance with LBTHsmaximum parking standards, which are set at a maximum of 1 space per 15bedrooms. However the preference will be for a car-free development as thePublic Transport Accessibility Level (PTAL) is 6a. Therefore, on-site carparking will need to be justified.

    At least 1 disabled car parking space will be required on site.

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    Cycle parking will need to be provided as per LBTHs standards. Separateareas will be required for guests and staff. Shower and changing facilitieswill be required for staff. LBTHs preferred cycle parking is Sheffield D-Stands, but there is scope for other types if necessary.

    LBTHs policy requires coach parking to be provided at 1 space per 100

    beds. The London Plan policy requires 1 space per 50 beds. If on-site coach parking cannot be provided, it will be necessary to

    demonstrate consideration of a sequential approach to an alternativesolution, which could include:i) Use of a lay-by for drop-off and pick-up and use of coach parking

    facilities elsewhere (e.g. the Tower of London);ii) Consultation with Transport for London on other options;

    Restriction on the use to prevent group bookings through a S106 legalagreement. This has been used elsewhere but is not favoured by LBTHslegal department.

    A travel plan would not be required for the proposal given the nature of thehotel use which results in a high turnover of guests; and as the applicationis not referable to the GLA.

    A draft servicing management plan should be submitted with theapplication.

    A construction method statement would not be required for the change ofuse scheme.

    3.2.4 Accessible Rooms:

    London Plan policy now requires 10% of the total number of rooms to beaccessible or adaptable for disabled users and the scheme will be requiredto meet this target.

    Consideration will need to be given to the room types (A, B and C) as perthe Mayors Draft Best Practice Guidance and what would be required.

    3.2.5 Energy:

    The proposal should be in accordance with the London Plan energyhierarchy.

    A BREEAM pre-assessment and energy report will be required for theapplication.

    3.2.6 Planning Obligations:

    Planning obligations should be assessed against LBTHs adoptedSupplementary Planning Document. The Heads of Terms are as set out inthe provided agenda, namely:i Employment, skills, training and local enterprise;

    ii Community Facilitiesiii Sustainable transport;iv Public Open Space;v Streetscene and built environment;

    3.2.7 Community Engagement

    It was agreed with LB Tower Hamlets that a public consultation exhibition wouldnot be required for this type of development. However, surrounding neighbourswill be informed of the submission of the application by a letter-drop. Anexample of the letter is included at Appendix 3.

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    4 Planning History

    Following a review of Tower Hamlets online planning records which date back

    to 2000; the following planning history has been identified for 42 Adler Street:

    Full planning permission was granted on 12 October 2006 for Change ofuse of ground floor of south wing from general offices (Class B1) to financialand professional services (Class A2) initially as a recruitment consultancy.(Application Reference: PA/06/01432).

    Full planning permission was granted on 21 November 2006 for Change ofuse of ground floor of south wing from B1 Offices to either B1 Offices or A2Financial & Professional Services. (Application Reference: PA/06/01785).

    Full planning permission and conservation area consent was granted on 21July 2009 for Removal of existing equipment and replacement with a new

    electrical sub-station cabin fixed to a new 3 metre by 3 metre concrete slabstructure at the junctions of Plumbers Row and Mulberry Street, E1.(Application Reference: PA/09/00399).

    A full set of planning history records are available at the Council offices.

    Given the planning history records above it is our view that the building benefitsfrom an existing Class B1 Use with Class A2 at ground floor.

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    5 Planning Policy

    5.1 Development Plan

    The Development Plan for the site comprises the saved policies in the TowerHamlets UDP (1998); the adopted Core Strategy DPD (September 2010); theManaging Development DPD (Submission Version May 2012); various InterimPlanning Guidance documents including the Aldgate Masterplan (2007) and theCity Fringe Area Action Plan (2007), which are used for development controlpurposes and the London Plan (2011).

    5.2 The London Plan

    The site is located within the Central Activities Zone (CAZ). The London Planidentifies that the Central Activities Zone is suitable for commercial developmentassociated with business, tourism and retail and provision for national andinternational agencies, institutes and services, subject to the protection of

    housing and identified special policy areas (Policy 2.10).

    Policy 4.5 Londons Visitor Infrastructure encourages the provision of 40,000net additional hotel bed spaces to be provided by 2031 and to improve thequality, variety and distribution of visitor accommodation. It also states that newhotel development should be focused within the CAZ and Opportunity Areasand other central/accessible locations.

    London Plan Policy 5.1 seeks to reduce Londons carbon dioxide emissions by60% (below 1990 levels) by 2025.

    Policy 5.2 states that development proposals should make the fullestcontribution to minimising carbon dioxide emissions, in accordance with the

    following hierarchy:

    Be lean: use less energy Be clean: supply energy efficiently Be green: use renewable energy

    Policy 5.2 sets out the Mayors carbon dioxide emissions reduction targets fornon-domestic buildings (minimum improvements on the Target Emission Rates(TER) as outlined in the national 2010 Building Regulations):

    2010 2013: 25% 2013 2016: 40% 2016 2019: As per building regulations requirements 2019 2031: Zero carbon

    Further, the Policy states that major development proposals should beaccompanied by a detailed energy assessment (the minimum requirements forenergy assessments are listed) which demonstrates how the targets for thereduction of carbon dioxide will be met against the above mentioned energyhierarchy.

    Policy 5.3 seeks to achieve the highest standards of design and construction, toimprove the environmental performance of buildings and mitigate against andadapt to climate change.

    Policy 5.5 sets out the Mayors target that by 2025, 25% of the heat and powerused in London to be generated through the use of localised decentralised

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    energy systems. To achieve this target the Mayor prioritises the development ofcentralised heating and cooling networks.

    Under Policy 5.6 development proposals should evaluate the feasibility of usingCombined Heat and Power (CHP) systems and where appropriate examine

    opportunities to extend such systems beyond the site boundary to adjacentsites. Further, major development proposals should consider the selection ofheating and cooling systems prioritising connection to existing systems overon-site systems.

    Under Policy 5.8 the Mayor supports and encourages more widespread use ofinnovative energy technologies to reduce use of fossil fuels and carbon dioxideemissions.

    Policy 5.10 encourages urban greening (i.e. development proposals integratinggreen infrastructure, such as tree planting, green roofs and walls and softlandscaping, to contribute to urban greening, including the public realm).

    Policy 6.13 details that the Mayors wishes to see an appropriate balancebetween new development and preventing excessive car parking provision,which could undermine more sustainable transport modes.

    Table 6.2, referenced in Policy 6.3, sets out the Mayors maximum parkingstandards. There is no specific standard given for hotel uses, but the followingare included:

    Use Maximum standards

    Space per sq m of gross floorspaceRetail Food (up to 500 m

    2) 35-50 (PTAL 4 to 2)

    Retail Non food 50-30

    Employment B1 600-1000Number of bedsResidential 1-2 beds: less than 1 per unit

    3-beds: 1.5 1 per unit4 or more beds: 2 1.5 per unit

    In addition, under Policy 6.3 developments must:

    ensure that 1 in 5 spaces (both active and passive) provide an electricalcharging point to encourage the uptake of electric vehicles

    provide parking for disabled people in line with Table 6.2. This requires 5 %of car parking capacity to be provided.

    meet the minimum cycle parking standards set out in Table 6.3

    provide for the needs of businesses for delivery and servicing.

    The planning decisions part of Policy 7.1 states (in part) that developmentshould:

    B be designed so that the layout, tenure, and mix of uses interface withsurrounding land and improve peoples access to social and communityinfrastructure...

    C. enable people to live healthy, active lives; maximize the opportunityfor community diversity, inclusion and cohesion; andcontribute to peoplessense of place, safety and security. Places of work and leisure, streets,neighbourhoods, parks and open spaces should be designed to meet theneeds of the community at all stages of peoples lives, and should meet the

    principles of lifetime neighbourhoods. D. The design of new buildings and the spaces they create should help

    reinforce or enhance the character, legibility, permeability and accessibility

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    of the neighbourhood.

    Policy 7.2 requires all new development to achieve the highest standards ofaccessible and inclusive design and supports the principles of inclusive design.

    Policy 7.3 seeks to create safe, secure and accessible environments.

    Policy 7.8 seeks to protect Londons historic environment and landscapes.

    Policy 7.19 states that development proposals should give sites of boroughimportance for nature conservation the level of protection commensurate withtheir importance.

    5.3 London Borough of Tower Hamlets

    5.3.1 Designation

    The site is designated within the LB Tower Hamlets (LBTH) UDP as:

    Central Activities Zone (Policy CAZ 1 and CAZ 4) - where a range ofCentral London Core Activities will be encouraged which foster Londonsrole as a financial, commercial, tourist and cultural centre. The Council willalso seek to maintain and enhance the varied and special character ofthese areas, to contribute to the social vitality particularly at ground floorlevel and to maintain a balance of uses.

    Whitechapel High Street Conservation Area where the character and theappearance of the conservation area will need to be preserved.

    In the Core Strategy, the site is located within the Aldgate Sub area. The Visionfor this area states:

    Rediscovering its gateway role as a mixed use, high density area with acommercial centre

    Aldgate will rediscover its gateway role, acting as an area of transition betweenthe City of London and the East End. With this, it will become an importantplace where large-scale office uses cluster around the transport interchange atAldgate, alongside a consolidated London Metropolitan University. Associated

    residential, commercial and evening uses will come, forward ensuring a mixed-use area that is lively both during the day and at night.

    High-quality public spaces will be provided along with a new park atBraham Street. It will be easier and safer to walk around with the removal of thesubway network, and its mix of architecture will reflect the transition from theCity to the East End.

    In the City Fringe Area Action Plan and the Interim Guidances proposals map,the site is located within the City Fringe Sub Area as:

    - Development Site (CF40) for Employment (B1), Residential (C3), Retail(A1, A2, A3, A4), Public Open Space. Minimum Open Space size 0.1ha, should be delivered through the implementation of the AldgateMaster Plan, by allocating Site CF40 for open space within the AAP.

    In the Aldgate Masterplan, the site is not allocated for any particular use. Theindicative land use zones surrounding the site are identified for:

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    Cultural and tourism uses will be focussed on the area around Altab AliPark, Whitechapel Art Gallery, Osborn Street and northwards along theBrick Lane corridor, towards Banglatown; and

    Higher education uses associated with London Metropolitan University will

    be focused in a new campus in the area north of Commercial Road andsouth of Whitechapel Road.

    5.3.2 Employment

    UDP Policy EMP 3 states that proposals for the change of use of outmoded orsurplus office floor space to Non B class uses, the council will take the followingmatters into account i) the length of time the property has been vacant and arequirement to demonstrate the property has been actively marketed; ii) thelevels of offices space in the area; iii) whether the property has servicingarrangements suitable for other Class B uses and iv) whether the proposals arein line with other policies within the plan.

    This policy approach is continued in the emerging Managing DevelopmentDPD. Draft Policy DM15 states:

    The upgrading and redevelopment of employment sites outside of spatial policyareas will be supported. Development should not result in the loss of active andviable employment uses, unless it can be shown, through a marketing exercise,that the site has been actively marketed (for approximately 12 months) and thatthe site is unsuitable for continued employment use due to its location,accessibility, size and condition.

    5.3.3 Hotels

    UDP Policy ART 7 identifies that favourable consideration will be given toproposals for major hotel development (30 or more beds) within the CentralArea Zone.

    Core Strategy Policy SP06 seek to concentrate hotels, serviced apartments andconference centres, to attract visitors and promote tourism in the borough, inCentral Activities Zone (CAZ), City Fringe Activity Area, Canary Wharf ActivityArea and Major and district centres.

    AAP Policy CFR9 identifies that large scale development will be supportedwithin the City Fringe Sub Area.

    Policy DM7 states that the Council will support the development of visitoraccommodation where:

    a. the size is proportionate to its location within the town centre hierarchy;b. there is a need for such accommodation to serve visitors and the boroughseconomy;c. it does not compromise the supply of land for new homes and the Councilsability to meet its housing targets;d. it does not create an over-concentration of such accommodation or causeharm to residential amenity; ande. there is adequate road access and servicing for coaches and other vehiclesundertaking setting down and picking up movements.

    5.3.4 Parking

    London Plan Policy 6.13 seeks an appropriate balance between promoting new

    development and preventing excessive car parking provision that canundermine cycling, walking and public transport use. This approach is reiteratedin the

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    Core Strategy Spatial Policy 09(4) reiterates the London Plan approach, whichpromotes car-free development to minimise on-site and off-site car parkingprovision and help address issues of congestion and air pollution.

    Core Strategy Spatial Policy 09 promotes car-free development, in order to

    minimise on-site and off-site car parking provision and help address issues ofcongestion and air pollution.

    Draft Policy DM22 of the Managing Development DPD continues to support asustainable approach to parking by encouraging permit-free parking in areas ofgood public transport.

    5.3.5 Design

    Core Strategy Spatial Policy 10 details the Councils requirements for goodquality design.

    Part 2 of Policy 10 seeks to protect and enhance the boroughs built heritage

    and historic environment. Part 3 of the policy states that this will be achievedthrough:

    Promoting and implementing placemaking across the borough toensure that the locally distinctive character and context of each place isacknowledged and enhanced.

    Protecting, conserving, and promoting the beneficial reuse of, oldbuildings that provide suitable locations for employment uses, includingsmall and medium enterprises.

    Encouraging and supporting development that preserves and enhancesthe heritage value of the immediate and surrounding environment andthe wider setting.

    Part 4 of Policy 10 specifically promotes good design principles, throughensuring development:

    Protects amenity, and promotes well-being; Uses design and construction techniques to reduce the impact of noise

    and air pollution; Respects its local context and townscape, including the character, bulk

    and scale of the surrounding area; Contributes to the enhancement or creation of local distinctiveness; Is flexible and adaptable to change; Uses high quality architecture, urban and landscape design; and Assists in creating a well-connected public realm that is easy and safe

    to navigate.

    Part 5 of Core Strategy Spatial Policy 10 and Policy DM26 identify Aldgate asappropriate locations for tall buildings.

    Policy DM24 provides further detail on the key elements of good design thatshould be considered at all scales of development. These include:

    a. ensuring design is sensitive to and enhances the local character andsetting of the development, taking into account the surrounding:

    i. scale, height, mass, bulk and form of development;ii. building plot sizes, plot coverage and street patterns;iii. building lines and setbacks, roof lines, streetscape rhythm and other

    streetscape elements;iv. design details and elements; andv. natural environment.

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    b. ensuring the use of high quality building materials and finishes;c. ensuring the internal design and layout of development maximisescomfort and usability for occupants and maximises sustainability of thedevelopment;

    d. ensuring development is designed to be easily adaptable to differentuses and the changing needs of users;e. protecting features of positive value within the site; andf. taking into account impacts on microclimate.

    Further, we note supporting paragraph 24.5 states that development shoulddemonstrate its potential for adapting to ensure the long-term sustainability andbeneficial re-use of development.

    Policy DM25 (Amenity) provides details on the amenity requirements thatdevelopments need to comply with. The policy states that development will berequired to protect, and where possible improve, the amenity of surroundingexisting and future residents and building occupants, as well as the amenity of

    the surrounding public realm.

    5.3.6 Heritage Assets and Conservation

    Core Strategy Spatial Policy 10 details a range of Heritage Assets that exist inthe borough and their contribution to the character, history and heritage ofTower Hamlets.

    Policy DM27 states that the Council will seek to protect and enhance theboroughs heritage assets.

    We note that applications for development within a heritage asset will only beapproved where:

    a. it does not result in an adverse impact on the character, fabric or identity ofthe heritage asset or its setting;b. it is appropriate in terms of design, scale, form, detailing and materials in itslocal context;c. it enhances or better reveals the significance of the asset or its setting;d. opportunities to mitigate or adapt to climate change through the re-use oradaptation are maximised; ande. in the case of a change of use, a thorough assessment should be carried outof the practicability of retaining its existing use and the wider benefits of theproposed use.

    The supporting text in paragraph 27.3 states that the Council will require an

    application to demonstrate an understanding of the significance of the relevantasset or its setting.

    5.3.7 Sustainability

    Core Strategy Spatial Policy 11 details the Councils requirements to achieve aborough wide carbon reduction target of 60% below the 1990 levels by 2025.The policy encourages the integration of renewable energy technologies on-siteto provide the highest achievable CO2 savings where feasible.

    Policy DM29 sets out the Councils target for renewable energy generation. Part3 of the policy states that the Council will support the sustainable retrofitting ofexisting development with provisions for the reduction of carbon emissions.

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    5.4 Hotel Capacity Figures

    The London Borough of Tower Hamlets produced a Retail and Leisure CapacityStudy in January 2009. The GLAs report: Demand and Capacity for Hotels andConference Centres in London (2002) found that there were around 1,500 hotel

    bedrooms in the Borough and that this was set to more than double. The largenumber of office developments proposed in the Borough is likely to increasehotel demand. The document does not set out any capacity figures for hotels;however it states that It is likely that there will be demand for new hotels up to2017.

    5.5 National Planning Policy

    Regard has been given to the National Planning Policy Framework (NPPF)(published 27 March 2012), which sets out the Governments planning policiesfor England and how these are expected to be applied. It is a materialconsideration in planning decisions.

    5.5.1 The Purpose of the Planning System

    The purpose of the planning system is to contribute to the achievement ofsustainable development (para 6) to which there are three dimensions:economic, social and environmental (para 7). As such, economic, social andenvironmental gains should be sought jointly and simultaneously through theplanning system (para 8). Thus and as is stated at paragraph 9, pursuingsustainable development involves seeking positive improvements in the qualityof the built, natural and historic environment, as well as in peoples quality oflife.

    5.5.2 Presumption in Favour of Sustainable Development

    At the heart of the NPPF is a presumption in favour of sustainable development(para 14; see also paras 187 and 1971). Paragraph 14 sets out that for decision

    making this means:

    approving development proposals that accord with the development planwithout delay; and

    where the development plan is absent, silent or relevant policies are out-of-date, granting permission unless: any adverse impacts of doing so would significantly and demonstrably

    outweigh the benefits, when assessed against the policies in thisFramework taken as a whole; or

    specific policies in this Framework indicate development proposalsshould be restricted.

    5.5.3 Building a Strong, Competitive Economy

    Under Building a strong, competitive economy (paras 18 - 22), the NPPF setsout (with our emphasis added) that:

    The Government is committed to securing economic growth(para 18);

    The Government is committed to ensuring that the planning system doeseverything it can to support sustainable economic growth. Planning shouldoperate to encourage and not act as an impediment to sustainable growth.

    1

    Paragraph 197 is notable in that it states when assessing and determiningdevelopment proposals, local planning authorities should apply the presumptionin favour of sustainable development.

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    Therefore significant weight should be placed on the need to supporteconomic growth through the planning system. (para 19); and

    To help achieve economic growth, local planning authorities should planproactively to meet the development needs of business and support an

    economy fit for the 21st century(para 20);

    5.5.4 Requiring Good Design

    Paragraph 56 sets out that the Government attaches great importance to thedesign of the built environment, continuing Good design is a key aspect ofsustainable development, is indivisible from good planning, and shouldcontribute positively to making places better for people.

    Paragraph 58 states that decisions should aim to ensure that developments(among other things) will function well and add to the overall quality of theareaand are visually attractive as a result of good architecture andappropriate landscaping, with paragraph 60 stating that decisions should not

    attempt to impose architectural styles or particular tastes and they should notstifle innovation, originality or initiative through unsubstantiated requirements toconform to certain development forms or styles

    5.5.5 Conserving and Enhancing the Natural Environment

    We also note that paragraph 111 states that decisions should encourage theeffective use of land by re-using land that has been previouslydevelopedprovided that it is not of high environmental value.

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    6 Planning AssessmentThis section of the Planning Statement provides an assessment of the proposeddevelopment against relevant national, regional and local planning policies. We

    detail below our planning analysis under the following headings:

    Loss of Office Space; Principle of Hotel Use; Economic and Social Benefits Conservation and Design; Transportation; Energy and Sustainability; and Noise

    6.1 Loss of Office Space

    The site comprises existing offices and is allocated within Interim Planning

    Policy for mixed use development as Development Site (CF40) which proposesEmployment (B1), Residential (C3) and Retail (A1, A2, A3, A4) uses with publicopen space. However, the Proposals Map (Submission Version May 2012)which has been published alongside the Managing Development DPD(Submission Version May 2012) shows the site is not allocated.

    The site is not located within a Preferred Office Location (POL) where LBTHseeks to consolidate and to primarily protect offices. Whitechapel is insteadconsidered to be a secondary office location. Due to its position on the fringe ofthe city, the site is constrained by competition from proposed developments inmore prime locations and is therefore less suitable for continued office use.

    The site has been subject to a comprehensive marketing exercise to find new

    tenants to use the property for continued office purposes. The property hasbeen marketed since 2008 by various marketing agents involving the use ofparticulars and a website to support the marketing exercise. Please refer to thesubmitted Employment and Marketing Statement for additional information.

    This exercise demonstrated that there was no interest in continued officeoperations at the site, with no potential occupiers identified. The marketingexercise therefore fulfilled the requirements of policy EMP3 and Draft PolicyDM15 of the Managing Development DPD.

    In terms of other available offices space in the area, there are a number ofoffices buildings along Whitechapel High Street including 45 and 100Whitechapel High Street which have been marketed for a significant period and

    still remain available. A search has also been undertaken of available officespaces within the City Fringe and North Fringe areas. The search undertakenfor this area identified approximately 1,696,034 sq ft. of surplus offices space onthe market. The data source for this report was based on the commercialproperty databases EGi London Offices Database and Focus (CoStar). Theextent of available space on the market demonstrates that there is a significantlevel of surplus office space. The loss of this office space would therefore notbe detrimental to office floor space supply, in line with Policy EMP3.

    In terms of employment generation, the hotel will provide employmentopportunities and will deliver economic benefits arising from visitors staying atthe hotel who will use businesses and facilities in the local area.

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    6.2 Principle of Hotel Use

    The site is located within the Central Area Zone which is recognised as not onlyan area of business growth, but also an area where recreational, commercial,social and cultural uses are also important in supporting role of the CAZ and the

    quality of life for those living, working and visiting the area. This is reinforced byPolicy CAZ1 of the UDP (1998) which states that the Council will normally givefavourable consideration to major hotel developments within the Central AreaZone (CAZ).

    Saved UDP Policy ART7 and Core Strategy Policy SP06 also state that hoteldevelopments should be concentrated in the Central Activities Zone and CityFringe Activity Area, both of which the application site is located within.

    The London Plan also supports hotel developments within the Central ActivitiesZone. Tourism is seen as a key growth industry for London. To accommodatethis growth, Policy 4.5 of the London Plan (2011) specifies a target of 40,000net additional hotel bedrooms by 2031 respectively. The policies identify the

    Central Activities Zone (CAZ) as a priority location for new hotelaccommodation and seek to maximise densities. Policy 4.5 also states that newvisitor accommodation should be delivered in appropriate locations, where thereis good public transport access, and further intensification of provision in areasof existing concentration within the CAZ should not be resisted, except wherethis will compromise local amenity or the balance of local land uses.

    It is our view that the proposal is appropriate in this location. The site lies withina highly accessible and sustainable location. A hotel use will also contribute tothe range of land use mix in the area to maintain a healthy balance of land usesand to add to the diversity in the locality in line with policy 4.5.

    6.3 Economic and Social Benefits

    The proposal is for the refurbishment and change of use of an existing building.The development will therefore comprise the re-use of an existing building,rather then the demolition and development of a new building.

    The proposal will bring a predominantly vacated building back into full use toprovide a high quality, energy efficient, modern hotel building which complieswith todays Building Regulation standards for all new works.

    The development will generate new jobs providing new job opportunities forlocal residents and suppliers/businesses. As part of the S106 Agreement, therewill also be an undertaking to enter into an employment, skills, training and localenterprise initiative with LBTH.

    The new use will also add to the vitality of the area by attracting visitors andguests to this part of Whitechapel, to complement other uses such as theWhitechapel Gallery. It will also bring economic benefits to the local area as theguests and visitors will use local services.

    The hotel development will also provide benefits to the local community. Thelounge and dining facilities provided by the hotel will be open to the generalpublic. The hotel scheme will also have an active frontage to provide naturalsurveillance.

    6.4 Conservation and Design

    Qbic Hotels seek to re-use existing buildings and convert them to hotels withminimal disruption to the existing fabric of the buildings. By not makingsubstantial changes to the structure and external envelope of the building, Qbic

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    are able to carry out minimal refurbishment works. To create the individual hotelrooms, Qbic then install their pre-fabricated Cubi rooms which plug-in to thebuildings services.

    As a result, there are substantial changes to the internal layout and fitting of the

    building, but minimal disruption to the external parts of the building that fallwithin planning control. Those external works required are proposed to upgradeand improve the building so it is fit for current occupational requirements.

    The following externals are proposed under the planning application:

    Replacement windows will be installed to all elevations. The replacementwindows are thermally protected double glazing units capable of providingboth solar control and acoustic attenuation. The frames will be powdercoated aluminium and will be installed within the existing openings andmullions.

    Rooftop air conditioning plant and acoustic screening and solar array. Theacoustic screen surrounding the air source heat pumps on the south side of

    the building measures approximately 2.4m high. A new circular sliding double-glazed main entrance door onto Adler Street

    set back from the main building line as existing. A projecting glazed feature canopy projecting off the west elevation onto

    Adler Street at ground floor level. The canopy will not extend beyond thefootpath and is comfortably above head height to ensure pedestrians canpass under the canopy.

    On the courtyard facing elevations, it is proposed to replace some windowswith powder coated aluminium windows to match the existing with opacifiedlook-a-like glazing.

    A small number of existing windows on the courtyard-facing elevations willbe infilled with a render finish in the reveals to accommodate the internallayout alterations.

    Replacement double-glazed door at ground level rear elevation facing thecourtyard and replacement fire-exit doors facing the courtyard. The existing roller-shutter service door and ramp to the rear courtyard

    facing elevation to be infilled with matching brickwork.

    All the external changes to the building are minor in nature, particularly those tothe front elevations that are more visible. Given this, and the nature of theproposed alterations, it is considered that the proposals will preserve thecharacter and appearance of the Conservation Area and accord with LondonPlan and LBTH planning policies as described above.

    6.5 Accessible Rooms

    Of the 174 new guest rooms planned for Phase One, nine will be fully fitted outfor full wheelchair accessibility and a further nine will be fitted out for ambulantdisabled use. These will incorporate specific measures and equipment forguests who are ambulant but experience other disabilities. When Phase II isimplemented, of the 13 additional guestrooms proposed, 1 no. will be designedfor full accessibility and one other for disabled guests who are ambulant. Thisequates to 5% fully wheelchair accessible rooms and 5% ambulant disabledrooms, resulting in a total of 10% of rooms providing facilities for disabledguests.

    The guestrooms designed for wheelchair use have been designed inaccordance with the recommendations contained in the Approved DocumentPart M and as outlined under the Accessible Hotels in London Type B room.

    The ambulant disabled rooms will be fitted out with vibrating pillows, strobelighting to both the guestroom and bathroom. The room will also be design with

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    contracting colours in accordance with the recommendations contained in theApproved Document Part M.

    It is considered this approach is acceptable given that it caters for differenttypes of disabled users, which is a realistic way of managing the demand for

    hotel rooms that cater for disabled guests. This approach also enables Qbichotels to maximise the use of their Cubi hotel room model. The provision of fullywheelchair accessible hotel rooms prevents the use of the pre-fabricated Cubimodels because of the strict dimension and level threshold requirements. Thismeans wheelchair accessible rooms will need to be fitted out in a conventionalway, which removes the advantages of the Cubi model. The 5% ambulantdisabled rooms will be able to use the Cubi model and will be supplemented bythe adaptations highlighted above. It is considered that this is a reasonable,realistic and pragmatic way of ensuring the hotel provides sufficient rooms fordisabled guests.

    Existing public toilets at ground floor level including an existing disabled w.c. areto be retained.

    6.6 Transport, Access and Servicing

    A Transport Statement has been produced by Peter Bret Associates (PBA) anda Servicing Management Plan has been produced by BNP Paribas Real Estatewith inputs from Qbic Hotel and PBA.

    6.6.1 Public Transport

    The site is highly accessible by public transport and has a Public TransportAccessibility Level (PTAL) of 6A by virtue of easy access to mainline trainstations, London Underground Stations and the extensive London bus network.The site is therefore suitable for a hotel development as it is located within a

    highly accessible area.

    6.6.2 Car and Cycle parking

    The hotel will comprise limited car parking for hotel staff and guests. Theexisting office use benefits from 10 parking spaces. The proposed developmentwill retain all 10 spaces, of which one will be allocated as a parking bay for bluebadge holders. This is in accordance with the LBTH standards which state thatthe maximum parking provision for hotels should be 1 space per 15 rooms. Themaximum car parking provision for the development would therefore be 12spaces. It is therefore intended that the majority of staff and visitors to thebuilding will use public transport modes, or will walk or cycle to the site.

    The site is accessible by bicycles and secure, covered cycle parking spaces are

    to be provided. Cycle parking will be provided in accordance with LBTHstandards, which are based on 1 cycle parking space per 10 staff and 1 spaceper 15 residents should be provided. Based on these numbers the total numberof cycle spaces should be 14. These will be provided in the form of Sheffieldcycle stands adjacent to the rear hotel entrance. This will ensure that they areboth convenient to use and secure.

    Shower and changing facilities will be provided for staff to encourage the use ofcycling.

    6.6.3 Coach Parking

    LBTH has advised that due to the size of the proposed Hotel a coach parking

    space should be provided as other hotel operators could potentially take thebuilding and allow coach bookings in the future.

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    The nature of the hotel is unlikely to generate coach trips as the operators willseek individual bookings rather than group books. Qbic Hotel has also advisedthat coach based bookings are not normally part of their cliental base.

    The policy approach identifies that the optimal location of the coach bay should

    be determined through be a sequential approach; firstly on-site provision,secondly on-street provision and finally the use of an existing coach parkingfacilities within the area.

    A swept path analysis has been undertaken by PBA which has identified thatGeometric constraints do not allow the coach to enter the car park as theentrance is very narrow and the site is constrained by existing car parking onthe site.

    In terms of on street coach parking provision, the closest coach parking facilityis located outside Whitechapel Gallery on Whitechapel Road. A coach bay isprovided, for a maximum stay of 1 hour and no return within 2 hours. However,discussions have taken place between PBA and TfL who has indicated that it

    will not be a feasible solution as the bay is presently in dispute due to an issuewith a Traffic Order.

    On going discussions are also taking place with TfL with regard to finding analternative on street coach parking bay or existing coach parking facility.

    6.6.4 Servicing

    A Service Management Plan has been produced by BNP Paribas Real Estateand is submitted as part of the planning application. This outlines how thebuilding will be serviced and provides details of how servicing will be managedto result in the lowest number of trips possible.

    Waste collection will be provided within the existing refuse storage area within

    the servicing yard. LBTH has confirmed that the continued on-street wastecollection will be acceptable, subject to appropriate considerations of vehicledwell time and internal storage and collection.

    The proposed development is likely to generate servicing trips which are relatedto consumable deliveries, linen collection and delivery, stationary supplies,delivery of cleaning products and general maintenance. The trips will beconsolidated to combine a number of different collections and deliveries by onevehicle, which will result in a relatively low number of trips being made.

    6.7 Energy and Sustainability

    Building Services Solutions has produced a Building Services and Energy

    Report. This report sets out the optimum energy strategy for the building thatwill deliver the most efficient solution to reduce energy consumption for thelifetime of the building and thus carbon emissions.

    This approach seeks to use less energy, supply energy efficiently and userenewable energy sources where possible. A full assessment of availabletechnologies has been undertaken to configure a system that will deliver theoptimum performance in view of the site conditions, the proposed use andconfiguration of the building and the viability of the technologies.

    The proposals have been designed in line with the London Plans EnergyStrategy. This includes:

    Be Lean Improve the energy efficiency of the scheme Be Clean Supply as much of the remaining energy requirement with low

    carbon technologies

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    Be Green Offset a proportion of the remaining carbon dioxide emissionsby using renewable energy technologies

    6.7.1 Be Lean

    The following leanenergy efficiency measures are proposed:

    Improving building fabric prevention of heat loss through the internalinsulation of external walls and provision of new windows to improvethermal value

    Passive design - use of good daylight to the bedrooms to reduce artificiallighting and use of blackout blinds to reduce heat build up and heat loss

    Reducing air filtration

    Low energy lighting and lighting control 95% of the hotel scheme will havelow energy lamps and fittings

    Flow restriction in showers to maximise flow to 9 litres per minute andtemperature controls to reduce overheating of water.

    6.7.2 Be Clean

    The following Clean energy supply will be provided which uses low carbontechnologies:

    Gas fired condenser heaters - to provide hot water. The heater will be ableto modulate down to a very low load allowing minimal wastage by not overheating the water having a 96-97 % efficiency.

    Air Conditioning /Comfort Cooling to provide controlled heating and cooling.To the central area and rooms through Air Sour heat Pumps. Identified toreduce CO2 emission by 43%. The Air Source Heat Pumps will alsoprovide free cooling for the air conditioning.

    Heat Reclaim Units - to reclaim heat or cooling from various areas from theextracted air and use it to condition the incoming external air before thesupply air enters the areas being served. This free cooling and heating willgreatly reduce the load and energy consumption of the air conditioningsystems

    6.7.3 Be Green

    A range of Green energy supplies were considered including:

    Biomass Boilers

    Wind Turbines CHP unit Photovoltaic panels Air Source Heat Pumps Solar thermal Collectors

    Following a thorough assessment as set out in the Building Services andEnergy Report, the following renewable measures have been selected.

    Photovoltaic cells to provide electricity Air source Heat Pumps for comfort cooling and heating

    These will provide electricity and heating and cooling respectively.

    Our investigations and the results of the thermal modelling have indicated that asignificant reduction in the carbon emissions over a baseline building can be

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    achieved by including systems and technologies that reduce the amount ofenergy required and by including renewable energy systems such as the airsource heat pump condensers and photovoltaic array.

    Together, these measures are predicted to reduce total Carbon Dioxide

    emissions from the whole development by around 30% when compared to thebase build model. This meets the London Plans requirement in Policy 5.2 toreduce carbon dioxide emissions for non-domestic buildings by 25% in theperiod 2010 2013 (minimum improvements on the Target Emission Rates(TER) as outlined in the national 2010 Building Regulations).

    In addition, John Packer Associates have prepared a Pre-BREEAMAssessment. Overall, it is proposed to achieve a BREEAM rating of Very Goodwith a score of approximately 62%. The threshold for the Very Good categoryis 55% meaning the predicted score is comfortably above this level.

    The assessment work undertaken has demonstrated it is not possible toachieve an Excellent rating as the development comprises the conversion of

    an existing building, therefore achieving more than Very Good is prohibitive.The minimum score required to achieve a BREEM Excellent rating is 70%. Theassessment work undertaken demonstrates that even if every available creditwere targeted (notwithstanding whether these are achievable), the maximumpotential score would be approximately 66-67% and therefore still significantlybelow the Excellent threshold. The enclosed letter from John PackerAssociates (who undertook the BREEAM assessment work) explains that thelimited design options brought about by conversion of an existing buildingmeans that achieving the Excellent rating is extremely difficult. In theirextensive experience, John Packer Associates has yet to award an Excellentrating where it involved the conversion of an existing building.

    In addition, it is important to note that by retaining and reusing much of the

    existing building carbon dioxide emissions are dramatically reduced whencompared against total demolition and new build.

    6.8 Noise

    A noise assessment has been prepared by Acoustic Design Consultancy and issubmitted as part of the planning application.

    The report outlines the methodology for the assessment of existing backgroundnoise levels, the recorded levels, the identification of noise-sensitive facades,and the noise levels the required noise levels of the proposed plant in order tomeet LB Tower Hamlets standards. The standard condition that will be appliedrequires installed plant to be 10dBA below existing background noise levels.

    A manned on-site noise survey was conducted overnight to capture backgroundnoise levels. An overnight survey was carried out as this covers the periodwhen noise levels are at their lowest, and will therefore dictate the lowest levelagainst which proposed plant will be assessed. Measurements were taken atfour different points to gather robust data from each identified noise sensitivefaade. The most crucial facade in terms of noise protection is the nearest one,on Mulberry Street.

    The lowest ambient background noise levels around the building were recordedon Mulberry Street with LAF90 values of 44.5dBA towards the top of the facadesand 42dBA at lower levels. The LAF90 value is the relevant value to use in theassessment as this represents the sound level exceeded for 90% of the time.

    Accordingly, the measured values of LAF90 indicate that services noise from thehotel must not exceed 34.5dBA at the level of the top floor of the Mulberry

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    Street building, and 32dBA closer to ground level in order to meet the -10dBArequirement.

    The specified rooftop plant will not meet these standards without noiseattenuation measures being incorporated. To achieve the standard, screening

    to the heat pumps will be required to provide an additional attenuation expectedto be around 15dB.

    6.9 Heads of Terms

    The following draft heads of terms have been discussed and agreed with LBTower Hamlets:

    Employment, skills, training and local enterprise; Community Facilities; Public Open Space; Sustainable Transport; and Street-scene and Built Environment.

    An undertaking will be made through the drafting of a S106 Agreement toincorporate these planning obligations.

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    7 ConclusionsThe office building is largely vacant. The building has been actively marketedsince 2008 to attract a new office occupier and no offers were made. The

    proposals will therefore allow under-utilised and outmoded office space to comeforward for an alternative use in line with Policy EMP3. This will allow thebuilding to be brought back into an active and more sustainable use to secureits long term future in line with the NPPF.

    The development of a hotel in the City Fringe and the Central Area/ActivitiesZone is an appropriate use in this location. The hotel will provideaccommodation for both business users and for tourists, to service the City andthe tourism zone to the north of the site which provides access to Brick Lane,Spitalfields Market, and the various Whitechapel tourist tours. The hotel schemewill therefore support the functions of the CAZ , in line with London Plan Policy2.10 and UDP Policy CAZ 1.

    The hotel development will contribute to the mixed use character of the area inline with the aspiration of the various emerging Policies for Aldgate, as set out inthe Aldgate Masterplan and Core Strategy.

    The development will also provide benefits to the local area in terms of jobcreation for local people and in terms of expenditure in the local economy fromguests staying at the hotel. The ground floor of the hotel will also be used as areception area and lounge/dining area for hotel guests. This will create anactive frontage to contribute to the vibrancy of the area and to provide naturalsurveillance, in line with Policy CAZ 4. The scheme will also enhance theneighbourhood and allow the facilities to be used by residents.

    The proposals will involve a change of use of the building. Whilst there may besome minor alterations to the exterior of the building, there will not be anadverse impact on the heritage interest in the area. The character andappearance of the Conservation Area and the setting of the Grade II * listedbuilding along Plumbers Row/Whitechapel High Street will be preserved in linewith the NPPF.

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    Appendix 1 - Photographs

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    Challenger House, 42 Adler Street

    PEJ/112752/E/APPSUB/010 1

    Front elevation of Challenger House facing Adler Street

    Front elevation of Cityside and Challenger House from across Altab Park

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    Challenger House, 42 Adler Street

    PEJ/112752/E/APPSUB/010 2

    View north along Adler Street showing Cityside and Challenger House

    View east along Whitechapel High Street showing cycle path and bus stop

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    Challenger House, 42 Adler Street

    PEJ/112752/E/APPSUB/010 3

    Side elevation of Challenger House facing Mulberry Street

    View north along Plumbers Row show vehicular access into site

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    Challenger House, 42 Adler Street

    PEJ/112752/E/APPSUB/010 4

    View through rear access gates of rear courtyard and elevation

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    Appendix 2 - Pre-ApplicationResponse Letter

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    Appendix 3 - Example of Letter toNeighbours

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    Nicola ForsterDirector

    BNP Paribas Real Estate5 Aldermanbury SquareLondon EC2V 7BP

    To the Occupier

    Tel:Switchboard:Fax:Email:

    020 7338 4119020 7338 4000020 7430 [email protected]

    Our ref: NIF/PEJ/112752/F/004L 28 June 2012

    To the Occupier

    NOTIFICATION OF PLANNING APPLICATION FOR NEW HOTEL AT CHALLENGER HOUSE,

    42 ADLER STREET, LONDON

    We write to inform you of proposals to convert the existing office building into a hotel on behalf ofthe applicant, Bridges Hotel Properties Ltd and the operator, Qbic Hotels.

    The proposals seek planning permission to convert the existing office building, known asChallenger House, to a 187 bedroom hotel. The hotel will be aimed at tourists and business guests

    and will result in complete refurbishment of the building, including some minor external works suchas new windows, doors and a new entrance canopy. Other than these changes, it is not proposedto carry out any other changes to the outside of the building.

    The planning application is due to be submitted to the London Borough of Tower Hamlets shortly.The Council will send letters to nearby residents and neighbours and will post site notices when theapplication is submitted. Members of the public will be able to view the proposals on the Councilswebsite or at the Councils offices. The Councils letters and site notices will provide details of howand when to make comments on the application.

    In the meantime, should you have any queries, please contact either Nicola Forster on telephone:0207 338 4119 and email: [email protected]; or Philip Jones on telephone: 020 73384053 and email: [email protected].

    Yours faithfully

    BNP Paribas Real Estate