Development Management Policies and Finsbury Local Plan Topic Paper: Hotels - August 2012
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Development Management Policies and Finsbury Local Plan Topic Paper: Hotels August 2012
1. Outline
1.1. This topic paper provides justification for the hotels policy in Islington’s
Development Management Policies DPD Submission Draft document.
The paper also provides a response to comments which have arisen
from the DPD consultation process.
2. Background
2.1. Proposed DM Policy DM28 sets out the policy for hotels and visitor
accommodation. Further detail is also provided by policy BC8 of the
Finsbury Local Plan. This policy has been informed by a number of
studies/documents.
2.2. The Islington Employment Study (2005) looked at the need for
employment land and premises in Islington. This was supplemented by
the Islington Hotels Study (Atkins, 2005), a supply/demand assessment
for hotels during the period up to 2016.
2.3. The hotels study considered that Islington should aim to meet future
needs by ensuring the provision of a range of hotel types aimed at
different market segments; including affordable / budget, lifestyle,
business, 3/4 Star, boutique and extended-stay accommodation.
2.4. In summary, the study recommended that the LDF contain policies
setting out criteria for assessing hotel applications, whilst directing hotels
to the following locations:
Large hotels at City Road South / Moorgate; Clerkenwell / Farringdon;
adjacent to King’s Cross; and Angel; and
Small to medium sized hotels at Highbury Corner; Archway; Nag’s
Head; and adjacent to Arsenal / LMU (Holloway Road tube).
2.5. These broadly correspond to the Key Areas identified in the Core
Strategy, except for the omission of Finsbury Park.
2.6. The London Hotel Demand Study (GLA, 2006) found that around 77% of
hotel bedrooms were located in Central London in 1996, but this had
declined to 69% in 2005. Taking into account more recent development
activity, the study projected that by 2008 the total stock of hotel
bedrooms in Central London would reduce to around 67% by 2008.
While this was considered to support GLA objectives for spreading the
benefits of tourism, much of the four/five star stock was expected to
remain within central London; with two star and budget hotels being
confined largely to other parts of the capital.
2.7. Overall the study identified need for an additional 2,300 hotel rooms by
2016, and 1,700 rooms between 2017 and 2026.2.8. The Government has made it clear that supporting guidance not listed in
Annex 3 of the NPPF is still extant, prior to its revocation after a full
review of all planning policy supporting guidance. The Good Practice
Guide on Planning for Tourism (DCLG, 2006) cancelled PPG21
(Tourism) when it was published in September 2006. It encourages local
authorities to identify suitable locations for hotels as part of the plan-
making process, in order to meet identified future needs. It emphasises
the importance of doing this for major hotels (e.g. those with business,
conference and banqueting facilities, or large tourist hotels), and
confirms that the sequential test should apply to these (i.e. by directing
them towards town centres and other similar locations).
2.9. The Accessible Hotels in London (Grant Thornton for the GLA, 2010)
report was commissioned to inform the London Plan policy on the
percentage of accessible hotel bedrooms required to meet demand over
the next 20 years. The report concluded that 10% of new hotel rooms
should be accessible, and also clarified that the London Plan should
provide a suitable definition of an ‘accessible room’ to ensure that they
will meet the needs of intended occupants.
2.10. Consistent with the London Plan, other London boroughs are taking a
similar approach to Islington with regard to positively directing hotel
development to specific areas where impacts can be managed and
where they meet certain criteria.
Borough Policy
Camden Directs larger hotels to Central London and smaller hotels to
town centres
Allows hotels elsewhere where they would attract limited
numbers of visitors
Specifies criteria for hotels (e.g. accessibility/servicing
requirements and character/amenity considerations)
Hackney Directs hotels to established employment areas with a PTAL
score of 5 or above or within/adjacent to identified town centres
Westminster Directs new hotels to certain areas (e.g. Paddington, Victoria,
West End), on streets that are not predominantly residential in
character
Protects existing hotels that do not have adverse effects on
residential amenity
Encourages change of use to residential in certain areas (e.g.
Pimlico, Bayswater)
City of London Allowing hotels that support the primary business/cultural roles
Refusing new hotels where they would compromise business
function/growth
Directing hotels away from existing residential areas
Tower Directs hotels towards the CAZ, City Fringe, Canary Wharf and
Hamlets town centres2.11. Two papers produced in 2010 by Tourism Insights1 explored issues
around tourism and planning, and cited positive impacts including:
Retraining the resident workforce
Providing routes to management for staff
Helping to diversify over-specialised economies
Supporting and enhancing local services and facilities, including
public services
Attracting arts, sports or cultural events (including conferences)
2.12. Hotels are akin to retail and leisure uses in the type of employment that
they generate. Providing for a limited amount of hotel development will
invariably support the Core Strategy objective of providing a range of
types of job within the borough.
2.13. The local economic benefits of hotels are well recognised in rural
locations, where visitor spend can be easily measured. In urban areas,
local benefits are clearly more difficult to estimate; but it is not
unreasonable to assume that hotels may generate income for nearby
shops and cafés.
2.14. Clearly, business tourism is likely to be a substantial driver of hotel
development in parts of the borough; particularly the CAZ. Business
hotel development is more likely to be linked to uplift/refurbishment of
office and conference facilities (alongside other types of complementary
use generated by office development, such as shops, restaurants and
bars). A benefit of business hotels is therefore their contribution to
diversity in the local employment market.
2.15. The primary, direct disadvantage of hotels is their local impact. Where
over-concentration occurs, hotels can harm the character of a place,
particularly in residential areas, both directly (e.g. creating noise and
disturbance for neighbouring residents) and indirectly (by generating a
high level of transience in the overnight population).
2.16. Hotels can also lead to a loss of land suitable for uses of greater priority,
such as housing or employment. In terms of employment land
specifically, although hotels can be classified as an employment use,
they often provide low employment densities, which means that other
employment uses providing higher employment densities would be
preferred where there was a conflict over available development land.
For example, the Homes and Communities Agency Employment
Densities Guide (2nd Edition) (2010) indicates that B1(a) office
floorspace generates around 1 employee per 12sqm, with budget hotels
generating around 1 employee per 3 bedrooms, general hotels
1
See
http://www.insights.org.uk/articleitem.aspx?title=Tourism+and+Planning.+Part+1%3a+The+Planning+Sy
stem and
http://www.insights.org.uk/articleitem.aspx?title=Tourism+and+Planning.+Part+2%3a+Tourism+Develop
ment+and+Planninggenerating around 1 employee per 2 bedrooms and 4/5 star hotels
generating around 1 employee per 1.25 bedrooms. Hotels therefore offer
much less capacity for employment growth.
2.17. Hotels have quite different travel patterns than, for example, office
buildings. Their occupants tend to arrive or depart at all times during the
week, rather than at peak times on weekdays. Although a number of
visitors in central London will arrive by public transport and foot, drop-off
areas for taxis and coaches are an important consideration. In addition
hotels generate more frequent deliveries; requiring essential supplies of
food, drink, laundry and other items necessary for the daily operation of
the business. Adequate servicing bays are therefore important.
3. Planning policy context
3.1. Islington’s adopted Core Strategy policy CS14(G) identifies Town
Centres as the appropriate location for hotels and visitor
accommodation; and also states that 10% of hotel bedrooms will be
required to be wheelchair accessible.
3.2. Policy CS13 addresses “employment uses”, which includes hotels (as
defined in the Glossary). Part A of the policy directs new employment
space “to locate in the CAZ and town centres where access to public
transport is greatest”. Policy CS7 indicates that hotels may be
acceptable in some CAZ locations.
3.3. The overall thrust of the Core Strategy is therefore to direct hotels
anywhere within Town Centres and in CAZ locations where access to
public transport is greatest. These are locations where hotel
development would best support the retail and service economy.
3.4. The London Plan policy 4.5 provides the key policy basis for the
proposed hotel policy in the DM Policies DPD; this policy directs new
visitor accommodation to Town Centres and within the Central Activities
Zone (CAZ) in Opportunity Areas/Intensification Areas. In Islington,
these are the Kings Cross and City Fringe Opportunity Areas and the
Farringdon/Smithfield Intensification Area.
3.5. London Plan Policy 4.5 also seeks to deliver 10% of net additional hotel
bedrooms to wheelchair accessible standards; seeks to ensure new
visitor accommodation meets the highest standards of design,
accessibility and inclusion; and aims to resist further intensification of
hotels in areas with an existing concentration.
3.6. The National Planning Policy Framework (NPPF) identifies hotels as a
Main Town Centre Use; therefore new hotel developments should be
directed to Town Centres.
4. Policy development4.1. The proposed DM Hotels Policy has a hierarchy approach to
development of hotels and other visitor accommodation, with Town
Centres preferred, then areas within the CAZ that are in close proximity
to national railway hubs (i.e., around Kings Cross, Farringdon, Moorgate
and Old Street). Outside of these locations, the council will resist
proposals for hotels and other visitor accommodation.
4.2. The proposed policy also has a number of criteria which new hotels and
visitor accommodation must meet, including supporting the areas
primary retail/business/cultural role; providing appropriate arrangements
for pick up/drop off, servicing and coaches; and demonstrating that there
will be no adverse impacts on residential amenity.
4.3. The policy affords preference to visitor accommodation designed, leased
and operated as a hotel for temporary occupation. Other types of visitor
accommodation which share common characteristics with permanent,
self-contained housing will be subject to conditions limiting the length of
occupation, and may also be assessed as a residential unit given the
common characteristics between the two.
4.4. Previous iterations of the policy, in the Issues & Options and Direction of
Travel draft documents, have been refined to ensure that the policy
reflects the conclusions of the studies/documents discussed in section 2,
is consistent with the NPPF, London Plan and adopted Core Strategy,
and appropriately addresses representations received during
consultation exercises.
4.5. Policy BC8 of the Finsbury Local Plan provides further detail on the
development of hotels. Policy BC8 identifies Opportunity
Area/Intensification Area boundaries and allows for hotels within these,
consistent with DM policy DM28.
5. Justification for proposed policy
5.1. The proposed DM policy limits development of hotels to Town Centres
and the CAZ within close proximity to national railway hubs. The policy
has been developed throughout the various consultation stages, taking
on board comments from various consultees including the GLA.
Following the Direction of Travel consultation, the policy was amended
to include the preferred hierarchy of hotel locations i.e. Town Centres,
then within the CAZ in close proximity to national rail hubs. The GLA has
stated that the proposed policy is consistent with the London Plan, which
directs new visitor accommodation to Town Centres and within the
Central Activities Zone (CAZ) in Opportunity Areas/Intensification Areas.
All national railway hubs within the CAZ in Islington are within an
Opportunity Area/Intensification Area. Further detail is also provided in
policy BC8 of the Finsbury Local Plan.5.2. During the development of the proposed DM hotels policy, the location of
hotels proved to be the most contentious issue. Several representations
were received relating to this issue:
A number of representations stated that hotels should be located
within the CAZ, either in areas with good public transport
accessibility/high Public Transport Accessibility Levels or anywhere in
the CAZ;
Representations were also received stating that hotels should be
allowed anywhere in the borough; in any areas with good public
transport/high PTAL; and in areas that promote business tourism.
5.3. The DM policy has not been amended to reflect these representations
for the reasons outlined below.
5.4. The proposed approach of identifying specific areas in the CAZ where
hotels will be suitable will assist in protecting land for more priority uses,
such as housing or higher density employment uses. Islington is a
densely developed borough and as such there is a need to ensure that
land is used as efficiently and intensively as possible for these priority
uses. Identifying specific locations is considered an appropriate
response to this issue and is commonly utilised in London (see Section 2
above).
5.5. The CAZ is home to a variety of uses, some of which are conducive to
hotel development and some of which are not. The areas around
national railway hubs offer substantial opportunities for a mix of uses due
to the superior level of accessibility. Hotels are considered to be
uniformly appropriate here, given the mixed-use nature of these areas.
Conversely hotels are not considered to be uniformly appropriate across
the entire CAZ, as there are a number of areas where they may
compromise the economic/business function or could detrimentally affect
residential amenity.
5.6. When considering how economic growth can be maximised, it is
important to differentiate between uses which drive economic growth,
and uses which support primary activities. Generally, premises within the
B use classes provide accommodation to sectors that drive economic
growth. Outside of town centres, other employment-generating uses,
including hotels, typically provide a supporting role.
5.7. Cumulatively, loss of land suitable for housing or higher density
employment floorspace to other uses such as hotels would have
significant adverse effects and would clearly be detrimental to the
sustainable development of the borough. Therefore, uses which promote
economic growth or help to address housing need should be given
priority over other uses in the plan-making process.
5.8. It is important that hotels fit with the role and function of locations and
are not just located in areas based solely on how suitable they are interms of accessibility. By dentifying specific locations where hotels are
suitable (subject to meeting supporting criteria to assess impact on
amenity, access, etc), potential conflicts with other policies will be
minimised, particularly housing policies. This approach will ensure that
Islington continues to make a significant contribution to London’s visitor
accommodation, but this should be balanced against the need to
manage neighbourhoods so that they function well and provide a high
quality of life for residents. Hotels are often not compatible with
residential neighbourhoods because the amount of activity they generate
can cause amenity problems.
5.9. The further detail provided by the Finsbury Local Plan ensures maximum
clarity and consistency with the London Plan. It should be noted that the
designated Opportunity Area/Intensification Area boundaries have been
adjusted in response to representations received.
5.10. The draft DM Policy states that outside of these locations, proposals for
hotels will be resisted. This approach will minimise the likelihood of hotel
development compromising other policy aims and is likely to support the
delivery of housing and higher density employment uses, which have
been demonstrated to be priority uses in the borough and will better
contribute to Islington’s sustainable growth.
5.11. Several representations stated the need to protect local amenity,
particularly by avoiding clusters of hotels and ensuring that hotels
harmonised with neighbouring development. The proposed policy has a
number of criteria which applications for hotels must meet, particularly
ensuring that there are no adverse impacts on residential amenity,
including cumulative impacts. This policy approach is consistent with the
London Plan, which aims to resist further intensification of hotels in
areas with an existing concentration. As set out earlier, directing hotels
to specific locations will protect the amenity of predominantly residential
areas.
5.12. The proposed hotels policy will ensure that hotel developments will not
result in adverse cumulative impacts, including where there would be an
over-concentration of hotels as a result of a development proposal.
Proposed policy DM20, which aims to limit harmful concentrations of
certain uses, could also be used to control the clustering of hotels in
specific areas.
5.13. The proposed policy exceeds the London Plan policy 4.5 requirement
that at least 10% of net additional hotel rooms are wheelchair
accessible; the proposed DM Policy requires at least 10% of all new
hotel rooms to be wheelchair accessible. This sets a clear threshold for
all new hotel rooms (including those new rooms developed as a result of
hotel redevelopment) and will enable the policy to be implemented
successfully. A policy requiring 10% of all new rooms to be accessible
will help better match demand and supply by disabled people and also
allow them greater choice and ease of access to appropriate rooms.5.14. This is a conservative requirement as it only applies to new rooms and is
the same as the requirement proposed for new housing. Under the 10%
target, the number of accessible rooms is estimated to increase from 2%
in 2010 to 4.5% by 2031.
5.15. This is consistent with the Mayor's best practice guidance on wheelchair
accessible housing which states that at least 10% of new homes should
be designed to be wheelchair accessible or easily adaptable for
residents who are wheelchair users.
5.16. As affordable housing policies have been strengthened, the
development of longer-term visitor accommodation, such as apart-
hotels, has increased. There is concern that this increase in
development is an attempt to circumvent the affordable housing policies
by developing longer-term visitor accommodation as de-facto long-term
housing, with no requirement to provide affordable units.
5.17. Longer-term visitor accommodation is generally assessed as a hotel use
(C1 use class) as it has similar local impacts. However, many types of
apart-hotels or serviced apartments are more similar in design and
function to permanent, self-contained housing (C3 use class). As such
they represent a special case that requires a particular approach to
controlling their development.
5.18. Hotels are the preferred route to providing short-term accommodation in
Islington, and the policy makes this clear; it is not intended that any type
of visitor accommodation is used or occupied by permanent households,
as this would be contrary to the sustainable development of Islington and
would also put pressure upon local services and infrastructure.
5.19. Where longer-term visitor accommodation is considered to fall within the
C3 use class (or outside a Use Class, i.e., Sui Generis), it will be
assessed using housing policies, particularly those relating to affordable
housing and housing standards. Consideration of whether proposals fall
into Use Class C1 or C3 will be taken on a case-by-case basis, based on
the attributes of a particular proposal. This approach will ensure that
proposals cannot circumvent affordable housing policies and therefore
deprive the borough of much needed new affordable housing units; and
will also allow them to be easily converted into suitable residential units
in the future.
5.20. Where proposals are assessed as C1 units, the proposed policy
indicates that maximum lease lengths will be conditioned to prevent the
unit being used as a de-facto C3 use and therefore avoid the associated
adverse impacts on local services and infrastructure.
5.21. Following comments received during the proposed submission
consultation (October 2011), the policy has been reworded to remove
the specific preference for standard hotels rather than apart-hotels. Thelow preference afforded to apart-hotels was as a result of
aforementioned circumventing of affordable housing policy by apart-
hotels in Islington; the policy is now more generic in its preference for
visitor accommodation designed, leased and operated as a hotel for
temporary occupation, which can include apart-hotels. Further
information on how proposals will be assessed is provided in the
supporting text.
5.22. A specific reference has also been made to the potential use of
conditions to limit the length of occupation, also as a result of comments
received during the consultation.You can also read
