Recall that one of Haringey’s three pillars for preferring FEC/CoPlan and the hotel was planning risk.

According to Haringey’s Cabinet Papers, “the bid not being recommended proposed higher residential buildings to the rear, requiring a new planning application

While the “bid being recommended aims to work with the existing planning arrangements

It seems the planning bit might have been optimistic…according to Planning Aid for London any change of use to a hotel will indeed require full new planning.

 

Below the text of our letter to Haringey and the advice from Planning Aid for London:


Attn: Emma Williamson, Assistant Director Planning, Haringey Council
cc. Lyn Garner, Alan Strickland

Dear Ms Williamson

Re. Hornsey Town Hall project, planning strategy

It has come to our attention, through the publication of the report ‘Recommendation of a preferred bidder for Hornsey Town Hall’ for cabinet 18th October, that planning considerations have played a key role in decision making in the procurement process for the Town Hall.

The cabinet report asserts that it is the opinion of the preferred bidder and Haringey Council that a new Full Planning Application is unlikely to be required for the bidder’s proposed scheme to convert the building to hotel use. We feel that this assumption cannot remain unexamined before the cabinet takes a decision on the preferred bidder, and would value your analysis of the planning strategy.

The original consent HGY/2010/0500 (varied 2013/0694, and implemented 2013) identified a C3 development in the East Wing and Link Block, and possible A3, A4, B1, D1, D2 & Sui Generis uses in the West Wing. These sections of the Town Hall are now proposed as hotel use.

We have sought advice from Planning Aid for London on whether such a change is acceptable without a Full Planning Application, and it is their opinion that it is not. Their full statement is appended below this note.

The avoidance of a Full Planning Application appears to run counter to accepted practice. The changes of use from residential to hotel, and from office to hotel are not permitted developments, nor do they fall within an understanding of what is achievable using a section 73 application for minor material amendments.

Can Haringey Planning Service supply a reasoned justification for the non-requirement of a new Full Planning Application in such a case?

We understand that no applications have yet been submitted to the Haringey planning team, but the cabinet report’s statement that a Full Planning Application is not required by one of the bidders is of material significance. If this is a faulty or uncertain assertion, then the scoring of the OJEU process and the risks identified in the bid are incorrect, potentially leading to an unlawful selection of bidder.

The report may therefore require immediate correction, or at least be withdrawn until the matter is more adequately determined.

This letter will be published on our website. We look forward to your reply. There has been little opportunity for public scrutiny of this process – and now to learn of the council’s desire to avoid the proper consultation of a full planning process is very disappointing.

Regards,
Hornsey Town Hall Appreciation Society

 
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Statement from Planning Aid for London :

On 12 Oct 2016, at 14:18, George Knott <george@knottarchitects.co.uk> wrote:

‘Hornsey Town Hall’

There seems to be, at least by implication, a view that the preferred bid is relatively ‘risk free’ as it can be developed within the parameters of the current Planning Permission.

We disagree.

Under the Town and Country Planning (Use Classes) Order 1987 as amended (England) 2015 there is a single Use-Class for hotels = C1
Under the April 2016 Updated Permitted Development Order there is no provision for Permitted Development for a change of use to C1

A Section 73 relates to ‘minor non-material amendments’ to permissions (+ Conditions). Introducing a C1 use is in no way ‘minor’.

The site is Grade 2(star) Listed. Any changes to the interiors or exteriors (bar minor maintenance) will require Listed Building Consent.

Therefore: introducing a hotel into the mix of development will require a Full Planning Application and a Listed Building Consent Application – along with a full consultation exercise. As such, fresh designs will need to be developed that indicate the hotel and how it changes the use-mix on the site. New or amended documentation required is likely to include:-

• Environmental Impact Assessment
• Listed Building and Conservation Area Statement
• Transport and Parking analysis and proposals
• Noise studies
• Sustainability justification
• Construction Management Plan.
Etc, etc

Please feel free to circulate this as you wish

Regards

PLANNING AID FOR LONDON