In addition to Labour’s support for the local petition on Dolphin Square, Cllr Adam Hug has submitted the following letter of objection to the Council’s Planning Department on behalf of the Labour Group:
Dear Julia, John and Michael
I am writing to object to the Westbrook proposals for Dolphin Square on the following grounds:
Increase in short term lettings – The revised application confirms the intentions of the applicant to further reduce long-term letting in Dolphin Square in favour of the more profitable short-term lettings market and expand the current hotel use within the Rodney House northern block which trades as the Dolphin House hotel.
The applicant now describes the construction of new serviced apartments (Class C3 residential) within the Rodney House block, which is proposed to be demolished and replaced with a new block of 10 stories instead of the existing 6 stories, as “serviced apartments (Class C3 temporary sleeping accommodation). The revised application proposes that the Rodney House block will include, inter alia, 160 studios as serviced apartments. This appears to be an attempt to take advantage of the May 26th 2015 Deregulation (enabling) legislation in London which was passed to support the sharing economy by allowing individual property owners to let out their homes by the night on sites like Airbnb for a maximum of 90 days a year. Previously, such letting was forbidden.
For an existing hotel operator to use this legislation to increase their accommodation available without the benefit of a C1(hotels) consent is an abuse of process. To comply with the law, these apartments will have to be let on a serviced basis for a minimum of 90 days each time a year after the annual 90-day quota has expired. Again, this will be difficult to control and will not generate the homes for long-term letting that are so urgently needed in Westminster. I also question whether such a consent is available to a hotel operator rather than an individual property owner.
As you know, Dolphin Square’s long-term tenants have been complaining about the expansion of short-term letting from the Dolphin House hotel in Rodney House to many other parts of Dolphin Square and the constant appearance of hotel-style linen trollies in corridors and lifts away from the existing hotel. For a landlord in central London, the economics are simple. The effect is the loss of long-term accommodation which is contrary to Westminster Planning Policy H2.
Contrary to hotels policy – The plan to demolish Rodney House and effectively double the size of the hotel is also contrary to Westminster Core Strategy CS22 which states that new hotels will be directed to the Paddington, Victoria, and Tottenham Court Road Opportunity areas, the Core Central Activities Zone (CAZ) and the North Westminster Development Area. It also states that existing hotels in Pimlico and Belgravia should be converted to residential use where possible to preserve the residential character of the area.
Loss of retail arcade – The applicant also seeks to develop a substantial parade of public shops (Use Class A1-A4) in Chichester Street in place of the small and famous Art Deco arcade within the existing building which will be lost on demolition. Such retail development is contrary to Westminster Core Strategy CS10 which states that “retail and other appropriate town centre uses will be directed to the Warwick Way/Tachbrook Street Central Activities Zone (CAZ).
Density and Height – Dolphin Square has a greater density and height than the adjoining Churchill Gardens estate and is contrary to Westminster Planning Policy H11 concerning housing density.
Impact on the Listed Gardens – The revised application does not take into account the recent listing by English Heritage as Grade II of the historic Dolphin Square gardens designed by Richard Sudell and continues to seek to demolish the Spanish/Mexican garden contrary to the advice of the Westminster Society and the 20th Century Society. The Spanish/Mexican garden will make way for 2 deep basements, one of which is described as D2 (leisure). The use class D2 includes “assembly” such as conference facilities and it is to be noted that the lower basement has 4 rooms labelled as studios and a huge void area which are highly likely to provide the conference facilities that the current Dolphin House hotel lacks.
Impact on the Conservation Area – The Conservation Area audit for Dolphin Square states clearly that the adding of a storey to one of the most densely populated buildings in the country would not be appropriate. It also states that demolition should not be allowed for a building of merit. The demolition and rebuilding of Rodney House with 4 additional stories on the narrow Chichester Street will be out of scale and will have a profoundly adverse effect on the Conservation area as a whole.
Lack of Affordable Housing – There is no provision for affordable housing on site within the application for which Dolphin Square had a long tradition. The Mayor’s office has called for 35% provision of affordable housing on site in the event that this planning application is granted consent which has been estimated to amount to 100 new affordable homes. Given both the history and the current context we would strongly argue that the affordable housing requirement should be delivered on site.
I urge you to recommend this application for refusal. Please keep me informed of any potential committee date information.
Yours sincerely
Adam
Adam Hug
Leader, Westminster Labour Group
02076412230