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Planning Committee Submission


Submission to Wandsworth Borough Council
Added on: 7 September 2020 at 17:49:55

Dominvs Hotel, Nine Elms: 2020/2047

The Battersea Society objects most strongly to this application which is an unneighbourly overdevelopment and one which would do irreparable harm to the streetscape.   It would damage the south side of Nine Elms, already subject to dense development, and would adversely affect both current and future residents.  We trust that Wandsworth Council will accept the need to exercise care and control over the previously consented plans, already seen by ourselves and others as at the margins of acceptable density.  We urge the Council to reject this application, and to call for a solution much closer to that consented for this site at 2011/1815.


Overdevelopment of the Site
Outline planning permission was given for a single building of 10,400 sq.m., with generous space onto Nine Elms Lane, and with a height of 10 storeys dropping to 2 storeys at the rear.  Condition 10 of the decision notice for 2011/1815 dated 30 March 2012 notes that ‘Hotel (Class C1) use shall not exceed 6,050 sq.m. GEA’. 


The current proposal for two buildings, the front at 10 storeys, the rear at 18 and a size more than three times that consented, with the footprint extending to near the margins of the site neither ‘respects the scale of neighbouring buildings’ nor is this a design ‘sensitive to neighbouring properties’.  Plot A7 is one of 9 plots within the Embassy Gardens site with building heights varying from 6-23 storeys and, as far as we are aware, the only plot where heights above those approved are being proposed.  


Streetscape
The visuals presented do not demonstrate the impact of the proposals on neighbouring buildings, on views from north and south and on the streetscape.  They fail to make clear the way that the buildings would diminish the impact of the US Embassy. The fact that the Embassy is set back from Nine Elms Lane, while the Dominvs buildings would be close to the pavement, is not made clear in the visuals which obscure this.  It is noted that the rear building is 7.5m below the height of the Embassy (just over three times a ceiling height of 2.4m).  The illustration on p.60 of the Design & Access Statement (DAS) does not properly show this, suggesting a much greater difference in height and bulk, and therefore of impact.  The proposals are not deferential to the US Embassy which, with the Battersea Power Station, is a signature building for the area. 


Overshadowing
The buildings would do substantial harm to the daylight available to residents in both the adjoining Ambassadors Building and to those in Elm Quay Court.  We are not impressed by suggestions that residents in Elm Quay Court are reacting because they will no longer have an empty site in front of them nor that their balconies have an adverse effect on their neighbours.  The buildings would overshadow the Linear Park and adversely affect it. 


Traffic
The discussion of the traffic implications of the development and of access by guests from public transport is naïve and both are concerning for their consequent impact on the safety of road users and pedestrians using this part of Nine Elms. Proposals to make Ponton Road more attractive for pedestrians and cyclists are put forward to justify the lack of off street parking for the hotel.  They ignore the fact that this is the main vehicle access route to the Waitrose car park and through to the US Embassy and other buildings.  As we noted in our response to the initial consultation (attached) we consider these proposals unworkable.  


The lack of off-street parking and of an off-road approach from Nine Elms Lane would add to traffic congestion along this relatively narrow and heavily trafficked road.  We cannot agree that the majority of hotel guests would only use public transport. It is more reasonable to assume (as does the Transport Assessment) arrivals by car or taxi, at least for the check in and check out journeys.  It also seems likely that taxis and other car services will want to wait nearby. 


The Transport Assessment ((table 6.3) estimates a p.m. peak hour taxi drop off of 31 taxis, i.e. one every 2 minutes. Given that it will take at least the same time and probably longer for guests to get in and out of each taxi ( and for some to also pay the fare) this could lead to a significant back up of taxis at the drop off area. Even if this is a ‘worst-case scenario’ it confirms our view that there will be significant taxi journeys made to the hotel.  The U-turn proposed for hotel traffic to regain entry to Nine Elms Lane looks awkward and potentially dangerous for both drivers and pedestrians. 


It is not clear whether coach travel will be appropriate to one of the two hotel offers but the proposals for the way in which a coach could drop off adds to our concern with the acknowledgement that:


“Given the constraints of the site and the size of a coach, it has not been possible to provide space within the curtilage of the site for a coach to safely unload guests while entering and exiting in forward gear” and that ... “To exit Ponton Road, the coach would reverse into the service yard entrance”.  Transport Assessment Part A p.32


Hotel Supply and the relation between the two separate hotel offers
We are not equipped to comment on the demand for hotel space in the future but do query the way in which existing and planned hotel offers are downplayed within the documentation.  We assume that the Nine Elms team at Wandsworth Council will be providing an economic assessment of hotel demand to aid officers and the Planning Applications Committee (PAC) in their assessment of this application. We consider the case for the two separate offers of the hotels is not fully made, nor any distinction made between different patterns of travel to the hotels and use of hotel and local facilities. It is not clear howthe facilities of the two hotels as proposed are complementary or discrete (eg breakfast area, lobbies, conference areas and restaurant on first floor of the south hotel).  We also have concerns as to how the central green link would actually be managed as a public throughway within the private areas of the hotels. 


Public Realm
The visual presentations of the green arbour, green link and Ponton Road gateway all give an impression of much larger open areas than the actual dimensions imply. Given the height and massing of the two buildings, the green arbour is more a narrow dark passage alongside the Embassy. It is conjectured that once construction across the south side of Nine Elms is complete Ponton Road will have relatively modest traffic loads. We dispute this.  Visuals suggest that the two sides of the street will effectively merge opposite the entrance to the proposed community café and those on pages 55 – 59 of the DAS are strangely free of road traffic!  This is hardly a realistic representation of the main artery road into the extensive developments on this side of Nine Elms Lane. We consider the greening of any central reservation in Ponton Road could only be very limited, and not lush trees as suggested. 


Statement of Community Involvement
While this sets out the details of the consultation fully it does not accurately reflect the response, given that it concentrates on the questionnaire and, as far as we can see, omits any mention of the objections voiced by ourselves and others.  It does note that 76% objected to the proposals (although 70 is an insufficient base to be significant).  There is also the suggestion that objections came mainly from the residents of Elm Quay Court which, while it may be true of the questionnaire, does not reflect the much wider concern about these proposals.  


Conclusion
We urge the PAC to recognise the good sense of the original plans for the whole site and to reject this application, calling instead for plans which maintain the integrity of the original plans consented at 2011/1815


Our response to the original consultation can be found here


You can see full details of this application and other comments, or to make your own views known by copying 2020/2047 and pasting it into the box you will find here