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HE Proof of Evidence Final 14 5 18 TOWN AND COUNTRY PLANNING ACT 1990 SECTION 79 AND TOWN AND COUNTRY PLANNING (INQUIRIES PROCEDURE) (ENGLAND) RULES 2000 PROOF OF EVIDENCE MICHAEL ALAN DUNN BA, MA, Dip UD, IHBC Application by Starbones Ltd. Land at Chiswick Roundabout, Great West Road, Chiswick, London W4 5QB Local Planning Authority reference 00505/EY/P18 PINS reference APP/F5540/W/17/3180962 1 CONTENTS 1.0 INTRODUCTION 3 2.0 ROLE OF HISTORIC ENGLAND 5 3.0 SCOPE OF EVIDENCE 6 4.0 THE PROPOSALS AND HISTORIC ENGLAND’S INVOLVEMENT WITH THE APPLICATION SITE 7 5.0 DECISION-MAKING CONTEXT 11 5.1. Statutory duties ............................................................................................ 11 5.2. National heritage policy context ..................................................................... 12 5.3. Development plan policy context .................................................................... 18 5.4. Relevant guidance ........................................................................................ 29 6.0 ASSESMENT OF THE SIGNIFICANCE OF HERITAGE ASSETS AFFECTED BY THE PROPOSALS AND THE IMPACT OF THE PROPOSALS ON THAT SIGNIFICANCE 34 6.2 Royal Botanic Gardens, Kew ......................................................................... 37 6.3 Gunnersbury Park and Kensington Cemetery .................................................. 51 6.4 Kew Green Conservation Area ....................................................................... 69 6.5 Strand on the Green Conservation Area ......................................................... 80 7.0 SUMMARY AND CONCLUSIONS 94 2 1.0 INTRODUCTION 1.1. My name is Michael Alan Dunn. I am a conservation specialist and I hold an MA in Building Conservation from the University of York (1998) and a post- graduate degree in Building Conservation from the Universität Bamberg, Germany ( Das Aufbaustudium Denkmalpflege, 1993). I also have a BA in History from the University of Minnesota (1990) and a post-graduate diploma in Urban Design from the University of Westminster (2000). I have been a Full Member of the Institute of Historic Building Conservation since 2000. 1.2. I have been professionally involved with managing change to the historic environment in England for 20 years. In summary, after working for several years as an historic buildings analyst in Germany, I began my career in England assessing historic buildings and areas and advising local authorities on heritage issues in Hertfordshire before taking up the post as Conservation Officer for the London Borough of Haringey, where I provided heritage input to inform planning and listed building consent decisions in the Borough. 1.3. I joined Historic England in 2003 as an Inspector of Historic Buildings and Areas and subsequently became a Team Leader in the London Region. My role included advising on development affecting historic buildings and areas, ranging from individual listed building proposals to major heritage-led redevelopment schemes such as for the Crown Estate in London’s West End and for Argent at King’s Cross. I played a central role in advising London Underground Ltd. during their restoration and upgrading of their listed Modernist stations, and the approach adopted helped shape elements of 3 Historic England’s Conservation Principles guidance. I was directly involved in Historic England’s acquisition of Harmondsworth Barn (listed grade I) near Heathrow Airport and its subsequent restoration. 1.4. Since 2012 I have been Historic England’s Principal Inspector of Historic Buildings and Areas for London, leading a team of nine inspectors for Greater London and accountable for their expert advice. This includes pre- application negotiations with developers and considering applications for planning permission, listed building consent and scheduled monument consent. Many of the applications I deal with are highly complex and/or politically sensitive and so referred to our London Advisory Committee 1 to inform Historic England’s response. I regularly speak on behalf of Historic England to the media and at conferences and training events and I have been a registered lecturer at the Universität Viadrina in Germany since 2009. 1.5. The evidence in this proof is true to the best of my knowledge and belief. I confirm that the opinions expressed are my true and professional opinions. 1 The purpose of the London Advisory Committee is: ‘To advise the Commission and staff of Historic England, on request, on those cases in London which are novel, contentious, of exceptional sensitivity or technical or academic complexity or which raise broader policy issues relating to: a) statutory consent applications or pre-application proposals; b) the preparation of conservation and management plans, and schemes for repair, development, management, interpretation or presentation; c) programmes and projects in London for the identification, recording, investigation and analysis of the historic environment and for the preparation of the resulting records, syntheses, reports and publications; d) the referral to UNESCO of contentious development proposals within World Heritage Sites in London; e) other relevant/appropriate matters as requested by Commission or staff’. 4 2.0 ROLE OF HISTORIC ENGLAND 2.1 Historic England is an independent grant-aided body governed by Commissioners. It was established with effect from 1 April 1984 under Section 32 of the National Heritage Act 1983. The general duty of Historic England under Section 33 is as follows: “…so far as is practicable: (a) to secure the preservation of ancient monuments and historic buildings situated in England; (b) to promote the preservation and enhancement of the character and appearance of conservation areas situated in England; and (c) to promote the public’s enjoyment of, and advance their knowledge of, ancient monuments and historic buildings situated in England and their preservation”. 2.2 Historic England’s sponsoring ministry is the Department for Digital, Culture, Media & Sport, although its remit in conservation matters intersects with the policy responsibilities of a number of other Government departments, particularly the Ministry of Housing Communities & Local Government, with its responsibilities for land use planning matters. 2.3 Historic England is a statutory consultee on certain categories of applications for planning permission and listed building consent. Similarly Historic England advises the Secretary of State on those applications, subsequent appeals and 5 on other matters generally affecting the historic environment. It is the lead body for the heritage sector and is the Government’s principal adviser on the historic environment. 2.4 Historic England encourages pre-application discussions and early engagement on projects to ensure informed consideration of heritage assets and to ensure that the possible impacts of proposals on the historic environment are taken into account. 2.5 The Historic Buildings and Monuments Commission for England was known as “English Heritage” between 1984 and 2015. In the interests of clarity and for consistency all references in this proof are to Historic England, the name adopted in 2015, whether or not the relevant organisation at the time was English Heritage or Historic England. 3.0 SCOPE OF EVIDENCE 3.1. In a letter of 17 October 2017 the Secretary of State notified the London Borough of Hounslow (the Council) that he had decided to recover the appeals for his own determination and he therefore made directions accordingly. 3.2. The scope of my evidence will include a description of the proposals, a summary of Historic England’s views upon past applications for the site, how it has dealt with the current applications, a description of the heritage assets affected and an assessment of their significance. I then assess the impact of 6 the proposals upon the significance of the heritage assets in turn, in the context of the statutory duties relevant to applications that affect the historic environment and Government policy in the National Planning Policy Framework 2012 (‘NPPF’, CDC.01), together with the relevant advice produced by Historic England. 4.0 THE PROPOSALS AND HISTORIC ENGLAND’S INVOLVEMENT WITH THE APPLICATION SITE 4.1 The proposals are for the redevelopment of the site with a tall building of two tower elements, one reaching 120m AOD (32 storeys) and the other reaching 109m AOD (25 storeys). A mix of uses is proposed including retail, commercial and residential. The building will be of curvilinear form and clad with a range of coloured fins of different design and orientation. Advertising, targeting vehicular traffic on the M4, will be integrated into the design and is subject to a separate application and appeal for advertisement consent . Historic England’s involvement with previous applications 4.2 The site is located immediately north of Chiswick Roundabout and was previously occupied by a 1920s building that for many years was a branch of the NatWest Bank. That building was demolished in 1998. Historic England began providing advice on proposals for the site’s redevelopment in 1999. In that year, we objected strongly to a proposed 31 storey office building known as “the Pinnacle’, which we considered would have a highly detrimental impact on: 7 • The character and appearance of the River Thames, contrary to the aims and policies of the Thames Landscape Strategy and regional planning guidance; • The character and appearance of sites included in the Register of Parks and Gardens of special historic interest, including Kew
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