Heritage Statement Unit 11, Nos. 23-25 Mill Street, London, SE1 2BE

Acumen UK Solutions Ltd March 2021

CONTENTS

Chapter: Page:

1.0 Introduction 1 2.0 The Relevant Heritage Assets 2 3.0 The Significance of the Heritage Assets 4 4.0 Impact Assessment 12 5.0 Conclusions 16

1.0 Introduction

1.1 This Heritage Statement has been prepared on behalf Acumen UK assets affected, including any contribution made by their setting. Solutions Ltd in respect to applications for planning and Listed The level of detail should be proportionate to the assets’ Building Consent for the change of use with internal alterations to importance and no more than is sufficient to understanding the form a residential dwelling (the ‘proposed development’) at Unit potential impact of the proposals on their significance. As a 11, Nos. 23-25 St. Saviour’s Dock, Mill Street, London (the minimum the relevant historic environment record should have ‘application site’). been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is 1.2 From a heritage perspective the application site forms part of a proposed includes, or has potential to include, heritage assets with grade II listed building. It is located in the St. Saviour’s Dock archaeological interest, local planning authorities should require Conservation Area and is within the settings of a cluster of listed developers to submit an appropriate desk-based assessment and, buildings that enclose the dock and the western side of Mill Street. where necessary, a field evaluation.” (NPPF Paragraph 189)

1.3 In determining the proposals Southwark Council, as the local 1.5 Given the above legislative and policy requirements Chapter 2 of planning authority (LPA), has a series of ‘statutory duties’ under the this Heritage Statement identifies the relevant heritage assets that Planning (Listed Buildings and Conservation Areas) Act 1990 to could be affected by the proposal. Chapter 3 describes the have special regard to the desirability of preserving the listed significance of the heritage assets, proportionate to the potential buildings or their settings or any features of special architectural or impact of the proposed development. Chapter 4 provides an historic interest that they possess and also to pay special attention assessment of that potential impact and Chapter 5 makes a series to the desirability of preserving or enhancing the character and of conclusions with reference to the relevant legislation and policy appearance of conservation areas. requirements.

1.4 National planning policy in respect to the conservation of the historic environment is set out in the National Planning Policy Framework (revised 2019) (NPPF) and places the following requirements on applicants:

“In determining applications, local planning authorities should require an applicant to describe the significance of any heritage

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2.0 The Relevant Heritage Assets

Introduction Table 2.1: Listed buildings relevant to the application site:

2.1 The NPPF defines a heritage asset as follows: Listed Building: Grade:

“A building, monument, site, place, area or landscape identified as Nos. 23 and 25 St. Saviour’s Wharf II having a degree of significance meriting consideration in planning decisions, because of its heritage interest. It includes designated 2.5 Nos. 23 and 25 Mill Street form part of a group of listed buildings heritage assets and assets identified by the local planning authority that enclose the western side of Mill Street and the dock of St. (including local listing).” Saviour’s Wharf to the rear of Mill Street. Given the modest scale of the proposed internal alterations it is highly unlikely that the Designated Heritage Assets special interest of the adjoining listed buildings would be affected. However, for completeness the following listed buildings are

referred to in Chapter 3 in respect to the group value of the 2.2 The NPPF confirms that designated heritage assets comprise, World application site: Heritage Sites, scheduled monuments, listed buildings, protected

wreck sites, registered parks and gardens, registered battlefields • Vogan’s Mill, No. 17 Mill Street (Grade II Listed). and conservation areas. • New Concordia Wharf, South Block, No. 27 Mill Street (Grade II 2.3 The designated heritage assets that are relevant in considering the Listed). proposed development are identified below: • New Concordia Wharf, North-east Block with Water Tower and Chimney (Grade II Listed). • New Concordia Wharf. St. Saviour’s Block Range (Grade II Listed Buildings: Listed).

2.4 Listed buildings are designated for their special architectural or Conservation Areas: historic interest in accordance with the DCMS Principles for Selection of Listed Buildings (2010). The listed building identified in

Table 2.1 are relevant with respect to the proposed development: 2.6 Conservation areas are areas of special architectural or historic interest the character or appearance of which it is desirable to

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preserve or enhance (Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990).

2.7 The application site is located within the St. Saviour’s Dock Conservation Area.

Non-Designated Heritage Assets

2.8 Historic England guidance in Decision-Taking in the Historic Environment Good Practice Advice Note 3 (2015) advises that non- designated heritage assets may be identified through the following mechanisms:

“Non-designated heritage assets include those that have been identified in a Historic Environment Record, in a local plan, through local listing or during the process of considering the application.”

2.9 Southwark Council has published a Draft Local List however it does not include heritage assets in Mill Street or St. Saviour’s Wharf. Given the concentrations of designated heritage assets associated with St. Saviour’s Wharf, the tightly enclosed character of Mill Street and the extent and form of the proposed development a HER search has not been considered necessary to inform this Heritage Statement.

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3.0 The Significance of the Heritage Assets

Introduction an asset in its setting is also influenced by other environmental factors such as noise, dust and vibration from other land uses in the 3.1 The NPPF defines significance (for heritage policy) as: vicinity, and by our understanding of the historic relationship between places.” “The value of a heritage asset to this and future generations because of its heritage interest. The interest may be archaeological, 3.4 Historic England guidance on The Setting of Heritage Assets Historic architectural, artistic or historic. Significance derives not only from Environment Good Practice Advice in Planning Note 3 (Second a heritage asset’s physical presence, but also from its setting. For Edition, 2017) confirms that: World Heritage Sites, the cultural value described within each site’s Statement of Outstanding Universal Value forms part of its “Setting is not itself a heritage asset, nor a heritage designation, significance.” although land comprising a setting may itself be designated. Its importance lies in what it contributes to the significance of the 3.2 The setting of a heritage asset is defined by the NPPF as follows: heritage asset or to the ability to appreciate that significance.”

“The surroundings in which a heritage asset is experienced. Its 3.5 The description of the significance of the heritage assets, provided extent is not fixed and may change as the asset and its below, is proportionate to their importance and the likely impact of surroundings evolve. Elements of a setting may make a positive or the proposed development on their significance, including their negative contribution to the significance of an asset, may affect the setting. ability to appreciate that significance or may be neutral.”

3.3 The National Planning Practice Guide (NPPG) further advises, that:

“The extent and importance of setting is often expressed by reference to visual considerations. Although views of or from an asset will play an important part, the way in which we experience

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Nos. 23-25 St. Saviour’s Wharf, Mill Street (Grade II Figure 3.1: John Rocques Plan of London (1766) Listed) (https://geo.southwark.gov.uk)

Special Architectural and Historic Interest

3.6 Unit 11 occupies part of the 1st Floor of the former warehouse, which the list entry describes as follows:

“Warehouse, now residential and business units. C. 1860. Stock brick with plain parapet with copying. 6 storeys, symmetrical 9-bay front with 3 hatch ranks (now balconies) with yellow bull-nosed reveals. Entranceways either side of central hatch rank on ground floor have segmental, gauged-brick arches and yellow bull-nosed reveals. Pairs of windows each side of hatch ranks with segmental, gauged-brick arches. 5th floor has 2 cast-iron pivot hoists with

arched braces and circular bracing to spandrels. Drain pipes slightly recessed. Interior: rebuilt to include internal courtyards; some Figure 3.2: St. Saviour’s Dock (1827) (https://www.british-history original beams and cast-iron columns. Good sequence with .ac.uk) adjoining New Concordia Wharf buildings and group value with a range of wharf buildings in Mill Street.”

3.7 The mouth of the River Neckinger first provided access to the C11th Bermondsey Abbey and was later named St. Saviour’s Dock. The Conservation Area Appraisal (Southwark Council, 2003) confirms that it was fully enclosed with buildings by the beginning of the C17th. The street pattern of Shad Thames and Mill Street was identifiable on John Rocques Plans of London during the mid C18th and the dock was enclosed by an organic late Medieval townscape.

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Figure 3.3: Greenwood’s Map of London of 1830 illustrates a series Figure 3.4: Ordnance Survey Map (1872) (1:2,500) of deep blocks between Mill Street and St. Saviour’s Dock

3.9 Following the development of the adjoining warehouses the 3.8 The townscape enclosing the western side of Mill Street was western side of Mill Street remained largely unchanged. The 1951- transformed by a sequence of warehouse developments during the 53 Ordnance Survey Map confirms that all of the warehouses mid to late C19th. St. Saviour’s Wharf, incorporating the application between Mill Street and St. Saviour’s Dock had been converted to site, was constructed c.1860 with Mill Wharf to the south-west and corn mills, however the building form remained consistent during a more open aspect to the north-east, illustrated on the Ordnance the C20. The Ordnance Survey Map of 1983-90 illustrates that Survey Map of 1872, prior to the construction of Vogan’s Mill and large, continuous, footprint of St. Saviour’s Wharf. However, an New Concordia Wharf during the 1880s. The developing townscape aerial photograph from 2002 confirms that the former warehouse on the eastern side of St. Saviour’s Dock contrasted with the finer had been partly reconstructed by that time and the plan form grain of narrow frontages that enclosed the western side of the incorporated two larger inner light-wells, indicating that the wharf inlet at that time. had been reconfigured for residential apartments by that time.

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Figure 3.5: Ordnance Survey Map 1983-90 (incomplete) (1:1,250) 3.10 The former warehouse is six storeys in height. The elevation to Mill Street includes three letting-in bays within a symmetrical elevation, totalling nine bays in a 1-1-2-1-2-1-1 pattern. The double bays to the centre of the elevation incorporate single entrance doors. All of the door and window openings are under segmental gauged-brick arches. The reveals to the doors and letting-in bays are emphasised with yellow bull-nose brick detailing. The upper floor openings to the letting-in bays have been adapted to form balconies to the apartments and the fenestration to the Mill Street elevation has been renewed.

Figure 3.7: The Mill Street elevation of St. Saviour’s Wharf

Figure 3.6: Aerial Photograph 2002 (Google Earth Pro)

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3.11 Much of the internal floorplan and original roof of the former to the unit are constructed with exposed brickwork, including bull- warehouse appears to have been removed during the late C20th nose brick detailing that matches the elevation to Mill Street. conversion. A comparison from 1922 and a current aerial view confirms that only the eastern and western ends of the hipped Figure 3.9: The view from Unit 11 into the internal courtyard roofs were retained and the central part of the warehouse was reconstructed to include a new roofscape and two large light- wells/courtyards

Figure 3.8: The original warehouse roofscape compared with the current arrangement

Figure 3.10: The staircase to Unit 11

3.12 The application site comprises a unit that faces onto one of the modern internal courtyards rather than an external elevation to either Mill Street or St. Saviour’s Dock. The unit incorporates a modern domestic balcony onto the courtyard and is accessed from a reconstructed staircase that leads from Mill Street. The interior of Unit 11 includes modern fixtures and services, but has retained two iron columns and the associated timber beams. The internal walls

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Figure 3.11: The retained columns and beams to Unit 11 Figure 3.13: The existing entrance, storage cupboard and balcony to Unit 11

Figure 3.12: The internal elevation to the inner courtyard

The Contribution of Setting to Significance

3.13 Setting makes an important contribution to the significance of St. Saviour’s Wharf. Although the interior of the former warehouse has been reconfigured it forms part of an important group of warehouses that developed alongside St. Saviour’s Dock. The external elevations clearly demonstrate the warehouse typology and complement the adjoining Vogan’s Mill and New Concordia Wharf in respect to their historic function and dock-side location.

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3.14 The adjoining warehouses are broadly consistent in form and overlook the water on both sides of the dock generates its character height, and each contribute to the intense sense of enclosure in and also influences the character of the streets that serve them. Mill Street and to the dock itself. The footprint and depth of the blocks is illustrative of a phase of growth and the need to maximise The practical need to maximise building areas for the business of the useable space of each block. storing goods coming in off the ships led to almost complete building coverage of plots, with no external space except for the 3.15 The consistent use of yellow London stock brick, quite austere public streets that provided essential access to them. The streets elevations and minimal detailing also adds to a sense of continuity themselves are reduced to minimal widths and in Shad Thames within the setting of St. Saviour’s Wharf. warehouses are linked to one another with catwalks and bridges above. Buildings in the most valuable locations on the riverfront are St. Saviour’s Wharf Conservation Area typically built 6 or 7 and up to 9 storeys high.”

3.16 St. Saviour’s Dock Conservation Area was originally designated in Figure 3.14: The view, south, into St Saviour’s Dock 1973. The boundary is drawn tightly around the dock and associated hinterland, following the alignment of Shad Thames on the western side of the dock and extending east to include part of Worsley Street and Jacob Street and culminating at the northern end of East Lane. A Conservation Area Appraisal was published in 2003.

3.17 The Conservation Area Appraisal identifies three character areas, the first of which comprises Shad Thames, St. Saviour’s Dock and Mill Street and includes the application site.

3.18 The Conservation Area Appraisal summarises Character Area 1 as follows:

“St. Saviour’s Dock is the distinctive feature around which the Conservation Area is based. The unbroken line of warehouses that

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3.19 The character of Mill Street is slightly more variable, with the 3.20 St. Saviour’s Wharf clearly makes a positive contribution to the eastern side of the street enclosed by lower, three-storey, character and appearance of the conservation area. However, the buildings, several of which comprise relatively recent application site, comprising an internal unit overlooking the developments. However, the Conservation Area Appraisal modern inner courtyard, does not contribute to the key views and confirms: vistas within the conservation area, is associated with the substantial reconstruction of a key warehouse and is considered to “The original parts of Vogan’s Mill, New Concordia Wharf and St. make a neutral contribution to the significance of the conservation Saviour’s Wharf together form an important six-storey group on the area. western side of Mill Street. Reeds Wharf is connected to this group by China Wharf, a modern apartment of warehouse architecture that exploits some of the larger scale traditional features, such as broad relieving arches and dominant gables. Wall cranes are an important feature of the dock elevations of St. Saviour’s and New Concordia Wharves.”

Figure 3.15: New Concordia Wharf adjoining St. Saviour’s Wharf

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4.0 Impact Assessment

Introduction desirability of preserving or enhancing the character or appearance of that area.” 4.1 The proposed development has been assessed in accordance with the relevant legislation, national and local planning policies. 4.3 Case law has determined that ‘preserve’ means ‘to do no harm’.

The Planning (Listed Buildings and Conservation National Planning Policy Framework Areas) Act 1990

4.4 Paragraph 190 requires LPAs to identify and assess the particular 4.2 The 1990 Act incorporates several ‘statutory duties’ for decision- significance of any heritage asset that may be affected by a makers, including the following: proposal, including development affecting the setting of a heritage asset, taking account of available evidence and any necessary “S. 16 (2): In considering whether to grant Listed Building Consent expertise. LPAs should take this into account when considering the for any works the local planning authority or the Secretary of State impact of a proposal on a heritage asset. shall have special regard to the desirability of preserving the

building or its setting or any features of special architectural 4.5 In determining applications, Paragraph 192, requires LPAs to take interest which it possesses.” account of:

“S. 66 (1): In considering whether to grant planning permission or a) the desirability of sustaining and enhancing the significance of permission in principle for development which affects a listed heritage assets and putting them to viable uses consistent with building or its setting, the local planning authority or, as the case their conservation; may be, the Secretary of State shall have special regard to the b) the positive contribution that conservation of heritage assets can desirability of preserving the building or its setting or any features make to sustainable communities including their economic vitality; of special architectural or historic interest which it possesses.” and c) the desirability of new development making a positive “S. 72 (1) In the exercise, with respect to any buildings or other land contribution to local character and distinctiveness. in a conservation area, of any powers under any of the provisions mentioned in subsection (2), special attention shall be paid to the

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4.6 When considering the impact of a proposed development on the or architectural significance. Planning proposals that have an significance of a designated heritage asset, great weight should be adverse effect on the historic environment will not be permitted. given to the asset’s conservation. “This is irrespective of whether any potential harm amounts to substantial harm, total loss or less The character and appearance of Conservation Areas should be than substantial harm to its significance.” (Paragraph 193) recognised and respected in any new development within these areas. Article 4 Directions may be imposed to limit permitted 4.7 Paragraph 194 states that any harm to, or loss of, significance to a development rights, particularly in residential areas. designated heritage asset, should require clear and convincing justification. Paragraph 196 requires that in circumstances that In this policy the term historic environment includes conservation would lead to less than substantial harm to a designated heritage areas, listed buildings scheduled monuments, protected London asset, the harm should be weighed against the public benefits of Squares, historic parks and gardens and trees that area protected the proposal, including, where appropriate, securing its optimum by Tree Preservation Orders, trees that contribute to the character viable use. or appearance of a conservation area and ancient hedgerows.”

4.8 LPAs should look for opportunities for new development within the Policy 3.16: Conservation Areas setting of heritage assets to enhance or better reveal their significance. Proposals that preserve those elements of the setting “Within conservation areas, development should preserve or that make a positive contribution to the asset should be treated enhance the character or appearance of the area. favourably (Paragraph 200). New development, including Alterations and Extensions. Southwark Local Plan Planning permission will be granted for new development, including 4.9 Until the New Southwark Plan (2033) is adopted, local planning the extension or alteration of existing buildings provided that the policies are contained in the Saved Southwark Plan (2007) and the proposals: Core Strategy (2011). i. Respect the context of the conservation area, having regard to the Policy 3.15: Conservation of the Historic Environment content of conservation area appraisals and other adopted supplementary planning guidance/documents; and “Development should preserve or enhance the special interest or ii. Use high quality materials that complement and enhance the historic character or appearance of buildings or areas of historical conservation area; and

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iii. Do not involve the loss of existing traditional features of interest 4.11 The NPPF Consistency Review (2013) concluded that the above which make a positive contribution to the character and policies can be given ‘significant weight’, however this is in the appearance of the conservation area; and context of the consideration of ‘heritage significance’ and the iv. Do not introduce design details or features that are out of balancing of harm or loss against other public benefits in the character with the area, such as the use of windows and doors London Plan, which are not included in the Local Plan (2007). made of aluminium, uPVC or other non-traditional materials;”

4.10 Policy 3.16 also covers proposals that involve demolition, which is Impact Assessment not relevant in respect to the proposed development. 4.12 The proposed development comprises the change of use of Unit 11 Policy 3.17: Listed Buildings to form a residential apartment. The apartment would have two double bedrooms, one with an en suite, a separate bathroom and “Development proposals involving a listed building should preserve kitchen/dining living room. the building and its features of special architectural or historic interest. 4.13 The proposed development would not require any external alterations to the building. The principal elevations of St. Saviour’s Alterations and Extensions Wharf, facing Mill Street and St. Saviour’s Dock would remain unchanged and those key aspects of the building, which allow the Planning permission for proposals which involve an alteration or significance of the Wharf to be appreciated, would be preserved by extension to a listed building will only be permitted where: the proposed development. The proposed residential use would face onto the inner courtyard, which is domestic in character, and i. There is no loss of important fabric; and would not affect the appreciation of the significant elements of the ii. The development is not detrimental to the special architectural or building. historic interest of the building; and iii. The development relates sensitively and respects the period, 4.14 Internally, the principal surviving historic features within Unit 11, style, detailing and context of the listed building or later additions comprising the two columns and associated timber beams, would of architectural or historic interest; and be retained in situ. The existing exposed brickwork would also iv. Existing detailing and important later additional features of the remain uncovered. building are preserved, repaired or, if missing, replaced.”

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4.15 The existing space would be subdivided to take advantage of the the significance of the designated heritage asset with a change of window bays to the inner courtyard and enable the proposed use that would be consistent with its conservation (NPPF Paragraph bedrooms to be formed. However, the large-scale internal spaces 192). The proposals would not cause harm to the significance of the of the warehouse were essentially removed when the building was identified heritage assets and therefore NPPF Paragraphs 194-196 reconfigured during the late C20th conversion. The iron columns are not engaged in this instance. While proposals that preserve would be retained within the living room and the central bedroom. those elements of setting that make a positive contribution to the The proposed partitions would not harm the historic features of heritage asset should be treated favourably (NPPF Paragraph) 200. the space and could be removed if the use of the building ever changed again in the future. The proposed conversion would 4.20 In respect to the ‘saved policies’ of the Southwark Local Plan therefore cause further physical change within Unit 11, however (2007), the proposed development would preserve the historic that change would not harm the significance of the designated environment (Policy 3.15). The proposals would also preserve the heritage asset. character and appearance of the St. Saviour’s Conservation Area (Policy 3.16). 4.16 In this context, the proposed development is considered to be in accordance with S.16 of the Planning (Listed Buildings and 4.21 The proposed conversion would cause change within Unit 11 of St. Conservation Areas) Act 1990 as it would preserve the special Saviour’s Wharf. However, that change would take place in the architectural and historic interest of the listed building. context of the wide-ranging reconfiguration of the central part of the warehouse in the late C20th. The internal features that 4.17 The proposed development would not impact on the contribution survived that large-scale conversion would be retained in Unit 11 of ‘group value’ to the significance of St. Saviour’s Wharf, or cause and the new partitions would be reversible in the future. Case Law any change within the setting of the adjoining listed buildings. (South Lakeland, 1992) has confirmed that ‘preserve’, in this Therefore, the proposed development is considered to meet the context, is to be taken to mean ‘to do no harm’, as opposed to requirements of S.66 of the 1990 Act. preventing change. Furthermore, the NPPF definition of Conservation (for heritage policy) is “The process of maintaining 4.18 Similarly, the proposals would preserve the character and and managing change to a heritage asset in a way that sustains appearance of the St. Saviour’s Wharf Conservation Area and are in and, where appropriate, enhances its significance.” In this context, accordance with S.72 of the 1990 Act. the proposed changes to Unit 11 of St. Saviour’s Wharf would preserve the elements that contribute positively to its heritage 4.19 With reference to the NPPF, the proposals have been informed by a significance would be consistent with the ‘saved polices’ of the proportionate description of the significance of the relevant Local Plan. heritage assets (NPPF Paragraph 189). The proposals would sustain

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5.0 Conclusions

5.1 The application site forms a single unit within St. Saviour’s Wharf, a duties’ of the Planning (Listed Buildings and Conservation Areas) grade II listed former warehouse located between Mill Street and Act 1990. St. Saviour’s Dock. The Wharf adjoins several other listed buildings and is located in the St. Saviour’s Dock Conservation Area. 5.5 The proposals would satisfy the NPPF objective of conserving the historic environment and are also consistent with the relevant 5.2 Th current space of Unit 11 St. Saviour’s Wharf was formed in the ‘saved policies’ of the Local Plan. late C20th at the time the former warehouse was reconfigured, to include two large inner courtyards, and converted mostly to residential use. The external windows to Unit 11 face into one of the internal courtyards. Although the unit was adapted as part of the wider conversion, it retains two iron columns, the associated timber beams and an area of decorative brickwork.

5.3 The proposed development comprises the conversion of the existing space into a two-bedroomed apartment. The proposals would introduce several new partitions, however all of the existing details that contribute to the significance of the listed building would be retained. The proposals would not change the external appearance of St. Saviour’s Wharf and while the proposed partitions would be reversible if the use changed again in the future the proposed internal change is considered to represent a neutral impact on the significance of the heritage assets.

5.4 The proposed development would preserve the special architectural and historic interest of St. Saviour’s Wharf and the character and appearance of the St. Saviour’s Dock Conservation Area. The proposals are therefore in accordance with the ‘statutory

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