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Town and Country Planning Act 1990 Appeal By TOWN AND COUNTRY PLANNING ACT 1990 APPEAL BY STARBONES LTD LAND AT CHISWICK ROUNDABOUT, GREAT WEST ROAD, CHISWICK, LONDON W4 APP/F5540/W/17/3180962 & APP/F5540/Z/17/3173208 PROOF OF EVIDENCE: ROYAL BOTANIC GARDENS, KEW WORLD HERITAGE SITE Andrew Croft BA MA On behalf of Royal Botanic Gardens, Kew May 2018 CONTENTS 1.0 QUALIFICATIONS AND EXPERIENCE ............................................................ 3 2.0 DEVELOPMENT AND SCOPE OF EVIDENCE .................................................. 5 3.0 LEGISLATIVE AND PLANNING POLICY CONTEXT ........................................ 9 4.0 SETTING AND THE ASSESSMENT OF IMPACT ............................................. 45 5.0 ROYAL BOTANIC GARDENS, KEW WORLD HERITAGE SITE ...................... 53 6.0 OTHER AFFECTED ASSETS WITHIN THE WHS ............................................. 84 7.0 REVIEW OF THVIA AND THVIA ADDENDUM........................................... 107 8.0 CONCLUSIONS .......................................................................................... 113 Appendices A EXTRACTS FROM 2014 WHS MANAGEMENT PLAN B EXTRACTS FROM 2002 WHS CONSERVATION PLAN C SUPPORTING MATERIAL D ILLUSTRATIVE PHOTOGRAPHS E HISTORIC ILLUSTRATIONS, MAPS AND PLANS F 2014 PERIODIC REPORT G EXTRACTS FROM 2014 WHS MANAGEMENT PLAN RELATING TO SETTING H EXTRACTS FROM LONDON BOROUGH OF RICHMOND LOCAL PLANS I LAND BETWEEN CITY FARM AND COTSWOLD VIEW, BATH: APPEAL DECISION J LAND SOUTH OF ST GEORGE’S ROAD, HAYLE: APPEAL DECISION K ELIZABETH HOUSE, 39 YORK ROAD, LONDON: APPEAL DECISION L LAND OFF NORTH AVENUE, DARLEY ABBEY: APPEAL DECISION 1.0 QUALIFICATIONS AND EXPERIENCE 1.1.1 My name is Andrew Croft. I am a Director at Chris Blandford Associates, an independent environmental, heritage and landscape consultancy. I was formerly a Technical Director at Atkins Ltd, a firm of multi- disciplinary engineering and environmental consultants. 1.1.2 I am a professional heritage consultant with a BA in Archaeology and Prehistory and a MA in Landscape Archaeology, both from the University of Sheffield. I have over 20 years’ experience in heritage management and environmental planning. 1.1.3 I have considerable experience in relation to the management of World Heritage Sites (WHSs) in the UK and overseas. I have supported sites at all stages in their development from initial feasibility, through nomination and onto management planning and development control. I have also supported the development of destination and tourism masterplans for a number of WHSs; as well as pioneering the development of Capacity Studies, Setting Studies and adopted Supplementary Planning Documents for WHSs in the UK. I have prepared legally binding Decrees for a WHS in Oman and engaged with the International Council on Monuments and Sites (ICOMOS) and the United Nations Education, Scientific and Cultural Organisation (UNESCO) and supported various nomination and advisory missions. 1.1.4 Relevant projects include preparing Management Plans for the Liverpool WHS, Durham Castle and Cathedral WHS, Giants Causeway WHS and Bahla Fort WHS (Oman); development of a capacity and setting study for the Saltaire WHS; a transport strategy for the Avebury WHS; a setting study for the Orkney WHS; a regeneration strategy for part of the Derwent Valley Mills WHS; and a full Supplementary Planning document for the Liverpool WHS. I have also developed a number of strategies for sustainable tourism projects at WHSs including the Hadrian’s Wall WHS, Al Zubarrah (Qatar) WHS and Orkney WHS. I am currently advising Highways England on the proposed A303 scheme through the Stonehenge WHS. 1.1.5 Notably, I played a key role in the successful Nomination of the Royal Botanic Gardens, Kew WHS in 2002 / 2003, including defining the significance of the Site, its boundaries and its Buffer Zone. I led the preparation of the Nomination Document, WHS Management Plan and full Conservation Plan for the Site. Key elements of the 2002/3 Management Plan were carried forward into the 2014 Management Plan. 1.1.6 I have developed numerous conservation plans, management plans and strategies for heritage sites in the UK. I have also prepared conservation plans and studies for archaeological complexes, historic buildings and historic landscapes; as well as Historic Landscape May 2018 3 Proof of Evidence: RBG, Kew WHS Kew Curve-PoE_05-18-AC (FINAL) Chris Blandford Associates Characterisation studies. Clients have included English Heritage, Historic England, Historic Scotland, Cadw, the National Trust, numerous councils and other charities and organisations. 1.1.7 I have prepared detailed analyses of the setting of important heritage sites to inform their conservation and long-term planning decisions and strategies. This has included work for the Orkney WHS, Belton House and Gardens, Hardwick Hall and the Thornborough Henges. My work for the Royal Botanic Gardens, Kew WHS, Saltaire WHS, Durham WHS and Liverpool WHS also involved extensive analysis of setting and approaches to the management of change within that setting. 1.1.8 I have broad experience in the heritage and environmental planning sector. This includes preparation of a large number of Environmental Statements (ES) for schemes across the UK, including for wind energy developments, housing developments, road projects, rail schemes, defence projects and flood alleviation works. This work has been undertaken for a range of private and public sector clients. 1.1.9 I have served as an expert witness at inquiries in relation to the impact of wind energy schemes, highways and housing developments on the setting, character and fabric of the historic environment. 1.1.10 I am familiar with the Royal Botanic Gardens, Kew WHS and its setting. I have visited the WHS and its environs on a number of occasions in preparing for this inquiry and in preparation of the WHS Nomination and Management Plan. Additionally, I have been to the Royal Botanic Gardens, Kew as a visitor on a number of occasions. 1.1.11 My evidence provides my professional views on the potential impact of the proposed development on the Royal Botanic Gardens, Kew WHS. My evidence identifies all matters which I consider to be relevant and I have drawn the Inquiry’s attention to such matters that could affect perceptions of the validity of my professional views. The contents of my evidence are correct to the best of my knowledge and the opinions expressed are my true and professional opinions. May 2018 4 Proof of Evidence: RBG, Kew WHS Kew Curve-PoE_05-18-AC (FINAL) Chris Blandford Associates 2.0 DEVELOPMENT AND SCOPE OF EVIDENCE 2.1 Development Proposals 2.1.1 The appeal relates to two applications: Planning application (Appeal ref. APP/F5540/W/17/3180962 - LPA ref. 00505/EY/P18) “Redevelopment of site to provide a mixed-use building of one part ground plus 31 storeys and one part ground plus 24 storeys, comprising 327 residential units (Use Class C3), office (Use Class B1) and retail/restaurant uses (Use Class A1-A3), basement car and bicycle parking, resident amenities and hard and soft landscaping with all necessary ancillary and enabling works” Advertisement consent application (Appeal ref. & APP/F5540/Z/17/3173208 – LPA ref. 00505/EY/AD22) “Erection of three internally illuminated fascia signs to proposed building” 2.1.2 My evidence relates to Appeal ref. APP/F5540/W/17/3180962. 2.1.3 The scheme is described in the appellant’s Design and Access Statement (CDA.01 + CDA.02) and accompanying application drawings (CDA.17). 2.2 Determination of Application and RGBK’s Objection 2.2.1 Both applications were refused by the Local Planning Authority on the 9th of February 2017. Five reasons for refusal were given, the first of which is relevant to my evidence: “1. The development, by virtue of its location, scale and design, would cause harm, including substantial harm to a range of designated heritage assets including Royal Botanic Gardens Kew World Heritage Site, a Grade II* listed registered park, listed buildings of all grades, locally listed buildings and conservation areas through harm to their settings. It has not been demonstrated that the substantial harm would be necessary to achieve substantial public benefits that outweigh that loss or that the public benefits of the proposal would outweigh the harm caused. The development is contrary to policies 7.8 (Heritage assets and archaeology), 7.10 (World Heritage Sites), 7.7 (Location and design of tall and large buildings) and 7.4 (Local character) of the London Plan (consolidated with alterations since 2011), policies CC4 (Heritage), CC3 (Tall buildings) and GB1 (Greenbelt and Metropolitan Open Land) of the Hounslow Local Plan (2015) and the aims and objectives of the aims and objectives of the National Planning Policy Framework (2012)” May 2018 5 Proof of Evidence: RBG, Kew WHS Kew Curve-PoE_05-18-AC (FINAL) Chris Blandford Associates 2.2.2 The Royal Botanic Gardens, Kew (RBGK; the organisation) objected to the development in February 2016 (see letter CDE.07). This stated that: “We wish to object to this application due to the substantial harm the proposed building will cause to attributes contributing to Kew’s Outstanding Universal Value (OUV) as set out in our World Heritage Site Management Plan, namely: i) Kew’s rich and diverse historic cultural landscape, and ii) Kew’s iconic architectural legacy, in particular Kew Palace and the Orangery. We also object to harm the proposed building would cause to the setting of the World Heritage Site, particularly views from Kew Green.” 2.2.3 RBGK also provided a concise report in December 2016 responding to the appellant’s amended Townscape, Heritage and Visual Impact Assessment (THVIA) (CDE.07). This report is considered further in Section 7 of this proof of evidence. 2.2.4 Historic England, as the Government’s statutory advisor on the historic environment has objected to the scheme, partly on the basis of its impact on the Royal Botanic Gardens, Kew WHS. Additionally, the local planning authority has also refused the scheme citing the impact on the setting and Outstanding Universal Value (OUV) of the WHS in its reason for refusal.
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