Town and Country Planning Act 1990

Appeal by Starbones Ltd

Proof of Evidence of Philip Grover BA (Hons), BTP, DIP ARCH (CONS), MRTPI, IHBC

relating to

Design and Heritage matters

on behalf of

London Borough of Hounslow

Planning Application Reference: 00505/EY/P18 & 00505/EY/AD22

Appeal Reference: APP/F5540/W/17/3180962 & APP/F5540/Z/17/3173208

May 2018

Contents

Page

1.0 Witness details 2

2.0 Appeal background and scope of evidence 4

3.0 Decision-making context 9

4.0 The appeal site and appeal proposals 23

5.0 Heritage assets and impacts 27

6.0 Design issues 59

7.0 Conclusions 69

Appendix A: Plates 71

Planning appeal: Chiswick Curve © Grover Lewis Associates Ltd. Proof of evidence: Philip Grover – Design & Heritage matters May 2018 1

1.0 Witness details

1.1 My name is Philip Russell Grover and I am a Director of Grover Lewis Associates Limited, a specialist town planning and built heritage consultancy. I have over 35 years’ experience as a built heritage professional dealing with all aspects of development in the historic environment, including issues related to integration of new development within sensitive historic contexts.

1.2 I hold an Honours Degree (BA) in Architecture from Oxford School of Architecture (now Oxford Brookes University), a Bachelor’s Degree in Town Planning from South Bank Polytechnic (now South Bank University) and a Postgraduate Diploma in Architectural Conservation from the University of Bristol. I am a member of the Royal Town Planning Institute (RTPI) and a founder member of the Institute of Historic Building Conservation (IHBC).

1.3 My professional experience includes working for Gloucester City Council where, as Design and Conservation Officer, I took a leading role in the revitalisation of the city’s historic docks. At Newark and Sherwood District Council I was the Design and Conservation Manager responsible for leading a number of successful conservation-led regeneration projects in both rural and urban areas.

1.4 Between 1995 and 2005 I was Director of Postgraduate Studies in Historic Conservation within the School of the Built Environment at Oxford Brookes University and was responsible for developing the institution as one of the leading centres for conservation education and research in the UK. Research and consultancy commissions undertaken whilst at Oxford Brookes University included work for the then Office of the Deputy Prime Minister, English Heritage, Heritage Lottery Fund, IHBC and the Canal & River Trust.

1.5 Prior to setting up my own specialist consultancy in 2009 I was Director of Historic Buildings at the Newark office of CgMs Consulting, and before that Director of Historic Environment at the Central London office of RPS Planning. Since becoming a consultant I have been involved in advising a wide variety of public, charitable and private clients on design and heritage issues, often acting as a mediator between developers and local authorities/Historic England. As such I am fully conversant with national policy guidance relating to planning for the historic environment.

1.6 During my career as a historic environment specialist I have continually needed to address issues relating to the impact of development proposals on the setting of heritage assets, in respect of both large-scale and smaller projects.

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In the majority of these cases location, scale, massing, and design has been a central part of the consideration as to the acceptability of the development proposal.

1.7 In my capacity as a planning and heritage consultant I have at various times acted for developers, local authorities and third-party objectors. Consequently, I consider that I am able to take a balanced professional view in assessing the likely impact of proposals on the historic environment. I am also familiar with the issues appertaining to the setting of heritage assets, including the current and most recent guidance relating to the subject.

1.8 The evidence that I have prepared and provide for this appeal, Ref. APP/F5540/W/17/3180962 & APP/F5540/Z/17/3173208 in this proof of evidence, is true and has been prepared and is given in accordance with the guidance of my professional institution, the Royal Town Planning Institute. I confirm that the opinions expressed are my true and professional opinions.

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2.0 Appeal background and scope of evidence

Appeal details

2.1 The appeal is in respect of the refusal by the London Borough of Hounslow (hereafter referred to as the LB of Hounslow) of an application for full planning permission for the redevelopment of land adjacent to the Chiswick Roundabout, Great West Road, London W4 for a 32-storey building, plus two basement levels, comprising 327 residential units and office, retail/restaurants uses (LPA Ref: 00505/EY/P18), and refusal of an associated application for advertisement consent for three internally illuminated signage panels to the proposed building (LPA Ref: 00505/EY/AD22).

2.2 The appeal building comprises three linked elements; a 32-storey tower (120.29m AOD), a 25-storey tower (98.57m AOD) and a 17-storey link.

2.3 The planning application was submitted in December 2015. The application proposals were deemed by the LB of Hounslow to be EIA development under the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. Consequently, the application was accompanied by a wide range of technical reports including, amongst other things, a Townscape, Heritage and Visual Impact (THVIA) report (CDA.11), which constitutes volume 3 of an overall Environmental Statement (ES) dated December 2015 and submitted in support of the application. The THVIA includes an assessment of the effects of the proposed development in its townscape context, including the effect on heritage assets.

2.4 To support the analysis the THVIA, a number of ‘Accurate Visual Representations’ (AVRs) have been prepared on behalf of the Appellant, and these appear in section 9 of the THVIA. The THVIA claims, at paragraph 2.10, that ‘Each viewpoint and view from it represents the ‘maximum’ exposure’ of the development as well as its ‘maximum conjunction’ with sensitive elements of the built environment’. The THVIA goes on to assert that ‘This means that it should not be possible for readers to find potential alternative viewpoints which allow more open or representative views of the development’. As will be seen from my evidence, and that of others, these statements have been found to be inaccurate.

2.5 An addendum THVIA (CDA.15) was submitted in October 2015 in response to post-submission discussions with the Council officers and representations received from consultees. The addendum provides a more detailed assessment of the effects of the proposed development on the significance

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and setting of heritage assets, including additional information on the Royal Botanical Gardens, Kew World Heritage Site, and conservation areas at Kew Green, Strand on the Green and Gunnersbury Park. The Addendum THVIA includes additional visual representations of the proposed development in its context, to augment those in the original THVIA of December 2015.

2.6 In addition to the THVIA document, the application for planning permission, and the associated application for advertisement consent, was accompanied by a Design and Access Statement (DAS) (CDA.01) dated December 2015. This document contains an analysis of the site, the design principles and design evolution that has been applied to the development, as well as proposals for the public realm that form part of the development. An Addendum DAS (CDA.02) dated October 2016 was submitted post-application to present a summary of the design revisions to the proposed development. As well as some amendments to the internal layouts (including an increased number of proposed residential units) the addendum DAS illustrated minor changes to the external appearance of the building including revisions to the advertisement proposals and provided additional information on the façade design.

2.7 The planning application was subject to consultation with a wide variety of external bodies, including English Heritage (now Historic England). Historic England objected to the proposal.

2.8 The planning application, together with the associated advertisement application, was considered by The LB of Hounslow’s Planning Committee on 12 January 2017. Based on the recommendation in the planning officer’s report, the Planning Committee (CDB.01) resolved to refuse both the planning application and the advertisement consent application.

2.9 The Council’s Decision Notice dated 9 February 2017 in respect of the planning application (CDB.04) cited five reasons for refusal. Reason 1 relates specifically to heritage matters and Reason 2 relates to design matters. They are as follows:

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

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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).

2. The development, by virtue of its location, scale, mass and design would not constitute the very highest, outstanding quality of design required for a tall building in this location. It would cause harm to the character of the wider area around the site and the skyline. It would be contrary to policies 7.4 (Local character), 7.6 (Architecture) and 7.7 (Location of tall buildings and large buildings) of the London Plan (consolidated with alterations since 2011), policies CC1 (Context and Character), CC2 (Urban Design and architecture), CC3 (Tall Buildings) and CC5 (Advertisement Panels, Hoardings and Structures) of the Hounslow Local Plan (2015) and the aims and objectives of the National Planning Policy Framework (2012).

2.10 The Council’s Decision Notice dated 9 February 2017 in respect of the application for advertisement consent (CDB.05) cited two reasons for refusal as follows:

1. The proposed advertisements, by virtue of number, size, location, design and illuminance would adversely impact on the character and appearance of the area and would result in harm to the residential and visual amenity of neighbouring properties contrary to the National Planning Policy Framework and National Planning Practice Guidance and policies CC1 (context and character) and CC5 (Advertisement Panels, Hoardings and Structures. They would also cause harm to the quality and character of the building upon which they would be located, and would conflict with and cause harm to the character and amenity of the area, contrary to Policy CC5 (Advertisement Panels, Hoardings and Structures) of the Hounslow Local Plan 2015.

2.The advertisement panels, by virtue of size, location and illumination would have a harmful impact on the setting of nearby heritage assets and would detract from the landscape and visual amenity of the Metropolitan Open Land contrary to the National Planning Policy Framework, National Planning Practice Guidance and policies CC1 (Context and Character), CC4 (Heritage), CC5 (Advertisement Panels, Hoardings and Structures) and GB1 (Green Belt and Metropolitan Open Land) of the Hounslow Local Plan 2015.

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2.11 An appeal against the Council’s decision was lodged on behalf of Starbones Ltd. on 5 April 2017. The appeal was recovered for determination by the Secretary of State by letter of 17 October 2017.

Scope and nature of evidence

2.12 My evidence is given on behalf of the LB of Hounslow. Grover Lewis Associates was appointed by the Council in January 2018. I have been engaged as an independent expert witness to assess the scheme and to provide specialist design and heritage evidence. I have not previously advised the Council with regard to the application for planning permission.

2.13 My evidence deals solely with those aspects of the Council’s reasons for refusal that relate to design and heritage, namely matters cited in Reasons for Refusal 1 and 2 of the planning application and Reason 1 and 2 of the application for advertisement consent. As such, my evidence forms part of the Council’s case in respect of the refusal of planning permission and advertisement consent. Other aspects covered in the Council’s reasons for refusal, including, affordable housing, amenity and access are dealt with by other expert witnesses. This proof of evidence should therefore be read in conjunction with the proofs of evidence prepared by the other witnesses. I should emphasise that my evidence does not seek to weigh any harm against the wider public benefits claimed for the proposals. This aspect of the case is addressed by Mr. Baker who deals with the overall planning balance.

2.14 My evidence is informed by relevant published guidance, professional experience, and a critique of assessments made by others. I have made myself familiar with the case and carried out fieldwork and research between January and April 2018.

2.15 As part of my evidence I have provided a set of photographs (Appendix A) to illustrate some of the key points made in relation to setting, views and potential visual impact. These photographs are intended to be illustrative only, and do not purport to have the technical properties of a verified image. However, I have taken care to ensure that these photographs are a fair and reasonable representation of the views that are experienced from various positions surrounding the appeal site. It is important that these views are experienced and assessed on site.

2.16 I also include, within my proof of evidence, copies of some of the Appellant’s visualisations at reduced size. These are included for reference purposes only. The Appellant’s updated visualisations should be studied at their appropriate size and the correct viewing distance.

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2.17 Part of the LB of Hounslow’s evidence relates to the technical adequacy of the Appellant’s photomontage visualisations. This evidence is provided on behalf of the Council by Mike Spence of MS Environmental. Mr. Spence has provided a critique of the Appellant’s technical methodology for the production of visualisations and has provided alternative visualisations from some of the key positions affecting the setting of heritage assets. I have liaised with Mr. Spence in relation to the positions from which the alternative visualisations have been taken.

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3.0 Decision-making context

3.1 My evidence takes account of relevant legislation as well as both the national and local design and heritage policy context. It also has regard to relevant national guidance relating to design and heritage matters.

Statutory duties

3.2 Statutory duties relating to proposals affecting listed buildings and conservation areas are contained in the Planning (Listed Buildings and Conservation Areas) Act 1990 (CDH.01).

3.3 The relevant statutory duty relating to development affecting a listed building is contained in Section 66 (1) of the Planning (Listed Buildings and Conservation Areas) Act 1990. This makes it a duty for a local planning authority, in considering whether to grant planning permission for development which affects a listed building or its setting, to ‘have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses’. As the settings of a number of listed buildings would be affected by the appeal proposals, the statutory duty under s66 (1) is directly engaged in this instance.

3.4 The relevant statutory provision relating to development affecting conservation areas is contained in Section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990. This states that, in the exercise of planning functions, ‘with respect to any buildings or other land in a conservation area … special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area’

3.5 In the case of the appeal proposal, the proposed development does not fall within a conservation area. Therefore, I consider that the statutory duty under Section 72(1) is not engaged in this instance. Nevertheless, both national and local policies relating to of the settings of conservation areas are relevant in this instance and are discussed below.

3.6 The courts have held that ‘preserving means doing no harm’ and have established that, where a proposal would cause some harm, the desirability of preserving a listed building or its setting, or character of a conservation area, should not simply be given careful consideration, but should be given ‘considerable importance and weight’ when the decision-maker carries out the planning balance (Ref. Barnwell Manor Wind Energy Ltd v. East

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Northamptonshire District Council, English Heritage, the National Trust and the Secretary of State for Communities and Local Government [2014] EWCA Civ 137).

National heritage policy context

3.7 Central Government planning policy is set out in the National Planning Policy Framework (NPPF) (CDC.01), published in March 2012. A number of the policies set out in the NPPF are of direct relevance to the consideration of the appeal proposals.

3.8 At the heart of the NPPF is a presumption in favour of sustainable development (NPPF, para 14). The NPPF at paragraph 7 advises that sustainable development has three dimensions: economic, social and environmental. It advises, amongst other things, that the environmental role involves protection and enhancement of the built and historic environment.

3.9 The NPPF establishes at paragraph 17 a set of 12 core planning principles that should underpin both plan-making and decision-taking. These include, amongst other things, the principles that planning should:

‘Always seek to ensure high quality design and a good standard of amenity for all existing and future occupants of land and buildings’

‘Conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations’.

3.10 The NPPF defines conservation (for heritage policy) as ‘the process of maintaining and managing change to a heritage asset in a way that sustains and, where appropriate, enhances its significance’ (Annex 2: Glossary, page 51).

3.11 The NPPF defines designated heritage assets as ‘a world heritage site, scheduled monument, listed building, protected wreck site, registered park and garden, registered battlefield and conservation area, designated as such under the relevant legislation’ (Annex 2: Glossary, page 51).

3.12 Of particular relevance to my evidence are policies relating to the good design and conservation and enhancement of the historic environment. These matters are dealt with respectively in sections 7 and 12 of the NPPF.

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3.13 In respect of requiring good design, chapter 7 of the NPPF states at paragraph 58 amongst other things, that planning policies and decisions should:

‘respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation’

3.14 Paragraph 61 of the NPPF states that:

‘High quality and inclusive design goes beyond aesthetic considerations. Therefore, planning policies and decisions should address the connections between people and places and the integration of new development into the natural, built and historic environment’.

3.15 Paragraph s64 states that:

‘Permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions’.

3.16 Paragraph 67 states that:

‘Poorly placed advertisements can have a negative impact on the appearance of the built and natural environment’.

3.17 In respect of heritage matters section 12 of the NPPF refers to the concept of a heritage asset, which is defined as ‘a building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest’. (Annex 2: Glossary).

3.18 The policies in section 12 of the Framework are predicated on the concept of significance. The Annex 2: Glossary (page 56) defines the significance of a heritage asset (for heritage policy) as: ‘the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting’.

3.19 The NPPF (Annex 2: Glossary p.56) defines the setting of a heritage asset as: “The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of

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a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral”.

3.20 Paragraph 132 also makes it clear that significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. It goes on to state that ‘as heritage assets are irreplaceable, any harm or loss should require ‘clear and convincing justification’

3.21 The policies in Chapter 12 of the NPPF make provision for ‘substantial’ and ‘less than substantial’ harm to the significance of heritage assets. Where a development would cause ‘substantial harm’ to a heritage asset paragraph 132 states: ‘Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional’.

3.22 Paragraph 133 of the NPPF deals with the approach to be taken where a development proposal is considered to result in substantial harm or total loss of significance of a designated heritage asset. In such instances the NPPF states that local planning authorities should refuse consent unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh the harm or loss.

3.23 Paragraph 134 states that in cases where there is less than substantial harm to the significance of a designated heritage asset, ‘this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use’.

3.24 It should be noted that the Government has published a revised consultation draft to the NPPF (CDC.03). Consultation on the draft commenced on 5 March 2018 and closed on 10 May 2018. Most notably, the text draft document has been revised (paragraph 182) to clarify that World Heritage Sites are recognised internationally for their Outstanding Universal Value, and that this forms part of their significance and should be taken into account in considering development proposals. The draft document has also been revised at paragraph 189 to clarify that when considering the impact of a proposed development on a designated heritage asset, decision-makers should give great weight to the asset’s conservation irrespective of whether the potential harm to its significance amounts to ‘less than substantial harm’ or ‘substantial harm or total loss’ of significance.

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Development plan policy context

3.25 The development plan policy context that is relevant to this appeal comprises both the strategic policies set out the London Plan (2016) (CDC.04) and the local development plan policies set out in the London Borough of Hounslow Local Plan (September 2015) (CDD.01). The development plan policies that relate to the heritage aspects appeal proposals are summarised below:

3.26 The policies in the London Plan that are particularly relevant to design and heritage matters are Policies 7.4, 7.6, 7.7, 7.8.and 7.10.

3.27 London Plan Policy 7.4: Local Character, states, amongst other things that:

‘A development should have regard to the form, function and structure of an area, place or street and the scale, mass and orientation of surrounding buildings.’

London Plan Policy 7.4 goes on to state, in respect of planning decisions, that buildings streets and open spaces should provide a high-quality design response that:

‘has regard to the pattern and grain of the existing spaces and streets in orientation, scale, proportion and mass’

‘contributes to a positive relationship between the urban structure and natural landscape features, including the underlying landform and topography of an area’

‘is human in scale, ensuring buildings create a positive relationship with street level activity and people feel comfortable with their surroundings’

‘allows existing buildings and structures that make a positive contribution to the character of a place to influence the future character of the area’

‘is informed by the surrounding historic environment’.

3.28 London Plan Policy 7.6 Architecture, states that:

‘Architecture should make a positive contribution to a coherent public realm, streetscape and wider cityscape. It should incorporate the highest quality materials and design appropriate to its context’.

In respect of planning decisions, the policy goes on to state, amongst other things, that buildings and structures should:

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‘be of the highest architectural quality’

‘be of a proportion, composition, scale and orientation that enhances, activates and appropriately defines the public realm’

‘comprise details and materials that complement, not necessarily replicate, the local architectural character’

‘not cause unacceptable harm to the amenity of surrounding land and buildings, particularly residential buildings, in relation to privacy, overshadowing, wind and microclimate. This is particularly important for tall buildings’

‘provide high quality indoor and outdoor spaces and integrate well with the surrounding streets and open spaces’

3.29 London Plan Policy 7.7 Location and design of tall and large buildings, sets out a strategic aim that:

‘Tall and large buildings should not have an unacceptably harmful impact on their surroundings’.

In relation to planning decisions the policy goes on to state, amongst other things, that tall and large buildings should:

‘only be considered in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building’

‘relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm (including landscape features), particularly at street level;’

‘individually or as a group, improve the legibility of an area, by emphasising a point of civic or visual significance where appropriate, and enhance the skyline and image of London’

London Plan Policy 7.7 goes on to state, amongst other things, that:

‘The impact of tall buildings proposed in sensitive locations should be given particular consideration. Such areas might include conservation areas, listed buildings and their settings, registered historic parks and gardens, scheduled monuments, battlefields, the edge of the Green Belt or Metropolitan Open Land, World Heritage Sites or other areas designated by boroughs as being sensitive or inappropriate for tall buildings’.

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3.30 The supporting text to London Plan Policy 7.7 makes it clear that tall buildings can have ‘a significant detrimental impact on local character’. Consequently, it advises that ‘they should be resisted in areas that will be particularly sensitive to their impacts and only be considered if they are the most appropriate way to achieve the optimum density in highly accessible locations, are able to enhance the qualities of their immediate and wider settings, or if they make a significant contribution to local regeneration’.

3.31 London Plan Policy 7.8: Heritage Assets and Archaeology states, amongst other things, in relation to planning decisions that:

‘Development affecting heritage assets and their settings should conserve their significance, by being sympathetic to their form, scale, materials and architectural detail’.

3.32 London Plan Policy 7.10: World Heritage Sites sets out a strategic aim that:

‘Development in World Heritage Sites and their settings, including any buffer zones, should conserve, promote, make sustainable use of and enhance their authenticity, integrity and significance and Outstanding Universal Value’.

London Plan Policy 7.10 goes on to explain that the Mayor has published Supplementary Planning Guidance (SPG) entitled: London’s World Heritage Sites – Guidance on Settings. I deal with the SPG in more detail below.

In relation to planning decisions the Policy 7.10 states that:

‘Development should not cause adverse impacts on World Heritage Sites or their settings (including any buffer zone). In particular, it should not compromise a viewer’s ability to appreciate its Outstanding Universal Value, integrity, authenticity or significance. In considering planning applications, appropriate weight should be given to implementing the provisions of the World Heritage Site Management Plans’.

3.33 The policies in the Hounslow Local Plan that are particularly relevant to design and heritage matters arising in this appeal are Policies CC1, CC2, CC3, CC4 and CC5.

3.34 Local Plan Policy CC1: Context and character states, ‘the Council will recognise the context and varied character of the borough’s places and seek to ensure that all new development conserves and takes opportunities to enhance their special qualities and heritage’. It goes on to state, amongst other things, that that Council will expect developments to demonstrate how the proposal:

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‘Responds to the wider context and history of the area, its communities, its natural landscape and its urban structure, form and function’.

3.35 Local Plan Policy CC2: Urban Design and Architecture states, that the Council will ‘retain, promote and support high quality urban design and architecture to create attractive, distinctive and liveable places’. It goes on to state, amongst other things, that the Council will expect development proposals to:

‘Respond meaningfully and sensitively to the site, its characteristics and constraints, and the layout, grain, massing and height of surrounding buildings.’

‘Promote and support contemporary architecture that responds intelligently to current and future lifestyles, needs and technology, whilst ensuring it’s rooted in local context, at all scales’

3.36 Local plan Policy CC3: Tall Buildings states, that Council ‘will support tall buildings of high quality in identified locations which accord with the principles of sustainable development’. It goes on to state, amongst other things, that the Council will expect tall building proposals to:

‘Be sensitively located and be of a height and scale that is in proportion to its location and setting, and carefully relate and respond to the character of the surrounding area’

‘Be designed to give full consideration to its form, massing and silhouette, including any cumulative impacts, and the potential impact of this on the immediate and wider context’

‘Take opportunities to enhance the setting of surrounding heritage assets, the overall skyline and views’

3.37 Local Plan Policy CC4: Heritage states, amongst other things, that the Council will expect development proposals to:

‘Conserve and take opportunities to enhance any heritage asset and its setting in a manner appropriate to its significance’

‘Demonstrate that substantial harm to or loss of a heritage asset is avoided, unless exceptional circumstances can be demonstrated, consistent with the NPPF’

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‘Demonstrate that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset (see Glossary), this harm will be outweighed by the public benefits of the proposal, including securing its optimum viable use’

Local Plan Policy CC4 goes on to state, amongst other things, that:

‘Any development within or affecting a Conservation Area must conserve and take opportunities to enhance the character of the area, and respect the grain, scale, form, proportions and materials of the surrounding area and existing architecture’

The policy states that developments should:

‘Conserve and enhance the internationally recognised Outstanding Universal Value of the Royal Botanic Gardens Kew World Heritage Site, its buffer zone and its setting, including views to and from the site’.

3.38 Local plan Policy CC3: Advertisement Panels, Hoardings and Structures, states that Council recognises that ‘advertisements can have economic development benefits and that they may support regeneration objectives in appropriate locations, however all advertisements must respect their context with suitable regard to considerations of amenity and public safety’. It goes on to say, amongst other things, that its will expect development proposals to:

‘Demonstrate that the advert is sensitively placed and designed to not adversely impact the setting of heritage assets and strategic or local views’

Relevant guidance

National Planning Practice Guidance (NPPG)

3.39 Interpretation of the policies in the NPPF is provided by the on-line National Planning Practice Guidance (NPPG) (CDC.02) that was first published in March 2014. The NPPG provides guidance on a wide range of planning issues, including design and heritage matters.

3.40 In respect of heritage, the NPPG section entitled ‘Conserving and enhancing the historic environment’ emphasises the need for a clear understanding of the significance of a heritage asset and its setting in order to develop proposals which avoid or minimise harm to significance (Paragraph: 019 Reference ID: 18a-019-20140306).

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3.41 Amongst other things, the NPPG provides useful guidance on the concepts of significance, and setting, as well as guidance on how to assess if a proposal would cause substantial harm to a designated heritage asset.

3.42 The NPPG advises that ‘what matters in assessing if a proposal causes substantial harm is the impact on the significance of the heritage asset’. It reiterates the wording of the NPPF in stating that ‘significance derives not only from a heritage asset’s physical presence, but also its setting’ (Paragraph: 017 Reference ID: 18a-017-20140306).

3.43 In stating the policy position for all heritage assets, paragraph 017 of the NPPG states that ‘whether a proposal causes substantial harm will be a judgment for the decision taker, having regard to the circumstances of the case and the policy in the National Planning Policy Framework’. It goes on to say that ‘In general terms, substantial harm is a high test, so it may not arise in many cases. For example, in determining whether works to a listed building constitute substantial harm, an important consideration would be whether the adverse impact seriously affects a key element of its special architectural or historic interest’.

3.44 An important principle set out in Paragraph 009 of Section 12 of the NPPG is that, in the context of decision-taking, proper assessment of the nature, extent and importance of the significance of a heritage asset and its setting is at the heart of understanding the potential impact and acceptability of development proposals. Paragraph 020 advises that a clear understanding of significance is necessary to develop proposals which avoid or minimise harm.

3.45 In respect of design matters, the NPPG provides useful guidance in respect of promotion of local character, and the form, scale and materials of new development.

3.46 Paragraph 007 Reference ID: 26-007-20140306 advises that ‘The successful integration of all forms of new development with their surrounding context is an important design objective, irrespective of whether a site lies on the urban fringe or at the heart of a town centre’. It also advises that views into and out of larger sites should also be carefully considered from the start of the design process’.

3.47 In relation to form, the NPPG advises at Paragraph: 025 Reference ID: 26-025- 20140306 that

‘Towers can be successful, or unsuccessful, depending on where they are placed, how they relate to their surroundings, their use and their architectural

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and design quality.’ It states that ‘Some forms pose specific design challenges, for example how taller buildings meet the ground and how they affect local wind and sunlight patterns should be carefully considered. Stand alone buildings can create ill-defined spaces around them and terraces can appear monotonous and soulless if poorly designed’.

3.48 In relation to scale Paragraph: 025 Reference ID: 26-025-20140306 advises that ‘Decisions on building size and mass, and the scale of open spaces around and between them, will influence the character, functioning and efficiency of an area. In general terms too much building mass compared with open space may feel overly cramped and oppressive, with access and amenity spaces being asked to do more than they feasibly can’.

3.49 Paragraph 025 goes on to advise that

‘The size of individual buildings and their elements should be carefully considered, as their design will affect the: overshadowing and overlooking of others; local character; skylines; and vistas and views. The scale of building elements should be both attractive and functional when viewed and used from neighbouring streets, gardens and parks’.

Paragraph 025 further advises that

‘The massing of development should contribute to creating distinctive skylines in cities, towns and villages, or to respecting existing skylines. Consideration needs to be given to roof space design within the wider context, with any adverse visual impact of rooftop servicing minimised’

Historic England Guidance

3.50 The following Historic England publications provide relevant guidance: Historic Environment Good Practice Advice in Planning Note 2 (GPA2) Managing Significance in Decision-Taking in the Historic Environment (March 2015) (CDF.12) and Historic Environment Good Practice Advice in Planning Note 3 (GPA3): The Setting of Heritage Assets (December 2017) (CDF.13).

3.51 GPA2 forms part of a suite of good practice advice documents that supersede the earlier PPS5 Historic Environment Planning Practice Guide. GPA2 reiterates earlier guidance that the assessment of the significance of heritage assets is an essential part of the planning process. I have had regard to this advice in preparing this proof of evidence.

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3.52 GPA3 provides a framework for the assessment of proposed changes to the setting of a heritage asset. It gives helpful and up to date advice that provides clarity and detail to the understanding of the concept of the setting of a heritage asset.

3.53 GPA3 advises at paragraph 8 that ‘While setting can be mapped in the context of an individual application or proposal, it does not have a fixed boundary and cannot be definitively and permanently described for all time as a spatially bounded area or as lying within a set distance of a heritage asset because what comprises a heritage asset’s setting may change as the asset and its surroundings evolve ‘

3.54 In order to assess the degree of potential harm to the significance of a heritage asset, GPA3 advises a five-step approach:

• Step 1: Identify which heritage assets and their setting are affected • Step 2: Assess whether, how and to what degree these settings make a contribution to the significance of the heritage asset(s) • Step 3: Assess the effects of the proposed development, whether beneficial or harmful, on that significance • Step 4: Explore the way of maximising enhancement and avoiding or minimising harm • Step 5: Make and document the decision and monitor outcomes

3.55 In seeking to evaluate the likely impact that the revised appeal proposals would have on the setting and significance of designated heritage assets identified in this proof of evidence, I have had regard to the Historic England guidance on setting contained in GPA3.

3.56 Of particular relevance in the context of the appeal proposals for a 32-storey building on land at the Chiswick Roundabout is the Historic England Historic Environment Good Practice Advice in Planning (GPA 4) Tall Buildings (CDF.14). Published in December 2015, GPA4 replaces previous guidance on tall buildings provided by English Heritage and CABE in 2007.

3.57 GPA4 seeks to guide those involved in planning for and designing tall buildings so that they are delivered in a sustainable and successful way through the development plan and development management process. The advice is aimed at all relevant parties, including developers, designers, local authorities and other interested parties.

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3.58 GPA4 points out at paragraph 1.2, amongst other things, that ‘if the building is not in the right place and well designed a tall building, by virtue of its size and widespread visibility, can cause harm to the qualities that people value about a place.’ It goes on to state that ‘One of the principal failings in the design of tall buildings was a lack of understanding of the nature of the areas around them, and the impact they would have on both specific features of the historic environment and its general character’.

Thames Strategy – Kew to Chelsea

3.59 Thames Landscape Strategy (CDF.11) is a document commissioned in 1999 by a steering committee that included a number of agencies including the Greater London Authority, English Heritage (now Historic England) English Nature (now Natural England) the Environment Agency the Port of London Authority and the riparian boroughs including Hounslow.

3.60 The Thames Strategy covers the stretch of river between Kew and Chelsea, starting at the historic waterfront at Strand on the Green and ending at the industrial riverside at Nine Elms. The Strategy seeks to provide a long-term vision, and the basis for a more holistic approach to the many complex and interrelated issues relating to planning, management and uses relating to this stretch of the River Thames.

3.61 The objectives of the Thames Strategy correspond with other strategic planning policies aimed at protecting and managing the riverside environment of the Thames. Important local views along the Thames are identified from page 3.31 of the Strategy. It identifies the view of Strand on the Green from the Kew Tow Path as one of a number of important local views. An important objective of the strategy outlined in a table at page 3.100 in respect of views and vistas is in ‘Establishing a symbiotic and supportive relationship within a skyline. Avoiding negative impacts on strategic views, important local views, important local panoramas and local prospects.’

3.62 Part 4 of the Thames Strategy identifies the character of each of eight ‘character reaches’, which have been defined on the basis of detailed character appraisal. The first of these is Kew and Strand on the Green.

London’s World Heritage Sites – Guidance on Settings SPG

I have previously referred to the Mayor of London’s SPG on London’s World Heritage Sites – Guidance on Settings (March 2012) (CDC.11). The SPG aims to ensure ‘a more consistent interpretation of setting and understanding of their importance in contributing to an appreciation of Outstanding Universal Value,

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integrity authenticity and significance’. In doing so its purpose is to support the implementation of Policy 7.10 of the London Plan 2016 by providing:

• ‘a consolidated source of information on understanding World Heritage Sites and their settings in the context of London;

• a discussion of the elements of setting that contribute to the appreciation of Outstanding Universal Value that should be considered by policy makers, developers and other stakeholders to ensure World Heritage Sites and their settings are conserved and enhanced;

• an assessment framework with a stepped approach to assess the effect of development proposals and proposals for change in plan making on London’s World Heritage Sites and their settings.’

3.63 Section 4 of the SPG sets out the elements of setting that contribute to the appreciation of Outstanding Universal Value. It states at paragraph 4.17 that the elements of character that are particularly relevant to the setting of World Heritage Sites include, amongst other things; profile, massing, scale materials and colour. Section 5 sets out a framework for assessing impact and managing change in World Heritage Sites and their settings.

Statement

3.64 I have had regard to the above statutory duties, planning policies, and guidance, in my assessment of the impact and effects of the appeal proposal on the surrounding areas including designated heritage assets. In reaching my conclusions I have also had regard to relevant case law relating to impacts on heritage assets, namely Barnwell Manor (CDH.05), Bedford (CDH.04) and Irving (CDH.06).

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4.0 The appeal site and proposals

The appeal site

4.1 The appeal site is located to the north-west of the Chiswick Roundabout, which forms the busy traffic intersection at the junction of the A4 Great West Road, the A406 North Circular Road (Gunnersbury Road), the A205 South Circular Road, the A315 Chiswick High Road, with the elevated M4 motorway passing overhead. The site and its immediate surroundings are dominated by traffic routes that converge at this point, and in particular by the elevated section of the M4.

4.2 Historically, the Chiswick Roundabout marks the end of the Great West Road or Brentford Bypass, which was first opened in 1925, the first section of which became known as the ‘Golden Mile’ due to the vibrant businesses attracted to the area. The elevated section of dual carriageway was first opened in 1959 and became part of the M4 motorway in 1965.

4.3 The appeal site is roughly triangular in shape and is of 0.28 hectares in area. It is of modest size, measuring approximately 65 meters north to south, and 67 metres east to west. It is bound by the Chiswick Roundabout to the south, Gunnersbury Avenue to the east, Larch Drive to the north and the Great West Road and M4 to the west. Beyond Larch drive to the north is a B&Q Superstore, with an associated surface car park.

4.4 Historically, the site remained largely undeveloped until the 20th century, being part of a larger area of orchard land, and partially occupied by a small dwelling known as Gunnersbury Cottage. In 1926 a two-storey brick building was erected on the south-eastern portion of the site, providing a purpose-built branch of the National Provincial Bank (later to become the Natwest Bank) with its entrance portico facing the roundabout. Later, a small café was erected behind the bank to the north-west.

4.5 The Natwest Bank building was demolished in 1998, and the site has remained vacant since then. As previously developed land, the appeal site is regarded as a brownfield site. Currently, the site has advertising hoardings around its perimeter, including three large advertisements on each of its three corners. Plate 1 is a general view of the site.

4.6 The tallest building in the immediate vicinity of the appeal site is the BSI building, near Gunnersbury Station Chiswick, which at circa 71.3m AOD stands out as an incongruous feature in many townscape views. The elegant

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standpipe tower of the former Kew Bridge Pumping Station (now the London Steam Museum) is a local landmark standing at a height of 67m AOD. Further to the west on the Great West Road, lie the six 23-storey Brentford Towers of the Haverfield Estate, Green Dragon Lane which rise to circa 72m AOD. Another tall building to the west of the appeal site is the ‘Vantage West’ building, which stands at a height of 62m AOD. The tallest element (outline parameters) of the approved Lionel Road stadium scheme, Brentford is up to 61m AOD.

4.7 Over recent years various development proposals have come forward for the site. Mr. Baker includes a detailed list of the relevant planning history on the appeal site in his proof of evidence. Planning permission for a 13-storey (55m) office building known as the ‘Citadel’ was granted in 2002. By virtue of a commencement of the development this remains an extant permission. Subsequently, in 2012 planning permission for a 10-storey (49.67m) development comprising office, retail and outdoor advertising known as the ‘Octopus’ was granted. However, the permission for this development has now lapsed. I discuss the comparison between the impact of the extant consented ‘Citadel’ scheme and that of the appeal scheme below.

The appeal building

4.8 The appeal proposal comprises a building formed of three connected volumes of curved plan form; an east tower rising to a maximum of 32 storeys (120.29m AOD), a west tower rising to 98.57m AOD) and a 17-storey linking element. From its narrow base the building flares out gradually over the first five storeys, then rises up vertically from that point. The first six floors of the proposed 32- storey building would be used for offices, retail and/or café space and amenity space. A public atrium is proposed on the ground floor. The floors above would contain 327 residential units. Two basement levels would provide motorcycle and cycle parking, space for refuse, plant, substations and switch rooms.

4.9 I note that, at just over 120m AOD, the appeal building would be the tallest building in the borough of Hounslow and is nearly double the height of other existing tall buildings in the locality. It is much taller than the highest block of the consented Lionel Road stadium scheme, which allows for buildings up to 61m AOD.

4.10 The external envelope of the appeal building predominantly comprises clear glass curtain walling and would have a reflective appearance. The elevations are proposed to be articulated by horizontal and vertical fins of anodised aluminium, ‘wedged balconies’ and coloured panels. The vertical fins in varied colours, projecting at varied angles from the façade, are located predominantly

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on the east and west facades to provide solar shading. The horizontal fins would be similarly coloured.

4.11 The Design and Access Statement (DAS) states that the design principles for the development rely on three individual building volumes to break down the overall massing and create a composition. However, from many viewpoints the separate volumes would not easily be read, and the DAS accepts that ‘this alone is not sufficient to contrast the volumes as they merge into each other’. For this reason, the DAS explains that a colour strategy has been adopted to enhance the individuality of each separate volume. The DAS at 5.2.4. states that the colour palette ‘draws inspiration from the local environment by adopting an earth tone colour palette that emulates the natural hues of the local conservation areas’. It explains that the inspiration for this comes form the colours of reflections in the River at Strand on the Green.

Advertisements

4.12 The appeal proposals, as amended, incorporate illuminated LED digital advertisements at three locations on the lower parts of the façade to maximise viewing exposure on the principal roads that converge at the Chiswick Roundabout. The proposed advertisements were the subject of a separate advertisement regulations application. Originally there were to be four such advertisements, but one of the four, an east-facing panel at high-level, was deleted in the latest iteration of the scheme.

4.13 The DAS explains that the proposed advertising locations address viewers travelling at different speeds. The largest of the advertising panels (Screen 1) is proposed at high-level on the western corner of the building and is intended to be visible to travellers arriving into London along the M4 when travelling speeds and viewing distances are relatively high. This sign, as amended in the latest iteration of the proposals, is to be 21.5m wide and 7.8m high and set approximately 15.6m above ground level. A smaller, similarly orientated sign (screen 2) measuring 10m in width and 7.8m in height is proposed to be located beneath Screen 1 and would be positioned 3.9m above ground level and designed to target travellers on the A4. A similarly sized sign (screen 3) is proposed on the north-north-east corner of the development, facing Gunnersbury Avenue (North Circular). This sign is proposed to be 10m wide and 7.8m high, and approximately 7.8m above ground level.

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Comparison between the appeal proposal and the extant approved ‘Citadel’ scheme

4.14 As I have mentioned above, I am aware of the planning history relating to the appeal site, including the previously-approved and extant permissions. The extant approved 2002 ‘Citadel’ scheme would rise to 13-storeys (55m). This is comparable with the scale of the tallest buildings that currently exist in the area.

4.15 At 32-storeys (120.29m) the appeal proposal would be more than twice the height of the ‘Citadel’ scheme and by far the tallest building in the Borough of Hounslow. It is clear that, at this height, the appeal building would have far greater visual impact on the skyline than the approved Citadel scheme. In respect of other important heritage assets in the area, I consider that the ‘Citadel’ would be far less dominant in key views than would be the case with the appeal proposal. For example, the Citadel would hardly rise above:

• The tree line in Royal Botanic Gardens, Kew, • the tree line in Gunnersbury Park • the historic buildings that line the north side of Kew Green

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5.0 Heritage assets and impacts

Background

5.1 The THVIA document submitted as part of the application for the Chiswick Curve assessed the impacts on a wide range of heritage assets. The assessment was augmented by an addendum THVIA issued in October 2016.

5.2 In response to the assessment in the THVIA, and in order to inform decision- taking in relation to the planning application for the proposed Chiswick Curve development, the LB Hounslow commissioned a specialist report from the Built Heritage Consultancy (BHC) to assess the likely impact of the proposals on the setting and significance of heritage assets that would be affected by the proposals. The consultant’s report, dated February 2016, responds to the assessment in the THVIA. A supplementary assessment report was subsequently commissioned from BHC in the light of revisions to the proposed development, and the additional material provided by the addendum THVIA. The conclusions in both the original report and the addendum prepared by BHC are reflected in the officer’s report and recommendations to the Planning Committee.

5.3 I have read both the original THVIA and the addendum THVIA and noted the assessment of impacts of the proposed development on heritage assets in both documents. I have also read both the original and supplementary assessments undertaken by BHC on behalf of the LB of Hounslow. I have also carried out my own assessment of the impact that the appeal proposals would have on heritage assets in the area. I largely concur with the conclusions of the BHC in respect of heritage impacts.

5.4 I disagree with a number of the assessments within the THVIA and addendum THVIA. In particular I do not agree with the general tenor of argument set out by the Appellant in the THVIA that, due to the high design quality of the appeal proposal, there would be only beneficial effects, and that in consequence no harm would be caused, so that it is unnecessary to weigh harm against the public benefits of the proposal as required by the policies in the NPPF.

5.5 In a great many cases, particularly where the heritage assets in question are a considerable distance from the appeal proposal, and therefore affected by the intervening urban development or trees, I do not think there would be material harm caused to setting and significance by the proposal. Conversely, in the case of a number of heritage assets that lie close to the appeal site, including the Registered Park and Garden at Gunnersbury, the Royal Botanical Gardens World Heritage Site at Kew, and a number of conservation areas, I consider

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that material harm would be caused to significance. In some cases, I consider that there would be a very high level of harm to the significance of heritage assets caused by the appeal proposal. I discuss below the heritage assets that I consider would experience a high degree of harm.

5.6 The appeal site does not fall within a conservation area and there are no statutorily or locally designated heritage assets within the site. Likewise, the immediate context of the appeal site in the vicinity of the Chiswick Roundabout is not sensitive from a heritage standpoint. However, due to the very large bulk and height of the appeal proposal, there are a great many heritage assets beyond the immediate vicinity of the site that could potentially be impacted upon by the appeal proposal.

5.7 A number of important area-based heritage assets, each containing individually designated and non-designated heritage assets, are located in relatively close proximity to the site and would be impacted upon by the appeal proposal. Most notably these include the Royal Botanical Gardens, Kew, which is inscribed as a World Heritage Site as well as being designated as a grade I Registered Park and Garden and a conservation area. Part the World Heritage Site also lies within the Kew Green Conservation Area. Also notable is the grade II* Registered Park and Garden at Gunnersbury Park (which is located within the Gunnersbury Park Conservation Area).

5.8 In addition to the designated historic landscapes referred to above, a number of conservation areas would be impacted upon by the appeal proposals. The closest of these to the appeal site is the Gunnersbury Park Conservation Area, which lies a short distance to the north. Also close to the appeal site is the Thorney Hedge Conservation Area, which lies a short distance to the east, the Kew Bridge Conservation Area that lies a short distance to the south west, and the Wellesley Road Conservation Area, which lies a short distance to the south. Slightly further to the south, beyond the Wellesley Road Conservation Area, is the Strand on the Green Conservation Area, which occupies a position on the north bank of the River Thames. The conservation area includes part of the River Thames itself, up to its midstream point at the boundary between the London Boroughs of Hounslow and Richmond upon Thames. Immediately abutting Strand on the Green Conservation Area, on its east side, and also bordering the River Thames, is the Grove Park Conservation Area. To the immediate north of the Grove Park Conservation Area is the Chiswick House Conservation Area. Immediately to the south of the Strand on the Green Conservation Area, on the south side of the River Thames, is the Kew Green Conservation Area, which lies within the London Borough of Richmond upon Thames and includes part of the River Thames up to its midstream point.

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5.9 Conservation area character statements were adopted for each of the above conservation areas within in the LB of Hounslow in March 2006. These character statements set out the defining characteristics of the conservation areas. The Council is currently in the process of reviewing of its conservation area statements to provide greater clarity of the key elements that need to be protected. Draft appraisals for the Wellesley Road, Thorney Hedge, Strand on the Green, Kew Bridge, and Gunnersbury Park Conservation Areas have been prepared by LB of Hounslow. These appraisals provide more detailed analysis of the key attributes of the conservation areas, and include maps showing key views. I understand that the draft appraisals are the subject of public consultation from 7 May 2018 for six weeks.

5.10 In this proof of evidence, I focus strongly on the area-based heritage assets referred to above, as well as the most affected individual heritage assets that fall within them. Below I summarise the significance of each of these area- based heritage assets (including where appropriate component heritage assets), as well as highlighting the contribution that setting makes to their significance. I then discuss the impacts that the appeal proposals would have on the setting and significance of heritage assets most affected by the appeal proposal. I stress that this is not an exhaustive list of the heritage impacts, rather it is a summary of those that I consider to be most important.

Heritage significance and impact of the appeal building

Royal Botanical Gardens, Kew WHS, CA and RPG - significance

5.11 The Royal Botanical Gardens at Kew were designated a grade I Registered Park and Garden in October 1987, and in January 1991 the London Borough of Richmond upon Thames designated the gardens as a conservation area, incorporating a long stretch of the south bank of the River Thames, outside the grounds of the gardens. The London Borough of Richmond of Thames has published a conservation area statement (CDF05). The Royal Botanical Gardens was inscribed by UNESCO as a World Heritage Site (WHS) in July 2003 (CDF.16).

5.12 A buffer zone has been established for the WHS. This includes the entirety of the width of the River Thames west of Kew Bridge, as far as and including Syon Park and Old Deer Park. The buffer zone also includes all of Kew Bridge, and a short section of the River Thames east of the bridge, including part of the south bank of the river, and the westernmost part of Strand on the Green.

5.13 A Management Plan for the WHS was adopted in March 2014 (CDF.10). The Management Plan highlighted the WHS buffer zone and important sightlines and views within, to and from Kew Gardens. The plan discusses the

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importance of vistas and visual envelopes extending outside the WHS buffer zone to the Outstanding Universal Value of the WHS.

5.14 The Royal Botanical Garden at Kew was established in the early 18th century and increased in size under Sir William Hooker in the mid-19th century. The gardens contain extensive botanic collections (including living plants and trees) that have been enriched over three centuries. Set amongst a series of parks and estates along the River Thames south-western reaches, the historic landscape garden includes work by renowned landscape architects Bridgeman, Kent, Chambers, Capability Brown and Nesfield, illustrating significant periods of English Garden design from the 18th to the 20th centuries.

5.15 Set within the designed landscape are 44 listed buildings, many of which are by notable architects and highly graded. Notable amongst these buildings are Kew Palace (Dutch House), The Orangery and the Pagoda all of which are listed grade I. Kew Palace is also a Scheduled Monument. Later buildings illustrate the development of a scientific collection of plants in the 19th century, and include the grade I listed Palm House, which is one of the most important iron and glass structures in the world. Other listed buildings within the WHS include the grade II listed Temple of Aeolus, an open-sided, Classical domed rotunda, set on a raised viewing mound. The eight-columned Temple was designed in the 19th century and carefully replicates an earlier structure by Sir William Chambers.

5.16 The listed buildings within the gardens draw significance from their designed landscape setting. For example, the exceptional Classical Orangery designed by Sir William Chambers draws major significance from its setting within a designed landscape, including views across the lawns to the south. Similarly, Kew Palace, which is a fine example of a 17th century house, has an intrinsic historical and visual relationship with the surrounding designed landscape, both in terms of external views, and views from within the house, Views from windows are identified in the WHS Management Plan as providing a visual connection between the Palace, the Thames and the gardens. The open-sided Temple of Aeolus, on its raised viewing mound, was specifically designed to enable views across the designed landscape.

5.17 The basis for the future protection and management of the Royal Botanical Gardens WHS is set out in the Statement of Outstanding Universal Value (OUV), approved by the World Heritage Committee in 2010 (CDF.17). The OUV of the World Heritage Site of Kew Gardens comprises:

• a rich and diverse historic cultural landscape providing a palimpsest of landscape design’; • iconic architectural legacy;

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• globally important preserved and living plant collections • a horticultural heritage of keynote species and collection; • key contributions to development in plant science and plant taxonomy’

5.18 Having regard to the first of the two attributes of the OUV, a particularly important aspect of the heritage significance of the Royal Botanical Gardens at Kew is the many highly-graded listed buildings set within an outstanding designed landscape. Similarly, much of the significance of the grade I Registered Park and Garden at Kew derives from the high-quality landscape design, with its primary and secondary views, containing overlapping formal and informal elements. Whilst certain formal viewpoints within the designed landscape at Kew are clearly of particular value, the experience of this unique heritage asset is a kinetic one, which cannot be distilled to singular viewpoints.

5.19 With the exception of the tower blocks of the Haverfield Estate, which can be seen on the skyline in certain views to the west and diminish the visual experience at Kew, the wider setting of Kew Gardens remains largely unharmed by intrusive development within its setting. It should be noted that the tower blocks of the Haverfield Estate were developed in the 1970s, prior to the inclusion of Royal Botanic Gardens at Kew on the Register of Historic Parks and Gardens, the designation of the conservation area and the inscription of the World Heritage Site. The outstanding designed landscape at Kew, with its layers of heritage designations, incorporating important vistas, and settings of highly-graded listed buildings, means that this unique heritage asset is particularly sensitive to change resulting from inappropriate development within its setting.

Royal Botanical Gardens, Kew – impact of appeal proposal

5.20 The appeal proposal would be located approximately 0.85km to the north-east of the closest part of the designated area, beyond the World Heritage Site (WHS) buffer zone which embraces the adjacent River Thames, Kew Bridge and the adjoining open part of Kew Green.

5.21 I note that the Appellant’s original THVIA document, states, at paragraph 8A.109, that the appeal proposal would be ‘largely obscured from viewpoints within the gardens themselves, owing to dense foliage in both summer and winter’. It accepts that the appeal proposals ‘will be visible from positions to the south of the Orangery’. It also accepts at 8B.59, that the proposed development will be a ‘prominent element’ from the upper levels of the Pagoda. The THVIA concludes, in respect of the Royal Botanical Gardens Conservation Area, that whilst the sensitivity of the asset is ‘high,’ the magnitude of change on it would be ‘low in a very limited part of the conservation area, leading to exceptionally minor impact of a beneficial nature owing to the quality of the architecture, its

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sculptural form, textured façade and colouration’. Similarly, in respect of the Royal Botanical Gardens World Heritage Site, the THVIA claims at paragraph 8C.36, that there would only be ‘incidental views of the Orangery’, and that due to the quality of the design of the appeal proposal this would ‘do no harm’. The THVIA also asserts that views from or to other heritage assets within the WHS are not affected by the proposals.

5.22 Contrary to the Appellant’s claims, I consider that the appeal proposal would be visible and would form a harmful and intrusive feature from a number of positions within the WHS and in some cases would be visible in juxtaposition with listed buildings located within the designated area. The main viewpoints where the proposed tower would intrude into the scene are:

• From the open grassed area to the south-west of the grade I listed Orangery • From the frontage area of the grade I listed Kew Palace • From the Temple of Aeolus Mound • From the Plant Family Beds area • From the Rock Garden area • The view over The Grass Garden • From the western end of Kew Green

5.23 The appeal proposal would appear as an arbitrary vertical element on the skyline. The open grassed area the south-west of the Orangery, where three paths come together, affords fine views of The Orangery in its designed, verdant parkland setting. The proposed tower would appear as a highly intrusive, incongruous and alien feature directly behind The Orangery or slightly to the right, dependent on the precise viewpoint. The visualisations prepared on behalf of LB of Hounslow and RBGK are helpful in illustrating this point (see Viewpoints 14 and 15). It would be impossible to appreciate the listed building in its parkland setting from this aspect without the intrusion of the tower above the tree line.

5.24 There are no other alien or intrusive features directly behind the Orangery in views of it from this direction. The Appellant’s ES visualisations fail to reflect the true impact of the proposal. ES Views 36 and 37 suggest that the proposed tower would be screened by trees, which would not be the case from many positions to the south-west of The Orangery. ES View 16 appears to be based on a photograph taken with a less representative tilt/shift lens. This photograph includes the Haverfield Estate towers, which are located to the west. Whilst the towers are intrusive in the wider scene, they do not appear in the backdrop or immediate surrounds of The Orangery when it is viewed from the south-west and are screened from view from more distant positions to the south-west of The Orangery, in the vicinity of the triangular conjunction of paths (see Viewpoint 15). I acknowledge that the skyline to the west of the Orangery has

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been partly compromised by the presence of the Haverfield Estate towers, a development that pre-dates both the inscription of Kew as a WHS and the current planning requirements relating to consideration of impacts on the settings of heritage assets. The intrusive presence of the Haverfield Estate towers was recognised by UNESCO, when the Royal Botanic Gardens were considered for inscription. In views where both the appeal proposal and the Haverfield Estate towers would be visible, the proposed development would add considerably to the existing degree of harm caused to the highly sensitive and vulnerable setting of this part of the WHS.

5.25 The appeal proposal would also be seen in conjunction with the highly sensitive Kew Palace, which is designated as a Scheduled Ancient Monument and grade I listed building, as well as being a very important feature of the Kew WHS. The proposal would be visible in juxtaposition with Kew Palace in oblique views from the frontage area of the Palace, which are views not currently affected by other tall buildings, and from upper floor windows in the north-eastern end of the building in winter. The Appellant’s claim that the proposed tower would be screened relies on foliage screening (compare LB of Hounslow and RBGK’s Viewpoint 12 with ES view 32). The proposed tower would form a highly intrusive, incongruous and alien feature in the wider setting of the Palace and in views out over the designed landscape of the Kew WHS. See Viewpoint 13, which is a view from an upper floor window at Kew Palace.

5.26 The grade I listed Temple of Aeolus was erected on a mound and was clearly intended to provide panoramic views over the gardens. The appeal building would intrude into the outward view to the north-east from the Temple of Aeolus over the Plant Family Beds in the middle distance and the Kew Green area beyond. The impact would be greater than suggested in the Appellant’s ES, as illustrated by a comparison of LB of Hounslow and RBGK’s Viewpoint 18 with the Appellant’s ES view 35. The appeal proposal would form a highly intrusive, incongruous and alien feature in the wider setting of the landscape of the Kew WHS. It would have similar impact when viewed from lower level in the Plant Family Beds area (see LB of Hounslow and RBGK’s Viewpoint 19).

5.27 The appeal proposal would intrude into numerous views from the north-eastern part of the Royal Botanic Gardens, including views to the north-east from the Rock Garden, from the Davies Alpine House and the area to its north, and from the Grass Garden (see LB of Hounslow and RBGK’s Viewpoints 20 and 21). The proposed tower would constitute an overpowering skyline feature that would dominate the delicate tower of St Anne’s Church on Kew Green, which can be glimpsed in certain of these views.

5.28 The appeal proposal would intrude into views from the western part of Kew Green, which constitutes part of the inscribed WHS. The nature of the intrusion

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is illustrated in the Appellant’s ES view 21, which is taken from a position adjacent to the WHS boundary. The proposed tower would form a highly intrusive, incongruous and alien feature in the outward views from this part of the WHS over its setting.

5.29 On the basis of the above assessment, I consider that the appeal proposal would cause a high level of harm to the World Heritage Site, Registered Park and Garden and Conservation Area at the Royal Botanical Gardens, Kew. In respect of the former it would harm the Outstanding Universal Value identified by UNESCO. I consider the level of harm to be less than substantial in the terms of the NPPF, but at the higher level of the scale of less than substantial harm.

Gunnersbury Park Conservation Area and RPG - significance

5.30 As I have already mentioned, Gunnersbury Park Conservation Area is the closest of the conservation areas to the appeal site. The conservation area was designated in November 1990. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.04).

5.31 Gunnersbury Park Conservation Area encompasses a large area, incorporating three distinct elements; the grade II* Registered Park and Garden of Gunnersbury Park, which has its origins in the 17th century, Gunnersbury Park/Kensington Cemetery, which was established in 1929, and an area of inter-war suburban housing to the east of Gunnersbury Avenue, centred on Princess Avenue and Park Drive and known as the Gunnersbury Park Garden Estate. The latter area, sometimes referred to as Gunnersbury Triangle Estate, was developed between 1926 and 1931 and mainly comprises long terraces with half-timbering. Gunnersbury Park/Kensington Cemetery is the closest part of the conservation area to the appeal site. Together, Gunnersbury Park and Gunnersbury/Kensington Cemetery are designated as Metropolitan Open Land.

5.32 Gunnersbury Park has its origins in 1658-63, when a large mansion was built for the lawyer and politician Sir John Maynard on a site that lay between the two present mansions. From 1762-86 it was the summer residence of Princess Amelia, daughter of King George II, who improved the grounds and built many of the garden buildings. The original house was demolished in 1800 after the majority of the estate was purchased by Alexander Copland, a wealthy building contractor, who built himself a new house in 1802. The house and estate were subsequently bought by Nathan Mayer Rothschild in 1835, and subsequently remodelled and enlarged into the present house by Sydney Smirke. A smaller mansion was erected to the east of the main house in 1805 occupied from

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1807-28 By Major Alexander Morrison, as retired east India company Officer. The house was acquired by the Rothchilds in 1889 who used it for their guests.

5.33 After 1917 the estate was split up; the houses and 186 acres of land were acquired by the local authorities of the time, and the grounds made a public park in 1926. The larger of the two early 19th century mansion houses, Gunnersbury Park House (otherwise known as the ‘Large Mansion’) is now a museum, and the ‘Small Mansion’ used for events (although both are currently closed for repairs). The mansion houses and other related structures have been the subject of a substantial programme of lottery-funded repairs and renovations, due to be completed imminently.

5.34 Within Gunnersbury Park there are 21 individually listed buildings. These include, most notably, the two mansions referred to above, which are set on an elevated terrace at the northern end of the registered parkland. The Large Mansion is listed grade II*, whereas the Small Mansion is listed grade II. Other associated parkland buildings and structures include the Conservatory (or Orangery) the East Stables and the Temple, all of which are listed grade II*. The listed buildings within the park draw significance from their designed landscape setting. A key feature of the Registered Park and Garden is the aesthetic value of the ornamental and picturesque buildings set within a designed landscape.

5.35 The Registered Park and Garden at Gunnersbury Park has been the subject of a Conservation Management Plan (CMP), prepared in 2014 on behalf of Gunnersbury Park and Museum. Amongst other things the CMP highlights the high level of heritage significance of the designed historic landscape at Gunnersbury Park. The landscape has evolved over time and has multiple layers of history. Its greatest contributors are recognised as William Kent and Sir William Chambers, both undertaking works in the 18th century. The CMP identifies key views of fundamental importance to the design concept of landscape, foremost amongst which are those from the elevated terrace adjacent to the mansions at the northern end of the parkland, from where commanding views southwards across the designed landscape can be enjoyed. Another key viewpoint is identified in the CMP is that looking south across the Round Pond across the designed landscape. I note that these viewpoints are also highlighted in the plans that are included within the LB of Hounslow’s draft appraisal for Gunnersbury Park Conservation Area.

5.36 The skyline setting of the parkland, with its mature trees contributes greatly to the significance of Gunnersbury Park itself and the conservation area that encompasses it. Some views in the park have been adversely affected by existing taller buildings, but to the south and south-east, trees screen much of the existing and consented development. This aspect of the parkland and

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conservation area setting and significance is particularly vulnerable to the threat of inappropriately scaled development to the south. In addition to the parkland views, there are important views towards the appeal site from within the Gunnersbury/Kensington Cemetery, and from within the Gunnersbury Park Garden Estate.

5.37 Gunnersbury Park/Kensington Cemetery lies to the south of Gunnersbury Park and forms the southernmost portion of the Gunnersbury Park Conservation Area.

Gunnersbury Park – impact of appeal proposal

5.38 The appeal proposal would intrude harmfully into a large number of views in a southerly direction from both the RPG and the wider conservation area, which includes the Gunnersbury/Kensington Cemetery and residential development around the margins of Gunnersbury Park.

5.39 The appeal proposal would be much taller than other existing or consented buildings apparent from within the park) approximately double the height of the tallest). It would be located approximately 825 metres to the south-south-east of the Large Mansion and would intrude into key views from the vicinity of the grade II* listed building, which was designed to enjoy a southerly aspect over its designed landscape, as illustrated in LB of Hounslow and RBGK’s Viewpoint 1. Viewpoint 3 is a view from an upper floor window of the Large Mansion, which is publicly accessible as a museum. Trees within the designed landscape would screen the proposed tower in some views from the grounds in the vicinity of the mansion, as illustrated in the Appellant’s ES view but there would be numerous other positions from which the proposal would be clearly visible. The southerly views from the mansion, the parkland in its immediate vicinity, and the nearby round pond are highly sensitive to intrusion and would be seriously impacted upon by the proposed tower, which would form a highly intrusive, incongruous and alien feature in the setting of this composite heritage asset (see in LB of Hounslow and RBGK’s Viewpoint 2).

5.40 The appeal proposal would be highly visible in the principal view from the grade II* listed Temple in Gunnersbury Park, and would diminish the contribution made to the Temple by its setting.

5.41 The intrusive impact of the proposed tower would be particularly powerful within the Gunnersbury/Kensington Cemetery, where there is a tranquil ambiance. At its closest point, the proposed tower would be less than 155 metres from the cemetery. The visual intrusion of the enormous tower is illustrated in the Appellant’s ES view 4 (see below). The proposed tower would appear as a highly intrusive, incongruous and alien feature. The tower would

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be omnipresent and would have a particularly disturbing impact on those seeking contemplation and solace in the tranquil environment of the cemetery. The effect of overlooking from so many residences into the cemetery would erode the sense of private contemplation by visitors at any time. The proposed tower would have a particularly unfortunate relationship with the Katyn Memorial, which, although not subject to any form of heritage designation, is the most impressive architectural monument in the cemetery. The relationship of the appeal proposal with the Katyn Memorial is illustrated in in LB of Hounslow and RBGK’s Viewpoint 4.

Appellant’s View 4 (summer) as updated (extract from THVIA Addendum)

5.42 The proposed tower would also result in a harmful intrusion into southerly views from the Gunnersbury Park Garden Estate, in particular in views from Princes Avenue from where the tower would appear as a highly intrusive, incongruous and alien feature that would alter the highly consistent and little spoiled character and appearance of this part of the conservation area. The Appellant’s ES view 5 is taken from the northern end of Princes Avenue. Whilst the tower would be visible in this view, it is shown partly screened by the avenue of trees that line Princes Avenue. The proposal would be much more visible and intrusive in positions towards the southern end of the street, in the vicinity of the junction with Park Drive, as illustrated in in LB of Hounslow and RBGK’s Viewpoint 5.

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5.43 I acknowledge that in some views from Gunnersbury Park and the Gunnersbury/Kensington Cemetery, the Haverfield Estate towers, and other buildings such as Vantage West and the BSI building on the Chiswick High Road intrude into the setting of the composite heritage asset. These are considerably lower features than the proposed tower. Within Gunnersbury Park, these features are most prominent from the less sensitive west side of the park which is made up of playing fields. The Vantage West and the BSI building are visible in some of the more sensitive southerly views. Nevertheless, the proposal would intrude into many views which are currently largely unspoiled. In any event, poorly considered development from the past should not provide a justification for a further inappropriate intrusion.

5.44 For the reasons outlined above, I am of the view that the level of harm caused to the significance of the Gunnersbury Park Conservation Area and RPG would be very serious. In the terms of the NPPF I would place the level of harm at the highest level of less than substantial harm.

Kew Green Conservation Area – significance

5.45 The Kew Green Conservation lies immediately to the south of the Strand on the Green Conservation, on the south side of the River Thames, within the London Borough of Richmond upon Thames. A conservation area at Kew Green was first designated in January 1969, with extensions in 1982 and 1988. The conservation area includes the linear approach to the green from the south along Kew Road and the areas of Victorian and Edwardian suburban housing on the east side.

5.46 The London Borough of Richmond upon Thames has published a short character statement for Kew Green Conservation Area (CDF.02), highlighting its historical development, character, and problems and pressures. The character statement explains that the conservation area was designated ‘due to its character as an historic open space, the associated high quality of mostly C18th development and its superior riverside environment’

5.47 Kew flourished when Frederick, Prince of Wales established his country residence, the White House, there in 1728. This was followed by the development of the Royal Botanic Gardens. Kew Bridge was completed in 1758 and the advent of the railway in 1860 led to the development of the Priory estate as an area of commuter housing.

5.48 The conservation character statement highlights that ‘The Green constitutes a fine example of an historic green with an entrance to Kew Gardens to the west and is surrounded by large 18th and 19th century houses, many of which are listed and which through the quality of their architecture add formal grace to

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the central area’. The houses that surround the green have a restrained elegance and are of consistent modest domestic scale. The early 18th century grade II* listed church of St Anne sits within the green itself. Kew Green still retains much of its historic character, and the limited amount of modern development within the area is of sympathetic scale. The character statement observes that Kew Green forms ‘a visually cohesive area with an easy identifiable sense of place it has a definite village character.’ This character is enhanced by the abundance of mature trees, which contribute to the verdant quality of the area.

5.49 Kew Green itself` is roughly triangular in form and bisected by the Kew Road (South Circular). The entrance to the Royal Botanical Gardens, with its gates and entrance lodges, lies on its west side of the green. The westernmost part of the green is included within the boundary of the World Heritage Site. Much of the conservation area falls within the buffer zone of the World Heritage Site. At the eastern side of the green the pond forms a focal point. The two and a half storey housing in this area forms a backdrop to the pond.

5.50 The cohesive townscape and high architectural quality of the historic buildings that surround Kew Green, particularly on its northern edge, is one of the defining characteristics contributing to the significance of the conservation area. It is at the very heart of the special character and appearance of the area. In this connection I note that the Appellant’s original THVIA document states at paragraph 8A.96 that ‘The significance of the Kew Green Conservation Area derives from its character and appearance as a historic open space with a village character, surrounded by 18th century development with an exterior edge of the riverside.’

5.51 The characteristic skyline of the historic buildings that define the northern edge of Kew Green, is an important component contributing to the character of the conservation area, which is particularly vulnerable to damage arising from inappropriate development of greater height and visual prominence within its wider the setting. Whilst there has been some modern development affecting the skyline setting of the Kew Green Conservation Area, most notably the Haverfield Estate tower blocks to the north-west, the views to the north and north-east of the green currently remain largely uncompromised by such development.

5.52 In addition to the green itself, a key element of the Kew Green Conservation Area is the riverside, which has a tranquil, semi-rural quality. It has an informal character, which contrasts with the more formal character of the green. To the east of Kew Bridge, the riverside is backed by small-scale 18th and 19th century houses, gardens and allotments, with access to the riverside via a series of narrow footpaths. To the west of the bridge the riverside becomes increasingly

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secluded, being backed towards the west edge of the conservation area by Kew Gardens. The riverside setting of the conservation area, particularly in views looking north towards Strand on the Green, contributes greatly to its significance. I note that the Appellant’s original THVIA document highlights at paragraph 8A.96 that ‘The river itself contributes an important element of the setting of the conservation area’. As with the green itself, the riverside is vulnerable to inappropriate development within wider the setting of the conservation area, particularly in views looking north towards Strand on the Green.

5.53 The character statement prepared by the London Borough of Richmond upon Thames states that Kew Green Conservation Area was designated due to its character as an historic open space, the associated high quality of mostly 18th century development, and its superior riverside environment. The character statement highlights the problems and pressures that may result from development that would harm the balance of the river and landscape- dominated setting of the conservation area, and the obstruction of or spoiling of views, skylines and landmarks.

Kew Green Conservation Area – impact of appeal proposal

5.54 The appeal proposal would have a particularly adverse visual impact on views in the northern direction from a multitude of viewpoints within the large open grassed areas of the Kew Green Conservation Area, to either side of the South Circular Road. The proposed tower would loom above the highly consistent scale of the low-rise buildings that define and enclose the northern side of the open areas. The tower would appear as a highly intrusive, incongruous and alien feature that would be visible in almost all northward views from the open grassed areas, except in close proximity to the buildings on the Green’s northern edge.

5.55 An indication of the likely impact of the appeal proposal on Kew Green is illustrated in the Appellant’s ES view 21 (from the western open area), ES view 34 (from the eastern open area), and ES view 40 (from a position near the grade II* listed St Anne’s Church, within the western open area). The nature of the impact on the open area within Kew Green is better illustrated in LB of Hounslow and RBGK’s Viewpoints 10 and 11. The proposed tower would have a similar impact in views from the adjacent area to the immediate east, around the Kew Green Pond, which is modelled in the Appellant’s ES view 42. In all these views, the proposed tower would appear as a highly intrusive, incongruous and alien feature at odds with the modest domestic scale of the conservation area. Its assertive appearance would be in direct conflict with the restrained elegance of the properties that surround the green.

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Appellant’s View 21 as updated (extract from THVIA Addendum)

Appellant’s View 40 as updated (extract from THVIA Addendum)

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5.56 The appeal proposal would add to the damage caused to the sensitive skyline of Kew Green by the Haverfield Estate tower blocks to the north-west, by imposing a highly intrusive, incongruous feature in currently unharmed views from the green looking north and north-east.

5.57 As noted above, the Appellant’s THVIA document acknowledges that the significance of the Kew Green Conservation Area is derived from its character and appearance as an historic open space with a ‘village character surrounded by 18th century development’. However, whilst at paragraph 8A.97 the THVIA considers the sensitivity of the conservation area to be ‘high’ and the magnitude of change ‘medium’, giving rise to a major effect, it concludes that this would be beneficial owing to the high quality of the architecture of the appeal proposal. I find it difficult to comprehend how such a major impact can be construed to be beneficial in the light of the London Plan policy 7.8, which requires that development affecting heritage assets and their settings should conserve their significance, ‘by being sympathetic to their form, scale, materials and architectural detail’. It is not at all clear to how the large, bulky and incongruous form and scale of the appeal proposal is sympathetic to the small- scale village character that is at the heart of the significance of Kew Green.

5.58 I acknowledge that the proposed tower would have little impact on the residential streets within the Kew Green Conservation Area. However, I consider the open grassed areas, where the proposal would intrude incongruously in almost all northerly views, to be a key element of the conservation area.

5.59 As noted above, the westernmost part of the Kew Green open grassed area is within the Kew WHS. It should be noted that the remainder of the open area is within the WHS buffer zone. Therefore, for the reasons I have outlined, the impacts on this area constitute an adverse impact on the Outstanding Universal Value of the WHS as well as on the character and appearance of the Kew Green Conservation Area and the settings of the listed buildings that line its northern edge.

5.60 I consider that the appeal proposal would cause very serious harm to the highly sensitive riverside environment of Kew Green Conservation Area. It should also be noted that the views from the south bank of the River Thames of the Strand-on-the- Green Conservation Area that would be adversely impacted by the appeal proposal are from positions within the Kew Green Conservation Area. Consequently, the adverse impact would relate to both heritage assets.

5.61 For the reasons outlined above, I am of the view that the damage caused by the appeal proposal would be so serious that it would result in substantial harm

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to the significance of the Kew Green Conservation Area in the terms of the NPPF.

Strand on the Green Conservation Area – significance

5.62 As I have mentioned above, Strand on the Green Conservation Area lies a short distance to the south of the appeal site. The conservation area is of long standing, having been designated in November 1968. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.01).

5.63 Historically, Strand on the Green developed from the 18th century as a small settlement of fisherman’s cottages, aligned to the banks of the River Thames. Gradually the fisherman’s cottages, many of which still remain, were augmented by boat-builders sheds and maltings, public houses and later private houses. Originally, there was no riverside walkway as today, access being via the shingle shore of the river itself. However, progressive silting by the late 19th century led to the building of an embankment wall, giving access to the houses. By the close of the 19th century Strand on the Green had assumed much of the appearance it still has today.

5.64 Strand on the Green Conservation Area lies on the banks of the River Thames and is framed between the two river crossings of Kew Bridge and Kew Railway Bridge (both grade II listed). The conservation area is of linear form, reflecting the form of the historical settlement, with its surviving fisherman’s cottages, boat builders’ sheds, public houses, maltings and larger more elegant houses added in the late 18th century. The river frontage is lined with a continuous row of historic buildings, many of which are statutorily listed, including the early 18th century grade II* Zofany House, which lies towards the centre of the group. The conservation area also includes modest but attractively detailed Victorian and Edwardian houses that were developed after the initial settlement, making use of the former access road running behind the frontage buildings, parallel with the river, and linked to the riverside walkway by a series of narrow passages.

5.65 The significance of the Strand on the Green Conservation Area lies in its tranquil riverside location and its remarkably intact ensemble of historic buildings, of varying individual design, but consistent modest scale, giving rise to a traditional historic townscape of exceptionally high quality. The exceptional quality of the group of riverside buildings at Strand on the Green is recognised in the Thames Strategy, which at page 4.10 describes it as ‘one of the most important historical and architectural waterfronts between Kew and Chelsea’. The Strategy comments that the sensitivity of Strand on the Green has

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generally been respected, but that the skyline has been broken by the BSI tower at Gunnersbury.

5.66 The exceptional townscape of Strand on the Green Conservation Area is especially appreciated in views looking northwards towards the historic riverside settlement, across the Thames from the Surrey (south) side. The townscape is also appreciated in views from the grade II listed Kew Bridge, in views of rail passengers crossing the Thames on the grade II listed Kew Railway Bridge and by users of the river itself. In these views the setting of the conservation area, with its largely unbroken skyline, is especially important, and contributes greatly its significance. I note that these key views are identified on the map included within the draft conservation area appraisals prepared by LB of Hounslow. This aspect of the conservation area’s setting and significance is particularly vulnerable to the threat of inappropriately scaled development to the north. The current conservation area statement for Strand on the Green and the points up the vulnerability of inappropriate changes to the skyline in views from the Surrey side of the River. Similarly, the Thames Landscape Strategy highlights ‘The importance of considering the impact of development away from the river on the A4/M4 corridor and Gunnersbury, which has had a negative impact on the skyline and backdrop to the architectural waterfront.’

Strand on the Green Conservation Area – impact of appeal proposal

5.67 As evidenced by the appellant’s own visualisations (see Views 12, 12A and 13 of the THVIA), in views from the south side of the River Thames, the appeal proposal would appear as a large, bulky and incongruous addition to an otherwise largely unbroken skyline of traditional buildings. The assertiveness of the appeal building would be in stark contrast to the understated small-scale traditional architecture of the waterfront. This adverse impact is further corroborated by the additional visualisation commissioned by LB of Hounslow and RBGK (see Viewpoint 9).

5.68 The appeal proposal would be an incongruous addition to the skyline that would cause serious damage to a key element contributing to the significance of the Strand on the Green Conservation Area, as well as harming the setting of the listed buildings (including the grade II* Zofany House) that form a cohesive and modestly-scaled frontage to the riverside, both individually and collectively. The tower would become a new and unwelcome focus to a cherished skyline. Whilst I acknowledge that views from this area towards the north-west are, to some extent, affected by taller buildings of Brentford and around Kew Bridge, the appeal development would stand out as a massive and discordant feature that is far larger than any other existing or consented building in the area.

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Appellant’s View 12 as updated (extract from THVIA Addendum)

Appellant’s View 12A as updated (extract from THVIA Addendum)

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5.69 The appeal proposal would also appear large and incongruous in high-level public views experienced by rail travellers crossing the Thames on the grade II listed Kew Railway Bridge at the eastern side of the conservation area. Plate 1 is a view of Strand on the Green looking north-west from Kew Railway Bridge in which the lower construction crane on the site adjoining the appeal site is clearly visible. The appeal building would also appear as a large and incongruous intrusion to boaters using of the river itself. Additionally, the appeal proposal would be visible as a large and incongruous intrusion from positions within some of the streets of Strand on the Green Conservation Area and would sit unhappily with the small domestic scale of the traditional townscape. Plate 2 is a view looking north towards the appeal site along Hearne Road the Strand on the Green Conservation Area. Plate 3 is a similar view looking north along Spring Grove. Note that the construction crane on the site adjoining the appeal site is clearly visible.

5.70 The intrusion into the key views of the historic riverside settlement, which is composed of predominantly low-rise buildings, would result in an extremely high level of harm to the setting and significance of the conservation area.

5.71 For the reasons outlined above, I am of the view that the damage caused by the appeal proposal would be so serious that it would result in substantial harm to the significance of the Strand on the Green Conservation Area.

Wellesley Road Conservation Area - significance

5.72 The Wellesley Road Conservation Area was designated in December 2002. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.08).

5.73 The conservation area is based on the mainly mid-19th century suburban residential developments along Wellesley Road and Chiswick High Road. The primary significance of the conservation area derives from its historical value as one of the earliest residential estates in Chiswick, and from the surviving cohesive suburban townscape and the well-preserved architectural detailing of its Victorian properties.

5.74 The residential development of the area took place from the mid-19th century and was on a planned layout, albeit based on ancient road patterns of the area, which are still visible, now transformed into modern thoroughfares. A significant part of the Victorian housing was built by a local landowner and speculative developer, Adam Askew, who also owned estates in Hammersmith and Shepherds Bush. The Ordnance Survey map of 1865 shows Oxford and Cambridge Roads marked out, and it is understood that most of the land north of Wellesley Road had been developed by 1871. The development of the area

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coincided with the opening of Gunnersbury Railway Station by the London and South Western Railway (LS&SWR) in 1869. Continued residential development of the area was spurred by the arrival of the railway, with housing in adjoining streets undertaken by other speculators. By the 1880s Askew had developed further land east of the railway line. Known as ‘Gunnersbury’ the new residential area drew prestige from its proximity to Gunnersbury Park.

5.75 The speculative housing in the new suburb ranged in size, catering for all scales of the Victorian middle class, with some grand houses but also smaller properties. The housing was of consistent style and quality and ranged from two to three storeys in height and were constructed in yellow stock bricks with stucco detailing under slate roofs. The houses are generally either of Italianate Neo-Classical or Gothic Revival style. A great many of the Victorian houses in what is now the Wellesley Road Conservation Area retain their original detailing. The cohesive townscape of Wellesley Road Conservation Area is appreciated in axial views along its tree-lined streets. I note that these key views are shown on the maps included within the draft appraisal for Wellesley Road Conservation Area prepared by LB of Hounslow.

5.76 Overall, despite a number of modern infill developments within the Wellesley Road Conservation Area, it retains much of its original domestic scale, style and character. It has a calm, intimate and self-contained character. Many of the streets are tree-lined. The area is intensely urban in character, with open space generally limited to rear gardens. Although large-scale developments are present in the surrounding area, these do not, for the most part, affect the setting of the conservation area, except on the edges, for example on Chiswick High Road. The intimate, domestic scale and character of the conservation area is however, vulnerable to inappropriately scaled development within its setting, which could affect the skyline.

Wellesley Road Conservation Area – impact of appeal proposal

5.77 The appeal proposal would be highly visible as a large and dominant intrusion into the setting of the conservation area, appearing as an incongruous element that is out of scale with the predominantly domestic scale of this high-quality, well-preserved suburban area.

5.78 The scale of the appeal proposal in relation to the historic townscape of the Wellesley Road is clearly apparent in the Appellant’s ES views 6,7 and 8. The incongruity of the proposals is particularly evident in ES view 7 (see below), in which the appeal proposal towers above and jars with the modestly-scaled domestic properties in Clarence Road.

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Appellant’s View 7 as updated (extract from THVIA Addendum)

5.79 I consider that there would also be other positions within the conservation area where the appeal proposal would appear as a large and intrusive feature. For example, it would appear as a highly dominant feature in the view looking north-north-west from Wellesley Road, close to its junction with Clarence Road (see Plate 4) and in a view in a similar orientation at the junction of Brooks Road, Oxford Road South and Stile Hall Road (see Plate 5). Note that the construction crane on the site adjoining the appeal site is clearly visible above the rooflines in these views.

5.80 The appellant’s THVIA assessment states that on balance ‘the introduction of a new element of high architectural quality is considered to be beneficial to the setting of the conservation area and views out of it’. The THVIA concludes that the effect would be ‘Moderate Beneficial’.

5.81 Given the incongruity of the appeal proposal, and its dominating presence, I cannot agree with the conclusion in the THVIA that its effect on the setting of the Wellesley Road Conservation Area would be beneficial. In my view the appeal proposals would be at odds with the low-rise suburban character of the conservation area and far from enhancing its setting, would cause serious harm.

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5.82 For the reasons outlined above, I am of the view that the level of harm caused to the significance of the Wellesley Road Conservation Area would be serious, but in the terms of the NPPF less than substantial.

Thorney Hedge Conservation Area - significance

5.83 The Thorney Hedge Conservation Area was designated in December 2002. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.07).

5.84 The conservation area comprises two linked elements; an area of mid-19th century suburban residential development in the form of a horseshow formed by Thorney Hedge Road and Silver Crescent, and a short length of mixed 19th century residential and commercial development along either side of Chiswick High Road near Gunnersbury Station. The heritage significance of the conservation derives from the relatively intact nature of this small-scale Victorian suburban estate.

5.85 The Victorian houses on Thorney Hedge Road and Silver Crescent form an unexpected enclave of attractive suburban residential properties off an otherwise extremely busy predominantly commercial street. The houses were developed as a speculative development in the 1870s by William J Tomlinson, a local Chiswick builder. Unlike the properties in the adjacent Wellesley Road Conservation Area, the houses in Thorney Hedge Road and Silver Crescent are of a more consistent scale.

5.86 The houses in Thorney Hedge conservation area are of consistent style and quality and range from two to three storeys in height. The majority are two storeys and have an attic with dormers. They are constructed in red bricks with stone or stucco detailing under slate roofs. The great majority of the Victorian houses in the conservation area retain their original detailing.

5.87 The buildings on the Chiswick High Road comprise, on the south side, terraces and shops as well as a distinguished group of detached and paired villas at Nos. 409-425. These buildings are mostly of brick with stucco dressings and are of three storeys. On the north side of Chiswick High Road, close to the junction with Silver Crescent, is the John Bull public house, designated by the LB of Hounslow as a building of Local Townscape Character.

5.88 The horseshoe of streets formed by Thorney hedge Road and Silver Crescent are lined with mature lime trees and have a tranquil and intimate character, in contrast to the busy, urban Chiswick High Road. The consistent townscape of this part of the conservation area is appreciated in axial views along its tree- lined streets. I note that these key views are shown on the map included within

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the draft appraisal for Thorney Hedge Conservation Area prepared by LB of Hounslow. This miniature estate is largely inward looking. However, there is a break in the skyline at the hairpin junction of Thorney Hedge Road and Silver Crescent, through which it is potentially possible to see taller development.

Thorney Hedge Conservation Area – impact of appeal proposal

5.89 As I have previously mentioned, the heritage significance of the Thorney Hedge Conservation Area derives from the relatively intact nature of this small- scale Victorian suburban estate. The compact and intimate nature of the estate means that there would be limited places where the appeal proposal would be visible in views from within, or in tandem with, the conservation area.

5.90 However, the proposed tower block would be clearly visible as a large and incongruous feature in views from the Chiswick High Road section of the conservation area, close to Gunnersbury Station. The scale of the appeal proposal in relation to the historic townscape in this location is clearly apparent in the Appellant’s ES view 6.

5.91 The Appellant asserts that the appeal proposal would only be visible from view 6. Fieldwork carried out as a basis for this proof of evidence, corroborated by photographic analysis undertaken on behalf of the LB of Hounslow, indicates that the appeal proposal would, in fact, be visible from within the residential streets. Specifically, LB of Hounslow and RBGK’s Viewpoint 6 shows that the appeal proposal would be visible above the rooflines of housing at the hairpin junction of Thorney Hedge Road and Silver Crescent where it would have an overbearing impact.

5.92 The THVIA states that ‘the quality achieved in the architectural design will mean that the background setting of the conservation area will be enhanced’ and on this basis concludes that the effect of the proposals would be Minor Beneficial.

5.93 Given the incongruity of the appeal proposal, I cannot agree with the conclusion in the THVIA that its effect on the setting of the Thorney Hedge Conservation Area would be beneficial. In my view the appeal proposal would be at odds with the low-rise suburban character of the conservation area and would cause harm to its setting.

5.94 For the reasons outlined above, I am of the view that the level of harm caused to the significance of the Thorney Hedge Conservation Area would be serious, but in the terms of the NPPF less than substantial.

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Kew Bridge Conservation Area - significance

5.95 The Kew Bridge Conservation Area was designated in June 2004. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.09).

5.96 The special interest of the Kew Bridge Conservation Area derives from the convergence of historical routes into London and the crossing of the River Thames at this point. The conservation area extends to the centre point of the Kew Bridge where it meets the Kew Green Conservation Area within the London Borough of Richmond. The bridge itself is listed grade II and an important landmark in this part of London. Dating from 1903 the engineer for the bridge was John Wolfe and the architect was Cuthbert Breveton. It was the third bridge to be constructed over the Thames at this point, replacing a previous 19th century bridge, which in turn replaced a mid-18th century bridge. Kew Bridge is one of the most elegant Thames Road Bridges and consists of three elliptical arches constructed in grey granite. The roadway rises to the centre of the bridge in a gentle curve, affording fine views over the Thames and beyond. The view of Strand on the Green from Kew Bridge is particularly admirable. I note that this, and other key views in the conservation area, is identified on the maps included within the draft appraisal for Kew Bridge Conservation Area prepared by LB of Hounslow.

5.97 The conservation area derives major significance from the architectural and historical value of the Victorian pumping station complex (now the Kew Bridge Steam Museum), with its tall, slender standpipe tower and the lower main pumping house, great engine house (all grade I listed) and associated buildings. The pumping station was built for the Grand Junction Waterworks Company in 1867. The standpipe tower is a tall tapering structure constructed of rendered brickwork, surmounted by an octagonal cupola. The pumping station complex, and the standpipe tower in particular, is a major local landmark which is prominent in both key local views in a number of long-range views in and around the conservation area, including views from Kew Gardens and Gunnersbury Park.

5.98 To some extent the wider setting of the Kew bridge Conservation Area has been compromised by large-scale modern development beyond its boundaries development. However, the conservation area remains vulnerable to further inappropriate development in its setting.

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Kew Bridge Conservation Area – impact of appeal proposal

5.99 As I have mentioned, the special interest of the Kew Bridge conservation area derives from the convergence of historical routes into London and the crossing of the River Thames at this point, together with the architectural and historical value of the Victorian pumping station complex (now the Kew Bridge Steam Museum).

5.100 The appeal proposal would appear as a large and incongruous element in views from the grade II listed Kew Bridge. It would also be very prominent in views from the junction of Kew Bridge and Kew Road as shown in Appellant’s ES view 10. The assessment in the THVIA asserts that the sensitivity of the view is ‘low with considerable opportunity for improvement’. Whilst I agree that there is scope for improvement, I do not agree with the assertion that the quality of this view is low. Indeed, the presence of both listed and non-designated heritage assets in this view mean that, despite the dominance of a wide urban highway, it retains some considerable townscape merit.

5.101 A further viewpoint is modelled in the Appellant’s ES view 11. The assessment in the THVIA considers that the presence of the grade I listed pumping station makes this a view of high sensitivity, but states that due to intervening trees there would be very little change as a result of the development. I consider the choice of view point to be poor, giving rise to an assessment that downplays the impact on the local townscape and the grade I listed pumping station that is misleading. I am of the view that, in approaches to the pumping station further along Kew Bridge Road to the west, and in views from the much-used ‘Heritage Walk’ pedestrian footway that runs parallel to Kew Bridge Road to the north, the impact of the appeal proposal on the listed building and conservation areas would be considerably more marked, and harmful to the setting of the listed pumping station complex and the conservation area. Plate 6 shows the view looking east towards the appeal site. View 7 prepared on behalf of LB of Hounslow and RBGK shows the effect of the appeal proposals from the footway.

5.102 I accept that in some views towards the appeal proposal the consented Brentford Football Club scheme would intervene or be seen in the same view. However, I consider that the appeal scheme is of such a scale that it would cause harm over and above the lower-scaled Brentford Football Club development.

5.103 The THVIA contends that the magnitude of change to the conservation area would be ‘low’ in relation to the conservation areas as a whole, and that ‘the high quality of architecture proffered by the development will enhance the setting of the conservation area giving rise to a Minor Beneficial effect overall’.

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5.104 I cannot agree with the conclusion in the THVIA that its effect on the setting of the Kew Bridge Conservation Area would be beneficial. The intrusion of the appeal proposal into views towards the pumping station with its elegant standpipe tower detract considerably from the its heritage significance. In my view the appeal proposals would cause harm both to the setting of the grade I listed pumping station and the conservation area overall.

5.105 For the reasons outlined above, I am of the view that the level of harm caused to the significance of the Kew Bridge Conservation Area would be serious, but in the terms of the NPPF less than substantial.

Grove Park Conservation Area - significance

5.106 The Grove Park Conservation Area was designated in January 2002. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.06).

5.107 Much of the significance of the Grove Park Conservation Area derives from its historical and architectural interest as the first large-scale Victorian housing estate in Chiswick, and the intact nature of many of its suburban houses and tree-lined streets. Also of significance is its distinctive riverside setting, with its boathouses and later housing.

5.108 Grove Park derives its name from a Tudor House that was close to the River Thames. The house and surrounding land was acquired by the Duke of Devonshire, the owner of Chiswick House, in 1861. Chiswick Station was built on land owned by the Duke in 1849. The Duke subsequently developed a speculative residential estate known as Grove Park on land south of the railway, the first large Victorian housing estate in Chiswick.

5.109 From the 1870s the estate began to be developed with large mansions set in spacious grounds. Some of the earliest houses were built along the riverside in Grove Park Road. Large houses continued to be built for the first twenty years of the estate, but subsequently, smaller houses began to be developed, some replacing earlier large houses. Later development at Grove Park included the Ibis and Polytechnic boathouses on the riverside in 1889. The University Boathouse (listed grade II) was built in 1936.

5.110 In 1958 the Thames Village development on the riverside was completed. A further riverside development, Chiswick Staithe was constructed in 1964-5 on the site of one of the large Victorian mansions. The Chiswick Quay development was completed in 1972.

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5.111 The Grove Park Conservation Area encompasses the entirety of the Victorian Grove Park residential estate. A significant part of the suburban estate still survives, its spacious and affluent properties set in spacious gardens. Although the largest of the original houses have been redeveloped, the smaller properties of the subsequent phases of development survive. Several of the streets were designed as tree-lined avenues, and these streets still retain their now mature trees.

5.112 Also incorporated within the conservation area is part of Chiswick Bridge as far as its midway point where the Hounslow Borough boundary meets that of Richmond upon Thames. The bridge was built in 1930-33 and was designed by Alfred Dryland with Herbert Baker as consulting architect. This grade II listed building has polygonal viewing platforms on each side, affording fine views over the conservation area and along the Thames.

5.113 Although the conservation area is, for the most part, intimate and self- contained, it enjoys an open setting on the riverside from which it draws significance. This aspect of the conservation area’s wider setting is largely free of visual intrusion from inappropriately scaled buildings beyond the conservation area and is vulnerable to inappropriately scaled development beyond the boundaries of the area.

Grove Park Conservation Area – impact of appeal proposal

5.114 Much of the significance of the Grove Park Conservation Area derives from its historical and architectural interest as the first large-scale Victorian housing estate in Chiswick, and the intact nature of many of its suburban houses and tree-lined streets, although significance is also derived from its distinctive riverside setting with its boathouses and later housing.

5.115 The THVIA points out that Grove Park Conservation Area is over a kilometre away from the appeal site at its closest point. It states that there are few roads that within the conservation areas that are axial to the appeal proposal, and that there are limited points where glimpses of the proposed development would be possible. I accept that views from within the tree-lined streets of the residential core of the conservation area would be limited. However, I consider the appeal proposal would intrude incongruously into important views over the conservation area from the grade II listed Chiswick Bridge, half of which falls within the conservation area. In these views the appeal proposal would appear as a dominant, alien feature, towering above the modest scale of the riverside of Grove Park Conservation Area. Viewpoint 8 commissioned by the LB of Hounslow and RBGK is a view from Chiswick Bridge, taken from within the boundaries of the conservation area, showing the visual impact of the appeal proposal on the riverside setting of the Grove Park Conservation Area.

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5.116 The THVIA states that the effect of the development on the conservation area is likely to be ‘very minor or negligible’, and the ‘where it is seen the proposed development will represent an enhancement’. It concludes that the effect would be ‘Negligible: Beneficial’. This conclusion is based solely on the limited visibility within the core of the conservation area and does not take into account the adverse effects I have referred to in relation to the riverside views. I do not agree that the effect of the development on the setting of the conservation area would be negligible or beneficial. On the contrary, I consider that there would be a harmful impact.

5.117 For the reasons outlined above, I am of the view that harm would be caused to the significance of the Grove Park Conservation Area. In the terms of the NPPF this harm would be less than substantial.

Chiswick House Conservation Area – significance

5.118 The Chiswick House Conservation Area was designated in July 1977. The defining characteristics of the conservation area are set out in the LB of Hounslow’s conservation area statement of March 2006 (CDF.03).

5.119 The character statement states that the Chiswick House Conservation Area is of large size with many distinct character areas. It highlights that the primary architectural and historic interest of the conservation area rests with the grade I listed Chiswick House and its landscaped grounds, which forms the focus of the conservation area. Of secondary interest within the conservation area are the surrounding residential streets that were developed in the 19th and 20th century. The wider residential area was designated primarily to protect views into and out of the 18th century landscape surrounding Chiswick House, and to retain the quality of the surrounding streets. Many of these have grassed verges and flowering street trees, complementing the house and park.

5.120 Chiswick House was built from 1727-9 Richard Boyle, third Earl of Burlington and stands alone within its extensive grounds, which are surrounded by mature tree planting. It was restored in 1956-7 and is now the property of English Heritage together with a small area of formal garden. The rest of the grounds form a public park, managed by the LB of Hounslow. Chiswick House is significant as a highly influential and early example of English Palladianism, and also as the only remaining large house in the south Chiswick area.

5.121 The earliest residential development took place in the mid-19th century. The first area to be developed was Paxton Road, with areas to the west and north of Chiswick House not being developed until the early 1920s. The style of housing varies, most being large scale detached and semi-detached two-

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storey properties, with smaller groups of Edwardian terraced housing. There are also a few 19th and early 20th century elaborate private houses not found elsewhere in the borough.

5.122 Chiswick House Conservation Area comprises a townscape of predominantly low-rise residential properties, which contributes to its significance. For the most part, this consistent townscape is unharmed by inappropriately scaled development within its wider setting.

5.123 Clearly the most sensitive area in the conservation area is Chiswick House and its immediate surroundings. However, the residential streets surrounding the core of the conservation area are also vulnerable to inappropriate development within their setting.

Chiswick House Conservation Area – impact of appeal proposal

5.124 As I have previously highlighted, the primary architectural and historic interest of the conservation area rests with the grade I listed Chiswick House and its landscaped grounds. Of secondary interest within the conservation area are the surrounding residential streets that were developed in the 19th and 20th century.

5.125 Two visualations were prepared by the Appellant ES views 27 and 28 from within the grounds of Chiswick House. These show that the appeal proposal would not be visible above the tree line within the grounds of the house. Dense tree cover would screen views in the direction of the appeal proposals in both summer and winter.

5.126 The THVIA points out that there are few roads within the conservation area that are axial to the appeal site from which the proposed development would be visible. It points out that an exception would be Staveley Road to the south- west of Chiswick House, and that in views along this road are likely to terminate with the appeal proposals rising in the background. My own fieldwork, aided by the visibility of a tall construction crane (of lower height than the appeal proposal) on the site adjoining the appeal site, confirms that the appeal building would indeed be visible in views looking north-west as one progresses along Staveley Road. Plate 7 shows such a view. I consider that it would also be visible from a number of other locations above the rooflines within the residential streets in the conservation area, including, for example, in views looking north-west along Sutton Court Road, close to Chiswick Railway Station (see Plate 8). In these views the appeal proposal would intrude into a townscape that is otherwise largely unaffected by inappropriately scaled development in its wider setting. As such it would, where visible, be at odds

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with the low-rise suburban character of the conservation area and would be harmful to its setting and significance.

5.127 The THVIA concludes that, on balance, the impact of the proposal would be minor or neutral and that the effect would be ‘Minor Beneficial’. Whilst I accept that the effect of the appeal proposal on the setting of the conservation area would be minor, due to the limited visibility and distance (1,5km), I do not agree that the effect would be beneficial. In my opinion, where visible, the appeal proposal would have a harmful effect, albeit of a minor nature.

5.128 For the reasons outlined above, I am of the view that harm would be caused to the significance of the Chiswick House Conservation Area. In the terms of the NPPF the harm would be less than substantial.

Summary

5.129 In summary, I am of the view that by virtue of its location, scale and design, the appeal proposal would cause harm to a range of designated heritage assets including the Royal Botanic Gardens Kew World Heritage Site, the grade II* listed registered Gunnersbury, a number of conservation areas and individual listed buildings within them through harm to their settings. In the case of Strand on the Green and Kew Green Conservation areas I consider the degree of harm to be substantial in the terms of the NPPF. I do not consider the appeal proposal to be of outstanding design that would make a beneficial addition to heritage assets in the surrounding area, nor that it would justify the degree of harm caused. I am of the view that the appeal proposal would conflict with the development plan policies outlined above and with the objectives of the NPPF.

Heritage impact of the proposed advertisements

5.130 As previously outlined, the appeal proposals involve the erection of three large illuminated advertisements. Reason for refusal 2 of the application for advertisement consent stated that the advertisement panels, by virtue of size, location and illumination would have a harmful impact on the setting of nearby heritage assets.

5.131 I consider that the largest and highest of the advertisements, namely Screen 1, a high-level sign wrapping round the west-facing corner of the building, would be unduly prominent and visible from within the Gunnersbury/Kensington Cemetery, which forms part of the Gunnersbury Conservation Area. I note that the THVIA states that the ‘bridging element’ that extends across level 5 of the appeal building would be apparent above the treeline viewed from within the Cemetery. This being so, I consider that the upper portion of the advertisement screen would be visible. The illuminated

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advertisements would be particularly apparent in the darker winter months when the shielding effect of intervening trees would be at its minimum. I note that large illuminated advertisements are visible on the roof of the nearby building at No. 3 Great West Road. At a height of 15m above ground level this is lower than the appeal advertisement, which would be at a height of 19m above ground level. Screen 1 would also be visible form positions on the edge of the Wellesley Road Conservation Area. The smaller, north-facing Screen 3, designed to target south-bound travellers on the North Circular would be visible from Gunnersbury Avenue, which is within the Gunnersbury Park Conservation Area.

5.132 I am mindful of the April 2018 appeal decisions, Ref: APP/F5540/H/17/3180712 & APP/F5540/H/17/3180718, which allowed illuminated advertisement signs on the appeal site. However, I note that the advertisement signage allowed at appeal is smaller in size and set at a lower height than that of the current appeal proposal, being 16m wide by 4m high set at 12m above ground level as opposed to 21m wide by 7.8m wide set at 15.6m above ground level. This being the case, the consented advertisement is likely to be less intrusive than that of the appeal proposal.

Summary

5.133 I summary, I am of the view that the proposed advertisement panels would, by virtue of size, location and illumination, cause harm to the setting of heritage assets in the vicinity of the appeal proposal. Whilst I would rate this harm to be less than substantial in the terms of the NPPF, it should be weighed in the planning balance. In my view the proposed advertisements would conflict with local planning policies outlined above.

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6.0 Design issues

6.1 In this section I consider the shortcomings of the proposed design in relation to reason for refusal No.2 of Planning application and reason for refusal No.1 of Advertisement application.

6.2 Reason for refusal 2 of the planning application states that the proposed development, by virtue of its location, scale, mass and design, would not constitute the very highest, outstanding quality of design required for a tall building in this location, and that it would cause harm to the character of the wider area around the site and the skyline. As a consequence, it would be contrary to relevant design policies on the NPPF, the London Plan and the Hounslow Local Plan. I set out below my views on the design of the appeal proposal having regard to the objectives set out in the relevant design polices.

Scale and form

6.3 In my opinion, the proposed development would be of dominant scale and form, and would appear as an overpowering mass, protruding into the skyline, unrelated to any other existing or planned building. The two related concepts of scale and form are taken together as the excessive height and bulk of the proposed design clearly derives from the attempt to fit such a large amount of accommodation onto the relatively small appeal site.

6.4 According to the Appellant’s DAS (section 5.2.2, page 82), the height of the building has been determined by the view towards the Grade I listed Palm House at the Royal Botanic Gardens. It is not clear why this particular heritage asset has been considered in isolation, why views towards the Palm House predominate when it cannot currently be seen from the site, or why views towards other heritage assets were not taken into consideration.

6.5 The Appellant’s DAS acknowledges that the proposed height and bulk of the proposed building would be potentially intrusive (see Sections 4.6 and 4.7). The architects have attempted to mitigate this shortcoming by amending an earlier iteration of the design by stepping the towers, in order to set back the top levels in views from the south. In my view, this refinement has made little difference. Even with this design refinement, the visual impact of the proposed building would be incongruous in its surroundings due to its overall excessive height and bulky form.

6.6 The Appellant’s DAS (section 1.1) describes the proposal as a ‘bespoke design-led response’. It would seem to me that the proposal is in fact a

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development-led response that seeks to accommodate an excessive amount of accommodation on a relatively small site and that the principle objective of the design has been to mitigate the visual impact of the excessive height and mass inherent in provision of such a large amount of floorspace.

6.7 The Government’s National Planning Practice Guidance (NPPG) advice that the massing of development should contribute to creating distinctive skylines in cities, towns and villages, or to respecting existing skylines (Paragraph: 026 Reference ID: 26-026-20140306) supports my concern with regard to the excessive height and bulk of the proposal.

Inelegance

6.8 In my opinion, the form of the proposed development would be inelegant. The inelegance of the design relates to its proposed bulk and mass. In particular, the inelegance derives from the way the proposed mass widens over the lower storeys, and then rises as one before dividing into two towers, creating a clumsy, bottom-heavy form with a narrow base. As the conjoined base-bulk constitutes over half the height of the building, the two towers appear as stubby protrusions rising from an enormous solid rather than elegant/slender forms. In many views, the two protruding towers would merge into one, forming a single, ungainly bulk.

6.9 The Appellant’s DAS (at section 4.4) states that the scheme explored three building volumes of sculpted forms to break down the overall massing of the building and reduce the impact of the proposal in long distance views. In my view, this objective would not be achieved, particularly in long distance views. At section 5.1, the DAS repeats that the architectural volume is composed of three distinct curved forms. In my opinion, three distinct vertical forms would not be apparent. The Appellant’s own visualisations show that two towers rise out of a bulky base mass. From the immediate surroundings at ground level, I consider that the building would appear as one overbearing mass, due to the widening form above. The inelegance of the bulk would become particularly apparent in views from further away. From the distances where the proposal would impact on heritage assets referred to in in this proof, I consider that the silhouette and bulk would become dominant. In my view, the proposed building is shown to be an inelegant and intrusive bulk in both the visualisations prepared by the Appellant and the additional visualisations prepared on behalf of the LB of Hounslow and Kew Gardens.

6.10 The Appellant’s DAS (at section 4.4) claims virtue in the smaller footprint at ground level. In my opinion, the wider, oversailing upper floors would create an overbearing bulk looming above, from immediate surrounding viewpoints.

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Relationship to the immediate surroundings

6.11 The Appeal Site is a relatively small plot to accommodate such an enormous building. It is located within a gyratory traffic system. It is currently difficult, unpleasant and dangerous passing through this area on foot or as a cyclist. The proposed development retains narrow footways around the perimeter of the site, albeit reconfigured. Whilst a central thoroughfare is proposed, it is highly likely that this would become a private controlled space as it does not contain sufficient commercial space to draw pedestrians to this hostile area.

6.12 The Appellant’s DAS (at section 4.8, page 72) states that the design of the public realm developed significantly to transform the existing island into a greener, safer, and connected part of the public realm and that this is a major benefit of the proposal. The DAS states on page 80 that “a generous landscaped forecourt leads into a publicly accessible internal garden”.

6.13 The Appellant’s DAS Addendum (page 11) states that 498 m² (GIA) of cafe and retail space would be provided. However, the proposed ground floor plan (ref. SEW_1100-01) as amended shows only two A1/A3 units with floor areas of 73 and 32 m², the larger of which is set at a raised level, accessible by steps or a platform lift. The much larger A1/A3 unit of 354 m² proposed at first floor level (which would be accessed by a staircase from the larger ground floor A1/A3 unit) would make little contribution to a vibrant ground floor public space. The relatively small quantum of A1/A3 units would not be likely to create significant footfall. The images of a vibrant streetscene, such as that at page 101 of the Appellant’s DAS are unlikely to materialise, given that the only A1/A3 unit directly accessible at ground floor level has a mere 32 m² floor area.

6.14 Residential users of the dwellings above are likely to primarily access the building directly from the surrounding streets, so may not use the atrium, which would further reduce the likelihood of vibrant use of the proposed internal public space. As a result, it is highly likely that the atrium would be little used. In order to safeguard against anti-social behavior access to the atrium would inevitably have to be controlled and it would almost certainly become a private space. It is acknowledged in the DAS (section 5.5.1, page 102) that “this space will have controlled access during evening hours”. During such times, and at any other times that public access might be denied, public access would be around the narrow perimeter footpaths. In my view, access alongside the North Circular Road would be only marginally less unpleasant than the existing arrangement. Access for pedestrians along the north-western side of the building abutting Larch Drive would become even more inconvenient, unpleasant and dangerous than the existing arrangements, due to the presence of the proposed car-park entrance and a service/loading bay, which

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extends along approximately half of the Larch Drive frontage. As Mr. Baker points out in his proof of evidence, Larch Drive would be a hostile environment for pedestrians.

6.15 The Appellant’s DAS (section 5.5.3, page 104) states that the proposed development is designed to maximise active street frontages. In my view, this claim cannot be justified. The majority of the exterior of the building at ground floor level is taken up with such elements as the refuse holding area, the car- park entrance, the car-park smoke vent shaft, the bike lobby, residential lobbies, and the HV intake area, all of which constitute dead-frontage. The diagram on page 104 of the DAS includes the residential lobby areas and the entrance areas to the central space as active frontage. The only elements that have any potential to be correctly described as active frontage are the two small A1/A3 units and these are not designed with shop fronts addressing the exterior. In my view, the exterior of the building at ground floor level, with the exception of the entrance points, is little different to the glazed exterior of the upper parts and cannot be accurately described as an active frontage.

6.16 The Government’s NPPG advises with regard to towers that “how taller buildings meet the ground” is a specific design challenge (paragraph: 025 Reference ID: 26-025-20140306), emphasising the importance of the ground floor elements and the proposals for the immediate surroundings.

6.17 The proposed landscaping proposals within the application site, external to the building, are limited to modest planting proposals around the narrow margins. Whilst planting along these margins would be welcome, it may be difficult to establish planting as proposed in such hostile environmental conditions. Even if such planting could be established, it would do little more than minor softening of the edges of the enormous bulk of the proposed building.

6.18 The Appellant’s DAS (section 7.3.3, page 158) states that the designers have looked beyond the application boundary at the wider environment to consider how the existing landscape could be improved. However, the proposals put forward are very modest, amounting to little more than minor enhancement of the underpass area below the M4 and improvements to two pedestrian road crossings. The more substantial landscaping enhancements illustrated in the DAS, such as planting on the Chiswick Roundabout, semi mature tree planting on the central reservation of the North Circular Road, and highway enhancements to Larch Drive, are described as aspirational public realm works that could be delivered by utilising community infrastructure levy contributions from developments (see DAS, section 7.3.3). Consequently, the sketch illustration on page 162 of the DAS is somewhat misleading and the claim

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made in section 4.8 of the DAS (page 72) that “a major offering of the proposals is to enhance the public realm” is not supported by the facts.

6.19 The proposed illuminated advertisement panels, which are discussed in more detail below, would be particularly prominent in the surrounding areas to the immediate north and west of the proposed building. By their nature, they would draw the eye, as accepted in the Appellant’s DAS Addendum (section 4.2.2) in the explanation of the reason for the omission of the originally proposed fourth advertisement panel. The three proposed advertisement panels, two of which are double-stacked on the western corner, would become the focus of views towards the building from the north and west and would seriously degrade the quality of the local environment.

Relationship to the wider surroundings

6.20 I have already explained the harmful impact that the proposed building would have on a considerable number of heritage assets in the wider surroundings. As a component of good design is the way a building respects its surroundings, my evidence relating to the impact on heritage assets, supports the Council’s reason for refusal relating to design.

6.21 The part of west London that would be affected by the proposed tower is primarily low-rise in character. There are some tall buildings in the vicinity of the proposal, which are for the most part clustered in a zone to the west of the appeal site. None are of the scale of the proposed building. Nor are any other consented schemes in the area. In my opinion, the proposed building, by virtue of its enormous scale and bulk, would be inherently incongruous in this predominantly low-rise part of west London. The proposal would be significantly taller than any other building in that wider context and would stand distinct and visually isolated from other larger buildings in the skyline. In short, it is quite simply in the wrong location. As a result, it would constitute an alien and incongruous intrusion as perceived from its wider surroundings.

6.22 The Government’s NPPG advice that the success of towers is dependent on where they are placed, how they relate to their surroundings, their use and their architectural and design quality, supports my conclusions (paragraph: 025 Reference ID: 26-025-20140306).

Materials

6.23 The proposed materials would be reflective, in contrast to almost all other buildings in the surrounding area, which would make the building stand out

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from, rather than harmonise with, its surroundings, contrary to the guidance in paragraph 028 of the NPPG (Reference ID: 26-028-20140306).

6.24 I do not criticise the architect’s attempt to add interest to the exterior of the building by the introduction of a fine-grained pattern of multi-coloured cladding panels and fins. However, I consider that the subtleties of this architectural approach would only be appreciated at a relatively close range, and not be discerned from the range where the appeal building impacts on the most sensitive heritage assets. The reflective nature of the proposed cladding materials would inevitably make the building contrast with and stand out from other buildings in the area. In combination with the height and bulk of the structure, this reflective characteristic would reinforce the prominence of the proposed building in views from the surrounding area.

6.25 As noted below, the proposed large-scale illuminated advertisement panels would be in stark contrast with the fine-grained, multi-coloured cladding of the remainder of the proposed building.

Detracting nature of the proposed advertisements

6.26 In my opinion, the presence of large-scale, illuminated advertisements on the lower parts of the proposed tower, significantly degrade any claimed aesthetic qualities that the proposed building might have. I can think of few, if any, examples of purpose-designed buildings, that can be commended for their design quality in carrying large-scale illuminated advertisements of this sort, save perhaps the Lucozade building with its original illuminated sign (now replaced with a digital advert). Such advertisements inherently commercialise and debase the appearance and aesthetic intentions of the design. According to the submitted application documentation, the advertisements are essential to the viability of the proposal so cannot simply be omitted to secure an enhancement.

6.27 The Appellant’s DAS (at page 68) states that ‘As the existing site already has three free-standing advertising screens, LBH were keen to see that the design of advertising screens was considered and integrated with the proposed development, and not an afterthought’. My understanding from Council officers is that they did not actively encourage the inclusion of illuminated advertisements. The proposed advertisements are put forward by the applicant. The LB of Hounslow may well have advised that if advertisements are to be put forward, they should be integrated into the design. In my opinion, the proposed advertisements fail in this respect. They are over-large panels, unrelated to any other aspect of the proposed design, which would appear as attached to rather than integrated into the proposed structure.

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6.28 The related viability information indicates that the proposed advertisements are an essential element of the financial viability of the project. The advertisements are not justified on any aesthetic or design grounds. In my view, the proposed advertisements are commercial elements that debase the architecture and appearance of the proposed building.

6.29 The Appellant’s DAS (at page 68) states that, initially, the design of the advertising screens sought to avoid the large and opaque digital screens that dominate the building and streetscape. This is exactly what the Appellant now proposes. The Appellant has argued consistently throughout the Design and Access Statement (e.g. see section 1.1) and the Environmental Statement that the design of the proposed building is of the highest architectural quality, yet the structure is used as a support for large-scale advertisements that clash with the proposed building’s fine-grained elevational architectural features. The presence of these incongruous and obtrusive advertisements militates against any such claim of high architectural quality.

6.30 As discussed above, the proposed advertisement panels would have a seriously detrimental impact on the environmental amenity and townscape character of the immediately surrounding area to the north and west of the proposed development, as perceived by pedestrian users.

6.31 For the reasons set out in detail above, the proposal is contrary to the following planning policies.

London Plan Policy 7.4: Local character

6.32 The proposed development would not provide a high-quality design response that has regard to the pattern and grain of the existing spaces and streets in orientation, scale, proportion and mass, would not be human in scale, would not create a positive relationship with street level activity, and the design is not informed by the surrounding historic environment.

London Plan Policy 7.6: Architecture

6.33 The proposed development would not be of the highest architectural quality.

London Plan Policy 7.7: Location and design of tall and large buildings

6.34 The proposed development would not relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm (including landscape features), particularly at street level; would

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not enhance the skyline and image of this part of London; would not have ground floor activities that provide a positive relationship to the surrounding streets; and would not make a substantial improvement to the permeability of the site and the wider area. Furthermore, the proposal would impact adversely on important local views.

Hounslow Local Plan Policy CC1: Context and Character

6.35 The proposed development would not improve, promote the appreciation of, sustain and conserve, areas in the wider surroundings which have a high quality, well established and coherent character that is sensitive to change; nor would it suitably enhance the poorer and more mixed character of the immediate surroundings, the proposal constitutes poor quality design. The proposal does not respond to the wider context and history of the area, as required by the policy.

Hounslow Local Plan Policy CC2: Urban Design and Architecture

6.36 The proposed development would not create an attractive, distinctive, and liveable place and would not constitute high quality urban design and architecture. The proposal would not function well in itself, particularly at lower level in its effect on the surrounding area and would not have a positive impact on the amenity of current and future residents, visitors and passers-by. Nor would it respond meaningfully and sensitively to the site, its characteristics and constraints, and the layout, grain, massing and height of surrounding buildings. The proposed atrium would not make a clear distinction between private, semi- private and public space and the public realm would not be comfortable, safe and attractive at times when the atrium was inaccessible. The proposed building would not minimise overbearingness or minimise direct overlooking of the nearby Kensington Cemetery.

Hounslow Local Plan Policy CC3: Tall Buildings

6.37 The proposed development has not been carefully designed and sensitively placed so as not to have a significant adverse impact on the setting of, views from and between heritage assets. The proposal would have a significant adverse impact on the setting of and views from heritage assets including Gunnersbury Park, the Royal Botanic Gardens Kew World Heritage Site, and the Thames foreshore landscape. It should be noted that the policy states that existing tall buildings which are in inappropriate locations (assessed against the criteria of this policy) do not provide a justification for the provision of new ones. The proposed development is not of a height and scale that is in proportion to its location and setting and would not carefully relate and respond

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to the character of the surrounding area, nor is it of the highest architectural design and standards. The form, mass and silhouette of the proposal would have a seriously adverse impact on the immediate and wider context. The proposed building would not provide a positive edge to the public realm and a human scale through the careful treatment of ground floors and lower levels, nor would it take opportunities to enhance the setting of surrounding heritage assets, the overall skyline and views.

Hounslow Local Plan Policy CC5: Advertisement Panels, Hoardings and Structures

6.38 The proposed advertisements would not respect their context with suitable regard to amenity and public safety. The proposed advertisements would degrade the elevations and appearance of the building they would be attached to; would constitute over-prominent features that would be incompatible with the townscape of the immediate surroundings of the proposed building as perceived by pedestrians; and would impact adversely on the setting of heritage assets. As a result of their size, shape and positioning, the proposed advertisements would appear as attached to the proposed building rather than as integral components of its design.

National Planning Policy Framework, Chapter 7: Requiring good design

6.39 The proposed development would not function well and add to the overall quality of the area, particularly at ground level, nor would it optimise the potential of the site to accommodate development, respond to local character and history, or reflect the identity of local surroundings and materials. The proposal would not be visually attractive in its immediate or wider surroundings, rather it would be over-bearing and obtrusive. The proposal is therefore in conflict with NPPF paragraph 58. The Council’s case against the proposed development centres on its overall scale, density, massing, height, and landscape in relation to neighbouring buildings and the local area more generally and is therefore consistent with paragraph 59 of the NPPF. The Council’s case is also consistent with paragraph 61 of the NPPF which makes clear that high quality and inclusive design includes the integration of new development into the historic environment. Paragraph 64 of the NPPF sets out a firm instruction that permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions and paragraph 67 makes clear that poorly placed advertisements can have a negative impact on the appearance of the built and natural environment. As a consequence of the shortcomings of the design of the proposed building, the proposal does not

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constitute sustainable development under the terms of the NPPF (paragraphs 17 and 56).

Summary

6.40 In my view the appeal building, by virtue of its location, scale, mass and design would not constitute the very highest, outstanding quality of design required for a tall building in this location and would cause harm to the character of the wider area around the site and the skyline. As such it would conflict with both national and local planning policies outlined above. Similarly, I consider that the proposed advertisement panels would have a seriously detrimental impact on the environmental amenity and townscape character of the immediately surrounding area to the north and west of the proposed development.

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7.0 Conclusions

7.1 In arriving at my conclusions, I have taken account of the relevant decision- making context in which the appeal must be determined, including the national and local design and heritage policy. It has also taken into account the scale, massing and disposition of the appeal proposal within its surrounding physical context, including the significance of heritage assets, and the particular contribution that setting makes to significance. This has informed conclusions with regard to the impact that the appeal proposals would have on the character.

7.2 I consider that that the appeal proposal would cause harm to the setting and significance of a number of heritage assets in the vicinity of the appeal site. In relation to the Strand on the Green Conservation Area and the Kew Green Conservation Area I consider that the level of harm caused would be substantial in the terms of the NPPF. This is due to the fact that, in both cases, very serious harm would be caused to a key element of significance of the conservation area. In the case of the other heritage assets I have cited in the proof of evidence I consider the harm to be less than substantial, but nevertheless in a number of instances serious, such that it should be taken into account in weighing the planning balance. In the case of Gunnersbury Conservation Area and Registered Park, and the Royal Botanical Gardens, Kew World Heritage Site, I consider that the level harm would be towards the upper end of the scale of less than substantial harm.

7.3 I do not agree with the Appellant’s assertions in the THVIA that, due to the high design quality of the appeal proposal, there would be beneficial effects, and that in consequence no harm would be caused and so, by extension, it is unnecessary to weigh harm against the public benefits of the proposal as required by paragraphs 133 and 134 of the NPPF.

7.4 The appeal building would be considerably taller than any other existing or consented building in the Borough of Hounslow, and if allowed would be totally out of scale with the generally low-rise nature of its surroundings. The proposed tower would also be of bulky and inelegant form. In my opinion the building does not relate well to its surroundings. It would therefore cause harm to the character of the wider area around the site and the skyline. Likewise, I consider that that the proposed advertisement panels would have a seriously detrimental impact on the setting of designated heritage assets and the environmental amenity and townscape character of the immediately surrounding area.

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7.5 For all of these reasons I consider the appeal proposal to be in conflict with relevant design and heritage policies in the London Plan and the Hounslow Local Plan and the design and heritage policy objectives of the NPPF.

7.6 Clearly, in making a decision on the planning balance, the Inspector must, in accordance with the provisions of s66, give considerable importance and weight to the desirability of preserving listed buildings and their settings, as well as having regard to the relevant policies in the NPPF. I am of the view that the appeal proposal would fail to preserve the setting of the listed buildings I have cited in this proof of evidence.

7.7 I am of the view that if the important designated heritage assets that I have highlighted in this proof of evidence are to have meaning, and the policies that are intended to protect them are to have their intended effect, then it is precisely developments such as the appeal proposal that the planning system is intended to prevent.

7.8 In conclusion, I note that, in assessing the overall planning balance, Mr. Baker’s evidence demonstrates that the harmful effect resulting from the appeal proposals would not be outweighed by the public benefits that the appellant claims for the proposals.

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Appendix A Plates

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Plate 1: View of Strand on the Green looking north-west from Kew Railway Bridge. Note that the construction crane on the site adjoining the appeal site is clearly visible.

Plate 2: View looking north towards the appeal site along Hearne Road, Strand on the Green Conservation Area. Note that the construction crane on the site adjoining the appeal site is clearly visible in this view.

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Plate 3: View looking north towards the appeal site along Spring Grove, Strand on the Green Conservation Area. Note that the construction crane on the site adjoining the appeal site is clearly visible in this view.

Plate 4: View looking north-north-west from Wellesley Road, close to its junction with Clarence Road. Note that the construction crane on the site adjoining the appeal site is clearly visible in this view.

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Plate 5: View looking north-west towards the appeal site at the junction of Brooks Road, Oxford Road South and Stile Hall Road. Note that the construction crane on the site adjoining the appeal site is clearly visible above the rooflines in this view

Plate 6: View looking east towards the appeal site along Brentford High Street/Kew Bridge Road. Note that the construction crane on the site adjoining the appeal site is clearly visible in this view

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Plate 7: View looking north-west along Staveley Road, Chiswick House Conservation Area, towards the appeal site. Note that the construction crane on the site adjoining the appeal site is clearly visible above the rooflines in this view

Plate 8: View looking north-west along Sutton Court Road, Chiswick House Conservation Area, towards the appeal site. Note that the construction crane on the site adjoining the appeal site is clearly visible above the rooflines in this view

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