Historic England Response on Watermans Site Proposals

Mr Stephen Hissett Direct Dial: 020 7973 3785 London Borough of Hounslow Development Control Our ref: P00639153 The Civic Centre Lampton Road TW3 4DN 14 September 2017

Dear Mr Hissett

Arrangements for Handling Heritage Applications Direction 2015 & T&CP (Development Management Procedure) (England) Order 2015 40 AND 40A HIGH STREET (ALBANY RIVERSIDE) BRENTFORD TW8 0DS Application No 00607/T/P1

Thank you for your letter of 10 August 2017 notifying Historic England of the above application.

Historic England first commented on pre-application proposals at the Waterman’s Site in August 2016. The proposals were presented internally to our regional casework review panel, and the applicants also presented to our most senior casework committee on site at Kew Gardens in September 2016. Following that meeting further advice was issued on 7 October 2016. Having been consulted on subsequent amendments to the scheme Historic England provided a third letter of advice on 4 August this year.

Summary Throughout the course of our pre-application consultation we set out our serious concerns over the impact of the proposals on the setting of the Royal Botanic Gardens, Kew, World Heritage Site, and in particular the Grade I listed Scheduled Monument of Kew Palace. The setting of the Palace and World Heritage Site is of the highest quality and is an essential part of the experience and enjoyment of this world famous site. It also plays a major part in understanding how Kew and the ‘Arcadian Thames’ played such an important role in drawing the royal court and centuries of royal, scientific, and artistic patronage to this area of London. We consider the encroachment of urban, modern construction such as the large blocks of flats proposed for the Albany riverside will fundamentally undermine the existing quality of the setting of Kew Palace, including in views currently untouched by modern development, and will set an uncontrollable precedent for further new buildings within the hinterland of the World Heritage Site.

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Historic England Advice

Significance The Albany Riverside site is currently occupied by the Waterman’s Arts Centre and a two storey office building. It is not included within any conservation areas and contains no designated heritage assets. Historic England has no objection to the redevelopment of these building in principle.

The development site is in close proximity to a number of highly designated assets. These include:

 The Royal Botanic Gardens, Kew, World Heritage Site  The World Heritage Site Buffer zone  The Grade I Registered Park and Garden, Royal Botanic Gardens, Kew  Kew Palace, Grade I listed and a Scheduled Ancient Monument  The Orangery at Kew, Grade I listed  Kew Palace Flats, Grade  Kew Green Conservation Area  Royal Botanic Gardens Conservation Area

This is not a comprehensive list but it is enough to demonstrate the very highest levels of protection and significance afforded to the area to the south of the development site. There are only eighteen World Heritage Sites in England and their recognition by UNESCO is a sign of truly exceptional international significance.

The building we now refer to as Kew Palace is also known as the Dutch House and is the principal standing remnant of a much larger complex of buildings used as a country retreat by the Georgian royal household between 1728 and 1818. The history of this site as a place of pleasure and relaxation away from London and Westminster began long before when Kew existed as a quiet neighbouring parish to the major Tudor palace at Richmond.

Life continued in that pattern at Kew in the 1630s when Samuel Fortrey, a City merchant, commissioned the building of the Dutch House as his own rural retreat. At that time the Dutch Republic was emerging as a global empire surpassing that of the English with huge commercial power. Dutch cultural influence grew with it, especially in Protestant England, and the architecture of the Dutch House reflects this. Its distinctive gables are the most striking evidence of this fashion, but in its construction the pioneering use of ‘Flemish’ bond in the very high quality brickwork marks one of the first major projects in English architectural history of a building technique that would come to dominate brick building for the following centuries.

I emphasise here the very high design quality of the Dutch House in order to

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demonstrate the early history of sophisticated courtly fashions that can be found at Kew. Its proximity to the royal palace at Richmond allowed these advertisements of taste and status to reach their intended audience, and the building’s position close to the Thames ensured both that it was seen by important passers by and that it could be easily accessed from London.

In 1728 the estates at Kew were annexed to the Royal Palace at Richmond by the recently crowned George II and Queen Caroline. Their three daughters moved into the Dutch House, while Prince Frederick of Wales and Princess Augusta moved into and enlarged the (now lost) 'White House' positioned just to its south.

The occupation of Kew by the royal household, as opposed to merely expanding Richmond Palace, allowed them to use this adjoining site in a separate and less formal manner. Its position at the northern edge of the park of the Palace of Richmond removed the inhabitants from the formality of court and provided an opportunity for newly fashionable Picturesque landscaping to influence the establishment of the gardens. The relaxed enjoyment of Kew and the attractiveness of its outdoor setting is exemplified in Philip Mercier’s 1733 musical portrait of the Prince of Wales with three of his sisters grouped in front of the Dutch House.

The presence of Prince Frederick at Kew has importance for a number of reasons. Frederick was the heir to the Hanoverian dynasty, but was also the chief opponent to his father’s government. He used the arts and his royal patronage in a very public and politicised fashion. He was lavish with his expenditure, and at the forefront of emerging tastes. As a consequence, the alternative court which surrounded him at his retreat at Kew will have expected to find the highest possible standards of luxury and display amongst the wooded groves of the parkland.

It was Frederick who initiated the first serious landscaping works around Kew, and these were continued in earnest after his death by his widow Augusta. Over the course of the eighteenth century this brought to Kew the work of Charles Bridgeman, William Kent, William Chambers, and Lancelot 'Capability' Brown: a litany of the most highly regarded English landscape designers and architects.

Augusta as dowager Princess of Wales established the first botanic garden at Kew in 1759, and this role expanded under the influence of Sir Joseph Banks between 1772 and 1820. Banks' extraordinary talents in establishing a world class collection at Kew were complemented by his successors to the extent that today Kew contains some of the largest botanical collections in the world.

Associated with this long history of the highest quality architecture and landscaping is an equally impressive roll call of cultural and scientific achievement at Kew. Great literary figures such as Voltaire, Alexander Pope, Horace Walpole, and Daniel Defoe visited the palace and gardens, and the Arcadian landscape has inspired a literary

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outpouring. In his 1767 poem ‘Kew Garden’ Henry Jones rhapsodised over the natural setting of the site ‘where art and nature must incessant vie’, and later celebrated that ‘here princely states, and rustic plainness verge, in sweet vicinity for ever fix’d’.

The palace, gardens and Arcadian Thames feature in paintings, engravings and sketches by numerous artists, including Mercier, Peter Lely, John Gainsborough, Canaletto, William Chambers, and Turner. Turner in particular sketched the relationship of the old Palace and the river. It has been understood for centuries that the environment of these gardens is exceptional and inspiring. As early as the eighteenth century foreign tourists included Kew and its gardens in their itineraries of England and the flow of visitors has not stopped since.

The combination of exceptional buildings, landscaping, planting, history and location make Kew a unique and unparalleled site. It is visited by over a million people every year and was inscribed as a World Heritage Site in 2003. It's attributes of Outstanding Universal Value include but are not limited to the following:

 A rich and diverse heritage cultural landscape  Relationship with the River Thames and wider Arcadian landscape and beyond  A series of key vistas  Royal residency and patronage of the gardens as evidenced in Kew Palace

Historic England attaches particular importance to the contribution that setting makes to the overall significance of Kew Palace and the Kew Botanic Gardens World Heritage Site. Setting is distinct from character, curtilage, or views, though it may incorporate these things. As the environment within which a heritage asset is experienced it includes a complex set of physical, perceptual, and associational attributes.

The experience of Kew is fundamentally defined by the very layered composition of planting, landscape features, spectacular buildings, and the river beyond. The result is a contribution to the significance of Kew as a whole that is of very clear and exceptional magnitude. The setting of the Palace and Garden is a key aspect of the totality of Kew’s significance and requires careful protection.

The Arcadian river setting as a backdrop to the Palace and gardens ties together the many layers of very highly designated heritage sites in place at Kew. The term ‘Arcadian’ is intended to evoke the wooded groves of ancient Greece, a landscape of rivers and streams, philosophers and muses inhabiting the landscape of a classical golden age. It is the defining feature of the World Heritage Site Buffer Zone, and the historical connection between Kew Palace and the Thames.

The Arcadian Thames is the vital thread that runs through the whole of Kew’s long

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history. It tells the story of Kew’s attraction to its early patrons, to the royal family, to great cultural figures, and to the development of the spectacular gardens as they are today.

The preservation of these Arcadian qualities as defined by the river setting enables visitors to view Kew through the same lens as its earlier patrons. This environment facilitates the understanding of the Dutch House as the rural retreat it was built to be nearly four hundred years ago.

While London has evolved beyond the boundaries of the Palace and its gardens, successful screening has prevented a great deal of modern development from being directly visible. Meanwhile some very poor elements of setting - a former gasworks - have been removed to the great enhancement of the World Heritage Site. This screening occurs in the high trees of the Aits in the Thames, described by the Thames Landscape Strategy as follows: ‘The Aits, reflected in the dark water, form the major element in the views from Brentford, Kew and Kew Bridge, disguising and revealing vistas to make the river seem larger and more mysterious.

Where modern development has become visible the result is a harmful and discordant intrusion that conflicts with the Arcadian qualities described above: the ‘Kew eye’ and the Haverfield Estate are the most prominent examples of this kind of impact.

Despite these existing impacts there remain positions from which visitors today can recover the scenery of the Georgian court and the experience of a site valued for its Arcadian charm.

Impact The proposals will bring about the demolition of all buildings on the development site, and their replacement with five blocks, varying in height between six and seven storeys (not including ground and lower ground).

At present the development site is largely screened from the south side of the Thames. Should the proposals be realised this will change. The new blocks will be visible in the setting of Kew Gardens, the World Heritage Site and its Buffer Zone, Kew Palace, and the 'Arcadian Thames'.

The experience of the setting of several designated heritage assets will be altered by the introduction of new built forms where none exists currently, and by the contrast of a verdant natural setting against a modern built environment. The scale of impact varies seasonally due to the screening effects of trees.

Policy Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes it a statutory duty for Local Planning Authorities to consider the impact of proposals on

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listed buildings. They are required to have special regard [my emphasis] to the desirability of preserving the setting of a listed building. Section 72 requires that special attention [my emphasis] shall be paid to the desirability of preserving or enhancing the character or appearance of a conservation area.

Guidance on the fulfilment of statutory planning duties is set out in the Government’s National Planning Policy Framework 2012 (NPPF). Fundamental to the NPPF is a presumption in favour of sustainable development. This includes a core principle which states that heritage assets should be conserved in a manner appropriate to their significance. Section 12 of the NPPF is devoted to the conservation and enhancement of the historic environment, and includes the following paragraphs of direct relevance to this case:

 Paragraph 131 - Local Authorities should take account of the desirability of new development making a positive contribution to local character and distinctiveness.  Paragraph 132 - Local Authorities should put great weight on an asset’s conservation, and the more important the asset the greater the weight of consideration. The significance of an asset can be harmed by development within its setting [my emphasis].  Paragraphs 133 and 134 set out the tests applied to any harm to designated heritage assets that must be met if harm is to be justified.  Paragraph 137 - Local Planning Authorities should look for opportunities for new development within conservation areas and within the setting of heritage assets to enhance or better reveal their significance.

The National Planning Practice Guidance (NPPG) provides useful areas of clarification for the above policies. It makes the following points regarding setting (inter alia):

 Setting is the surroundings in which a designated heritage asset is experienced, and may therefore be more extensive than its curtilage.  The extent and importance of setting is often expressed by reference to visual considerations... other environmental factors may amplify the experience of the significance of an asset.  'The contribution that setting makes to the significance of the heritage asset does not depend on there being public rights or an ability to access or experience that setting. This will vary over time and according to circumstance.'  When assessing any application for development which may affect the setting of a heritage asset, LPAs may need to consider the implications of cumulative change.

This guidance is clarified further in case law. Following the ruling in Barnwell Manor Wind Energy Limited v East Northamptonshire District council, English Heritage, the

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National Trust and the Secretary of State for Communities and Local Government [2014] EWCA Civ 137, considerable importance and weight should be given to the desirability of preserving the setting of a listed building when carrying out the planning balance. Less than substantial harm does not equate to a less than substantial planning objection. There is a presumption that preservation is desirable.

The strategic policy framework for development in London is set out in the London Plan (adopted by the GLA in July 2011). Policy 7.4 concerns local character and states that development should improve an area's visual or physical connection with natural features (7.4A). Further, development should be 'informed by the surrounding historic environment' (7.4B.e).

Policy 7.8 addresses heritage assets and archaeology, and (7.8D) states that 'development affecting heritage assets and their settings should conserve their significance, by being sympathetic to their form, scale, materials and architectural detail.'

Policy 7.10 is of particular relevance in that it directly concerns London's World Heritage Sites. It states that (7.10A) development in the setting of a World Heritage Site should make sustainable use of and enhance their authenticity, integrity, significance, and Outstanding Universal Value.

7.10B states that development should not cause adverse impacts on World Heritage Sites, or their settings, including any buffer zone. The ability to appreciate Outstanding Universal Value, integrity, authenticity, or significance is of particular importance. It goes on to state that appropriate weight should be given to implementing the provisions of World Heritage Site Management Plans.

Since 2005 UNESCO has required all World Heritage Sites to be supported by concise, formal statements that encapsulate the qualities that justify their Outstanding Universal Value. That produced for Kew Royal Botanic Gardens is included within the sites Management Plan. Any such statement should explain the attributes through which Outstanding Universal Value is conveyed. The attributes of Outstanding Universal Value at Kew are set out under the 'significance' section above, and are referenced here in order to emphasise the weight attached to these attributes as material considerations in any planning decision which might affect them.

The Thames Landscape Strategy is referenced in the London Plan (Policy 7.29) and has been adopted as Supplementary Planning Guidance by the London Borough of Hounslow. It is concerned to protect the local character of the Arcadian Thames between Weybridge, Hampton and Kew. It identifies as a main point of consideration concerning development at the Brentford Waterfront the views of that site from Kew Gardens (Page 169)

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Thames Landscape Strategy Policy 12.3 seeks to ‘Prevent any further flat-roofed, high rise buildings from intruding into the Brentford Waterfront massing.’

Position This proposal presents a series of changes to the environment around Kew Palace and Kew Gardens that will directly impact on the Arcadian setting of those assets, an aspect of their Outstanding Universal Value as a World Heritage Site.

In cases where harm is proposed to the significance of a designated heritage asset the NPPF directs that great weight should be given to the asset’s conservation. ‘The more important the asset, the greater the weight should be.’ (Paragraph 132.) Kew Gardens and Kew Palace benefit from the highest possible levels of heritage protection as a combination World Heritage Site, Grade I listed building, Scheduled Monument, Grade I registered Park and Garden, and a Conservation Area. The greatest weight must therefore be given to their conservation if the terms of the NPPF are to be upheld.

The International Council on Monuments and Sites (ICOMOS) which advises UNESCO on the conservation and protection of World Heritage Sites issued in 2011 Guidance on Heritage Impact Assessments for Cultural World Heritage Properties (such as Kew Gardens). That guidance tells us that where the impact of a proposal is likely to affect the attributes of a site’s Outstanding Universal Value then the sensitivity to change should be considered as follows:

We find multiple instances of harm proposed as part of this application, and consider the severity of impact to range between large and very large according to the table above. These impacts occur to the significance of the Palace and Gardens which is derived from their setting.

The contribution that setting makes to the overall significance of Kew is substantial for several reasons. First, the outdoors environment at Kew is well understood for its very

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high quality and for the long history of considered landscaping and design. Second, the ability to intellectually reconstruct the atmosphere of a rural retreat is essential in understanding the appeal of this site to the Georgian court, and the setting of the gardens today is perfectly suited to reveal and enhance this layer of significance. Third, aspects of the setting of Kew are specifically inscribed in the Attributes of Outstanding Universal Value identified in the site’s management guidelines. Most particularly these include the ‘relationship with River Thames and wider Arcadian landscape beyond’.

Views 11c, 11s, 12, 13, 16, 19, 20 and 21 demonstrate that the arrival of new buildings between or above the treeline causes an irreconcilable clash of character between the fundamental characteristics of an historic Arcadian landscape of exceptional value, and the intensity of rapidly changing modern London.

View 19 (above) as existing is a good example of the quality of the setting of Kew Palace when shown to its best advantage. The palace is seen in its garden setting, with the trees of the Thames in the background. Between the palace and its Grade I listed kitchen buildings (left, ‘Kew Palace Flats’) there is a space defined only by trees and clear sky. Even in winter the setting is entirely absent of modern intrusions, allowing the parkland and historic buildings to be framed by trees and sky alone. The whole effect is picturesque, humane, and has taken centuries to develop.

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The impact of the development is shown in the above visual. Blocks of flats replace the treeline as the backdrop to the Palace. Rather than historic parkland, the Palace is now set against a large housing development. This clearly harms the experience of visitors to Kew, and obscures the Arcadian qualities that are a defining feature of the environment around the Palace and Gardens.

Moving a short way to the east or west from viewing position 19 brings twentieth and twenty-first century buildings in to view. The result is, in each case, a regrettable imposition on the quality of the setting of Kew. This fine relationship between historic buildings and parkland becomes eroded through poorly considered additions.

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View 16 shows especially clearly the deterioration of the setting of the Palace through insensitive modern development (the GWQ or ‘Kew Eye’ tower) and to the left of that the cumulative impact that would be brought about by this proposal. This creates a ragged, ad hoc setting to the palace. It is clearly not the result of plan-led development, and does nothing to reveal or enhance the significance of the World Heritage Site, Palace or Gardens.

Another example of significant change seen in the proposed visuals is View 20, taken from the north elevation of the Palace. The new buildings will, in winter especially, be seen to approach the height of the prominent tower of the Haverfield Estate seen in the right hand side of this view. The proposals would differ from the tower, however, in being much closer to the palace, and forming a wall of development as perceived from this position.

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Views 12 and 13 (above, proposed) are, as existing, excellent examples of the value of the 'Arcadian Thames'. They show a verdant environment, heavily treed, with the appearance of a natural, un-embanked, riverine context. The impact of the proposals in both summer and winter views is immediately clear: it will surpass the tree-line in height and introduce tall, solid, modern blocks into views otherwise defined by a consistent arboreal, riverine quality. These views are major contributors to the Kew

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Green conservation area, help to define the buffer zone of the World Heritage Site, and characterise the sense of an 'Arcadian Thames' which forms an attribute of the World Heritage Site's Outstanding Universal Value.

We consider the visibility of the proposals to be harmful to the setting of Kew Palace, Kew Gardens, and the Arcadian Thames. These are all related, and the environment within which they are appreciated is therefore highly sensitive. The complexity of these relationships is shown in the attributes of Outstanding Universal Value identified in the World Heritage Site Management Plan: the green environs, the Arcadian Thames, and the evidence of royal residence.

As a result of the size of the proposed buildings there will be a degree of visibility in the setting of the Palace and Gardens that ultimately compromises the quality of the environment around the World Heritage Site. The ease with which it is possible at present to understand the appeal of Kew’s parkland setting to its early patrons will be undermined if this proposal is constructed. This picks apart at the fabric of Kew’s significance and its attributes of Outstanding Universal Value. In our view this is a very serious degree of harm that will be apparent on a world stage. The necessary delivery of public benefits required to justify this harm in the terms of the NPPF would need to be clear, convincing, and very great.

The planning application seeks to combine the benefits of an associated scheme at the former police station in central Brentford to justify any harm caused by the development at Albany Riverside. The ‘heritage benefits’ cited in justification include the removal of the police station building, the improvement of the river side path, the construction of ‘high quality’ buildings, and the creation of a public art work. In our view these are not standard heritage benefits as set out in Planning Policy Guidance, and are minor changes which might be expected of any development brought forward at these sites.

Historic England is not in a position to assess in detail the other public benefits attributed to these proposals, such as the provision of new retail and residential accommodation, and the relocation of the Watermans Arts Centre. However, we would question whether the extent of harm proposed is necessary in order to achieve these aims, and whether their desirability is sufficient to outweigh the substantial public interest in the preservation of the World Heritage Site at Kew.

Recommendation We consider the proposals to cause serious harm to the significance of heritage assets of the highest possible designations. The severity of this impact is a departure from the principles and policies of the NPPF and cannot be considered to be sustainable development. We are not convinced that such harm is necessary to regenerate the site successfully and bring about wider public benefits, though we support the pursuit of those aims.

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We also believe that the proposals are contrary to the Planning (Listed Buildings and Conservation Areas) Act 1990 which requires Local Planning Authorities to have special regard to the desirability of preserving listed buildings or their setting (Section 66) and to pay special attention to the desirability of preserving or enhancing the character or appearance of a conservation area (Section 72).

As such Historic England opposes this application in the strongest possible terms.

Please contact me if we can be of further assistance. We would be grateful to receive a copy of the decision notice in due course. This will help us to monitor actions related to changes to historic places.

Please note that this response relates to historic building and historic area matters only. If there are any archaeological implications to the proposals it is recommended that you contact the Greater London Archaeological Advisory Service for further advice (Tel: 020 7973 3712).

Yours sincerely

Matthew Cooper Inspector of Historic Buildings and Areas E-mail: [email protected] cc Shane Baker, London Borough of Hounslow Sean Doran, London Borough of Hounslow Mike Dunn, Historic England Tom Horne, DP9 David Holroyd, Kew Gardens

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