Land North of Pound Lane, Lpa: 16/05783/Out Pins: App/Y3940/W/16/3162997
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THE RICHBOROUGH ESTATES PARTNERSHIP LLP CO-JOINED SECTION 78 APPEALS, SEMINGTON, WILTSHIRE RICHBOROUGH ESTATES APPEAL: LAND NORTH OF POUND LANE, LPA: 16/05783/OUT PINS: APP/Y3940/W/16/3162997 OXFORD LAW APPEAL: LAND NORTH OF ST GEORGE’S ROAD LPA: 16/06956/OUT PINS: APP/Y3940/W/16/3164255 DR CHRIS MIELE MRTPI IHBC PROOF OF EVIDENCE RE. HERITAGE MATTERS MAY 2017 LAND NORTH OF POUND LANE, SEMINGTON CHRIS MIELE PROOF OF EVIDENCE RE HERTIAGE MATTERS CONTENTS Section Page No. 1.0 Introduction 1 2.0 Instructions and Scope of the Statement 6 3.0 Statutory Provision and Planning Policy Considerations 10 4.0 Historic Development of Semington 25 5.0 The Significance of Semington Aqueduct, Former St George’s Hospital and WWII Structures 28 6.0 Comparative Assessment of the Sites 51 7.0 Performance Against Policy 64 8.0 Signed Affirmation 66 APPENDICES (bound separately) 1 Heritage Asset Map (1) 2 List Descriptions (3) 3 The ‘Barnwell Decision’ (16) 4 The ‘Forge Field’ Decision (34) 5 The ‘Forest of Dean’ Decision (57) 6 The ‘Palmer’ Decision (81) 7 GPA3: the Setting of Heritage Assets (Historic England, March 2015, republished July 2015) (93) 8 Historic maps (112) 9 Heritage Collective, Land north of Pound Lane, Semington. Heritage Statement of Case prepared on behalf of Oxford Law, April 2017 (117) 10 Biography of Henry Edward Kendall by James Stevens Curl in Oxford Dictionary of National Biography, September 2004 (143) 11 Historical accounts of Semington Workhouse by Peter Higginbotham and Liz Corfield (Wiltshire OPC Project) (145) 12 Historic England, Listing Selection Guide. Transport Buildings (2015) (161) Shared Heritage, Landscape and Visual Appendix: Photographic Volume (bound in separate volume) LAND NORTH OF POUND LANE, SEMINGTON 1 CHRIS MIELE PROOF OF EVIDENCE RE HERITAGE MATTERS 1.0 INTRODUCTION 1.1 My name is Chris Miele and I am a senior and owning Partner at Montagu Evans’ central London office. I am a Chartered Town Planner and a Member of the Institute of Historic Building Conservation. I have twenty-five years professional experience as a specialist in heritage matters and also hold advanced academic qualifications in architectural and urban history. Our Practice 1.2 Montagu Evans is a leading firm of chartered surveyors. Established in 1921, we 21 owning partners employ nearly 300. I work in our West End offices, which are the registered office of the LLP. 1.3 We provide all areas of development surveying consultancy, from rating and valuation to management and investment advice. The town planning consultancy has always been central to our business, and it is provided through our Planning and Development Department. Professional Background: Some Current Projects and Clients 1.4 As a partner in the Planning and Development department I provide specialist advice on sites that involve development in the historic environment and sensitive landscapes. There I run a team of experts who work on heritage-based projects of all kinds, involving highly graded listed buildings, World Heritage Sites, Scheduled Monuments and sensitive land (conservation areas, Registered Parks, MOL, Green Belt, AONBs). I have worked on many housing schemes, large and small, which affect heritage assets directly or indirectly. I have advised on development affecting historic engineering structures and historic hospitals and workhouses, which I mention here because those asset classes are treated in my evidence in support of the Appellant. LAND NORTH OF POUND LANE, SEMINGTON 2 CHRIS MIELE PROOF OF EVIDENCE RE HERITAGE MATTERS 1.5 I act regularly as an independent expert witness on planning appeals and call-in inquiries. I am aware of the duties of expert planning witnesses. I work to the RTPI Code of Conduct for chartered planners at appeals (see signed affirmation at the conclusion of this Proof). My Evidence is also prepared in accordance with the March 2016 guidance on planning appeals, Annexe O, ‘What is expert evidence?’ 1.6 My public and charitable clients have included the Royal Shakespeare Company, the Trustees of the Victoria and Albert and Natural History Museums in London, English Heritage, the Oxford Colleges (Magdalen, Keble and Exeter), University College London, Keele University, Middlesex University, Transport for London, the City of Westminster, and Southern Water. I have also worked for the Greater London Authority, first on the preparation of the London View Management Framework 2007 edition (SPG to the then London Plan), and on the redesign of Parliament Square, which bounds the Westminster World Heritage Site. 1.7 This is in addition to the advisory work I do to support development work undertaken by major cultural institutions, notably the British Museum and South Bank Centre. I advise the Universities of Leicester and Sheffield on a range of projects, along with other notable educational institutions (Sussex, Durham, and Oxford). 1.8 Over the last five years I have become more involved in large housing schemes and town extensions as well as the promotion of land for housing allocations through the local plan. My clients include major national housebuilders: Commercial Estates Group, City and Country, Hallam Land, Wates, Bloor, Berkeley, Barratt’s, Fairview New Homes, Barwood Land and Estates, Barratt’s, Taylor Wimpey, and Gladman. This is my first instruction with Richborough Estates. 1.9 I have no other current instructions with the Appellant. I describe my involvement in further detail in the next section. LAND NORTH OF POUND LANE, SEMINGTON 3 CHRIS MIELE PROOF OF EVIDENCE RE HERITAGE MATTERS Other Relevant Experience, including CABE, Select Committee Advice and English Heritage Advice 1.10 I draw to the Inspector’s attention other relevant experience, notably my work as a panel member on the National Design Review Panel of the Commission for Architecture and the Built Environment or ‘CABE’ from 2003 to end 2007. 1.11 I have previously acted as professional advisor to the ODPM Select Committee on Heritage and Regeneration and in this capacity contributed to the Committee’s report and recommendations on that subject (2005). I have also served as an external member on English Heritage’s Research and Standards Committee. Past Employment 1.12 Formerly I was Senior Planning Director at RPS Planning central London office, and before that, from 1998 to 2004, a Director at Alan Baxter & Associates, a multi- disciplinary consultancy based in engineering. 1.13 From 1991 to 1998 I was employed by English Heritage (now Historic England), providing advice in support of its statutory functions. I should add here, because it is relevant to the facts of this case, that I trained at EH as a listing inspector (as we were called then), and continued to contribute to listing casework from time to time where the matter at hand reflected my particular expertise. I continue to represent clients in designation matters. Thus I consider myself particularly qualified to comment on the extent of the listing as it pertains to the Aqueduct – that is the basis of OL’s criticism of RE’s proposals, as I will explain further in section 5.0. Academic Qualifications and Credentials/Publications 1.14 Before settling in the United Kingdom, and whilst completing my masters and doctoral work, I held several academic and museum appointments, at Columbia University, LAND NORTH OF POUND LANE, SEMINGTON 4 CHRIS MIELE PROOF OF EVIDENCE RE HERITAGE MATTERS New York University, the Metropolitan Museum of Art and Museum of Modern Art, all in New York. 1.15 I hold an Honours Degree (BA) in the history of architecture and planning from Columbia College, Columbia University in the City of New York, and post-graduate degrees – an MA and a PhD – in this subject area from the Graduate School of Arts and Sciences, New York University. I latterly studied town and country planning at South Bank University. 1.16 I have an extensive record of academic and professional publications. This includes editing a volume of essays in Yale University Press’ Studies in British Art series, on the history and philosophy of the conservation movement in this country. In April 2010 Merrell published my book on the new UK Supreme Court, a Grade II* listed Edwardian building on Parliament Square. I contributed to and designed this commercial publication for the Ministry of Justice and UK Supreme Court. 1.17 English Heritage published a book I wrote jointly with a former colleague, on C18 architecture. I am currently working on a biography of the Victorian architect George Gilbert Scott. I have published articles recently on him along with other historical publications (currently an essay for a collection of articles on the C19 century design William Morris). 1.18 I am invited to review books and articles in my special subject area, and have been a referee for proposals put to the British Academy on architectural-heritage topics in addition to reviewing proposals to the AHRC. This is in addition to regular lectures at professional and academic conferences in the UK, USA and in Europe. I have also served on the management committee of the William Morris Society, and I am recently appointed as chairperson to the Board of the post-graduate Centre for Urban History, Leicester University. LAND NORTH OF POUND LANE, SEMINGTON 5 CHRIS MIELE PROOF OF EVIDENCE RE HERITAGE MATTERS 1.19 In recognition of my scholarly achievements I have been elected a Fellow of the Royal Historical Society (2001) and of the Society of Antiquaries, London (2000). 1.20 I was additionally a trustee of two historic houses in London (including one of Elizabethan date) and for several years chaired a conservation area advisory committee in my local London area. 1.21 I set out this academic background because I consider it goes to the weight to be attributed to my Evidence about the significance of the heritage assets under discussion.