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. Planning appeal: Chiswick Curve © Grover Lewis Associates Ltd. Proof of evidence: Philip Grover – Design & Heritage matters May 2018 2 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. Planning appeal: Chiswick Curve © Grover Lewis Associates Ltd. Proof of evidence: Philip Grover – Design & Heritage matters May 2018 3 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 Planning appeal: Chiswick Curve © Grover Lewis Associates Ltd. Proof of evidence: Philip Grover – Design & Heritage matters May 2018 4 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