Dear Mr Studdert
OPEN LETTER TO PETER STUDDERT
CHAIR LLDC QUALITY REVIEW PANEL
11 December 2014
Planning Application No. 14/00262/FUL
Swan Wharf, E3 2NQ
We have read the report of your meeting about Swan Wharf and were surprised to note that, apart from yourself, there were only two other members of the panel present at the meeting on 12 September 2014.
Throughout the report there are references to the â€œthree-storey extensionâ€ on the existing three-storey stable block. There is even a reference to the proposed workspace being provided in the â€œexisting stable building". The applicants drawings clearly indicate that the existing stable block is to be demolished (apart from two outer walls) and replaced by a new and wider six-storey building.
In its letter of 8 September 2014, English Heritage describes the demolition as "substantial" and clearly objects to the loss of the heritage asset. English Heritage also comments on the harm to the conservation area caused by the loss of the building; and the unacceptable visual competition between the "ï¬ne Edwardian detailingâ€ of the two retained outer walls and the large windows and timber cladding of the upper three storeys of the proposed new six-storey building.
English Heritage â€œwould welcome the opportunity to discuss an alternative scheme that... seeks to retain the heritage asset..." This offer was not included in the reportâ€™s section on English Heritageâ€™s views. in this context, we have to point out that a height reduction of the so-called â€œextension" to two-stories would fail to address English Heritage's advice that the three-storey Edwardian stable block is retained in the Fish Island and White Post Lane Conservation Area.
Although the multi-storey stable block at Swan Wharf has lost its external horse ramps, it is probably the finest of the few surviving examples in London. Finer indeed, than the Grade ll-listed three-storey example at Kingsland Basin, which only has â€˜small stable windowsâ€™ in its first and second storeys and, overall, has less special architectural and historic interest than the stable block at Swan Wharf. Nevertheless, it has been retained and minimally adapted in an exemplary development by London & Quadrant (see EEWGâ€™s second letter of objection dated 8 September 2014).
The proposed wider six-storey building, on the site of the substantially demolished three-storey stable block and part of the yard at Swan Wharf, is a new building. it is therefore within the remit of the QRP to comment on its quality as a new building.
We note, speciï¬cally, that the panel stated that the scheme has â€œmuch to recommend it in terms of the quality of architecture proposed". However, in relation to the advice from English Heritage, this cannot outweigh the loss of the heritage asset and the harm to the conservation area. We must also point out that an alternative conservation-led scheme would be perfectly capable of providing â€œa welcome mix of residential and workspace accommodation, with a cafÃ© on the ground floor facing the canalâ€.
As most of the QRP members are architects and consultants specialising in new buildings, rather than the repair and adaptation of historic buildings, it should not, in our opinion, be asked to comment on applications such as Swan Wharf. It seems to us that there is an urgent need for the LLDC to set up a Conservation Review Panel (CRP) for the four conservation areas within the Legacy Corporation Area. And that further consideration of the Swan Wharf and Wallis Road applications (and other conservation area applications) should be postponed until the CRP has been established and commented on such applications.
In support of these suggestions, we would refer to the publication version of the LLDC Local Plan 2015-2031 (submitted 21 November 2014 to the Secretary of State with minor amendments and corrections); specifically, with respect to Sub Area 1 and the area priorities set out in 10.3 and their embodiment in the following policies:
POLICY 1.1.3: Restore and reuse buildings of heritage value for employment uses;
POLICY 1.2.2: Enhance existing yards;
POLICY 1.4.1 - 1.4.3: Concerning proposals for development within the boundary or immediate setting of heritage assets.
Clearly, the existing Edwardian stable block at Swan Wharf should be minimally adapted for "creative and cultural industrial uses" and not residential uses. Also, development at Swan Wharf should have regard to retaining and enhancing the existing yard; and that any new building in the yard should be carefully designed along the lines set out in policy 1.4 to respect four heritage assets: the existing three-storey stable block and its 1960s extension, the adjacent Forge building at Crown Wharf, Old Ford Locks and the "Lee Navigationâ€, The latter includes the part of the River Lea next to Swan Wharf and the Hackney Cut (including heritage asset Old Ford Locks). It was the inclusion of the river and locks in the LLDCâ€™s extended conservation area which made Swan Wharf and its wider setting the most attractive part of the Fish island and White Post Lane Conservation Area.
The Local Plan has been submitted to the Secretary of State and whilst it has to be examined in public and adopted, it is clearly an emerging plan and is, therefore, a material consideration in the determination of this application. Failure to comply with policies 1.1.3, 1.2.2, and 1.41 to 1.43 would constitute additional reasons for refusal.
We also note that the Planning Authority is concerned about the lack of affordable housing. With respect to policy 1.1.3, may we take this opportunity to record our expectation that the restored and reused three-storey stable block is only used for creative and cultural industries (as at present) and is not used for affordable or any other sort of housing.
Destroying the character of the conservation area for the sake of 46 residential units is completely unnecessary. There is extensive development planned for the surrounding area which will more than satisfy its housing requirements, a significant proportion of which will be affordable housing; along with new public green spaces and commercial / creative workspace for various employment uses.
Following are approximate numbers of residential units planned at just a few of these sites:
- Neptune Wharf (522)
- McGrath site / Hepscott Road (500)
- Bream Street / Dace Road opposite Swan Wharf (230)
- Monier Road (122)
In fact, the eastern part of the McGrath site is in the Fish Island and White Post Lane Conservation Area and the proposals for the development of the McGrath site include the retention and adaptation of three locally-listed industrial buildings; and the retention and adaptation of an existing industrial building just outside the boundary of the conservation area.
Over seventy individual objections to PA 14/00262/FUL have been lodged, including representations from prominent organisations such as:
In addition, the â€œ700 signature petition" has now exceeded 1,000 signatures.
- English Heritage
- The Victorian Society
- East End Waterway Group
- Greater London Industrial Archaeology Society
- The Hackney Wick and Fish Island Planning and Development Unit
- The East End Preservation Society
- Heritage of London Trust
- SAVE Britainâ€™s Heritage
With respect to the Local Plan and the November 2014 Conservation Area Appraisals, we note that the â€œlocally-listed buildings" and most of the â€œbuildings of townscape meritâ€ identified in the January 2014 conservation area appraisals are now being referred to as â€œheritage assetsâ€. All the heritage assets in the extended Fish Island Conservation Area and the extended Hackney Wick Conservation Area are â€œsignificant... and every effort should be made to preserve or enhance them, as they contribute positively to the character and appearance of the conservation areaâ€œ.
Furthermore, all the buildings in the Dace Road cluster 'â€˜...form a coherent and complimentary group of medium to high heritage significanceâ€. (Fish island and White Post Lane Conservation Area Appraisal November 2014). This means that the heritage assets at Swan Wharf and Crown Wharf are of regional to national significance which suggests...â€ that each asset could be a candidate for statutory listing."(Fish Island and White Post Lane Conservation Area Appraisal January 2014). The medium to high significance of the non-designated heritage asset at Swan Wharf would be substantially harmed by the proposed development; and NPPF Section 134 requires the Legacy Corporation to make a â€œbalanced judgementâ€, which, in this case, can only result in refusal. Especially as the proposed development would also cause substantial harm or loss to the designated heritage asset, namely the Fish island and White Post Lane Conservation Area. And, it has not been "demonstrated that the substantial harm or loss is necessary to achieve substantial benefits that outweigh the harm or lossâ€ (NPPF Section 133). Nor do this Sectionâ€™s four alternative requirements apply:
- The nature of the asset does not prevent all reasonable uses of the site
- The asset is currently and fully in appropriate employment use, demonstrating that there are uses that will â€œenable its conservationâ€
- Conservation by grant-funding, etc. not applicable
- Most of the site, in conformity with area priorities and policies as set out in the Local Plan, is currently and fully in appropriate employment use
Finally, we understand that the applicant is making amendments to PA 14/00262/FUL, with a view to it being determined by the Development Committee in the New Year. Given all the reasons set out in this open letter and the English Heritage letter and other letters of objection, we think the LLDC should ask the applicant to withdraw PA 14/00262/FUL; and encourage the applicant to come forward with an alternative scheme, as advised by English Heritage.
For and on behalf of East End Waterway Group