blog by Philip Grant, in a personal capacity
in February, I first wrote about the 1 Morland Gardens planning application (Housing
or Heritage? Or both?), under which Brent Council propose to
demolish a locally listed Victorian villa in Stonebridge, to build a new adult
education college and 65 affordable homes on the site.
2 Morland Gardens (not No. 1) - this is the "twin" Victorian villa. (Photo by Harry Brown)
of some defects in the original application, identified from “consultee
comments”, a new batch of plans and documents has recently been submitted. Public
consultation is now open again on application 20/0345, until Thursday 16 July.
One of the new documents is a Heritage Impact Assessment (“HIA”) [see copy below], and this is what raises the
important question in my title.
listed buildings are those which have been identified by a Council as “heritage
assets”. “Significance” for planning
purposes is defined 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.”
planning policies (like national ones, and the London Plan), acknowledge the
importance of heritage assets, and set out how they should be protected when
there are any proposals affecting them. The policy states: ‘The council will
resist significant harm to or loss of heritage assets.’ Anyone considering
a development should start with ‘an understanding of the architectural or
historic significance of the heritage asset and its wider context.’
is capable of doing this, as the current application for the locally listed
Clock Cottage at Kenton Grange shows. Those plans conserve the old cottage,
while building assisted-living flats for disabled people around a courtyard
(former stables) behind it. Unfortunately, whoever was giving planning advice,
to the Council Officers / Lead Member for the 1 Morland Gardens scheme, either did
not understand the policies over heritage assets, or thought they could be
ignored (because it was a Council scheme, Planning Committee would “rubber
When the original application was submitted in February, Brent's
planning agents claimed that the locally listed Victorian villa had
'minimal significance', without providing much evidence to support that, and
ignoring existing evidence (such as Brent's existing local listing assessment,
which gave it a significance score of 8 out of 12). Local historians knew this
was nonsense, and launched a campaign to save the building (originally known as
“Altamira”)’. Their petition, asking the Council not to demolish the building,
achieved 368 signatures.
the "Brent & Kilburn Times", 5 March 2020.
I submitted my objection comments in
early March, explaining in detail why the application’s assessment of heritage
significance was false, and recommending that Planning Officers should advise
their Council colleagues to withdraw the application. This appeared to have no
In April, a copy of the comments
on the application by Brent's Principal Heritage Officer was obtained. He said that 1 Morland Gardens 'should be considered
an important local heritage asset of high significance.' He also pointed
out that the applicants (Brent Council) had not provided a proper appraisal of
the heritage asset, and the impact of their proposals on it, as required by
Brent's own planning policies, and said 'the applicants should seek further
advice from a heritage specialist to gather further evidence in support of this
The June 2020 HIA is in response to
the Principal Heritage Officer’s comments. The document was prepared on the
Council's behalf by Messrs Lichfields, who describe themselves as 'the
pre-eminent planning and development consultancy in the UK.' Lichfields report
was prepared by heritage specialists, but they were aware why their client
(planning agents, acting on behalf of Brent Council) needed that report, at
such a late stage in the planning process - to support their planned demolition
of the building!
In the introduction to their report,
Lichfields make clear that: 'The overview of the significance of the heritage
assets has been undertaken using a combination of desk-based study and archival
research.' They go on to say that: 'Fieldwork was not possible due to the
current Covid-19 situation.' In other words, they only looked at a limited
number of documents, and did not come to look at the building, its setting or
the surrounding area.
Despite the limited material
available to them, they reached the conclusion: 'the building is of low
significance’. Explaining how they reached this conclusion, their report
says: ‘The methodology for our assessment of significance draws from the NPPF,
HE’s Conservation Principles and the DMRB.’ The table they show for the
criteria used is taken from the DMRB, and their conclusion is also: ‘In summary
and according to DMRB significance criteria (set out in Section 1), the
building is of low significance as it is of low historic and
architectural importance and of local interest only.’
DMRB? No, I hadn’t heard of it
either. It is actually the Design
Manual for Roads and Bridges, issued by Highways England in 2019,
as guidance for designing national infrastructure projects such as trunk roads
and motorways. Your guess, as to why the HIA used those criteria, may be
similar to mine – to get the “right” result for their client! Why not use
Brent’s own significance scoring criteria for locally listed buildings, which
was adopted by the Council’s Planning Committee in July 2015?
The HIA does refer to that system,
claiming that the significance score for 1 Morland Gardens should be 6 out of
12, rather than the 8 out of 12 given to it for its entry in Brent’s local
list. I will explain why I believe they are wrong.
One of the “sources” their desk-based
assessment used for considering the historic development of the area was a “Brief
History of Stonebridge”, produced by the Grange Museum and
Brent Archives. The author of that booklet has already submitted an objection
comment, pointing out that a quotation used from it was taken out of context.
The HIA had used ‘it was never as
grandiose as its planners had originally intended’ to play down the importance
of the 1876 Stonebridge Park development. The author had actually compared the
smart villas built to the scene originally
envisaged in a lithograph by the architect.
Junior's lithograph of his proposed estate development, c.1872. (Brent Archives image 1776)
The HIA devotes just eight lines to
assessing the historic significance of 1 Morland Gardens, before marking down
its score to just 1 out of 3. The author of the booklet, who became an expert
on the local history of Brent in his 17 years at our Museum and Archives, has
made clear that this assessment is totally flawed. Its key statements are that
Stonebridge Park ‘was typical of the late-19th century suburban expansion of
London,’ and that ‘1 Morland Gardens
is not a rare survival, but typical of the eclectic late-Victorian villas seen
across Brent. Therefore, the historic significance of the building is
considered to be lower than originally assessed, scoring 1/3.'
to Stonebridge Park from Hillside, c.1905. (Brent
Archives online image 7914)
The 1876 development, was the first
housing development in this part of Willesden, and gave its name to the
Stonebridge Park area. It was built when Willesden’s population was around
25,000, before the massive late-Victorian influx that saw most of the
area’s mainly working-class housing constructed, and the population rise to
114,000 by 1901. Added to this, 1 and 2 Morland Gardens are the only two
surviving Italianate-style villas in Brent, so they are rare survivals.
Any change to the existing historic significance score should be up to 3/3, not
down to 1/3.
1 and 2
Morland Gardens from Hillside, February 2020.
The other significance criteria that
the HIA seeks to mark the building down on is its authenticity.
Because it ceased to be a private
house 100 years ago, and has undergone internal alterations several times since
then, Lichfields argue that the building is ‘much altered’, and therefore only
worth 1/3. But the alterations had already been taken into account when Brent
scored it 2 out of 3. It is the authentic Victorian outside appearance of the
villa, in its setting with the similarly styled 2 Morland Gardens, which has
hardly changed since they were built, which makes them so valuable and
significant. Just compare the two views above, taken 115 years apart!
If you agree that the Victorian villa
at 1 Morland Gardens has a high significance, not a low one, and that it still
has value to this and future generations, then I hope you will help to persuade
Brent Council that it should not be demolished. The planning application,
20/0345, is open for public consultation again, and you can submit your
comments (hopefully objecting to the plans to demolish “Altamira”) on the planning
Significance is significant.
We can try to ensure that the true significance of this building is what
decides the planning application, not the false appraisal of it presented in
the Heritage Impact Assessment!
THE HERITAGE IMPACT ASSESSMENT