Following on from his recent guest
blog, “How
Significant is Significance”, Philip Grant has sent the
following “Open Email”:-
To: Carolyn Downs, Chief Executive, and
Cllr. Muhammed Butt, Council Leader,
London Borough of Brent.
Cllr. Muhammed Butt, Council Leader,
London Borough of Brent.
19 July 2020
This
is an open email
Dear Ms Downs and Councillor Butt,
Brent Council planning
application 20/0345 – 1 Morland Gardens, Stonebridge, NW10
You may have noticed a letter
I wrote, which was published in the “Brent & Kilburn Times” on Thursday 16
July.
The letter’s heading in the
newspaper was ‘Altamira’ (the original name of the locally listed Victorian
villa which the Council seeks to demolish), but my suggested heading was ‘Let's be honest about 1 Morland Gardens’. That is what I intend to be here.
A version
of the published letter has appeared on the “Kilburn Times” website today, but
this omits the final paragraph as it appeared in print (full text below, for
ease of reference). That paragraph said:
‘there
is still time for Brent Council to withdraw this application, and consult on
redevelopment which would see the Victorian villa at 1 Morland Gardens
retained, and converted to provide affordable homes for Brent residents who
need them.’
I
am writing to recommend to you both, as the Council’s top officer and leading
elected representative, that Brent Council does withdraw application 20/0345,
as the only reasonable action in the circumstances of this matter.
I realise that investment of
up to £43million for the proposed scheme at 1 Morland Gardens was approved by Cabinet
in January this year, subject to planning approval. That planning approval is
the key issue here.
Although
those behind this scheme commissioned a “Historic Building Assessment” of the
locally listed Victorian villa in April 2019, that document only recorded the
history of the building and its current state. It did not ‘demonstrate a clear
understanding of the archaeological, architectural or historic significance’ of
1 Morland Gardens, which is what is required before a planning
application affecting a heritage asset is put forward.
As
I said in my published letter: ‘if the Council had properly considered the
heritage importance of this building in the first place, they would never have
suggested demolishing it.’ In trying to remedy the situation, after this had
been pointed out by the planning Case Officer in April, a consultant firm was
appointed to prepare a ”Heritage Impact Assessment” (HIA) on behalf of the
Council (as applicant), which was submitted last month.
I
have publicly referred to that report’s conclusion as a ‘false “low
significance” assessment’. I know that is a serious charge to make, but I
believe it is fully supported by the detailed objection comments I submitted on
5 July (a copy is attached, for information). In reality, the building has
"high significance", which means that Brent's planning policies
require the building to be retained as part of any sympathetic redevelopment of
this site.
My
letter refers to the senior officers and councillors proposing the 1 Morland
Gardens scheme, and asks: ‘Do they really intend to use the HIA, seeking to
deceive Brent’s planning committee into approving a planning application which
they should really reject?’ I put the same question to you, and look
forward to receiving your answer in the near future.
There
is a precedent for Brent Council withdrawing a planning application which
proposed the demolition of an important locally listed building. This happened
in 2012, just before the application (made in the name of its development
partner) seeking to demolish the remaining Victorian section of Willesden Green
Library was due to go to Planning Committee. The reason given was ‘to allow for
further consultation’.
If
you have any doubts that withdrawing the Council’s planning application is the
right thing to do, let me draw your attention to a key paragraph (4.1) of the
May 2019 Strategy document:
‘The
value of Brent’s heritage should not be underestimated and is a key message of
the Historic Environment Place-making Strategy.
Once a heritage asset is demolished it cannot be replaced. Its historic value is lost forever to the
community and future generations and it cannot be used for regeneration and
place-making purposes. The effective
preservation of historic buildings, places and landscapes and their stewardship
is therefore fundamental to the Council’s role.’
If
Brent Council goes ahead with application 20/0345, and somehow manages to get
it approved, it will not only cause the loss of this important locally listed
heritage asset. It would seriously damage Brent Council’s reputation, and would
set a precedent that would put every other heritage asset in Brent at risk of
demolition. I hope that you will not allow that to happen.
Yours
sincerely,
Philip
Grant.
Text of my letter, as
published in the “Brent & Kilburn Times” on 16 July 2020:
‘Altamira
On
Brent’s planning application to demolish the locally listed Victorian villa at
1 Morland Gardens in Stonebridge, and replace it with a new college and homes -
if the council had properly considered the heritage importance of this building
in the first place, they would never have suggested demolishing it.
The
application could not proceed in April because it had not shown a clear
understanding of this heritage asset’s significance (its value), or shown why
the benefits of the proposal outweighed the harm to that heritage importance.
That is why a heritage impact assessment (HIA) was submitted last month, and
there is further consultation.
The
HIA was prepared by a reputable firm of planning consultants, but it was a
desk-based assessment. Some of the information they based their findings on has
been shown to be incorrect.
They
also used the Design Manual for Roads and Bridges as the main criteria for
assessing the building’s significance, rather than the system adopted by Brent
for evaluating its locally listed heritage assets. On that basis, the HIA
concluded that the Victorian villa was of “low significance”.
This
just happens to be the only opinion which would justify the demolition under
Brent’s planning policies for heritage assets.
Brent’s
own principal heritage officer has said that 1 Morland Gardens “should be
considered an important local heritage asset of high significance”. This is
based on Brent’s scoring system, and is backed up by evidence submitted by The
Victorian Society, a professor of architectural history and a long-serving
expert at Brent Museum & Archives, as well as a number of other local
historians and many local residents. 368 residents have signed a petition
against the demolition.
The
senior officers and councillors proposing this scheme are meant to serve the
people of Brent with honesty and integrity. The false “low significance”
assessment has been made on their behalf. Do they really
intend to use the HIA, seeking to deceive Brent’s planning committee into
approving a planning application which they should really reject?
Comments
close today (July 16) on application 20/0345, but there is still time for Brent
Council to withdraw this application, and consult on redevelopment which would
see the Victorian villa at 1 Morland Gardens retained, and converted to provide
affordable homes for Brent residents who need them.’
Philip Grant's original objection comment on the application:
2 comments:
On Monday morning, I received a promising acknowledgement of my open email from Carolyn Downs office:
'Carolyn is aware of the concerns you’ve raised and has asked ...... to look into the matter. You will receive a response as soon as possible.'
On Tuesday morning, I received an acknowledgement from the "Office of the Leader":
'Your enquiry has been forwarded to the respective department, who will look into the issue and make every effort to resolve it.'
Ten minutes later, I was sent an email from Brent's Head of Planning (who as part of Brent as Local Planning Authority is meant to be "at arms length" from the London Borough of Brent as applicant in this case!).
He referred to my open email, thanked me for drawing my letter in the local newspaper to his attention, and told me that my objection would be considered and summarised in the Officer Report when the application goes to Planning Committee (probably on 12 August).
You will probably understand why I have "replied" to that by writing again to Carolyn Downs and Cllr. Butt, asking for a reply to my actual open email, from a senior representative of Brent as the "person" applying to demolish the locally listed heritage building at 1 Morland Gardens.
FOR INFORMATION:
This morning I received (from "The Office of the Leader") a letter from Amar Dave (Strategic Director, Regeneration and Environment), in reply to my open email of 19 July, on behalf of Brent Council as applicant in this case (20/0345). He replied to all the points I had raised, and I will summarise his long letter below.
He said that the architectural and historic significance of the Victorian villa had been understood at an early stage of the planning process, saying: 'The assessment was reviewed by planners following submission and we were informed that it was a very thorough assessment of the condition of the historic building.' - My response to this would be that if their assessment had demonstrated a proper understanding of the building's significance, they would not have been asked to provide on, several months after their original application was submitted!
He did not agree my assertion that 65 homes, a new education centre and affordable workspace was an overdevelopment of this small site, saying: 'Further, the results of our option appraisal and public consultation within the locality showed significant need for these facilities in Stonebridge.'
In response to my assertion that the "low significance" assessment was false, he said: 'This report provided an independent assessment of the significance of the locally listed building.' He also said: 'The validity of the HIA has been confirmed by the Planning Officers.' - My response would be that, despite what the Planning officers might have said, the Council's Principal Heritage Officer has rejected the HIA's claim that the significance score should be reduced from 8 out of 12 to only 6 out of 12.
In response to my question of whether the Officers and councillors proposing this scheme 'really intend to use the HIA, seeking to deceive Brent’s planning committee into approving a planning application which they should really reject?’ Mr Dave has said: 'The HIA is part of the suite of planning documents to be assessed by officers, and considered by the Planning Committee. This will include in the report the assessment of the Council’s own Principal Heritage Officer. The Committee will be able to come to their own judgement on the significance of the building, and will balance this against all other aspects of the scheme.'
He has also said: 'We do not accept your assertion that a decision as either landowner, or as a planning authority, to agree this scheme would put "every other heritage asset in Brent at risk of demolition".'
The Council does not intend to withdraw its planning application.
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