ࡱ> wyv @ ,bjbjʚʚ .Sjjjjjjj~DL~q,P+++++++$-R0j+]j&&&+jj+,x*x*x*&jj+x*&+x*x*jjx* AN'Bx**A,0q,x*}0(}0x*~~jjjjx*}0j*PFdx*(,"++~~n* ~~Mr Brian Russ. Special ProjectsDirect Dial: 01483 252040Gravesham Borough CouncilPlanning ServicesDirect Fax: 01483 252001Civic CentreWindmill St.Your reference:Gravesnd HQtr GRAVESEND Kent DA12 1AUOur reference: JR/GS GHer Qtr. P00064922 18th November 2008  Dear Brian, Heritage Quarter- Gravesend Town Centre - Proposed Development. I write with regard to the above planning application and to follow up our recent informal discussions. English Heritage comments as follows on the application. Summary Whilst we welcome some of the changes made to create improvements on the eastern side of the scheme, our major concerns remain, primarily regarding the proposed tall building, and also the area surrounding the church. The tall building proposal in particular, is not development plan led, is not considered an exceptional design and is wholly out of context with the prevailing character of Gravesends Heritage Quarter. It will overtly dominate Gravesend, having an overbearing effect on the Heritage Quarter and thus the features identified as historic assets in the design statement and by the design brief. It will adversely effect the setting of key historic buildings and moreover the historic context of the conservation area and its individual heritage assets, including significant relationships to Gravesends defensive heritage. In short, we consider the proposals detrimental to Gravesends historic sense of place. Detailed Advice. The towns Heritage Quarter has considerable significance. This includes the inter relationship between Gravesends historic urban core, the riverside, the Thames itself and Tilbury fort. The blockhouse remains and New Tavern Fort (both scheduled monuments) and the Town and Royal piers (including the approach to Gravesend from the Thames) bear testament to the origins of the town for riverside defence and trade. The surviving historic fabric of the towns core from the late C17th to the early 20th century essentially provide the basis for the prevailing built form of the town. The focal point in the historic core of the town has, for over 300 years been St Georges Church adjacent to the heart of the High Street. The heritage values of Gravesend (see English Heritages publication Conservation Principles) not only include the evidential values of the above buildings but also the potential to yield further evidence as a result of archaeological investigation of the development of the town. There are also historic values that illustrate the development of the place as a riverside settlement and its changing fortunes. The surviving defence heritage of Gravesend is a significant example of its kind indicating how the town established an early role in protecting the Thames and thus the passage to London in the C16th. With Tilbury fort and the Milton blockhouse, the site of the Henrician Gravesend blockhouse illustrates this historic role. The Clarendon hotel nearby, has its origins in the mid C17 for the use of the Duke of York, then Lord High Admiral. The towns defensive role continued with the construction of New Tavern Fort in the later 18th Century. Historic images show the construction of the gun emplacements east of the block house with prominent views of St Georges Church in the townscape. Other prints show how the visual relationship of this church to the piers has also survived. The buildings east and west of the High Street whilst dating primarily from the C18th and C19 as a result of a major fire, are set within a surviving tenement/ burgage plot pattern that provides the basis for the tight grained character of the core of the town and its High Street. The scale and pattern represents several phases in the towns history from the late medieval period described above to the towns more developed ship chandling and lighterage role in the C18th and then as a London orientated pleasure resort role in the first half of C19th. The latter is represented by inns, other buildings in the High Street, gardens, the Town Pier (probably the earliest surviving cast iron pleasure pier) and the Terrace/Royal pier. The current built form of the Heritage Quarter of the town centre has retained its low to medium rise early built form. This includes the planned cohesive Georgian style architecture of AH Wilds set piece terraced layout of Harmer Street (1840). Only at the more recent St Andrews Court does the scale get to a more substantial mid rise. The historic fabric also provides aesthetic values, not only through set piece architecture such as the town hall (also by AH Wilds) in the core of the High Street, but through the vernacular form and patina accrued by various other buildings of the C18th , 19th and early 20th centuries. Views of parts of the town, including spaces surrounding the church, are often fortuitous but contribute to the sense of place. Some of these have historic significance for example - the later relationship of the New Tavern fort views along the terrace towards St Georges Church is a kinetic view. Views from the river towards Gravesend and the approaches to the piers also show an attractive rising terraced townscape which is of a human scale. The view from the Royal Pier area and blockhouse towards the Clarendon Hotel and St Georges church and High Street buildings, survives as a reminder of the relationship between the defensive role of the town and its civilian and commercial history. More critically, views from Tilbury Fort towards Gravesend, and from the Henrician blockhouse out to the forts provide an understanding of the defensive historic context. The piers view approaches to Gravesend are also aesthetically of value, not only including the St Georges church spire in the townscape but also those of St Andrews Chapel, St Johns and others. . While the riverside wharves buildings have been replaced or lost, the scale and height of buildings to the west of the pier retains a low to medium rise form, such that the townscape topography of the heritage quarter remains seen as one of essentially a compact low to medium rise form, clearly read in kinetic views from the river and pier approaches. The historic focal point being St Georges church. This church, and the apex of others, also punctuate the townscape if viewed from high points above the town to the south e.g. Windmill Hill ES (Vp11). Archive prints of the town show the primacy of St Georges Church or its predecessor in the townscape from the riverside approaches from the mid C16. Vp11, also shows how the tall building E06 mass and height will overtly dominate other subtle and elegant but considerably less tall features of the towns historic core. English Heritage consider that a tall building of the magnitude now proposed will have a severe adverse impact on the significant heritage values set out above. It will dominate the layers of historic fabric around it, being overbearing on the nature and scale of the surroundings which form the essence of the Heritage Quarter and interrupting key views and the settings of heritage assets. View point :14 ES vol 3 is but one view that illustrates this. We have set out in previous letters our views regarding any justification of the need for tall building proposals in Gravesend to be plan led as referred to the EH/ CABE guidance. Eastern Side of High Street the car park area. There have been welcome changes to the proposed buildings in the eastern side of the High Street, to reinstate part of the town that has long been the car park gash in the townscape. This principle is important and positive. However, there are aspects of the proposals that still require further improvements. Given the nature of the buildings on the east side of Queen Street, we are prepared to accept an incremental step change in height for this development, but a modern design should take cues from the surroundings. The scheme displays current architectural idioms, including features that could be anywhere, but crucially it lacks a sense of belonging and of adding to Gravesends sense of place. While noting the further amendment to the SW corner of the north block, we consider that views along Bank Street still impose upon, rather than compliment views of St Georges church. The views from Queen Street along Bank Street, show this unfortunately challenging the Church in the roofscape. We welcome the revisions made to tackle the problem of inactive dead edges onto Bank Street, although the management of restaurant units will require considerable endeavour to ensure usage here. There remain unresolved issues of levels (clearly apparent in the model) for the pedestrian access, from the alleys to the north east side of the High Street through into the development. The existing finer grain, which is represented by such alleys for those walking through it, needs to be integrated into the scheme rather than faced with service yards. While there is of course a clear need for service provisions, these should be dealt with as streets. Largely due to the underground car parking and slope, there is a problem of blank walling at street levels alien to Gravesends heritage quarter, particularly when walking towards the river. Active edges or attractive edges in the case of residential uses, need to be made along the pedestrian routes (not just inside the new square) so that the rear of the High Street is active, adding to the High Street and encouraging pedestrian movement. While the north block has an improved with varied articulation, the south block design still appears as one continuous mono block as viewed from the east, therefore some articulation and variation at roof level should seek to address this. The north block on the other hand, is almost overly varied and thus busy, a better balance is needed with more architectural coherence between the blocks. The junction of Bank Street and Queen Street has improved, but much will depend on landscape, lighting and high quality, best practice street design (including minimal signage). We noted the elevations have residential accommodation over commercial uses overlooking Bank Street, whereas if other uses were at first floor and above facing this street, this might allow the street to be narrower, with the blocks being pulled closer together, thus aiding a continuity of the prevailing grain. Crossing over Crooked Lane you are aware of the extensive areas of hard landscape surface adjacent to the road despite the terracing. This may look stark approaching from the east side new development and the High Street. The road appears to have widened from previous plans, perhaps to accommodate Fastrack, which can rail against ease of pedestrian movement, relying solely on engineered crossing points rather than a strong pedestrian bias. Area west side of High Street including the church. St Georges Church and its setting is a highly significant component of the Gravesend townscape. Historically and to a lesser extent today the church has appeared pre-eminent. At close quarters, the relationship of any church extension and the single aspect housing is important to the setting of the church. We have referred to this in previous letters and at meetings. Accurate photo montages (AVR)and sections through the space between the two are required. We have recently met again with the PCC to set out our concerns. Our current views about the church are briefly set out below. We previously also stressed the need for joint discussions with Kent Highways to consider how far the one way Princess Street to the east of the church could be narrowed such as to allow flexibility in the design of any church extension if located on the south side of the church. We are not aware of the results of any meeting or indeed if this has taken place. The DAS (page 87) indicates that options for locating the church extension were considered but of the two realistic options, the north seems to have been very readily dismissed as blocking routes to the river. We see no reason why such an extension could not add possible interest to a route to the river, possibly adding to Gravesends finer grain. We do not comment in detail on the church extension proposals at this time as the design does not form part of the current submission. However we have continued to discuss the proposed designs with the PCC, in order to seek to resolve both the highly unsatisfactory combined visual relationship between the proposed church extension and the shopping and commercial component of the west element of the Edinburgh House application. We will require accurate views from the north side (NW) of the proposed church square and from the southern footway/ access road approaches i.e. a walking view in order to understand the effect of the church proposals and the larger scheme together, irrespective of the final church design. We reiterate that the case for location of the church extension on the south rather than north side of the church needs to be convincingly put forward. West Street Bath Street. We previously reported that earlier changes appeared to have assisted in breaking down the sense of a rather monolithic continuous built edge and approach along Bath Street/ West Street. The impression is nonetheless still of a one build block. This becomes readily apparent when the bulk of the scheme is read from the north end of Bath Street. While early discussions on the Heritage Quarter development accepted the possible likelihood of the loss of the current west views of St Georges Church, the proposals at that time created openings and visual links near Church Street. Current proposals would remove all such views. The wire diagrams supplied unfortunately give an impression of the overall unremitting and substantial bulk of the proposed developments western edge and the complete cut off of views from Bath Street and much of West Street. We would wish to encourage a softer approach to the western edges of W03/02 and greater variation in modelling of W02 and W01onto West Street with perhaps possible breaks in the larger block, for views or routes to the church. Outline application and parameter plans. English Heritage has concerns that an outline application approach offers too greater uncertainty as to the critical public elevations and their relationship to the church, church yard and West Street. Parameter plans are indicated as being supplied and are shown in the DAS and application but such proposed outline development flexibility is not helpful to clarity, including an understanding of the nature of the proposed space between the church, the shopping commercial development or the single aspect housing facing the south side of the church. Furthermore, its planning control cannot be assured. Further detailed information on elevations including the relationship of the south eastern block to Princess Street to the rear of the lower High Street is also needed. River frontage and the Tall Building proposal. We refer to our previous letter in June 2008 where we cited the EH/CABE advice on tall buildings i.e. that they should be plan led. Our comments on the E/A scoping in November 2005 also referred to such advice. Government encourages local planning authorities to identify suitable locations where tall buildings are, and are not, appropriate, in areas where such developments are accepted as a possibility. We have referredparticularly to page 2.6 of the guidance. The current proposal does not follow this advice. The submitted statement looks at a location for a tall building in the Heritage Quarter development area only. The selection location appears to pre-suppose that a tower of the magnitude submitted is possible in locations A-D in the statement also without looking at alternative imaginative, informed designs in those locations. The environmental statement supplied is of general concern to us its regarding built heritage and heritage views. The defenceheritage element is located in the archaeology section but appears not to be linked to the earlier chapter, in ascribing weighting to the heritage holistically. It selects view sites but without setting out why such locations are significant. Various viewpoints appear omitted in the visual impact assessment, from Royal Pier road for example. The character assessment lists out townscape components, including designations, but not why these are valued. The brief character description area extends to the station but not the site location selection area. We have previously commented in brief on the design aspects of the tall building. Our views remain unchanged that it is not an elegant structure. The north and south elevations, despite its vertical separation are slab like in silhouette. Comparisons are made in the tall building statement with other examples, but those cited are all related to major city block contexts. We must point out that we have previously suggested other alternatives to a tall building should be fully explored, including for example, cues taken from the defensive history of the town or encompassing an urban garden as part of imaginative architecture that could embrace the St Andrews gardens, with greater scope for public access to the waterfront. We have previously referred to the Gravesham Borough Council development brief and statements that do not appear to have been resolved in the application. For example under the brief para 3.6 it is stated that development should carefully respect the scale of residential buildings on the south side of upper Crooked lane and those nearby the river. We still consider the current proposal is flawed with respect to these and other related key aspects of the brief. Finally, two points, firstly as indicated earlier, the Heritage Quarter has much scope for revealing more evidence leading to a greater understanding of its history and this includes potential archaeology. We consider that further work is required in consultation with Kent CCs heritage conservation team regarding assessment of archaeological impacts and possible pre application determination work. Secondly, we are not aware of how proposals might be affected by the flood risk assessment and requirements of the Environment Agency, particularly along the riverside and works required due to the development proposed facing West Street and E02/3 onto Crooked Lane. How might these affect elevation design? Recommended . In conclusion, English Heritage believes that, although there are some improvements to the scheme in the proposed blocks east of the High Street, our earlier major concerns have yet to be addressed. Therefore we must advise as follows. Against the acceptance of an outline application and parameter plans (with flexible heights and footprint) particularly for the west side scheme around the church. The proposals for church extension and the SW side of the submitted scheme should be considered together. We also consider such proposals can create a high risk of a monolithic design. This will impact heavily and adversely on the setting of the church but can also create a continuous monotonous face to West Street and parts of Bath Street. That whilst we welcome the improvements in the scheme to the east of the High Street, several of our earlier concerns have not yet been addressed as indicated above. These should be satisfactorily addressed before the proposals for the east side blocks might move forward positively. That we strongly object to the proposal for the 33 storey tall building, not only in that it is not plan-led, but that it is out of character with Gravesend, and the Heritage Quarter in particular. It will do substantial harm to the settings of listed buildings, scheduled monuments and adversely affect the conservation areas. English Heritage must recommend that the proposals in their current form are rejected for the reasons set out above. In addition, we consider that insufficient information is supplied to judge the effect of the submitted proposals on the overall setting of the church, relative to recent designs drafted by the PCC for the church extension. Next steps.  !:;<UVWXYjk     " # $ % & ' ( ְˑ hhOJQJ^JmH sH  hhOJQJ^JmH sH hhH*OJQJ^JhOJQJ^J hhCJOJQJ^JaJhhCJaJhhOJQJ^JhhOJQJ^Jhh5OJQJ\^J2!;<VXYkb ]"]b N?Z"]b ]Nkdv$$If0@!6234aNkd$$If0@! 6234a $Ifgd,"]b N?Z"]b ]NkdZ$$If0@!6234a $IfgdNkd$$If0@! 6234a "]"]b N?Z"]b ]b ]Nkd6$$If0@! 6234a $IfgdNkd$$If0@!6234a # % & ( 4 6 v x "]b N?ZU!]U!]U!]U!]U!]gdNkd"$$If0@!6234a $IfgdNkd$$If0@! 6234a ( 3 4 5 6 u v w x     % & `b\]^_79@ABC#hh>*OJQJ^JmH sH #hhH*OJQJ^JmH sH hOOJQJ^JmH sH &hh5OJQJ\^JmH sH  hhOJQJ^JmH sH  hhOJQJ^JmH sH *OJQJ^JmH sH )hh5>*OJQJ\^JmH sH h1ROJQJ^JmH sH hOOJQJ^JmH sH  hhOJQJ^JmH sH  hhOJQJ^JmH sH :''!)#)++u-w-//00222759588t;x;;???CCACFF!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!] !]!]!] !]!]!] !]!]!] !]!]gd[2\22222222u4z45'5657585958888::s;t;w;x;y;;;;;;==>>???????м|nnЊhmROJQJ^JmH sH hIOJQJ^JmH sH #hh>*OJQJ^JmH sH #hMh>*OJQJ^JmH sH hJ^OJQJ^JmH sH &hh5OJQJ\^JmH sH  hhOJQJ^JmH sH  hhOJQJ^JmH sH hMOJQJ^JmH sH +??CCCC@CACCCzDDD:F?FFFFF H%HHIIIJIKIIJJJJJ1L2L3L4L5L6LMMNN N N﷥﷥k&hh6OJQJ]^JmH sH hMOJQJ^JmH sH /hMh>*B*OJQJ\^JmH ph# sH #hMB*OJQJ^JmH ph# sH )hhB*OJQJ^JmH ph# sH #hh>*OJQJ^JmH sH  hhOJQJ^JmH sH  hhOJQJ^JmH sH *FIIKIJJ2L4L6LN NOOPPPQQU UNXRX}ZZ[[[b~!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]!]h^hgd ^`gdgd NOOOOPPPPPPPPPQQQRRRUU UVVVVVLXNXPXRXTXdX>Y޼ިިޙ{l{l{`{l{l{h2OJQJmH sH hhOJQJmH sH hhOJQJmH sH hhCJaJmH sH hhOJQJmH sH &hh5OJQJ\^JmH sH &hh6OJQJ]^JmH sH hROJQJ^JmH sH  hhOJQJ^JmH sH  hhOJQJ^JmH sH ">Y@Y|Z}Z~ZZ[[[[[[|a~b~c~d~i~:=LMNOPQRScd{|±±wb)hhB*OJQJ^JmH phsH #h2B*OJQJ^JmH phsH )hhB*OJQJ^JmH phsH U hhOJQJ^JmH sH  hhOJQJ^JmH sH &hh5OJQJ\^JmH sH hhOJQJmH sH hhOJQJmH sH h7?OJQJmH sH &English Heritage does of course, wish to see regeneration of Gravesend that will build upon the earlier investment in its historic fabric, so to both reinforce and add to its sense of place. We will welcome further discussions on the Heritage Quarter proposals and, following our comparatively recent informal meeting, we have suggested a possible workshop approach that might assist in order to address positively our concerns and those of others. There should however be no doubt that major revision to elements of the scheme will be required in order to arrive at a solution that we are able to support. If, notwithstanding our advice, you propose to recommend approval of the scheme in its present form, please advise us of the date of the committee and send us a copy of your report at the earliest opportunity. Yours sincerely GRAHAM STEAGGLES Historic Areas Advisor South East Region. CC. 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