ANNEX 2
Chris HawkingPlanning and Regeneration
Middlesbrough Borough Council
PO Box 99A
Town Hall
Middlesbrough
TS1 2QQ / Direct Dial: / 0191 269 1230
Your Ref:
Our Ref: / HB6007/728/0003
Date: / 15 April 2011
Dear Chris,
ACKLAM HALL
I said that I would provide you with some summary comments on the bundleof information we received on disc from Fairhurst in March 2011 in respect of the emerging development proposal at Acklam Hall.
As with our earlier advice, this letter seeks to help realise a solution of appropriate high quality which truly secures the long-term future of this highly significant site. Please feel free to share it with the developer and their team. The following should, of course,be read in conjunction withearlier correspondence, including thesubstantive written comments we providedon 9 July 2010, the letter from Carol Pyrah to Ian Parker dated 24 March 2011, and numerous email communications over this period. We have provided separate comments to you on the “Appendix 1” information in an email dated 23 March 2011.
This letter focuses chiefly on design matters; our parallel concerns about the sale contract and related legal documents, and the way these would seem to fetter the ability of the local planning authority to secure both the early initial repair of the site and its long-term management, are recorded elsewhere.
Preliminary comments
It is perhaps useful to commence with the following preliminary comments:
1. We acknowledge that significant proposals of this kind inevitably raise a great many planning issues which the local planning authority must assess and adjudicate on. English Heritage's specific remit, on the other hand, is to assess the impact of the proposed scheme upon the grade I listed building and its setting, and upon the character and appearance of the designated conservation area.
2. The significance of the site is derived from its origins as a late seventeenth century manor house, set within the remnants of a designed historic landscape. The twentieth century witnessed a period of major change at Acklam: some of this change has served to strengthen and enrich the site’s heritage value; other changes have led to the site’s fragmentation and to elements of its heritage value being eroded. The Hall was listed at grade I (by definition, of exceptional national interest) in 1951. That designation places it in the top 2% of all listed buildings in England.
3. We acknowledge that the situation at Acklam is complex and that securing a long-term viable future for the site presents many challenges. Those challenges are, however, very clearly defined in the Council’s published development brief. It is noteworthy that, among other matters, the brief refers explicitly to the need for (to quote): “the highest quality of development”, “the very highest and most sensitive design skills” and “a conservation-led approach to the highest standards of national best practice”. In our view, these requirements continue to be essential prerequisites for a successful scheme at Acklam and this has been a consistent theme of our advice to date.
4. We have, as you know, separately confirmed that English Heritage would object to the scheme in its current form were it to be submitted to us as a formal notification. In our view, the current proposal would have a detrimental impact upon the character and appearance of the conservation area and upon the setting of the principal listed building. We consider that the benefits arising from the current proposal would not be sufficient to outweigh the harm to the significance of the conservation area and to the setting of the Hall and, as such, would not meet the requirements of PPS5 (Planning and the Historic Environment). The current scheme reflects a poor understanding of the site and the exciting opportunities it offers.
5. The disc from Fairhust provides the first substantive package of information we have received for the scheme as a whole. This is most welcome; a consistent theme of the comments we have provided so far is a plea for proportionate levels of further detail. Nonetheless, there continue to be significant gaps in – and omissions from – the information now before us. The following is not an exhaustive list, however by way of example:
● we can find no rear elevation drawings for the proposed housing units,
● there is no phasing plan for the scheme as a whole; and
● the Appendix 7 document falls well short of the “design code” requirements we set out in our letter dated 9 July 2010 (paragraph 12).
The latter document provides no comfort that any new building to the east side of the Hall would be of equal (and, ideally, better) design quality when compared to the buildings which currently occupy this part of the site. As you know, the existing buildings here are identified in the published conservation plan as being of “moderate significance”. In line with the approach in PPS5, the provision of greater certainty about the design quality of any replacement extension would seem to us to be vital in demonstrating that a replacement building would deliver sufficient benefits to outweigh the harm or loss of significance arising from the removal of the existing structures.
6. Similarly, the lack of any reference in the latest information we have received to key design guide documents such as By Design or Building for Life is a concern for us. As PPS1 (Delivering Sustainable Development) states, good design should respond to local context, strengthening local character and distinctiveness. Schemes which fail to take the opportunities available for improving the quality of an area should not, PPS1 advises, be accepted. PPS1 also makes clear, however, that good design is about much more than the visual appearance of a new development, or the architecture of individual buildings; it is also about the way a development functions, the way it creates high quality spaces, and the way it brings people together through places that connect with each other and that avoid segregation. In our view, these would be among the hallmarks of a successful scheme at Acklam and, as such, we believe that a more fundamental rethink (drawing upon the high level design skills required by the published development brief) is needed before such essential ingredients are realised. As you know, By Design provides practical advice to help secure the delivery of the government’s commitment to good design, as set out in PPS1.
7. The latest information (Appendix 3) concludes that the proposed scheme would result in an increase in useable floor area (across the entire site) of 80% when compared to the existing situation. In the light of this finding, we re-state the advice we provided in our July letter (paragraph 8) for the local planning authority to satisfy itself – through consideration of the developer’s financial appraisal – that the current proposal represents a proportionate response to the investment needs of the site. As previously advised, our acceptance of such intensification of development is ultimately dependent upon our being satisfied that the proposed scheme would achieve the necessary high design quality such that the benefits arising from the proposal would be sufficient to outweigh any harm or loss to the significance of the site.
8. Since the emerging proposal is premised on the fact that the land to the north side of the Hall has very limited development potential (as stipulated in the published development brief), we re-state our earlier advice that it will be important for a legally enforceable mechanism to be applied to any forthcoming consent in order to restrict the future development of this part of the site.
9. Finally, as mentioned in our email of 31 March 2011, we await a copy of the Council’s EIA screening opinion.
Moving forward
To try and move the scheme forward, and against the backdrop of government planning policy guidance in PPS1 and PPS5, we have set out below some of the specific elements or characteristics which we consider to be inherent in a successful scheme at Acklam. For ease of reference, these are presented in a series of bullet points. The following should not be viewed as a conclusive or exhaustive list; it is not. The following comments do suggest, however, that the starting point for a revised scheme should be the preparation of a more rigorous and clearly articulated contextual appraisal which extends beyond the immediate boundaries of the development site.
A. A scheme that responds to, and interprets, the history and development of the site
By way of example:
● The current proposal adopts a largely standard approach to the housing design across the entire site. This cuts across the conservation plan analysis, as amplified in the submitted historic landscape assessment, which identifies distinct landscape character areas, notably “the walled garden”, “the woodland areas” and “the front lawn”. The proposed soft landscape strategy skilfully interprets this important narrative (paragraph 8.3.3, Appendix 5), however this could profitably be carried through into other elements of the design. This could be achieved by (for example) modifying not only the external appearance of the housing units within each character area but also the disposition of those units in order to create a scheme with real identity, real individuality and real sense of place. This, for us, is one of the exciting development opportunities presented by this site: the opportunity to reveal and interpret the site’s unique history, development and significance.
B. A bespoke scheme that responds to local character and context and which reinforces local distinctiveness
By way of example:
● The current proposal is not sufficiently rooted in its surroundings, such that it would form a bespoke solution which would add to the overall character and quality of the site. The design of the proposed buildings is ordinary and undistinguished. We are not opposed to the principle of the proposed uses in the broad locations shown, provided that the necessary high design quality can be achieved. Nor are we opposed to a contemporary design approach which draws imaginative inspiration from its surroundings. Furthermore, we are content that the height and general massing of the proposed housing and medical centre are appropriate, again provided that the necessary high design quality can be secured.
● We have provided separate comments, by email on 1 March 2011, on the external appearance of the proposed housing units and so we need not repeat the various points. As Building for Life states, “the best schemes are usually those that recognise the individuality of a place”. The latest information (for example, Appendices 5 and 6) does not adequately explain how the proposal has been informed by, and how it responds to, the essential characteristics of the site, its history, development and distinctiveness. The analysis of the proportional relationships within the architecture of the Hall (page 26, Appendix 5) provides an interesting line of inquiry, however this narrative is not developed and no explanation is provided of how these relationships (nor indeed how some of the Hall’s other distinctive architectural forms) have informed the design. The form and external design of the proposed medical centre is especially lacking in contextual references; this building would appear as a discordant and incongruous feature in this location which would fail to take the opportunities available for better revealing the significance of the conservation area (contrary to policy HE9.5, PPS5) and for enhancing the setting of the grade I listed building (contrary to policy HE10.2, PPS5).
● A simple palette of high quality construction materials, used and detailed in a creative way, could work very well at Acklam. As By Design acknowledges, responding to local building forms – and using local materials, building methods and details – is a major factor in enhancing local distinctiveness and sense of place.
C. A scheme that functions well and that is fully integrated into its surroundings
By way of example:
● We welcome the incorporation of the Yew Avenue – an important surviving fragment of the historic landscape - into the scheme. However, as previously advised, this feature needs to be more fully integrated into the development so that it has a clear use or function. This could be achieved by creating a pedestrian link between the Avenue and the public footpath through the west woodland, and by turning the proposed housing units at the east end of the Avenue so that their fronts (and front entrances) address this route.
● With regard to the proposed medical centre, the bland monolithic character of the rear elevation would produce an unattractive and uninviting space to the rear of the Hall. This elevation would appear as an obtrusive feature in views from the Hall and from the proposed Hall extension. The principal entrances to this building are not sufficiently prominent or identifiable, as would be necessary to ensure that this public building functions well.
D. A scheme that strengthens the open character of the spaces to the front and west side of the Hall
By way of example:
● In our view, the character of these open spaces would be harmed through fragmentation with estate railings. We appreciate the need for suitably designed railings in order to define the private gardens of proposed housing units, and we also recognise that there may be a need to provide a discreet and suitably designed railing along the southern edge of the front lawn in order to define this area as a semi-public space (in contrast to the public spaces to the south). However, we consider that any further subdivision would have a detrimental effect upon the open informal character of these important spaces.