Watford Junction Draft Development Brief 2016

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Comment

Watford Junction Draft Development Brief 2016

Watford Junction Draft Development Brief

Representation ID: 598

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness and would be keen to see a positive strategy for the conservation of the historic environment incorporated into a vision for the area.

Full text:

Consultation Responses

a) Watford Local Plan - Part 2: Site Allocations and Development Management Policies - Publication Version July 2016 and accompanying Watford Local Plan Part 2 Publication Stage Environmental Report August 2016.

b) Draft Watford Junction Development Brief

c) Croxley View/Ascot Road Study

WATFORD LOCAL PLAN - PART 2: SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES - PUBLICATION VERSION JULY 2016 AND ACCOMPANYING WATFORD LOCAL PLAN PART 2 PUBLICATION STAGE ENVIRONMENTAL REPORT AUGUST 2016.

Thank you for consulting Historic England on the submission draft of the Local Plan Site Allocations and Development Management Policies Document.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.

We very much welcome the references to the historic environment made throughout the draft development framework document and appreciate the effort made to acknowledge the positive contribution to character and placemaking that the historic environment can bring. The document has been set out clearly and is commendably accessible in format. The following amendments are therefore suggested to ensure that the draft SPD fully reflects the statutory requirement to take into account opportunities to draw on the contribution made by all elements of the historic environment.

You will note that we have previously responded to earlier drafts of this document in February 2015 and to an addendum incorporating a Taller Buildings policy in February 2016. Whilst we commended the Borough's comprehensive evidence base incorporating Conservation Area Appraisals and a managed local list of locally important structures, we also requested that some changes be made to the document; particularly consistency of approach to the conservation and enhancement of the historic environment.

Whilst we would not normally expect to offer substantive comment at submission stage, we note that few of the changes requested at earlier stages have been incorporated into the final submission document and this response therefore reiterates our preferred changes to ensure that the plan adequately sets out a positive strategy for the historic environment as required by the NPPF and fulfils the Sustainable Community Objective to be a town that protects its environment and heritage set out within Watford Borough Council's adopted Core Strategy (2013).
We encourage ongoing dialogue and request to be notified of the date of the Examination in Public by the Secretary of State as we may wish to make representations.

Heritage Policies

Policy UD4 - The Historic Environment

We are pleased to see a specific policy addressing the conservation of the historic environment . However we have the following comments to make regarding necessary changes for a sound Local Plan.

Listed Buildings and their setting

The NPPF requires that when considering the impact of a proposed development on the significance of a designated asset, great weight should be given to the asset's conservation. Significance can be harmed by development within the setting of the listed building and substantial harm (including to the setting of a listed building) should be wholly exceptional.

By separating the 'setting of a listed building' from the section on 'listed buildings', the plan implies that a lesser degree of significance is accorded to the setting of a listed building than to a listed building itself.

As submitted, references to the need for wholly exceptional circumstances refer only to the demolition of listed buildings. This does not reflect the NPPF which sets out that substantial harm or loss of highly significant listed buildings (Grade II* or I), which can include harm to the setting of such a building, should be wholly exceptional.

We are also concerned that in consideration of setting, the current policy states that in the event of harm to or loss of significance, this should be weighed against public benefit. This is the role of the planning system but we feel that a more robust strategy for the conservation of the historic environment should set out that harm or loss of significance of the setting of a listed building will not be acceptable.
We strongly encourage the Borough to combine listed buildings and their setting for a robust and NPPF compliant policy that sets out a positive strategy for the conservation and enjoyment of historic environment.

Development in the vicinity of a listed building

We request the following amendment to ensure that the Council's policy for the conservation of the historic environment is appropriate to ensure that listed buildings are given due consideration in the determination of planning applications for development. Without this alteration, the policy relates solely to development of the listed building itself with no other policy for the protection of the significance of listed buildings when development is beyond the listed building.

The Council will preserve the character and setting of the borough's listed buildings and will support applications where:

* The extension/alteration of a listed building development would not adversely affect its character as a building of special architectural or historic interest; both internally and externally, or adversely affect its wider setting.

Conservation Areas

We request the following minor amendments;

Within conservation areas, development will be supported where it:

* Uses materials, finishes, including those for features such as walls, railings, gates and hard surfacing, that are appropriate to local context preserve or enhance the character of the Conservation Area.
* Results, where relevant, in the removal of unsympathetic features and the restoration or reinstatement of missing features.

All other bullet points are supported as consulted.

Demolition in Conservation Areas

We encourage robust policy protection for Conservation Areas and we are pleased to see this addressed within the local plan. We caution however, that the local plan should not be more stringent than the requirements within the NPPF as this may weaken the application of the policy. As such, the first and third bullet points are very welcome. The intent of the second bullet point is understood. This may be a hard policy test in practice however, as, theoretically, all buildings are capable of repair and some beneficial use, even if not suitable or viable. We caution that the use of a difficult test may lead to the entire policy (and decisions based on it) which seek to appropriately conserve the historic environment being challenged at appeal. We suggest that this bullet point is omitted to strengthen the policy.

We request the following omission from the text;
Permission will not be granted for development outside of but near to a conservation area which adversely affects the setting, character, appearance of or views into and out of that conservation area.

This allows for consideration of any affects to a Conservation Area without having to define the difficult question of what is 'near' to the site or not.

Future Designations

Watford Borough Council has a commendable history of local listing, conservation area appraisal and review of its surviving historic environment. It would be a positive strategy to embed this positive approach to heritage conservation within the draft local plan with a policy supporting future designations of locally listed buildings, registered parks and gardens and other heritage assets,

General Comments

Glossary

Listed Buildings and Locally Listed Buildings appear twice. In each case, the first definition is the most appropriate.

Policy SPMX1 - Special Policy Areas

This omits the wording suggested in our previous letter dated 04/02/15 which requested that the sentence Development proposals should accord with the related Core Strategy Policy be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that the principle of development does not override the need to comply with other adopted policies including those that seek to enhance and protect the historic environment.

Policy SPMX2 - Mixed Use Allocations Policy

As this policy states that development will be appropriate on these sites, it is important to ensure that the historic environment is appropriately considered. The mechanism for this is through robust development considerations as set out in Appendix I.

These are acceptable in many places but references to the historic environment are not consistently presented and in some cases there are gaps, as set out in our previous advice of February 2015. In some of these sites, heritage assets in the locality are named and even graded where in others they are partially identified or omitted altogether, even where they are within the allocated site. For this reason I have reviewed the wording of each site within Appendix I - Site Schedules in the table attached to these comments and request that any suggested changes be incorporated to ensure that the protection and enhancement of the historic environment is a consideration for future developers and not contrary to the presumption in favour of development.

See attached table for detailed comment on Appendix I.

Policy TLC9 - Character Areas

This policy refers to the character areas within Watford Town Centre. We would welcome the following minor amendments to the wording;

* Recognition that Character Area ii - the Cultural Area includes the named Civic Core Conservation Area and many listed and locally listed buildings. Additional clarity is considered particularly necessary given that the Environmental Report accompanying the policy document determines that the impact of the character area designation on 'heritage' is neutral (See Page 41 of the Environmental Report accompanying the submission)..
* Recognition that the Palace Theatre and Colosseum are Grade II listed buildings.
* The text relating to Character Area vii - Heritage Area St Mary's and High Street/King Street Conservation Areas does not reflect the amendment requested in our letter of February 2016 which requested the following addition;
The primary concern in these areas is the impact of any proposed development on the designated heritage assets. The Council will expect proposals for development in these areas to actively seek to enhance the identified character and appearance of the conservation areas and the settings of the listed buildings and other heritage assets within and adjoining them.

We are supportive of the Council's encouragement of the redevelopment of the Church Car Park as this is an opportunity to better respond to the Grade I St Mary's Church and the thirteen Grade II structures in its immediate locality, including Watford's remaining Tudor houses the Grade II listed Bedford Alms Houses. The setting of the church is an important part of its significance and developers should be asked to give this careful consideration to this building of exceptional national significance. As such, we again request the above addition to the policy wording.
Policy EMP4 - Change of Use from B Class Outside of Designated Employment Areas

We request that the sentence The proposal must also be compatible with surrounding uses be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that compatibility with surrounding uses does not overcome the need to consider the historic environment and relevant policies within the Local Plan.

Policy EMP5 - Clarendon Road, Station Road and Bridle Path Office Area

This area contains a number of locally listed buildings the retention of which would be beneficial to refer to within this policy to offer them a degree of protection. Retention of these locally listed buildings could enhance the townscape and character of the future office quarter and we encourage reference to them within this policy.

Policy SD6 - Renewable Energy Technology , Policy SD15 - External Lighting Policy & Policy INF2 - Mobile Communications

We are pleased to see the incorporation of the historic environment within the text of these policies. We recommend that the last bullet point in Policy SD15 - External Lighting Policy be altered from heritage assets to historic environment for consistency and to allow greater flexibility in protecting the historic environment beyond designated assets.

Policy TB1 - Location of taller buildings

We are disappointed to note that our detailed advice of February 2016 has not translated into amendments to the wording of the draft policies.

We again submit the following suggested amendments, in the awareness that the proposed locations are in close proximity to the historic core of Watford, several listed and locally listed buildings and Conservation Areas.

The majority of Watford is characterised by low level residential and other forms of development where taller buildings would generally be considered inappropriate. All development needs to be designed in order to respect, reinforce and enhance the local character, including historic character, of the area in which it is located and to contribute to Watford's distinctive sense of place and identity as referred to in Policy UD1 of the Core Strategy....

... (Watford Junction SPA2): The Watford Junction Masterplan should be referred to for further detail on how the pinnacles should be incorporated into the wider townscape and to achieve a positive strategy for the conservation and enjoyment of the historic environment.

The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage (See page 62 of the Environmental Report).

Policy TB2 - Design of Taller Buildings

Please alter 'heritage assets' to 'the historic environment' throughout the document to ensure the widest possible application of the policy to historic places and non-designated heritage assets.

We recommend the inclusion of 'high' in front of quality within the discussion of public realm (point 8).

We note that Criterion 10 - Heritage has been removed. As a result it is particularly important to ensure that the remaining criteria adequately allow for protection of the historic environment.

We note that the accompanying Environmental Report finds that the impact of Policy TB2 is positive or 'sustainable' with regard to Watford's Historic Environment (see page 62 of the accompanying Heritage Report). The change of terminology from within the policy text from heritage assets to historic environment may assist in mitigating harm from taller buildings to ensure that the policy can be considered sustainable.

Appendix I - Site Schedules

We reiterate our comment that we would not normally expect to offer substantive changes to the Local Plan at submission stage. However, as previous suggestions have not been incorporated with regard to the historic environment and clarity of presentation of heritage considerations, we request the following revisions to the text.

These changes will be necessary to ensure that the plan adequately takes into account the desirability of sustaining and enhancing the significance of heritage asserts and identifies opportunities to draw on the contribution made by the historic environment to the character of Watford.

Site Comments Justification
SPA1 - Town Centre Replace 'Heritage assets' with The Historic Environment. Please add the following point: Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Little Cassiobury and Former Stable Blocks (registered on the national Heritage at Risk register) will be given significant weight. The historic environment encompasses more than designated heritage assets. The NPPF requires that a local plan sets out a positive strategy for conservation and enjoyment of the historic environment including heritage assets most at risk through neglect, decay or other threats. As this Grade II* listed building, which is on the Heritage at Risk register is not otherwise mentioned within the Local Plan, it is appropriate to mention a positive strategy for its conservation in Policy SPA1. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA2 - Watford Junction Please replace 4th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the adjacent Nascot Conservation Area, Grade II listed Benskins House (The Flag Public House), Reeds Crescent and other heritage assets within the area. Within the site, the conservation of the Grade II listed Old Station House and its setting should form part of the proposals. For consistency with the remaining policies, we recommend naming and grading the listed heritage assets referred to. For continuity with previous consultations, locally listed Reeds Crescent is retained as a named asset. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different name, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. Grade II Old Station House is within the site and its conservation should therefore be given emphasis. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA3 - Health Campus Please insert the preservation and enhancement of the setting of before 'the Square Conservation Area' at Bullet Point 9. Reuse of Grade I Iisted Shrodells Wing of Watford General Hospital is welcome (We note a typographical error in its name [Grade II listed) ) as is due consideration to the Square Conservation Area.
SPA4 - Lower High Street Please replace 6th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street and the Grade II listed Bushey Arches. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. This is amended for consistency of approach with regard to heritage assets and to ensure that all of the nine listed buildings/structures and other locally listed buildings within the site are captured, not just the two mentioned. Reference to Grade II* listed Frogmore House is amended for consistency with Little Cassiobury at Policy SPA1. The wording seeks an appropriate scheme of repair and reuse rather than 'restoration' which has a specific meaning in terms of conservation and may not be appropriate. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA5 - Dome Roundabout No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA6 - Western Gateway No comment As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site MXD1 - North Watford Library/ Lemarie Centre No comment No comment
Site MXD2 - The Brow No comment No comment
Site MXD3 - Gas Holder Site Please add: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. We welcome the requirement for archaeological assessment and a heritage statement. We reiterate our comments with regard to Policy SPA4.
Site MXD4 - Ascot Road No comment No comment
Site R1 - Sainsbury's and adjoining land Please replace the 4th Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Monmouth House and Nos. 151-153 High Street. Proposals should preserve and enhance the Civic Core Conservation Area and its setting. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street and a potential Roman Road, and adjacent to the point that they are believed to meet we request archaeological assessment where appropriate.
Site R2 - Former TJ Hughes and adjoining land Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Palace Theatre, Beechen Grove Baptist Church and Nos. 14-16 The Parade as well as locally listed buildings at Nos. 11-33 The Parade. Proposals should preserve and enhance the setting of the adjacent Civic Core Conservation Area. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R3 - BT Telephone Exchange and adjoining warehouses Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 14-16 and No 58 High Street which will be expected to be retained. The significance and setting of the adjacent Grade I listed Holy Rood Church and St. Mary's Church and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is in the vicinity of two Grade I listed buildings. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R4 - Church Street Car Park and land fronting Market Street Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade I listed building of St Mary's Church and Grade II* listed Elizabeth Fuller Free School and the cluster of Grade II buildings and structures to the south of the site. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is within the core of surviving historic buildings and open spaces within Watford, including Grade I St.Mary's church and its open setting. Please note that the Elizabeth Fuller Free School is Grade II* listed, not Grade II listed as noted in the consultation document wording. As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site R5 - Charter Place Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 63-65 High Street which will be expected to be retained. The significance and setting of the adjacent Grade II listed No. 58 High Street, the Beechen Grove Baptist Chapel and the Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan. We request the removal of any reference to the frontage of Nos. 63-65 High Street which may encourage façade retention rather than the more appropriate retention of the building as a whole. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
Site CF1 - Tolpits Community Facility No comment No comment
Site H1 - Pinner Road Please replace the 7th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Oxhey Conservation Area, nearby Grade II listed buildings and other heritage assets within the area, particularly the locally listed Railway Arms Public House. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H2 - Skate Park, Lower Derby Road No comment No comment
Site H3 - Vicarage Road Please replace the 5th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Red Lion Public House and Watford Printers Buildings and the Square Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H4 - Telephone Exchange, First Avenue No comment No comment
Site H5 - Builders Yard, Queens Avenue No comment No comment
Site H6 - Bill Everett Centre No comment No comment
Site H7 - Rickmansworth Road Please replace the 1st bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of Nos. 195-199 Rickmansworth Road. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H8 - Garages, Gossamers No comment No comment
Site H9 - Metropolitan Station, Cassiobury Park Avenue Please replace the 3rd bullet point up to 'is required' with Design and development will need to be sympathetic to the significance and setting of the Grade II listed Watford Station. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H10 - Croxley View No comment No comment
Site H11 - Garages Bowman's View No comment No comment
Site GT1 - Land at Tolpits Lane No comment No comment
Site E1 - Watford Business Park No comment No comment
Site E2 - Imperial Way/Colonial Way No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site E3 - Fishers No comment No comment
Site E4 - Greycaine Road Please replace the 3rd bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Paramount Industrial Estate and Former Odhams Press Hall. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street we request archaeological assessment where appropriate.
Site E5 - Clarendon Road Please replace 2nd Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the Grade II listed Benskins House (The Flag Public House) and the Beechen Grove Baptist Chapel and locally listed buildings clustered around Clarendon Road which will be expected to be retained. The significance and setting of the adjacent Grade II listed Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the setting of the adjacent Estcourt Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan.. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different names, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
Site E6 - Leavesden Studios No comment No comment

DRAFT WATFORD JUNCTION DEVELOPMENT BRIEF

Thank you for consulting Historic England on the submission draft of the Watford Junction: Draft Development Brief (August 2016).

We encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers. We are aware of the many social and economic benefits that the development of the Watford Junction area aims to bring about.

Having reviewed the draft development brief we are concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness.

We are particularly keen to see a positive strategy for the conservation of the historic environment incorporated as part of the vision for the area. This would then cascade into the subsequent development briefs for individual sites. The historic environment is greater than a list of designated assets and encompasses locally listed buildings, character areas, the area's historic development, use patterns, street morphology and social history and a successful development brief should seek to draw on the elements of an area's historic character that make it unique and distinctive. Successful developments balance historic character with the other positive aims of placemaking to make locally distinctive places.

The Draft Masterplan is to be adopted as a Local Plan document and should therefore respond to the NPPF's requirement that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment.
To appropriately address this requirement, we recommend that the Baseline Assessment acknowledges the designated heritage assets within and directly adjacent to the site and identifies that the masterplan is an opportunity to draw on the contribution that the historic environment makes to local character.

The baseline assessment should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings.

Some, but not all of the listed buildings are marked on the Opportunities Map within the Baseline Assessment (the Former London Orphan Asylum is omitted for instance). If these are to be marked, we request that all of the listed buildings within a defined radius are properly mapped to avoid giving the impression that the setting of some are more acceptable to respond to than others. None of the Locally Listed Buildings nor Conservation Areas are included. We suggest that the draft document reflects the information contained within Watford's Conservation Areas Management Plan (2013).

We strongly encourage the acknowledgement and recognition of the historic environment as an opportunity within the SWOT analysis within the baseline assessment and that the retention and conservation of the Grade II Listed Building be made an explicit aim of the document.

The Vision and Objectives page should reflect the positive conservation of the historic environment and acknowledge this as a critical element of successful placemaking. We recommend that an additional objective be added to draw on the contributions of the historic environment to produce a locally distinctive place.
We note that the subdivision of the development site into four character quarters fails to include the area of the site that is within the Nascot Conservation Area (and contains the Grade II listed building) within any of the proposed quarters. There is development potential within this neutral part of the Conservation Area which would particularly benefit from guidance as how to appropriately respond to the surrounding Nascot Conservation Area and we would welcome a positive approach to development in this location. This area, identified as Area 21 in the General Masterplan maps contained within the Area Schedule is also omitted from a dedicated analysis of a suitable quantum of development, provided for other identified sub-areas within the area schedule.

We recommend that the possible development of this area be addressed within any revised document.

In making any revisions to the document, we recommend that Historic England's guidance note 'The Historic Environment in Local Plans: Good Practice Advice in Planning 1' is considered and its recommendations incorporated into any subsequent draft.

This document can be found at the following location:
<https://content.historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1.pdf/>

I would also recommend that you review the following guidance which may be of assistance to you to produce robust policies on tall buildings and placemaking appropriate to the aims of the NPPF in terms of conservation of the historic environment:

<https://content.historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/heag037-tall-buildings.pdf/>

<https://content.historicengland.org.uk/images-books/publications/streets-for-all-east-of-england/east-eng-streets.pdf/>

Croxley View/ Ascot Road Study

Thank you for consulting Historic England on the draft Croxley View / Ascot Road Study. We note that there are no Historic Assets on site but note the Grade II listed building Cassio Bridge Lodge is sited to the north of the site and we encourage that any development proposals are considered with regard to setting of this building.
We have no comments to make on the developing brief.

Summary

In preparation of all local plan documents, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime, we look forward to continuing to work with you and your colleagues in the preparation of the Local Plan documents.

Comment

Watford Junction Draft Development Brief 2016

Watford Junction Draft Development Brief

Representation ID: 694

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Baseline Assessment required the designated heritage assets within and directly adjacent to the site and identifies that the Masterplan is an opportunity to draw on the contribution that the historic environment makes to local character. It should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings. All these features should be mapped.

Full text:

Consultation Responses

a) Watford Local Plan - Part 2: Site Allocations and Development Management Policies - Publication Version July 2016 and accompanying Watford Local Plan Part 2 Publication Stage Environmental Report August 2016.

b) Draft Watford Junction Development Brief

c) Croxley View/Ascot Road Study

WATFORD LOCAL PLAN - PART 2: SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES - PUBLICATION VERSION JULY 2016 AND ACCOMPANYING WATFORD LOCAL PLAN PART 2 PUBLICATION STAGE ENVIRONMENTAL REPORT AUGUST 2016.

Thank you for consulting Historic England on the submission draft of the Local Plan Site Allocations and Development Management Policies Document.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.

We very much welcome the references to the historic environment made throughout the draft development framework document and appreciate the effort made to acknowledge the positive contribution to character and placemaking that the historic environment can bring. The document has been set out clearly and is commendably accessible in format. The following amendments are therefore suggested to ensure that the draft SPD fully reflects the statutory requirement to take into account opportunities to draw on the contribution made by all elements of the historic environment.

You will note that we have previously responded to earlier drafts of this document in February 2015 and to an addendum incorporating a Taller Buildings policy in February 2016. Whilst we commended the Borough's comprehensive evidence base incorporating Conservation Area Appraisals and a managed local list of locally important structures, we also requested that some changes be made to the document; particularly consistency of approach to the conservation and enhancement of the historic environment.

Whilst we would not normally expect to offer substantive comment at submission stage, we note that few of the changes requested at earlier stages have been incorporated into the final submission document and this response therefore reiterates our preferred changes to ensure that the plan adequately sets out a positive strategy for the historic environment as required by the NPPF and fulfils the Sustainable Community Objective to be a town that protects its environment and heritage set out within Watford Borough Council's adopted Core Strategy (2013).
We encourage ongoing dialogue and request to be notified of the date of the Examination in Public by the Secretary of State as we may wish to make representations.

Heritage Policies

Policy UD4 - The Historic Environment

We are pleased to see a specific policy addressing the conservation of the historic environment . However we have the following comments to make regarding necessary changes for a sound Local Plan.

Listed Buildings and their setting

The NPPF requires that when considering the impact of a proposed development on the significance of a designated asset, great weight should be given to the asset's conservation. Significance can be harmed by development within the setting of the listed building and substantial harm (including to the setting of a listed building) should be wholly exceptional.

By separating the 'setting of a listed building' from the section on 'listed buildings', the plan implies that a lesser degree of significance is accorded to the setting of a listed building than to a listed building itself.

As submitted, references to the need for wholly exceptional circumstances refer only to the demolition of listed buildings. This does not reflect the NPPF which sets out that substantial harm or loss of highly significant listed buildings (Grade II* or I), which can include harm to the setting of such a building, should be wholly exceptional.

We are also concerned that in consideration of setting, the current policy states that in the event of harm to or loss of significance, this should be weighed against public benefit. This is the role of the planning system but we feel that a more robust strategy for the conservation of the historic environment should set out that harm or loss of significance of the setting of a listed building will not be acceptable.
We strongly encourage the Borough to combine listed buildings and their setting for a robust and NPPF compliant policy that sets out a positive strategy for the conservation and enjoyment of historic environment.

Development in the vicinity of a listed building

We request the following amendment to ensure that the Council's policy for the conservation of the historic environment is appropriate to ensure that listed buildings are given due consideration in the determination of planning applications for development. Without this alteration, the policy relates solely to development of the listed building itself with no other policy for the protection of the significance of listed buildings when development is beyond the listed building.

The Council will preserve the character and setting of the borough's listed buildings and will support applications where:

* The extension/alteration of a listed building development would not adversely affect its character as a building of special architectural or historic interest; both internally and externally, or adversely affect its wider setting.

Conservation Areas

We request the following minor amendments;

Within conservation areas, development will be supported where it:

* Uses materials, finishes, including those for features such as walls, railings, gates and hard surfacing, that are appropriate to local context preserve or enhance the character of the Conservation Area.
* Results, where relevant, in the removal of unsympathetic features and the restoration or reinstatement of missing features.

All other bullet points are supported as consulted.

Demolition in Conservation Areas

We encourage robust policy protection for Conservation Areas and we are pleased to see this addressed within the local plan. We caution however, that the local plan should not be more stringent than the requirements within the NPPF as this may weaken the application of the policy. As such, the first and third bullet points are very welcome. The intent of the second bullet point is understood. This may be a hard policy test in practice however, as, theoretically, all buildings are capable of repair and some beneficial use, even if not suitable or viable. We caution that the use of a difficult test may lead to the entire policy (and decisions based on it) which seek to appropriately conserve the historic environment being challenged at appeal. We suggest that this bullet point is omitted to strengthen the policy.

We request the following omission from the text;
Permission will not be granted for development outside of but near to a conservation area which adversely affects the setting, character, appearance of or views into and out of that conservation area.

This allows for consideration of any affects to a Conservation Area without having to define the difficult question of what is 'near' to the site or not.

Future Designations

Watford Borough Council has a commendable history of local listing, conservation area appraisal and review of its surviving historic environment. It would be a positive strategy to embed this positive approach to heritage conservation within the draft local plan with a policy supporting future designations of locally listed buildings, registered parks and gardens and other heritage assets,

General Comments

Glossary

Listed Buildings and Locally Listed Buildings appear twice. In each case, the first definition is the most appropriate.

Policy SPMX1 - Special Policy Areas

This omits the wording suggested in our previous letter dated 04/02/15 which requested that the sentence Development proposals should accord with the related Core Strategy Policy be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that the principle of development does not override the need to comply with other adopted policies including those that seek to enhance and protect the historic environment.

Policy SPMX2 - Mixed Use Allocations Policy

As this policy states that development will be appropriate on these sites, it is important to ensure that the historic environment is appropriately considered. The mechanism for this is through robust development considerations as set out in Appendix I.

These are acceptable in many places but references to the historic environment are not consistently presented and in some cases there are gaps, as set out in our previous advice of February 2015. In some of these sites, heritage assets in the locality are named and even graded where in others they are partially identified or omitted altogether, even where they are within the allocated site. For this reason I have reviewed the wording of each site within Appendix I - Site Schedules in the table attached to these comments and request that any suggested changes be incorporated to ensure that the protection and enhancement of the historic environment is a consideration for future developers and not contrary to the presumption in favour of development.

See attached table for detailed comment on Appendix I.

Policy TLC9 - Character Areas

This policy refers to the character areas within Watford Town Centre. We would welcome the following minor amendments to the wording;

* Recognition that Character Area ii - the Cultural Area includes the named Civic Core Conservation Area and many listed and locally listed buildings. Additional clarity is considered particularly necessary given that the Environmental Report accompanying the policy document determines that the impact of the character area designation on 'heritage' is neutral (See Page 41 of the Environmental Report accompanying the submission)..
* Recognition that the Palace Theatre and Colosseum are Grade II listed buildings.
* The text relating to Character Area vii - Heritage Area St Mary's and High Street/King Street Conservation Areas does not reflect the amendment requested in our letter of February 2016 which requested the following addition;
The primary concern in these areas is the impact of any proposed development on the designated heritage assets. The Council will expect proposals for development in these areas to actively seek to enhance the identified character and appearance of the conservation areas and the settings of the listed buildings and other heritage assets within and adjoining them.

We are supportive of the Council's encouragement of the redevelopment of the Church Car Park as this is an opportunity to better respond to the Grade I St Mary's Church and the thirteen Grade II structures in its immediate locality, including Watford's remaining Tudor houses the Grade II listed Bedford Alms Houses. The setting of the church is an important part of its significance and developers should be asked to give this careful consideration to this building of exceptional national significance. As such, we again request the above addition to the policy wording.
Policy EMP4 - Change of Use from B Class Outside of Designated Employment Areas

We request that the sentence The proposal must also be compatible with surrounding uses be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that compatibility with surrounding uses does not overcome the need to consider the historic environment and relevant policies within the Local Plan.

Policy EMP5 - Clarendon Road, Station Road and Bridle Path Office Area

This area contains a number of locally listed buildings the retention of which would be beneficial to refer to within this policy to offer them a degree of protection. Retention of these locally listed buildings could enhance the townscape and character of the future office quarter and we encourage reference to them within this policy.

Policy SD6 - Renewable Energy Technology , Policy SD15 - External Lighting Policy & Policy INF2 - Mobile Communications

We are pleased to see the incorporation of the historic environment within the text of these policies. We recommend that the last bullet point in Policy SD15 - External Lighting Policy be altered from heritage assets to historic environment for consistency and to allow greater flexibility in protecting the historic environment beyond designated assets.

Policy TB1 - Location of taller buildings

We are disappointed to note that our detailed advice of February 2016 has not translated into amendments to the wording of the draft policies.

We again submit the following suggested amendments, in the awareness that the proposed locations are in close proximity to the historic core of Watford, several listed and locally listed buildings and Conservation Areas.

The majority of Watford is characterised by low level residential and other forms of development where taller buildings would generally be considered inappropriate. All development needs to be designed in order to respect, reinforce and enhance the local character, including historic character, of the area in which it is located and to contribute to Watford's distinctive sense of place and identity as referred to in Policy UD1 of the Core Strategy....

... (Watford Junction SPA2): The Watford Junction Masterplan should be referred to for further detail on how the pinnacles should be incorporated into the wider townscape and to achieve a positive strategy for the conservation and enjoyment of the historic environment.

The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage (See page 62 of the Environmental Report).

Policy TB2 - Design of Taller Buildings

Please alter 'heritage assets' to 'the historic environment' throughout the document to ensure the widest possible application of the policy to historic places and non-designated heritage assets.

We recommend the inclusion of 'high' in front of quality within the discussion of public realm (point 8).

We note that Criterion 10 - Heritage has been removed. As a result it is particularly important to ensure that the remaining criteria adequately allow for protection of the historic environment.

We note that the accompanying Environmental Report finds that the impact of Policy TB2 is positive or 'sustainable' with regard to Watford's Historic Environment (see page 62 of the accompanying Heritage Report). The change of terminology from within the policy text from heritage assets to historic environment may assist in mitigating harm from taller buildings to ensure that the policy can be considered sustainable.

Appendix I - Site Schedules

We reiterate our comment that we would not normally expect to offer substantive changes to the Local Plan at submission stage. However, as previous suggestions have not been incorporated with regard to the historic environment and clarity of presentation of heritage considerations, we request the following revisions to the text.

These changes will be necessary to ensure that the plan adequately takes into account the desirability of sustaining and enhancing the significance of heritage asserts and identifies opportunities to draw on the contribution made by the historic environment to the character of Watford.

Site Comments Justification
SPA1 - Town Centre Replace 'Heritage assets' with The Historic Environment. Please add the following point: Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Little Cassiobury and Former Stable Blocks (registered on the national Heritage at Risk register) will be given significant weight. The historic environment encompasses more than designated heritage assets. The NPPF requires that a local plan sets out a positive strategy for conservation and enjoyment of the historic environment including heritage assets most at risk through neglect, decay or other threats. As this Grade II* listed building, which is on the Heritage at Risk register is not otherwise mentioned within the Local Plan, it is appropriate to mention a positive strategy for its conservation in Policy SPA1. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA2 - Watford Junction Please replace 4th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the adjacent Nascot Conservation Area, Grade II listed Benskins House (The Flag Public House), Reeds Crescent and other heritage assets within the area. Within the site, the conservation of the Grade II listed Old Station House and its setting should form part of the proposals. For consistency with the remaining policies, we recommend naming and grading the listed heritage assets referred to. For continuity with previous consultations, locally listed Reeds Crescent is retained as a named asset. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different name, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. Grade II Old Station House is within the site and its conservation should therefore be given emphasis. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA3 - Health Campus Please insert the preservation and enhancement of the setting of before 'the Square Conservation Area' at Bullet Point 9. Reuse of Grade I Iisted Shrodells Wing of Watford General Hospital is welcome (We note a typographical error in its name [Grade II listed) ) as is due consideration to the Square Conservation Area.
SPA4 - Lower High Street Please replace 6th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street and the Grade II listed Bushey Arches. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. This is amended for consistency of approach with regard to heritage assets and to ensure that all of the nine listed buildings/structures and other locally listed buildings within the site are captured, not just the two mentioned. Reference to Grade II* listed Frogmore House is amended for consistency with Little Cassiobury at Policy SPA1. The wording seeks an appropriate scheme of repair and reuse rather than 'restoration' which has a specific meaning in terms of conservation and may not be appropriate. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA5 - Dome Roundabout No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA6 - Western Gateway No comment As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site MXD1 - North Watford Library/ Lemarie Centre No comment No comment
Site MXD2 - The Brow No comment No comment
Site MXD3 - Gas Holder Site Please add: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. We welcome the requirement for archaeological assessment and a heritage statement. We reiterate our comments with regard to Policy SPA4.
Site MXD4 - Ascot Road No comment No comment
Site R1 - Sainsbury's and adjoining land Please replace the 4th Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Monmouth House and Nos. 151-153 High Street. Proposals should preserve and enhance the Civic Core Conservation Area and its setting. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street and a potential Roman Road, and adjacent to the point that they are believed to meet we request archaeological assessment where appropriate.
Site R2 - Former TJ Hughes and adjoining land Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Palace Theatre, Beechen Grove Baptist Church and Nos. 14-16 The Parade as well as locally listed buildings at Nos. 11-33 The Parade. Proposals should preserve and enhance the setting of the adjacent Civic Core Conservation Area. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R3 - BT Telephone Exchange and adjoining warehouses Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 14-16 and No 58 High Street which will be expected to be retained. The significance and setting of the adjacent Grade I listed Holy Rood Church and St. Mary's Church and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is in the vicinity of two Grade I listed buildings. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R4 - Church Street Car Park and land fronting Market Street Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade I listed building of St Mary's Church and Grade II* listed Elizabeth Fuller Free School and the cluster of Grade II buildings and structures to the south of the site. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is within the core of surviving historic buildings and open spaces within Watford, including Grade I St.Mary's church and its open setting. Please note that the Elizabeth Fuller Free School is Grade II* listed, not Grade II listed as noted in the consultation document wording. As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site R5 - Charter Place Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 63-65 High Street which will be expected to be retained. The significance and setting of the adjacent Grade II listed No. 58 High Street, the Beechen Grove Baptist Chapel and the Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan. We request the removal of any reference to the frontage of Nos. 63-65 High Street which may encourage façade retention rather than the more appropriate retention of the building as a whole. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
Site CF1 - Tolpits Community Facility No comment No comment
Site H1 - Pinner Road Please replace the 7th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Oxhey Conservation Area, nearby Grade II listed buildings and other heritage assets within the area, particularly the locally listed Railway Arms Public House. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H2 - Skate Park, Lower Derby Road No comment No comment
Site H3 - Vicarage Road Please replace the 5th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Red Lion Public House and Watford Printers Buildings and the Square Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H4 - Telephone Exchange, First Avenue No comment No comment
Site H5 - Builders Yard, Queens Avenue No comment No comment
Site H6 - Bill Everett Centre No comment No comment
Site H7 - Rickmansworth Road Please replace the 1st bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of Nos. 195-199 Rickmansworth Road. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H8 - Garages, Gossamers No comment No comment
Site H9 - Metropolitan Station, Cassiobury Park Avenue Please replace the 3rd bullet point up to 'is required' with Design and development will need to be sympathetic to the significance and setting of the Grade II listed Watford Station. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H10 - Croxley View No comment No comment
Site H11 - Garages Bowman's View No comment No comment
Site GT1 - Land at Tolpits Lane No comment No comment
Site E1 - Watford Business Park No comment No comment
Site E2 - Imperial Way/Colonial Way No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site E3 - Fishers No comment No comment
Site E4 - Greycaine Road Please replace the 3rd bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Paramount Industrial Estate and Former Odhams Press Hall. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street we request archaeological assessment where appropriate.
Site E5 - Clarendon Road Please replace 2nd Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the Grade II listed Benskins House (The Flag Public House) and the Beechen Grove Baptist Chapel and locally listed buildings clustered around Clarendon Road which will be expected to be retained. The significance and setting of the adjacent Grade II listed Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the setting of the adjacent Estcourt Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan.. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different names, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
Site E6 - Leavesden Studios No comment No comment

DRAFT WATFORD JUNCTION DEVELOPMENT BRIEF

Thank you for consulting Historic England on the submission draft of the Watford Junction: Draft Development Brief (August 2016).

We encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers. We are aware of the many social and economic benefits that the development of the Watford Junction area aims to bring about.

Having reviewed the draft development brief we are concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness.

We are particularly keen to see a positive strategy for the conservation of the historic environment incorporated as part of the vision for the area. This would then cascade into the subsequent development briefs for individual sites. The historic environment is greater than a list of designated assets and encompasses locally listed buildings, character areas, the area's historic development, use patterns, street morphology and social history and a successful development brief should seek to draw on the elements of an area's historic character that make it unique and distinctive. Successful developments balance historic character with the other positive aims of placemaking to make locally distinctive places.

The Draft Masterplan is to be adopted as a Local Plan document and should therefore respond to the NPPF's requirement that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment.
To appropriately address this requirement, we recommend that the Baseline Assessment acknowledges the designated heritage assets within and directly adjacent to the site and identifies that the masterplan is an opportunity to draw on the contribution that the historic environment makes to local character.

The baseline assessment should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings.

Some, but not all of the listed buildings are marked on the Opportunities Map within the Baseline Assessment (the Former London Orphan Asylum is omitted for instance). If these are to be marked, we request that all of the listed buildings within a defined radius are properly mapped to avoid giving the impression that the setting of some are more acceptable to respond to than others. None of the Locally Listed Buildings nor Conservation Areas are included. We suggest that the draft document reflects the information contained within Watford's Conservation Areas Management Plan (2013).

We strongly encourage the acknowledgement and recognition of the historic environment as an opportunity within the SWOT analysis within the baseline assessment and that the retention and conservation of the Grade II Listed Building be made an explicit aim of the document.

The Vision and Objectives page should reflect the positive conservation of the historic environment and acknowledge this as a critical element of successful placemaking. We recommend that an additional objective be added to draw on the contributions of the historic environment to produce a locally distinctive place.
We note that the subdivision of the development site into four character quarters fails to include the area of the site that is within the Nascot Conservation Area (and contains the Grade II listed building) within any of the proposed quarters. There is development potential within this neutral part of the Conservation Area which would particularly benefit from guidance as how to appropriately respond to the surrounding Nascot Conservation Area and we would welcome a positive approach to development in this location. This area, identified as Area 21 in the General Masterplan maps contained within the Area Schedule is also omitted from a dedicated analysis of a suitable quantum of development, provided for other identified sub-areas within the area schedule.

We recommend that the possible development of this area be addressed within any revised document.

In making any revisions to the document, we recommend that Historic England's guidance note 'The Historic Environment in Local Plans: Good Practice Advice in Planning 1' is considered and its recommendations incorporated into any subsequent draft.

This document can be found at the following location:
<https://content.historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1.pdf/>

I would also recommend that you review the following guidance which may be of assistance to you to produce robust policies on tall buildings and placemaking appropriate to the aims of the NPPF in terms of conservation of the historic environment:

<https://content.historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/heag037-tall-buildings.pdf/>

<https://content.historicengland.org.uk/images-books/publications/streets-for-all-east-of-england/east-eng-streets.pdf/>

Croxley View/ Ascot Road Study

Thank you for consulting Historic England on the draft Croxley View / Ascot Road Study. We note that there are no Historic Assets on site but note the Grade II listed building Cassio Bridge Lodge is sited to the north of the site and we encourage that any development proposals are considered with regard to setting of this building.
We have no comments to make on the developing brief.

Summary

In preparation of all local plan documents, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime, we look forward to continuing to work with you and your colleagues in the preparation of the Local Plan documents.

Support

Watford Junction Draft Development Brief 2016

Watford Junction Draft Development Brief

Representation ID: 718

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers.

Full text:

Consultation Responses

a) Watford Local Plan - Part 2: Site Allocations and Development Management Policies - Publication Version July 2016 and accompanying Watford Local Plan Part 2 Publication Stage Environmental Report August 2016.

b) Draft Watford Junction Development Brief

c) Croxley View/Ascot Road Study

WATFORD LOCAL PLAN - PART 2: SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES - PUBLICATION VERSION JULY 2016 AND ACCOMPANYING WATFORD LOCAL PLAN PART 2 PUBLICATION STAGE ENVIRONMENTAL REPORT AUGUST 2016.

Thank you for consulting Historic England on the submission draft of the Local Plan Site Allocations and Development Management Policies Document.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.

We very much welcome the references to the historic environment made throughout the draft development framework document and appreciate the effort made to acknowledge the positive contribution to character and placemaking that the historic environment can bring. The document has been set out clearly and is commendably accessible in format. The following amendments are therefore suggested to ensure that the draft SPD fully reflects the statutory requirement to take into account opportunities to draw on the contribution made by all elements of the historic environment.

You will note that we have previously responded to earlier drafts of this document in February 2015 and to an addendum incorporating a Taller Buildings policy in February 2016. Whilst we commended the Borough's comprehensive evidence base incorporating Conservation Area Appraisals and a managed local list of locally important structures, we also requested that some changes be made to the document; particularly consistency of approach to the conservation and enhancement of the historic environment.

Whilst we would not normally expect to offer substantive comment at submission stage, we note that few of the changes requested at earlier stages have been incorporated into the final submission document and this response therefore reiterates our preferred changes to ensure that the plan adequately sets out a positive strategy for the historic environment as required by the NPPF and fulfils the Sustainable Community Objective to be a town that protects its environment and heritage set out within Watford Borough Council's adopted Core Strategy (2013).
We encourage ongoing dialogue and request to be notified of the date of the Examination in Public by the Secretary of State as we may wish to make representations.

Heritage Policies

Policy UD4 - The Historic Environment

We are pleased to see a specific policy addressing the conservation of the historic environment . However we have the following comments to make regarding necessary changes for a sound Local Plan.

Listed Buildings and their setting

The NPPF requires that when considering the impact of a proposed development on the significance of a designated asset, great weight should be given to the asset's conservation. Significance can be harmed by development within the setting of the listed building and substantial harm (including to the setting of a listed building) should be wholly exceptional.

By separating the 'setting of a listed building' from the section on 'listed buildings', the plan implies that a lesser degree of significance is accorded to the setting of a listed building than to a listed building itself.

As submitted, references to the need for wholly exceptional circumstances refer only to the demolition of listed buildings. This does not reflect the NPPF which sets out that substantial harm or loss of highly significant listed buildings (Grade II* or I), which can include harm to the setting of such a building, should be wholly exceptional.

We are also concerned that in consideration of setting, the current policy states that in the event of harm to or loss of significance, this should be weighed against public benefit. This is the role of the planning system but we feel that a more robust strategy for the conservation of the historic environment should set out that harm or loss of significance of the setting of a listed building will not be acceptable.
We strongly encourage the Borough to combine listed buildings and their setting for a robust and NPPF compliant policy that sets out a positive strategy for the conservation and enjoyment of historic environment.

Development in the vicinity of a listed building

We request the following amendment to ensure that the Council's policy for the conservation of the historic environment is appropriate to ensure that listed buildings are given due consideration in the determination of planning applications for development. Without this alteration, the policy relates solely to development of the listed building itself with no other policy for the protection of the significance of listed buildings when development is beyond the listed building.

The Council will preserve the character and setting of the borough's listed buildings and will support applications where:

* The extension/alteration of a listed building development would not adversely affect its character as a building of special architectural or historic interest; both internally and externally, or adversely affect its wider setting.

Conservation Areas

We request the following minor amendments;

Within conservation areas, development will be supported where it:

* Uses materials, finishes, including those for features such as walls, railings, gates and hard surfacing, that are appropriate to local context preserve or enhance the character of the Conservation Area.
* Results, where relevant, in the removal of unsympathetic features and the restoration or reinstatement of missing features.

All other bullet points are supported as consulted.

Demolition in Conservation Areas

We encourage robust policy protection for Conservation Areas and we are pleased to see this addressed within the local plan. We caution however, that the local plan should not be more stringent than the requirements within the NPPF as this may weaken the application of the policy. As such, the first and third bullet points are very welcome. The intent of the second bullet point is understood. This may be a hard policy test in practice however, as, theoretically, all buildings are capable of repair and some beneficial use, even if not suitable or viable. We caution that the use of a difficult test may lead to the entire policy (and decisions based on it) which seek to appropriately conserve the historic environment being challenged at appeal. We suggest that this bullet point is omitted to strengthen the policy.

We request the following omission from the text;
Permission will not be granted for development outside of but near to a conservation area which adversely affects the setting, character, appearance of or views into and out of that conservation area.

This allows for consideration of any affects to a Conservation Area without having to define the difficult question of what is 'near' to the site or not.

Future Designations

Watford Borough Council has a commendable history of local listing, conservation area appraisal and review of its surviving historic environment. It would be a positive strategy to embed this positive approach to heritage conservation within the draft local plan with a policy supporting future designations of locally listed buildings, registered parks and gardens and other heritage assets,

General Comments

Glossary

Listed Buildings and Locally Listed Buildings appear twice. In each case, the first definition is the most appropriate.

Policy SPMX1 - Special Policy Areas

This omits the wording suggested in our previous letter dated 04/02/15 which requested that the sentence Development proposals should accord with the related Core Strategy Policy be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that the principle of development does not override the need to comply with other adopted policies including those that seek to enhance and protect the historic environment.

Policy SPMX2 - Mixed Use Allocations Policy

As this policy states that development will be appropriate on these sites, it is important to ensure that the historic environment is appropriately considered. The mechanism for this is through robust development considerations as set out in Appendix I.

These are acceptable in many places but references to the historic environment are not consistently presented and in some cases there are gaps, as set out in our previous advice of February 2015. In some of these sites, heritage assets in the locality are named and even graded where in others they are partially identified or omitted altogether, even where they are within the allocated site. For this reason I have reviewed the wording of each site within Appendix I - Site Schedules in the table attached to these comments and request that any suggested changes be incorporated to ensure that the protection and enhancement of the historic environment is a consideration for future developers and not contrary to the presumption in favour of development.

See attached table for detailed comment on Appendix I.

Policy TLC9 - Character Areas

This policy refers to the character areas within Watford Town Centre. We would welcome the following minor amendments to the wording;

* Recognition that Character Area ii - the Cultural Area includes the named Civic Core Conservation Area and many listed and locally listed buildings. Additional clarity is considered particularly necessary given that the Environmental Report accompanying the policy document determines that the impact of the character area designation on 'heritage' is neutral (See Page 41 of the Environmental Report accompanying the submission)..
* Recognition that the Palace Theatre and Colosseum are Grade II listed buildings.
* The text relating to Character Area vii - Heritage Area St Mary's and High Street/King Street Conservation Areas does not reflect the amendment requested in our letter of February 2016 which requested the following addition;
The primary concern in these areas is the impact of any proposed development on the designated heritage assets. The Council will expect proposals for development in these areas to actively seek to enhance the identified character and appearance of the conservation areas and the settings of the listed buildings and other heritage assets within and adjoining them.

We are supportive of the Council's encouragement of the redevelopment of the Church Car Park as this is an opportunity to better respond to the Grade I St Mary's Church and the thirteen Grade II structures in its immediate locality, including Watford's remaining Tudor houses the Grade II listed Bedford Alms Houses. The setting of the church is an important part of its significance and developers should be asked to give this careful consideration to this building of exceptional national significance. As such, we again request the above addition to the policy wording.
Policy EMP4 - Change of Use from B Class Outside of Designated Employment Areas

We request that the sentence The proposal must also be compatible with surrounding uses be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that compatibility with surrounding uses does not overcome the need to consider the historic environment and relevant policies within the Local Plan.

Policy EMP5 - Clarendon Road, Station Road and Bridle Path Office Area

This area contains a number of locally listed buildings the retention of which would be beneficial to refer to within this policy to offer them a degree of protection. Retention of these locally listed buildings could enhance the townscape and character of the future office quarter and we encourage reference to them within this policy.

Policy SD6 - Renewable Energy Technology , Policy SD15 - External Lighting Policy & Policy INF2 - Mobile Communications

We are pleased to see the incorporation of the historic environment within the text of these policies. We recommend that the last bullet point in Policy SD15 - External Lighting Policy be altered from heritage assets to historic environment for consistency and to allow greater flexibility in protecting the historic environment beyond designated assets.

Policy TB1 - Location of taller buildings

We are disappointed to note that our detailed advice of February 2016 has not translated into amendments to the wording of the draft policies.

We again submit the following suggested amendments, in the awareness that the proposed locations are in close proximity to the historic core of Watford, several listed and locally listed buildings and Conservation Areas.

The majority of Watford is characterised by low level residential and other forms of development where taller buildings would generally be considered inappropriate. All development needs to be designed in order to respect, reinforce and enhance the local character, including historic character, of the area in which it is located and to contribute to Watford's distinctive sense of place and identity as referred to in Policy UD1 of the Core Strategy....

... (Watford Junction SPA2): The Watford Junction Masterplan should be referred to for further detail on how the pinnacles should be incorporated into the wider townscape and to achieve a positive strategy for the conservation and enjoyment of the historic environment.

The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage (See page 62 of the Environmental Report).

Policy TB2 - Design of Taller Buildings

Please alter 'heritage assets' to 'the historic environment' throughout the document to ensure the widest possible application of the policy to historic places and non-designated heritage assets.

We recommend the inclusion of 'high' in front of quality within the discussion of public realm (point 8).

We note that Criterion 10 - Heritage has been removed. As a result it is particularly important to ensure that the remaining criteria adequately allow for protection of the historic environment.

We note that the accompanying Environmental Report finds that the impact of Policy TB2 is positive or 'sustainable' with regard to Watford's Historic Environment (see page 62 of the accompanying Heritage Report). The change of terminology from within the policy text from heritage assets to historic environment may assist in mitigating harm from taller buildings to ensure that the policy can be considered sustainable.

Appendix I - Site Schedules

We reiterate our comment that we would not normally expect to offer substantive changes to the Local Plan at submission stage. However, as previous suggestions have not been incorporated with regard to the historic environment and clarity of presentation of heritage considerations, we request the following revisions to the text.

These changes will be necessary to ensure that the plan adequately takes into account the desirability of sustaining and enhancing the significance of heritage asserts and identifies opportunities to draw on the contribution made by the historic environment to the character of Watford.

Site Comments Justification
SPA1 - Town Centre Replace 'Heritage assets' with The Historic Environment. Please add the following point: Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Little Cassiobury and Former Stable Blocks (registered on the national Heritage at Risk register) will be given significant weight. The historic environment encompasses more than designated heritage assets. The NPPF requires that a local plan sets out a positive strategy for conservation and enjoyment of the historic environment including heritage assets most at risk through neglect, decay or other threats. As this Grade II* listed building, which is on the Heritage at Risk register is not otherwise mentioned within the Local Plan, it is appropriate to mention a positive strategy for its conservation in Policy SPA1. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA2 - Watford Junction Please replace 4th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the adjacent Nascot Conservation Area, Grade II listed Benskins House (The Flag Public House), Reeds Crescent and other heritage assets within the area. Within the site, the conservation of the Grade II listed Old Station House and its setting should form part of the proposals. For consistency with the remaining policies, we recommend naming and grading the listed heritage assets referred to. For continuity with previous consultations, locally listed Reeds Crescent is retained as a named asset. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different name, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. Grade II Old Station House is within the site and its conservation should therefore be given emphasis. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA3 - Health Campus Please insert the preservation and enhancement of the setting of before 'the Square Conservation Area' at Bullet Point 9. Reuse of Grade I Iisted Shrodells Wing of Watford General Hospital is welcome (We note a typographical error in its name [Grade II listed) ) as is due consideration to the Square Conservation Area.
SPA4 - Lower High Street Please replace 6th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street and the Grade II listed Bushey Arches. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. This is amended for consistency of approach with regard to heritage assets and to ensure that all of the nine listed buildings/structures and other locally listed buildings within the site are captured, not just the two mentioned. Reference to Grade II* listed Frogmore House is amended for consistency with Little Cassiobury at Policy SPA1. The wording seeks an appropriate scheme of repair and reuse rather than 'restoration' which has a specific meaning in terms of conservation and may not be appropriate. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA5 - Dome Roundabout No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA6 - Western Gateway No comment As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site MXD1 - North Watford Library/ Lemarie Centre No comment No comment
Site MXD2 - The Brow No comment No comment
Site MXD3 - Gas Holder Site Please add: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. We welcome the requirement for archaeological assessment and a heritage statement. We reiterate our comments with regard to Policy SPA4.
Site MXD4 - Ascot Road No comment No comment
Site R1 - Sainsbury's and adjoining land Please replace the 4th Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Monmouth House and Nos. 151-153 High Street. Proposals should preserve and enhance the Civic Core Conservation Area and its setting. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street and a potential Roman Road, and adjacent to the point that they are believed to meet we request archaeological assessment where appropriate.
Site R2 - Former TJ Hughes and adjoining land Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Palace Theatre, Beechen Grove Baptist Church and Nos. 14-16 The Parade as well as locally listed buildings at Nos. 11-33 The Parade. Proposals should preserve and enhance the setting of the adjacent Civic Core Conservation Area. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R3 - BT Telephone Exchange and adjoining warehouses Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 14-16 and No 58 High Street which will be expected to be retained. The significance and setting of the adjacent Grade I listed Holy Rood Church and St. Mary's Church and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is in the vicinity of two Grade I listed buildings. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R4 - Church Street Car Park and land fronting Market Street Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade I listed building of St Mary's Church and Grade II* listed Elizabeth Fuller Free School and the cluster of Grade II buildings and structures to the south of the site. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is within the core of surviving historic buildings and open spaces within Watford, including Grade I St.Mary's church and its open setting. Please note that the Elizabeth Fuller Free School is Grade II* listed, not Grade II listed as noted in the consultation document wording. As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site R5 - Charter Place Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 63-65 High Street which will be expected to be retained. The significance and setting of the adjacent Grade II listed No. 58 High Street, the Beechen Grove Baptist Chapel and the Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan. We request the removal of any reference to the frontage of Nos. 63-65 High Street which may encourage façade retention rather than the more appropriate retention of the building as a whole. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
Site CF1 - Tolpits Community Facility No comment No comment
Site H1 - Pinner Road Please replace the 7th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Oxhey Conservation Area, nearby Grade II listed buildings and other heritage assets within the area, particularly the locally listed Railway Arms Public House. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H2 - Skate Park, Lower Derby Road No comment No comment
Site H3 - Vicarage Road Please replace the 5th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Red Lion Public House and Watford Printers Buildings and the Square Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H4 - Telephone Exchange, First Avenue No comment No comment
Site H5 - Builders Yard, Queens Avenue No comment No comment
Site H6 - Bill Everett Centre No comment No comment
Site H7 - Rickmansworth Road Please replace the 1st bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of Nos. 195-199 Rickmansworth Road. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H8 - Garages, Gossamers No comment No comment
Site H9 - Metropolitan Station, Cassiobury Park Avenue Please replace the 3rd bullet point up to 'is required' with Design and development will need to be sympathetic to the significance and setting of the Grade II listed Watford Station. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H10 - Croxley View No comment No comment
Site H11 - Garages Bowman's View No comment No comment
Site GT1 - Land at Tolpits Lane No comment No comment
Site E1 - Watford Business Park No comment No comment
Site E2 - Imperial Way/Colonial Way No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site E3 - Fishers No comment No comment
Site E4 - Greycaine Road Please replace the 3rd bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Paramount Industrial Estate and Former Odhams Press Hall. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street we request archaeological assessment where appropriate.
Site E5 - Clarendon Road Please replace 2nd Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the Grade II listed Benskins House (The Flag Public House) and the Beechen Grove Baptist Chapel and locally listed buildings clustered around Clarendon Road which will be expected to be retained. The significance and setting of the adjacent Grade II listed Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the setting of the adjacent Estcourt Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan.. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different names, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
Site E6 - Leavesden Studios No comment No comment

DRAFT WATFORD JUNCTION DEVELOPMENT BRIEF

Thank you for consulting Historic England on the submission draft of the Watford Junction: Draft Development Brief (August 2016).

We encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers. We are aware of the many social and economic benefits that the development of the Watford Junction area aims to bring about.

Having reviewed the draft development brief we are concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness.

We are particularly keen to see a positive strategy for the conservation of the historic environment incorporated as part of the vision for the area. This would then cascade into the subsequent development briefs for individual sites. The historic environment is greater than a list of designated assets and encompasses locally listed buildings, character areas, the area's historic development, use patterns, street morphology and social history and a successful development brief should seek to draw on the elements of an area's historic character that make it unique and distinctive. Successful developments balance historic character with the other positive aims of placemaking to make locally distinctive places.

The Draft Masterplan is to be adopted as a Local Plan document and should therefore respond to the NPPF's requirement that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment.
To appropriately address this requirement, we recommend that the Baseline Assessment acknowledges the designated heritage assets within and directly adjacent to the site and identifies that the masterplan is an opportunity to draw on the contribution that the historic environment makes to local character.

The baseline assessment should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings.

Some, but not all of the listed buildings are marked on the Opportunities Map within the Baseline Assessment (the Former London Orphan Asylum is omitted for instance). If these are to be marked, we request that all of the listed buildings within a defined radius are properly mapped to avoid giving the impression that the setting of some are more acceptable to respond to than others. None of the Locally Listed Buildings nor Conservation Areas are included. We suggest that the draft document reflects the information contained within Watford's Conservation Areas Management Plan (2013).

We strongly encourage the acknowledgement and recognition of the historic environment as an opportunity within the SWOT analysis within the baseline assessment and that the retention and conservation of the Grade II Listed Building be made an explicit aim of the document.

The Vision and Objectives page should reflect the positive conservation of the historic environment and acknowledge this as a critical element of successful placemaking. We recommend that an additional objective be added to draw on the contributions of the historic environment to produce a locally distinctive place.
We note that the subdivision of the development site into four character quarters fails to include the area of the site that is within the Nascot Conservation Area (and contains the Grade II listed building) within any of the proposed quarters. There is development potential within this neutral part of the Conservation Area which would particularly benefit from guidance as how to appropriately respond to the surrounding Nascot Conservation Area and we would welcome a positive approach to development in this location. This area, identified as Area 21 in the General Masterplan maps contained within the Area Schedule is also omitted from a dedicated analysis of a suitable quantum of development, provided for other identified sub-areas within the area schedule.

We recommend that the possible development of this area be addressed within any revised document.

In making any revisions to the document, we recommend that Historic England's guidance note 'The Historic Environment in Local Plans: Good Practice Advice in Planning 1' is considered and its recommendations incorporated into any subsequent draft.

This document can be found at the following location:
<https://content.historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1.pdf/>

I would also recommend that you review the following guidance which may be of assistance to you to produce robust policies on tall buildings and placemaking appropriate to the aims of the NPPF in terms of conservation of the historic environment:

<https://content.historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/heag037-tall-buildings.pdf/>

<https://content.historicengland.org.uk/images-books/publications/streets-for-all-east-of-england/east-eng-streets.pdf/>

Croxley View/ Ascot Road Study

Thank you for consulting Historic England on the draft Croxley View / Ascot Road Study. We note that there are no Historic Assets on site but note the Grade II listed building Cassio Bridge Lodge is sited to the north of the site and we encourage that any development proposals are considered with regard to setting of this building.
We have no comments to make on the developing brief.

Summary

In preparation of all local plan documents, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime, we look forward to continuing to work with you and your colleagues in the preparation of the Local Plan documents.

Comment

Watford Junction Draft Development Brief 2016

Watford Junction Draft Development Brief

Representation ID: 719

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Recommend that an additional objective be added to the vision and objectives page to draw on the opportunities of the historic environment to produce a locally distinctive place.

Full text:

Consultation Responses

a) Watford Local Plan - Part 2: Site Allocations and Development Management Policies - Publication Version July 2016 and accompanying Watford Local Plan Part 2 Publication Stage Environmental Report August 2016.

b) Draft Watford Junction Development Brief

c) Croxley View/Ascot Road Study

WATFORD LOCAL PLAN - PART 2: SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES - PUBLICATION VERSION JULY 2016 AND ACCOMPANYING WATFORD LOCAL PLAN PART 2 PUBLICATION STAGE ENVIRONMENTAL REPORT AUGUST 2016.

Thank you for consulting Historic England on the submission draft of the Local Plan Site Allocations and Development Management Policies Document.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.

We very much welcome the references to the historic environment made throughout the draft development framework document and appreciate the effort made to acknowledge the positive contribution to character and placemaking that the historic environment can bring. The document has been set out clearly and is commendably accessible in format. The following amendments are therefore suggested to ensure that the draft SPD fully reflects the statutory requirement to take into account opportunities to draw on the contribution made by all elements of the historic environment.

You will note that we have previously responded to earlier drafts of this document in February 2015 and to an addendum incorporating a Taller Buildings policy in February 2016. Whilst we commended the Borough's comprehensive evidence base incorporating Conservation Area Appraisals and a managed local list of locally important structures, we also requested that some changes be made to the document; particularly consistency of approach to the conservation and enhancement of the historic environment.

Whilst we would not normally expect to offer substantive comment at submission stage, we note that few of the changes requested at earlier stages have been incorporated into the final submission document and this response therefore reiterates our preferred changes to ensure that the plan adequately sets out a positive strategy for the historic environment as required by the NPPF and fulfils the Sustainable Community Objective to be a town that protects its environment and heritage set out within Watford Borough Council's adopted Core Strategy (2013).
We encourage ongoing dialogue and request to be notified of the date of the Examination in Public by the Secretary of State as we may wish to make representations.

Heritage Policies

Policy UD4 - The Historic Environment

We are pleased to see a specific policy addressing the conservation of the historic environment . However we have the following comments to make regarding necessary changes for a sound Local Plan.

Listed Buildings and their setting

The NPPF requires that when considering the impact of a proposed development on the significance of a designated asset, great weight should be given to the asset's conservation. Significance can be harmed by development within the setting of the listed building and substantial harm (including to the setting of a listed building) should be wholly exceptional.

By separating the 'setting of a listed building' from the section on 'listed buildings', the plan implies that a lesser degree of significance is accorded to the setting of a listed building than to a listed building itself.

As submitted, references to the need for wholly exceptional circumstances refer only to the demolition of listed buildings. This does not reflect the NPPF which sets out that substantial harm or loss of highly significant listed buildings (Grade II* or I), which can include harm to the setting of such a building, should be wholly exceptional.

We are also concerned that in consideration of setting, the current policy states that in the event of harm to or loss of significance, this should be weighed against public benefit. This is the role of the planning system but we feel that a more robust strategy for the conservation of the historic environment should set out that harm or loss of significance of the setting of a listed building will not be acceptable.
We strongly encourage the Borough to combine listed buildings and their setting for a robust and NPPF compliant policy that sets out a positive strategy for the conservation and enjoyment of historic environment.

Development in the vicinity of a listed building

We request the following amendment to ensure that the Council's policy for the conservation of the historic environment is appropriate to ensure that listed buildings are given due consideration in the determination of planning applications for development. Without this alteration, the policy relates solely to development of the listed building itself with no other policy for the protection of the significance of listed buildings when development is beyond the listed building.

The Council will preserve the character and setting of the borough's listed buildings and will support applications where:

* The extension/alteration of a listed building development would not adversely affect its character as a building of special architectural or historic interest; both internally and externally, or adversely affect its wider setting.

Conservation Areas

We request the following minor amendments;

Within conservation areas, development will be supported where it:

* Uses materials, finishes, including those for features such as walls, railings, gates and hard surfacing, that are appropriate to local context preserve or enhance the character of the Conservation Area.
* Results, where relevant, in the removal of unsympathetic features and the restoration or reinstatement of missing features.

All other bullet points are supported as consulted.

Demolition in Conservation Areas

We encourage robust policy protection for Conservation Areas and we are pleased to see this addressed within the local plan. We caution however, that the local plan should not be more stringent than the requirements within the NPPF as this may weaken the application of the policy. As such, the first and third bullet points are very welcome. The intent of the second bullet point is understood. This may be a hard policy test in practice however, as, theoretically, all buildings are capable of repair and some beneficial use, even if not suitable or viable. We caution that the use of a difficult test may lead to the entire policy (and decisions based on it) which seek to appropriately conserve the historic environment being challenged at appeal. We suggest that this bullet point is omitted to strengthen the policy.

We request the following omission from the text;
Permission will not be granted for development outside of but near to a conservation area which adversely affects the setting, character, appearance of or views into and out of that conservation area.

This allows for consideration of any affects to a Conservation Area without having to define the difficult question of what is 'near' to the site or not.

Future Designations

Watford Borough Council has a commendable history of local listing, conservation area appraisal and review of its surviving historic environment. It would be a positive strategy to embed this positive approach to heritage conservation within the draft local plan with a policy supporting future designations of locally listed buildings, registered parks and gardens and other heritage assets,

General Comments

Glossary

Listed Buildings and Locally Listed Buildings appear twice. In each case, the first definition is the most appropriate.

Policy SPMX1 - Special Policy Areas

This omits the wording suggested in our previous letter dated 04/02/15 which requested that the sentence Development proposals should accord with the related Core Strategy Policy be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that the principle of development does not override the need to comply with other adopted policies including those that seek to enhance and protect the historic environment.

Policy SPMX2 - Mixed Use Allocations Policy

As this policy states that development will be appropriate on these sites, it is important to ensure that the historic environment is appropriately considered. The mechanism for this is through robust development considerations as set out in Appendix I.

These are acceptable in many places but references to the historic environment are not consistently presented and in some cases there are gaps, as set out in our previous advice of February 2015. In some of these sites, heritage assets in the locality are named and even graded where in others they are partially identified or omitted altogether, even where they are within the allocated site. For this reason I have reviewed the wording of each site within Appendix I - Site Schedules in the table attached to these comments and request that any suggested changes be incorporated to ensure that the protection and enhancement of the historic environment is a consideration for future developers and not contrary to the presumption in favour of development.

See attached table for detailed comment on Appendix I.

Policy TLC9 - Character Areas

This policy refers to the character areas within Watford Town Centre. We would welcome the following minor amendments to the wording;

* Recognition that Character Area ii - the Cultural Area includes the named Civic Core Conservation Area and many listed and locally listed buildings. Additional clarity is considered particularly necessary given that the Environmental Report accompanying the policy document determines that the impact of the character area designation on 'heritage' is neutral (See Page 41 of the Environmental Report accompanying the submission)..
* Recognition that the Palace Theatre and Colosseum are Grade II listed buildings.
* The text relating to Character Area vii - Heritage Area St Mary's and High Street/King Street Conservation Areas does not reflect the amendment requested in our letter of February 2016 which requested the following addition;
The primary concern in these areas is the impact of any proposed development on the designated heritage assets. The Council will expect proposals for development in these areas to actively seek to enhance the identified character and appearance of the conservation areas and the settings of the listed buildings and other heritage assets within and adjoining them.

We are supportive of the Council's encouragement of the redevelopment of the Church Car Park as this is an opportunity to better respond to the Grade I St Mary's Church and the thirteen Grade II structures in its immediate locality, including Watford's remaining Tudor houses the Grade II listed Bedford Alms Houses. The setting of the church is an important part of its significance and developers should be asked to give this careful consideration to this building of exceptional national significance. As such, we again request the above addition to the policy wording.
Policy EMP4 - Change of Use from B Class Outside of Designated Employment Areas

We request that the sentence The proposal must also be compatible with surrounding uses be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that compatibility with surrounding uses does not overcome the need to consider the historic environment and relevant policies within the Local Plan.

Policy EMP5 - Clarendon Road, Station Road and Bridle Path Office Area

This area contains a number of locally listed buildings the retention of which would be beneficial to refer to within this policy to offer them a degree of protection. Retention of these locally listed buildings could enhance the townscape and character of the future office quarter and we encourage reference to them within this policy.

Policy SD6 - Renewable Energy Technology , Policy SD15 - External Lighting Policy & Policy INF2 - Mobile Communications

We are pleased to see the incorporation of the historic environment within the text of these policies. We recommend that the last bullet point in Policy SD15 - External Lighting Policy be altered from heritage assets to historic environment for consistency and to allow greater flexibility in protecting the historic environment beyond designated assets.

Policy TB1 - Location of taller buildings

We are disappointed to note that our detailed advice of February 2016 has not translated into amendments to the wording of the draft policies.

We again submit the following suggested amendments, in the awareness that the proposed locations are in close proximity to the historic core of Watford, several listed and locally listed buildings and Conservation Areas.

The majority of Watford is characterised by low level residential and other forms of development where taller buildings would generally be considered inappropriate. All development needs to be designed in order to respect, reinforce and enhance the local character, including historic character, of the area in which it is located and to contribute to Watford's distinctive sense of place and identity as referred to in Policy UD1 of the Core Strategy....

... (Watford Junction SPA2): The Watford Junction Masterplan should be referred to for further detail on how the pinnacles should be incorporated into the wider townscape and to achieve a positive strategy for the conservation and enjoyment of the historic environment.

The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage (See page 62 of the Environmental Report).

Policy TB2 - Design of Taller Buildings

Please alter 'heritage assets' to 'the historic environment' throughout the document to ensure the widest possible application of the policy to historic places and non-designated heritage assets.

We recommend the inclusion of 'high' in front of quality within the discussion of public realm (point 8).

We note that Criterion 10 - Heritage has been removed. As a result it is particularly important to ensure that the remaining criteria adequately allow for protection of the historic environment.

We note that the accompanying Environmental Report finds that the impact of Policy TB2 is positive or 'sustainable' with regard to Watford's Historic Environment (see page 62 of the accompanying Heritage Report). The change of terminology from within the policy text from heritage assets to historic environment may assist in mitigating harm from taller buildings to ensure that the policy can be considered sustainable.

Appendix I - Site Schedules

We reiterate our comment that we would not normally expect to offer substantive changes to the Local Plan at submission stage. However, as previous suggestions have not been incorporated with regard to the historic environment and clarity of presentation of heritage considerations, we request the following revisions to the text.

These changes will be necessary to ensure that the plan adequately takes into account the desirability of sustaining and enhancing the significance of heritage asserts and identifies opportunities to draw on the contribution made by the historic environment to the character of Watford.

Site Comments Justification
SPA1 - Town Centre Replace 'Heritage assets' with The Historic Environment. Please add the following point: Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Little Cassiobury and Former Stable Blocks (registered on the national Heritage at Risk register) will be given significant weight. The historic environment encompasses more than designated heritage assets. The NPPF requires that a local plan sets out a positive strategy for conservation and enjoyment of the historic environment including heritage assets most at risk through neglect, decay or other threats. As this Grade II* listed building, which is on the Heritage at Risk register is not otherwise mentioned within the Local Plan, it is appropriate to mention a positive strategy for its conservation in Policy SPA1. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA2 - Watford Junction Please replace 4th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the adjacent Nascot Conservation Area, Grade II listed Benskins House (The Flag Public House), Reeds Crescent and other heritage assets within the area. Within the site, the conservation of the Grade II listed Old Station House and its setting should form part of the proposals. For consistency with the remaining policies, we recommend naming and grading the listed heritage assets referred to. For continuity with previous consultations, locally listed Reeds Crescent is retained as a named asset. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different name, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. Grade II Old Station House is within the site and its conservation should therefore be given emphasis. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA3 - Health Campus Please insert the preservation and enhancement of the setting of before 'the Square Conservation Area' at Bullet Point 9. Reuse of Grade I Iisted Shrodells Wing of Watford General Hospital is welcome (We note a typographical error in its name [Grade II listed) ) as is due consideration to the Square Conservation Area.
SPA4 - Lower High Street Please replace 6th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street and the Grade II listed Bushey Arches. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. This is amended for consistency of approach with regard to heritage assets and to ensure that all of the nine listed buildings/structures and other locally listed buildings within the site are captured, not just the two mentioned. Reference to Grade II* listed Frogmore House is amended for consistency with Little Cassiobury at Policy SPA1. The wording seeks an appropriate scheme of repair and reuse rather than 'restoration' which has a specific meaning in terms of conservation and may not be appropriate. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA5 - Dome Roundabout No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA6 - Western Gateway No comment As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site MXD1 - North Watford Library/ Lemarie Centre No comment No comment
Site MXD2 - The Brow No comment No comment
Site MXD3 - Gas Holder Site Please add: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. We welcome the requirement for archaeological assessment and a heritage statement. We reiterate our comments with regard to Policy SPA4.
Site MXD4 - Ascot Road No comment No comment
Site R1 - Sainsbury's and adjoining land Please replace the 4th Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Monmouth House and Nos. 151-153 High Street. Proposals should preserve and enhance the Civic Core Conservation Area and its setting. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street and a potential Roman Road, and adjacent to the point that they are believed to meet we request archaeological assessment where appropriate.
Site R2 - Former TJ Hughes and adjoining land Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Palace Theatre, Beechen Grove Baptist Church and Nos. 14-16 The Parade as well as locally listed buildings at Nos. 11-33 The Parade. Proposals should preserve and enhance the setting of the adjacent Civic Core Conservation Area. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R3 - BT Telephone Exchange and adjoining warehouses Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 14-16 and No 58 High Street which will be expected to be retained. The significance and setting of the adjacent Grade I listed Holy Rood Church and St. Mary's Church and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is in the vicinity of two Grade I listed buildings. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R4 - Church Street Car Park and land fronting Market Street Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade I listed building of St Mary's Church and Grade II* listed Elizabeth Fuller Free School and the cluster of Grade II buildings and structures to the south of the site. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is within the core of surviving historic buildings and open spaces within Watford, including Grade I St.Mary's church and its open setting. Please note that the Elizabeth Fuller Free School is Grade II* listed, not Grade II listed as noted in the consultation document wording. As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site R5 - Charter Place Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 63-65 High Street which will be expected to be retained. The significance and setting of the adjacent Grade II listed No. 58 High Street, the Beechen Grove Baptist Chapel and the Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan. We request the removal of any reference to the frontage of Nos. 63-65 High Street which may encourage façade retention rather than the more appropriate retention of the building as a whole. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
Site CF1 - Tolpits Community Facility No comment No comment
Site H1 - Pinner Road Please replace the 7th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Oxhey Conservation Area, nearby Grade II listed buildings and other heritage assets within the area, particularly the locally listed Railway Arms Public House. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H2 - Skate Park, Lower Derby Road No comment No comment
Site H3 - Vicarage Road Please replace the 5th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Red Lion Public House and Watford Printers Buildings and the Square Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H4 - Telephone Exchange, First Avenue No comment No comment
Site H5 - Builders Yard, Queens Avenue No comment No comment
Site H6 - Bill Everett Centre No comment No comment
Site H7 - Rickmansworth Road Please replace the 1st bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of Nos. 195-199 Rickmansworth Road. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H8 - Garages, Gossamers No comment No comment
Site H9 - Metropolitan Station, Cassiobury Park Avenue Please replace the 3rd bullet point up to 'is required' with Design and development will need to be sympathetic to the significance and setting of the Grade II listed Watford Station. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H10 - Croxley View No comment No comment
Site H11 - Garages Bowman's View No comment No comment
Site GT1 - Land at Tolpits Lane No comment No comment
Site E1 - Watford Business Park No comment No comment
Site E2 - Imperial Way/Colonial Way No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site E3 - Fishers No comment No comment
Site E4 - Greycaine Road Please replace the 3rd bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Paramount Industrial Estate and Former Odhams Press Hall. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street we request archaeological assessment where appropriate.
Site E5 - Clarendon Road Please replace 2nd Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the Grade II listed Benskins House (The Flag Public House) and the Beechen Grove Baptist Chapel and locally listed buildings clustered around Clarendon Road which will be expected to be retained. The significance and setting of the adjacent Grade II listed Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the setting of the adjacent Estcourt Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan.. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different names, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
Site E6 - Leavesden Studios No comment No comment

DRAFT WATFORD JUNCTION DEVELOPMENT BRIEF

Thank you for consulting Historic England on the submission draft of the Watford Junction: Draft Development Brief (August 2016).

We encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers. We are aware of the many social and economic benefits that the development of the Watford Junction area aims to bring about.

Having reviewed the draft development brief we are concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness.

We are particularly keen to see a positive strategy for the conservation of the historic environment incorporated as part of the vision for the area. This would then cascade into the subsequent development briefs for individual sites. The historic environment is greater than a list of designated assets and encompasses locally listed buildings, character areas, the area's historic development, use patterns, street morphology and social history and a successful development brief should seek to draw on the elements of an area's historic character that make it unique and distinctive. Successful developments balance historic character with the other positive aims of placemaking to make locally distinctive places.

The Draft Masterplan is to be adopted as a Local Plan document and should therefore respond to the NPPF's requirement that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment.
To appropriately address this requirement, we recommend that the Baseline Assessment acknowledges the designated heritage assets within and directly adjacent to the site and identifies that the masterplan is an opportunity to draw on the contribution that the historic environment makes to local character.

The baseline assessment should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings.

Some, but not all of the listed buildings are marked on the Opportunities Map within the Baseline Assessment (the Former London Orphan Asylum is omitted for instance). If these are to be marked, we request that all of the listed buildings within a defined radius are properly mapped to avoid giving the impression that the setting of some are more acceptable to respond to than others. None of the Locally Listed Buildings nor Conservation Areas are included. We suggest that the draft document reflects the information contained within Watford's Conservation Areas Management Plan (2013).

We strongly encourage the acknowledgement and recognition of the historic environment as an opportunity within the SWOT analysis within the baseline assessment and that the retention and conservation of the Grade II Listed Building be made an explicit aim of the document.

The Vision and Objectives page should reflect the positive conservation of the historic environment and acknowledge this as a critical element of successful placemaking. We recommend that an additional objective be added to draw on the contributions of the historic environment to produce a locally distinctive place.
We note that the subdivision of the development site into four character quarters fails to include the area of the site that is within the Nascot Conservation Area (and contains the Grade II listed building) within any of the proposed quarters. There is development potential within this neutral part of the Conservation Area which would particularly benefit from guidance as how to appropriately respond to the surrounding Nascot Conservation Area and we would welcome a positive approach to development in this location. This area, identified as Area 21 in the General Masterplan maps contained within the Area Schedule is also omitted from a dedicated analysis of a suitable quantum of development, provided for other identified sub-areas within the area schedule.

We recommend that the possible development of this area be addressed within any revised document.

In making any revisions to the document, we recommend that Historic England's guidance note 'The Historic Environment in Local Plans: Good Practice Advice in Planning 1' is considered and its recommendations incorporated into any subsequent draft.

This document can be found at the following location:
<https://content.historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1.pdf/>

I would also recommend that you review the following guidance which may be of assistance to you to produce robust policies on tall buildings and placemaking appropriate to the aims of the NPPF in terms of conservation of the historic environment:

<https://content.historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/heag037-tall-buildings.pdf/>

<https://content.historicengland.org.uk/images-books/publications/streets-for-all-east-of-england/east-eng-streets.pdf/>

Croxley View/ Ascot Road Study

Thank you for consulting Historic England on the draft Croxley View / Ascot Road Study. We note that there are no Historic Assets on site but note the Grade II listed building Cassio Bridge Lodge is sited to the north of the site and we encourage that any development proposals are considered with regard to setting of this building.
We have no comments to make on the developing brief.

Summary

In preparation of all local plan documents, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime, we look forward to continuing to work with you and your colleagues in the preparation of the Local Plan documents.

Comment

Watford Junction Draft Development Brief 2016

Watford Junction Draft Development Brief

Representation ID: 720

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

A development approach to the Nascot Conservation Area in the area identified as Area 21 should be addressed within any revised document and this should use HE guidance as a resource.

Full text:

Consultation Responses

a) Watford Local Plan - Part 2: Site Allocations and Development Management Policies - Publication Version July 2016 and accompanying Watford Local Plan Part 2 Publication Stage Environmental Report August 2016.

b) Draft Watford Junction Development Brief

c) Croxley View/Ascot Road Study

WATFORD LOCAL PLAN - PART 2: SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES - PUBLICATION VERSION JULY 2016 AND ACCOMPANYING WATFORD LOCAL PLAN PART 2 PUBLICATION STAGE ENVIRONMENTAL REPORT AUGUST 2016.

Thank you for consulting Historic England on the submission draft of the Local Plan Site Allocations and Development Management Policies Document.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.

We very much welcome the references to the historic environment made throughout the draft development framework document and appreciate the effort made to acknowledge the positive contribution to character and placemaking that the historic environment can bring. The document has been set out clearly and is commendably accessible in format. The following amendments are therefore suggested to ensure that the draft SPD fully reflects the statutory requirement to take into account opportunities to draw on the contribution made by all elements of the historic environment.

You will note that we have previously responded to earlier drafts of this document in February 2015 and to an addendum incorporating a Taller Buildings policy in February 2016. Whilst we commended the Borough's comprehensive evidence base incorporating Conservation Area Appraisals and a managed local list of locally important structures, we also requested that some changes be made to the document; particularly consistency of approach to the conservation and enhancement of the historic environment.

Whilst we would not normally expect to offer substantive comment at submission stage, we note that few of the changes requested at earlier stages have been incorporated into the final submission document and this response therefore reiterates our preferred changes to ensure that the plan adequately sets out a positive strategy for the historic environment as required by the NPPF and fulfils the Sustainable Community Objective to be a town that protects its environment and heritage set out within Watford Borough Council's adopted Core Strategy (2013).
We encourage ongoing dialogue and request to be notified of the date of the Examination in Public by the Secretary of State as we may wish to make representations.

Heritage Policies

Policy UD4 - The Historic Environment

We are pleased to see a specific policy addressing the conservation of the historic environment . However we have the following comments to make regarding necessary changes for a sound Local Plan.

Listed Buildings and their setting

The NPPF requires that when considering the impact of a proposed development on the significance of a designated asset, great weight should be given to the asset's conservation. Significance can be harmed by development within the setting of the listed building and substantial harm (including to the setting of a listed building) should be wholly exceptional.

By separating the 'setting of a listed building' from the section on 'listed buildings', the plan implies that a lesser degree of significance is accorded to the setting of a listed building than to a listed building itself.

As submitted, references to the need for wholly exceptional circumstances refer only to the demolition of listed buildings. This does not reflect the NPPF which sets out that substantial harm or loss of highly significant listed buildings (Grade II* or I), which can include harm to the setting of such a building, should be wholly exceptional.

We are also concerned that in consideration of setting, the current policy states that in the event of harm to or loss of significance, this should be weighed against public benefit. This is the role of the planning system but we feel that a more robust strategy for the conservation of the historic environment should set out that harm or loss of significance of the setting of a listed building will not be acceptable.
We strongly encourage the Borough to combine listed buildings and their setting for a robust and NPPF compliant policy that sets out a positive strategy for the conservation and enjoyment of historic environment.

Development in the vicinity of a listed building

We request the following amendment to ensure that the Council's policy for the conservation of the historic environment is appropriate to ensure that listed buildings are given due consideration in the determination of planning applications for development. Without this alteration, the policy relates solely to development of the listed building itself with no other policy for the protection of the significance of listed buildings when development is beyond the listed building.

The Council will preserve the character and setting of the borough's listed buildings and will support applications where:

* The extension/alteration of a listed building development would not adversely affect its character as a building of special architectural or historic interest; both internally and externally, or adversely affect its wider setting.

Conservation Areas

We request the following minor amendments;

Within conservation areas, development will be supported where it:

* Uses materials, finishes, including those for features such as walls, railings, gates and hard surfacing, that are appropriate to local context preserve or enhance the character of the Conservation Area.
* Results, where relevant, in the removal of unsympathetic features and the restoration or reinstatement of missing features.

All other bullet points are supported as consulted.

Demolition in Conservation Areas

We encourage robust policy protection for Conservation Areas and we are pleased to see this addressed within the local plan. We caution however, that the local plan should not be more stringent than the requirements within the NPPF as this may weaken the application of the policy. As such, the first and third bullet points are very welcome. The intent of the second bullet point is understood. This may be a hard policy test in practice however, as, theoretically, all buildings are capable of repair and some beneficial use, even if not suitable or viable. We caution that the use of a difficult test may lead to the entire policy (and decisions based on it) which seek to appropriately conserve the historic environment being challenged at appeal. We suggest that this bullet point is omitted to strengthen the policy.

We request the following omission from the text;
Permission will not be granted for development outside of but near to a conservation area which adversely affects the setting, character, appearance of or views into and out of that conservation area.

This allows for consideration of any affects to a Conservation Area without having to define the difficult question of what is 'near' to the site or not.

Future Designations

Watford Borough Council has a commendable history of local listing, conservation area appraisal and review of its surviving historic environment. It would be a positive strategy to embed this positive approach to heritage conservation within the draft local plan with a policy supporting future designations of locally listed buildings, registered parks and gardens and other heritage assets,

General Comments

Glossary

Listed Buildings and Locally Listed Buildings appear twice. In each case, the first definition is the most appropriate.

Policy SPMX1 - Special Policy Areas

This omits the wording suggested in our previous letter dated 04/02/15 which requested that the sentence Development proposals should accord with the related Core Strategy Policy be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that the principle of development does not override the need to comply with other adopted policies including those that seek to enhance and protect the historic environment.

Policy SPMX2 - Mixed Use Allocations Policy

As this policy states that development will be appropriate on these sites, it is important to ensure that the historic environment is appropriately considered. The mechanism for this is through robust development considerations as set out in Appendix I.

These are acceptable in many places but references to the historic environment are not consistently presented and in some cases there are gaps, as set out in our previous advice of February 2015. In some of these sites, heritage assets in the locality are named and even graded where in others they are partially identified or omitted altogether, even where they are within the allocated site. For this reason I have reviewed the wording of each site within Appendix I - Site Schedules in the table attached to these comments and request that any suggested changes be incorporated to ensure that the protection and enhancement of the historic environment is a consideration for future developers and not contrary to the presumption in favour of development.

See attached table for detailed comment on Appendix I.

Policy TLC9 - Character Areas

This policy refers to the character areas within Watford Town Centre. We would welcome the following minor amendments to the wording;

* Recognition that Character Area ii - the Cultural Area includes the named Civic Core Conservation Area and many listed and locally listed buildings. Additional clarity is considered particularly necessary given that the Environmental Report accompanying the policy document determines that the impact of the character area designation on 'heritage' is neutral (See Page 41 of the Environmental Report accompanying the submission)..
* Recognition that the Palace Theatre and Colosseum are Grade II listed buildings.
* The text relating to Character Area vii - Heritage Area St Mary's and High Street/King Street Conservation Areas does not reflect the amendment requested in our letter of February 2016 which requested the following addition;
The primary concern in these areas is the impact of any proposed development on the designated heritage assets. The Council will expect proposals for development in these areas to actively seek to enhance the identified character and appearance of the conservation areas and the settings of the listed buildings and other heritage assets within and adjoining them.

We are supportive of the Council's encouragement of the redevelopment of the Church Car Park as this is an opportunity to better respond to the Grade I St Mary's Church and the thirteen Grade II structures in its immediate locality, including Watford's remaining Tudor houses the Grade II listed Bedford Alms Houses. The setting of the church is an important part of its significance and developers should be asked to give this careful consideration to this building of exceptional national significance. As such, we again request the above addition to the policy wording.
Policy EMP4 - Change of Use from B Class Outside of Designated Employment Areas

We request that the sentence The proposal must also be compatible with surrounding uses be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that compatibility with surrounding uses does not overcome the need to consider the historic environment and relevant policies within the Local Plan.

Policy EMP5 - Clarendon Road, Station Road and Bridle Path Office Area

This area contains a number of locally listed buildings the retention of which would be beneficial to refer to within this policy to offer them a degree of protection. Retention of these locally listed buildings could enhance the townscape and character of the future office quarter and we encourage reference to them within this policy.

Policy SD6 - Renewable Energy Technology , Policy SD15 - External Lighting Policy & Policy INF2 - Mobile Communications

We are pleased to see the incorporation of the historic environment within the text of these policies. We recommend that the last bullet point in Policy SD15 - External Lighting Policy be altered from heritage assets to historic environment for consistency and to allow greater flexibility in protecting the historic environment beyond designated assets.

Policy TB1 - Location of taller buildings

We are disappointed to note that our detailed advice of February 2016 has not translated into amendments to the wording of the draft policies.

We again submit the following suggested amendments, in the awareness that the proposed locations are in close proximity to the historic core of Watford, several listed and locally listed buildings and Conservation Areas.

The majority of Watford is characterised by low level residential and other forms of development where taller buildings would generally be considered inappropriate. All development needs to be designed in order to respect, reinforce and enhance the local character, including historic character, of the area in which it is located and to contribute to Watford's distinctive sense of place and identity as referred to in Policy UD1 of the Core Strategy....

... (Watford Junction SPA2): The Watford Junction Masterplan should be referred to for further detail on how the pinnacles should be incorporated into the wider townscape and to achieve a positive strategy for the conservation and enjoyment of the historic environment.

The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage (See page 62 of the Environmental Report).

Policy TB2 - Design of Taller Buildings

Please alter 'heritage assets' to 'the historic environment' throughout the document to ensure the widest possible application of the policy to historic places and non-designated heritage assets.

We recommend the inclusion of 'high' in front of quality within the discussion of public realm (point 8).

We note that Criterion 10 - Heritage has been removed. As a result it is particularly important to ensure that the remaining criteria adequately allow for protection of the historic environment.

We note that the accompanying Environmental Report finds that the impact of Policy TB2 is positive or 'sustainable' with regard to Watford's Historic Environment (see page 62 of the accompanying Heritage Report). The change of terminology from within the policy text from heritage assets to historic environment may assist in mitigating harm from taller buildings to ensure that the policy can be considered sustainable.

Appendix I - Site Schedules

We reiterate our comment that we would not normally expect to offer substantive changes to the Local Plan at submission stage. However, as previous suggestions have not been incorporated with regard to the historic environment and clarity of presentation of heritage considerations, we request the following revisions to the text.

These changes will be necessary to ensure that the plan adequately takes into account the desirability of sustaining and enhancing the significance of heritage asserts and identifies opportunities to draw on the contribution made by the historic environment to the character of Watford.

Site Comments Justification
SPA1 - Town Centre Replace 'Heritage assets' with The Historic Environment. Please add the following point: Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Little Cassiobury and Former Stable Blocks (registered on the national Heritage at Risk register) will be given significant weight. The historic environment encompasses more than designated heritage assets. The NPPF requires that a local plan sets out a positive strategy for conservation and enjoyment of the historic environment including heritage assets most at risk through neglect, decay or other threats. As this Grade II* listed building, which is on the Heritage at Risk register is not otherwise mentioned within the Local Plan, it is appropriate to mention a positive strategy for its conservation in Policy SPA1. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA2 - Watford Junction Please replace 4th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the adjacent Nascot Conservation Area, Grade II listed Benskins House (The Flag Public House), Reeds Crescent and other heritage assets within the area. Within the site, the conservation of the Grade II listed Old Station House and its setting should form part of the proposals. For consistency with the remaining policies, we recommend naming and grading the listed heritage assets referred to. For continuity with previous consultations, locally listed Reeds Crescent is retained as a named asset. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different name, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. Grade II Old Station House is within the site and its conservation should therefore be given emphasis. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA3 - Health Campus Please insert the preservation and enhancement of the setting of before 'the Square Conservation Area' at Bullet Point 9. Reuse of Grade I Iisted Shrodells Wing of Watford General Hospital is welcome (We note a typographical error in its name [Grade II listed) ) as is due consideration to the Square Conservation Area.
SPA4 - Lower High Street Please replace 6th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street and the Grade II listed Bushey Arches. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. This is amended for consistency of approach with regard to heritage assets and to ensure that all of the nine listed buildings/structures and other locally listed buildings within the site are captured, not just the two mentioned. Reference to Grade II* listed Frogmore House is amended for consistency with Little Cassiobury at Policy SPA1. The wording seeks an appropriate scheme of repair and reuse rather than 'restoration' which has a specific meaning in terms of conservation and may not be appropriate. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA5 - Dome Roundabout No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA6 - Western Gateway No comment As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site MXD1 - North Watford Library/ Lemarie Centre No comment No comment
Site MXD2 - The Brow No comment No comment
Site MXD3 - Gas Holder Site Please add: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. We welcome the requirement for archaeological assessment and a heritage statement. We reiterate our comments with regard to Policy SPA4.
Site MXD4 - Ascot Road No comment No comment
Site R1 - Sainsbury's and adjoining land Please replace the 4th Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Monmouth House and Nos. 151-153 High Street. Proposals should preserve and enhance the Civic Core Conservation Area and its setting. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street and a potential Roman Road, and adjacent to the point that they are believed to meet we request archaeological assessment where appropriate.
Site R2 - Former TJ Hughes and adjoining land Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Palace Theatre, Beechen Grove Baptist Church and Nos. 14-16 The Parade as well as locally listed buildings at Nos. 11-33 The Parade. Proposals should preserve and enhance the setting of the adjacent Civic Core Conservation Area. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R3 - BT Telephone Exchange and adjoining warehouses Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 14-16 and No 58 High Street which will be expected to be retained. The significance and setting of the adjacent Grade I listed Holy Rood Church and St. Mary's Church and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is in the vicinity of two Grade I listed buildings. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R4 - Church Street Car Park and land fronting Market Street Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade I listed building of St Mary's Church and Grade II* listed Elizabeth Fuller Free School and the cluster of Grade II buildings and structures to the south of the site. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is within the core of surviving historic buildings and open spaces within Watford, including Grade I St.Mary's church and its open setting. Please note that the Elizabeth Fuller Free School is Grade II* listed, not Grade II listed as noted in the consultation document wording. As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site R5 - Charter Place Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 63-65 High Street which will be expected to be retained. The significance and setting of the adjacent Grade II listed No. 58 High Street, the Beechen Grove Baptist Chapel and the Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan. We request the removal of any reference to the frontage of Nos. 63-65 High Street which may encourage façade retention rather than the more appropriate retention of the building as a whole. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
Site CF1 - Tolpits Community Facility No comment No comment
Site H1 - Pinner Road Please replace the 7th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Oxhey Conservation Area, nearby Grade II listed buildings and other heritage assets within the area, particularly the locally listed Railway Arms Public House. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H2 - Skate Park, Lower Derby Road No comment No comment
Site H3 - Vicarage Road Please replace the 5th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Red Lion Public House and Watford Printers Buildings and the Square Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H4 - Telephone Exchange, First Avenue No comment No comment
Site H5 - Builders Yard, Queens Avenue No comment No comment
Site H6 - Bill Everett Centre No comment No comment
Site H7 - Rickmansworth Road Please replace the 1st bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of Nos. 195-199 Rickmansworth Road. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H8 - Garages, Gossamers No comment No comment
Site H9 - Metropolitan Station, Cassiobury Park Avenue Please replace the 3rd bullet point up to 'is required' with Design and development will need to be sympathetic to the significance and setting of the Grade II listed Watford Station. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H10 - Croxley View No comment No comment
Site H11 - Garages Bowman's View No comment No comment
Site GT1 - Land at Tolpits Lane No comment No comment
Site E1 - Watford Business Park No comment No comment
Site E2 - Imperial Way/Colonial Way No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site E3 - Fishers No comment No comment
Site E4 - Greycaine Road Please replace the 3rd bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Paramount Industrial Estate and Former Odhams Press Hall. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street we request archaeological assessment where appropriate.
Site E5 - Clarendon Road Please replace 2nd Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the Grade II listed Benskins House (The Flag Public House) and the Beechen Grove Baptist Chapel and locally listed buildings clustered around Clarendon Road which will be expected to be retained. The significance and setting of the adjacent Grade II listed Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the setting of the adjacent Estcourt Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan.. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different names, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
Site E6 - Leavesden Studios No comment No comment

DRAFT WATFORD JUNCTION DEVELOPMENT BRIEF

Thank you for consulting Historic England on the submission draft of the Watford Junction: Draft Development Brief (August 2016).

We encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers. We are aware of the many social and economic benefits that the development of the Watford Junction area aims to bring about.

Having reviewed the draft development brief we are concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness.

We are particularly keen to see a positive strategy for the conservation of the historic environment incorporated as part of the vision for the area. This would then cascade into the subsequent development briefs for individual sites. The historic environment is greater than a list of designated assets and encompasses locally listed buildings, character areas, the area's historic development, use patterns, street morphology and social history and a successful development brief should seek to draw on the elements of an area's historic character that make it unique and distinctive. Successful developments balance historic character with the other positive aims of placemaking to make locally distinctive places.

The Draft Masterplan is to be adopted as a Local Plan document and should therefore respond to the NPPF's requirement that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment.
To appropriately address this requirement, we recommend that the Baseline Assessment acknowledges the designated heritage assets within and directly adjacent to the site and identifies that the masterplan is an opportunity to draw on the contribution that the historic environment makes to local character.

The baseline assessment should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings.

Some, but not all of the listed buildings are marked on the Opportunities Map within the Baseline Assessment (the Former London Orphan Asylum is omitted for instance). If these are to be marked, we request that all of the listed buildings within a defined radius are properly mapped to avoid giving the impression that the setting of some are more acceptable to respond to than others. None of the Locally Listed Buildings nor Conservation Areas are included. We suggest that the draft document reflects the information contained within Watford's Conservation Areas Management Plan (2013).

We strongly encourage the acknowledgement and recognition of the historic environment as an opportunity within the SWOT analysis within the baseline assessment and that the retention and conservation of the Grade II Listed Building be made an explicit aim of the document.

The Vision and Objectives page should reflect the positive conservation of the historic environment and acknowledge this as a critical element of successful placemaking. We recommend that an additional objective be added to draw on the contributions of the historic environment to produce a locally distinctive place.
We note that the subdivision of the development site into four character quarters fails to include the area of the site that is within the Nascot Conservation Area (and contains the Grade II listed building) within any of the proposed quarters. There is development potential within this neutral part of the Conservation Area which would particularly benefit from guidance as how to appropriately respond to the surrounding Nascot Conservation Area and we would welcome a positive approach to development in this location. This area, identified as Area 21 in the General Masterplan maps contained within the Area Schedule is also omitted from a dedicated analysis of a suitable quantum of development, provided for other identified sub-areas within the area schedule.

We recommend that the possible development of this area be addressed within any revised document.

In making any revisions to the document, we recommend that Historic England's guidance note 'The Historic Environment in Local Plans: Good Practice Advice in Planning 1' is considered and its recommendations incorporated into any subsequent draft.

This document can be found at the following location:
<https://content.historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1.pdf/>

I would also recommend that you review the following guidance which may be of assistance to you to produce robust policies on tall buildings and placemaking appropriate to the aims of the NPPF in terms of conservation of the historic environment:

<https://content.historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/heag037-tall-buildings.pdf/>

<https://content.historicengland.org.uk/images-books/publications/streets-for-all-east-of-england/east-eng-streets.pdf/>

Croxley View/ Ascot Road Study

Thank you for consulting Historic England on the draft Croxley View / Ascot Road Study. We note that there are no Historic Assets on site but note the Grade II listed building Cassio Bridge Lodge is sited to the north of the site and we encourage that any development proposals are considered with regard to setting of this building.
We have no comments to make on the developing brief.

Summary

In preparation of all local plan documents, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime, we look forward to continuing to work with you and your colleagues in the preparation of the Local Plan documents.

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