A Letter from Ray Harrison to Swale Borough Council Planning Dept.
Planning and listed building consent applications 16/508342/LBC and 18/508341/Full for Building No 1, Standard Quay, Abbey Road, Faversham, Kent, ME13 7BS.
I wish to raise objection to the proposals put forward in the above applications. I understand that this letter may arrive outside the closing date for public comment but would be grateful if you could nonetheless consider it, given that part of the consultation period fell over the winter break.
In relation to the previous applications at this site and the Appeal against their refusal, it was a proposed new restaurant use that the Inspector, in the Appeal Decisions dated 16 Jan 2015, ruled unacceptably damaging in principle to the character of the listed building.
The Appeal cases referred to are Appeal A: APP/V2255/A/13/2202894 and Appeal B: APP/V2255/E/13/2202924, both relating to Building No 1, Standard Quay, Abbey Road, Faversham, Kent, ME13 7BS.
The current applications as now tabled remain essentially unaltered from those that have gone before in respect of the principle of the proposed new restaurant element. As noted it was upon the principle of the new restaurant use that the previous Appeals failed.
To support my case of objection I set out some detail from the Committee Report on the Appeal and the Appeal Decision itself as follows –
The Council’s Planning Committee Report of 12th March 2015, Item 3.2, page 115, headed ‘The Appeal Decision..’ This is a very good summary of the Appeal Decision, written at the time for the benefit of Members.
The main part of the head para, Para 8.03 of the Report, on page 115 reads:
‘ In the Inspector’s Appeal decision… he dismissed the Council’s case … He identified (that) the main issue to be considered was whether the proposals would preserve the special interest of the listed building, and preserve or enhance the character of the conservation area.’
Para 8. 04 of the Report quotes the Inspector. The key part of this quoted passage is as follows:
‘… Overall, I find that the significance of the building lies in the part it plays in the wharf as a whole and by enclosing a space which evokes the utilitarian uses for which it was built and subsequently used.’
Para 8.05 provides further quotation, the important passage here being:
‘….The changes that would be necessary to turn the building into a restaurant would make its appearance far smarter and more refined. As a result, the overall nature of the building would change and this important element of its special interest would be altered so much that the character of both the building and the conservation area would be significantly damaged. If the appeals were permitted, it would be unreasonable to refuse subsequent consent for cleanable surfaces for food preparation, additional signage or measures to reduce draughts and this incremental damage would further harm the significance of the listed building.’
Para 8.06 notes that:
‘He (the inspector) took the view that the significantly harmful level of intervention proposed in order to convert the building to a restaurant was not necessary to sustain the future of the listed building.’
Para 8.08 notes that:
‘He concluded that, on balance, the proposals failed to preserve and would cause harm to the special interest of the listed building and the character of the conservation area, and that the benefits of the scheme would not outweigh the harm.’
Relevant extracts from the Appeal decision.
Extract – Para 8, page 2 of the Decision:
‘….Overall, I find that the significance of the building lies in the part it plays in the wharf as a whole and by enclosing a space which evokes the utilitarian uses for which it was built and subsequently used.
Extract – Para 14, page 3 of Decision:
‘… While the current roof covering might not be adequate for its proposed use, it was perfectly adequate for its last use and, as maritime storage or maritime related uses, it is probably not necessary for the building to be entirely weather tight or draught proofed….’
Extract – Para 16, page 4 of Decision.
‘…I find that the costs to sustain the building for storage or maritime uses need not entail the level of intervention proposed….Moreover, given that the building was in use in roughly its current condition before the last lease was terminated, I find that occupiers could be found to fund the extent of repairs required without changing the use of the building.’
The significance and implications of the Inspector’s judgments.
It was the inspector’s view that an important part of the significance of the building lies in the entity of its form (space, structure and finishes), inside and out, as it survived as a maritime uses structure, in one form or another, from its inception until its modern maritime-use related leases were terminated by the Appellant.
He considered that maritime uses or maritime storage uses could have continued and that these would have brought in sufficient funds to keep the building wind and weather tight – i.e. appropriate for the uses involved and entirely appropriate also for the location on an historic industrial maritime Quay in the Faversham conservation area.
The proposed restaurant use would involve the ‘smartening-up’ of the building. One particular area of smartening, as the drawings show, is to the insides of its external envelope where insulation and internal wall and roof sheathing significantly reduce the quality of extant interior character.
Such changes to character are seen in timber framed barn conversions through the County. There is no doubt, and experience shows, that in these cases, after ‘conversion’ the barns are left with little evidence of their millennial original functions of crop storage in great open bays and the heavy, dusty and back breaking winter time manual labour of threshing .
The farmer is invariably able to demonstrate that his barn is inappropriate for modern day agricultural use. Conversion then introduces entirely non-agriculturally related uses, such as residential, that might be brought in to ‘save’ the building from dereliction.
This case however differs from the standard barn conversion exercise because as noted by the Inspector there was a previous and viable use of the building. This perpetuated the historic working characteristics of this traditional, pre-industrial, timber-framed, maritime related structure – inside and out – protecting its fragile historic character.
It is important to recognise that this particular type of building, of this age and form and in this historic condition, is a very a rare, and vanishing, phenomenon in its own right today – vanishing in part of course due to the success of planning/LBC applications such as this one.
The implication of the Inspector’s ruling is that restaurant use would only be acceptable if it posed as little threat to the historic entity of the building as did its last rented uses, which the Appellant had discontinued (see comment on Para 8.06 of the Council’s report, (page 1 here) and Par 16, page 4 of the Decision, (page 2) here). And this of course is impossible. This remains the case with the current application, just as much as with its predecessor.
I fully concur with the Inspector’s ruling and believe, like him, that in the interests of preserving the unusual degree of historic interest that this very rare, threatened building possesses, the current application for its re development (which in respect of the restaurant element at least follows those that have gone before) should be refused.
J.R.Harrison. AA Dipl., Registered Architect, Dipl. Cons (York), MIHBC.