Petition update

conservation object

Phil Webb
Wolverton, ENG, United Kingdom

Simon Peart
Our Ref:
Application no: 16/00360/FUL
Proposal: Partial demolition of the Stratford Road wall, removal of two trees, and
erection of a foodstore of 2,478 sqm GIA with associated access including new
pedestrian ramp and steps, servicing, parking and landscape.
Land At Wolverton Railway Works, Stratford Road, Wolverton
Based on the information provided (please tick one):
Planning (Listed Buildings and Conservation Areas) Act 1990, sections 66, 72 The National Planning Policy Framework (NPPF), particularly section 12
Planning Practice Guidance (PPG) & Historic Environment GPA’s Adopted Milton Keynes Core Strategy –Policy CS19
Milton Keynes Local Plan –saved policies
HE5, HE6

Significance Fundamentally, the planning application site falls within Wolverton Conservation Area, a designated heritage asset. It also lies within the setting of other designated heritage assets/ listed buildings, these being,The Royal Train Shed, The Former Railway Works Building (‘Triangular Building’), the Railway Bridge (171C –‘Stephenson Bridge’) and the Former Reading Room Building, all formerly associated with the Wolverton Railway Works, the current site of which contains the application site.(Note the conservation area boundary is shown incorrectly in Fig 2 of the Design and Access Statement but correctly shown in Appendix A of the submitted Heritage Assessment).
The Council’s Conservation Area
Review, 2009, sets out the character, appearance and significance of the Wolverton conservation area.
Its distinct areas are identifiable from their differing forms which arise due to the various functions that each one performs.Whilst all contribute to the significance of the conservation area, the works complex itself is at the very core of the significance of the conservation area and the reason for its designation.
No objection
Application needs amending or additional information is needed

The railways works site itself possesses significance under more than one of the heritage values defined by Conservation Principles: Polices and Guidance (English Heritage, now Historic England, 2008). This significance is set out in the Wolverton Railway Works Heritage Assessment carried out by Alan Baxter, commissioned by Milton Keynes Council.

The conclusion of which is appended at the end of this report.The heritage statementsubmitted with the application lists relevant policies and guidance documents.
Whilst it correctly observes the limited inter-visibility between the surroundings and interior of the works site, it does so in a fashion that seeks to imply a limitation in its visual contribution to the Wolverton Conservation Area. Regardless of this, the statement does recognise that the Works ‘has a major positive contribution to the Conservation Area’s significance’. Owing to its location, the presence of the imposing Stratford Road boundary wall of the works and the difference in levels either side of the wall, the planning application site’s primary relationship is currently with the wider works site. In particular, it abuts the wagon building and repairs shop to
the west, the modern Tesco store to the east and the large saw mill and timber shed to the north.
Within the works site,red brick is the only material used to face buildings, with the later Tesco adopting the same material.
West of the saw mill, the buildings adopt a more standardised design characterised by repeating gables and pitched roofs, pier and panel brick work within which large openings are set, doors in gables, windows in flank elevations. Roofs are typically grey slate.
This palette of materials is also typical of the residential areas which lie outside but adjacent to the works site. As such, it is a unifying element that reinforces the relationship between the works and the housing (i.e. that the latter was required by the former) and in turn the character and appearance of the conservation area. The use is so consistent that buildings not built from this palette are a conspicuous departure, often detracting from the homogenous quality of the area.
As described by the heritage statement, the engine depot building that previously occupied the application site was demolished during the Tesco Redevelopment, as was, it is presumed,
its accompanying traverser. Within the site the railway lines that embedded in the concrete are all that remain.At the southern boundary of the site, the Stratford Road wall is a powerful reminder of the boundary of the works, and in some instances it is the first indication of the presence of the works in the town. It is a key component within the conservation area making a positive contribution to its character and appearance, possessing significance across a number of values,but particularly historical and communal value.
To the east are a group of listed buildings (listed above), these buildings (and structure) formed part of the Wolverton Railway works. The application site lies within the remaining works site, thus it might reasonably be argued that it lies within their setting.
Direct views between the listed structures and the application site are very limited at best, albeit there is some relationship retained between other parts of the current works site and the listed buildings.
The redevelopment of part of the works site to accommodate the Tesco represents a major intervention that had a detrimental impact on its integrity and the direct visual relationship between the listed buildings and the application site. In a wider sense however, the scale of the site and the buildings that remain on it mean that the works can still be appreciated as an entity.
Aside from direct intervisibility, the application site does play a role in the wider appearance and presence of the works which forms a key part of the setting of the listed buildings. Whilst the buildings on the current works site post-date the listed buildings, they provide important components of the setting of the listed buildings. They illustrate the ultimate extent of the operations of which the listed buildings were part. They help to place the listed buildings into the continual development and evolution of the site, illustrating how requirements, functions, standardisationand speed of expansion altered after their construction. It is the presence of the current works site that provides the context the listed buildings, without it they would be an isolated remnant of a considerably larger operation and the ability to appreciate the history of Wolverton and the listed buildings would be markedly weakened
Key Issues
Statutory Duties The LPA must give ‘special regard’ to the desirability of preserving the building or its setting or any features of special architectural interest which it possesses (section66).
The LPA must pay ‘special attention’ to the desirability of preserving or enhancing the character or appearance of the conservation area (section 72).Local Plan Policy
Whether the development would adversely affect the setting of the nearby listed buildings(policy HE5).Whether the development proposal would preserve or enhance the character and appearance of the [conservation] area (policy HE6)

Core Strategy

Whether the development will protect and enhance the significance of the Borough’s heritage assets (policy CS19).NPPF Whether the proposal sustains and enhances the significance of the heritage assets, making a balanced judgement having regard to the scale of harm or loss and significance of the heritage asset (paras. 131 to 135). Development Principle There is no heritage objection to the principle of re-using this site. It is entirely feasible that a new use and a new building which preserves the character and appearance of the conservation area and the setting of nearby listed buildings can be accommodated on the site.
As such re-use is encouraged, subject to the following paragraph and comments under ‘development detail’ below.I note that the supporting information refers on various occasions to the wider railway works application (15/02030/OUTEIS). However, It does not consider the feasibility of adapting one of the railway works buildings to house the proposed food store. The potential re-use of the works buildings will be a material consideration of. Clearly, if the opportunity to re-use one of the railway buildings is not fully examined or evidenced by the applicant at this stage, it is likely to have an adverse effect on the acceptability of the wider scheme which proposes to demolish all but part of one of the remaining buildings on the works site.
The reduction in height of the Stratford Road wall as proposed will cause harm to conservation area, a designated heritage asset.
This harm falls into the ‘less than substantial’ category, as such, paragraph 134 of the NPPF would apply. It directs that that the harm should be weighed against the public benefits delivered by the proposal.

Development Detail

General Observations

The visualisations of the store are limited to a single view point. This is insufficient for a
proposal of this nature within a conservation area. A viewpoint of the proposed
building, looking NW from the entrance to the site is conspicuous by its absence.
This view point would also have shown the east elevation and arguably given a greater overall appreciation of the proposal Similarly there is no street scene elevation to show the appearance from Stratford Road, its relationship to the lowered wall and the buildings either side. This would also show how the proposed transition from full height wall to the proposed lower height would be dealt with. Other than the proposed section drawings, the drawings generally fail to show the surroundings and context within which the scheme is proposed.


Whilst there is no objection to the general arrangement proposed on the site, the foodstore building is located very close to its western boundary.
It is appreciated that within the site, this offers an efficient layout, however it has impacts on the adjacent wagon building and repairs shop building.
The proposed food store is closer to its neighbour than the buildings are/were typically on the works site, indeed it is closer to it than its predecessor, the engine shed,was. Whilst there is no requirement for buildings to adopt exactly the same position as previous buildings, in this case the result is a very poor, if not a total lack of relationship between the two buildings.
The eastern façade of the works building was clearly designed to be seen, and possesses a degree of quality to its industrial form, being characterised by its repeating brickwork gables, louvered arched windows and large entrance openings. In stark contrast, the proposed food store offers an entirely blank elevation with no perceptible articulation other than a single window and door and the switch from white render to silver Alucobond sheeting.
The boundary between the buildings is to be marked by a fence (type to be confirmed) as opposed to the typical boundary treatment in the conservation area, a brick wall.
The relationship between the two buildings is extremely poor. From this it is clear that the proposal has been brought forward in isolation of its context, on the assumption that the application site is separate from the remainder of the works and that the surrounding buildings will be removed. Indeed, the submission fails mention how the building has been designed to take into account the neighbouring buildings.


The failure to take into account the context of the site is also wholly evident in the overall design of the building. The application again fails to evidence or explain in its supporting information how the proposed design has been arrived at. The Design and Access Statement in particular has adopted an incredibly brief and mechanical process by which it clarifies what is proposed, rather than providing evidence as to how the design has been arrived at and what it has taken into account. Perhaps most telling is the emphasis in paragraph 3.3of the Planning Statement, which can merely describe it as an ‘attractive design’that is ‘in keeping with the corporate style of Lidl stores’. It should be made clear, that there is no presumption against buildings that adopt a modern design, similarly there is no requirement to slavishly replicate what is already found in the conservation area. Evidence of this is that Council officers previously supported a new Tesco store on the adjacent site that made significant and numerous design revisions to ensure that its modern design was sympathetic to its context.
In short, the proposed design is one that fails to pick up on any element of the character and appearance of its context, the Wolverton conservation area. In doing so it creates a building which is knowingly alien to its surroundings, achieving a stark contrast to both the dominant railway buildings around it, the residential building opposite it and, arguably, even the existing foodstore adjacent to it.
This contrast however, is not a positive one, as can be the case with building that are intentionally designed as such, in this case it appears simply as result of a corporate style. Buildings that intentionally contrast the local vernacular often employ some element of their design to pay reference to their surroundings. In this case, it could have been one of many things, for example, simply to use brick, to have a strong repeating bay arrangement, repeating windows or to use gables and pitched roofs. Instead the building adopts and entirely different arrangement in every respect including its horizontally biased rear and side elevations. If the building is to pay no reference to its surroundings whatsoever, it would have to achieve a very high standard of design, perhapsto make its own positive contribution outright. Unfortunately,that is not the case with this particular design.
The suggestion may bemade that,because the building will be located below the level of Stratford Road its visual impact would be reduced, this. However, the store would be used by significant numbers of members of the public and would be visible from the street scene, as confirmed by the submitted visualisation and paragraph 3.4 of the Planning Statement which states that the Stratford Road wall is being demolished in order to open up the site’. The fact that it will be seen by people using Stratford Road, people using the store itself, and workers on the adjacent works site, reinforces why the use of a generic design is neither justified nor an appropriate response when being placed in an area of such distinct character and appearance. The design simply fails to respond to its conservation area context and to reinforce the local distinctiveness of Wolverton.
Demolition of Stratford Road Wall As above, the Stratford Road wall is an important feature of the conservation area and its reduction down to 1 metre in height causes harm. Indeed, the reduction of the wall will not only results in a visual erosion of and loss of fabric to an important feature in the conservation area, it
will in turn cause further harm because it allows greater views of a building which itself would detract from the character and appearance of the conservation area.


There is no evidence to suggest that the applicant has considered other options to minimise this impact since it is proposed to be reduce the height across the entire width of the plot, although this is of course preferable to its entire removal. As above,there are no details submitted to illustrate how the transition in heights between wall sections is to be dealt with, how the new opening with be treated and no indication of the scope of works that (if any) will be undertaken to the wall e.g. repairs or stripping of paint to the internal face.
In conclusion, the proposed scheme fails to demonstrate, either through supporting information or by being evident in the proposed design, that any consideration or regard has been given to the heritage context of the site, particularly the Wolverton conservation area. The result is that harm will be caused to the Wolverton conservation area. Whilst this harm will be considerable it falls within the ‘less than substantial’ category rather that ‘substantial harm or total loss’ when considered in the context of the conservation area.In weighing this harm, the Local Planning Authority has a statutory duty to pay ‘special attention’ to ‘to the desirability of preserving or enhancing the character or appearance of that area ’Recent decisions in the High Court and Court of Appeal have re-affirmed the need for decision makers to give ‘great weight’ to these statutory matters, particularly in relation to material considerations that do not carry the equivalent statutory requirements.
The harm caused could be outweighed by public benefits delivered by the scheme, as allowed by paragraph 134 of the NPPF. However, given the impact of the store and the isolated nature of this proposal, there are no heritage related public benefits delivered by the scheme.
It is possible that the scheme can deliver other, non-heritage, public benefits that will counterweigh the harm. However, if these can be delivered in a way that avoid the harm caused by this particular scheme, then these will carry less weight in this weighing exercise.

Setting of Listed Buildings
As above, whilst there is limited direct intervisibility, the application site forms part of the wider setting of the listed buildings (i.e. the works site), contributing to their setting and, in turn, their significance.
Due to the nature of the design of the scheme, particularly its disruptive appearance, there will be a harmful impact to the setting of the group of listed buildings, however, this impact is partly mitigated by the presence of the exiting Tesco store.
The level of harm caused falls within the ‘less than substantial’ category, as such the comments regarding paragraph 134
above are again relevant.Again, in weighing this harm, the Local Planning Authority has a statutory duty: In considering whether to grant planning permission for development which affects a listed building or its setting,
the local planning authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses
Recent decisions in the High Court and Court of Appeal have re-affirmed the need for decision makers to give ‘great weight’ to these statutory matters, particularly in relation to material considerations that do not carry the equivalent statutory requirements.


Excerpt from Wolverton railway Works Heritage Assessment,
Alan Baxter Associates,

3.7 Summary Statement of Significance

The significance of the Site has been recognised by its inclusion in Wolverton Conservation Area, a designated heritage asset.
As described in 3.3.3, it contains railway sheds and other historic elements that are positive
contributors to the character or appearance of the Conservation Area. Beyond that designation, this chapter has shown that the Site is significant for the following reasons.
• Communal value: as the reason for the historic development of Wolverton, the town’s most
important employer and a major part of its local identity.
• Historical value: as the oldest continuously operated railway works in the world, and as a site that exemplifies the large scale, architectural standardisation and associated workers settlements of the consolidation and completion periods of the English railway network in general, and as the Carriage Works of the London & North Western Railway in particular.
• Aesthetic value: its historic railway sheds are substantial structures that, although almost all are to a standardised and functional design, exist together with the spaces between them to create a consistent and impressive historic character.
• Evidential value: as an operational railway works, with historic buildings that are generally
instructive of their continued use, underlined by specific historical uses where associated machinery and infrastructure survives.
• Setting: for its visual, spatial and historic relationship with the wider town, most notably the
contemporary residential settlement and the listed railway buildings that now form part of the Wolverton Park development.
• Comparative assessment: as one of the three major English carriage works at the 1923


grouping, as one of the two that survives close to its extent in 1923, and as the only one th
at does so in close proximity to surviving listed early railway works buildings

(Please draft any suggested reasons for refusal or suggested conditions including reference to relevant Planning Policy. If amendments or additional information is required please make your requirements clear)
Date response sent:19/04/16

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