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SOUTH EAST OFFICE EASTGATE COURT 195-205 HIGH STR EET GUILDFORD SURREY GU1 3EH Telephone 01483 252020 HistoricEngland.org.uk Historic England is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR) . All information held by the organisation will be accessible in res ponse to an information request, unless one of the exemptions in the FOIA or EIR applies. Mr Jeremy Lee Direct Dial: 01483 252026 Milton Keynes Council Development Control, Plan ning Our ref: P00478102 Civic Offices, 1 Saxon Gate East Central Milton Keynes MK9 3EJ 12 October 2015 Dear Mr Lee Arrangements for Handling Heritage Applications Direction 2015 & T&CP (Development Management Procedure) (England) Order 2015 RAILCARE MAINTENANCE DEPOT, STRATFORD ROAD, WOLVERTON, MILTON KEYNES, MK12 5NT Application No 15/02030/OUTEIS Thank you for your letter of 17 September 2015 notifying Historic England of the above application. Summary The proposals would involve the demolition of the majority of the surviving buildings of the Wolverton Railway Works. We hold that this would fail to preserve or enhance the conservation area which the site forms the heart of; instead it would entail substantial harm to its significance. We do not consider that the clear and convincing justification for demolition proposed has been provided in accordance with the requirements set out in the NPPF and legislation. Historic England Advice The significance of the Wolverton Railway Works This proposal is an outline application for the demolition of the majority of Wolverton Railway Works and its replacement with a new traincare facility occupying a smaller site and new-build housing. The works were founded in 1839 as the main locomotive and carriage works for the London to Birmingham Railway. When building and maintenance of locomotives transferred to Crewe in 1877 the site became a carriage works and reached its largest extent in the early 20th century. All the buildings on the site in question date from the later 19th and early 20th century and sit within the Wolverton Conservation Area. The Wolverton Conservation area is primarily of significance in that it is a good example of a railway town. At its heart is the works, which was the main source of employment; to the south of this is terraced housing, much of it built directly by the railway company. As a whole the conservation area tells the story of industrialisation in Britain very well: it demonstrates the vast scale and complexity that heavy engineering took place on during this period and the paternalistic nature of the companies involved, which not only employed but housed their workers. The works are of particular importance to this significance as they are the reason for the existence of the rest of the conservation area: it cannot be understood without it. The Wolverton Railway Works are also of historical interest in their own right. It is one of two examples (the other being Derby) of a large carriage works from the zenith of the railway age to survive reasonably complete and thus comparatively rare (of the other key sites Swindon has lost its carriage works whilst most of the historic buildings at Crewe have been demolished. Holgate Road, York is on a much smaller scale). The survival of specialist equipment, such as the traversers, is unusual. While very plain architecturally the use of standardised designs is interesting from a historical perspective. Their functional simplicity gives them a degree of handsomeness and monumentality; the combined architectural presence of the group is arresting. The architectural simplicity of the buildings is also reflective of the ethos of the London and North-Western Railway as a whole; it applied the same Spartan aesthetic to everything from locomotives to stations. The importance of the works buildings are recognised in the Wolverton Conservation Area Review (April 2009) in which all pre 1906 buildings on the site are identified as being of local significance. A Heritage Assessment of the railway works was also prepared in by Baxters for Milton Keynes Council in January 2015. This contains a good summary of the site’s development and significance: concluding that the site is significant for communal, historical, aesthetic, and evidential reasons and for its visual, historical and spatial relationship with the surrounding town. It also highlights its importance as one of only two major carriage works which survives close to its maximum extent. We support the conclusions of this report.By contrast we consider that the Built Heritage Statement supplied by CGMS in support of this application underestimates the significance of the buildings as it does not take proper account of their role as the heart of the conservation area, their relative rarity nor their historical interest. The impact of the proposals The extent of the demolition proposed is such that the site would lose virtually all of its architectural and historical special interest. This would have a profound impact on the character of the conservation area. The story it tells, that of a planned industrial town, would no longer be intelligible if the works at the heart of it are removed. Without it the remaining elements of the works (including the grade II listed New Works, Reading Room and Royal Train shed) become isolated fragments that are no longer intelligible as elements of a greater whole. If demolished the impact on the conservation area would be so great that the Council would need to question whether the area was still worthy of designation. Therefore we conclude that the proposals would entail substantial harm to the designated Heritage Asset that is the Wolverton Conservation Area. Planning policy considerations Section 72 of the Planning (listed buildings and conservation areas) Act 1990 requires the Council to pay special attention to the desirability of preserving or enhancing the character or appearance of a conservation area. The loss of a large number of buildings which positively contribute to an area will clearly neither preserve nor enhance it. Furthermore, the core planning principles set out in paragraph 17 of the NPPF include the conservation of heritage assets in a manner appropriate to their significance. The proposals would not achieve this. Neither would they sustain and enhance the significance of the heritage asset in question, as paragraph 131 of the Framework states is desirable. As the proposals would entail substantial harm to a designated heritage asset they need to be assessed against paragraph 133 of the NPPF. This states that: “Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply: ● the nature of the heritage asset prevents all reasonable uses of the site; and ● no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and ● conservation by grant-funding or some form of charitable or public ownership is demonstrably not possible; and ● the harm or loss is outweighed by the benefit of bringing the site back into use. We offer for your Authority’s consideration that the majority of the benefits claimed for the scheme are less than substantial. Firstly this is an outline scheme; the eventual form and magnitude of many of the benefits claimed are unclear. Furthermore, the heritage benefits claimed are of very limited value: they would retain some slight memory of the site rather than preserving its significance. The additional housing should also be considered as being of limited benefit given that the site is not allocated for housing in the local plan. We recognise that retaining railway use on the site is a key policy objective for the Local Authority. However, we do not consider that it has been demonstrated that demolition of virtually all buildings on the site is necessary to achieve this. Employment use is only proposed for part of the site. Therefore the demolition of the entire site is not necessary. In addition it is not clear that the complete demolition of the eastern part of the site is necessary to secure continued use as a railway maintenance and repair facility. The arguments against reuse of buildings put forward in the Viability Report included with this application are not at present conclusive. While consolidating the works into a smaller area may well be desired by the operator achieving this should not be seen as a justification for demolition. For example, a need is stated for two storey offices but offices could be accommodated using more of the existing single storey accommodation. Likewise it is stated that buildings are at the wrong alignment to run trains into but this is only true if the depot is compressed into the eastern end of the site. It is unclear why levelling the floors is not practical. The argument about needing additional height to split bodies from bogies and space to work around carriages needs justifying in more detail. The size of cranes now needed and how that compares with the size of the present buildings needs to be explained. Given that it has not been demonstrated that near complete demolition is necessary to deliver a substantial public benefit all the tests set out in paragraph 133 of the NPPF need to be applied. The application does not demonstrate that any of these have been met. Firstly, the nature of the heritage asset clearly does not prevent all reasonable uses as similar buildings (the listed Former Works Building and the Former Royal Train Shed) have been converted to residential use. Work done as part of the CMGS Viability Report suggests that a similar conversion of the buildings on the site would be possible. Other industrial uses are possible and we note that part of the application is a discount food store. These stores need what are effectively large sheds with big floor plates very like the wagon building shed, carriage repair or paint shop. Use for this purpose would be theoretically possible. Secondly, as no appropriate marketing has been undertaken it has not been demonstrated that there is no viable use for the site in the medium term. Thirdly, it has not been demonstrated that conservation by grant funding or some form of charitable public ownership is not possible. Finally, as much of the present site is currently in a beneficial use it has not been demonstrated that the loss is outweighed by the benefit of bringing the site back into use. Conclusions The Railway Works at Wolverton is a very complex and difficult site where there is a clear need for regeneration. In our view this should be heritage led and focus on the retention and reuse of the historic buildings on the site. Demolition should only be accepted as a last resort and we do not think that the case has been made for this. We suggest that the best way forward would be to separate the issue of the works and housing. We need to have a greater understanding of the operational needs of the railway works and how much of the existing building stock could be potentially reused and would be willing to meet with the current operator in order to do this. Reuse of one or some of the buildings as a discount food store also should be investigated. We accept that, given current market conditions, residential conversion may be the optimum viable use for at least part of the site. Experience with other former railway buildings in Wolverton suggests that residential conversion is possible. Again we would be willing to work with the developer to look at ways of achieving this. Recommendation As the application currently stands we object on the basis that this would cause substantial harm to the conservation area. We would offer to work with the applicant and the authority regarding the regeneration of the site so that an appropriate scheme in relation to the historic environment could be put forward and so would recommend that the application be deferred or withdrawn to enable this to be undertaken and would welcome the opportunity of advising further. Should this not be the case, then we consider that the application should be refused on the basis that no clear and convincing justification to demolish a group of buildings that make a key contribution to the signi ficance of the conservation area appears to have been provided in accor dance with the requirements set out in the NPPF and legislation. We would welcome the opportunity of advising further. Please consult us again if any additional information or amendments are submitted. If, notwithstanding our advice, you propose to approve the scheme in its present form, please advise us of the date of the committee and send us a copy of your report at the earliest opportunity.