Friday, 2 March 2012

Questions for Brent's Conservation Officer

 Letter to Mark Smith, Brent Council's Conservation Officer

Dear Mark Smith,

We recently spoke on the phone regarding the plans for the Regeneration of Willesden Green. I mentioned during our conversation that I was concerned that the plans included the Demolition of the old 1894 Library currently occupied by BIAS.

You said that you had been involved in discussion with the Regeneration team and that it was your view that the financial benefits of the proposals outweigh the reasons for retaining a significant heritage asset within the Conservation Area of Willesden Green High Road.

I am aware that your decision making will be made in accordance with Planning Policy Statement 5 and would like clarification on the following:

HE3.1 gives guidance of Policy approach.
Please could you let me know the details of your proactive strategy to conserve the historic environment of the High Road. I notice that the Spotted Dog has a retained  façade. Clearly architectural context is respected and preserved by your department.

Have all the points (i-iii) of HE3.1 been considered with regard to the Old library Building?

Please can you direct me to the Brent local framework strategy for the High Road Conservation Area. I am particularly interested in the Council’s policy on investment in Heritage Asset. Surely, as a landmark building, the historic library building gives an important sense of place. Its history and plaque are fitting tribute to the rate payers of Willesden, who worked hard to ensure literacy. Is this not the ideal context for any new development?

Please can you also let me know the extent of Consultation that has been carried out to understand local community views. I notice that the Council carried out a Consultation of a target audience of 12 people. I have spoken to several of the people involved in that Consultation. They have all said that they requested that the Old Library should be preserved. Please also note that subsequent to the plans being published, there is a strong objection locally to the Galliford Try scheme. A petition has been circulated during the last 3 weeks and well over 1000 signatures have been collected. Planning Policy Statement 5 paragraph HE7.3 tells me that reasonable steps should be taken to seek the views of the Community. Please can these steps be taken during the current Consultation period? Your comments regarding, the Consultation to date would be appreciated.

Has the following been considered carefully?

HE9.1 says that there should be a presumption in favour of the conservation of designated heritage assets and the more significant the designated heritage asset, the greater the presumption in favour of its conservation should be. Once lost, heritage assets cannot be replaced and their loss has a cultural, environmental, economic and social impact. Significance can be harmed or lost through alteration or destruction
of the heritage asset or development within its setting. Loss affecting any designated heritage asset should require clear and convincing justification.

Please let me know where I can find your report justifying the demolition of the 1894 Library? I assume, as a contract has been signed with Galliford Try for a development including the demolition of the Old 1894 Library, that a report has been written by your department giving guidance on the following:

HE9.2 Where the application will lead to substantial harm to or total loss of significance, local planning authorities should refuse consent unless it can be demonstrated that:
(i) the substantial harm to or loss of significance is necessary in order to deliver substantial public benefits that outweigh that harm or loss; or
(ii) (a) the nature of the heritage asset prevents all reasonable uses of the site; and
(b) no viable use of the heritage asset itself can be found in the medium term that will enable its conservation; and
(c ) conservation through grant-funding or some form of charitable or
public ownership is not possible; and
(d) the harm to or loss of the heritage asset is outweighed by the benefits of
bringing the site back into use.

My own view is as follows;
The Old Library makes a positive contribution to the character of Willesden Green. It is a landmark building and a monument to the determination of the local 1894 poll tax payers who raised funds in times of terrible poverty to provide books, a library and ensure literacy. Surely it is these historic values that should be celebrated and influence the future character of the area?

The development should be informed by The Old library, not facilitated by it’s demolition. It reinforces meaning and civility and it’s presence should enhance our relationship with the new building. It is an inherent and unique part of the Willesden Cultural heritage and should be recognised as a catalyst for regeneration. It should be valued, conserved, restored and put to a suitable and viable use in the new Library Centre. The area around the Old Library is an attractive gathering space and lively market place, it makes a good contribution to the economic vitality of the High Road. This space is an essential part of our local townscape.

Please consider these matters before an Application is submitted to ensure that Public funds are not wasted on developing plans for a scheme that has not followed normal Planning procedure.

Kind regards
Kate Spence

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