Strong objections to Bishopsgate Goodsyard plans
The applications would cause substantial harm to the setting of designated heritage assets, including listed buildings and conservation areas. Furthermore, the design of the tall buildings is not of a quality commensurate with the great prominence they would have on London's skyline.
You can read the Victorian Society's full response to the planning applications in respect of the Bishopsgate Goodsyard Site below.
RE: Bishopsgate Goodsyard site (Braithwaite Viaduct, Grade II, 1840; Forecourt wall and gates to Bishopsgate Goods Station, Grade II, 1877-84); outline application for the comprehensive mixed use redevelopment of the site
Thank you for consulting the Victorian Society on this application. The proposals were discussed by the Victorian Society’s Southern Buildings Committee at their last meeting, and I write now to convey their views. We strongly object to these applications, because they would cause substantial harm to the setting of a large number of designated heritage assets, including listed buildings and conservation areas, and the design of the tall buildings is not of a quality commensurate with the great prominence they would have on the skyline of large parts of London.
While the application site straddles two boroughs, necessitating separate applications, it can only be sensibly assessed as one proposal; much of our letter applies to both sets of applications but there are elements that are only relevant to one. I should note that the Design & Access Statement is 348 pages long and in 182 separate electronic files on the Tower Hamlets website; much of it is repetitive and indulgent, more likely to deter scrutiny than clarify the intentions of the designers.
Historic character of the site
The northern half of the Bishopsgate Goodsyard vaults complex was demolished in 2003. The construction of the East London Line was the pretext, but the railway could have been placed on top of the vaults; it is likely that the real reason for the demolition was to sterilise the site for future large scale redevelopment. The remaining southern half of the Bishopsgate Goodsyard vaults includes two Grade II-listed structures. It is surrounded by a number of east London’s most important and interesting conservation areas. The complex as a whole is of enormous character, resonance and interest, which is not lessened by the failure of the historic building designation system to find a suitable label to attach to it. Its Piranesian caverns are a distinctive and evocative feature of the area; they lend themselves to a large variety of uses. While the Goodsyard is close to the City, Shoreditch, Boundary Street and Spitalfields it has a very different character.
The proposal fails to respond adequately to the character of the site, a character which is defined by the screen wall which acts as a strong edge, and the vaults which historically acted as a podium for structures above. While not all of this screen wall and not all of the vaults still exist, much of it does, and it is damaging and unfortunate that the scheme proposes the demolition of the screen wall on Commercial Street, fails to reinstate a contemporary version on the north-west quadrant of the site, and fails to consistently use the first floor level to the south of the East London Line as a podium. Instead, it demolishes much of the vaults and fragments the site, separating the gateway on Shoreditch High Street from the rest of the site, and it greatly erodes the coherent and distinctive character of the Goodsyard as a cohesive whole.
In terms of the treatment of the designated heritage assets, we welcome the retention and repair of the listed Braithwaite Viaduct. Its use for shopping below with a linear park above is entirely suitable.
Forecourt Wall and Gates
The listed Forecourt Wall and Gates present complex problems. The first problem is to decide what the listing and the curtilage covers. The list description is imprecise and unhelpful to all; it would have been useful for this description to have been revised. It is clear that the listing does not cover the entire Goodsyard complex; this would be the cart pulling the horse. It is equally clear that the Forecourt Wall and Gates gain most of their significance from their function as the entrances to a large multi-level complex of vaults. The large ornamental gate is the start of a ramp which historically led north and then east to attain the upper level. The gateway is the main ground level access to the vaults complex, and the oriel window is placed to mark the point at which another ramp, starting from Wheler Street, finally attains the upper level. It is this arrangement, and the size and importance of the vast complex of arches behind, which gives the ornamental gateway and forecourt its meaning and logic – its significance.
The proposals for the Forecourt Wall and Gates would be highly damaging. One aspect of them is unacceptable in principle. Outline consent only is being sought for plot A. And yet this building will envelop and include the northern three arches of the Forecourt Wall and Gates. It is unacceptable for listed building consent to be given for major alterations to this listed building without detailed and comprehensive proposals for the treatment of the whole listed building, and the structures that abut it. For this to be left as a reserved matter would be entirely contrary to the well-established principle that one cannot be granted outline listed building consent. The treatment of this listed building must be considered as a whole, not divided into two elements.
The proposal to demolish the screen wall running round to Commercial Street would cause substantial harm to the setting of this listed building, by reducing it to an isolated fragment rather than the entrance to a huge complex of vaults. It would become a heritage exhibit in a complex of tall buildings. It would be greatly preferable to retain the ramp from Wheler Street and use this ramp, in addition to the gateway at lower level, as a major access point to plots A, F and G at first floor level.
Even if one were to accept the amputation of the listed building from the rest of the vaults, it is surely unnecessary for the small vaults between arches G9 and V1 to be demolished and replaced with a curvilinear concrete structure. Together with theraising of the parapets in concrete, this threatens to make the listed structure look like a skin-deep veneer applied onto a concrete jelly mould.
It appears from the proposed drawings that the freestanding section of wall on Shoreditch High Street, in which the gate winding mechanism is housed, is to be retained. Confusingly, it is not shown on the renders; this must be clarified. But it does not lead to anything; it just stops after a few metres. It is not the fault of the applicants that the continuation of the ramp was demolished in 2003. But it is unfortunate that they have not taken this opportunity to ensure that the ramp and the gate actually lead somewhere; for example a stair climbing and turning to the right to access Building A would recreate the function and spirit of the previous ramp and would actually give the gate a meaning again. This possibility and others should be investigated; it would be unacceptable for such damage to be done to the setting of a listed structure without a coherent and resolved treatment for that structure to be one of the outcomes.
For these reasons the application would cause substantial harm to the Forecourt Wall and Gates.
Paragraph 133 of the NPPF states that in this scenario 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 four tests are satisfied. The necessity for this loss has not been demonstrated, given the clear potential for a development at a similar scale that would retain the original podium level and the screen wall connecting the Wall and gates to the rest of the Goodsyard, enabling the Wall and Gates to retain its significance.
Non-designated heritage assets – other brick vaults
We welcome the retention of the arches to the south of the Braithwaite Viaduct (while noting that development is not possible in this area of the site due to it being reserved for the possible future widening of the railway tracks out of Liverpool Street). The retained London Road promises to be a unique and fascinating street. It is unfortunate that Network Rail is insisting on it being screened so excessively from the railway, given that the views out over the railway cutting are an important element of its character; pressure should be put on Network Rail to adopt a common sense compromise approach here rather than the blanket adoption of abstract standards which threaten to spoil the street while having a negligible impact on safety.
The removal of the arches between the Braithwaite Viaduct and the listed gateway (a valuable non-designated heritage asset) would be damaging to the setting of bothlisted buildings, fragmenting a cohesive and important industrial complex and townscape, and would also mean the destruction of large amounts of important nondesignated heritage assets. The hydraulic accumulator in Arch V36 is an important and impressive part of the heritage of the site, and its retention and repair should be a condition of any consent.
We defer to the Georgian Group on the impact of the proposals on 70-74 Sclater Street.
66-68 Sclater Street, a double-fronted residential building with shops below dated 1877, is proposed to be demolished. It is within the Brick Lane and Fournier Street Conservation Area. The heritage assessment states that it is of low significance; in fact it is just the sort of handsome but not extraordinary historic building that conservation area status is designed to protect. It also plays an important role in the setting of the listed weavers’ cottages next door. Its demolition would harm the conservation area and has not been adequately justified.
We welcome the retention of the screen wall on Sclater Street, an important contributor to the character of the area. However, we note that several large openings are proposed to be made in it for vehicle servicing. These would erode the sense of enclosure that is an important aspect of the character of the Goodsyard; it would be much better for vehicle servicing to take place from Wheler/Braithwaite Street rather than Sclater Street. The lowering of the cills of some of the windows within the screen wall arcades is understandable; but some should be kept at their original level as well to show the original form.
The former mission room on Sclater Street appears to be an interesting and rare survival, part of the history of the East End. Its full scholarly restoration as a selfcontained building with its original roof should be a condition of consent for any scheme. It should also be assessed for designation if this has not yet been done.
While the screen wall on Sclater Street is to be kept, Plot E seems to completely envelop it, with building above, below and both sides. It is unclear how structurally feasible its retention is in this scenario; what is clear is that it would be largely invisible and that its significance, as the architectural expression of the edge of the Goodsyard, would be lost. This would again harm the conservation area of which it forms the boundary at this point. This aspect of the scheme should be rethought – there should be separate buildings to either side of the wall with different architectural expressions and scales, and space left between the buildings to the north and the wall.
Proposed new buildings
In terms of the new buildings proposed for the site, there are two sets of questions. The first is the appropriate scale of development. The second is the precise architectural expression. There can be no doubt that towers of up to 48 storeys would have a major impact on the skyline of east London. The CGIs confirm this. Views from a number of conservation areas that are currently low-rise will have the sudden intrusion of very tall buildings, casting huge amounts of shadow and utterly changing the context of important areas like the Boundary Street Estate and Shoreditch. They would dominate the modestly scaled historic urban landscape. The scale chosen relates to the character of the City, not that of Shoreditch and Spitalfields. Here the lack of a clear and comprehensive London-wide policy on where tall buildings should or should not go becomes apparent. In the view of the Victorian Society such a sensitive area is the wrong place for tall buildings. Substantial harm would be done to the setting of the surrounding five conservation areas and a large number of listed buildings.
Even if your authorities take the view that tall buildings are acceptable on this site in principle, a separate question arises about the quality of these designs. Any building that is 48 storeys high and will be seen by millions of people every day and will form an important part of the skyline of London could only ever be acceptable if it was of the very highest architectural quality.
The large buildings proposed for this site are not of a quality commensurate with the historic buildings that will surround them. They do not adequately respond to the surrounding context. Their design is generic and undistinctive. In a suburb of Shenzhen they would be unremarkable; in central London they are completely unacceptable.
For all the reasons above we recommend that this application is refused. It represents gross over-development and would harm the setting of a number of listed buildings and conservation areas. Given the magnitude of the impacts described above the application should be referred to the Secretary of State; we urge him to call it in for determination at a public inquiry.
Monday 15 December, 2014