Mr. Alex Bushell27
th
January 2011Major Developments TeamCamden Borough CouncilCamden Town HallJudd StreetLondonWC1H 9JEDear Sir,
Middlesex Hospital Annexe, 44 Cleveland Street, W1T 4JU
Application Numbers 2010/2205/P and 2010/2209/C.Re: Archaeology and Heritage
I am writing to you on behalf of RESCUE – The British Archaeological Trust. RESCUEis a non-political organisation which exists to support archaeology and archaeologists inBritain and abroad. We receive no support from government and are entirely dependenton the contributions of our members to fund our work. Details of our activities can befound on our website:www.rescue-archaeology.org.uk .Please note that this
communication and any response we may receive as a consequence will be placed on our website for the information of our members.We wish to register
strong objections
against
both
of the above-cited applications.According to PPS5, "
Local Planning Authorities should require an applicant to providea description of the significance of the heritage assets affected and the contribution of their setting to that significance... As a minimum, the Historic Environment Record should have been consulted and the heritage assets themselves should have beenassessed using appropriate expertise where necessary given the application's impact.Where an application site includes, or is considered to have the potential to include,heritage assets with an archaeological interest, local planning authorities should requiredevelopers to submit an appropriate desk-based assessment and, where desk-based research is insufficient to properly assess the interest, a field evaluation.
" The Heritageand Urban Design Appraisal that has been submitted to accompany these proposals does
not
fulfill these requirements, is thoroughly inadequate and not fit-for-purpose as a
Heritage Statement. In support of this contention, the following points should be takeninto consideration:
•
There has been no discernable consultation with the Historic Environment Recordto inform this Heritage and Urban Design Appraisal. This is a
mandatoryminimum
for the compilation of a Heritage Statement, and it should be rejectedwithout firm evidence of this.
•
According to the Appraisal, the site was previously a paupers’ burial ground untilits acquisition for the construction of the Covent Garden Workhouse, which wascompleted in 1778. However, the Appraisal pointedly fails to expand on thisimportant aspect of the site’s history. Just what exactly happened on this site
prior
to 1778? What was on this site in the Medieval period (for example)? Howlong was the paupers’ burial ground in use and what was its extent? Was itcleared prior to the construction of the workhouse (there should be records), or merely built over? Are there a large number of extant burials on this site that willrequire archaeological excavation should the development proceed, or has thestanding structure destroyed any evidence of their presence? If there are burialshere, they would most certainly qualify as Heritage Assets under the definition of PPS5, and they would require specialist analysis. Potentially, they could providevaluable and significant information relating to the local lower social class populations of this part of London in the period up to 1778. These are important points that will affect the financial viability of any development scheme – yet theyare ignored in the very document that should be addressing them. These issuesshould be discussed in detail, and on the evidence provided the site should bearchaeologically evaluated prior to determination of either of the applications, inorder to assess these questions.
•
As outlined in PPS5 above, a Heritage Statement should assess the “significance”of the site. However, this is clearly not attempted in this Appraisal. There are no phased plans or elevations presented outlining the chronology of the developmentof the site, and nor is there any written description of the interior of the structureand surviving elements. Nor are there any photographs of the interior – in factthere is no evidence presented that indicates any study of the interior of this building was undertaken at all. All that is presented, is a short preamble regardingthe “history” of the existing building which largely concentrates on “damage” – whether by rebuilding, additions or bombing – without attempting to clarifywhether or not these episodes have detracted from the significance of the site.Paragraphs 3.13 – 3.15 are particularly evidential of this deficiency. At no point isany attempt made to outline the surviving elements of the structure that mightrender it of significance under the terms of PPS5. Instead, broad statements aregiven outlining the absorption of the 18
th
century building within a 19
th
centuryone (is this structure not significant also?), bomb damage, “poor quality repairs”,the unoriginal roof and supposedly altered interior. So what exactly does survivehere?
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