Recommendation: Refusal

I have significant concerns about this proposal. There are elements of the scheme, mainly the raising of the levels in order to build above the flood level and the principle of a fairly large quantum of building development, which have already been considered in the earlier proposal which formed part of the outline master plan for Hayle Harbour. In my view these were, and remain, harmful proposals in themselves. However, the harm done by those proposals were weighed against a comprehensive set of proposals for repairs and refurbishments to the heritage assets of the wider harbour area. In this present proposal no such wide-ranging heritage benefits would accrue. I therefore consider the harm to outweigh the benefits to the listed buildings and the character and appearance of the conservation area.

While it is true that South Quay has at present an untidy and in some areas, a rather unsightly appearance, this is largely due to the unattractive infill which has been deposited. It seems to me that there must be less harmful ways of delivering improvements to the status quo than the development proposal now before me. The ideal use of South Quay in my view would be as well-designed, fairly small scale, low intensity development area nearest to the viaduct, ideally achieved without raising the level of the buildings significantly above the existing levels, with the seaward part enhanced to form high quality public open space. Such a scheme would harmonise with the character of the conservation area and would preserve the setting and the physical substance of the listed quays. Given the importance of Hayle Harbour as part of the World Heritage Site it seems possible that some form of heritage grant aid could enable such a scheme to take place. The quay walls are in need of repair, but my feeling is that there is not such urgency about this as to require the local planning authority to permit harmful development just in order to bring about those repairs more quickly. It would be better to work towards a scheme which is beneficial all round.

The layout of the proposal places a large monolithic building in the central part of the quay, where it will be very dominant in views within the conservation area. The history of development on South Quay is of fairly low, modestly sized buildings, with storage of materials around the quay. This is a strong departure from that established character, and one which I find harmful to the character of the conservation area and to the setting of the listed quay walls. The indicative illustrations suggest a building of a large scale which has really nothing in character or aesthetics, scale or materials, in common with the strong local vernacular of Hayle’s modestly-scaled, rather polite, stucco terraces, nor with its heritage of robust granite commercial and industrial buildings. Using this interesting historic waterfront area for extensive parking I also find incongruous and regrettable.

To sum up, I find the harm to the setting of the listed buildings and to the character and appearance of the conservation area to strongly outweigh the benefits of the proposed repairs to the heritage assets.

Thank you for supplying a copy of the working draft of the Heritage Report, prepared by Planning Perspectives. I appreciate that this is a working draft, and is subject to amendment and comment. I had prepared draft comments on the proposals (based on the previously available information boards) which I have attempted to amend in light of the working draft supplied; however, given the timing of the receipt of the working draft and the need for our comments to be supplied in time for tomorrow's meeting, I have been unable to study the document in great detail. These comments are, therefore, supplied on the understanding that they may be subject to amendment / clarification.

With regards to the draft heritage statement, I would seek clarification / amendment to para. 2.24. Given the extensive nature of the WHS, OUVs statements prepared for the CWDMWHS are general, and have not been prepared to a site by site level. This does not mean that "Hayle did not officially demonstrate any OUVs on its own". We would expect the heritage statement would draw out the OUVs (in consultation with the WHS team / EH / etc as applicable) as they relate to Hayle Harbour, as well as discuss the impact of any proposals on those OUVs.

I am concerned regarding the fact that the developer chose to undertake a period of public consultation on a proposal prior to seeking the views of statutory consultees, and may in effect be raising public expectation regarding proposals which might be unacceptable. As the Government's advisor on the historic environment, who may ultimately have to brief the DCMS on our views, it is of particular concern that we were not engaged directly at an earlier stage.

With regards the proposals we have limited our consideration to the preferred option. English Heritage have previously been supportive of development around the Harbour on the basis that it secured the repair and long term future of its historic assets (both designated and undesignated). It is, therefore, disappointing that whilst the intention to repair the harbour walls remain, that it is now no longer intended to remove the spoil previously dumped in the harbour. Whilst it appears that it is not proposed to build a structure on the area of land created by the spoil (?), the use of this land for essential infrastructure (roads, etc) will ensure that this spoil cannot be removed for the lifetime of these proposals, if ever. This represents a serious diminution in the heritage benefits of the proposals. We would expect all of the previous heritage benefits negotiated as part of the previous outline application to remain.

The level of visual information provided with these proposals, which consists of one plan and four artist's sketches, is poor. This is a major development in a historic environment of international importance. It is essential that those assessing the proposals are provided with sufficient information to enable a clear view to be formed. There are also concerns regarding the accuracy of the information, with the heritage statement making reference to the creation of a pedestrian bridge across Penpol Creek, but no such bridge appears on any drawings. That said, even with the limited amount of information provided these proposals raise serious concerns.
Whilst we recognise the need for a viable use to be found for South Quay, the current proposals raise significant issues regarding the principle of accommodating a supermarket of this size in this location. Whilst an argument could be made that one might expect to find warehouses and/or similar utilitarian industrial on a quayside location, these would be of a different scale and nature to such a large retail supermarket. This concern relates not just to the building itself, but also to its surrounding infrastructure and car-parking; which would be of a wholly different, and unacceptable, character to historic quayside open-spaces.

The current proposals appear to be driven by the desire to accommodate a supermarket of a particular size (including car-parking, etc) on the site, without due regard to its context. The proposals do not consider the site within its overall context, and potentially indicate a piecemeal and disjointed approach to the regeneration of Hayle. It fundamentally fails to consider the wider master-planning of the area and, in doing so, could jeopardise the long-held aspirations to regenerate Hayle in a holistic and considered manner. In this regard it ultimately fails to achieve sustainable development as set out in PS1.

Clearly the proposed building will be out of scale with any other building in the immediate area, in terms of its footprint and bulk, and will be an incongruous element. The indicative illustrations indicate that far from being a utilitarian structure, with a grain and appearance suitable for this historic quayside location, it is more akin to an out-of-town retail park. In addition to concerns regarding the bulk and form of the building, we would also be concerned regarding the desire of any supermarket operator to "brand" the building, with signage, colouring, etc. The location of the proposed supermarket does nothing to integrate it with its surrounding urban context; and indeed its access route and servicing yard will, potentially, blight the tip of the South Quay.

Concerns regarding the inappropriate scale and appearance of the supermarket building itself also extend to the surrounding car-park. This usage will dominate the open space on the quay and, along with associated signage, landscaping, shopping trolley corrals and stores, will be an incongruous element within the WHS and Conservation Area.

Given that the surrounding conservation area has been in receipt of funding from a THI scheme and EH, we would also recommend that you are confident that a large supermarket in this location would not adversely affect those existing regeneration initiatives.

This is a poor quality and, apparently, opportunistic proposal which takes no account of its sensitive location, within the WHS and Conservation Area. In addition to the harm to those heritage assets it fails to deliver all the heritage benefits previously tabled. We would wish to be involved in offering pre-application advice on this site, but would object to the current proposals as they stand.
I hope these comments are of use.
Regards
Simon Ramsden, English Heritage

As per my phone message(s) last week, English Heritage wish to object to the proposals on South Quay, on the basis of harm to the WHS, Conservation Area, etc., as set out in our comments at pre-application advice stage.

Following further site visits and discussion (since those comments were prepared), there may be elements of our comments we would wish to supplement, but they cover the salient points.

Further consideration has been given to the issue of the covered slipways; the previous outline (which Penwith were minded to approve subject to a S106) proposed exposing the historic slipways, which we regarded as a benefit to the scheme and to the OUV of the site. The current scheme does not propose to reinstate them, and indeed proposes to build over them. Although we cannot be sure that the slipways are under the spoil (and only a physical excavation would answer that question), based on the information we have there is a high probability that they are below ground. We would wish any scheme coming forward (possibly in conjunction with the adjacent site), to re-expose / reinstate the historic slipways we would not support building over this area for two reasons; firstly that it would, in all likelihood, damage the slipways and secondly that it would prevent the possibility of their exposure, for the lifetime of the building (and possibly beyond).

Given that pre-application discussions are commencing on the adjacent site, this would seem an ideal opportunity to bring forward a coordinated approach to the slipways.

Simon Ramsden
Team Leader: Devon, Cornwall and Isles of Scilly Team
English Heritage
29 Queen Square
Bristol
BS1 4ND