EAST END WATERWAY GROUP
SECOND MARCH 2020 NEWSLETTER
GASHOLDER SPECIAL TEN: BETHNAL GREEN
UNIQUE CANALSIDE HERITAGE BEING DESTROYED
IN BICENTENARY YEAR OF REGENT’S CANAL
The 30-day consultation period started on 28 February 2020 but St William Homes’ HERITAGE STATEMENT (dated March 2020) was not posted on the Council’s website until 12 March 2020. To complicate matters further, there are two other heritage documents submitted as part of the Environmental Statement. The first to be put on the website is a BUILT HERITAGE document.
This reveals that both in-ground tanks are to be removed. This means that the dismantled guide frames would probably be put back on new pile-driven foundations – completely destroying the significance, archaeological interest and structural integrity of both the No.2 and No.5 gasholders (see PETITION TO ST WILLIAM HOMES (paras 1 and 2). It also means that the dismantled guide frames are not being ‘reinstated’ (which means they are being put back on their original in-ground tanks) but are being re-erected more or less on their present sites – without their original holding-down bolts (which connect the frames to their original in-ground tanks); and without their original guide rails and roller carriages (see drawings and images, in particular drawing RSHP-P-0410-D-El and PETITION TO ST WILLIAM HOMES para 3).
The re-erected guide frames will, therefore, be further stripped of their significance and archaeological interest. And to compound this gross act of heritage vandalism, the stripped guide frames will be painted almost black so that, in the case of the No.2, it would no longer be possible to see and appreciate the various classical details.
This destructive approach is justified In the Heritage Statement by Montagu Evans: the same heritage consultants who were employed by National Grid Property Holdings (part of St William Homes) to assist Historic England with a last-minute assessment of the remaining gasholders in London so that National Grid’s gas sites in London could be cleared of any surviving gasholders for maximum residential re-development. MONTAGUE EVANS APPLIED TO ENGLISH HERITAGE FOR A CERTIFICATE OF IMMUNITY TO PREVENT THE LISTING OF ALL FOUR GASHOLDERS AT BETHNAL GREEN, FOR FIVE YEARS.
Not surprisingly, Montagu Evans ignores all the evidence provided by the EAST END WATERWAY GROUP and gives the two historic gasholders at Bethnal Green a very low level of significance. This deeply-flawed undervaluation of the historic gasholders is partly based on the Certificate of Immunity (from listing) applied for by Montagu Evans and issued by English Heritage in February 2015, which failed to recognise the high evidential, historical and aesthetic value of the No.2 and No.5 gasholders. See the amended SIGNIFICANCE, ARCHAEOLOGICAL INTEREST AND POSITIVE CONTRIBUTION OF THE No. 2 AND No. 5 GASHOLDERS AT BETHNAL GREEN for a summary of their actual value and their substantial positive contribution to the character and appearance of the Regent’s Canal Conservation Area. The substantial contribution as set out in the summary would be destroyed by:
The No.2 and No.5 gasholders are not “above ground gasholders” (HS p.5), they are gasholders with three parts; and of the three parts, the guide frames on their original in-ground tanks are the two parts which contribute most to the significance of each gasholder and the significance of the Regent’s Canal Conservation Area. To maintain the structural integrity of the unique gasholders, the highly visible guide frames must be retained on their mostly-concealed original foundations.
The upper parts of the wide circular walls in both archaeologically interesting in-ground tanks are slightly exposed above ground and their tops are seen between the pedestals of the superimposed columns and between the bases of the tapering box-lattice standards.
The proposed dismantling of the guide frames to remove and replace their original foundations is like dismantling Blackpool Tower to remove and replace its original foundations.
NATIONAL, REGIONAL AND LOCAL PLANNING POLICIES
The destruction of the substantial positive contribution to the character and appearance of the LBTH Regent’s Canal Conservation Area would not “preserve the significance of gasholders Nos.2 and 5” (HS 6.6) and the “significance of these assets would” not “be enhanced through the refurbishment and creative reuse of the frames” (HS 6.11) and would result in substantial harm to the conservation area; and the local planning authority should, therefore, refuse consent (NPPF para 201 and 195).
Furthermore, both historic gasholders (with all three of their original parts) are listed in the CA appraisal among “the elements which form part of the canals special character and interest” and as the largest and most distinctive of those elements, they are “elements which contribute” to the “special character or appearance” of the Regent’s Canal Conservation Area. And, although they are non-designated or unlisted heritage assets, there is “a presumption in favour of the retention of unlisted buildings that make a positive contribution to the character and appearance of a conservation area” (Local Plan Policy S.DH3 para 6) regardless of the 2015 Certificates of Immunity. Also , “development within conservation areas” should “enhance or better reveal their significance”, which is clearly not the case with St William Homes’ proposed development. The proposals as set out above would, therefore, contravene Local Plan Policy S.DH3 para 6. And, because they also “fail to preserve or, where appropriate, enhance the borough’s designated and non-designated heritage assets in a manner appropriate to their significance” (in this case, the assets are the Regent’s Canal Conservation Area and the non-designated but highly significant No.2 and No.5 gasholders), the proposals would also contravene Local Plan Policy S.DH3 para.1.
The proposals would also contravene Site Allocation 1.3 – Marian Place Gas Works and The Oval (LBTH Local Plan adopted January 2020). This includes the design principle or requirement that Gasholders No.2 and No.5 are heritage assets to be retained reused and enhanced. Clearly reuse of the three-part gasholders requires the removal of their telescopic bells (and the water in the in-ground tanks) but the failure to retain the other two highly significant attached parts of the three-part gasholders (i.e. the guide frames on their original in-ground tanks) would be a clear breach of Site Allocation 1.3 in the borough’s recently adopted Local Plan. The failure to properly retain the guide frames by the proposed dismantlement and re-erection on new pile-driven foundations, without their archaeologically important holding-down bolts, guide rails and roller carriages, would also be a breach of Site Allocation 1.3 in the borough’s recently adopted Local Plan.
The proposals would also contravene Policy HC 1 in the new London Plan.
Policy HC 1C states that “Development proposals affecting heritage assets …. should conserve their significance” and “should avoid harm”. This means that the significance or special interest of the two historic gasholders (especially the guide frames on their original in-ground tanks) should be properly looked after and not harmed in any way.
Policy HC 1D states that “The protection of undesignated heritage assets of archaeological interest equivalent to a scheduled monument should be given equivalent weight to designated heritage assets”.
This means that, as the No.2 guide frame on its original in-ground brick tank is an undesignated or unlisted heritage asset with the same level of archaeological interest as a scheduled monument (see amended SIGNIFICANCE, ARCHAEOLOGICAL INTEREST AND POSITIVE CONTRIBUTION OF THE No.2 AND No.5 GASHOLDERS AT BETHNAL GREEN), the local planning authority has a duty to recognise the high archaeological interest of the No.2 guide frame on its original in-ground brick tank, and give it the same protection as a designated or listed heritage asset.
Also to recognise that the No.2 guide frame and the No.2 in-ground tank are each of sufficient significance and archaeological interest to be conserved together, and to ensure that both parts are conserved in situ without any dismantlement; and that there is no loss of historic fabric (including integral parts of archaeological importance or interest – such as the rarely surviving concealed holding-down bolts, the guide rails and roller carriages).
LETTERS OF OBJECTION
Please write or e-mail letters of objection to the destructive proposals to [email protected] (quoting PA/19/02717/A1 by 28 March 2020 or soon after – this is a large application and Tower Hamlets usually continues to accept comments after the consultation period).
Please bear in mind that for your objections to be treated as ‘material considerations’ they must be along the lines set out above and refer to the relevant national, regional or local planning policies (including Site Allocation 1.3 in the LBTH Local Plan). Please include demands for:
The world’s oldest surviving large gasholder guide frame on its original in-ground brick tank (and the circular grassed public open space) would be maintained and insured by the purchasers of the flats in proposed Building A
AND/OR IF YOU HAVE NOT YET SIGNED THE PEITITION TO TOWER HAMLETS COUNCIL (which mentions the in-ground tanks) PLEASE SIGN ASAP AND ENCOURAGE OTHERS TO SIGN (www.BIT.do/plan-object)