APPRAISAL OF COLPAI BY ALEC FORSHAW

AN INDEPENDENT APPRAISAL OF PROPOSALS FOR THE RICHARD CLOUDESLEY SCHOOL, GOLDEN LANE EC1

L.B.Islington Planning Application Ref: P2017/2961/FUL

City of London Planning Application Ref:

Demolition of the former Richard Cloudesley School, City of London Community Education Centre, garages and substation, erection of a 3 storey building with rooftop play area (Class D1) (2300.5 sqm GEA) and a single storey school sports hall (Class D1) (431 sqm GEA) to provide a two-form entry primary school, erection of a 14 storey building to provide 66 social rented units (Class C3) (6135 sqm GEA), landscaping and associated works. Duplicate application submitted to the City of London as part of the site falls within the City.

Brief Description of Proposals

1. The scheme proposes the comprehensive redevelopment of the former Richard Cloudesley School and part of the north edge of the Golden Lane Estate, comprising a mixed use scheme to provide a new two-form primary school (the City of London Primary Academy), plus nursery provision, together with a new block of housing facing Golden Lane.

2. The school comprises an L-shaped three storey classroom range plus a screened rooftop play ground which effective creates a scale of four storeys. In addition there is a single storey double-height hall on the south side.

3. The residential block occupies the frontage to Golden and rises to 14 storeys in height for most of its length, and comprises 66 flats.

4. The site straddles two boroughs. While the majority of the site lies within the London Borough of Islington, the southern edge of the site encroaches into the City of London. Planning applications are therefore being made to both local authorities by the applicant who is the City of London Corporation.

Method of Appraising the Proposals

5.  This document appraises the current proposals in terms of its various impacts on designated and undesignated heritage assets, and assesses its merits against the following material considerations:

-       National Planning Policy Framework March 2012

-       National Planning Policy Guidance March 2014

-       The London Plan 2016

-       London Borough of Islington Local Plan 2013

-       Finsbury Local Plan (Area Action Plan for Bunhill and Clerkenwell) 2013

-       St Luke’s Conservation Area Guidelines

-       City of London Local Plan 2015

-       City of London Golden Lane Estate Supplementary Planning Guidance 2013

THE SITE, THE HERITAGE ASSETS AND THEIR CONTEXT

6. The majority of the site includes the former Richard Cloudesley School, built in the early 1970s as a special needs school for the London Borough of Islington. This was constructed on land that had previously been occupied by buildings on the south side of Hatfield Street and the north side of Basterfield Street, which had run west of Golden Lane, parallel to Baltic Street before the war. The older buildings here and further south had been bombed and cleared after the war to provide an area for comprehensive redevelopment which included the Barbican and Golden Lane sites.

7. The existing school buildings, now vacant, are low-rise, and in a modernist style with distinctively angled pitched roofs. The frontage to Baltic Street retains brick boundary walls from the old Board School playground.

Golden Lane Estate

8. The site lies immediately to the north of the Golden Lane Estate, and includes part of the original curtilage of the Estate, presumably with the intention of creating a straight southern boundary and a larger development site. The Golden Lane Estate, designed and constructed between 1952 and 1960 by Chamberlin Powell and Bon, is a Designated Heritage Asset of exceptional significance and importance. It is recognised as one of the best and most influential post-war housing estates in Britain and is statutorily listed Grade II, and partly Grade II* (the Crescent House frontage to Goswell Road).

9. The Golden Lane Estate originally lay within the Metropolitan Borough of Finsbury, which became part of the London Borough of Islington in 1965, but following the boundary changes of 1994 was transferred into the City of London. This appeared to make some sense at the time, as the Golden Lane Estate was owned and managed by the City Corporation, and still is.

10. A petition of some 767 signatures has been presented to the City Corporation requesting the designation of a new conservation area to include the Golden Lane Estate and neighbouring sites including Bernard Morgan House, and the Corporation have agreed to investigate this and report back.

St Luke’s Conservation Area

11. The site lies partly within the St Luke’s Conservation Area, first designated by the London Borough of Islington in 1975 but substantially extended in 2002. The Conservation Area includes the 1888 Board School in Baltic Street, now occupied by the London College of Fashion. The western end of the original curtilage of the Board School, beyond the school keeper’s house is within the application site, including the brick school playground boundary walls.

12. The former school is a particularly fine example of its type designed under the direction of the London County Council architect E.R.Robson. It has an impressive north elevation facing Baltic Street, with an expressive gable visible along Honduras Street, but also boasts a fine southern elevation in the form a broad curving bay. This was always intended to be seen by the public from the street, facing as it originally did onto the north side of Hatfield Street, which had buildings only on its southern side. The southern elevation of the Board School remains clearly visible from Golden Lane and contributes very positively to the character and appearance of the area.

13. The part of the St Luke’s Conservation Area which is close to the application site is characterised by primarily late 19^th century commercial buildings, former warehouses, mainly 3 or 4 storeys in height. The buildings on the corner of Baltic Street and Golden Lane are particularly good examples and together with the school, make an important contribution to the character and appearance of the conservation area.

14. Particular care has been taken by the local planning authority over the last twenty years in controlling roof extensions in this part of the conservation area. Roof extensions on existing three or four storey buildings in Golden Lane, Banner Street, Garret Street and elsewhere have been modestly scaled and set back from the street frontage to minimise their impact.

15. The only tall building within the St Luke’s Conservation Area is the tower and spire of St Luke’s Church, which is a significant historic landmark. The top of the tower, with its unusual taper and extraordinary weather-vane can be seen from Fann Street, south of the Golden Lane Estate, across the top of Basterfield House.

POLICY CONTEXT

National Planning Policy Framework

16. Various parts of NPPF are relevant to the development of the site, including a requirement for good design and sustainable development, provision of good quality housing, and policies on conserving and enhancing the historic environment.

The London Plan 2016

17. The London Plan provides an important context for housing standards, density of development and the paramount importance of good design.

Local Development Framework

18. Islington’s Local Plan provides guidance on the suitable locations for tall buildings across the Borough. The application site is not an area that has been identified by Islington Council as being appropriate for high buildings. It does not form part of or lie close to the cluster of tall buildings around the Old Street roundabout and the adjacent part of City Road, or the clusters around City Road Basin or Chiswell Street. These locations for existing and new tall buildings are a long way from the application site, and have no visual connection.

The Finsbury Local Plan 2013

19. The site lies within an area identified in Figure 17 of the Finsbury Local Plan where a building height of around 6 storeys would be appropriate. Policy BC9 makes it clear that “the existence of a tall building in a particular location will not of itself justify its replacement with a new tall building on the same site or in the same area”.

20. The site is allocated as Site BC34 in the Finsbury Local Plan which makes specific proposals for future development of the Richard Clousdesley School site. It notes that the previous school function will be fully incorporated within the Golden Lane Campus, and recommends that the site is redeveloped to provide housing, open space and play facilities. It states that any new buildings should be sensitively designed to minimise impacts on neighbouring residential buildings, and that proposals should conserve and enhance heritage assets, including the neighbouring locally listed buildings to the north, the Golden Lane Estate, and the St Luke’s Conservation Area.

21. The site also falls within an area of deficiency in access to nature. The Finsbury Local Plan states that public open space should be provided to offset the loss of playground space and to relieve pressure on Fortune Street Park.

Conservation Area Policies

22. Policies for the St Luke’s Conservation Area stipulate that new buildings and extensions to existing buildings, should conform to the height, scale and proportions of existing buildings in the immediate area, using materials sympathetic to the character of the area in terms of colour and texture

Golden Lane Estate Listed Building Management Guidelines Supplementary Planning Guidelines 2013

23.  This important document, produced jointly by English Heritage (now Historic England) and the City of London Corporation, and adopted by the City Corporation as SPG in 2013, stresses the holistic significance of the Golden Lane Estate. “The Estate should be appreciated in its entirety: not only for its various components but also for its setting within the surrounding urban fabric. The views from and into the Estate have become important, and part of its special interest lies in its relationship with adjoining buildings. Their height, scale, mass form, materials and detailing could, for example, have an impact on that special interest. Any development on the immediate boundaries of the listed area should take into account the significance of the Estate’s setting. No new buildings, infilling, removals or extensions should be introduced which would be detrimental to the integrity of the Estate as a whole. The relevant local authority should, therefore, take into account the significance of the Estate’s setting to its special architectural interest when considering any developments on the immediate boundary of the Estate.”

EVALUATION OF PROPOSALS

Demolition

24. The existing Richard Cloudesley School buildings are of some interest as an example of the typology of low-rise primary schools built in Islington by the Inner London Education Authority (ILEA) in the late 1960s/early 1970s following the Plowden Report 1965 which recommended a domestic scale – ‘little buildings for little people’. It is acknowledged however that the original special needs educational use of the buildings has ceased, and been relocated nearby in the Golden Lane Campus. Redevelopment is acceptable, in principle.

25. The proposal involves the demolition of part of the original Board School boundary wall on Baltic Street, west of the former School House, which is regrettable and avoidable, at least in its totality.

Archaeology

26. The site lies within the Moorfields Archaeological Priority Area, and there is potential for significant archaeology on the site, a short distance outside the Roman city walls. It seems most unlikely that a thorough investigation of the site was carried out after the war. At the very least, a watching brief is required while demolition, excavations and foundation works are being carried out on any new development.

Scale and Massing of New Buildings

27. The proposed residential block rises to a height of 46 metres above ground level, which makes it a tall building in policy terms, well over the threshold of 30 metres. The site lies outside an area where tall buildings are either promoted or considered appropriate, and thus presents a fundamental conflict with policy.

28. Islington’s policy on tall buildings does potentially allow exceptions where there are exceptional or outstanding design merits for the proposal. That is very definitely not the case with the current proposal, which breaks almost every principle of good urban design.

29. The scale and height of the residential block poses serious challenges to the existing townscape and historic environment. It will be extremely dominant in the immediate and wider urban context. In terms of the conservation area it will challenge the scale and dominance of the spire of St Luke’s Church (Grade I listed), which is the main landmark in the area. It will have a hugely detrimental impact on the listed Golden Lane Estate.

30. While there are post-war residential slabs to the south and south-east of the site, it is significant that none of these lie immediately on the back edge of any existing street line, but are set back and located within substantial areas of open space, following Corbusian principles. All the blocks on the east side of Golden Lane, with the exception of the very narrow six-storey No.88, are well set back from the street, so that their impact is reduced. Most of the Peabody Estate buildings are 6 or 7 storeys, very similar to the lower blocks of the Golden Lane Estate. The 13 storey Peabody Tower is well set back from the street, behind a well-planted garden.

31. An argument is put forward by the applicant that the proposed residential slab relates to and replicates the mass of Great Arthur House, and thus acts as a natural and acceptable ‘extension’ to the Golden Lane Estate. The argument shows a complete failure to understand the master plan and overall layout of the Golden Lane Estate. Great Arthur House is the centre-piece of the estate, oriented north-south and carefully placed as part of the orthogonal estate layout so that the width of the open areas to its east and west were equal to or greater than the height of the block. Put more simply, Great Arthur House could be laid down on its side in either direction in the communal spaces to its east or west. For Chamberlin Powell and Bon, the spaces between the buildings were as important as the buildings themselves.

32. By contrast, the proposed tower on the application site (actually taller than the residential element of Great Arthur House excluding its sculpted roof element), has no space around it to ameliorate or soften its massive bulk. The proposed residential slab is positioned so as to rise hard up against the existing pavement, both denying it any space in which to stand, and resulting in an over-bearing impact on the street.

33. While it may have been accepted by the City of London within its ‘cluster’ of tall commercial buildings in the eastern part of the City that these might rise vertically from the back-edge of pavement (e.g. the Bishopsgate Tower), producing a New York-style canyon effect, this is not a premise that should be remotely acceptable in a residential or mixed residential/commercial area.

34. The urban design and heritage consultants for the applicant presume that because there are some tall buildings within the vicinity of the site then there is a straightforward case for allowing another. It is a false and self-serving argument. If repeated elsewhere in Islington it could be used to justify towers anywhere in the borough, for example at Highbury Corner (next to Dixon Clark Court), Clerkenwell (next to Michael Cliffe House) or in King’s Cross (next to Bevin Court).

35. In terms of the application site the very tall Barbican towers are a considerable distance away. Indeed when viewed from the east side of Golden Lane between Garret Street and Banner Street the Barbican towers appear to be a similar height to Great Arthur House. This also happens to be one of the best public views of the ensemble of the listed Barbican towers and Great Arthur House, with the low-rise elements of the Golden Lane Estate in the foreground. The proposed residential slab will block this view. It will be overpoweringly prominent in views along Golden Lane, from Old Street in the north and approaching from the south from Beech Street. It will rise dramatically above the existing low-rise blocks of Basterfield House, Stanley Cohen House, Bowater House and Bayer House.

36. From within the Golden Lane Estate the new slab will loom over Basterfield House when viewed from the communal open space to its south. The size and proximity of the new residential block will have a very detrimental impact on the appearance and setting of the Golden Lane Estate. It will destroy the prominence of Great Arthur House as the focus of the Golden Lane Estate.

37. Overall, the proposals cause very serious harm to the setting of the Golden Lane Estate, and run completely contrary to the principles involved in its original layout. The Golden Lane Estate Listed Building Management Guidelines are admirable in extolling the high importance of the Estate, its layout and its setting. Given that English Heritage was a contributor and co-author of the Guidelines, it is extraordinary that the current advice of Historic England appears to pay them little attention.

38. From within the St Luke’s Conservation Area the proposed residential block will be very dominant, rising above the gable of the former Board School in Baltic Street when viewed from Old Street along the length of Honduras Street. The contrast in scale between the new slab and the commercial buildings in the conservation area will be extreme, a juxtaposition which Chamberlin Powell and Bon handled with far greater sensitivity and understanding with the design of Hatfield House.

39. Similarly the view westwards along Banner Street from Whitecross Street will be dominated by the proposed new block on the west side of Golden Lane, belittling the scale of buildings within the conservation area on the north side of Banner Street.

40. The new frontage to Golden Lane will block existing views of the fine south elevation of the Board School. Only a limited side-on view will remain visible in the narrow gap left in the Golden Lane frontage. The applicant’s argument in paragraph 7.148 of its Planning Statement that the new residential building will improve the setting of the locally listed buildings ‘by removing a gap’ and ‘providing a better townscape context’ is extremely unconvincing. The locally listed buildings will be simply dwarfed by the proposals.

41. The view of St Luke’s spire currently visible from Fann Street will be lost, obstructed by the proposed new residential block.

42. The scale of the new L-shaped school block is also not inconsiderable, slightly higher than the Victorian Board School which it abuts, and equal in height to Hatfield House. Even without the residential element, the new school on its own would present a sizeable addition to the townscape.

Design

43. It is telling that the applicant has chosen to attempt to differentiate the tall element of the residential block by placing it on a podium (although neither the tower or podium are set back from the pavement edge building line). The podium block, in dark materials, attempts to be sympathetic with the architectural language of Basterfield and Stanley Cohen Houses, as if to concede that this is an appropriate scale and design for the street. The attempt to ‘disguise’ the tall element by using paler colours, as if it might somehow disappear or recede from view, is an unconvincing and unsuccessful device.

44. In terms of being an ‘outstanding’ or ‘exceptional’ design, which might justify a major departure from tall buildings policy, there is nothing to indicate this is the case. Islington Council’s Design Review Panel considered the scheme three times at pre-application stage and has raised each time serious concerns about the design and massing. At its last review in May 2017 members of the Panel continued to raise concerns regarding the height and dominance of the residential development on the street scene, particularly in views from Old Street and Banner Street. The Panel felt that the architectural expression was unresolved and did not sit well as currently proposed.

45. There is also a fundamental point that the mass, bulk and scale of the proposed residential block is so flawed that no amount of tinkering with design details or materials will alleviate its adverse impact.

Impact on adjoining residential amenity

46. The proximity of the new residential block has a highly detrimental impact on the outlook and overshadowing of existing flats in Basterfield House. Even though the 4^th – 13^th floor element of the block has been moved away from the southern boundary of the site, the four storey element, taller than Stanley Cohen House, will have a major impact.

47. Information provided by the applicant (paragraphs 7.194 and 7.195 of the Planning Statement) states that the existing recessed rooms of Basterfield House and Hatfield House will be adversely affected by the proposals. The Statement ‘blames’ this on the presence of the original balconies and projections, suggesting that if these did not exist then there would not be a problem. It is a ludicrous argument, as they are clearly part of the listed building. Any reduction in day-lighting to existing habitable rooms should be avoided.

48. The school hall, dining room and kitchen, located on the southern boundary of the site will also have a detrimental impact on the western end of Basterfield House.

Land Use

49. Mixed school and residential development has been done before in Islington, notably in King Henry’s Walk and Hungerford Road/York Way, but inevitably involves compromise on the part of both elements. Particularly issues of concern are overlooking of classrooms and play areas from residential properties, and the provision of adequate amenity and play space for both. The proposal to accommodate a two-form entry primary and infant school together with a large amount of housing appears to be over-ambitious, resulting in a gross over-development of a comparatively small site (0.4 hectares). It is telling that the applicant’s Design and Access Statement lists its first ‘Design Principle’ as maximising the development of the site.

The School

50. The combined two-form entry and nursery provision will accommodate 458 children. This in itself is an enormous intensification in educational use over the previous school on the site. The scale of the new school buildings is significant, equal to the Board School adjacent.

51. The proposed location of the sports hall and kitchens along the south-west edge of the site has an undesirable impact on the residents of Basterfield House. The building is 3.5 metres tall along the boundaries of the site, comprising an increase in what is currently there. The main part of the hall is 5.5 metres in height, and although set back by two metres from the boundary, will remain very close to the Basterfield House flats.

52. Venting of smells from the kitchens might also have a negative impact on nearby flats.

53. The rooftop playground is screened by a wall in an attempt to contain noise, but the open playground areas are not and will likely be a major source of noise, which will be very difficult to contain. The noise assessment report produced by the applicant appears to have ignored this aspect of the scheme.The only mention of noise mitigation measures in the applicant’s report is the ‘quiet teaching space’ near Hatfield House.

Residential Density

54. The proposed residentially density is grossly in excess of the maximum allowed in the London Plan or Islington’s Local Plan, even allowing for good access to public transport. The London Plan allows for a range of 650 – 1,100 habitable rooms per hectare in areas of excellent public transport, and recommends that the maximum should only be exceeded where social infrastructure, open space and play facilities are adequate.

55. With 187 habitable rooms in the proposed scheme, the residential density will be around 2,000 habitable rooms per hectare, almost double the recommended maximum. This super-high density is not mitigated by generous provision of public open space. Indeed there is a complete lack of open space in the scheme itself and an existing deficiency in the local area.

56. The density proposed is enormously greater than existing residential densities in the area, including Great Arthur House, the whole of the Golden Lane Estate and the nearby Peabody estate.

57. It should be noted that in pre-application discussions between the City and Islington Housing Departments, it was agreed that the mix of unit sizes and apportionment to each authority would apply in a scheme of only 40 units, if that was a consequence of planning or other unforeseen development restrictions. A smaller, less dense, scheme has therefore been contemplated.

Residential Mix and Tenure

58. While the provision of 66 new units of social rented housing may seem highly desirable, this must be considered in the context of recent decisions nearby within the City of London. The planning approval in May 2017 for the redevelopment of Bernard Morgan House permits the replacement of a block which previously provided 120 affordable housing units for key workers (police officers) by a new residential block of 99 private flats with no affordable housing. A sum of £ 4.5 million is included in a Section 106 agreement to fund off-site provision, presumably contributing to some of, but by no means all, the housing proposed on the Richard Cloudesley School site. Care must be taken therefore in how many boxes are ticked in terms of meeting targets for affordable housing by the two boroughs. Under normal circumstances, the 99 private flats approved at Bernard Morgan House should fund 66 affordable units off site. Taking the two sites together it would appear that the Richard Cloudesley School site merely meets the off-site requirements of the proposed redevelopment of Bernard Morgan House. Overall, it still falls short of the affordable housing that Bernard Morgan House previously provided. If social housing were being provided on the Bernard Morgan House, then there might be less of an argument to put so much on the Richard Cloudesley School site.

59. The mix of units provides a considerable number of 2 and 3 bed units, potentially accommodating children. None of these units have gardens, and only have balconies of limited size. Perhaps because of overlooking issues with the school at the lower levels, and the arrangement of deck access, the balconies to the 3 bed units face east, and so receive no afternoon sun.

60.  The Finsbury Local Plan 2013 highlighted the need for socially rented family homes in the area, but it is highly questionable whether it is right to provide these in a slab block of such high density or with so little play space.

61.  The applicant’s Design and Access Statement notes that the position and design of the housing has been so arranged because they ‘need to be marketable with their own distinct address.’ Presumably the flats will not, in fact, be marketable.

Open Space and trees

62. Despite the requirements of the Finsbury Plan, the proposals make no contribution to the provision of additional public open space in the area. The area is already deficient in open space, and the only nearby facility, Fortune Street Park, is heavily used, including by children from the Golden Lane Campus. Islington Council’s Parks Department and the Friends of Fortune Street Park made strong objections to the City Corporation regarding the adverse impacts on the park of the proposed redevelopment of Bernard Morgan House, objections that were completely ignored.

63. The applicant’s Planning Statement states that, using the GLA’s planning guidance, an area of 430 square metres of separate children’s play space should be provided for the residential element of the scheme. No such space is provided. The excuse given is that ‘the site is heavily constrained in terms of the available area.’ It is symptomatic of the overdevelopment of the site.

64. There is perhaps an assumption by the City that the new residential block can be regarded as an ‘extension’ of the Golden Lane Estate, and that the additional residents will be entitled to share its existing private facilities. The applicant’s Design and Access Statement labels the spaces within the Golden Lane Estate as ‘public’, when in fact they are semi-private, for the benefit of the residents of the Estate. The over-used Fortune Street Park is the only public open space in the immediate vicinity of the site.

65. The proposal involves the needless loss of existing semi-mature trees in the south-west corner of the site. These silver birch and cherry trees are an important amenity in an area where there are few trees. They are appropriate for their situation, are in good health and have a reasonable life-expectancy. This is confirmed by Appendix 3 of the applicant’s Tree Report, which confirms that all the existing trees have a future life span of 10+ or 20+ years. They should be retained. The proposed replanting of young trees will not be adequate compensation.

66. The applicant’s suggestion that it is retaining existing mature plane trees in Baltic Street is a spurious claim, as they are beyond the application and development site.

67. The location of the kitchens and double-height sports hall in the south-west corner of the site will have a detrimental impact on the adjacent Golden Lane Estate allotments in terms of shadowing.

Public Realm and Permeability

68. A considerable part of the ground floor to Golden Lane is made up of access gates to refuse storage, utilities and a substation, providing an extremely unappealing frontage for pedestrians. The school entrance will be busy at the beginning and end of the school day, but completely dead at other times. Security of schools is a major issue, understandably preventing any sense of permeability or visual access into the site.

69. Despite the City of London’s intention to improve the public realm along Golden Lane, following its area development strategy produced by Publica, the ground floor uses do little to produce an animated frontage outside school opening and closing times.

70. The proposed public access to the community use of the hall is down a narrow alleyway next to Hatfield House. It is a tortuous and uninviting route. The hall itself in its proposed position contributes nothing to the public realm. It would be far better to locate the multi-purpose hall on the Golden Lane frontage, where it might contribute to the vitality of the street.

Sustainabilty

71. While the new buildings themselves are designed to comply with current requirements for sustainability, the most questionable consequence of the proposal is traffic generated by the new school. The normal requirement for primary schools in urban areas is that pupils should be able to walk to and from home. A school should thus be located within the catchment area for the pupils it will serve. There is no evidence that this will be the case with the proposed school here. The existing Golden Lane Campus provides infant and primary places for the local catchment area and special needs places for a wider area. The applicant’s Travel Plan makes an assumption that all the pupils will be live very close to the school and thus be able to walk, accompanied by a parent or guardian. However there is a strong possibility that pupils at the proposed new school will not all live within walking distance and will be driven by bus or car.

72. The proposal involves the loss of existing garages which are part of the Golden Lane Estate and which currently provide valuable parking for disabled residents. There is no proposal to replace this.

BALANCE OF HARM AGAINST PUBLIC BENEFITS

73. The proposals cause harm to designated heritage assets, notably the setting of the Golden Lane Estate and the St Luke’s Conservation Area. Some residents of the Golden Lane Estate will argue that the harm is substantial, invoking consideration under Paragraph 133 of NPPF. Others may argue that the degree of harm is less than substantial, triggering consideration under Paragraph 134 of NPPF. In either case, the local planning authority is required to weigh or balance the harm caused against the public benefits achieved by the proposal.

74. It should also be noted that while it has been held that ‘substantial’ harm might require the virtual destruction of the significance of a designated heritage asset, the implication is that ‘less than substantial’ harm can involve very serious harm to the asset. In all cases, it has been held that when balancing harm against public benefit, heritage matters should be given very considerable weight. The Planning Act requires that ‘special’ care be given to conserving and enhancing the historic environment.

75. In addition the claims of the applicant that the proposals will provide significant public benefits need to be examined in detail.

Provision of school

76. While it is the case that Islington’s population is increasing, resulting in a need for more school places, it is far from evident that Golden Lane is the right location. New primary school provision should have regard to the greatest concentrations of family housing. The recent creation of the Golden Lane Campus, comprising the redevelopment and enlargement of the former Prior Weston School, has already created a very sizeable new primary education facility in the immediate vicinity of the site. The Golden Lane Campus already accommodates in the order of 800 pupils. The school in Moreland Street has also been significantly enlarged recently. Given the location of the site on the very edge of borough, it is doubtful that the site successfully meets identified educational need within the London Borough of Islington.

77. There is no convincing evidence that either population levels or numbers of children of primary school age are rising significantly within the City of London, and certainly not to a level that justifies a new two-form entry school.

Provision of Housing

78. The proposal includes 66 new social rented housing units, which is welcomed by Islington. In reality it does little more than meet the City of London’s affordable housing obligations, providing off-site provision conveniently outside the borough, for luxury residential developments within it. The excessive density of development and lack of amenity space places a major question mark over the quality and suitability of the accommodation provided, particularly for family housing.

Provision of Community Facilities

79. It is intended that the multi-purpose school sports hall will be available for community use. However the hall is poorly located for public access, and makes no contribution to the public realm. The hall cannot be regarded as an adequate alternative to public open space and external play space. Nor is it clear what the community demand for the hall will be, given that there are existing community hall facilities nearby. Given its location, tucked away at the back corner of the school site, rather than facing the Golden Lane frontage, it remains unclear how it will be used and managed by the wider community.

OPTIMUM VIABLE USE

80. Paragraph 134 of NPPF requires that ‘where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use’. National Planning Policy Guidance 2014 suggests that the issue of Optimum Viable Uses should include consideration as to whether an alternative scheme or proposal might cause less harm whilst also achieving equal or greater public benefits, even if that scheme is not the most profitable.

81. It is surely the case that a less dense development, achieving fewer but higher quality housing units, together with the provision of new public open space, better public realm and a multi-purpose hall that is more accessible to the community would result in a far better balance of public benefit against harm caused, and would enhance the local area rather than putting it under great stress.

CONCLUSION

82. The proposed redevelopment of the Richard Cloudesley School in Golden Lane will cause very serious harm to the significance of the designated heritage assets that comprise the Golden Lane Estate and the St Luke’s Conservation Area. It is considered that this harm should be accorded very great weight.

83. The excessive development of the site will bring further pressure to bear on existing over-stretched local facilities, notably the Fortune Street Park.

84. Although the scheme does provide public benefits from the point of view of the London Borough of Islington in terms of social housing, this provision should be seen in the context of the City of London trying to meet its own obligations to provide social housing, but seeking to do this outside its own boundaries. The effective loss of affordable housing units for key workers at Bernard Morgan House (within the City) should be taken into consideration. The overall net gain in affordable housing is marginal.

85. The very high density and lack of external garden or play space makes the quality of the family housing highly questionable.

86. The school might be seen as a public benefit, but the location is this new facility is debatable, given that the demand for new school places is not local. It is highly likely that many pupils will need to be driven considerable distances from their homes to the new school, which is unsustainable and undesirable into terms of community cohesion.

87. The proposed community use is poorly located in terms of independent public access.

88. Overall it is considered that the benefits do not outweigh or justify the harm caused. It is considered that the site should be redeveloped more sympathetically, with less harmful impact on the heritage assets and on the amenities of neighbouring residents whilst achieving equal benefits. In its current form the planning applications should be refused.

Alec Forshaw

August 2017

The Author

Alec Forshaw (MRTPI, IHBC) worked as a town planning, urban designer and conservation officer with the London Borough of Islington from 1975 to 2007. He appeared as an expert witness at the 2014 Public Inquiries on Smithfield Market and the Liverpool Welsh Streets. He lectures, campaigns and acts as a trustee in a volunteer capacity for many heritage organisations, including the Victorian Society, the 20^th Century Society, the Heritage of London Trust, the Churches Conservation Trust, SAVE Britain’s Heritage and the Islington Building Preservation Trust.

He is the author of Smithfield, Past, Present and Future (2015), 1970s London (2012), Twentieth Century Buildings in Islington (2001) and New City: Contemporary Architecture in the City of London (March 2013), and co-author of The Barbican: Architecture and Light (2015).