planning, heritageplanning, heritageheritage, design

Planning, Planning, Planning, Planning, HeritageHeritageHeritageHeritage, Design , Design , Design , Design

& Access& Access& Access& Access StatementStatementStatementStatement “Internal Works to Richard I Including

Openings to Adjacent Property, Balustrade to Accessibility Ramp and Removal of External

Stairs”

52525252----55556666 Royal Hill, Greenwich, London, SE10 Royal Hill, Greenwich, London, SE10 Royal Hill, Greenwich, London, SE10 Royal Hill, Greenwich, London, SE10

8RT 8RT 8RT 8RT

June 2021

www.planningpotential.co.uk Page 1 Copyright © Heritage Potential 2020

Contents

1. Introduction 2

2. Site Context and Planning History 3

3. Policy and Guidance 5

4. Heritage Significance 9

5. Proposals Error! Bookmark not defined.Error! Bookmark not defined.Error! Bookmark not defined.Error! Bookmark not defined.

6. Planning and Heritage Assessment Error! Bookmark not defined.Error! Bookmark not defined.Error! Bookmark not defined.Error! Bookmark not defined.

7. Summary 12

Heritage PotentialHeritage PotentialHeritage PotentialHeritage Potential

LondonLondonLondonLondon

Magdalen HouseMagdalen HouseMagdalen HouseMagdalen House

148 Tooley Street148 Tooley Street148 Tooley Street148 Tooley Street

London SE1 2TULondon SE1 2TULondon SE1 2TULondon SE1 2TU

T: 020 7357 8000T: 020 7357 8000T: 020 7357 8000T: 020 7357 8000

____________________________________________________________________________________________________________________________________________________________________

Report Author: Report Author: Report Author: Report Author: Niall HanrahanNiall HanrahanNiall HanrahanNiall Hanrahan

Niall.HanrahanNiall.HanrahanNiall.HanrahanNiall.Hanrahan@[email protected]@[email protected]

Report RefereReport RefereReport RefereReport Reference:nce:nce:nce:

5656565677777777HERHERHERHER

June 2021


1. Introduction

1.1. This Planning, Heritage, Design & Access Statement has been prepared by Heritage Potential (a trading name of Planning Potential

Ltd), on behalf of Young & Co.’s Brewery (hereafter referred to as Young’s), in support of proposals for the ‘Internal Works to Richard

I Including Openings to Adjacent Property, Balustrade to Accessibility Ramp and Removal of External Stairs’ at 52-56 Royal Hill,

Greenwich, London, SE10 8RT. The purpose of this report is to examine the impacts associated with the proposed development on

the historic and architectural significance of the heritage asset.

1.2. The Statement has been prepared by Niall Hanrahan of Planning Potential. Niall has a MSc in Historic Conservation and is also MRTPI

accredited. This joint heritage and planning specialism allows him to effectively balance the public benefits of proposals against any

identified harm to heritage assets.

1.3. Section 2 of this Statement describes the site and its surroundings.

1.4. Section 3 sets out the relevant policy and guidance framework.

1.5. Section 4 assesses the significance of any relevant heritage assets, principally the statutorily listed building.

1.6. Section 5 describes the proposals in detail.

1.7. Section 6 justifies the proposals and assesses the development against relevant national and local planning policies.

1.8. Section 7 provides an overview of the proposal and draws conclusions.

1.9. Overall, this statement provides an assessment of the proposals in relation to the relevant national and local planning policies and

demonstrates that the proposals will result in a negligible impact on the listed building. Crucially, the proposals are essential to the

continued use of No.56 as a public house and the amalgamation has been designed to be discreet focusing on what would have

once been an external boundary wall to No.54 of low significance. The public benefits of ensuring the survival of an important

community use are considered to be substantial and would far outweigh any negligible impact on historic fabric. The removal of the

existing metal stairs to the rear of both properties is considered to be a notable benefit and the minor works to the interior of Richard

I are considered to be necessary and appropriate.

1.10. Paragraph 196 of the NPPF is not considered to be engaged by the proposed works, and even if a worst case scenario was to be

taken, the public benefits of investment into the community use would certainly outweigh any negligible harm.

June 2021


2. Site Context and Planning History

2.1. The application site covers both Richard I at 52-54 Royal Hill and Greenwich Union at 56 Royal Hill, Greenwich, London, SE10 8RT.

The Grade II listed properties of No.50-52, once a pair of cottages, have early 18th Century origins and sit in a terrace of properties of

various ages, including the later addition of No.54 which has subsequently been amalgamated with no.52 to form the double fronted

Richard I Public House. No.56 (Greenwich Union) is neither statutory or locally listed.

2.2. The site is located on the eastern side of Royal Hill opposite its junction with Royal Place. It is located within the West Greenwich

Conservation Area and the buffer zone of the Maritime Greenwich World Heritage Site.

Figure 1: Figure 1: Figure 1: Figure 1: 52525252----56 Royal Hill56 Royal Hill56 Royal Hill56 Royal Hill Figure 2: Figure 2: Figure 2: Figure 2: StStStStairs to Rearairs to Rearairs to Rearairs to Rear

Source: Heritage Potential Source: Heritage Potential

Figure 3: Site LocationFigure 3: Site LocationFigure 3: Site LocationFigure 3: Site Location

Source: OS

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2.3. Of relevance to this application, the two public houses are proposed to become one individual public house. The main element of the

proposal seeks listed building consent for the creation of two openings with the modern extension to Richard I to provide access

through to the Greenwich Union side. The proposed locations for the openings are within what would have historically been the garden

boundary wall to No.54. The significance of this area is low given the listing is largely focused on the significance of the pair of C18

cottages at No.50-52 and No.54 has become part of the listing by way of amalgamation with No.52. The proposals are careful not to

create openings within the historic interior of either building.

Planning Planning Planning Planning HistoryHistoryHistoryHistory

2.4. The following recent applications are relevant to the application site:

Reference Reference Reference Reference Description Description Description Description Decision & Date Decision & Date Decision & Date Decision & Date

20/3413/F &

20/3414/L

Replacement of Kitchen Extraction and AC Units at rear of

property; (Including Like for Like Replacement Roof Slates).

Grant – 04.01.2021

20/0555/F &

20/0556/L

External redecoration and internal refurbishments. Grant – 14.04.2020

15/0064/F Alterations to boundary fencing for means of escape, relocation

of bin store, new shed, alterations to paving and planters in beer

garden and new jumbrella.

Grant – 09.03.2015

14/1544/A &

14/1543/L

Installation of replacement branded signage. Grant – 01.08.2014

13/0542/F Construction of a single storey rear extension with partially

glazed rear wall, fixed rooflight and first floor fire escape over,

Internal remodelling and essential repairs and maintenance to

front elevation (Resubmission).

Grant – 18.09.2013

13/0543/L Construction of a single storey rear extension with partially

glazed rear wall, fixed rooflight and first floor fire escape over,

Internal remodelling and essential repairs and maintenance to

front elevation (Resubmission).

Grant – 18.09.2013

June 2021


3. Policy and Guidance

Heritage LegislationHeritage LegislationHeritage LegislationHeritage Legislation

3.1. The Planning (Listed Buildings and Conservation Areas) Act 1990 is the primary legislation and foundation on which further policy,

and guidance relating to the conservation of the historic environment is built. Section 66 of the Act relates to the ‘general duty as

respects listed buildings in exercise of planning functions’, with Section 66 (1) stating that when deciding whether to grant planning

permission for a development, special regard must be given by the local authority to the “desirability of preserving the building or its

setting or any features of special architectural or historic interest which it possesses” (Planning Act 1990, Section 66).

3.2. In relation to the setting of listed buildings, the Court of Appeal clarified interpretation of Section 66 (1) within Barnwell Manor Wind

Energy Ltd v East Northampton District Council [2014] EWCA Civ 137 (Royal Courts of Justice, 2014), ruling that the setting should

be “given considerable importance and weight” when the decision maker carries out the balancing exercise.

3.3. Section 66 (2) of the Act states that “a local authority shall have regard to the desirability of preserving features of special architectural

or historic interest, and in particular, listed buildings”.

3.4. Section 72 of the Act relates to the ‘general duty as respects conservation areas in exercise of planning functions’, with Section 72

(1) of the Act stating that in exercising planning functions, “special attention should be paid to the desirability of preserving or enhancing

the character or appearance of that area”.

NPPF (2019)NPPF (2019)NPPF (2019)NPPF (2019)

3.5. The National Planning Policy Framework, with which all Local Development Plans must comply, constitutes the national level of

planning policy and is a material consideration in planning decisions. The NPPF was originally introduced in March 2012 and was

subsequently updated and published on 24 July 2018. The 2018 update broadly retains the wording of the 2012 Chapter on

Conserving and Enhancing the Historic Environment (Chapter 16). The NPPF was recently updated again (February 2019) in order to

provide definitions for housing need. No paragraph numbers changed as a result of this update.

3.6. The NPPF represents a continuation of the philosophy contained within Planning Policy Statement 5 (PPS5), introduced in 2010 and

one of a number of planning policy documents replaced by the NPPF in 2012.

3.7. The NPPF uses slightly different terminology to the Act and emphasises that authorities should take account of “the desirability of

sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation”.

3.8. ‘Conservation’ is defined within the NPPF as “the process of maintaining and managing change to a heritage asset in a way that

sustains and, where appropriate, enhances its significance”.

3.9. No definition of ‘preservation’ (or any variant) is contained within the document. However, Historic England advise that both

‘conservation’ and ‘preservation’ are concerned with the management of change which seeks to sustain the special interest or

significance of heritage assets. ‘Conservation’ has the addition of taking opportunities to enhance significance where it is possible

and considered to be appropriate. This is discussed in Historic England’s 2018 publication Decisions: Legal Requirements for Listed

Building and Other Consents.

3.10. The NPPF also helps to define other key terms within heritage policy. These are provided within the table below.

TermTermTermTerm DefinitionDefinitionDefinitionDefinition

Heritage Assets “A building, monument, site, place, area or landscape identified as having a degree of significance meriting

consideration in planning decisions, because of its heritage interest. It includes designated heritage assets

and assets identified by the local planning authority (including local listing).” (p.67)

Designated Heritage Assets “A World Heritage Site, Scheduled Monument, Listed Building, Protected Wreck Site, Registered Park and

Garden, Registered Battlefield or Conservation Area designated under the relevant legislation.” (p.66)

Significance “The value of a heritage asset to this and future generations because of its heritage interest. This interest

may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s

physical presence, but also from its setting.” (p.71)

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Setting of a Heritage Asset “The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the

asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to

the significance of an asset, may affect the ability to appreciate that significance or may be neutral.” (p.71)

3.11. Chapter 16 specifically relates to conserving and enhancing the historic environment (paras. 184-202).

3.12. Paragraph 189 stipulates that within applications, applicants are required to describe the significance of the heritage assets affected

and the contribution made by their setting. Local authorities should also identify and assess the significance of the heritage assets

affected by a proposal. This should be taken into account when assessing the impact of a proposals on a heritage asset (Paragraph

190). Paragraph 192 of the NPPF goes on to state that when determining applications, local planning authorities should take account

of:

a) the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with

their conservation;

b) the positive contribution that conservation of heritage assets can make to sustainable communities including their economic

vitality; and

c) the desirability of new development making a positive contribution to local character and distinctiveness. (p.55)

3.13. Paragraphs 193-202 of the document discuss how potential impacts to heritage assets should be considered with paragraph 193

stipulating a requirement for great weight to be given to an asset’s conservation when considering the impact of a proposed

development on its significance. The weight given should reflect the importance of the asset (p.55).

Degrees of HarmDegrees of HarmDegrees of HarmDegrees of Harm

3.14. Where harm to the significance of a designated heritage asset is identified, the NPPF requires clear and convincing justification of the

proposals. The document categorises levels of harm as: total loss; substantial harm; and less than substantial harm.

3.15. Paragraph 195 states that where a development would lead to substantial harm to (or total loss of) the significance of a designated

asset, local planning authorities should refuse consent, unless it can be demonstrated that such harm is necessary to achieve

substantial public benefits that outweigh that harm, or all of the following apply:

a) the nature of the heritage asset prevents all reasonable uses of the site; and

b) no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its

conservation; and

c) conservation by grant-funding or some form of not for profit, charitable or public ownership is demonstrably not possible; and

d) the harm or loss is outweighed by the benefit of bringing the site back into use.

3.16. Paragraph 196 states that where a proposed development will lead to less than substantial harm to the significance of a designated

asset, this should be weighed against the public benefits of the proposal, including securing its optimum viable use.

National Planning Practice GuidanceNational Planning Practice GuidanceNational Planning Practice GuidanceNational Planning Practice Guidance (NPPG) (NPPG) (NPPG) (NPPG)

3.17. The NPPG offers guidance as to what public benefits may constitute and could be anything that delivers economic, social or

environmental progress as described in the National Planning Policy Framework (Paragraph 7). Public benefits may include heritage

benefits, such as:

• sustaining or enhancing the significance of a heritage asset and the contribution of its setting

• reducing or removing risks to a heritage asset

• securing the optimum viable use of a heritage asset in support of its long-term conservation

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The London Plan (March 2021)The London Plan (March 2021)The London Plan (March 2021)The London Plan (March 2021)

3.18. Policy D3 ‘Optimising Site Capacity Through the Design Led Approach’: requires all development to make the best use of land by

following a design-led approach that optimises the capacity of sites, including site allocations. Optimising site capacity is defined as

ensuring that development is of the most appropriate form and land use for the site. The policy also seeks for proposals to enhance

local context by delivering buildings and spaces that positively respond to local distinctiveness through their layout, orientation, scale,

appearance, and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions.

3.19. Policy D5 ‘Inclusive Design’: Requires development proposals to achieve the highest standards of accessible and inclusive design,

including: being designed to take into account London’s diverse population; provide high quality people focussed spaces that are

designed to facilitate social interaction and inclusion and be convenient and welcoming with no disabling barriers.

3.20. Policy HC 1 ‘Heritage Conservation & Growth’: Seeks for development proposals affecting heritage assets, and their settings, to

conserve their significance, by being sympathetic to the assets’ significance and appreciation within their surroundings. The cumulative

impacts of incremental change from development on heritage assets and their settings should also be actively managed. Development

proposals should avoid harm and identify enhancement opportunities by integrating heritage considerations early on in the design

process

3.21. Policy HC7 – ‘Protecting Public Houses’ – States that boroughs should protect public houses where they have a heritage, economic,

social or cultural value to local communities. It goes on to note that pubs are a unique and intrinsic part of British culture. Many pubs

are steeped in history and are part of London’s built, social and cultural heritage. However, pubs are now under threat from closure

and redevelopment pressures, with nearly 1,200 pubs in London lost in 15 years.

Local Planning Policy Local Planning Policy Local Planning Policy Local Planning Policy

Greenwich Local Development Framework (2014)Greenwich Local Development Framework (2014)Greenwich Local Development Framework (2014)Greenwich Local Development Framework (2014)

3.22. Policy DH1 – Design – is the Borough’s overarching design policy and promotes developments that can demonstrate that they

positively contribute to the improvement of both the built and natural environments.

3.23. Policy DH3 – Heritage Assets – states that the Council will protect and enhance the heritage assets and settings of Royal Greenwich,

including the Maritime Greenwich World Heritage Site, preserving or enhancing the character or appearance of the 20 Conservation

Areas, applying a presumption in favour of the preservation of statutory listed buildings and their settings.

3.24. Policy DH (h) – Conservation Areas – i) character and Setting states that planning permission will only be granted for proposals which

pay special attention to preserving or enhancing the character or appearance of the Conservation Area. The local scale, the established

pattern of development and landscape, building form and materials will all be taken into account.

3.25. Policy DH (i) – Statutory Listed Buildings – will take a presumption in favour of the protection of listed buildings.

3.26. Policy DH (ii) – External or Internal Alterations – should respect the integrity of the buildings and harmonise with their special

architectural or historical character. Where consent is required for internal alterations, features of interest should be respected and left

in situ wherever possible.

3.27. Policy EA (b) – Pubs – states that The Royal Borough supports the retention of pubs that have a community role and will resist the

change of use or demolition except where continued use as a pub is no longer economically viable.

3.28. Policy DH(b) – Protection of Amenity for Adjacent Occupiers – states that extensions or renovations of buildings will only be permitted

where it can be demonstrated that the development does not cause an unacceptable loss of amenity to adjacent occupiers by

reducing the amount of daylight, sunlight or privacy they enjoy or result in an unneighbourly sense of enclosure.

3.29. Policy E(a) – Pollution – states that planning permission will not normally be granted if the proposal would likely result in the

unacceptable emission of noise, light, vibrations, odours, fumes, dust, water and soil pollutants or grit.

3.30. Policy E(c) – Air Pollution – states that development proposals with the potential to result in any significant impact on air quality will be

resisted unless measures to minimise the impact of air pollutants are included. Such planning applications should be accompanied

by an assessment of the likely impact of the development on air quality.

June 2021


West GreWest GreWest GreWest Greenwich Conservation Area Appraisal (2013)enwich Conservation Area Appraisal (2013)enwich Conservation Area Appraisal (2013)enwich Conservation Area Appraisal (2013)

3.31. The West Greenwich Conservation Area Appraisal sets out the historical development of the Conservation Area, analyses its character

and identifies opportunities for change and enhancement. The appraisal is now 7 years’ old and some of the observations and

recommendations are now out of date.

June 2021


4. Heritage Significance

4.1. This Section assesses the significance of the heritage assets potentially affected by the proposed works. These are considered to be

the Grade II listed No. 50-52 Royal Hill and the West Greenwich Conservation Area.

No.50No.50No.50No.50----55552222 Royal HillRoyal HillRoyal HillRoyal Hill

4.2. The Grade II listed properties of No.50-52 have early 18th Century origins and sit in a terrace of properties of various ages, including

the later addition of No.54 which has subsequently been amalgamated with No.52 to form a double fronted public house (Richard I).

4.3. The Historic England listing description describes the properties at No.50-52 as:

“II Early C18 pair, each 2 storeys and attic, 2 windows. No 50 has sunk basement also. Tiled mansard roofs (No 50 with 1 square

dormer. Multicoloured stock brick with parapets. No 50 has cornice band and 1st floor band. No 52 has brick moulded and dentilled

cornice. Gauged red brick arches to renewed sash windows, those of No 50 with glazing bars, in old box frames. No 50 has door,

of 2 glazed and 2 fielded panels and flat lower part, under cornice hood and blocked fanlight of interlacing pointed arches. Narrow,

moulded architrave, pulvinated frieze and dentilled cornice hood on brackets. Cast iron lance-head area railings. No 52 has late

C19 public house front on ground floor. One double door at either side under elliptical arched fanlight, round, projecting central

window bay with curved glass.”

4.4. The Richard I Public House at No.52-54 has informally been known as ‘The Tolly’ due to its history of selling Tolly Light Ale and there

are also records of the public house being referred to as “Ye Old House” (circa 1908). Listings from 1896; however, do show “Richard

I” at No.52 Royal Hill, indicating that this is in fact its historic and formal name. It is understood that No.52 was owned by George

Honeybone from 1910 and in 1923 he managed to buy No.54 (which had been a confectioner since 1908 – visible in Figure 7, below),

amalgamating the two and extending the floorspace of the public house.

Figure 7: Figure 7: Figure 7: Figure 7: Ye Old House 190Ye Old House 190Ye Old House 190Ye Old House 1909999 Figure 8: Figure 8: Figure 8: Figure 8: Undated Image of No.54 ShopfrontUndated Image of No.54 ShopfrontUndated Image of No.54 ShopfrontUndated Image of No.54 Shopfront

Source: Young’s Source: Young’s

4.5. It is understood that for much of the 20th Century, No.52 was a single room public bar with No.54 operated as an off licence until the

late 70s or early 80s. Figure 7, below, shows fascia signage in 1972 reading “Tolly” but with “Richard I” written on the boundary wall

between No.50 and No.52. The pub was under Young’s ownership by the time figure 10 was taken, circa 1979, and appears to have

lost its “Tolly” signage. In both images No.54 can be seen as a designated off licence.

June 2021


Figure Figure Figure Figure 9999: Circa 1972 Image of : Circa 1972 Image of : Circa 1972 Image of : Circa 1972 Image of the “Tolly”the “Tolly”the “Tolly”the “Tolly” Figure Figure Figure Figure 10101010: Circa 1979 Image of Richard I : Circa 1979 Image of Richard I : Circa 1979 Image of Richard I : Circa 1979 Image of Richard I

Source: Metropolitan Archives Source: Pubwiki

4.6. In more recent years, the bars of No.52 and No.54 have been internally connected via a new opening to the front of the properties. A

large single storey conservatory style extension has also been added to the rear. Plant equipment sits close to the first floor rear and

is generally well hidden from view due to the length of the extension.

4.7. Historic Mapping shows the building of No.50-52 as one of a few along Gang Lane in 1761 (before the present-day Royal Hill was

laid out). By the 1850s, Royal Hill had been formally laid out although No.50-52 can be seen to be semi-detached with the present

day No.54 not yet built.

Figure Figure Figure Figure 11111111: John Rocque Map Showing : John Rocque Map Showing : John Rocque Map Showing : John Rocque Map Showing Gang LaneGang LaneGang LaneGang Lane (1761)(1761)(1761)(1761) Figure Figure Figure Figure 11112222: : : : OS MapOS MapOS MapOS Map Circa 1850Circa 1850Circa 1850Circa 1850

Source: Old Maps Source: National Library of Scotland

4.8. Mapping after 1850 shows a densified terrace with No.50-52 now forming part of this terrace. This indicates that the current building

of No.54 Royal Hill is a mid 19th Century addition.

4.9. The public house has been in commercial use for a number of decades and has more limited internal significance. Architectural

Significance

4.10. No.52 has considerable architectural significance, forming one of a pair of early 18th Century houses. Along with No.50, the pair are

highly symmetrical with 2 timber windows and a tiled mansard roof. A central chimney stack protrudes with dominance between the

two properties.

4.11. No.54 is a later addition, understood to have been built in the mid 19th Century. The building is a storey taller but has been designed

with shared features to No.52 such as timber sash windows and a dentilled cornice. The roof is of slate rather than tile and is less

prominent in the street due to the tight arrangement and more limited views above 2 storeys.

4.12. The ground floor frontage to No.54 has been designed to match the older frontage of No.52 and the entire public house (No.52-54)

has been painted in white and somewhat demarcates it as a single use building.

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Figure 1Figure 1Figure 1Figure 13333: OS Map Circa : OS Map Circa : OS Map Circa : OS Map Circa 1868186818681868 Figure 1Figure 1Figure 1Figure 14444: OS Map Circa 18: OS Map Circa 18: OS Map Circa 18: OS Map Circa 1895959595

Source: National Library of Scotland Source: National Library of Scotland

4.13. It is evident that the interior of No.54 (the southern side of Richard I) is less significant than the C18 side of the public house. The

building itself is much later and the use of the space has been changed a number of times. With the property being amalgamated

with No.52 in 1923, the bar is a 20th Century addition and of lesser importance compared to the main bar in the northern side of the

pub.

Historic SignificanceHistoric SignificanceHistoric SignificanceHistoric Significance

4.14. The properties of No.50-52 form some of the earliest Georgian development in Greenwich albeit No.52 has since been amalgamated

with the mid-19th century building of No.54. No.54, in itself, has some historic significance as part of the street’s Victorian densification.

Artistic SignificanceArtistic SignificanceArtistic SignificanceArtistic Significance

4.15. The building has limited artistic interest.

Archaeological SignificanceArchaeological SignificanceArchaeological SignificanceArchaeological Significance

4.16. The building has the potential for some archaeological significance although this is out of the scope of the application.

West Greenwich Conservation AreaWest Greenwich Conservation AreaWest Greenwich Conservation AreaWest Greenwich Conservation Area

4.17. The building forms part of a tight knit network of high quality terraced properties. The buildings within the terrace are generally attractive

with brick the predominant facing material and timber windows found through the local area. The conservation area is large and

includes areas much closer to the river.

4.18. The rear of commercial properties within the area is the focus for plant and functional equipment essential to their success. There are

examples, such as 89 Royal Hill, where these installations are more obvious due to a break in the terraced nature of the streets. The

terraces are generally beneficial in hiding such equipment and also allowing for extensions, as found at the application site.

4.19. The conservation area has considerable architectural and historic interest however this is largely focused towards the front of

properties and contained within the street layout. The rear of properties along Royal Hill have more limited interest.

4.20. No.56 Royal Hill is a more recent building, certainly of 20th Century and of limited architectural or historical integrity. It’s additional

height is a little out of scale with the remainder of the terrace.

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5. Proposals

5.1. The proposed works allow for:

• Alterations to entrance lobbies;

• Strip and application of bar top lacquer to bar in No.52;

• Strip and stain bar front in No.52;

• Provision of pumps to bar in No.54;

• Creation of 2 no. new openings between No.54 and No.56;

• Repair and redecoration of modern toilet facilities;

• New fire doors to first floor;

• Casement window to staff toilets;

• Removal of steel staircases to rear;

• New balustrade to ramp at rear;

Proposed GF PlanProposed GF PlanProposed GF PlanProposed GF Plan

Source: Sampson

June 2021


Proposed FirsProposed FirsProposed FirsProposed First Floort Floort Floort Floor

Source: Sampson

Proposed FirsProposed FirsProposed FirsProposed First Floort Floort Floort Floor

Source: Sampson

June 2021


6. Planning and Heritage Assessment

6.1. The planning system is plan-led. Planning law requires that applications for planning permission must be determined in accordance

with the development plan, unless material considerations indicate otherwise. The National Planning Policy Framework is a material

consideration in planning decisions. It also provides guidance on how to draw up Development Plans and policies.

National Planning PolicyNational Planning PolicyNational Planning PolicyNational Planning Policy

• National Planning Policy Framework (NPPF) (February 2019);

• National Planning Policy Guidance (NPPG) (March 2014).

Development Plan PoliciesDevelopment Plan PoliciesDevelopment Plan PoliciesDevelopment Plan Policies

6.2. The application proposal is required to be assessed against the adopted Development Plan for Greenwich, which comprises the

following documents:

• London Plan (2021); and

• Royal Greenwich Local Plan (2014).

6.3. A summary of the relevant planning policies is contained in SeSeSeSection ction ction ction 3333 of this Statement.

Main ConsiderationsMain ConsiderationsMain ConsiderationsMain Considerations

6.4. The main considerations when assessing this application is:

• The Retention of Public Houses;

• Impact on the Significance of the Listed Building and Conservation Area;

6.5. These matters are assessed against the relevant national and local planning policies within this section and it is concluded that the

proposals are necessary to securing the survival of No.56 as a public house and care has been taken to ensure that the proposals

are acceptable in terms of design.

The Retention of PThe Retention of PThe Retention of PThe Retention of Public Houses ublic Houses ublic Houses ublic Houses

6.6. Public houses are an important part of British heritage, both in terms of culture and architecture. However, ever increasing taxes, beer

duty, changes to legislation, and changing customer needs have put a strain on the traditional pub. This has resulted in a requirement

for pubs to continue adapting to maintain viability. This requirement has been compounded by the recent Covid-19 Pandemic and

Greenwich Union, at No.56 Royal Hill, which was a small pub with limited potential for diversity, has unfortunately been a victim of

recent events.

6.7. The rate of closures in recent years has been covered widely in the media and official date has shown that there were 3,530 working

pubs in London in 2018, a fall of 27% compared with 2001, with numbers falling in 31 of the 32 boroughs. This figure shows the risk

to public houses within London, the importance of protecting and enhancing these community assets, and providing opportunity to

diversify to ensure the future security of an important community use.

6.8. In recent years, the Government has granted additional powers to local authorities to help protect pubs, and in 2015 removed the

Permitted Development (PD) rights of developers to change the use of pubs from A4 to other ‘A’ uses without planning permission.

On 23 May 2017, and with acknowledgment to the growing trend to provide food in pubs, the Government again amended the Town

and Country Planning (General Permitted Development Order) to allow the change of use of A4 (drinking establishments) to A3/A4

(drinking establishments with expanded food provision) and vice versa.

6.9. This, in addition to the recent inclusion of public houses within the NPPF (2018) as important community facilities, demonstrates that

the Government are prioritising the retention of public houses across the country.

6.10. More locally, Policy HC7 (Protecting Public Houses) in the Draft London Plan (2017) and Policy EA (b) of the Greenwich Local Plan

(2014) highlight the importance of public houses and the desire for their retention, wherever possible. Policy EA (b) specifically

discusses resisting changes of use or demolition of pubs unless they can be demonstrated to be economically unviable. This would

June 2021


indicate that a pub would not have to be on its last legs to be granted permission to improve its offer; rather, a proactive approach

should be taken to ensure pubs avoid financial hardship and the threat of closure.

6.11. The proposals within this application will allow for the public house to survive as part of an amalgamation with the adjacent Richard I.

This amalgamation will allow for a larger space with improved internal and external amenities. The proposals have been designed to

be minimal with the proposed openings via what would have been an external boundary wall between No.54 and No.56. The more

significant side of the listed building, No.52, which was once a C18 cottage, would be largely unaffected by the amalgamation.

6.12. It is abundantly clear that the proposed development at No.56 is compliant with local and national policies and seeks to ensure the

longevity of an important community asset, as prioritised by Central Government and Greenwich in recent publications and legislation.

Impact on the Significance of the Impact on the Significance of the Impact on the Significance of the Impact on the Significance of the AAAAdjacent djacent djacent djacent Listed Building Listed Building Listed Building Listed Building and Conservation Areaand Conservation Areaand Conservation Areaand Conservation Area

Alterations to entrance lobbies

6.13. The existing entrance lobbies are fairly modern, as demonstrated by the early 20th Century images of the site where Victorian

shopfronts are shown. These were evidently replaced during the 20th Century for a fairly traditional, albeit modern, design. The

relocation of door entrances would have seen any previous lobbies removed and replaced.

6.14. Nonetheless, the proposals to the lobbies are minimal and seek to allow for improved access, fire safety and to maximise internal

space. The proposals will all be completed in materials to match the existing.

Strip and application of bar top lacquer to bar in No.52 & Strip and stain bar front in No.52

6.15. The existing bar to No.52 is in need of work having fallen into a little disrepair. The bar front has evidently been adapted in the past

and the bar top would appear to be a later replacement. The proposals are suitably minor and seek to reuse the existing fabric, albeit

with new paint and a new bar top lacquer applied after being stripped.

6.16. The proposals will help to protect the bar in the future and are considered to be for the long term conservation benefit of the public

house.

Shopfronts to Shopfronts to Shopfronts to Shopfronts to NNNNo.52 and No.54 in 1909o.52 and No.54 in 1909o.52 and No.54 in 1909o.52 and No.54 in 1909

Source: Young’s

June 2021


Provision of pumps to bar in No.54

6.17. The bar to No.54 is evidently a later addition given the use of this side of the building was as a confectioner up until at least 1923

when the building was purchased by the owner of No.52. The proposals for this bar are minor and seek to allow for additional hand

pumps.

6.18.

Bar to No.52Bar to No.52Bar to No.52Bar to No.52

Source: Heritage Potential

Bar to No.5Bar to No.5Bar to No.5Bar to No.54444

Source: Heritage Potential

June 2021


Creation of 2 no. new openings between No.54 and No.56

6.19. The proposed openings between No.54 and No.56 have been designed to be located in the least architecturally or historically sensitive

locations possible and will sit within a modern extension that once would have been part of the garden. As such, the wall where the

openings would be located would once have been a garden boundary wall and of minimal significance. The proposed location is less

sensitive than an opening towards the front of the public house.

6.20. The openings have been designed to be fairly simple with exposed steel beams allowing for a clear legibility that an opening has been

created and that the spaces were once separate.

6.21. Given the relatively low significance of this part of the listed building, having been amalgamated into the footprint of a C18 cottage,

the proposals are considered to be subtle and likely to only cause negligible heritage impacts.

Existing and ProposeExisting and ProposeExisting and ProposeExisting and Proposed Bar Sectiond Bar Sectiond Bar Sectiond Bar Section

Source: Sampson

June 2021


Repair and redecoration of modern toilet facilities

6.22. The proposals include some minor refurbishment works to the existing modern toilets and within the modern extension. These

elements are included on the drawings for information and wouldn’t necessarily require consent due to only modern fabric being

affected.

New fire doors to first floor & Casement window to staff toilets

6.23. New fire doors are proposed at first floor level. The existing doors are all modern and sit within areas adapted when the buildings were

amalgamated in 1923. A new casement window to the staff toilet is proposed for fire safety reasons.

6.24. Works within this area are considered to be minor.

Removal of steel staircases to rear

6.25. The existing steel staircases to the rear garden detract from the significance of the listed building and their removal is considered to

be a benefit.

New balustrade to ramp at rear

6.26. The proposed new balustrade in the garden will improve accessibility and is considered to be a benefit.

Overall ImpactOverall ImpactOverall ImpactOverall Impact

6.27. It is considered that the proposals preserve the significance of the heritage assets, in line with Policies DH3 and DH (i) of the Local

Plan. As such, the proposals are not considered to engage Paragraph 196 of the NPPF and satisfy Section 66 and 72 of the 1990

Planning Act. Should a worst case scenario be taken, a negligible impact would results from the creation of the new openings however

the benefits of ensuring that No.56 is retained as public house and the benefits of investment in both properties and the removal of

unsightly staircases to the rear are all public benefits that would outweigh this harm and satisfy Paragraph 196 of the NPPF.

Proposed OpeningsProposed OpeningsProposed OpeningsProposed Openings

Source: Sampson

June 2021


7. Summary

7.1. Overall, this statement provides an assessment of the proposals in relation to the relevant national and local planning policies and

demonstrates that the proposals will not result in any harm to the adjacent listed building or conservation area. Crucially, the proposals

are essential to the continued use of No.56 as a public house and have been designed to be as sensitive as possible. As such, the

design and arrangement of the proposals is considered subtle and appropriate.

7.2. It is demonstrated that the proposals offer an appropriate solution to the amalgamation of the two public houses and give the best

possible change for survival of the historic use of the buildings. Paragraph 196 of the NPPF is not considered to be engaged by the

proposed works, and even if a worst case scenario was to be taken, the public benefits of investment into the community asset would

certainly outweigh any negligible harm.

planning, heritageplanning, heritageheritage, design

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