Date: 19 December 2012 Reference: 466306
PLANNING (LISTED BUILDINGS AND CONSERVATION AREAS) ACT 1990
BUILDINGS OF SPECIAL ARCHITECTURAL OR HISTORIC INTEREST
Lea Bridge Waterworks, Lea Bridge Road, Waltham Forest
Further to our acknowledgement of you request for a review of the decision not to list the Lea Bridge Waterworks. I am the Department’s officer responsible for the review of listing decisions and had no involvement in the original decision not to list.
After considering your grounds for review they are not sufficient to consider overturning the original decision. The reasons for this decision are given later in this e-mail.
Circumstances under which the overturning of a previous decision will be considered
Overturning an original decision will only be considered if there is evidence that the original decision has been wrongly made. Examples of a wrongly made decision would be:
- where there has been a significant factual error, e.g. the wrong building was listed; or
- where there has been some irregularity in the process that has affected the outcome, e.g. significant relevant considerations have not been taken into account/significant irrelevant considerations have been taken into account.
Reviews of decisions are also undertaken if there is significant new evidence, not previously considered, relating to the special architectural or historic interest of the building in a national context as defined by the Planning (Listed Buildings and Conservation Areas) Act 1990. For example:
- where new evidence relating to the date of a building has been discovered; or
- where there has been a material change of circumstances affecting the assessment of a building’s architectural or historic interest.
In all the above cases evidence can only be considered which relates to the special architectural or historic interest of the building. The Principles of Selection for Listing Buildings, March 2010, (copy attached) sets out general principles, as well as the statutory criteria, for measuring architectural and historic interest in the national context. Other factors, such as planning considerations and local importance, cannot be taken into account. Disagreement with the advice of English Heritage without persuasive new evidence will also not be considered grounds for review.
The grounds you have submitted are not sufficient to consider overturning the original decision for the following reasons.
The form of English Heritage’s advice report
The English Heritage (EH) advice report is a summary of the significant evidence sufficient to reach a conclusion on the level of architectural and historic interest of a building. Although fully considered not all the evidence submitted with the original application, therefore, will be summarised in the report.
Function and Form - The statutory criteria specify that architectural and historic interest are the key considerations when assessing a building for listing. The function of the Turbine Shed, the name itself provides a clue, has been consider in general terms. This is, however, a subsidiary consideration and not central to the assessment given the lack of intactness of the Waterworks as a whole. The form of the building is covered by the assessment of its architecture.
Technological interest – When considering the technology of an industrial building innovation is an important consideration. In this case the technology was old fashioned for its time and clearly not innovative. In the context of listing, even if the machinery survives, the turbine technology does not enhance a case for listing.
The survival of original machinery – The resources of EH are extremely limited and full inspections will only be carried out if buildings show a clear potential to meet the statutory criteria. The limited architectural interest and limited survival of the waterworks overall do not demonstrate potential. In these circumstances expending resources on a full inspection cannot be justified.
The history of the water industry – Water power of various types is common across the whole country with varying levels of survival of associated structures from the Roman period onwards. As a reminder of the long history of water power the limited survival of Lea Bridge Waterworks adds little in either a national or regional context.
The mid-C19 cholera epidemics – The surviving buildings of the Lea Bridge Waterworks all post-date the big mid-C19 cholera epidemics and, therefore, have no direct association with them.
Architectural assessment and style of the building – The form, structure and architectural embellishment of the Turbine House have been assessed according to the evidence available. Although you differ from EH in your opinion of the architecture no new information has been provided for a reassessment to be warranted.
As with the ‘Architectural assessment and style of the building’ above the style and architectural features of the building have been assessed by EH on the evidence available. The building has the external appearance of a house and has been assessed in that context. The internal layout of the building is unknown and speculation takes us no further forward. The building does not show sufficient potential for listing to merit the resources required for a full inspection.
As noted in ‘The survival of original machinery’ above resources do not allow a full inspection of a building if it does not show potential to meet the statutory criteria. We cannot base a decision to list on speculation as to whether or not original machinery survives and the completeness of any that does. The principal decision to list must be made on factual information.
The development of the Waterworks has been considered and is outlined in the EH advice report. WWII bomb damage is very common across South and East London in particular but across most British towns and cities in general. Whatever the reasons for demolition the lack of survival of buildings that represent a complete or nearly complete late Victorian waterworks and the alterations made to surviving buildings are a barrier to listing.
Given the lack of special architectural interest in the buildings assessed, for group value to be a significant factor, the buildings would need to have a very close and complete functional relationship clearly demonstrating the full ‘industrial’ process. The lack of completeness for the Waterworks as a whole means that group value would not be a determining factor.
The information you have submitted is not sufficient to provide grounds for overturning the original decision. The original decision and the reasons for it should therefore stand and the Lea Bridge Waterworks, Lea Bridge Road, Waltham Forest should not be added to the statutory list.
Further opportunity to make a listing application
The Secretary of State has a continuing duty under the Planning (Listed Buildings and Conservation Areas) Act 1990 to maintain an up-to-date statutory list of buildings of architectural or historic interest. If significant new information should come to light in the future then a new listing application may be made to English Heritage through their on-line application process.
Designation Review Manager, Heritage Protection Team, Department for Culture, Media and Sport