Mr.

Alex Bushell 27th January 2011

Major Developments Team
Camden Borough Council
Camden Town Hall
Judd Street
London
WC1H 9JE

Dear Sir,

Middlesex Hospital Annexe, 44 Cleveland Street, W1T 4JU

Application Numbers 2010/2205/P and 2010/2209/C.
Re: Archaeology and Heritage

I am writing to you on behalf of RESCUE – The British Archaeological Trust. RESCUE

is a non-political organisation which exists to support archaeology and archaeologists in
Britain and abroad. We receive no support from government and are entirely dependent
on the contributions of our members to fund our work. Details of our activities can be
found on our website: www.rescue-archaeology.org.uk. Please note that this
communication and any response we may receive as a consequence will be placed on our
website for the information of our members.

We wish to register strong objections against both of the above-cited applications.

According to PPS5, "Local Planning Authorities should require an applicant to provide

a description of the significance of the heritage assets affected and the contribution of
their setting to that significance... As a minimum, the Historic Environment Record
should have been consulted and the heritage assets themselves should have been
assessed using appropriate expertise where necessary given the application's impact.
Where an application site includes, or is considered to have the potential to include,
heritage assets with an archaeological interest, local planning authorities should require
developers to submit an appropriate desk-based assessment and, where desk-based
research is insufficient to properly assess the interest, a field evaluation." The Heritage
and Urban Design Appraisal that has been submitted to accompany these proposals does
not fulfill these requirements, is thoroughly inadequate and not fit-for-purpose as a
Heritage Statement. In support of this contention, the following points should be taken
into consideration:

• There has been no discernable consultation with the Historic Environment Record
to inform this Heritage and Urban Design Appraisal. This is a mandatory
minimum for the compilation of a Heritage Statement, and it should be rejected
without firm evidence of this.

• According to the Appraisal, the site was previously a paupers’ burial ground until
its acquisition for the construction of the Covent Garden Workhouse, which was
completed in 1778. However, the Appraisal pointedly fails to expand on this
important aspect of the site’s history. Just what exactly happened on this site
prior to 1778? What was on this site in the Medieval period (for example)? How
long was the paupers’ burial ground in use and what was its extent? Was it
cleared prior to the construction of the workhouse (there should be records), or
merely built over? Are there a large number of extant burials on this site that will
require archaeological excavation should the development proceed, or has the
standing structure destroyed any evidence of their presence? If there are burials
here, they would most certainly qualify as Heritage Assets under the definition of
PPS5, and they would require specialist analysis. Potentially, they could provide
valuable and significant information relating to the local lower social class
populations of this part of London in the period up to 1778. These are important
points that will affect the financial viability of any development scheme – yet they
are ignored in the very document that should be addressing them. These issues
should be discussed in detail, and on the evidence provided the site should be
archaeologically evaluated prior to determination of either of the applications, in
order to assess these questions.

• As outlined in PPS5 above, a Heritage Statement should assess the “significance”

of the site. However, this is clearly not attempted in this Appraisal. There are no
phased plans or elevations presented outlining the chronology of the development
of the site, and nor is there any written description of the interior of the structure
and surviving elements. Nor are there any photographs of the interior – in fact
there is no evidence presented that indicates any study of the interior of this
building was undertaken at all. All that is presented, is a short preamble regarding
the “history” of the existing building which largely concentrates on “damage” –
whether by rebuilding, additions or bombing – without attempting to clarify
whether or not these episodes have detracted from the significance of the site.
Paragraphs 3.13 – 3.15 are particularly evidential of this deficiency. At no point is
any attempt made to outline the surviving elements of the structure that might
render it of significance under the terms of PPS5. Instead, broad statements are
given outlining the absorption of the 18th century building within a 19th century
one (is this structure not significant also?), bomb damage, “poor quality repairs”,
the unoriginal roof and supposedly altered interior. So what exactly does survive
here?
 • The Appraisal – at length – attempts to dismiss the significance of the site using
the PPS5 current guidelines. However, all the references cited predate the
instigation of these guidelines. It appears that the previous assessments have
concentrated on the architectural survival of the original 18th century structure
rather than its historic importance, merit and significance as a composite entity
and the contribution that the whole makes to the character of the area and our
understanding of that period of history which it represents. No attempt has been
made to assess the overall significance of the site in accordance with the current
guidelines and criteria. This is a serious omission, and one that is clearly
detrimental to the appropriate appraisal of the site. Furthermore, the Appraisal
appears to suggest that we should deny this character – “It is hard to see how the
values of the original workhouse on the site might relate to the values held by
people now” (3.50), and without explaining what does survive - “It is not
reasonable or credible to say that enough of the workhouse survives in Cleveland
Street for it to represent to us in a meaningful way the things for which it stood.”
(3.53). One might offer similar comments about Stonehenge – yet we recognise
the contribution of that much-altered site constructed by individuals holding
different values to our own to our understanding of the past.

The policies set out in PPS5 are designed to assess the overall significance of a heritage
asset and determine whether the site – or elements thereof - are appropriate for
conservation. Should appropriate assessment demonstrate that a site does not embody
“significance” then – and only then - should proposals for redevelopment be considered
along with appropriate measures for mitigation. This Heritage and Urban Design
Appraisal does not do this. Indeed, only one third of the document discusses the site
historically at all. The rest is given over to justification for development, the “merits” of
the new scheme and policy. These issues have no place in a true Heritage Statement,
meaning that these applications have actually been submitted without the required
supporting documentation, and should not have been validated.

We would urge that at the very least, the applicants be informed that the Heritage and
Urban Design Appraisal does not fulfil the criteria for a Heritage Statement set out in
PPS5. The applicants should be instructed that according to current National Planning
Policy, they are required to present a comprehensive appraisal of the site which
encompasses all relevant documentary, archaeological and architectural evidence in a
dedicated discussion document compiled by a an appropriately qualified professional
organisation. Should the applicants be unwilling or unable to do this, both applications
should be refused on the grounds of inadequate submission of supporting information.

Yours sincerely

Diana Friendship-Taylor
Chair
RESCUE – The British Archaeological Trust