Historic England has supported the Coventry Society’s views about the damage that will be caused to the Hill Top Conservation Area by the Council’s plans to relocate the Coventry Cross from its existing location to Ironmonger Row. Their full letter to the Council is re-published below:
Dear Mr D’Onofrio
T&CP (Development Management Procedure) (England) Order 2015 & Planning (Listed Buildings & Conservation Areas) Regulations 1990
CATHEDRAL LANES, BROADGATE, COVENTRY, CV1 1LL
Application No. FUL/2018/2655
Thank you for your letter of 19 October 2018 regarding the above application for planning permission. On the basis of the information available to date, we offer the following advice to assist your authority in determining the application.
Historic England Advice
The site lies close to several listed building including the Grade I listed Holy Trinity church, the Grade II* former County Hall building and the Grade I listed new and old cathedral of St Michael. It encompasses the terrace at the back of the Cathedral Lanes development and the recreation of the Coventry Cross. The latter was erected in 1976 and represents the long lost mid-16th century cross (perhaps on the site of an Eleanor Cross) which stood in the Cross Cheaping until its destruction in the 18th century. It is not listed in its own right, but it stands within a conservation area, as does the rest of the site.
The site is a sensitive one in view of the number of highly graded designated heritage assets in the vicinity. The public space between the buildings, which is mostly green, is a particularly valuable area within the Conservation Area and is likely to be a focus of much attention in 2021 when Coventry will be the City of Culture. The cross forms a focal point on this side of the open space. Its replacement will be a paved area allied with the expansion of the dining area at the back of the Cathedral Lanes development.
The loss will inevitably have a detrimental impact on the adjoining listed buildings (through changes to their setting) and to the character of the Conservation Area. The existing terraces are a little tired and heavy handed in design terms but the proposals do not offer any improvement, indeed they seem to form a greater barrier.
The total demolition of the cross will cause substantial harm to the undesignated heritage asset. The Design and Access Statement says that it will be re-erected, but then makes it clear that that work will be undertaken by the Council rather than by the developer. There is no mention in the application of the method of demolition or the proposed storage pending re-erection.
Section 72(1) of the 1990 Act requires that schemes in Conservation Areas should pay special attention to the ‘desirability of preserving or enhancing the character or appearance’ of the area, whilst paragraph 200 of the NPPF advised that schemes should enhance and better reveal the significance conservation areas and other heritage assets. Paragraph 196 with respect to the balancing judgement when deciding on schemes which cause less than substantial harm to designated heritage assets needs to be taken into account. The need for good design in this context is considered in Section 12, particularly at paragraphs 127 and 130. As for the removal of the cross paragraph 197 applies and emphasises the need for such assets to be taken seriously.
We cannot see any heritage benefits in the scheme which would outweigh the level of harm that it will cause. It is, of course, for you as the planning authority to judge the overall benefits of the scheme and whether or not they outweigh the heritage harm. If you are minded to grant consent then it would be appropriate to impose appropriate conditions to ensure the careful dismantling and re-erection of the cross on a meaningful time scale, which might help to reduce the level of heritage harm caused.
Historic England has concerns regarding the application on heritage grounds.
We consider that the issues and safeguards outlined in our advice need to be addressed in order for the application to meet the requirements of the NPPF as set out above. In determining this application you should also bear in mind the statutory duty of section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to the desirability of preserving listed buildings or their setting or any features of special architectural or historic interest which they possess and section 72(1) of the Act to pay special attention to the desirability of preserving or enhancing the character or appearance of conservation areas.
Your authority should take these representations into account and seek amendments, safeguards or further information as set out in our advice. If there are any material changes to the proposals, or you would like further advice, please contact us.
Principal Inspector of Historic Buildings and Areas