Historic Environment Assessment

MOLA

April 2020

Heritage Statement

www.mola.org.uk

© MOLA Mortimer Wheeler House, 46 Eagle Wharf Road, London N1 7ED tel 0207 410 2200 fax 0207 410 2201 email:[email protected] Museum of London Archaeology is a company limited by guarantee Registered in England and Wales Company registration number 07751831 Charity registration number 1143574 Registered office Mortimer Wheeler House, 46 Eagle Wharf Road, London N1 7ED

Harrow Carparks Project Rayners Lane

HA5 5EG

Heritage Statement

www.mola.org.uk

© MOLA Mortimer Wheeler House, 46 Eagle Wharf Road, London N1 7ED tel 0207 410 2200 fax 0207 410 2201 email:[email protected] Museum of London Archaeology is a company limited by guarantee Registered in England and Wales Company registration number 07751831 Charity registration number 1143574 Registered office Mortimer Wheeler House, 46 Eagle Wharf Road, London N1 7ED

Harrow Carparks Project Rayners Lane

HA5 5EG

Heritage Statement

NGR 517 637; 192 596

Sign-off history

issue no.

issue date prepared by reviewed by approved by reason for issue

1

01/08/2019 Alicia Vickers Assistant Project

Manager—Built Heritage

Samuel Abelman Project Manager—

Built Heritage

Chris Thomas Director Heritage

Preliminary issue

2 09/10/2019 Alicia Vickers Assistant Project



Built Heritage

Chris Thomas Director Heritage

Revised




Built Heritage


Built Heritage

Revised




Built Heritage


Built Heritage

Revised




Built Heritage


Built Heritage

Revised




Built Heritage


Built Heritage

Final

11 21/04/2020 Rebecca Reynolds Heritage Consultant

- - Client revisions

PO code: P19-249

Heritage Statement © MOLA 2020 i

Contents

Executive summary 1

1 Introduction 4

1.1 Origin and scope of the report 4

1.2 Heritage assets 4

1.3 Aims and objectives 4

2 Methodology and sources consulted 5

2.1 Baseline 5

2.2 Significance 5

2.3 Impact 6

2.4 Conclusions and Recommendations 6

3 Policy Baseline 7

3.1 Introduction 7

3.2 Statutory Protection 7

3.3 National Planning Policy Framework 7

3.4 Greater London Regional Policy 9

3.5 Local Planning Policy (Harrow Council) 12

4 Built Heritage Baseline 15

4.1 History of Rayners Lane Conservation Area 15

4.2 Site description 17

4.3 Heritage assets within the setting. 17

4.4 General Planning Advice 3 (GPA3) The Setting of Heritage Assets (Historic England 2015) 22

5 Statement of Significance 24

5.1 Introduction 24

5.2 Significance Criteria 24

5.3 The subject site 25

5.4 Rayners Lane Underground Station and Rayners Lane Conservation Area 25

6 Proposed Development 26

6.1 Proposal 26

7 Impact of Proposed Development 28

7.1 Discussion of heritage impact 28

7.2 Discussion of relevant heritage views 30

8 Conclusions and Recommendations 32

8.1 Conclusions 32

8.2 Recommendations 32

9 Bibliography 33

9.1 Published and documentary sources 33

9.2 Other Sources 33

Heritage Statement © MOLA 2020 ii

Figures

Cover: View to the subject site (source: Karakusevic Carson Architects)

Fig 1 Site location plan

Fig 2 Historic image of Rayners Lane (Source: The National Archives UK).

Fig 3 Historic image of Rayners Lane Station (Source: The National Archives UK).

Fig 4 Rayners Lane Conservation Area, approx. location of the subject site shown by a red star (source: Harrow Council—Pinner Conservation Areas)

Fig 5 Rayners Lane Conservation Area, approx. location of the subject site shown by a red star (source: Harrow Council—Pinner Conservation Areas).

Fig 6 Rayners Lane Conservation Area, showing characteristics of the conservation area (source: Harrow Council—Pinner Conservation Areas).

Fig 7 Aerial sketch view of site layout (source: Karakusevic Carson Architects).

Fig 8 CGI view showing new residential blocks (source: Karakusevic Carson Architects).

Fig 9 Existing view of the station platforms (source: Karakusevic Carson Architects).

Fig 10 CGI showing the proposed view from the station platform (source: Karakusevic Carson Architects).

Fig 11 Viewpoint 2 Alexandra Avenue just south of the Ace Cinema (source: Landscape Visual).

Fig 12 Viewpoint 9 View from Alexandra Avenue (source: Landscape Visual).

Fig 13 Viewpoint 11 View from Imperial Drive (source: Landscape Visual).

Note: site outlines may appear differently on some figures owing to distortions in historic maps. North is approximate on early maps.

Heritage Statement © MOLA 2020 1

Executive summary

CBRE Ltd has commissioned MOLA (Museum of London Archaeology), on behalf of the applicant, to carry out a heritage statement in advance of proposed development for the Harrow Carparks Project (Rayner’s Lane), in the London Borough of Harrow. The scheme comprises redevelopment of the site for new residential development, public carparking and public realm improvements. The site falls under the jurisdiction of Harrow Council.

The subject site comprises a carpark adjacent to Rayners Lane Underground Station. The site runs along the south of the railway.

The subject site does not contain any nationally designated (protected) heritage assets such as scheduled monuments, listed buildings or registered parks and gardens, but the site does include a Site of Importance for Nature Conservation. However, the site is to the north west of Rayners Lane Underground Station, a Grade II listed heritage asset identified as ‘Rayner’s Lane London Regional Transport Underground Station including shops and platforms’ (including Rayner’s Lane Station, Alexandra Avenue)—Historic England list entry number: 1261430. The subject site is also within the setting of the Rayner’s Lane Conservation Area and within the setting of the ‘Ace Cinema’ (a Grade II* listed heritage asset—Historic England list entry number: 107972)9, as well as locally listed shop buildings located on Alexandra Avenue (numbers 468-472 Alexandra Avenue).

The station building and integrated shops and platforms, constructed in c1938, are significant for its Modern Movement architecture. The station building was built to a design by Charles Holden and Reginald Uren and features a large cube-shaped brick and glass ticket hall capped with a flat reinforced concrete roof and geometrical forms typical of the new stations built in this period. Rayners Lane Conservation Area developed in the c1930s and transformed the suburb through classic Metroland development around the tube station with the latest amenities, with fine groups of Modernist and Art Deco style buildings. The station is the centrepiece of the conservation area.

The proposal will comprise the construction of up to 128 residential units, with four buildings (5-6 storey mansion blocks) across the site (from east-west); with flexible ground floorspace and a public carpark along with associated public realm enhancements. Only Building A (5 storeys) will be partially visible in the backdrop of the station and is considered for potential heritage impact.

This desk-based study assesses the possible impacts of the proposed development on built heritage assets in and around the site. Although below ground heritage assets (historic structures) are not discussed in detail, they have been noted where they assist in the archaeological interpretation of the site. A separate Archaeological Assessment has been undertaken by MOLA and accompanies this planning application.

This report has the following findings:

The subject site comprises a strip of land alongside the railway for proposed redevelopment. The site sits outside of the conservation area and is presently car-parking. The site makes a low contribution to the setting of the Grade II listed station building and conservation area.

• The proposed building is designed as an overall simple, modern and high-quality built form in the setting of the identified heritage assets. Building A will be set back from the rear of the station (which has a main frontage to Alexandra Avenue). It will be in the backdrop of the station with partial visibility only (and will sit at a lower level than the station).

• The proposed development (originally 6 storeys) has reduced Block A to 5 storeys, to reduce its visibility beyond the station.

There will be a minor heritage impact on principal views to the station from some aspects, as the upper portion of the proposed development will be partially visible beyond the station building; however, the proposed new development is designed such that the principal presentation and symmetry of the station building will remain the key elements in its principal views. The proposed new development will be substantially set back and appear subservient and unobtrusive in the backdrop.

There will be a moderate heritage impact on the view from the platforms. The view to the southwest from the platform will be screened by the new development; however, a sense of ‘openness’ and greenery is retained in views to the northwest from the station platform.

https://en.wikipedia.org/wiki/Reinforced_concrete

https://en.wikipedia.org/wiki/Reinforced_concrete


• The proposed development will not interrupt key views to the station as the modernist form and detailing of the station will continue to be a prominent feature in views.

• The simple character and quality of the proposed new development will not draw attention away from the scale, character and quality of the historic streetscape and station building, which will retain prominence. The proposed overall rectangular form and flat roof of the new development will respond to the form of the station. Further, the proposed materiality (brickwork) will respond to the materiality of the main station building.

• The proposed development will not impact upon the ability to interpret the special character, features and consistency of the main shopping street (Alexandra Avenue) within the conservation area. The proposed development is unlikely to have any significant visibility from the High Street or Alexandra Avenue beyond existing development and tree coverage.

The proposed development is considered likely to have ‘less than substantial harm’ to the setting of the identified heritage assets, due to the scale of the proposed development (with the present carpark currently contributing to openness); however, the harm is at the lower end of the threshold and outweighed by the significant public benefits of the proposal. The sympathetic and high-quality design response of the proposed development (as outlined within this report) should be considered, together with the provision of significant public realm enhancements.

The public benefits of the proposal have been summarised below and are further detailed in the accompanying planning documentation.

• Delivery of 128 Affordable Housing units at a policy compliant mix. Providing London Affordable Rent and Shared Ownership Properties

• The delivery of a circa 82 cycle hub spaces within the red line boundary of the site. Harrow is a borough which TfL consider to have the most potential for increasing cycle usage and trips increasing the use of sustainable modes within the Borough.

• The cycle hub will be provided and existing car parking spaces reduced which will contribute to wider sustainability aspirations of the Borough and the GLA.

• Creation of a Landscaped Garden adjacent to a SINC, which is publicly accessible green open space within the heart of Rayners Lane.

• Preservation of the original concrete fence along the station platform and original lighting, which contributes to the overall conservation of the station as a heritage asset; and

• High quality public realm enhancements.


Fig 1 Site location plan (Source: Karakusevic Carson Architects).


1 Introduction

1.1 Origin and scope of the report

1.1.1 CBRE Ltd has commissioned MOLA (Museum of London Archaeology), on behalf of the applicant, to carry out a heritage statement in advance of proposed development for the Harrow Carparks Project (Rayners Lane), in the London Borough of Harrow (National Grid Reference: 517 637:192 596) Fig 1. The scheme comprises redevelopment of the site for new residential development, carparking and associated public realm enhancements.

1.1.2 This heritage statement assesses the impact of the scheme on built heritage assets (standing buildings). Such a document is necessary in the planning process in order that the local planning authority (LPA) can formulate an appropriate response in the light of the impact upon any known or possible heritage assets. These are parts of the historic environment which are considered to be significant because of their historic, evidential, aesthetic and/or communal interest.

1.1.3 The assessment has been carried out in accordance with the requirements of the National Planning Policy Framework (NPPF) (2019) and to standards specified by the Chartered Institute for Archaeologists (CIfA Dec 2014a, 2014b), Historic England (EH 2008, 2015), and the Greater London Archaeological Advisory Service (GLAAS 2014), and the City of London (CoL 2004). Under the ‘Copyright, Designs and Patents Act’ 1988 MOLA retains the copyright to this document.

1.1.4 Note: within the limitations imposed by dealing with historical material and maps, the information in this document is, to the best knowledge of the author and MOLA, correct at the time of writing. Further archaeological investigation, more information about the nature of the present buildings, and/or more detailed proposals for redevelopment may require changes to all or parts of the document.

1.2 Heritage assets

1.2.1 The subject site does not contain any nationally designated (protected) heritage assets such as scheduled monuments, listed buildings or registered parks and gardens. However, the site is to the north west of Rayners Lane Underground Station, a Grade II listed heritage asset identified as ‘Rayner’s Lane London Regional Transport Underground Station including shops and platforms’ (including Rayner’s Lane Station, Alexandra Avenue)—Historic England list entry number: 1261430.

1.2.2 The subject site is within the setting of the Rayner’s Lane Conservation Area and is within the setting of the ‘Ace Cinema’ (a Grade II* listed heritage asset)—Historic England list entry number: 1079729, as well as locally listed shop buildings on Alexandra Avenue (numbers 468-472 Alexandra Avenue).

1.3 Aims and objectives

1.3.1 The aim of the assessment is to:

• assess the likely impacts upon the significance of the assets arising from the proposals; and

• provide recommendations for further assessment where necessary of the historic assets affected, and/or mitigation aimed at reducing or removing completely any adverse impacts upon buried heritage assets and/or their setting.


2 Methodology and sources consulted

2.1 Baseline

2.1.1 The baseline for this assessment has been determined primarily through desk-based research into designated and undesignated heritage assets on and near the site of the proposed development. It has been confirmed and extended by a site visit by a MOLA Built Heritage Consultant.

2.1.2 The following are the principal sources consulted:

• MOLA - in-house Geographical Information System (GIS) with statutory designations GIS data, the locations of all key indicators of known prehistoric and Roman activity across Greater London, past investigation locations, projected Roman roads and burial grounds from the Holmes burial ground survey of 1896; georeferenced published historic maps; Defence of Britain survey data, in-house archaeological deposit survival archive; and archaeological publications.

• Historic England - information on statutory designations including scheduled monuments and listed buildings, along with identified Heritage at Risk.

• The London Society Library - published histories and journals.

• British National Copyright Library - historic Ordnance Survey maps from the first edition (1860-70s) to the present day.

• Groundsure Landmark - historic Ordnance Survey maps from the first edition (1860-70s) to the present day, and Goad fire insurance maps.

• British Geological Survey (BGS) - solid and drift geology digital map; online BGS geological borehole record data.

• Historic England Archive, Swindon - vertical and specialist (oblique) air photographs.

• Internet - web-published material including LPA local plan, and information on conservation areas and locally listed buildings.

2.2 Significance

2.2.1 The assessment considers all structures on or near the site of a proposed development to have potential significance as heritage assets. From this start position, the values and significance of each asset will be determined using criteria set out in Historic England (formerly English Heritage)’s Conservation Principles, Policies and Guidance (EH 2008). All structures with a level of significance as heritage assets will be discussed in the report and included as material considerations in the assessment. Structures of negligible value and significance as heritage assets will not be assessed further and will generally be excluded from the report except where there is a need for explanation of their exclusion from the assessment, such as being part of the site.

2.2.2 For each built heritage asset to be considered, a description will be provided leading to a statement of significance for that asset. Section 10 sets out the criteria used to determine the significance of heritage assets. This is based on four values set out in Historic England’s Conservation Principles, Policies and Guidance (EH 2008), and comprise evidential, historical, aesthetic and communal value. The report assesses the likely presence of such assets within (and beyond) the site, factors which may have compromised buried asset survival (i.e. present and previous land use), as well as possible significance.

2.2.3 The significance of the asset is derived from its historical, evidential, communal and aesthetic values, these in turn derived from the building’s fabric, design, landscape and history.

2.2.4 In the case of Conservation Areas, the significance will be primarily found in their character assessments and those aspects of the historic built environment that make positive contributions to them.

2.2.5 The methodology for assessing the setting of designated heritage assets follows best practice as covered in Historic England's Good Practice Advice (GPA) document 3 (HE 2017). The


basis for this methodology is set out below:

All heritage assets have significance, some of which have particular significance and are designated. The contribution made by their setting to their significance also varies.

Although many settings may be enhanced by development, not all settings have the same capacity to accommodate change without harm to the significance of the heritage asset or the ability to appreciate it. This capacity may vary between designated assets of the same grade or of the same type or according to the nature of the change. It can also depend on the location of the asset: an elevated or overlooked location; a riverbank, coastal or island location; or a location within an extensive tract of flat land may increase the sensitivity of the setting (i.e. the capacity of the setting to accommodate change without harm to the heritage asset's significance) or of views of the asset. This requires the implications of development affecting the setting of heritage assets to be considered on a case-by-case basis.

2.2.6 GPA3 sets out this methodology in stages, or steps:

Step 1 - identify the asset(s) likely to be affected and the extent of setting

Step 2 - assess how and to what degree the setting makes a contribution to the significance of the assets

Step 3 - assess the effect of the proposed development on the significance of the asset;

Step 4 - seek to maximise enhancement and minimise harm; and

Step 5 - document and monitor outcomes

2.2.7 Steps 1 and 2 are dealt with in section 4.5, step 3 in section 7.2 and step 4 in sections 8.2 and 8.3. Step 5 is the preserve of the LPA.

2.3 Impact

2.3.1 Impacts are those actions associated with the proposed development with potential to alter the significance of a heritage asset through affecting the values that contribute to it.

2.3.2 For each built heritage asset, the potential impacts of demolition and construction will be assessed in terms of how they may alter these values and, by extension, significance of each.

2.3.3 For Conservation Areas, the assessment will focus on the preservation and/or enhancement of their historic character.

2.4 Conclusions and Recommendations

2.4.1 The built heritage assessment will conclude with a list of impacts on built heritage assets in the baseline.


3 Policy Baseline

3.1 Introduction

3.1.1 There is potential for the proposed development to impact on the significance of designated and undesignated built heritage assets and Conservation Areas. These impacts will likely take the form of demolition or other physical alteration to buildings, demolition and new construction that may alter the setting of designated heritage assets, and demolition and new construction that may affect the character and setting of Conservation Areas.

3.1.2 The following lays out the general criteria upon which the proposed development will be

assessed. The full policy framework can be found in Section 8.1.

3.2 Statutory Protection

Listed Buildings and Conservation Areas

3.2.1 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the legal requirements for the control of development and alterations which affect buildings, including those which are listed or in conservation areas. Buildings which are listed or which lie within a Conservation Area are protected by law. Grade I are buildings of exceptional interest. Grade II* are particularly significant buildings of more than special interest. Grade II are buildings of special interest, which warrant every effort being made to preserve them.

3.3 National Planning Policy Framework

3.3.1 The Government issued the National Planning Policy Framework (NPPF) in March 2012 (DCLG 2012) and supporting Planning Practice Guidance in 2014 (DCLG 2014). The 2012 NPPF was revised and a new NPPF published in July 2018, with minor revisions in February 2019 (MHCLG 2019).

Conserving and enhancing the historic environment

3.3.2 The NPPF section concerning “Conserving and enhancing the historic environment” (section 12 of the NPPF 2012) has been replaced by NPPF 2018 Section 16 (unchanged in February 2019), reproduced in full below:

Para 184. Heritage assets range from sites and buildings of local historic value to those of the highest significance, such as World Heritage Sites which are internationally recognised to be of Outstanding Universal Value. These assets are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations.

Para 185. Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account:

• a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;

• b) the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring;

• c) the desirability of new development making a positive contribution to local character and distinctiveness; and

• d) opportunities to draw on the contribution made by the historic environment to the character of a place.

Para 186. When considering the designation of conservation areas, local planning authorities should ensure that an area justifies such status because of its special architectural or historic interest, and that the concept of conservation is not devalued through the designation of areas that lack special interest.


Para 187. Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:

• a) assess the significance of heritage assets and the contribution they make to their environment; and

• b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

Para 188. Local planning authorities should make information about the historic environment, gathered as part of policy-making or development management, publicly accessible.

Proposals affecting heritage assets

Para 189. In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

Para 190. Local planning authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise. They should take this into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset’s conservation and any aspect of the proposal.

Para 191. Where there is evidence of deliberate neglect of, or damage to, a heritage asset, the deteriorated state of the heritage asset should not be taken into account in any decision.

Para 192. In 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.

Considering potential impacts

Para 193. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.

Para 194. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of:

• a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional;

• b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.

Para 195. Where a proposed development will lead to substantial harm to (or total loss of significance of) a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, 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.


Para 196. 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, where appropriate, securing its optimum viable use.

Para 197. The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.

Para 198. Local planning authorities should not permit the loss of the whole or part of a heritage asset without taking all reasonable steps to ensure the new development will proceed after the loss has occurred.

Para 199. Local planning authorities should require developers to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) in a manner proportionate to their importance and the impact, and to make this evidence (and any archive generated) publicly accessible. However, the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted.

Para 200. Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to the asset (or which better reveal its significance) should be treated favourably.

Para 201. Not all elements of a Conservation Area or World Heritage Site will necessarily contribute to its significance. Loss of a building (or other element) which makes a positive contribution to the significance of the Conservation Area or World Heritage Site should be treated either as substantial harm under paragraph 195 or less than substantial harm under paragraph 196, as appropriate, taking into account the relative significance of the element affected and its contribution to the significance of the Conservation Area or World Heritage Site as a whole.

Para 202. Local planning authorities should assess whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from.

3.4 Greater London Regional Policy

The London Plan

3.4.1 The overarching strategies and policies for the whole of the Greater London area are contained within the London Plan of the Greater London Authority (GLA March 2016). The current 2016 consolidation Plan is still the adopted Development Plan. The GLA have published their ‘intend to publish’ version of the Draft London Plan (December 2019). This is now being attributed material weight in the planning process.

3.4.2 Policy 7.8 of the adopted (2016) London Plan relates to Heritage Assets and Archaeology:

A. London's heritage assets and historic environment, including listed buildings, registered historic parks and gardens and other natural and historic landscapes, conservation areas, World Heritage Sites, registered battlefields, scheduled monuments, archaeological remains and memorials should be identified, so that the desirability of sustaining and enhancing their significance and of utilising their positive role in place shaping can be taken into account.

B. Development should incorporate measures that identify, record, interpret, protect and, where appropriate, present the site's archaeology.

C. Development should identify, value, conserve, restore, re-use and incorporate heritage assets, where appropriate.

D. Development affecting heritage assets and their settings should conserve their significance, by being sympathetic to their form, scale, materials and architectural detail.

E. New development should make provision for the protection of archaeological resources, landscapes and significant memorials. The physical assets should, where possible, be made available to the public on-site. Where the archaeological asset or memorial cannot be preserved or managed on-site, provision must be made for the investigation, understanding, recording, dissemination and archiving of that asset.

F. Boroughs should, in LDF policies, seek to maintain and enhance the contribution of built,


landscaped and buried heritage to London's environmental quality, cultural identity and economy as part of managing London's ability to accommodate change and regeneration.

G. Boroughs, in consultation with English Heritage [now named Historic England], Natural England and other relevant statutory organisations, should include appropriate policies in their LDFs for identifying, protecting, enhancing and improving access to the historic environment and heritage assets and their settings where appropriate, and to archaeological assets, memorials and historic and natural landscape character within their area.

3.4.3 Para. 7.31 A supporting Policy 7.8 notes that 'Substantial harm to or loss of a designated heritage asset should be exceptional, with substantial harm to or loss of those assets designated of the highest significance being wholly exceptional. Where a development proposal will lead to less than substantial harm to the significance of a designated asset, this harm should be weighed against the public benefits of the proposal, including securing its optimal viable use. Enabling development that would otherwise not comply with planning policies, but which would secure the future conservation of a heritage asset should be assessed to see of the benefits of departing from those policies outweigh the disbenefits.'

3.4.4 It further adds (para. 7.31B) 'Where there is evidence of deliberate neglect of and/or damage to a heritage asset the deteriorated state of that asset should not be taken into account when making a decision on a development proposal'.

3.4.5 Para. 7.32 recognises the value of London's heritage: '…where new development uncovers an archaeological site or memorial, these should be preserved and managed on-site. Where this is not possible provision should be made for the investigation, understanding, dissemination and archiving of that asset'.

The Draft New London Plan

3.4.6 On 13th March, the Secretary of State (‘SoS’) issued a letter to the Mayor of London which directed a number of changes to be made to the Intend to Publish Draft London Plan (December 2019). Until the Mayor of London incorporates these directions, the Draft London Plan cannot be published for adoption. The SoS considers there are a number of the inconsistencies with national policy (NPPF, 2019) and missed opportunities to increase housing delivery across London. The directions given by the SoS are specific and focus on the following topics:

• Small Sites: Concerns that this policy lacks credibility given the policies overall impact on housing requirements.

• Industrial Land: The SoS is directing a more proportionate stance by removing the ‘no net loss’ requirement on existing industrial land sites while ensuring Boroughs bring forwards new industrial land.

• The Mix of Housing: Concerns the plan will be at the detriment of family sized dwellings.

• Optimising Density: Higher density developments should be consented in clusters that have already taken this approach, and gentle density is encouraged in around high streets and town centres.

3.4.7 This report has been completed following the direction from the SoS. Given the direction received from the SoS this report continues to make reference to those policies from the Intend to Publish London Plan which remain unaffected by the SoS directions. Where policies referenced within this report are impacted upon, reference has also been made to the currently adopted London Plan (2016, as amended).

3.4.8 Policy HC1 “Heritage conservation and growth” of the Draft New London Plan (as set out here incorporating the minor changes published in July 2019) relates to London’s historic environment:

A. Boroughs should, in consultation with Historic England, local communities and other statutory and relevant organisations, develop evidence that demonstrates a clear understanding of London’s historic environment. This evidence should be used for identifying, understanding, conserving, and enhancing the historic environment and heritage assets, and improving access to, and interpretation of, the heritage assets, landscapes and archaeology within their area.


B. Development Plans and strategies should demonstrate a clear understanding of the historic environment and the heritage values of sites or areas and their relationship with their surroundings. This knowledge should be used to inform the effective integration of London’s heritage in regenerative change by:

1) setting out a clear vision that recognises and embeds the role of heritage in place-making

2) utilising the heritage significance of a site or area in the planning and design process

3) integrating the conservation and enhancement of heritage assets and their settings with innovative and creative contextual architectural responses that contribute to their significance and sense of place

4) delivering positive benefits that conserve and enhance the historic environment, as well as contributing to the economic viability, accessibility and environmental quality of a place, and to social wellbeing.

C. Development proposals affecting heritage assets, and their settings, should 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.

D. Development proposals should identify assets of archaeological significance and use this information to avoid harm or minimise it through design and appropriate mitigation. Where applicable, development should make provision for the protection of significant archaeological assets and landscapes. The protection of undesignated heritage assets of archaeological interest equivalent to a scheduled monument should be given equivalent weight to designated heritage assets.

E. Where heritage assets have been identified as being At Risk, boroughs should identify specific opportunities for them to contribute to regeneration and place-making, and they should set out strategies for their repair and re-use.

3.4.9 Para. 7.1.8 adds ‘Where there is evidence of deliberate neglect of and/or damage to a heritage asset to help justify a development proposal, the deteriorated state of that asset should not be taken into account when making a decision on a development proposal’.

3.4.10 Para 7.1.11 adds ‘Developments will be expected to avoid or minimise harm to significant archaeological assets. In some cases, remains can be incorporated into and/or interpreted in new development. The physical assets should, where possible, be made available to the public on-site and opportunities taken to actively present the site’s archaeology. Where the archaeological asset cannot be preserved or managed on-site, appropriate provision must be made for the investigation, understanding, recording, dissemination and archiving of that asset, and must be undertaken by suitably-qualified individuals or organisations.

3.4.11 Policy HC2, “World Heritage Sites” is as follows:

A. Boroughs with World Heritage Sites and those that are neighbours to authorities with World Heritage Sites should include policies in their Development Plans that conserve, promote, actively protect and interpret the Outstanding Universal Value of World Heritage Sites, which includes the authenticity and integrity of their attributes and their management.

Development proposals in World Heritage Sites and their settings, including any buffer zones, should conserve, promote and enhance their Outstanding Universal Value, including the authenticity, integrity and significance of their attributes, and support their management and protection. In particular, they should not compromise the ability to appreciate their Outstanding Universal Value, or the authenticity and integrity of their attributes.

C. Development Proposals with the potential to affect World Heritage Sites or their settings should be supported by Heritage Impact Assessments. Where development proposals may contribute to a cumulative impact on a World Heritage Site or its setting, this should be clearly illustrated and assessed in the Heritage Impact Assessment.

D. Up-to-date World Heritage Site Management Plans should be used to inform the plan-making process, and when considering planning applications, appropriate weight should


be given to implementing the provisions of the World Heritage Site Management Plan.

3.5 Local Planning Policy (Harrow Council)

Harrow Local Plan Core Strategy

3.5.1 The Harrow Local Plan currently comprises Core Strategy and Development Management Policies that contain strategic approach to managing growth and development to 2026. The Development Management Local Plan was adopted on 4th July 2013 while the Core Strategy was adopted on 12th February 2012. The relevant heritage policies of the Strategy are outlined below:

Core Policy 1

Overarching Policy Objectives

1. Manage growth in accordance with the spatial strategy.

2. Resist any loss of Green Belt.

3. Safeguard and enhance Metropolitan Open Land.

4. Resist any net loss of open space and where possible seek to increase provision.

5. Enhance residents’ access to open space, recreation, health care, education and community facilities.

6. Deliver a minimum of 6,050 net additional homes between 2009 and 2026.

7. Deliver homes which are affordable, accessible and meet their occupiers’ needs including

the elderly, the disabled, larger households, vulnerable adults and the Gypsy & Traveller community.

8. Protect the character of Harrow’s suburbs and town centres.

9. Resist development on gardens.

10. Safeguard identified views and viewpoints from inappropriate development.

11. Strengthen Harrow town centre and maintain or enhance the vitality and viability of all town centres and neighbourhood parades (identified in Appendix B).

12. Promote job creation and business growth.

13. Maintain an integrated, sustainable transport network which supports growth.

14. Contribute to a 60 per cent reduction in London’s carbon dioxide emissions by 2025.

15. Manage and mitigate flood risk.

16. Increase the sustainable management of waste.

17. Deliver the infrastructure needed to support growth.

18. Conserve and enhance Harrow’s heritage assets, such as its conservation areas.

Core Policy CS: 1

Managing Growth in Harrow

A. Growth will be managed in accordance with the Spatial Strategy. The Harrow & Wealdstone

Intensification Area will be the focus for regeneration, providing for a significant portion of new development in accordance with

Policy CS 2, including almost half of all new homes over the plan period.

Growth throughout the rest of the Borough will be directed to town centres and strategic previously developed sites and managed in accordance with sub-area policies.

CS3-CS10 Local Character

B. Proposals that would harm the character of suburban areas and garden development will be

resisted. All development shall respond positively to the local and historic context in terms of design, siting, density and spacing, reinforce the positive attributes of local distinctiveness whilst promoting innovative design and/or enhancing areas of poor design; extensions should respect their host building.

C. Proposals that would harm identified views or impede access to public viewpoints will be resisted.

D. Proposals that would harm the significance of heritage assets including their setting will be resisted. The enhancement of heritage assets will be supported and encouraged.


E. All new development must create and maintain accessible, safe and secure neighbourhoods in accordance with best practice standards. Where appropriate, development should also seek to Core Policy CS 1 promote and enhance biodiversity in accordance with the aims of the Harrow Biodiversity Action Plan and best practice.

Harrow Development Management Policies

3.5.2 The Development Management Local Plan sets out Harrows approach to managing development in Harrow through specific standards and policy criteria. The Development Management Policies were adopted on the 4th July 2013.

Section 3—Conservation & Heritage

Policy DM7: Heritage Assets

Managing Heritage Assets

A. When assessing proposals affecting heritage assets, including non-designated heritage assets, priority over other policies in the DPD will be afforded to the conservation of the assets affected and their setting as appropriate to the significance of the assets.

Proposals that secure the preservation, conservation or enhancement of a heritage asset and its setting, or which secure opportunities for sustainable enjoyment of the historic environment, will be approved.

B. The impact of proposals affecting heritage assets will be assessed having regard to:

a. emerging or adopted supplementary planning documents, including character appraisals and management plans or other relevant documents;

b. relevant issues of design, appearance and character including proportion, scale, height, massing, bulk, alignment, materials, historic fabric, use, features, location, relationship with adjacent assets, setting, layout, plan form and landscaping;

c. the preference to be afforded to proposals that both conserve and sustain heritage assets and their setting;

d. any sustainable economic benefits;

e. the need to mitigate climate change and to ensure that heritage assets are resilient to the effects of climate change; and

f. the desirability of increasing understanding and interpretation of heritage assets; and

g. the reversibility of any change.

C. The Council will use planning conditions and planning obligations where necessary to secure the exploitation of opportunities for sustainable public access to the historic environment.

Conservation Areas

D. In addition to (A) and (B) above, when considering proposals within conservation areas, the Council will:

a. support the redevelopment of sites that detract from the character or appearance of the conservation area; and

b. exploit opportunities to restore lost features or introduce new ones that would enhance the character and appearance of the conservation area.

Listed Buildings

E. In addition to (A) and (B) above, when considering proposals affecting listed buildings and their setting, the Council will:

a. pay special attention to the building’s character and any features of special architectural or historic interest which it possesses, and the role of the building’s setting in these regards; and

b. exploit all opportunities to secure the future of listed buildings particularly those on the ‘heritage at risk’ register.

Scheduled Ancient Monuments

F. In addition to (A) and (B) above, when considering proposals affecting scheduled ancient monuments, the Council will have regard to:

a. the relationship of the monument with other archaeology and the wider landscape in which it should be interpreted;

b. the condition and management of the monument; and

c. the existing and future security of the monument.


G. Major development and change of use proposals affecting a scheduled ancient monument will be required to provide and implement an action plan for the management of the monument.

Archaeology

H. In addition to (A) and (B) above, when considering proposals affecting an archaeological priority area, the Council will have regard to:

a. the known or anticipated significance of the archaeology;

b. the likely implications of the proposal upon the archaeology; and

c. the need to preserve the archaeology in situ; or

d. the adequacy of arrangements for the investigation, recording, archiving and (where appropriate) curation of archaeology not requiring preservation in situ.


4 Built Heritage Baseline

4.1 History of Rayners Lane Conservation Area

4.1.1 The history of the Rayners Lane Conservation Area is outlined within its Conservation Area Appraisal and Management Guidelines (adopted in December 2009) adopted as Appendix 11 to the Pinner Conservation areas. The following is sourced directly from the apprasail:

The Rayners Lane conservation area forms the centrepiece of a much larger residential suburb with which its development is inextricably linked. Until the building of the Metropolitan Railway Station in 1906 this was a rural area with a single farmstead, Rayners Lane Farm, to the north of the station at the junction of Rayners Lane and Farm Avenue. Rayners Lane itself is an ancient roadway which may have medieval origins. Despite the building of the station, the area initially remained completely undeveloped. However between 1929 and 1938 Rayners Lane was transformed into a modern suburb complete with all the latest amenities. This development was principally at the instigation of two companies, Metropolitan Railway County Estates and T F Nash and Company. Metropolitan Railway County Estates, a subsidiary of the Metropolitan Railway Company established to develop the land alongside the railway lines, built the more prestigious Harrow Garden Suburb to the north of the railway line.

T F Nash occupied most of the land to the south of the station and concentrated on the mass production of cheaper housing. Nash employed up to 1000 workers on the project and a temporary narrow gauge railway was laid to speed construction. The results were startlingly cheap, with prices starting at £545 in 1930. Nash excelled in publicising and marketing the estate. In 1934 a temporary triumphal arch was erected at the north end of Alexandra Avenue as part of a major promotion. A garage providing courtesy cars to enable prospective buyers to view plots was also provided. This was a clever trick that disguised quite how far these houses were from the station. The initial phases of construction concentrated on the building of the terraced and semi-detached houses that form the bulk of the suburb and the smaller parades of shops around Village Way and the lower part of Alexandra Avenue.

The majority of these properties were completed by 1935. The buildings in the conservation area belong to a later phase of construction, between 1935 and 1938; blocks of flats lining the southern part of Alexandra Avenue were also constructed at this time.1

1 Rayners Lane Conservation Area Appraisal Publication (Harrow Council),


Fig 3 Historic image of Rayners Lane (Source: The National Archives UK).

Fig 4 Historic image of Rayners Lane Station (Source: The National Archives UK).


4.2 Site description

4.2.1 The site is a linear surface car park which runs parallel and to the south of the London Underground line at Rayners Lane station. The site is accessed from High Worple

4.2.2 To the south and the west of the site is residential development and the rear gardens of dwellings along High Worple Street.

4.2.3 The site is within the setting of the Rayners Lane Conservation Area, which is characterised by modern Metroland development.

4.3 Heritage assets within the setting.

Rayners Lane Underground Station

4.3.1 Rayners Lane Underground Station was opened in c1938 when the Metropolitan Railway line was introduced to the area. It replaced an earlier station building. The station is located to the west of the junction of Rayners Lane, Alexandra Avenue and Imperial Drive.

4.3.2 The station building is the pivotal building within the streetscape and within Rayners Lane Conservation Area. The station building is described within the Historic England Database Listing Form for the site as follows:

Rayner’s Lane (west side) Rayner's Lane LRT Underground Station, including shops and platforms (including Rayner's Lane Station, Alexandra Avenue) GV II London Underground Station with integrated shops and platforms designed in 1938 by Charles Holden and Reginald Uren. Reinforced concrete post and lintel construction exposed at platform level; red brick infill, some load-bearing. Flat concrete roof slabs exposed as broad cornice band under deep eaves. Symmetrical composition on bridge over tracks. Single storey frontage to Alexandra Avenue features corner kiosks with original curved shopfronts; entrances to side lead through square double-height ticket hall to single storey rear bridge, whence stairs under stepped enclosures descend to platforms. Platform structures are integral with the hall, bridge and stairs, set back from the tracks under a deep concrete canopy on two levels divided by clerestory and with waiting area between metal screens at foot of stairs. Enclosed waiting rooms with curved ends. All glazing save shop fronts metal with strong horizontal emphasis in glazing bars. Ticket hall has two two-light full height strip windows at front, four-light windows asymmetrically spaced at sides, seven-light full-height window at rear. Ticket hall lined in brick, with collector's booth and sign 'To the Trains.' Over the entrance shops two roundels impaled on poles bear the legends 'Underground' and 'Rayners Lane'. At platform level survive the original 'platform' signs and roundels fully lined out in black. On open part of platform, 22 original standard lamps; the platforms are bounded by the original concrete fence punctuated by eight slabs bearing roundels and poster boards, included as a more complex variant on the Sudbury Town prototype, with greater maturity in the composition of its curved frontage layout. It is unusually rich in the survival of its signage and fixtures.2

Rayners Lane Conservation Area

4.3.3 The subject site is located in the setting of the Rayners Lane Conservation Area. The boundary of the conservation area is shown in Figure 3 below. The conservation area was first designated in 2003.

4.3.4 The Rayners Lane Conservation Area is described in the Rayners Lane Conservation Area Appraisal and Management Strategy (adopted in December 2009) as outlined below:

2 Historic England Database List Entry, Rayner’s Lane London Regional Transport Underground Station including shops and platforms (including Rayner’s Lane Station, Alexandra Avenue), accessed: https://historicengland.org.uk/listing/the-list/list-entry/1261430 , accessed August 2019.


• As originally planned, the streetscape in the centre of Rayners Lane gave the area a spacious and modern feel that complemented the surrounding buildings. Alexandra Avenue was conceived as an impressive boulevard lined with wide concrete pavements edged with granite kerbs and enhanced by ornamental trees planted along the western side. At the junctions of Alexandra Avenue with Warden Avenue and Imperial Drive, grass verges surrounded by concrete posts and post and chain fencing provided a welcome splash of greenery and an important streetscape feature. Street furniture was simple and included rather fine lampposts with a large circular globe sitting directly on top of the post. These were replaced in the 1960s by a futuristic concrete design with a curved top and a circular suspended shade. Other notable features include the fine signage around the Underground Station and a set of railings on the east side of the bridge over the tube line.

• The Underground Station is at the highest point in the conservation area, atop the railway bridge, and this higher level reinforces its role as a pivotal building in the conservation area.

• The conservation area’s two principal uses are commercial (shops, restaurants etc.) on the ground floor and residential flats above, although the former Cinema is in religious use. The character of the area is in large part derived from its role as a district shopping centre and the hustle and bustle associated with this and the station. It is key that these uses are retained. The residential flats above are also important in providing surveillance to the streets below.

• The key views are identified on the map below and comprise views up and down Alexandra Avenue and to the landmark buildings within the area.3

4.3.5 The conservation area is also significant for its streetscape trees and grass verges which form part of the character and townscape setting of the main street.

4.3.6 The integrity of the conservation area has been somewhat impacted through some later piecemeal changes to frontages and streetscape, and indirectly by alterations to houses on nearby residential streets.

Ace Cinema (Grade II* listed heritage asset)

4.3.7 The former ACE Cinema, designed in 1936 by F E Bromige, is located on Alexandra Avenue and is a prominent Art Deco designed cinema with a bold triple bowed frontage with a very wide central projection within which rise full height concave and convex steel framed windows. A stylised elephant's trunk with a curved 'head' projecting above the bowed parapet rises upwards from the entrance canopy. The cinema is described within the Historic England Database Listing Form for the site as follows:

Cinema 1936 by F E Bromige. Mass concrete and brick; flat asphalt roof. Tall triple- bowed concrete frontage with very wide central bowed projection: convex flanking concave metal windows rise to full-height within. Flat and bowed concrete canopy across front and above entrance doors. Rising upwards from the entrance canopy is a great concrete feature in the shape of a stylised elephant's trunk, with the curved "head" projecting in front of and above the bowed parapet. Interior: oval-shaped entrance foyer, with steps and railings to sunken tea-room in centre which has cigar-shaped coved plaster ceiling. Auditorium has concrete horizontal fluted gallery front and inward-curving walls; it is dominated by a fibrous plaster ceiling with deep coved ribs driving forward and downward to proscenium arch which is flanked by fluted side columns. A remarkably individual cinema design, and noted as the least altered late 1930s streamlined "art deco" cinema.4

Shops at 468-472 Alexandra Avenue (locally listed)

4.3.8 The shops at 468-472 Alexandra Avenue, built by R C White-Cooper and S R Turner in 1937, are four distinct blocks of shops with flats above, designed in the 'International Style’. They comprise simple cylindrical and square masses covered in a bright white render, enlivened by

3 Rayners Lane Conservation Area Appraisal and Management Strategy (Harrow Council), December 2009, pp6-11. 4 Historic England Database List Entry, Ace Cinema, accessed: https://historicengland.org.uk/listing/the-list/list-entry/1079729, accessed March 2020.


continuous runs of windows. The buildings feature complex rooflines with gabled end wings and hipped dormers, prominent doorways leading to the upper floor flats, featuring semicircular arched openings capped with gabled roofs, and an iron balcony at first floor level above the shop with steel railings. PRed brick dressings surround door and window openings, while pilasters surrounding doors and separating shops feature rusticated quoining and are capped with stone brackets or a decorative brick crocketted pinnacle. Decorative brick designs were also set into gables. The original windows were all of the steel Crittall type and doors are panelled with a single glass light.5

.

Fig 5 Rayners Lane Conservation Area, approx. location of the subject site shown by a red star

(source: Harrow Council—Pinner Conservation Areas)

5 Rayners Lane Conservation Area Appraisal and Management Strategy (Harrow Council), December 2009, pp6-4.


Fig 6 Rayners Lane Conservation Area, approx. location of the subject site shown by a red star (source: Harrow Council—Pinner Conservation Areas).


Fig 7 Rayners Lane Conservation Area, showing characteristics of the conservation area (source: Harrow Council—Pinner Conservation Areas).


4.4 General Planning Advice 3 (GPA3) The Setting of Heritage Assets

(Historic England 2015)

Introduction

4.4.1 General Planning Advice 3 (GPA3) The Setting of Heritage Assets (Historic England 2015) sets out the broad methodology for assessing the impact of development on the significance of assets. This suggests a staged approach - Step 1 being the identification of assets potentially affected; Step 2 being to assess whether, how and to what degree the setting makes a contribution to the significance of the heritage asset(s); Step 3 is to assess the effects of the proposed development, whether beneficial or harmful, on that significance; Step 4 is to explore the ways to maximise enhancement and avoid or minimise harm; and Step 5, which is the preserve of the LPA, is to make and document the decision and monitor outcomes.

Step 1

4.4.2 This report has identified that the heritage assets which could potentially be affected is the Rayners Lane Conservation Area and the Rayners Lane Underground Station (Step 1).

Step 2

4.4.3 In detail, Step 2 considers:

a) the physical surroundings of the asset, including its relationship with other heritage

assets;

b) the way the asset is appreciated; and

c) the asset’s associations and patterns of use.

4.4.4 Commentary of the various facets of these factors is as follows:

a) The asset’s physical surroundings

• Topography – the Station is at the highest point in the conservation area, atop the railway bridge, and this higher level reinforces its role as a pivotal building in the conservation area.

• Aspect – there is a linear plan form and terraced development comprising medium densities of development along the streetscape (along Alexandra Avenue).

• Other heritage assets (including buildings, structures, landscapes, areas or archaeological remains) – listed buildings within the conservation area are the Former Grosvenor Cinema (Grade II*) & Rayners Lane Underground Station (Grade II). Locally listed buildings within the conservation area are 464 to 472 (even) Alexandra Avenue.

• Definition, scale and ‘grain’ of surrounding streetscape, landscape and spaces – there is a linear plan form and terraced development comprising medium densities of development. The conservation area’s two principal uses are commercial (shops, restaurants etc). The streetscape in Rayners Lane was designed to give the area a spacious and modern feel that complemented the surrounding buildings. Alexandra Avenue was conceived as an impressive boulevard lined with wide concrete pavements edged with granite kerbs and enhanced by ornamental trees planted along the western side.

• Formal design e.g. hierarchy, layout – there is no formal design attributed to the subject site.

• Orientation and aspect – the Station building sits at the highest level and is appreciated in views looking north and south along the street.

• Historic materials and surfaces – the Station building is constructed of brick with reinforced concrete posts and lintel construction and a flat concrete roof slab. The buildings within the conservation area are brown brick with contrasting white render and pitched brown tiled roofs. The buildings feature complex rooflines with gabled end wings and hipped dormers, prominent doorways leading to the upper floor flats, featuring semi-circular arched openings capped with gabled roofs, and an iron balcony at first floor level above the shop with steel railings.

• Green space, trees and vegetation - the pavements are tree lined, provide greenery and are an important streetscape feature.


• Openness, enclosure and boundaries – the street is open.

• Functional relationships and communications – none in particular, but there is a visual relationship between buildings within the conservation area, which creates a consistent streetscape front.

• History and degree of change over time – As originally planned, the streetscape in the centre of Rayners Lane gave the area a spacious and modern feel that complemented the surrounding buildings. Alexandra Avenue was conceived as an impressive boulevard lined with wide concrete pavements edged with granite kerbs and enhanced by ornamental trees planted along the western side. Despite many changes, the original street layout survives, including the site of former grassed verges at the junctions of Alexandra Avenue with Warden Avenue and Imperial Drive, which have now been converted into raised beds. Streetscape clutter is beginning to detract from the area’s intended simplicity.

b) Experience of the asset

• Surrounding townscape character – as above.

• Views from, towards, though, across and including the asset – views to the conservation area are tangential and ‘in passing’. These are north and south along Alexandra Avenue and Imperial Drive to the station, which is the pivotal building in the conservation area.

• Visual dominance, prominence or role as focal point – as above, the Station is the pivotal building in the conservation area.

• Noise, vibration and other nuisances – low passing traffic.

• Diurnal changes – The street is lined with trees which are affected by diurnal changes. The greenery of the street is an important part of its townscape character. Diurnal changes may result in greater visibility to the station in views along the street at certain times.

• Sense of enclosure, seclusion, intimacy or privacy – the street is intended to be open. The buildings enclose the main shopping street. There is a consistent medium density scale along the street which contributes to its sense of enclosure.

• Land use – the land is commercial (shops) and residential.

• Accessibility, permeability and patterns of movement –there is high pedestrian traffic along the street at key shopping times and low passing traffic.

• Degree of interpretation or promotion to the public – the area is characteristic of its time period.

• Rarity of comparable survivals of setting – the conservation area is not considered rare. Modernist and Art Deco style buildings feature in numerous outer areas of London.

c) Associations

• The assets associative attributes – there is no associative attributes of the site beyond a neutral (negligible) contribution to the setting of the conservation area, the Station building and other identified heritage assets in the vicinity.

• Associative relationships between heritage assets – there is no visual relationship between the site and surrounding streetscape and conservation area. The subject site has a neutral (negligible) contribution to the setting and views associated with the conservation area.

Step 3

4.4.5 This assessment reinforces the initial conclusion that the subject site (carpark) makes a neutral (negligible) contribution to the significance, setting and views of the conservation area (Step 3).

Step 4

4.4.6 The proposed redevelopment of the site is subject to detailed design development (Step 4).

Step 5

4.4.7 Step 5 will be undertaken by Local Planning Authority in due course.


5 Statement of Significance

5.1 Introduction

5.1.1 The subject site does not contain any nationally designated (protected) heritage assets such as scheduled monuments, listed buildings or registered parks and gardens. However, the site is to the north west of Rayners Lane Underground Station, a Grade II listed heritage asset identified as ‘Rayner’s Lane London Regional Transport Underground Station including shops and platforms’ (including Rayner’s Lane Station, Alexandra Avenue)—Historic England list entry number: 1261430. The subject site is within the setting of the Rayner’s Lane Conservation Area, and within the setting of the ‘Ace Cinema’ (a Grade II* listed heritage asset)—Historic England list entry number: 1079729, as well as locally listed shop buildings on Alexandra Avenue (numbers 454-462, 420-438, 455-463 and 411-453 Alexandra Avenue).

5.2 Significance Criteria

5.2.1 ‘Significance’ lies in the value of a heritage asset to this and future generations because of its heritage interest, which may be archaeological, architectural, artistic or historic. Archaeological interest includes an interest in carrying out an expert investigation at some point in the future into the evidence a heritage asset may hold of past human activity, and may apply to standing buildings or structures as well as buried remains. Known and potential heritage assets within the site and its vicinity have been identified from national and local designations, HER data and expert opinion. The determination of the significance of these assets is based on statutory designation and/or professional judgement against four values (EH 2008):

• Evidential value: the potential of the physical remains to yield evidence of past human activity. This might take into account date; rarity; state of preservation; diversity/complexity; contribution to published priorities; supporting documentation; collective value and comparative potential.

• Aesthetic value: this derives from the ways in which people draw sensory and intellectual stimulation from the heritage asset, taking into account what other people have said or written;

• Historical value: the ways in which past people, events and aspects of life can be connected through heritage asset to the present, such a connection often being illustrative or associative;

• Communal value: this derives from the meanings of a heritage asset for the people who know about it, or for whom it figures in their collective experience or memory; communal values are closely bound up with historical, particularly associative, and aesthetic values, along with and educational, social or economic values.

5.2.2 Table 2 gives examples of the significance of designated and non-designated heritage assets.

Table 2: Significance of heritage assets Heritage asset description Significance

World heritage sites Scheduled monuments Grade I and II* listed buildings Historic England Grade I and II* registered parks and gardens Protected Wrecks Heritage assets of national importance

Very high (International/

national)

Historic England Grade II registered parks and gardens Conservation areas Designated historic battlefields Grade II listed buildings Burial grounds Protected heritage landscapes (e.g. ancient woodland or historic hedgerows) Heritage assets of regional or county importance

High (national/ regional/ county)


Heritage asset description Significance

Heritage assets with a local (i.e. parish) value or interest for education or cultural appreciation

Low (Local)

Historic environment resource with no significant value or interest Negligible

Heritage assets that have a clear potential, but for which current knowledge is insufficient to allow significance to be determined

Uncertain

5.3 The subject site

5.3.1 The subject site is not a heritage asset and does not contain any buildings.

5.4 Rayners Lane Underground Station and Rayners Lane Conservation Area

Rayners Lane Underground Station

5.4.1 Grade II listed buildings have high significance as a baseline.

5.4.2 The station building and integrated shops and platforms, constructed in c1938 is significant for its Modern Movement architecture. The station building was built to a design by Charles Holden and Reginald Uren and features large cube-shaped brick and glass ticket hall capped with a flat reinforced concrete roof and geometrical forms typical of the new stations built in this period.

Rayners Lane Conservation Area

5.4.3 Conservation areas have high significance as a baseline.

5.4.4 The significance of the Rayners Lane Conservation Area is outlined within the Rayners Lane Conservation Area Appraisal and Management Strategy below:

Rayner's Lane is an area of classic Metroland that developed around a Tube Station. The conservation area is of interest as it forms the centrepiece of a large 1930s residential development with fine groups of buildings in the Modernist and Art Deco style surrounded by a distinctive group of shops and flats in the house style of the developer.6

.

6 Ibid, Rayners Lane Conservation Area Appraisal and Management Strategy (Harrow Council), p4.


6 Proposed Development

6.1 Proposal

6.1.1 The scheme comprises redevelopment of the site for new residential development, public carparking and public realm improvements.

6.1.2 The proposal will comprise the construction of up to 128 residential units, with four buildings (5-6 storey mansion blocks) across the site (from east-west), with flexible ground floorspace and a public carpark; along with associated public realm enhancements. Only Building A (5 storeys) will be partially visible in the backdrop of the station and is considered for potential heritage impact.

6.1.3 The proposed development includes a high-quality masonry material palette which responds to the materiality and detailing of the listed station building. A rhythm of paired semi-recessed balconies and juliette windows offers an elegant composed expression to the new street as shown in Fig 8 below.

Fig 8 Aerial sketch view of site layout (source: Karakusevic Carson Architects).


Fig 9 CGI view showing new residential blocks (source: Karakusevic Carson Architects).


7 Impact of Proposed Development

7.1 Discussion of heritage impact

7.1.1 The subject site comprises a strip of land alongside the railway for proposed redevelopment. The site sits outside of the conservation area and is presently car-parking. It makes a low contribution to the setting of the Grade II listed station building and the conservation area. The proposed development contains a series of 5-6-storey mansion blocks across the site (from east-west).

Potential impact on heritage assets

7.1.2 The proposed building is designed as an overall simple, modern and high-quality built form in the setting of the identified heritage assets. Building A will be set back from the rear of the station (which has a main frontage to Alexandra Avenue). It will be in the backdrop of the station with partial visibility only (and will sit at a lower level than the station).

7.1.3 The proposed development (originally 6 storeys) has reduced Block A to 5 storeys, to reduce its visibility beyond the station. The revised proposal will better reflect the established suburban scale of the surrounding area in terms of height and massing. The views show that the proposed height and scale of the development will not compete against the dominance of the station, which is the primary focal point and tallest building within the conservation area.

There will be a minor heritage impact on principal views to the station from some aspects. The upper portion of the proposed development will be partially visible beyond the single storey shops adjacent to the station building; however, the principal presentation and symmetry of the station building will remain the key elements in its principal views. The proposed new development will be substantially set back and appear subservient and unobtrusive in the backdrop.

There will be a moderate heritage impact on the view from the platforms. The view to the southwest from the platform will be screened by the new development; however, a sense of ‘openness’ and greenery is retained in views to the northwest from the station platform.

7.1.4 The proposed development will not interrupt key views to the station as the modernist form and detailing of the station will continue to be a prominent feature in views.

7.1.5 The simple character and quality of the proposed new development will not draw attention away from the scale, character and quality of the historic streetscape and station building, which will retain prominence. The proposed overall rectangular form and flat roof of the new development will respond to the form of the station. Further, the proposed materiality (brickwork) will respond to the materiality of the main station building.

7.1.6 The proposed development will not impact upon the ability to interpret the special character, features and consistency of the main shopping street (Alexandra Avenue) within the conservation area. The proposed development is unlikely to have any significant visibility from the High Street or Alexandra Avenue beyond existing development and tree coverage.

Platforms

7.1.7 The proposed development will have a moderate heritage impact on the view and appreciation of ‘openness’ from the platform. The proposed development will be constructed close to the edge of the platform and will screen the views to the south west. The proposed development will result in appreciable change in the setting and view from the platform from this aspect; however, open views to the northwest will be retained unaffected.


Fig 10 Existing view of the station platforms (source: Karakusevic Carson Architects).

Fig 11 CGI showing the proposed view from the station platform (source: Karakusevic Carson Architects).


7.2 Discussion of relevant heritage views

View one

7.2.1 The proposed development will only have minor visibility in the backdrop of shop buildings along Alexandra Avenue within the conservation area and will be largely screened by the existing shopping parade and street trees, even in the winter months, as shown in Fig 11. The prominent built form and roof form of buildings along the street frontage will remain prominent in key streetscape views up and down Alexandra Avenue.

Fig 12 Viewpoint 2 Alexandra Avenue just south of the Ace Cinema (source: Landscape Visual).

View two

7.2.2 The proposed development will only be partially visible (part of the upper storey) above the single storey shop units adjacent to the station along Alexandra Avenue. Given the substantial distance that Building A will be set back behind the rear building line of the station, the overall impact will be minimised.


Fig 13 Viewpoint 9 View from Alexandra Avenue (source: Landscape Visual).

View three

7.2.3 The proposed development will not be visible from this aspect (from Imperial Drive) (see Fig 12), due to the sloping topography of the road and the existing built form alongside the station screening the development. The Station will remain a prominent feature in the streetscape from this aspect.

Fig 14 Viewpoint 11 View from Imperial Drive (source: Landscape Visual).


8 Conclusions and Recommendations

8.1 Conclusions

8.1.1 The proposed development is considered likely to have ‘less than substantial harm’ to the setting of the identified heritage assets, due to the scale of the proposed development (with the present carpark currently contributing to openness); however, the harm is at the lower end of the threshold and outweighed by the significant public benefits of the proposal. The sympathetic and high-quality design response of the proposed development (as outlined within this report) should be considered, together with the provision of significant public realm enhancements.

8.1.2 The public benefits of the proposal have been summarised below and are further detailed in the accompanying planning documentation.

• Delivery of 128 Affordable Housing units at a policy compliant mix. Providing London Affordable Rent and Shared Ownership Properties

• The delivery of a circa 82 cycle hub spaces within the red line boundary of the site. Harrow is a borough which TfL consider to have the most potential for increasing cycle usage and trips increasing the use of sustainable modes within the Borough.

• The cycle hub will be provided and existing car parking spaces reduced which will contribute to wider sustainability aspirations of the Borough and the GLA.

• Creation of a Landscaped Garden adjacent to a SINC, which is publicly accessible green open space within the heart of Rayners Lane.

• Preservation of the original concrete fence along the station platform and original lighting, which contributes to the overall conservation of the station as a heritage asset; and

• High quality public realm enhancements.

8.2 Recommendations

8.2.1 There are no recommendations.


9 Bibliography

9.1 Published and documentary sources

CIfA [Chartered Institute for Archaeologists] Dec 2014a, Standards and guidance for commissioning work or providing consultancy advice on archaeology and the historic environment, Reading.

CIfA [Chartered Institute for Archaeologists] Dec 2014b, Standards and guidance for historic environment desk-based assessment, Reading

DCLG [Department of Communities and Local Government], February 2019 National Planning Policy Framework

DCLG [Department of Communities and Local Government], March 2014 Conserving and Enhancing the Historic Environment: Planning Practice Guide

Domesday Book, A Complete Translation, eds Williams, A. and Martin, G.H. 1992, 2002. London: Penguin Books

EH [English Heritage], 2008 Conservation principles, policies and guidance. Swindon HE [Historic England] 2015a, The Setting of Heritage Assets – Historic Environment Good Practice

Advice in Planning: 3. Historic England in collaboration with the Historic Environment Forum, second edition, Historic England July 2015.

HE [Historic England] 2015b Managing Significance in Decision-Taking in the Historic Environment – Historic Environment Good Practice Advice in Planning: 2. Historic England in collaboration with the Historic Environment Forum, second edition, Historic England July 2015.

9.2 Other Sources

British Geological Survey online historic geology borehole data and digital drift and solid geology data Greater London Historic Environment Record Historic England designation data Internet – web-published sources: Groundsure historic Ordnance Survey mapping

Documents

Historic Environment Assessment