With the planning application for the dismantling of the Coventry Cross being set for a decision by Planning Committee on the 15th November, we are sharing with you below the representation made by the Coventry Society. We will also be submitting a petition with nearly 900 signatures in support of our campaign to leave the cross where it is.  At present the planning application is recommended for approval by officers. There is still time to make your own representation on the application – the deadline is 15th November but as that is also the date of the committee we recommend replying earlier.

The case to retain the cross is outlined in full below. Whilst we apologise for the length of the report, we feel that it is important that Coventry Citizens can read in full our objections and form their own judgement.

Planning Application FUL/2018/2655: Redevelopment of Trinity Square comprising of the removal and re-location of the Coventry Cross, the redesign of the public space area and reconfiguration of the existing rear terrace to facilitate a larger seating area in connection with the existing restaurant

 The Coventry Society OBJECTS to this planning application for the following reasons:

1. The description of the development is extremely misleading as the proposals submitted do not include any proposals for the relocation of the Coventry Cross, merely its dismantling. Furthermore the development does not “redesign the public space” but removes it entirely and replaces it with private space. We object to the loss of the public space and public amenity of the Cross and its replacement with a private dining area.
2. The submitted Heritage Statement is flawed in that it is based on the incorrect assumption that the development is in the High Street Conservation Area, whereas in fact it is located in the Hill Top Conservation Area, defined by the Government as one of the country’s highest ranking Conservation Areas. The Heritage Statement includes no analysis of the impact of the development on this Conservation Area and is therefore in breach of the provisions of a raft of Government and local policy.
3. The application is further flawed in that the accompanying letter describes the Coventry Cross as a War Memorial, thus demonstrating a complete lack of understanding of the heritage of the city and the Conservation Area.
4. There is no consideration of the Planning Listed Buildings and Conservation Areas Act 1990 and how development must preserve or enhance the Conservation Area. There is no discussion of the significance of the Cross and setting within the conservation area and the impact of the development on the setting of the two Grade 1 and a Grade 2* listed building which immediately adjoin it, and there is no mention of the conservation area appraisal and management plan which specifically identifies the Cross as a positive feature that should be retained.
5. The proposed development is in our opinion not of sufficient quality for such an important part of the city. The rear of Cathedral Lanes has not weathered well and would benefit from refurbishment, but not at the cost of demolishing a historic structure and losing public space.
6. We believe that the applicant has not provided evidence to justify the removal of a much loved feature, the replica of the Coventry Cross. The cross, although only dating back to the early 1970s, is a replica of the medieval Coventry cross and thereby acquired antiquity from the day it was built. It is included in the Historic Environment Records of the city and is referred to in the Conservation Area Appraisal as a heritage asset. (see Appendix below).
7. The development is contrary to the provisions of section 16 of the National Planning Policy Framework, in that the replica Coventry Cross has been defined as a Heritage Asset and the provisions of the NPPF have not been applied to the application. We provide more detail in the Appendix.
8. The development is contrary to the provisions of the Coventry Local Plan 2017 and in particular Policies HE1 and HE2 which detail how Heritage Assets should be treated. There is further explanation in the Appendix.
9. The proposed development is contrary to the provisions of the City Centre Area Action Plan and in particular policies CC2, CC14 and CC13. We provide a detailed analysis of this in the Appendix, but of particular note the City Centre Area Action Plan proposes this area as an Open Space / Node and the development of a private dining area will remove the potential to achieve this objective.
10. The development is contrary to the provisions of the Hill Top Conservation Area Appraisal and Management Plan. In particular the Appraisal defines the Cross as a Heritage Asset and this fact should be taken into account in considering the planning application. We provide further details in the Appendix.
11. The loss of the wheelchair ramp, and its replacement with an outdoor electrical lift will reduce the accessibility of the site for disabled people. Outdoor electric lifts are unsightly and unsuited to a historic conservation area.

The Coventry Society is disappointed at the lack of public consultation on these proposals. The demolition of the cross was applied for under planning application FUL/2018/0340. This application generated a significant number of objections to the relocation of the cross.  That application has been withdrawn, but the comments made on it will not be heard by the Planning Committee. Because of this the Coventry Society has raised a petition against the proposals which has so far received over 900 signatures and this will be presented to the Planning Committee at its meeting.

The Coventry Society recommends that Planning Committee demonstrates its independence and REFUSES this application for the above reasons. Approval of the proposals, in defiance of its own and government policies, would open the city council to accusations of maladministration and would set an unacceptable precedent for future developments in the city’s Conservation Areas.

Yours sincerely

Coventry Society

APPENDIX – THE POLICY CONTEXT

National Planning Policy Framework

The Coventry Society considers that the development is contrary to Section 16 of the National Planning Policy Framework. In particular the application does not consider the significance of the development in the context of the Hill Top Conservation Area and the close proximity of a number of Grade 1 and Grade II* Listed buildings, including St. Michael’s Church and tower, Holy Trinity Church, County Hall and the New Cathedral.

In particular paragraph 189 states “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. …. 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.”

[The planning application does not describe the significance of any of the heritage assets affected or include a desk based assessment of the archaeological significance of the site.]

Paragraph 194 states “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.”

[No clear and convincing justification has been provided.]

Paragraph 195 states “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,  …..

[The development will create significant harm to a heritage asset and there is therefore a presumption that consent should be refused. It is clear that the public benefit does not outweigh the harm.]

Coventry Local Plan 2017

 We feel that the following policies of the recently approved Local Plan are relevant to this application:

Policy HE1 Conservation Areas

3. Conservation Area Appraisals and Management Plans will be produced for all of the Conservation Areas to guide their preservation and enhancement. All development proposals within Conservation Areas will be determined in accordance with this Plan and the appropriate Appraisal and Management Plan.

[The application includes no justification for over-ruling the Appraisal and Management Plan for Hill Top Conservation Area.]

Policy HE2: Conservation and Heritage Assets

1. In order to help sustain the historic character, sense of place, environmental quality and local distinctiveness of Coventry, development proposals will be supported where they conserve and, where appropriate, enhance those aspects of the historic environment which are recognised as being of special historic, archaeological, architectural, artistic, landscape or townscape significance.

These Heritage Assets include:

1. a) Listed Buildings and Locally Listed buildings;
2. b) Conservation Areas;
3. c) Scheduled Ancient Monuments and Archaeological sites;
4. d) Registered Parks and Gardens; and
5. e) Other places, spaces, structures and features which may not be formally designated but are recognised as significant elements of Coventry’s heritage and are positively identified on the Coventry Historic Environment Record.

[This demonstrates that the Cross is a Heritage Asset and should be conserved]

2. Proposals likely to affect the significance of a heritage asset or its setting should demonstrate an understanding of such significance using currently available evidence.

[No evidence is provided that the development is appropriate in this historically sensitive area]

3. Development proposals involving heritage assets in general and listed buildings in particular, should acknowledge the significance of the existing building and the area by means of their siting, massing, form, scale, materials and detail.

[There is no acknowledgement of the significance of adjoining listed buildings]

6. Demolition or destruction of heritage assets will be resisted; proposals to demolish a heritage asset will therefore need substantial justification. The greater the damage to the significance of the asset, the greater the justification required and the public benefit needed to outweigh such damage.

[There is no justification provided, let alone substantial justification]

7. All proposals should aim to sustain and reinforce the special character and conserve the following distinctive historic elements of Coventry:

1. a) The surviving buildings, defences and street plan of the medieval city centre and its suburbs;
2. h) Archaeological remains of all periods from the earliest Prehistoric human habitation to the modern industrial period.

[The application does nothing to reinforce the special character of this area and no proposals are made for archaeological investigation]

The City Centre Area Action Plan 2017

In our view the application is contrary to the Council’s own City Centre Area Action Plan. In particular:

Policy CC2: Enhancement of Heritage Assets

1. All development within, or affecting the setting of, a Conservation Area (as highlighted in Figure 2) shall preserve or enhance its character and appearance and adhere to the policies of the relevant Conservation Area Appraisal and Management Plan.

1. All development relating to or in close proximity to heritage assets such as statutory and locally listed buildings, Scheduled Monuments, public artwork and non-designated heritage assets (Figure

2) shall be undertaken sympathetically to those heritage assets and seek to preserve or enhance their setting.

[The development does not preserve or enhance the setting of the Conservation Area and does not adhere to the polices of the Conservation Area Appraisal and Management Plan. The development is not sympathetic to the surrounding heritage assets.]

Policy CC4: Public Art

1. Established public art shall be retained in redevelopment proposals unless the benefits of its removal outweigh the harm of its loss. Where public art is lost replacement works shall be incorporated into new development unless robust justification is provided highlighting that this it is not viable.

[The Cross is a work of Public Art which is not being retained in the Conservation Area and is a loss to the historic environment.]

Policy CC13

1. All development proposals within the Hill Top and Lady Herbert’s Garden and The Burges Conservation Areas will only be considered acceptable if they demonstrate that they preserve and enhance the historic environment of the area and are in adherence with the policies of the respective Conservation Area Management Plans.
2. Within Archaeological Constraint Areas and areas of archaeological potential (Figure 3), appropriate archaeological assessment will be required prior to the determination of a development proposal. Where significant archaeological remains are found they shall be recorded in a manner proportionate to their significance. Remains of high significance shall be preserved and protected.

[The development does not preserve and enhance the historic environment surrounding it or adhere to the policies of the Conservation Area Management Plan. No archaeological assessment has been provided]

Development Guidelines

Figure 12b shows Development Guidelines for the Cathedrals and Cultural Areas sub area. This shows an Open Space / Node in the vicinity of what the applicant calls Trinity Square. The development proposed in this application will create private outdoor space (an outdoor dining area) in this vicinity and this will remove the option of creating a such a public space, indeed it will reduce the space available in the public realm.

Hill Top Conservation Area Appraisal

Other Heritage Assets, Positive Buildings, Spaces and Features of Value

* The Coventry Cross replica which enhances the historic character of the area.

[This demonstrates that the Cross is listed as  a Heritage Asset that contributes to the environment of the Conservation Area].

Hill Top Conservation Area Management Plan

The following proposals of the Management Plan are considered relevant to this development:

2.5 Demolition of Historic Buildings and Structures

Proposal

Buildings should only be demolished where it can be demonstrated that they make little or no contribution to the character and appearance of the Conservation Area. Any proposed replacement development must also enhance the area.

Issue Being Addressed

The vast majority of buildings within the Hill Top Conservation Area make a strong positive contribution to the character and appearance of the area. Only in a few very exceptional cases would demolition be considered.

[The Coventry Cross makes a significant contribution to the character of the Conservation Area. There should therefore be a strong presumption against the demolition of heritage assets in the Conservation Area]

3.1 Design of New Development

Proposal

All new development within the Conservation Area should enhance its historic character.

Issue Being Addressed

Recent developments have been carefully designed to enhance the area and compliment existing historic buildings. This approach should continue to be used for all future developments.

Action

The scale, massing, siting, design and materials for all new developments must demonstrate a

regard for and enhance the special architectural and historic interest of the Conservation Area.

[The development does not enhance the historic character of the area, but rather harms it by removing a key heritage asset]

4.9 Public Art

Proposal

Public art installations that make a positive contribution to the character of the Conservation Area will be retained and maintained.

Issue Being Addressed

The Conservation Area contains a number of works of public art that make a positive contribution to its character and enhance the street scene and green spaces. Within the Cathedral ruins, however, there are too many and this has resulted in an impression of clutter which detracts from the historic surroundings.

Action

Public art installations will be retained and maintained where they make a positive contribution to the character of the Conservation Area. When siting new public art installations thought must be given to their impact on important views and vistas, the setting of historic buildings, streets and green spaces.

[The Coventry Cross is a piece of public art which makes a positive contribution to the Conservation Area and should therefore be retained]