Our Objection Letter...

This letter was shared in full on the Dacorum Borough council planning portal and relayed by over 160 local residents. As a result of high public interest, the case will be reviewed at committee on 12th December 2024 at 7pm, The Forum. This is a public meeting and we'd really appreciate your in-person support on the night. We feel we have a very strong case and this letter details our resistance to Herts County councils residential proposal, which can be found here in favour of our alternative community focused alternative which you can find here.
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Dacorum Borough Council
Planning Department
The Forum
Marlowes
Hemel Hempstead
Hertfordshire
HP1 1DN
Date
Re: Proposed development of Heath Barn, Heath Farmhouse and Heath Cottage, Hemel Hempstead
Planning Application Reference: 24/00075/FUL & 24/00076/LBC
To Whom it May Concern,
I am writing to notify you of my objections to the proposed development of the Heath Barn and Cottage site on St. John’s Road, Boxmoor and the change of use from educational to residential that will be required for this development. I am deeply concerned that this historically significant heritage asset may be developed into residential dwellings, rather than the site being restored and repurposed for the use of the whole community.
My core objections to the planned development are detailed below.
Objections in relation to the listing of the Heath Barn and Cottage with Historic England
List entry numbers:
Heath Barn: 1251174
Heath Farmhouse: 1251155
Heath Barn Cottage: 1251157
Grouping
The Heath Barn, Heath Farmhouse and Cottage are 16th Century Grade II Listed buildings. Historic England’s guidance document, Adapting Traditional Farm Buildings: Best Practice Guidelines for Adaptive Reuse (2017), details that: ‘Most traditional farm buildings date from the 19th Century and only a very small proportion, usually older and more architecturally significant buildings, are protected through listing.’ The Heath Barn buildings fall within this ‘very small proportion’, and are consequently hugely historically and architecturally significant.
Under the listing, the buildings are grouped together as one. The Principles of Selection for Listed Buildings (Department for Digital, Culture, Media and Sport, 2018) gives details of the nature of this ‘group value’. Group value describes ‘the extent to which the exterior of the building contributes to the architectural or historic interest of any group of buildings of which it forms part’. As detailed in Paragraph 17, this is particularly significant in the case of the Heath Barn, Heath Farmhouse and Heath Barn Cottage buildings as there is indeed ‘a historical functional relationship between the buildings’, both in their use for centuries as a working farm and later, for decades in their use as a centre for musical education (see also section on Social and cultural context below). Additionally, the continuous square arrangement of the buildings around a courtyard is a ‘fine example of planning’ from the 16th Century and therefore hugely historically significant (see also section on Architectural context below). The proposed housing development would involve the group of buildings being divided into five separate dwellings, each under different ownership, subsequently greatly undermining their group value, their historical significance and effectively removing the functional relationship between them.
The National Planning Policy Framework (NPPF) 2012 (Section 16 Paragraph 197a) states that when determining applications, local planning authorities should take account of ‘the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation’. The group value attributed to the Heath Barn buildings is worthy of preserving. Were the buildings collectively to be restored for community use, their heritage significance would be honoured and even enhanced. To separate the buildings into private dwellings would undermine the social context of the grouping, preventing them from being used as a cohesive unit and maintaining their heritage significance, thereby contravening the above requirements of the NPPF.
Architectural context
The local history text Royalty to Commoners: Four Hundred Years of the Box Moor Trust (J and R Hands, 2004) describes some of the history of the Heath Barn and Cottage buildings: The ‘Haybarns’ or Heath Barns was a sub-manor of Hemel Hempstead and was once owned by Lieutenant Colonel F S Brereton. It is thought that the buildings are the second oldest in Boxmoor, and as such, they are hugely important to the wider architectural and cultural context of the area. As previously mentioned, the majority of the buildings on the site were built in the 16th Century - it must be noted that there are very few structures still standing in this area from the Tudor period. The buildings were constructed using traditional methods, using a timber-framed structure and stone. This is a significant agricultural building type. Barns of this structure and age are specific to Hertfordshire and the East of England. Of additional importance is the continuous square arrangement of the buildings around a central courtyard. The courtyard arrangement had functional significance based on the particular agricultural use of the site. Each building would have had a very specific purpose that contributed to the overall working of the farm, which further supports the ‘group value’ described above.
The Dacorum Borough Council (DBC) website states on its Listed Buildings page (https://www.dacorum.gov.uk/home/planning-development/planning-cons-design/listed-buildings) that when undertaking repairs or alterations to a listed building, three principles apply. Firstly, minimum intervention: the process of converting the Heath Barn and Cottage buildings into residential dwellings would undoubtedly cause more internal alterations and risks to the building than the process of restoring the buildings for continued community use. Secondly, honesty: ‘the alterations should be sympathetic to the existing fabric in terms of performance and character’. As previously mentioned, the changes required to convert the buildings into modern, functional and sustainable homes would change the performance and character of the buildings significantly. As the DBC website rightly states, this may confuse the historical interpretation of the fabric and devalue the original architecture. Thirdly, reversibility: Once converted, it would be highly unlikely that the buildings would ever be able to be ‘returned to the state in which [they were] found without harm’. Therefore, the proposed housing development can be considered as inappropriate and damaging to the architectural and historical integrity of the buildings.
The physical restraints of the buildings, and the limitations resulting from their Grade II Listed status, would necessitate that significant alterations be made in order to enable the residential conversion. However, an alternative use, such as a community initiative, could be much more easily accommodated within the existing fabric of the buildings, leading to fewer structural and cosmetic changes.
A recent site visit has provided important information on the current state of the site. Where the walls of the buildings have been infilled (as in the case of the caretaker’s cottage), and later extended elements added (such as an entry porch), this has contributed to damp and wet rot. The well-ventilated, open plan barn areas are in good order. In the inner courtyard, the raising of hard standing and built up planting has led to rising damp, impacting areas of the timber baseplate. A building of this age and structure needs to be able to ‘breathe’ and where this is contravened, damp will become a major factor needing to be controlled. Consequently, the projected cost to develop the buildings into housing that complies with building regulations will be higher than early indications may have suggested. A simpler upgrade for community use, could bring the building back into useful order much more cost effectively.
Social and cultural context
The Heath Barn and Cottage Buildings were used as a centre for musical education by The Hemel Hempstead School and Dacorum Music School from the 1950s until 2019. The function of the buildings over this period of time, and the musical learning, examinations, performances and collaborations that took place within them, has left a lasting positive impact on the communities of Boxmoor and Hemel Hempstead. There are many cherished memories of times spent within the buildings and many musical careers have been forged as a result of the educational experiences provided there. These social and cultural contributions previously made by the buildings to the community are very significant and need to be taken into consideration during all discussions about future use.
The NPPF Section 16 Paragraph 189 makes reference to the Planning (Listed Buildings and Conservation Areas) Act 1990, stating that heritage 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’. Furthermore, Sections 16 Paragraphs 197c and 190d state that local planning authorities and planning strategy should take into account: ‘the desirability of new development making a positive contribution to local character and distinctiveness’ and ‘opportunities to draw on the contribution made by the historic environment to the character of a place’. Additionally, Section 16 Paragraph 190b stipulates that consideration should be given to ‘the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring’. The development of these buildings for housing would contravene these requirements and necessitate that the historically and culturally significant features of the buildings were only available to the few, rather than the whole community. This would have a detrimental impact on the wider cultural environment of Boxmoor and Hemel Hempstead as a whole. As stated above, the Heath Barn buildings have been used and treasured by local residents and students for decades during their time as a centre for musical education and performance. To remove the opportunity for future communities to engage with the building in similar and new ways would contravene the NPPF Section 16 Paragraph 197b: ‘the positive contribution that conservation of heritage assets can make to sustainable communities’.
The Heath Barn and Cottage buildings are located in the heart of the community. They are surrounded on all sides by buildings associated with education, community and leisure: The Hemel Hempstead School, Hemel Hempstead Leisure Centre, St. John’s Church and The Boxmoor Playhouse. There are no adjoining housing developments. Many community events are hosted throughout the year on Blackbirds Moor opposite the buildings, including Box Moor Trust events, outdoor fitness classes, seasonal markets and family events and a visiting circus. To convert the Heath Barn buildings into private residential dwellings would not just be entirely at odds with its own historical context, but also the social and cultural context of its physical situation in the heart of the community. An alternative community initiative would be a logical and much needed addition to the area and would bring a wealth of opportunities for collaboration with the aforementioned local organisations.
Unfortunately, Boxmoor is not designated as a conservation area under the Dacorum Borough Council Local Plan (2004). Additionally, there appears to be no Character Appraisal and Management Proposal available for the area, as there is for other local areas of heritage significance, such as Hemel Hempstead Old Town and Aldbury. It is not clear why the historic profile of Boxmoor has not yet warranted a Character Appraisal and Management Proposal considering the variety of listed buildings in the area and the presence of the beautiful St. John’s Church next to Blackbirds Moor. Historic England’s guidance document, Adapting Traditional Farm Buildings: Best Practice Guidelines for Adaptive Reuse (2017), asserts that traditional farm buildings ‘make an essential contribution to England’s remarkably varied landscape character and local distinctiveness, telling us about how the land was settled and how our ancestors farmed and lived’. Alongside the determined and tireless work of The Box Moor Trust to preserve our natural environment, there is also a great need for a similar effort to preserve our historic environment and protect our heritage assets. A Character Appraisal and Management Proposal for Boxmoor would make it much more likely that this would happen.
Objections in relation to the change of use of the Heath Barn buildings from educational to residential
For the housing development to proceed, Dacorum Borough Council will need to approve the change of use of the buildings from Class F1 For the Provision of Education (Learning and non-residential institutions) to C3 Homes (Locations where people sleep) for the Heath Barn site, as described in the Town and Country Planning (Use Classes) Order, 1987. Should this happen, it would set a precedent for future developments and undermine the Council’s ability to resist similar inappropriate and policy-divergent applications for change of use. Furthermore, it would significantly undermine and devalue the cultural and social history of the building as an educational facility and prevent it being used for this purpose, or similar purposes, in the future.
Objections in relation to amenity and aspect for the proposed housing development and surrounding buildings
Section 12 (Achieving well-designed spaces) of the NPPF outlines the need for good design in sustainable development. Section 12 Paragraph 130a states that planning decisions should ensure that developments ‘will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development’. A five-dwelling private residential development will do very little to add to the overall quality of the area of Boxmoor, especially in comparison with what could be achieved and provided by the Heath Barn site if it were to be used as a community asset. Furthermore, Paragraph 130c states that developments should be ‘sympathetic to local character and history, including the surrounding built environment and landscape setting’; and Paragraph 130d states that developments should ‘establish or maintain a strong sense of place [in order to] create attractive, welcoming and distinctive places to live, work and visit’. As previously stated, The Heath Barn and Cottage buildings are surrounded by community and educational facilities, therefore the position of the site is entirely wrong for a private housing development. A ‘strong sense of place’ would not be achieved by this development. The five dwellings would be lost within an existing area of community activity and many difficulties are therefore likely to arise with regard to amenity and access for the proposed development and for the neighbouring buildings and organisations.
An established concern of this nature is that of The Boxmoor Playhouse. Two fire exits open out onto the land between The Boxmoor Playhouse and the Heath Barn buildings, one into the alleyway beside the Heath Barn boundary fence, but one directly to a gate, which opens onto Heath Barn land. Previously, a Hertfordshire County Council license existed (from 2008-2018), which allowed The Boxmoor Playhouse use of adjoining Heath Barn land in the event of an emergency evacuation due to fire. If an evacuation was required during a performance, there could be up to 250 people needing to exit the building at once. Although there are other fire exits around the building, the exit facing Heath Barn is essential as it allows people to quickly be completely clear of the building. The fact that a license was previously in place demonstrates the need for an ongoing arrangement of this nature, which may not be possible if the Heath Barn site is under private ownership by multiple residents.
Other difficulties regarding light and noise may arise as a consequence of the site’s proximity to community venues. The sports courts behind the Heath Barn buildings and the pitches belonging to The Hemel Hempstead School both require flood lighting in darker evenings. Additionally, at times there may be a high level of noise from sporting events on the school grounds and events on Blackbirds Moor (for example, the visiting circus). These potentially high levels of light and noise may both cause disturbance for residents of a housing development.
Section 12 Paragraph 130f of the NPPF states that developments should ‘create places that are safe, inclusive and accessible and which promote health and wellbeing, with a high standard of amenity for existing and future users’. It is essential to consider the variety of ways in which the proposed housing development contravenes this statement and presents challenges to the aspect of the potential future homeowners.
The windows of the Heath Barn buildings are small and most are looking onto the internal courtyard. There would be a distance of approximately 15m across the courtyard from window to window, far less than the preferred distance of 22m between windows in a residential development, especially between bedrooms and bathrooms. Future residents would effectively be looking directly into one another’s properties and have limited views of the areas surrounding the buildings. Due to the fact that the windows are historically significant, it would not be appropriate to frost them for bathrooms or bedrooms. Changes to any glazing would not be in keeping with the character of the building. Moreover, due to the internal angles of the courtyard arrangement of buildings, certain windows will look out within a 45o view cone. This means that there would be significant restriction of outlook from the buildings, leading to an oppressive living environment for potential residents in the affected properties.
The unequal distribution of external amenity space will mean that access to and from designated gardens and parking spaces will likely lead to adjustments to the external building fabric. It will be difficult to achieve this and ensure that the buildings remain true to their architectural heritage.
Consideration must be given to the energy efficiency of the buildings, particularly in relation to the double height elevation in parts of the Heath Barn buildings and the wall insulation requirements. We understand there is a special dispensation exempting Grade II Listed buildings from needing an Energy Performance Certificate, however in order to make modern homes which are comfortable and habitable through all seasons, there would be an expectation that the buildings meet the requirements of Part L: Conservation of fuel and power of The Building Regulations (2021 edition) for adequate thermal performance. Achieving this would have a major impact on the external and internal spaces of the buildings.
Additionally, with the current arrangement of the buildings and their age, many adjustments would be required under Part K: Protection from falling, collision and impact. This is particularly important in relation to the opening of external windows and doors, due to the proximity of the external wall to the pavement, and therefore, passing pedestrians. Other considerations include the suitability of staircases, steps and doorways in a building largely constructed in the 16th Century. It would also be essential to ensure that the proposed residential development meets all the requirements of Part M: Access to and use of buildings, particularly in relation to approach, private entrances and spaces and ensuring that the dwellings are accessible, adaptable and suitable for wheelchair users.
All of the above considerations and restrictions preclude a straightforward and low-cost renovation of these traditional farm buildings to a comfortable and sustainable residential development. Furthermore, as previously detailed, the extensive alterations would undermine the historical and architectural integrity of the entire site.
Objections in relation to local policies
The Dacorum Borough Council Adopted Core Strategy (2013) balances ‘the need for new development and infrastructure against the need to maintain the environmental and unique character of the borough’. There are several areas which are relevant to the potential benefits that an alternative community initiative within the buildings would bring. In essence, were the residential development to proceed, there would be extensive missed opportunities to bring positive change to our town. Some of these areas are outlined below.
Conserving the historic environment for the community
Paragraph 17.3 of the Adopted Core Strategy states that: ‘All heritage assets are important and should be conserved’. Paragraph 17.4 details how ‘historic features add tradition, continuity and character to a place, as well as being an asset for the economy, the environment and the wider community’. It acknowledges that ‘the promotion of cultural heritage and tourism, associated with historic places, is a driver of economic development’ (See also section on Business below). The Adopted Core Strategy Policy CS27: Quality of the Historic Environment states that: ‘All development will favour the conservation of heritage assets’ and ‘The integrity, setting and distinctiveness of designated … heritage assets will be protected, conserved and if appropriate enhanced’. The proposal to convert the Heath Barn site into residential dwellings completely contradicts these considerations and explicit policy, and ignores the potential benefits. However, a community asset, offering a wide range of services for the local population, would indeed fulfill the aspirational possibilities given in Paragraph 17.4, and more.
Business
Paragraph 11.7 of the Adopted Core Strategy states that substantial employment growth will be planned by ‘creating a more attractive and vital town centre, that makes best use of further regeneration and redevelopment opportunities’. Additionally, Theme 2 of Shaping the Future of Dacorum: Our Growth and Infrastructure Strategy to 2050, outlines how Dacorum plans to ‘Generate a vibrant economy with opportunities for all’. Of particular note is the intention to ‘Create a supportive environment to help emerging sectors and to help businesses to locate and develop new ventures’. The NPPF Section 6 Paragraph 85 states that decisions in relation to planning ‘should help create the conditions in which businesses can invest, expand and adapt’. Also highlighted are the importance of supporting economic growth and productivity and taking account of local business needs. The proposed housing development effectively removes the possibility of any future business opportunities within these important historic buildings. The Heath Barn site is an ideal space to develop a hub for local, independent businesses and organisations to work and collaborate, providing a variety of services to the community. There would also be potential to use areas within the buildings for office rentals, co-working spaces and meeting rooms. A dual-purpose community and business initiative would also offer many opportunities for employment. The buildings are also uniquely placed in an area of high pedestrian traffic and their proximity to other community spaces would enhance the frequency of use and the long-term viability of the space as a community asset.
Health and wellbeing
Paragraph 15.2 of the Adopted Core Strategy states that ‘The Dacorum Sustainable Community Strategy aspires to improve community wellbeing…’. Paragraph 15.4 acknowledges that multipurpose use for social infrastructure facilities is preferable if possible. Crucially, Paragraph 15.15 outlines that there is a ‘need to improve existing community facilities and consider further provision of both facilities and services…primarily for young people and the elderly’. Paragraph 15.24 describes the ‘wide range of benefits in providing and promoting a variety of cultural activities and facilities’, including: improving wellbeing, enriching quality of life, conserving cultural and historic heritage, improving mental and physical health, providing social benefits (particularly for groups at risk of exclusion) and supporting citizenship and community identity. The Adopted Core Strategy Policy CS23: Social Infrastructure states that: ‘Social infrastructure providing services and facilities to the community will be encouraged’.
Furthermore, Section 8 of the NPPF (Promoting healthy and safe communities) states that decisions in relation to planning ‘should aim to achieve healthy, inclusive and safe places’. The proposed housing development would prevent the future use of the Heath Barn for the community, therefore missing opportunities for firstly, the promotion of social interaction (Section 8 Paragraph 96a) and secondly, enabling and supporting healthy lifestyles (Section 8 Paragraph 96c). Paragraph 96c highlights that this is especially relevant where this would address identified local health and wellbeing needs, which could certainly be provided for within a multi-purpose community initiative.
In conclusion, I urge you to consider these objections carefully and take into account the views of local residents as demonstrated by the following data:
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A Facebook poll hosted on the Boxmoor Councillor’s page found that over 92% of more than 1000 respondents were in support of the Heath Barn site being used as a community asset.
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A recent survey carried out by the ‘Our Heath Barn’ team received over 500 responses from local residents. Some of the key findings were:
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91% did not think that the Heath Barn buildings would convert well to five or more private dwellings.
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95% thought it would be better to restore the Heath Barn site for community use, rather than develop it for housing.
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97% would welcome an inclusive community hub in Boxmoor, with a focus on the arts and wellbeing; and supporting local, independent businesses.
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Since conducting the survey, Our Heath Barn has heard from ten businesses who are keen to collaborate to form a community initiative within the buildings. Several more have expressed an interest.
It is clear, therefore, that there is a great strength of feeling among many of the residents of Boxmoor and Hemel Hempstead that the Heath Barn and Cottage site should be developed for community use and for the benefit of all. Should the planning application for residential dwellings be successful, the community will continue to explore options for appealing this decision.
It is the responsibility of our elected representatives to preserve buildings deemed of national historic importance. These buildings have been Listed for the current communities of Boxmoor and Hemel Hempstead and for future generations. The importance of the Listing by Historic England should not be underestimated. As outlined in the NPPF, the architectural, social and cultural value of a heritage asset such as the Heath Barn site is extremely high. These are historically significant buildings, and as such, they deserve to be preserved and available to all residents of the local community and beyond. Many thanks for your time and consideration.
Yours faithfully,
Full Name