Objection to new Maltings application 25/00792/CCD: Part demolition, alterations and extension to existing theatre and other ancillary works Julian Smart, 9 Quay Walls, Berwick, TD15 1HB I object to the planning application 25/00792/CCD on the following grounds: 1. Substantial and unjustifiable harm to a conservation area and iconic historic setting. 2. Harm to Berwick's tourist trade and its own residents. 3. Lack of justification for the intrusive signage. 4. The problems that a flat roof will cause via increased seagull activity in the centre of Berwick. DETAILS 1. Substantial and unjustifiable harm to a conservation area and iconic historic setting. The application's Heritage Statement admits that harm will be done to the conservation area. This harm could have been mitigated or entirely avoided - even enhancing the conservation area - with different design choices. The rear facade of this tall, flat-roofed modernist building will loom ominously over central Berwick, totally out of place amongst the smaller buildings and terracotta pantile or grey slate roofs that have been much admired over the years. The applicant asserts that dividing the building's mass up, the choice of texture and materials, and the building's "high-quality contemporary design" (a highly subjective characterisation) mitigates the impact on the surroundings. This mitigation is totally inadequate. The sheer mass of the building remains incongruous in its position, the large unframed windows remain extremely out of place amongst Berwick's traditional windows, and the flat roofs jar amongst the almost exclusively pitched neighbouring roofs. The introduction of pitched roofs for small ancillary buildings is billed as 'playful' but with the pitch of one being in the wrong direction, it comes across as silly and making a mockery of the contentious roof issue. The machinery on the roof may be visible from some vantage points - in a meeting with CAAG, the architect could not guarantee this would not be case. Views from many angles are severely damaged. Looking from the Quay Walls past the Granary, most of the view of the Town Hall's clock tower is obliterated. The much-loved view from the Old Bridge to the town and Quay Walls is ruined, as the eye is drawn to the monster building and away from the historic setting that is such a draw for visitors and residents alike. The view from Union Brae, currently another splendid vista taking in the Old Bridge and part of the Quay Walls, will be utterly dominated by the new Maltings. An exceptional design would have provided some justification for the change. But this boxy, utilitarianism building is simply an intrusion into a delightful setting, and does not make a positive contribution to our skyline. The argument that the new Maltings will hide the ugly Sports Direct building is extremely weak, as that building is still visible from many angles - and two wrongs do not make a right. The argument does not take into account the possibility of other ways to mitigate the poor aesthetics of the Sports Direct building. The provided 'visualisations' from Dock Road, Sandstell Road Car Park and Meg's Mount are wholly inadequate and misleading. Initially three pairs of identical photographs with no sign of the new Maltings, they have now been hastily annotated with faint red outlines of the building following a complaint. The photographs, lacking detail and in some cases seemingly taken through the wrong end of a telescope, do not represent how people will see the Maltings from these perspectives. The visualisations cannot therefore be said to offer a fair opportunity to see how the new buildings will affect views. The architect said he would try to get visualisations from the Royal Border Bridge, especially given the Borderlands desire for the building to be a beacon visible from the train, but these have not materialised and further undermine the ability of the public and consultees to evaluate the plan. The unsympathetic and intrusive aesthetics of the building will be exacerbated by any required netting to solve one of the problems the flat roof introduces - birds (see objection [4] below). As well as the immediate harms, the building would constitute a dangerous precedent for the future, opening the door for further unsympathetic buildings further eroding the conservation area. In weighing up the heritage harm done with the potential benefits, the application seeks to minimize the harm ("high-quality contemporary design", materials, articulation) while bigging up the benefits through assertions unaccompanied by a business plan. The business case relies on residents spending twice as much as before at the Maltings in increasingly difficult economic circumstances. There is little room for error if projected footfall fails to materialise, and there is the risk that in overreaching, the building will become an albatross around the taxpayer's neck. Figures for knock-on employment are plucked from the air without evidence and cannot be taken seriously. No clear evidence of enhanced programming is given, nor is there any indication of how increased footfall will be accomplished through marketing. Furthermore, the benefits are merely incremental since the Maltings already operates at multiple sites. In short, the application has not justified the destruction of heritage and potential loss in tourist revenue against the plan's benefits. The application contravenes National Planning Policy Framework (NPPF) para. 200 by failing to preserve the conservation area's significance. The application contravenes numerous parts of the Northumberland Local Plan (NLP), for example: QOP1 (b) Create or contribute to a strong sense of place and integrate the built form of the development with the site overall, and the wider local area, having particular regard to: i. Building heights; ii. The form, scale and massing, prevailing around the site; ... vi. distinctive local architectural styles, detailing and materials; QOP1 (c) Be visually attractive and incorporate high quality materials and detailing; QOP1 (d) Respect and enhance the natural, developed and historic environment, including heritage, environmental and ecological assets, and any significant views or landscape setting. The design also contradicts Historic England's 2022 letter to the NCC/Advance/the Maltings Trust (from a Freedom of Information request and reproduced on www.berwick-heritage.co.uk/faq_maltings#historicengland), urging restraint: "My feeling is that the brief would be strengthened if it could avoid the use of the word landmark, and with it the desire to maximise views, and particularly the requirement for the building to be clearly visible from the railway bridge as an architectural beacon. Our major concern is how the building would relate to the intricate townscape of the historic core of Berwick, and key buildings such as the town hall mentioned above. Several different approaches are available to this site which could produce a successful design. To us this is not about a need to avoid architecture with a strong visual identity, but it is about working within the historic character and context of the town. The aspirations for a landmark building and visibility from a distance could end up working against this context, so we would very much like to work positively with you to help develop an approach and design which avoids this." Given the building's flat roof, a lack of coherent architectural detailing in keeping with its setting, and its crass signage with the self-evident intention of 'visibility from a distance', the design goes against this initial advice, despite Historic England's later involvement as a consultee. 2. Harm to Berwick's tourist trade and its own residents. Berwick's tourist trade is largely dependent on the town's relatively unspoilt beauty and views of scenes containing traditional buildings to attract visitors. This attraction absolutely depends on the absence of clashing architecture. If the enjoyment of Berwick is damaged, there will obviously be less incentive for tourists to come and enjoy Berwick and spend money in the town - including at the Maltings. Historic England's 'Heritage Counts' initiative has looked at the link between wellbeing and heritage visits, with research calculating the impact of heritage on wellbeing as being worth on average £1,646 to each 'heritage participant' per year (in 2014). This is the amount of money that would need to be taken away from a person to reduce their wellbeing to the state before heritage participation. This backs up our common-sense notion that beautiful places are good for us. Therefore, harming Berwick's heritage harms both visitors and residents - many of whom live in Berwick because of its heritage. The effect on the town's heritage and consequently on people's wellbeing is cumulative. Developments such as Pets at Home, the new hospital, planned buildings adjacent to the Ramparts and Ness Street, and now this proposal, all combine to create significant harm to the place, its people, and its visitors. Do we want to develop a reputation for ruining our own heritage? This will benefit neither business nor the town's morale. 3. Lack of justification for the intrusive signage. The large MALTINGS signs on all four sides of the proposed building has no place in a conservation area, or in such a sensitive, raised position within Berwick. Crass promotion of this kind is unnecessary and should take a back seat to preservation of the Berwick skyline and conservation area. Other methods of promotion can be found. The report 'Tweed & Silk: A Public Realm Strategy for Berwick-upon-Tweed' (2011) notes: "A key problem is that currently the traditional streets are often spoiled by clutter such as signs, painted lines and inappropriate furniture, much like a lovely old tweed jacket covered in stains and badges." The new Maltings signage will add to that visual clutter and detract from enjoyment of the historic setting. 4. The problems that a flat roof will cause via increased seagull activity in the centre of Berwick. The flat roof design will exacerbate bird problems within the town. As well as causing an ongoing burden on the taxpayer tackling roosting birds, seagulls carry diseases, and an increase in their droppings in the centre of town may impact local quality of life and tourism. The problem can be observed from the Ramparts near the hospital, looking towards the roof of the B&M store. Any mitigation is likely to be unsightly (see the nets on the flat roof areas of Morrisons), and add to the harm to the historic roofscape. The applicant must have a strategy in place for dealing with this consequence of the flat roof design: due to the sensitivity of the location, the application cannot be considered complete without this. CONCLUSION The most serious impact of the development would be substantial and unjustifiable harm to Berwick's conservation area and its historic setting. The effect of this would be the own goal of harming Berwick's tourist trade and the wellbeing of its own residents. In addition, there is no justification for the extraordinarily inappropriate proposed signage. And the flat roof will exacerbate the problems Berwick already faces with seagull nuisance. All these considerable harms point to the necessity for rejecting this application.