RESCUE
The British Archaeological Trust
15a Bull Plain, Hertford,
Hertfordshire SG14 1DX
Telephone: 01992-553377
rescue@rescue-archaeology.freeserve.co.uk
http://www.rescue-archaeology.org.uk
Stephen Hissett
Planning Officer
London Borough of Hounslow
Civic Centre
Lampton Road
Hounslow
TW3 4DN
29th May 2015
Dear Mr. Hissett,
BRENT LEA RECREATION GROUND LONDON ROAD ISLEWORTH LONDON TW8 8JD
Erection of temporary school buildings with provision of children's covered play area
Application number P/2015/1467, 00707/AK/P1
Re: Archaeology
I am writing to you to register an OBJECTION to this application, on behalf of RESCUE The British Archaeological Trust. RESCUE is a non-political organisation dedicated to
supporting archaeology and archaeologists in Britain and abroad. We do not receive any
state support and are entirely dependent on the contributions of our members to support
our work. Details of our activities can be found on our website; www.rescuearchaeology.org.uk
The application seeks to establish a number of low-impact temporary school buildings on
what is currently an open recreation ground. In addition however due to future works
outlined within the proposals, it is clear that the application also seeks to establish the
principle of change of use and development on the site, with a series of school buildings
outlined to be constructed adjacent to temporary accommodation the within the two-year
timescale of this application.
The site falls within a designated Archaeological Priority Area (APA), and there are
numerous archaeological remains recorded locally. Of principal note, the London Road to
the north-west formed the main Roman route between London and Silchester, with ribbon
development being known along its length in the Brentford area. In 2002, excavations at
107 London Road (the former Park Tavern) revealed significant Roman remains relating to
such activity, with “strong evidence” for occupation of the area during the period C.AD 70200. The results of this investigation also indicated that such evidence almost certainly
extended beyond the rear of that site, into the Brent Lea Recreation Ground which is the
subject of this current application. Prehistoric and post-medieval material was also
recovered from these investigations, suggesting a high potential for remains from a number
of periods exist in the specific area - a suggestion that is entirely consistent with the
archaeological designation.
The National Planning Policy Framework (NPPF) is explicit that in submitting an application,
it is the obligation of the applicant to describe the significance of any heritage assets that
might be affected (Paragraph 128), and that the Local Authority has an obligation to assess
Help save the past for the future
this significance against the application using the appropriate expert advice (Paragraph
129). Where heritage assets might be of archaeological interest, the NPPF is also clear that
this assessment should take the form of desk-based research and field evaluation where
necessary. This national requirement is reflected in both the saved Hounslow Borough
2003 Unitary Development Plan (policy ENV-B.3.2, Sites of Archaeological Importance),
and in the emerging Local Plan that will replace it (policy CC4, Heritage), which make
identical requirements for the applicant to submit archaeological written assessment and
the results of field evaluation as appropriate, when development within an APA is proposed.
As the site is within an APA, and the principle of establishing a school permanently on this
site is being determined, it is clear that this application should have been accompanied by
the required archaeological information, produced and supplied by the applicant. This
information should also have been made available to the Borough archaeological advisors
(the Greater London Archaeological Advisory Service based in Historic England) to enable
the appropriate independent scrutiny of the material to be carried out and an informed
determination of the proposals to be made. As no such information has been produced and
the necessary scrutiny has not occurred, the application does not comply with either
national or local planning policy.
The possible archaeological resource on this site is consequently under threat as a result of
these proposals and RESCUE wishes to register an objection to this application proceeding
in its current incomplete form. We would request that the application should be either
deferred until such time as the necessary information is produced and made available, or
more appropriately refused on the basis of being an inadequate submission.
Yours sincerely,
Reuben Thorpe,
Chair,
RESCUE: The British Archaeological Trust
Cc:
Cllr. Steve Curren – LBH Leader of the Council
Cllr. Bob Whatley – Chair, LBH Planning Committee
Cllr. Elizabeth Patricia Hughes – Vice Chair, LBH Planning Committee
Gillian King – Archaeological Advisor, GLAAS
Help save the past for the future