GROUNDS OF APPEAL
Against the refusal of
PLANNING PERMISSION
and
LISTED BUILDINGS CONSENT
For a
Single storey extension
LPA Ref: PP/14/08978 & LB/14/08979
&
For a
Two storey extension
LPA Ref: PP/14/08981 & LB/14/08982
at
26 Chesham Place
London SW1X 8HH
INSPECTORATE Ref: -Appellant: Mr Sergey Kovanda
Architect: Project Orange
Appeal Agent: Richard Anstis
Pryor House, East Hanney, Wantage, OX12 0HU
07908 67 33 67 richard@nstis.com
DATE: April 2015
CONTENTS
1.0
INTRODUCTION
2.0
COMMON GROUND
3.0
MATTERS IN DISPUTE
4.0
CONCLUSION
APPENDICES
Appendix I
Addendum to the Heritage Advice - the proposal and decision
(Mark Strawbridge of MOLA)
1.0
INTRODUCTION
1.1
This document is a combined submission for four appeals. If the appeals are
not conjoined, then this document should be taken as being submitted for each
of the separated appeals.
1.2
This document is a combined submission of both the Grounds of Appeal and
Statement and Proof for all four and each of the appeals.
2.0
COMMON GROUND
2.1
No formal statement has been agreed by the LPA.
3.0
MATTERS IN DISPUTE
3.1
PP/14/08978 & PP/14/08981 both shared a single refusal reason:
The proposed extension, by reason of its position, bulk and full width nature,
would harm the special architectural and historic interest and heritage
significance of this Grade II listed building, would harm the original form and
integrity of the host building and would neither preserve nor enhance the
character or appearance of the conservation area. As such, the proposal fails
to comply with Core Strategy Policies CL1, CL2, CL3, CL4, CL9 and CL11
and guidance contained within the NPPF.
3.2
LBC/14/08979 & LBC/14/08982 both shared a single refusal reason:
The proposed extension, by reason of its position, bulk and full width nature,
would harm the special architectural and historic interest and heritage
significance of this Grade II listed building and would harm the original form
and integrity of the host building. As such, the proposal fails to comply with
Core Strategy Policy CL4 and guidance contained within the NPPF.
3.3
The first section of the singular reason for refusal in all four decision notices is
therefore identical, albeit with different policy references and with the
planning application refusals also considering the impact on the Conservation
Area. This statement will therefore address all four refusal reasons as one. The
appellant does not accept any element of the refusal reason in all four cases.
3.4
Appended to this statement is an addendum to the heritage advice that
accompanied the application. The addendum by Mark Strawbridge of MOLA
examines both the proposals and the reason for refusal of each. This second
heritage expert concurs with the first heritage expert Francis Maude of Donald
Insall Associates (whose report was submitted with the applications) in
concluding that neither proposal will harm the interest, significance, form or
integrity of the existing building and both would preserve or enhance the
character or appearance of the Conservation Area.
3.5
Indeed, Mr Strawbridge concludes that the impact will be Minor and Positive,
both for the building and for the Conservation Area.
4.0
CONCLUSION
4.1
Patently, two heritage experts disagree with the LPA officer on every aspect of
the decision.
4.2
The history of consents for changes to this building are highly relevant and are
listed in the Addendum (the LPA is to provide copies of each to assist the
inspector).
4.3
The impact of both the proposed single storey and the proposed two storey
extensions are considered minor and positive to both the Listed building and
the Conservation Area.
4.4
All four applications should have been approved.
APPENDIX I
ADDENDUM TO HERITAGE ADVICE