When Councillor George Crane said, at the recent meeting of Brent's Executive, that the Victorian library building had "no significance", he said it for a reason. He will be pleased that his comment has been widely reported, because that is the message he wants to get across, particularly to his colleagues on the Planning Committee. "Significance" will be a key factor when the planning application for the new Cultural Centre and the application for Conservation Area Consent to demolish the 1894 library building are considered.
Since March 2012, the official guidance for all planning matters has been the Government's new National Planning Policy Framework. It's Glossary includes the following definition:
Significance (for heritage policy): The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting.
The definitions also mean that the locally listed 1894 library building is a "Heritage Asset", and the Willesden Green Conservation Area is a "Designated Heritage Asset" for the purposes of NPPF.
When considering the impact of a proposed development, NPPF says that the applicant must 'describe the significance of any heritage assets affected'. The higher the heritage asset's significance, the stronger the case for conserving it, or refusing consent for the 'substantial harm or total loss of [its] significance' (i.e. its demolition!). From the point of view of the Council and Galliford Try, the lower they can make the significance of the 1894 library building and Willesden Green Conservation Area appear, the more chance they have of getting their proposals approved. So when Cllr. Crane says that the building has "no significance", or Beth Kay (Regeneration Officer) tells the Willesden ACF meeting (with several members of the Planning Committee present) that because of substantial alterations made to the original library building 'it does not retain significant architectural value', they are already preparing the ground to get the decision they want.
In our objection letters (I will be writing two, one for the planning application and one specifically for the conservation area consent application, which I hope will be considered separately on its own facts and law) we will need to get across the fact that both the Willesden Green Conservation Area and the locally listed 1894 Willesden Green Library building do have real value, and therefore a high significance for the purposes of consideration under NPPF. Here are some points worth making, but I am sure that campaigners can think of others which reflect their particular views:
that as well as the front of the old library being a beautiful architectural building in its own right (with the 'substantial alterations' made in the 1980's being what was necessary to retain that highly valued frontage when later extensions to it were removed) it is an important landmark building and an integral part of a group of late Victorian buildings which form the core of the Willesden Green Conservation Area;
that the 1894 library building makes a positive contribution to the character of the area;
that the 1894 library building played a key part in the social history of the area, and rather than knocking it down, it could be conserved and put to viable use as part of the new Cultural Centre (which will contain Brent's Museum and Archives) thereby enhancing its significance;
and if this appears to be the case when you look at the application documents:- that the Conservation Statement tries mislead the reader by understating the significance of the 1894 Library Building and/or the Willesden Green Conservation Area (giving at least one example).
The NPPF says (in para.132) 'Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification.' That is a good starting point for our fight to save the 1894 library building, but only if as many people as possible make the case that it, and the conservation area it stands in, do have real value and significance. If you would like to read the full National Planning Policy Framework guidance on "Conserving and enhancing the historic environment" (which replaced Planning Policy Statement 5 at the end of March), I have copied and pasted this section of NPPF and the relevant definitions from the Glossary into the 4-page pdf below.