Planning Committee
Thanet District Council
Cecil Square
Margate
Kent
CT9 1XZ12 October 2011
Dear Members
PLANNING APPLICATION REFERENCE NUMBER F/TH/10/1061 (ARLINGTON HOUSE & 1-50
ARLINGTON SQUARE, MARGATE CT9 1XP)
We understand that members are being updated on the application to build a 7,565
square metre superstore on top of the existing multi-storey Arlington car park
in light of the recent upgrading of the listing status of the Scenic Railway. We
are writing to formally object to the proposed plans on the grounds of the
impact the development will have on the setting of Dreamland site’s suite of
heritage assets: the recently upgraded Grade II* listed Scenic Railway, the
Grade II* Cinema building, and the Grade II listed menagerie cages and we are
also concerned about the potential harm to the fabric of the menagerie cages.
The proposed superstore is too big for the site. The metal-clad back wall of the
superstore will dwarf Dreamland’s heritage assets, providing an overbearing and
inappropriate backdrop to the group of listed structures and the landscaped
amusement park that is being rebuilt around them.
We also question Dr Chris Miele’s report, Expert opinion on the proposed
redevelopment of Arlington House and the effect on Heritage Assets, commissioned
by Thanet District Council and (we understand) funded by the developers.
We consider Dr Miele’s report to be biased and factually inaccurate, and we
question why the Council described the report in a recent press release as
“independent”. For this report to be truly independent there needs to be
evidence that there are no conflicts of interest.
Evidence that the report is not being written objectively can be found even in
the introductory paragraphs, where he states at paragraph 1.12:
“The application site is in the setting of the following listed buildings which
I have considered: the Grade II* Dreamland Cinema, Grade II animal cages and
menagerie and the Scenic Railway already mentioned, now graded II*. The
application site has been excluded from the Margate Conservation Area. Their
exclusion from it is noteworthy and reflects, I assume, the degraded immediate
setting of the listed structure and the menagerie/cages.”
His reference to “the application site” here should be to the Arlington site,
but the following sentence states “their exclusion from it”, which suggests he
is actually referring to the listed structures. If that is the case (and really
he needs to explain which he is referring to), there can be no justification for
stating that it is “noteworthy” that the structures are outside the conservation
area and that the “degraded” setting may have contributed to it, unless he is
laying the foundations for a report that is going to be diminishing their
importance. In addition, he should have been aware that the conservation area
was defined in 1997 when Dreamland was operating.
He also has not considered the potential for damage to the animal enclosures
anywhere in his report. At first glance, he may have excluded this thinking that
it had no relationship to the upgrading of the Scenic Railway. But damage to the
enclosures, that could result in their partial or complete loss or damage, would
undermine the Scenic Railway due to its strong connection to the enclosures (see
3.30 for his understanding of these functional and historic relationships).
The 18TH-century Gothick wall supporting the menagerie cages and cottage
abutting the Arlington car park are fragile structures and building works may
jeopardise their integrity. The Prince’s Regeneration Trust’s Conservation
Management Plan (2010) describes the wall as being in a very precarious
condition; the cages in an unstable state and currently substantially held up by
temporary propping. The lintels appear to have failed completely in the smaller
cages with the triple arch head to the largest cage being dependent on propping.
In 3.31 Dr Miele incorrectly suggests that English Heritage did not give great
weight to the setting of the Scenic Railway because it is degraded and no longer
functional (in fact, he states its setting is “lost”). He is obviously not aware
of the fact that the park is to be rebuilt and that English Heritage has been
involved in this project so is fully aware of it. This point significantly
undermines his report and we would ask that he review his statement in the
knowledge that the functional/historic setting of the Scenic Railway is not
lost. This theme runs all the way through the report and we believe materially
affects his overall conclusions.
He also mixes up his ‘wests’ and his ‘easts’, suggesting a lack of understanding
of the site’s context (e.g. 4.18, 4.21).
His conclusions on rarity in 4.29 are completely wrong, again demonstrating that
he was not properly briefed on our plans and seemingly unaware that English
Heritage has been closely involved.
4.21 is wrong. The land to the east of the Scenic was always part and parcel of
the Dreamland land holding and these views should be treated with equal
importance (albeit part of it was leased to Margate FC for a few years at the
time that the Scenic Railway was erected).
His second point in 4.22 is technically correct, but again does not take account
of the development that will reinstate the Scenic’s original setting. Regarding
his third point, the Scenic’s setting will be mediated by landscape in the
future, but that landscape would not disguise the overbearing appearance of the
rear of the shed. In 4.23 he admits he has not seen our landscape proposals, but
he could have seen them on the Dreamland Margate website (www.dreamlandmargate.com)
and in the Sea Change documentation. The Council should also have made him aware
of this when he was briefed.
4.31 to 4.33 is very weak and almost doesn’t consider the effects of the new
building at all, other than saying it is not actually on the site. It is in this
section of his analysis that we would have expected to see some acknowledgement
of impact.
Throughout the next few paragraphs he again relies continuously on the fact that
the setting has been compromised (4.38 is yet another example of this).
In 5.2, we are not sure how his report allows him to conclude that the new
building will not intrude on the aesthetic appreciation of the structure. Dr
Miele appears to completely misunderstand the aesthetics of the Scenic Railway.
He refers to the technical and engineering aesthetic of the Scenic Railway as
seen from an observer’s perspective. He does not discuss the aesthetics of
riding the Scenic Railway from a passenger’s perspective and that is the point –
the roller coaster is called the Scenic Railway because of the vista from the
train, which is the unique selling point of the ride.
The scenery around the Scenic Railway is a fundamental part of the ride. Our
Stage 2 application to the Heritage Lottery Fund describes the full restoration
the Scenic Railway to its former working glory. If we are going to invite
visitors to pay to ride the fully restored Scenic Railway to its former glory
then we will be peddling a lie. Additionally, Thanet District Council’s
application to the DCMS Sea Change fund for the reinstatement of Dreamland was
granted with the condition that landscape architects led the project. Landscape
is at the heart of the Dreamland project.
It is abundantly clear that the proposed large-scale superstore will have an
adverse impact on the overall aesthetic of the park, its landscaped gardens and
picnic areas. It puts at risk the Grade II listed menagerie cages, gothick wall
and cottage and compromises the setting of the Grade II* Scenic Railway. This
development will ultimately degrade the visitor experience.
We would also like to point out that it is the local authority’s stated aim to
improve the setting of Dreamland’s listed structures and allowing this structure
on the boundary of the site is directly contradictory to that aim.
Yours faithfully
Nick Laister
Chairman
For and on behalf of The Dreamland Trust
Cc Alan Byrne, Historic Buildings and Planning Advisor, English Heritage
Tom Foxall, Historic Buildings Inspector, English Heritage
Cherry Aplin, Assistant Planning Manager, TDC