. THeritage Impact Assessment for
LAND ADJ. 3 STATION ROAD
SOUTHWOLD IP18 6AX
For Southwold Town Council
Cover photo: Ariel view of the site
National Grid Reference: 650482 – 276601
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1.1 Bob Kindred Heritage Consultants were commissioned by Ingleton Wood LLP on behalf
of Southwold Town Council to undertake a Heritage Impact Assessment [HIA] for land
adjacent to 3-9 Station Road, and Blyth Road, Southwold IP18 6AX in accordance with the
National Planning Policy Framework [NPPF] in support of proposals for the erection of two
buildings comprising a general store and two other shop units, seven office units and two,
one-bed flats with a central courtyard.
1.2 It is understood form Ingleton Wood LLP that the Council has confirmed that the site is
situated within the Southwold Conservation Area as shown on the most recent Local Plan
policies map not withstanding that it is shown as outside the conservation area on the
boundary map printed in the District Council’s Conservation Area Character Appraisal
currently displayed on the Council’s website.
1.3 This is a regrettable potential cause for confusion, not least in complying with the
statutory duties in heritage legislation and national planning policy but also as a
benchmark for assessing proposals on the character ands appearance of conservation
areas. This HIA is therefore based on the premise that in regard to the extent of the
designated area it is the Local Plan policies map and not the Conservation Area Character
Appraisal that is correct.
1.4 There are no other designated or undesignated heritage assets in the immediate
vicinity. This Assessment therefore addresses the impact of the proposals on the setting of
the conservation area and the local townscape.
1.5 The scheme proposals are as set out in the Design and Access Statement and
associated application drawings by Ingleton Wood LLP and other supporting
documentation to which this Heritage Impact Assessment should be cross-referred.
1.6 An inspection of the site and the immediate surroundings to assess the impact of the
proposals and was undertaken on 26th
1.7 This report may be deposited with Suffolk Historic Environment Record and a copy sent
to the National Monuments Record maintained by Historic England if required.
Fig.1 Location Plan Not to scale
The law relating to conservation areas is enshrined in the Planning (Listed Buildings and
Conservation Areas) Act 1990. This places a duty on local planning authorities to pay
special attention to the desirability of preserving or enhancing the character or
appearance of conservation areas (Section 72) and case law generally extends this to
consideration of their settings where sites are adjacent to conservation areas.
2.2 The Heritage Impact Assessment to accompany the proposals is intended to comply
with the requirements of NPPF paragraph 128. Applicants must describe the impact of
proposals on the significance of any heritage asset to a level of detail proportionate to the
assets’ importance. This should be no more than is sufficient to understand the potential of
that impact on the significance; and further, to assist under the terms of paragraph 129
with an assessment of the relationship between the preservation or enhancement of the
conservation area or its setting.
2.3 Paragraph 132 of the NPPF apportions great weight to a designated asset’s
conservation. The more important the asset, the greater the weight should be. The NPPF
asserts that significance can be harmed or lost by inappropriate change and that this
requires clear and convincing justification.
2.4 It is considered that the heritage implications of the proposals on the heritage
significance of the Southwold Conservation Area are minimal and where the NPPF states
that this will lead to ‘less than significant harm’, paragraph 134 requires the special interest
to be weighed against the public benefits, including securing optimum viable use. This will
be the responsibility of the District Council as local planning authority to determine.
2.5 The NPPF also attaches great importance to matters of design. Paragraph 17 sets out
twelve core planning principles, one of which is to ‘always seek to secure high quality
design and a good standard of amenity for all existing and future occupants of land and
2.6 Paragraph 58 states that planning ‘policies and decisions should aim to ensure that
developments are well designed’ and paragraph 60 states that planning policies and
decisions should not attempt to impose architectural styles or particular tastes and they
should not stifle innovation, originality or initiative through unsubstantiated requirements to
conform to certain development forms or styles - notwithstanding the desirability of
promoting or reinforcing local distinctiveness.
2.7 The NPPF defines criteria relating to the consideration of heritage assets in paragraph
131 as the basis on which the Council should determine applications. In this instance it is
considered that the proposal would be an environmental enhancement and positively
contribute to sustaining this part of Southwold and its economic and social vitality.
DESIGNATED & UNDESIGNATED HERITAGE ASSETS Introductory remarks
3.1 The distribution of the formal national heritage designations as defined on the National
Heritage List for England1, and undesignated heritage assets defined in the Southwold
Conservation Area Appraisal, relative to the proposed site on the corner of Station Road
with Blyth Road is shown in Figure 2.
Fig. 2 Distribution of heritage assets in the locality of the site
3.2 The locations of individual listed buildings is indicate in red, buildings of special local
interest in blue, the extent of the site of the proposals in pink, the conservation area as
defined in the conservation area character appraisal in green and the more extensive
conservation area shown on the Local Plan proposals map in yellow. Listed buildings
3.3 As will be noted from Figure 2 all the listed buildings shown in red are well to the south of
the site and face either east on Station Road or southwest on North Green. Their distance
from the site and orientation are such that it is considered that their setting would not be
affected in any way by the proposals and would also be entirely screened by the two-and-
a-half storey premises Nos. 3-9 Station Road (‘Hurren Terrace’) and other intervening
buildings or similar scale. Buildings of local interest
3.4 Buildings identified under the NPPF as constituting undesignated heritage assets are
shown in blue in Figure 2. These are defined in Appendix 3 of the Southwold Conservation
Area Appraisal as “Buildings that make a positive contribution to the Character of the
and are located in the more northerly part of the Seaside Suburban
Character Area and the northwesterly part of the adjacent Seaside Corporation Character
3.5 Those undesignated heritage assets closest to the site are the west-southwesterly facing
Nos.1-5 North Green. This short terraced group is well to the south of the site of the
proposed scheme (and would also be obscured by Nos. 3-9 Station Road and other
intervening buildings). No undesignated heritage assets have been identified for parts of
Southwold outside the conservation area.
1 The National Heritage List does not show the boundary of Conservation Areas as these are treated as a local y generated designation. The conservation area boundary is
shown in Fig.2
Southwold Conservation Area
3.6 As noted in Section 2, NPPF paragraph 128 expects an evaluation the impact of the
proposals on significance to a proportionate level of detail commensurate with the assets’
importance and the principal issues concern the effect of the proposals on the setting of
the conservation area.
3.7 The proposed site sits at the corner of Station Road with Blyth Road and incorporates a
mid 20th century single storey flat-roofed red brick general store to the corner, a large
utilitarian modern single storey commercial shed in two units facing Blyth Road (Fig. 3), and
two large modern single storey sheds in use as a motor garage to the rear of the site
overlooking allotments and the golf course to the west (Fig.4). None of these buildings are
considered to be of any special architectural interest or heritage significance.
Fig. 3 Blyth Road frontage
Fig. 4 View from golf course with two shed building to be demolished (centre) with The
Rope House [Haward Architects] (right)
3.8 Southwold Conservation Area was designated by East Suffolk County Council in 1971
and inherited by Waveney District Council at its inception in 1974. Local planning
authorities have a duty to review their conservation area designations from time to time,
and the original boundaries of the conservation area were revised and extended in 1991.
3.9 Policies for the built environment including the conservation area were set out in the
adopted Waveney District Local Plan of November 1996. The current Waveney Local Plan
Core Strategy setting out the vision, objectives, spatial strategy and core policies to guide
development until to 2021 (and 2025 for housing) includes Policy CS 17 under its Built
Environment chapter where the District Council states it will work with partners and the
community to protect and enhance the built and historic environment.
3.10 Proposals for development will be expected to conserve or enhance the character
and setting of conservation areas - including Southwold - and proposals assessed against
the relevant Conservation Area Appraisal [CAA] and Management Plan. In the case of
Southwold this was adopted as a Supplementary Planning Document in 2008 and
consequently paragraph 128 of the NPPF requires applicants to describe the impact of
proposals on its significance.
3.11 The purpose of a CAA should be to explain the reasons for designation, describe the
area, outline its particular qualities and character and highlight those issues needing to be
addressed in order to ensure the area’s preservation and enhancement. As a designated
heritage asset the policies in the NPPF apply to it.
3.12 The Southwold CAA has four principal objectives:
• to describe the character of the area;
• to identify its special character;
• to put forward a basis for effective policy
control of development; and,
• to identify proposals for its
3.13 Southwold Conservation Area is quite extensive and for the purposes of defining its
architectural and historic interest it has been sub-divided into five character sub-areas. The
part forming the Seaside Suburban Character Area is the one that comes closest to the
proposed site and in essence the area includes the northwest part of the town between
Station Road in the north and Mill Lane in the south on the west side of the High Street and
bounded by Southwold Common to west.
3.14 The Seaside Suburban Character Area is noted to be an area of mainly late 19th and
early 20th century residential development formed by large terraced or semi-detached
houses set back behind small front gardens enclosed by dwarf walls or hedges. It also
includes an area behind the High Street where former gardens and yards of the High Street
premises have been exploited for leisure, retail and residential use. The generally prevailing
scale is a domestic one of two or two-and-a-half storeys with small confined spaces and a
generally high building density.
3.15 The conservation area boundary near the proposed development shown in green and
yellow in Figure 2 runs northward from the centre of Southwold along the rear of the
properties on the west side of Station Road before turning east along the south side of Blyth
Road and across Station Road to the south side of Pier Avenue incorporating the Blyth
3.16 It should be noted that there appears to be a discrepancy concerning the extent of
the conservation area. The boundary as shown on the Local Plan proposals map dated
January 2012 is more extensive than that shown in Figure 27 (page 14) of the CAA dated
3.17 Furthermore, the latter does not precisely coincide with the area shown for the Seaside
Suburban Character Area (page 35) - where the most northerly four buildings on the east
side of Station Road are unaccountably omitted - although the overall conservation area
boundary indicated in red (shown on the map on page 35) is indicated as extending east
and south beyond the highlighted Character Area (which is thus appears to indicate it to
be smaller in extent).
3.18 As noted in 3.9 above, if proposals for development are expected to be assessed
against the relevant Conservation Area Appraisal [CAA] and Management Plan but there
is a discrepancy in the boundary between the two documents, the consequences of this
must be a recipe for confusion for applicants and planning officers alike.
3.19 Station Road is not specifically referred to in the CAA, which concentrates on the
merits of the listed and locally listed buildings and public spaces significantly further to the
south, particularly enclosing the landscaped triangle forming North Green.
3.20 No reference to any boundary extension is made in the CAA dated March 2008, and
which pre-dates the draft Local Plan by almost a decade.
BRIEF HISTORICAL PERSPECTIVE
4.1 Southwold, was badly damaged by fire in 1659 although enough earlier buildings
survive along the High Street and Market Place. The town was once a hamlet in the parish
of Reydon but became ecclesiastically independent of it in 1752. During the 18th and 19th
centuries the once-important harbor declined in significance in favour of Lowestoft and this
accentuated a locally perceived need for better tourism and trade.
4.2 The development of the present site may be said to be bound up to some extent with
the brief rise, decline and closure of the railway as the land in the vicinity of the present site
remained largely undeveloped until the end of the 19th century when building appears to
have been briefly stimulated by the arrival of the railway.
4.3 Transport links from Southwold to elsewhere in Suffolk were poor in the 19th century and
although the East Suffolk Railway had been built in the 1850s it had taken a westerly course
from Ipswich to Lowestoft via Halesworth and Darsham leaving Southwold 9 miles from the
line. As a once-daily horse-drawn omnibus service from Darsham was considered
inadequate but requests for a branch line had been refused, the Southwold Railway
Company was formed and after some local difficulty a narrow gauge line was completed
and Southwold Station opened on 24th September 1879.
4.4 The absence of development in the area of the present site is shown on the Twenty-Five
Inch Ordnance Survey Map of 1882 published 1881 (i.e. three years after the arrival of the
railway) Figure 5.
Fig. 5 Site as shown on the 1882 Twenty-Five Inch Ordnance Survey Map not reproduced to scale
4.5 By 1903 some development had extended northward from Southwold town centre
towards the railway station with the construction of a parade of shops (now Nos. 3-9 Station
Road) and the completion of the Station Hotel (now the Blyth Hotel) on the east side in
c.1900. The corner plot to Station Road and Blyth Road remained vacant at this date but
the small terrace of three much altered red brick cottages Nos. 1-3 Blyth Road2 (Stanley
Cottages) adjacent to the site, had been competed, and the beginnings of the Edwardian
(and later) expansion of Southwold is also evident with the laying out of new estate roads,
2 Stanley Cottages are something of a historical curiosity. They bear the name but also a cartouche of the head
and shoulders of a man in a helmet that is clearly recognisable as Sir Henry Morton Stanley, Welsh journalist and
explorer famous for his exploration of central Africa and his search for missionary and explorer David Livingstone
who Stanley final y located in November 1871. Stanley's reports on his expedition made his name. Livingstone died
in 1873 but Stanley continued to explore the region returning to Europe in 1890 and becoming MP for Lambeth
(1895 to 1900) Stanley died in London in May 1904 but it is not at al clear why three smal Southwold cottages
should be named after the explorer.
particularly Pier Avenue and St Edmunds Road as shown on the Twenty-Five Inch Ordnance
Survey Map of 1903 published 1904. (Fig. 6) The local settlement pattern remained almost
unchanged on the Twenty-Five Inch Ordnance Survey Map of 1925 published 1927 (not
Fig. 6 Site as shown on the 1903 Twenty-Five Inch Ordnance Survey Map not reproduced to scale
4.6 The railway line was plagued by ill-fortune particularly after the First World War and the
operation of motorbuses from outside Southwold in 1926 and within Southwold from 1928
could not save the line and it closed on April 11th April 1929.
4.7 No local Twenty-Five Inch Ordnance Survey map was produced after the third edition
of the 1925 but the Six Inch Ordnance Survey Map of 1947 published 1953 (Fig. 7) continued
to show the corner site on Station Road with Blyth Road as undeveloped and appears to
show a consolidation of outbuilding to the rear of Nos. 3-9 Station Road (but this may be
down to the mapping conventions of buildings at that smaller scale). The gradual
emergence of development (un-hatched and therefore possibly under construction or
only recently completed) can be seen in Pier Avenue and St Edmunds Road to the east.
Fig. 7 Site in 1947 Six Inch Ordnance Survey Map not reproduced to scale
BRIEF OUTLINE OF THE PROPOSALS
5.1 The rationale behind the design approach to the proposal as set out in the Design and
Access Statement and accompanying documentation by Ingleton Wood LLP to which this
assessment should be cross-referred. Consequently the scheme is only described in outline
5.2 The proposal is to redevelop utilitarian 20th century buildings at the corner of Station
Road and Blyth Road (Fig. 3) and two large light industrial sheds to the rear [overlooking
allotments and golf course] (Fig. 4) to form two new buildings with L
-shaped footprints that
loosely interlock around an intimate central courtyard space in conjunction with the rear of
Nos. 3-9 Station Road.
5.3 The new accommodation is intended to comprise in Building 1 a general store to the
corner of Station Road and Blyth Road with two further retail units on Blyth Road with two
office units above and a further ground floor office unit to the rear.
5.4 To the south of the site is a further building forming two parts. Building 2A forms a wing
oriented east west with a single storey element to provide a coffee shop and two-storey
element with two office units at ground floor and a one-bed flat at first floor. The western
arm of the L
-shaped Building 2B provides a further two office units at ground floor and a
one-bed flat at first floor.
5.5 On Station Road the existing road frontage slopes gently from south to north and the
adjacent two-and-a-half storey Edwardian shops (Nos. 3 -9 ‘Hurren Terrace’) step gently
down the slope towards Blyth Road. The new building to this frontage will be similarly
stepped with a slightly lower ridgeline than the existing buildings but with a near identical
eaves line. In Blyth Road the return frontage will be slightly lower in overall height to better
relate to the existing adjacent red brick cottages to the west. The new buildings to the rear
of the site would have a suppressed one-and-a-half storey scale which would provide an
interesting contrast to the rear of the taller recent The Rope House (Fig.4) to the south.
5.6 The central courtyard to the new development is intended to be accessible by
pedestrians from a passageway on Blyth Road adjacent to Nos.1-3 (‘Stanley Cottages’)
and from a carriageway arch entranceway through the centre of Nos. 3-9 Station Road
TOWNSCAPE & SETTING CONSIDERATIONS
6.1 The NPPF requires the proponents of development proposals to evaluate the impact of
proposals on the setting of heritage assets considered likely to be affected by them. As
already noted, the location of the proposals ostensibly within the conservation area
requires such consideration.
6.2 Advice regarding the setting of heritage assets is set out in Historic England’s ‘Historic
Environment Good Practice Advice in Planning 3’ [GPA 3]
The aim is to assist in
implementing historic environment policy in the NPPF, but paragraph 10 (p.6) of GPA 3 also
states that the implications of development affecting the setting of heritage assets should
be considered on a case-by-case basis.
6.3 The NPPF makes it clear that the setting of a heritage asset is the surroundings in which a
heritage asset is experienced, its extent is
not always fixed and may make a positive or
negative contribution to significance or may be neutral in its effect and this may change
6.4 The NPPF expects a proportionate approach to be taken regarding the impact on
heritage assets and any assessment needs to be applied appropriately in relation to the
likely effect of the impact. Examination of the nature, extent and level of a heritage asset’s
significance are encouraged by GPA 3 but this should be considered proportionately as it
is recognizing that where proposals are not likely
to be prominent or intrusive the effects
on setting may often be limited to the immediate surroundings or negligible as is
considered to be the case here.
Setting of the conservation area
6.5 With regard to the setting of the conservation area, as noted and as shown in Figure 2
above, the conservation area as shown on the Local Plan policy map dated January 2012
incorporates the existing utilitarian single-storey buildings on the site and these are almost
entirely concealed by the two and two-and-a-half storey buildings fronting Station Street. As
the scale of the proposals are intended to be generally no greater than the existing buildings
it is therefore considered that the impact on the character and appearance of the
conservation area would be negligible. Townscape considerations
6.6 Southwold had only point of access via the Halesworth Road across Buss Creek and the
isolation from its surroundings is reinforced by the broad band of green space across the
waterway between the town and Reydon. As noted above the area to the south of the
Creek developed only towards the end of the 19th century with the arrival (and subsequent
demise) of the railway line and later in the first half of the 20th century by suburban housing in
streets such as Pier Avenue.
6.7 The 1961 edition of ‘Pevsner’s Suffolk; East4 described as Southwold as: “one of the
happiest and most picturesque seaside towns in England, but not cheerful in the cheerio
sense, and picturesque, but not in the quaint sense of Clovelly” but the present approach
over Buss Creek is drearily banal. The environs of the site
6.8 Although new development is presently under early construction between North Road
and Pier Avenue, the approach to the town is not worthy of the virtues ascribed to it by
Pevsner. To the northeast corner of Pier Avenue is a dispiritingly functional two-storey flat
roofed telephone exchange (Fig.8), while on the west side of Station Road is an equally
prosaic single-storey flat roofed police station. (Fig.9) Both buildings date from the last third
of the 20th century and appear typical of the work of the unlamented and long disbanded
3 Published by English Heritage in March 2015 and re-published by Historic England July 2015
4 Pevsner Architectural Guides, James Bettley & Nikolaus Pevsner  p. 514
Public Service Agency architects’ department. Neither building could be described as
promoting or reinforcing local distinctiveness.
Fig. 8 Southwold Police Station seen from the Blyth Rd frontage
Fig. 9 Telephone exchange and Blyth Hotel adjacent northeast to the site
6.9 The Blyth Hotel (the former Station Hotel) of c.1900 to the southeast corner of Pier Avenue
provides the only distinctive visual presence but is in need of some external maintenance.
This building is the work of a local architect, Thomas Edward Key5 (1864-1911) who had
offices at 1 Market Place, Southwold (and Aldeburgh).
6.10 The frontages at the staggered junction of Station Road with Blyth Road and Pier
Avenue therefore present a disintegrated townscape to everyone arriving from the north
(Fig. 10) and while the deleterious visual impact of the under-scaled Police Station will
remain, the present scheme offers an opportunity to provide a significantly better sense of
arrival in Southwold proper than the present single storey general store and utilitarian light
industrial buildings facing Blyth Avenue.
5 Brown, Hayward & Kindred, Dictionary of Architects of Suffolk Buildings, 1800-1914.
Ipswich  p.135.
6.10 There are no evidently predominant local building materials in the vicinity and some of
the dwellings in the vicinity have been the subject of unsympathetic alterations under
permitted development rights while others have seen original brick facades over-painted.
The scheme therefore presents an opportunity to establish a clear sense of architectural
coherence to this corner site and provide a suitable sense of arrival as a prelude to the visual
experience of the area granted conservation area status further to the south and east.
Fig.10 Main approach into Southwold showing the disintegrated townscape, poor
architectural quality and absence of sense of arrival
6.11 While the NPPF encourages good design it is otherwise silent on how this is achieved.
Notwithstanding that the government has withdrawn Planning Policy Guidance Note 15
Planning and the Historic Environment, the advice in the section on Development Control
paragraph 2.14 retains its validity in stating that:
The design of new buildings intended to stand alongside historic buildings needs very
careful consideration. In general it is better that old buildings are not set apart, but are
woven into the fabric of the living and working community. This can be done, provided
that the new buildings are carefully designed to respect their setting, follow fundamental
architectural principles of scale, height, massing and alignment, and use appropriate
materials. (my emphasis)
This does not mean that new buildings have to copy their older
neighbours in detail: some of the most interesting streets in our towns and villages include
a variety of building styles, materials, and forms of construction, of many different periods,
but together forming a harmonious group.
6.12 It is considered that the proposals satisfactorily meet these criteria in forming a
harmonious group of the appropriate scale, height, massing and alignment not withstanding
that they are would not be located alongside or in the vicinity of designated or un-
designated historic buildings.
6.13 Overall, the proposals are therefore considered to represent a notably beneficial visual
enhancement of the site that would be particularly constructive in terms imparting more of a
sense of arrival to the main route in to Southwold and a prelude to the experience of the
adjacent conservation area to the south. It is also considered that the new development
would conform to the advice advocated in paragraphs 60 and 137 of the NPPF.
7.1 Paragraph 128 of the NPPF requires a description of the potential impact on the setting
of heritage assets, in this instance Southwold Conservation Area, to a level of detail
proportionate to their significance and no more than is sufficient to understand the
potential of that impact.
7.2 There are no statutorily designated buildings or buildings of special local interest in the
vicinity, and the principal heritage issue is therefore the visual impact (or otherwise) of the
proposals on the setting of the conservation area. In terms of location, the proposed
scheme is in a discrete location at the most northwesterly extremity of the conservation
area (as defined by the Local Plan proposals map) would effectively be screened by the
existing two and two-and-a-half storey buildings fronting the west side of Station Road.
7.3 The Conservation Area Character Appraisal is silent about the merits (or otherwise of
buildings in Station Road and Blyth Road, and the Seaside Suburban Character Area is not
shown in that document to extend to the location of the proposed development site.
7.4 When viewed from the approach route across Buss Creek the buildings on the present
site do not enhance the approach to the conservation area in general and Southwold
town centre in particular and the present Telephone Exchange and Police Station and their
curtilages notably detract from the present disintegrated townscape exacerbated by the
wide highway junctions. It is considered that the present scheme offers a very good
opportunity to create a more appropriate and coherent townscape and an enhanced
sense of arrival to the area of Southwold south of Blyth Road.
7.5 On the basis of the very limited impact on the relative significance of this northwesterly
extremity of the conservation area it is considered that the proposals would be not only
acceptable in heritage terms but would also meet the wider design objectives set out in
paragraphs 58 and 60 of the NPPF and in doing so would help to contribute positively to
sustaining this part of Southwold, its economic and social vitality and its appearance.
Bob Kindred MBE BA IHBC MRTPI
Bob Kindred Heritage Consultants Ltd
Authorship of this Heritage Impact Assessment
The author of this report is Bob Kindred MBE BA IHBC MRTPI - the former Head of Conservation Urban
Design & Planning Policy at Ipswich Borough Council with over 38 years experience in the public,
private and third heritage sectors. He was awarded the MBE for services to heritage in 1999.
He is a member of the Council of the Institute of Historic Building Conservation; a Trustee of the
Ancient Monuments Society; a Casework Panel member of the Society for the Protection of Ancient
Buildings; an honorary member of the Suffolk Association of Architects; a member of the RIBA Suffolk
Design Review Panel; and a member of the St Edmundsbury & Ipswich Diocesan Advisory Committee.
He is joint consulting editor of the international Journal of Architectural Conservation.
He was the former Standing Special Heritage Advisor to the House of Commons Culture Media & Sport
Committee from 2005 to 2012; a member of the UK Commission for UNESCO from 1999 to 2010; and a
Main Committee of the Victorian Society from 1987 to 1997.