Bournemouth Borough Council

Town Hall

Bourne Avenue




2 February 2017                                                                                                                    By email


For the attention of Mr S Gould


Dear Sirs,


Re: OBJECTION – 7-2017-7448-S, Former Cliff End Hotel, 99 Manor Road, Boscombe


We are writing to object to the above application for demolition of the above building and proposed construction of a 5-, 6- and 7-storey building. What follows refers to, and has been based upon, national and local planning policy, the Site Development Brief SPD and the Heritage Statement, Design & Access Statement and other supporting documentation provided by the applicant.


  1. Loss of non-designated heritage asset – CS Policy CS40;


Although we acknowledge the conclusions of the Heritage Statement (Cotswold Archaeology, November 2017), we note that these conclusions are anchored around the repeated reference to the condition of the building: the Statement acknowledges the ‘degree of group value with other surviving late 19th-century villas in Manor Road and Christchurch Road’ (p. 27) and states that the current condition of the building limits this. The Statement also states that ‘this asset type is illustrative of the original intentions of the first developers of Boscombe’ (p. 27) and, again, limits this owing to the building’s ‘current and historically altered condition’.


On the condition of the building, it appears that a considerable number of years have passed without significant interventions to the building following the fire of 2012, although a sheeted scaffold and temporary roof have been added to the central core. We also note from the structural engineer (GAP Partnership Ltd) site inspection report 14 March 2013 the following observations:


  • 1: ‘On the ground floor working from the front Entrance, the front, left and right rooms are structurally stable’


  • 1: ‘The lower section of the staircase from ground to first floor is stable and can be used to access the first floor’


  • 2: ‘On the first floor, the front, left and right rooms are structurally stable’


  • 3: ‘The mid-section of the staircase, from first to second floor, appears to be stable, but there is a lot of debris on the staircase [blocking access to the upper floor]’


  • 4: ‘The debris on the staircase can be removed safely, thereafter the upper floor and roof can be accessed. What can be seen from the first floor indicates that the floor of the front rooms appears to be structurally stable.’


Furthermore, the site plan provided by the engineer indicates that safe access was possible to the entire ground and first floors other than one room in the northeast corner. These comments follow previous comments from a site visit on 25 January 2013:


  • 1: ‘Since the last inspection, a scaffold frame has been erected to the front gable wall. This will stabilise this section of the façade to allow safe repair to the wall…’


  • 1: ‘From the observations of this inspection, the front turret is stable at the moment.’


  • 2: ‘From the front, the left hand side from the central stair core is stable and safe, front and rear. The Gable wall on the right hand side of the photo above [in the report] is stable.


It seems therefore that the inspections of 2013 following the fire and various phases of temporary works found the building to be generally structurally stable from both external and internal site inspection. In this regard, we are concerned with the assertion in the Planning Statement that ‘the structural condition of the building is becoming a concern’ (p. 36) and that ‘there are very real and significant health and safety reasons for the demolition of the building as soon as is practically possible’ (p. 36). Alarmingly, the Planning Statement also refers to signs of stress in the scaffolding and that it is ‘holding the building in place’. It is our understanding that responsibilities exist upon scaffold users and hirers to ensure that scaffolding is inspected by a competent person every 7 days and following any circumstances which might jeopardise the safety of the installation (e.g. high winds). Therefore any stresses etc. on the scaffolding should have been noted and the scaffold amended accordingly: this has no bearing on the need for demolishing the heritage asset.


With the above in mind, and the chronology of events on the site, we would strongly advise the Local Planning Authority to take para. 130 of the NPPF into account; it would be our contention that the deteriorated state of the building should not affect the decision on this application. Once the arguments surrounding the building’s condition are discounted from the applicants’ submissions, it reveals a less-than-compelling justification for demolition of the heritage asset owing to its architectural character, possible historical association with the jeweller, Harriet Samuel, group value and contribution to the character of the East Cliff Conservation Area. Finally, we are mindful of the requirement of the Development Brief SPD that ‘the starting



point for any development should be the retention of the Victorian core of the building’ (p. 17).


  1. Harm to character of Conservation Area – Local Plan (Saved) Policy 4.4


It is acknowledged in the Planning Statement (p. 76) that the ‘loss of the building results in less than substantial harm’, apparently on the strength of the same conclusion in the Heritage Statement and against the view of the Development Brief SPD that such loss would result in ‘substantial harm’ (p. 12). There can be some debate as to the extent of harm and the level of justification required. However, in stating this, the application therefore implicitly acknowledges the positive contribution of the site to the Conservation Area, which constitutes the criterion for assessing harm under para. 138 of the NPPF.


The Planning Statement states that ‘the scale of the building is entirely appropriate in the context of adjoining tall buildings against which the proposals will be read’ (p. 76). However, the Development Brief SPD states that the tall buildings were present before designation of the Conservation Area and that ‘the prevention of further development of this scale, which is detrimental to the character of the area, was a prime consideration in designating the Conservation Area’ (p. 7). The current proposal, with its monolithic form in a non-congruent architectural style, therefore seems to take its justification from buildings which are acknowledged to be detrimental to the character of the area.


The current building with its central core and later wings of lesser architectural quality do nonetheless respect the topography of the site, with a cascade down towards Christchurch Road which lessens the visual impact of the current massing in important views into the Conservation Area from Christchurch Road and Boscombe Chine Gardens. In concentrating the building into one vertical mass, the proposed building will, in our view, be detrimental to the setting of the Conservation Area.


We therefore feel that, with the compounded effect of the loss of a positive contributor to the Conservation Area and a proposed replacement which is architecturally incongruent – neither respecting nor reflecting the predominant Victorian and Edwardian suburban Gothic of surviving buildings – and visually detrimental, the proposals as a whole constitute substantial harm to the Conservation Area.


In summary, we would consider it immeasurably more beneficial that the applicant revisit the scheme to include the restored Victorian core of the building, although we acknowledge that some development to the wings and site is likely to be achievable with the appropriate blend of congruent architectural style and massing.


Yours sincerely,


James Weir MA (Oxon) PgDipSurv PgCertArchHist FRSA IHBC

Heritage and Conservation Officer, Bournemouth Civic Society