9 November 1998

Your Ref: 98/0666/03

Dear Mr Stevens

REDEVELOPMENT, PRINCESSHAY, EXETER

Thank you for your consultation on this application.

As you know, we have been involved with this scheme since it was brought to our attention at the end of last year. At that time we were presented with an advanced concept which followed on from many months of discussion between your authority and the developers, Land Securities. The proposals had been prepared on the presumption that wholesale demolition of the immediate post--war area of the site could take place and were predicated on a layout and density of development necessary to achieve commercial viability.

We expressed concern that our ability to exercise constructive and fundamental influence over the scheme was by this time severely handicapped and, as a consequence, sought primarily to become familiar with the principles and values which had shaped the scheme before us. This of course necessitated seeking briefings on the many and various stages in the evolution of the scheme in an attempt to identify and where possible acknowledge the rationale that underpinned it.

Initially there seemed to be little information available to substantiate the scheme as a concept which derived confidently from an understanding of the character of the conservation area and its constituent elements such as below and above ground archaeology and the setting of the Close and Cathedral. A subsequent appraisal prepared and presented by the architects unfortunately lacked the degree of analysis which we would have expected for such a major development proposal, which prompted us to commission our own research. This first report sought only to confirm whether the Sharp post-war masterplan had been successful in its objectives and implementation and if, after some forty years, the surviving fabric could be deemed a legitimate contemporary piece of the city centre jigsaw. First impressions indicate this to be the case and it is our intention to commission follow-up work to establish exactly what the integrity of the plan depends on in terms of layout, scale and individual and collective architectural expression. This phase 1 report was circulated to both your authority and the developers and we have now received feedback which will help determine the parameters of the next phase of work.

In addition to an evaluation of existing fabric we have, on a without prejudice basis, critically appraised the replacement scheme. This has embraced issues such as uses, their disposition, traffic and retail impact, as well as more site specific considerations such as the impact on acknowledged and quintessential elements of historic Exeter.

Having made your authority and Land Securities aware of our profound disquiet about the scheme from the moment we were allowed to comment, the time has now come for us to formally register a fundamental objection to the current proposals because of their impact on the designated Conservation Area, the setting of nationally significant listed buildings in and around Exeter Cathedral and its Close and Southernhay, the setting of a Scheduled Ancient Monument - the City Wall -, and the destruction of important archaeological deposits.

All of our objections derive fundamentally from the scale of the scheme. It is the intensity of the development proposed that implies the destruction of the scale as well as the fabric of the present Princesshay; the erection of over-large scale buildings throughout the development; the necessity for extensive below-ground excavation; and servicing and traffic requirements that diminish the quality of the environment in Southernhay and the environs of the City Wall in particular. This issue of unacceptably large scale is compounded by the requirement for an on-site parking capacity and reaches its unfortunate climax in the size and location of the `anchor store'.

The impact of the scale and location of this building would be particularly devastating from the Close and hardly less significant from Southernhay. But our concern about the scale of development and its layout is by no means limited to a single site. It is a concern about the whole development. The site is large and abuts arguably the best and most sensitive of the existing fabric of the historic city along its southern and eastern boundaries; the environment of the Cathedral and Close provides one of the best ranges of historic urban building anywhere in England; Southernhay represents the peak of eighteenth century architecture in a city still renowned for its buildings of that period; and the City Wall is perhaps the most visible record of the long history of settlement on this site.

Reinforcing the rich texture of the historic city that surrounds the site is the modest scale of the post-war redevelopment within it. Whatever verdict history reaches about the qualities of its individual buildings (and we are critically reviewing these as part of our analysis), the singular achievement of the mid twentieth century contribution was to successfully weave together the scale and layout of new and old. This reaches its most convincing expression in the quietly pleasing character of Sharp's Princesshay, both in the radically new relationship it forges with the Cathedral and its knitting together with High Street and the new alignment of Bedford Street. It set the tone for the connections with the area around St Katherine's and east towards Southernhay.

The present scheme would destroy not only the tactful relationship that the existing post-war fabric has with the grain of the historic city that surrounds the site but the merits of the layout and buildings within it. We therefore believe that a development of the large scale proposed can never be successfully integrated into such a highly constrained historic environment without unacceptable damage to the historic townscape within and around the site, to the setting of some of the city's major historic buildings and to the integrity of its archaeological resources. These and other relevant criteria are, of course, laid out at length in PPGs 15 and 16 and it is our clear advice that this development signally fails to satisfy them in principle.

Regrettably, that failure is only highlighted by the architectural treatment employed. We have deliberately not engaged more than tangentially in the architectural handling of the development because we considered more fundamental issues needed to be addressed before we could talk meaningfully about design. This much at least needs to be said: sadly, this is not a scheme of the international architectural calibre that such an important site deserves. It's lack of distinction and conviction is only accentuated by the attempts (significantly perhaps by a different architectural hand) to minimise the impact of the largest structures by cladding the sheer walls of retail units with quasi-domestic, quasi-historic construction: it is an enterprise that is wholly unconvincing.

We acknowledge that the applicants have provided supporting documentation to justify commercially the principle of redevelopment and ultimately we may well assess this to establish the validity of their assertions. The principle of some level of redevelopment is not necessarily out of the question and something less comprehensive, if proven to be essential for the long-term viability of the city centre, would perhaps not attract our `in principle' objection.

The degree of environmental harm associated with the current proposals and the grave concern it causes must prompt us to present the application to our Historic Buildings and Areas Advisory Committee at the first available opportunity. Our involvement has so far included members of our regional team but our position, and the potential consequences, demand a fully definitive and corporate endorsement. We understand that formal amendments to the application are likely during the next few weeks and we would wish to await their submission before proceeding with the presentation.

Yours sincerely

David Stuart

Historic Areas Adviser

cc Land Securities