Protect Lambeth’s trees – Court of Appeal 8th June 2023

In December 2022, a High Court judge ruled that Lambeth officers had not erred when they claimed that Lambeth’s own planning application to demolish Ropers Walk was not in breach of their own Tree Policy (Q10). As a community, we couldn’t believe that the mere fact that if a developer pays compensation for the removal of trees, then it is no longer in breach of Lambeth’s tree policy, which ostentatiously is there to prevent valuable trees from being removed. Hence we applied to appeal the decision. The application was granted and on 8th June 2023, the case will appear before the Appeal Court.

Rewind back to March 2021, Lambeth’s planning committee approved the demolition of Ropers Walk despite the application then acknowledged as being in breach of its Tree Policy Q10. However, Lambeth officers erred when they advised the committee that heritage ought not to be a consideration. The community lodged a judicial review action, which was successful and the planning decision was quashed. Lambeth then resubmitted the planning application in November 2021 to the planning committee, now claiming that the Cressingham Gardens estate was indeed a Non-Designated Heritage Asset. However, it stated that it was now no longer in breach of its Tree Policy Q10.

How could this be, when the three much loved 80-90 year old trees were still being proposed for removal? In the intervening period between the two planning committees, the revised updated Tree Policy had come into force, although the draft had already existed at the time of the original planning application.

So what is this Tree Policy (Q10) you ask? It is Lambeth’s planning policy to prevent valuable trees from being removed. Specifically it requires:

B. Development will not be permitted that would result in the loss of trees of significant amenity, historic or ecological/habitat conservation value (including veteran trees), or give rise to a threat, immediate or long term, to the continued wellbeing of such trees.

C. Where trees are located within a development site, the proposal will be supported only where it has been demonstrated that:

i) trees of significant amenity, historic or ecological/habitat conservation value have been retained as part of the site layout …

However, Lambeth have inserted a clause G in its latest iteration of its Tree Policy (Q10):

“G. Where it is imperative to remove trees, adequate replacement planting will be secured. The amount and nature of the replacement planting will be based on the existing value of the benefits of the trees removed, calculated using cost/benefit tools such as i-tree or CAVAT as set out in London Plan policy G7 C.”

This latest Appeal Court action is about this clause G. Lambeth previously argued in the first High Court hearing that if a developer pays compensation in accordance with G, then even if a tree cannot be removed to make way for a development under the clauses B and C, it is still all hunky dory and there is no breach at all.

From the community’s perspective, if a developer is proposing to remove a valuable tree then it is still in breach of the Tree Policy and there should be some very serious contemplation before such a development is permitted. In Cressingham Garden’s case, a breach in the Tree Policy (Q10) in addition to the facts that Ropers Walk is part of an Non-Designated Heritage Asset and is part of the Amphibian Migratory Crossing registered with the Department of Transport should have resulted in a resounding refusal of the planning application.

We believe, this is an appeal that will have ramifications far beyond the borders of Cressingham Gardens and is about the protection of trees across the entirety of the Lambeth borough.

If you would like to support the fund raising for this legal action, donations can be made via the Save Cressingham GoFundMe campaign

The hearing will take place at 10.30am on 8th June in the Appeal Court located at the Royal Courts of Justice in London. It will be open to the public.

Festive fundraising to fight yet another Lambeth attempt to demolish

Recently, Lambeth  council once again approved the demolition of Ropers Walk at a recent planning application.  This is despite an elderly 83 year old freeholder not wanting to leave her home full of memories of her late husband. Consequently, we will be looking to take legal action against this travesty once again.   Thus, residents are raising funds once again.   

The latest creative initiative from the community are…

Hand-crocheted toads, perfect for Christmas stocking fillers and in recognition that Cressingham Gardens is the only officially registered Toad Crossing in inner London.  (£2 per toad)
Festive cards designed by our residents – the youngest artist being only 5 years old. Each comes with its own envelope.  (£3 for a set of 3)

 

 

 

 

 

 

 

 

 

Order form can be downloaded here: XmasOrderForm 

Or simply email savecressinghamgardens@gmail.com to organise collection of your toads and festive cards.

Judge gives green light for Judicial Review #3

Residents of Cressingham Gardens are embarking on their third High Court battle, after a judge granted permission for a judicial review of a decision to demolish their homes. 

Mrs Justice Lang DBE has ruled that Andy Plant, a resident of Cressingham Gardens estate, near Brixton in south London, can bring the community’s third challenge against the London Borough of Lambeth.

The date for the judicial review hearing has yet to be fixed, but is likely to take place at the Royal Courts of Justice in London towards the end of the year.

Cressingham Gardens resident have previously brought Lambeth council twice before the High Court for judicial reviews.  In November 2015, residents won against the local authority which had unlawfully resolved to flatten the estate’s 306 homes. Mrs Justice Elisabeth Laing quashed the decision after finding Lambeth had unfairly dropped refurbishment options from the consultation.

Lambeth council’s cabinet then rubber-stamped the proposed £110m full redevelopment option again at a meeting in March 2016.  This repeat decision which was also taken before the High Court in November 2016, but was allowed to stand.  

Since then the council has effectively failed to engage with the community.  Lambeth dismissed a petition signed by over 50% of households requesting that the so-called Resident Engagement Panel be democratically elected and an independent chair be appointed, rather than allowing a local councillor to self-appoint themselves. The panel has not met since May 2018.

At the start of the coronavirus pandemic in March 2020, Lambeth’s development subsidiary Homes for Lambeth embarked on an online community consultation fully aware that digital exclusion is a major issue on the estate, with many residents with only poor quality or even no internet access.  Lambeth’s latest proposal, advised by Savills, is to salami-slice identifying an initial block, Ropers Walk, for demolition and rebuild, rather than start with a master plan, in contravention with the Lambeth cabinet decision in March 2016.

Although the bulk of planning documents were submitted in July to Lambeth’s own planning department, the statutory consultation was not undertaken until December 2020 in the run up to Christmas and at the height of the covid pandemic.  

This latest judicial review will look at whether or not Lambeth properly considered the heritage aspects and the setting of precedence without a master plan in place.  Despite objections from heritage organisations 20th Century Society, SAVE Britains Heritage, Herne Hill Society and Brixton Society, the planning committee did not consider Cressingham Gardens’ status as a non-designated heritage asset.

In 2013, English Heritage (now Historic England) decided not to list Cressingham Gardens, but also wrote that “We do recognise its local significance, however, and conservation area status is suggested as a means of reflecting its overall character.”   Lambeth officers cited a lack of time in their day for not considering English Heritage’s suggestion.  Only in 2020 did Lambeth start to consult on the Brockwell Park Conservation Area borders, but the council’s proposal still did not include a proposal to extend the boundary to include the whole of Cressingham Gardens.  The results of this consultation are still outstanding. 

The community is now fund raising to pay for the legal costs for the judicial review.   To donate:

www.gofundme.com/SaveCressingham

Or donate directly via Paypal:

http://bit.ly/CressinghamPaypalDonation

Cute mini-suitcases for penny collection

Do you have loose change around your home?

Cressingham Gardens residents are handing out these super cute mini-suitcase boxes as a fundraising initiative. Simply grab one of these little suitcases and when it is full, a resident can come by to collect it.

Email cressinghamcommunity@gmail.com to request a mini-suitcase.

Penny collection suitcases

Residents are raising funds for the legal challenge of the latest Lambeth council decision to salami-slice and approve the planning application for the demolition of Ropers Walk. The council and its wholly owned development company, Homes for Lambeth, with the support of Savills, pushed through the planning application consultation over the most recent festive period during the covid lockdown. They completely ignored the fact that many residents, including residents living in the homes directly affected by the application, have no access to the internet and thus were not able to even review the application. It simple terms, it was a “Merry Christmas, we want to evict you and knock down your home.”

The residents have to now raise £30,000 to fund the legal action.

You are also more than welcome to donate directly online at: www.gofundme.com/SaveCressingham

“Sanctum Ephemeral” Cressingham Gardens fundraising auction

One of our very talented residents, is doing a fundraising auction his prints. In his own words….

Carl, from the series Sanctum Ephemeral, Mark Aitken 2017.

Sanctum Ephemeral is an award winning Arts Council of England photo series, installation and photobook. The portraits feature residents living on Cressingham Gardens Estate, Brixton, London. The photos are an exploration of how home as a repository of memory defines identity. We define our homes. Our homes define us.

The estate has been earmarked for demolition by Lambeth council – against the wishes of the overwhelming majority of residents. The loss of home and community can’t be measured against the short term gains of property developers. All money raised from this auction will go towards funding a new judicial review challenging demolition proposals.

Online auction of two exhibition prints from the award winning Sanctum Ephemeral series. Printed on fine Hahnemühle Photo Rag paper (75cm x 99cm). Each print is from a series of three. Sanctum Ephemeral was a finalist in Portrait of Britain 2017 and won the national Open Art Prize 2017 as well as exhibited in numerous galleries and published in national press. 

Visit here to see the whole series and further information. And finally, please forward this email to anyone you know who might be interested.

Click on the links below to bid:

Auction 1

Auction 2

Billy & Tommy, from the series Sanctum Ephemeral, Mark Aitken 2017. 

Cressingham Gardens part-redevelopment given planning go-ahead

Cressingham Gardens residents are challenging Lambeth’s decision last night to bulldoze part of their estate – in a move they claim is “unlawful salami-slicing”.

Lambeth councillors voted 6-1 to approve the 20-apartment redevelopment of 12 homes on Ropers Walk, despite receiving 395 objections and just two comments in favour.

An 83-year-old retired NHS nurse who has lived on the walk for 33 years has accused Lambeth of harassing her out of her home. Her objection was published by Lambeth council on its planning portal.

Ahead of last night’s meeting held on Zoom, a forcefully worded letter was submitted to the Planning Application Committee by lawyers representing the community.

The letter, downloadable here , lists a number of ongoing serious concerns over the lawfulness of the planning bid and alleges parts of the process have been misleading.

However, only one member of the committee, Green Party councillor Becca Thackeray, agreed with the community’s concerns and the plan was passed.

Residents are considering next steps for the challenge, to be announced soon.

 

Where to donate to Save Cressingham Gardens Fighting Fund:

https://uk.gofundme.com/savecressingham

Cressingham part-development is “unlawful salami-slicing”, lawyers claim

Lambeth received its own Christmas present from Cressingham Gardens residents in the form of a legal letter explaining how it would flout planning laws if it green lights the new development on Cressingham Gardens.

Among the concerns raised, are that the redevelopment of one block, without the promised masterplan, is designed to flout environmental obligations.

The legal objections also highlight:

  • Inappropriate development for location
  • The misidentification of a mature English Oak as a less valued Turkey Oak.
  • The marginal benefit of additional affordable homes being outweighed by many more negatives
  • Application should be delayed until after review of Brockwell Park Conservation Area boundary
  • Impact on daylight access for neighbouring estate homes not considered

Read the letter here:

For more information on how to object, read further here: https://bit.ly/DoubleConsultation .

Cressingham Gardens dealt a nasty double consultation for Christmas …

Lambeth Council, its property development company Homes for Lambeth and its advisors Savills, appear to have concurred that Christmas time is the perfect time to consult the residents of Cressingham Gardens and the wider community. Demolition and destruction of people’s homes full of memories are just the things that every person wants to talk about (not) over Christmas dinner. And yet, to make it truly jolly, Lambeth council has decided to double down on this tactic and to do TWO consultations in parallel that relate to Cressingham Gardens and the council’s intended destruction of the community.

What to do?

We need as many people as possible to feed into the consultations. Please spread the word.

Click on the links below for more details on …

  1. Consultation 1: How to object to the demolition of Ropers Walk (phase 1 of Cressingham Gardens demolition)

2. Consultation 2: How to request the inclusion of Cressingham Gardens in the Brockwell Park Conservation Area

3. How to donate to the Save Cressingham Gardens Fighting Fund

Cressingham demolition plan relaunched for Christmas.

Twelve homes on Roper’s Walk/Trinity Rise to be demolished in “step one” of full Cressingham Gardens redevelopment plan. Estate regeneration scheme opposed by majority of residents: more than 1000 people at risk of displacement. Plans threaten environment, affordability, community and health of residents.

Campaigners are warning that a plan to demolish 12 homes on Cressingham Gardens Estate is just the “thin end of the wedge” for the destruction of all 300 homes.

Plans to redevelop Roper’s Walk, by Lambeth council’s development vehicle “Homes for Lambeth”, went live on on December 4.

Under the plans the houses and flats, located at the southeastern end of the estate adjoining Trinity Rise, would be replaced by 20 apartments.

A retired NHS nurse aged in her 80’s is among those facing the prospect of home loss in the coming months, but she has vowed to fight the plans.

Only a fraction of the estate’s residents had been contacted nearly a week into the public consultation – with a looming deadline for comments on December 21, just days before Christmas.

Those who have been notified about the consultation have reacted angrily to the timing of the announcement, describing Lambeth’s cruel Christmas consultation during the Covid pandemic, as “shocking but not surprising”.

Lambeth had apparently made no progress since 2012, when proposals were first mooted, and residents had been hoping the council would give up on its ambition to flatten their homes.

There is a long history of the council treating residents unfairly over its plans for the estate and the community has twice been forced to challenge Lambeth in court, winning a judicial review in 2015.

Throughout the ordeal, Lambeth has never produced a masterplan for the proposed redesigned estate, despite spending hundreds of thousands of pounds of taxpayers’ money on consultants.

Residents, a majority of whom are opposed to demolition, recently won the legal right to manage the estate for themselves. The resident management organisation employed an estate director last year and is poised to sign a management agreement in 2021.

The government has also given residents the green light to explore transferring the ownership of the estate into community hands.

The community has produced an alternative People’s Plan which has the potential to provide 37 extra homes at council rent levels without forcing any residents out of their homes.

This would cost a fraction in contrast with Lambeth’s £120m estate-wide scheme, which at the last count offers just 27 extra additional council rent level homes across the estate.

Lambeth’s piecemeal plan for Roper’s Walk is intended to set a precedent for developing the wider scheme.

However, without a masterplan for the whole estate, the approach is widely considered to be incoherent.

How to Submit to the Consultation:

Objections have to be submitted electronically via Lambeth’s Planning application database.

Go via this direct link to the planning application:

Or search for the application reference 20/02406/RG3 in the planning database

Where to donate to Save Cressingham Gardens Fighting Fund:

https://uk.gofundme.com/savecressingham

Suggested points that can be included in objections to the planning consultation:

  • No Master Plan – The masterplan for the entire estate should be approved before Roper’s Walk application. Lambeth Local Plan states that when working out affordable housing it has to be part of a wider strategy.
  • Design doesn’t promote community cohesiveness. ASB built into design. – The existing design of Ropers Walk promotes neighbourliness – vital for vulnerable or isolated residents. The new proposed bock design puts residents at increased risk of loneliness and domestic violence. Furthermore, the design is poorly integrated into the rest of Cressingham Gardens, resulting in a long blocked off passageway next to Brockwell Park that will be a clear target for anti-social behaviour.
  • Poor design in light of covid risks – The community that is expected to be rehoused here is ~60% BAME and a high proportion are vulnerable (elderly & medical conditions). The design is high risk for Covid-19: e.g. communal entrance doors and narrow internal corridors. The existing building provides for direct access to front doors (ie no communal doors) and external walkways.
  • Loss of 90 year old trees – Three mature ~90 year old trees (English Oak, Lime & Yew) that pre-date the build of Cressingham Gardens are to be removed under the proposed development. This is in contravention of Lambeth’s own Local Plan (2015), Policy Q10: “development will not be permitted that would result in the loss of trees of significant amenity, historic or ecological/habitat value”.
  • Design is ugly and lacks distinctiveness – Lambeth’s own Local Plan (2015), Policy Q5 (local distinctiveness) requires that proposals should respond to local context and historic character in terms of townscape and landscape. The proposal has none of this. Furthermore, it will set a precedent for proposals for the rest of Cressingham Gardens, which is located on 10ha directly next to the beautiful Brockwell Park. It is a threat to “one of the nicest small housing schemes in England” (Lord Esher, past president of RIBA).
  • Negative impact on the Brockwell Park Conservation Area – Cressingham Gardens directly borders the Brockwell Park Conservation Area. Lambeth’s own Local Plan (2015), Policy Q22 (conservation areas), states that development proposals affecting conservation areas will only be permitted where they preserve the character or appearance of conservation areas by, among other things, protecting the setting including views in and out of the area. The height and massing of the proposed will impact the views from within the conservation area, as well as completely dominating the neighbouring properties. Furthermore, Cressingham Gardens should be included within the boundary of the conservation area in accordance with English Heritage’s report (click here to see how to comment on parallel consultation regarding the conservation area boundary extensions).
  • Loss of light and privacy – Height and mass of the proposed block will cut neighbours’ light and privacy.
  • Climate impact – Demolition will release embedded carbon during climate crisis.
  • Air pollution during construction including asbestos risk – Much dust and air pollutants will result during the construction in an area where there is a high proportion of vulnerable residents (elderly and health risks). Also, as with all 1970s build properties, asbestos is present. The asbestos is safe provided it is not disturbed and when it is removed, it requires very careful procedures. High risk that in adequate procedures are put in place. The current Homes for Lambeth development on the Westbury estate has resulted in at least one resident in a neighbouring property being hospitalised due to air pollutants during construction.
  • No financial viability – Homes for Lambeth claims that they don’t have to produce a financial viability report as the block will be 100% “affordable”. However, as the development is being underwritten by taxpayers, a report should still be produced showing the sources of funding and whether the development will pay for itself. As seen by the recent problems in Croydon and its wholly owned development company Brick by Brick, there is a high financial risk to the council.
  • Lack of genuine affordability – Homes for Lambeth claims all 20 new Ropers Walk homes will be “affordable”, with 70% at council-level rents and 30% shared ownership. What they don’t mention is that :
    • the scheme offers just 3 extra homes at council rent levels,
    • the council rents will rise 20-25 per cent
    • the share ownership properties are not genuinely affordable – similar shared ownership schemes require minimum £50k household income (median household income in Tulse Hill ward is £29k) – and Shared ownership is a poor deal for homeowners as they are forced to pay mortgages, 100% service charges and rent.
  • Parking Stress – The proposal provides for zero car parking within the site with the two disabled bays being placed on the Trinity Rise road.
  • Lack of consideration of local wildlife – Cressingham Gardens is home to the common toad and bats. The common toad is prevalent across the estate and is a Priority Species. Nevertheless, the Homes for Lambeth application claims that there is no evident of any such wildlife.
Homes for Lambeth proposed new building

Support the inclusion of Cressingham Gardens into the Brockwell Park Conservation Area

We are urging Lambeth Council to include the entire estate in the Brockwell Park Conservation Area (BPCA) as part of a review open to public consultation.

Organisations and Lambeth residents, including supporters of the threatened estate and park, can comment on boundary proposals and a draft character appraisal until 11 January 2021.

The consultation is part of a cyclic review of the borough’s conservation areas. 

It comes seven years after English Heritage first strongly suggested the boundaries of the BPCA could be extended to include the whole of Cressingham Gardens in December 2013. The campaign Save Cressingham Gardens first wrote to the borough’s head of conservation Doug Black to push for the extension in April 2015, in a move backed by conservation groups Friends of Brockwell Park, The Brixton Society, Twentieth Century Society, and SAVE Britain’s Heritage.  Mr Black told the signatories that there were not enough resources to give the request proper consideration.

The green mounds, which are a central feature of the estate near the Main Cressingham Gardens gate to Brockwell Park, are already protected under the BPCA.  The other “green finger” communal areas adjoining the park should similarly be included in the BCPA at a minimum, if not the entirety of the estate.  Cressingham Gardens is important both for its environmental integration to Brockwell Park (e.g. home to wildlife such as toads and bats, as well as many trees over 90 years old that predate Cressingham Gardens itself) as well as its architectural heritage and importance. 

The review is therefore a timely opportunity to spotlight the threat to the park’s landscape and character, which the estate’s redevelopment poses.

How to Submit to the Consultation:

The consultation webpage is here:

https://www.lambeth.gov.uk/consultations/have-your-say-on-the-draft-brockwell-park-conservation-area-character-appraisal-and

To go direct to the current proposal:

https://www.lambeth.gov.uk/sites/default/files/co-Draft-Brockwell-Park-CA-Character-Appraisal.pdf

To submit the consultation, email:  planningconservation@lambeth.gov.uk

Where to donate to Save Cressingham Gardens Fighting Fund:

https://uk.gofundme.com/savecressingham

Suggested points that members of the public could include in comments to the consultation:

Urge Lambeth to revisit the relevant part of the listing report from English Heritage (now Historic England), which is the government’s adviser on conservation. This includes praise for and comment on:

The successful integration of the estate with the “major asset” of Brockwell Park. The report remarks that the open and informal design takes advantage of and complements the green and natural setting.

The character is currently protected to a degree by the designation of the estate’s central open space within the existing conservation area. However, it was the clear view of English Heritage that additional designation should be afforded to protect the appearance of the site along with the particular low-rise mid-century character of the development and its “green fingers”: the spaces running from the park’s edge and between the buildings. 

As the conservation area comes into the estate itself, designation by extension is entirely logical and almost implicit in the way the boundary is drawn at this point.

In relation to the natural environment, the estate was designed around the trees, it sits below the tree line, and there is substantial and informal planting. The trees would be specially protected in a conservation area, thereby preserving the intended effect of bringing the park into the estate. The planting at Cressingham is similar to the approach used by Eric Lyons at the now grade II-listed Span estate at Parkleys, in Ham, and the conservation designated Fieldend in Strawberry Hill, and which no doubt influenced Cressingham under Ted Hollamby. 

Excerpts from the English Heritage report:

“Lambeth produced a large body of housing under Ted Hollamby, and it is in the smaller schemes of the 1970s, including Cressingham Gardens, where the qualities of contextualism, humanity and community-centric design are most in evidence. Cressingham Gardens adopts building types and forms used elsewhere on other Lambeth schemes… 

“However, where Cressingham is distinct from a number of other Lambeth developments is in the informality and spatial interest of its planning. The topography of the site is exploited, and the blocks are off-set or otherwise arranged, to create a sense of townscape. At its most successful, such as the view west along Chandler’s Walk [sic (Way)], enclosed by the garden walls to one side, and the row of bungalows to the other, the planning is exceptional.” 

While the architectural quality was not considered to be consistent enough for listing, the informality that held it back in this respect, is crucial to the park-side feel, and boosts the case for conservation:

“Outside of the environment created by the Walks, the interest of the estate comes not from the architectural quality of the structural elements, but from the quality of the spaces left in between; in some cases this is a tightly controlled relationship between built elements (as at Chandlers Way), but in a number of cases this is dependent on the quality of the natural environment to distinguish it, and there is little in the way of structured, or planned landscaping within some of these areas. This point is not a criticism of the scheme, it is part of what gives the estate its character, but does highlight one of the problems that Cressingham Gardens presents as a listing candidate. 

“The estate is a strong example of the important legacy of progressive public housing that Ted Hollamby and his department brought to Lambeth. [List of other London schemes]. The nature of the planning at Cressingham is very different, and this is part of its interest and value… Cressingham stands out for the informality of its planning, which reflects the careful respect paid to Brockwell Park, but listing can only recognise structures, not the open spaces between them…

“However, it is considered that the estate could benefit from greater formal recognition as a successful and popular housing scheme which achieves a particularly careful contextual response to its sensitive setting, adjacent to Brockwell Park Conservation Area. 

“It is also one of the more interesting housing schemes from this important period in the development of social housing, produced by one of the most progressive authorities. Cressingham Gardens has strong local interest and for this reason it is felt that a future reappraisal of the boundaries of Brockwell Park Conservation Area should give serious consideration to whether the estate should be included within it, in a similar way to previous extensions of the conservation area boundaries have encompassed other areas of housing of historic value adjacent to the park. 

“As acknowledged in the Brockwell Park Conservation Area Extension Report of 1999, the park is a ‘major asset and is extremely important to preserve and maintain its setting and the residential nature and scale of the built environment surrounding it’. Cressingham Gardens is a testament to the fact that despite pressure for high density development, Ted Hollamby and his department were equally conscious of the importance of the park’s setting and produced a scheme which responded to this with skill and sensitivity, both in the scale and massing of the built elements, as well as through the integration of these elements with informal open spaces which bring a park-like character into the estate.”

Conclusion (p 5): 

“We do recognise its local significance, however, and conservation area status is suggested as a means of reflecting its overall character.”

Earlier on in the report, Lambeth’s arguments against listing are summarised as largely centring around the qualities at Cressingham not being special in terms of the era and Hollamby’s projects elsewhere in the borough. There are around 45 estates listed as part of Hollamby’s output: English Heritage singles out just three for special praise, and one of them is Cressingham, the only large estate of the three. However, for the purposes of considering Cressingham for conservation, the relationship to the other developments of the era need not be a factor. English Heritage’s advice on conservation focuses strongly on the particular setting and the need to protect Cressingham as part of this. As such there is no need to consider it in relation to other estates of the period, elsewhere in the borough.