Designation Review Manager
Wednesday, 17 April 2013
DCMS decide to uphold the decision NOT to list the Tumble Down Dick
Our reference: 476140
PLANNING (LISTED BUILDINGS AND CONSERVATION AREAS) ACT 1990
BUILDINGS OF SPECIAL ARCHITECTURAL OR HISTORIC INTEREST
Tumbledown Dick Public House, Farnborough Road, Farnborough, Hampshire
Further to your application in which you asked for a review of the decision not to list the Tumbledown Dick Public House (the “Pub”). I am the Department’s officer responsible for the review of listing decisions and had no involvement in the original decision not to list.
After considering your grounds for review and evidence submitted they are not sufficient to consider overturning the original decision. The reasons for this decision are given below.
Circumstances under which the overturning of a previous decision will be considered
Overturning an original decision will only be considered if there is evidence that the original decision has been wrongly made. Examples of a wrongly made decision would be:
- where there has been a significant factual error, e.g. the wrong building was listed; or
- where there has been some irregularity in the process that has affected the outcome, e.g. significant relevant considerations have not been taken into account/significant irrelevant considerations have been taken into account.
Reviews of decisions are also undertaken if there is significant new evidence, not previously considered, relating to the special architectural or historic interest of the building in a national context as defined by the Planning (Listed Buildings and Conservation Areas) Act 1990. For example:
- where new evidence relating to the date of a building has been discovered; or
- where there has been a material change of circumstances affecting the assessment of a building’s architectural or historic interest.
In all the above cases evidence can only be considered which relates to the special architectural or historic interest of the building. The Principles of Selection for Listing Buildings, March 2010, (copy attached) sets out general principles, as well as the statutory criteria, for measuring architectural and historic interest in the national context. Other factors, such as planning considerations and local importance, cannot be taken into account. Disagreement with the advice of English Heritage without persuasive new evidence will also not be considered grounds for review.
The grounds you have submitted are not sufficient to consider overturning the original decision for the following reasons.
The Principles of Selection for Listing Buildings – Identifying and Recording the Historic Environment
This section of the Principles, from which you quote part of paragraph 3, is a generic commentary on identifying and recording the historic environment. It is a preamble to the main purpose of the document – listing buildings of architectural and historic interest – and sets the national context for listing. It doesn’t form part of the general principles or statutory criteria for listing.
The content of English Heritage’s advice report
It is important to note that the EH advice report is not intended to be a comprehensive account of the architecture and history of a building. Its purpose is to provide a summary sufficient to allow a decision to be made on whether or not a building meets the statutory criteria for listing. All information submitted as part of a listing application is critically assessed by EH during the drafting of their report. Opinions and facts submitted by any party are not accepted uncritically.
The General Principles applied during a listing assessment
The date of the rear extension is discussed later in this decision letter. The General Principles are general principles only and any building is subject to the more specific Statutory Criteria. Consequently the date of a building does not automatically result in its listing. It is also subject to the test of special architectural and/or historic interest.
The English Heritage Selection Guides
These are produced by EH to cover various broad building types. They are intended as a guide to what may be of importance when assessing a particular building type. They are non-statutory guidance only and are not listing criteria. The Principles of Selection for Listing Buildings take precedence over the Selection Guides.
Individual features of special interest
Very few buildings display special interest throughout and this would not be expected when assessing a building for listing. The purpose of section 1(3)(b) of the Planning (Listed Buildings and Conservation Areas) Act 1990 is to allow the Secretary of State to protect a specific feature of a building that is of special interest e.g. a particularly fine fireplace or plaster ceiling. Nothing with that level of special interest has been identified at the Tumbledown Dick PH.
The speculation on early fabric
The dating of the rear extension to the Pub to the C16-C18 is speculative. Although similar in form there is no clear evidence that this part of the Pub relates to the building in the 1780s watercolour by Thomas Rowlandson. Even if we accept that it is the same building it has been very heavily altered to the degree that, without any information on its construction, it is only the double roof configuration that tentatively identifies it. It has lost significant amounts of its original fabric, principally its façade, and doesn’t survive in anything like its original form.
The design of the ‘1817’ building
EH commented in their original advice on the form of the part of the building constructed around 1817 but with later alterations. Pubs are not rare building types nationally and selectivity when assessing them for statutory listing is important. In this case the Pub has been altered and extended. The southern part of the main building, for instance, being rebuilt or at least heavily remodelled between 1880 and 1896. As far as is known the building retains nothing of its C19 pub interior.
The Annersley family - The association of the Annesley family with the manorial estate is acknowledged. However, the Pub is only a minor feature of the estate and was constructed after the Annesley’s ownership. There is no direct and close historical association between the family and the Pub. There is also no direct association between the present Pub and ‘Kidnapped’ and similar stories.
The Wilmot family - The association with the Wilmot family, under whose ownership the present Pub was built, is closer than that of the Annesleys. However, the reasons for the Wilmot’s national importance, as expressed in the review request, has no demonstrable connection with the Pub.
The Rowlandson watercolour – The figures in the Rowlandson painting may be representative of local people in the street at the time but the images are too generalised to be associated with any particular prominent figures. Any attribution of names to a figure would be speculation and their appearance in the painting does not signify any direct association with the Pub.
The group value between the Pub, Farnborough House and St Peter’s Church is not strong. The three building types, pub, manor and church, are very common functional features of very many English towns and villages and weren’t planned or designed as a group. This, along with the very limited architectural interest of the Pub, significantly limits the group value and doesn’t add materially to a case for listing.
The EH advice report acknowledges that the Pub is locally important for its civilian and military role in the historic village of Farnborough. In a national context, however, it does not have the resonance either as a building of national importance or as a local building that adds significantly to the national building stock to merit listing. There are no quotas for listing buildings either by type or location. Buildings are listed solely on their ability to meet the statutory criteria for listing in a national context.
The development of the Tumbledown Dick PH over time
The C19 was a time of strong population growth and transport and trading development. The extension and development of buildings is a common factor in this period and the Pub does not demonstrate any development out of the ordinary.
The association with the local pottery industry
As a very important industry for the local economy many buildings in the area will have a direct or indirect association with pottery manufacture. There is no particular and direct association between the Pub and the pottery industry that could add materially to a case for listing.
The construction materials for the Pub
Historically transporting heavy building materials long distances would have been a slow and often difficult undertaking. It is not surprising, therefore, if the bricks used to build the Pub came from the local area. This would have been the case for most modest buildings and isn’t of any great significance. If the frontage did have some surface decoration, as suggested, it does not survive in any recognisable form and would represent a detrimental alteration to the original building.
The information you have submitted is not sufficient to provide grounds for overturning the original decision. The original decision, and the reasons for it, should therefore stand and the Tumbledown Dick Public House, Farnborough Road, Farnborough, Hampshire should not be added to the statutory list.
Further opportunity to make a listing application
The Secretary of State has a continuing duty under the Planning (Listed Buildings and Conservation Areas) Act 1990 to maintain an up-to-date statutory list of buildings of architectural or historic interest. If significant new information should come to light in the future then a new listing application may be made to English Heritage through their on-line application process.