Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — by Benjamin Webb BA(Hons) MA MA MSc PGDip(UD) MRTPI IHBC an Inspector appointed by the Secretary of State Decision date: 24 July 2024

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — TF8 7DX • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) against a failure to give notice within the prescribed period of a decision on an application for planning permission. • The appeal is made by Shropshire Homes against Telford and Wrekin Council. • The application reference is TWC/2021/0356. • The development proposed is 101 dwellings with associated access, infrastructure and demolition (to include the rebuilding and conversion of parts of a listed building to provide 3 dwellings), the creation of an open watercourse, and publicly accessible historic interpretation zone.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — Road, Coalbrookdale, Shropshire TF8 7DX • The appeal is made under section 20 of the Planning (Listed Buildings and Conservation Areas) Act 1990 (as amended) (the Act) against a failure to give notice within the prescribed period of a decision on an application for listed building consent. • The appeal is made by Shropshire Homes against Telford and Wrekin Council. • The application reference is TWC/2021/0358. • The works proposed are works to facilitate the conversion of the former compressor house and reconstruction of the former pattern shop to provide 3 dwellings.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. https://www.gov.uk/planning-inspectorate

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. https://www.gov.uk/planning-inspectorate Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 4. Amendments to the descriptions of development/works were agreed in advance of the Hearing. This was to ensure accuracy, and to exclude superfluous details. The amended descriptions appear within the banner heading above. 5. The main parties have worked together on the scheme over a number of years. Each are agreed that the appeals should be allowed. The Council however failed to determine the applications, principally on account of objections to the scheme raised by the International Council on Monuments and Sites (ICOMOS). These in turn led the Department for Digital, Culture, Media and Sport (DCMS) to warn that if ICOMOS’s concerns remained, and the development went ahead, the Ironbridge Gorge World Heritage Site (the WHS) could be placed at risk, and might ultimately be delisted. DCMS issued this warning notwithstanding a lack of objection to the scheme from Historic England. Both DCMS and Historic England have stressed a need to consider ICOMOS’s concerns in determining the applications. 6. The appellant provided an annotated series of historic images and a new section study at the Hearing.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. This was in response to a case made by the then Chair of the Ironbridge Gorge WHS Steering Group that buildings shown on 1753 plan of the works had survived within the northeastern part of the site well until into the C20th, and thus longer than was asserted within the appellant’s submissions. It was also in response to my indication prior to the Hearing that the accuracy of the appellant’s tithe map overlay (the overlay), required discussion. The latter was used to indicate the locations of buildings present on site in the 1840s. However, it omitted the range of buildings within the northeastern part of the site highlighted by the WHS Steering Group. 7. The appellant previously stated that there was little to suggest much from 1753 remained in 1849. The appellant’s new evidence however confirmed that the buildings omitted from the overlay are likely to have included possible ‘Darby-era’ parts of the works shown on the 1753 plan. These buildings include a structure identified as the ‘New Moulding House’, whose location partly corresponds to that of the proposed 4-storey apartment block, and which is furthermore depicted by numerous sources, including C20th photos. 8.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. The overlay is a repeated feature of various documents produced and circulated since 2021, including the 2023 Archaeological Management Plan. It was indeed used by both parties to assess, illustrate, and communicate potential impacts on the site’s archaeological significance, including within submissions to DCMS and ICOMOS. Its lack of completeness means that both it, and accompanying interpretation are at best misleading, at worst erroneous. 9. Given the sensitivity of the site it should not have taken until the day of the Hearing to present what was in effect basic desktop research into the historic development of the site. Having done so however, the appellant’s new evidence undermined the credibility of material presented by both main parties during the course of the previous 3 years. 10. Those who were not present at the Hearing, and who made representations at an earlier stage in the scheme’s development, are likely to remain unaware that they did so on the basis of an incomplete and flawed evaluation of the site’s historic development. These parties include Historic England and ICOMOS.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Whilst I attach great weight to Historic England’s advice, given that in this case it was based on information presented to it by the main parties, its content is open to question. Insofar as ICOMOS has voiced significant https://www.gov.uk/planning-inspectorate 2

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Whilst I attach great weight to Historic England’s advice, given that in this case it was based on information presented to it by the main parties, its content is open to question. Insofar as ICOMOS has voiced significant https://www.gov.uk/planning-inspectorate 2

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 concerns, it appears likely that these concerns would have been amplified had it been accurately informed. 11. I am conscious that each may have wished to see and comment on the appellant’s new evidence. At the same time, I cannot ignore its confirmation of the case made in representations by another interested party, or its direct relevance to my evaluation of the scheme. Aside from the new section study, which is part conjecture, the evidence itself simply fills minor gaps in the historical source material otherwise set before me. Those gaps do not account for past misinterpretation or misrepresentation of the latter. For this and the above reasons I have taken the appellant’s evidence into account. 12. The Council has questioned the status of comments provided by ICOMOS and considers that risks to the WHS are not a ‘material consideration’. Those risks however ultimately reflect the potential for harm to the Outstanding Universal Value (OUV) of the WHS identified by ICOMOS. ICOMOS is an advisor to UNESECO, whose World Heritage Committee is the body responsible for designating and delisting WHSs.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. The UK has treaty obligations in respect of the latter, which are currently reflected in national policy set out within the National Planning Policy Framework (the Framework) and Planning Practice Guidance. The role played by ICOMOS in relation WHSs mean that its comments and concerns are of direct relevance to assessing the scheme’s performance against national policy. That being so, whilst ICOMOS may be a non-statutory consultee, I attach great weight to its comments and have taken them into account accordingly. Main Issue 13. The main issue is the effect of the scheme on the WHS, together with other designated heritage assets, including whether the scheme would: (a) sustain and enhance the significance of on-site archaeology (Appeal A); (b) preserve the listed building (Appeals A and B); and (c) preserve the setting of the listed building, and that of other listed buildings (Appeal A), and preserve or enhance the character or appearance of Severn Gorge Conservation Area (the Conservation Area) (Appeals A and B); and, if harm would arise, whether clear and convincing justification for this has been demonstrated. Reasons Background 14.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. The site falls within the WHS, which is identified by the Framework as a designated heritage asset of the highest significance. This reflects the international cultural importance of the area as a cradle of the Industrial Revolution, and the continued ability of its buildings and landscape to illustrate that role. Much the same attributes help to underpin the significance of the overlapping Conservation Area. 15. The site currently contains a range of disused industrial buildings mostly dating to the early-late C20th. It had however been in use for processes connected to ironworking for a period of over 300 years. This exceptionally long period included an active role played in the early years of the Industrial Revolution, https://www.gov.uk/planning-inspectorate 3

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 when, in around 1718, Abraham Darby I built his Lower Works on part of the site. This followed his establishment of the world’s first coke powered blast furnace a short distance to the north, the remains of which are now a Scheduled Ancient Monument. 16. Most of the site’s subsequent history was as part of the Coalbrookdale Company works. Historic parts of the works to the north of the site comprise a large group of listed buildings identified within the appellant’s 2023 Heritage Impact Assessment, which notably include the works’ landmark Grade II* clock tower warehouse. These buildings remain in use by the Coalbrookdale Museum of Iron and the adjoining Enginuity Museum, and include the listed building of which the compressor house forms part. 17. In broad terms, the significance of these buildings as a group resides in their historic association with the Coalbrookdale Company, their historic industrial function and design, and their power to illustrate the past industrialisation of the area.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. The site as such forms an important component of the physical, visual and historic setting of listed industrial buildings to the north, as too an integral part of the broader historic industrial and cultural landscapes covered by the WHS and the Conservation Area. It therefore contributes to the significance of all. (a) Archaeology 18. Policy BE3 of the Telford and Wrekin Local Plan 2018 (the Local Plan) sets out the Council’s objective of protecting and enhancing the OUV of the WHS. Within this context it states that the WHS is an area of special archaeological interest within which all archaeological sites of significance will be afforded the same protection as that given to nationally important monuments. 19. The retaining wall along Wellington Road and part of the culvert carrying the Coal Brook through the west side of the site are each dated to the C18th. If they survive, other C18th components of the works now lie below ground. Documents produced by both main parties contain various somewhat inconsistent estimates of depth, but with a generalised 10-15 metres suggested within the Council’s 2022 correspondence with DCMS, and again within the appellant’s 2023 Heritage Impact Assessment. 20.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. The gradual infilling of the Upper Forge Pool in the south of the site and burial of the culvert with industrial waste are each reasonably well documented within historic source material. These features historically represented topographically low points within the site, and the existence of a considerable depth of made ground in these locations is unsurprising. The works were built on higher ground, and as is confirmed within the appellant’s newly submitted evidence, the historic development of the northeastern part of the site involved far fewer phases than previously suggested. Insofar as C18th fabric survived well into the C20th, any surviving archaeology might lie much closer to the surface than previously claimed. 21. The attachment of ‘New’ to the name of the Moulding House recorded within the northeastern part of the site in 1753 implies that it post-dates other moulding houses shown on the same plan. It might thus have been added during the era of Abraham Darby II rather than Abraham Darby I. Either way, it formed part of the ensemble of buildings likely to have been established on site by the latter. If they survive, the remains of the New Moulding House, and https://www.gov.uk/planning-inspectorate 4

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 those of any broadly contemporary structures, would hold considerable significance directly contributing to the OUV of the WHS. Within this context ICOMOS views it essential that all aspects connected with Abraham Darby and his production processes are conserved. In broad terms this appears to be an approach supported by Policy BE3. 22. As noted above, the New Moulding House, together with the range of generally similar buildings to which it had been attached by the 1840s, are shown on C20th photographs. As some of these photographs also feature the compressor house and the railway line along the east side of the site, these provide useful points of reference. 23. It is apparent within these photos that the New Moulding House and others within the group stood at a lower level than later buildings adjacent. The extent of difference varied, indicating general inconsistency in ground levels. Whilst the extent of difference is now reduced, evidencing some subsequent increase in levels, variation continues to be a feature of the northeastern part of the site.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. This is illustrated by the shed which currently stands in this location, whose ridge height shows a drop relative to the compressor house, and whose internal floor level lies significantly below that of the adjacent railway track bed. Each are similar characteristics of buildings shown in old photos. 24. A 3.2 metre deep trial pit dug as part of ground investigations within this shed identified made ground. This included demolition material, within which features recorded as a ’brick floor’ and ‘backfilled basement’ were identified at 1.2 and 1.25 metres depth. Similar observations at similar depths were made in relation to some other trial pits in the northern part of the site. These remains are more generally described within a related report as ‘buried structures’. The investigation was not undertaken for archaeological purposes, and the appellant suggests that these descriptions should not be taken literally. However, no more detailed record has been set before me, and it would appear more likely than not that the pits and trenches contain material related to the buildings which previously stood within the same locations. 25.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Though the appellant asserts that C18th components of the works were built on the natural ground surface and that any archaeology must therefore lie beneath the 3.2 metres of made ground identified, there is no certainty of this. Whilst it is possible that C18th buildings were themselves constructed on made ground, even if they weren’t, ‘standing’ lower portions of C18th structures may survive within the made ground identified. Indeed, given that demolition material appears to have been used to build up levels, it cannot be assumed that structures were necessarily demolished in totality. It is however clear that any surviving remains of the New Moulding House and adjoining buildings do not lie at anything approaching the 10-15 metres depth previously claimed. 26. A raft foundation on top of an engineered pad has been designed for the 4- storey block proposed for the north of the site. Construction of the pad would require excavation of 1.8 metres below the floor level of the existing sheds. Based on the trial pit this would be deep enough to encounter the remains of previous buildings.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. It was further confirmed that intervention would be required below 1.8 metres in relation to any significant voids detected, including those which might be formed by buried structures. The supporting evidence states that it would be necessary for such features to be ‘grubbed out/filled’. As voids https://www.gov.uk/planning-inspectorate 5

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. It was further confirmed that intervention would be required below 1.8 metres in relation to any significant voids detected, including those which might be formed by buried structures. The supporting evidence states that it would be necessary for such features to be ‘grubbed out/filled’. As voids https://www.gov.uk/planning-inspectorate 5

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 have been identified in ground investigations of the north of the site, interventions of this type cannot be ruled out. 27. Whilst preservation in situ may be something supported by Policy BE8 of the Local Plan, based on the above I can have little confidence that the proposed approach would safeguard C18th archaeology on site. Even if it did, the remains would become significantly less accessible than at present, partly sealed below a 4-storey residential block sat on 3 metres depth of floor, foundation and pad construction. Any archaeology sealed beneath the proposed flood channel immediately to the north would be similarly inaccessible. 28. It is argued that any C18th archaeology is inaccessible anyway and might be hazardous to excavate. However, this is at least partly based on assumptions of its depth, which are either inaccurate and/or remain to be archaeologically tested. Interested parties further suggest that advances in technology may enable non-destructive investigation within a much shorter future timeframe than has been assumed by the appellant. Such advances cannot be ruled out. 29.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. A condition has been proposed that would secure archaeological investigation of any remains encountered. Assuming that such remains exist, the Framework however indicates that the ability to record the past should not be a factor in deciding whether loss should be permitted. I appreciate that Historic England recommended a condition of the type proposed. Again however, it is apparent that its recommendations were based on the assumption that C18th archaeology was so deeply buried it was unlikely to be disturbed. 30. In view of my findings above, I conclude that the appellant has failed to convincingly demonstrate that the scheme would not have a harmful effect on on-site archaeology, and the contribution that it makes to the OUV of the WHS. (b) Listed building 31. The scheme would partly involve residential conversion of the compressor house, and reconstruction of the previously attached pattern house. As noted above, these form or formed small parts of a Grade II listed building otherwise located off-site. This is identified as the ‘former erecting and assembly shops’ within the statutory list.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Insofar as it is relevant to these appeals, the special interest and significance of the listed building resides in the role of its various parts in relation to the industrial processes historically undertaken across the Coalbrookdale Works site. In this way the listed building also positively contributes to the OUV of the WHS and character and appearance of the Conservation Area. 32. Whilst the external detailing of the compressor house generally mirrors that of the main body of the listed building, it also exhibits highly specialised design in the form of a rooftop water tank. This open-topped feature, which can be viewed from above from Wellington Road, was used to supply water for cooling machinery housed below. It thus directly relates to and illustrates the historic function of the building. In the absence of any other clear evidence of past function, it is a particularly significant feature whose past operation was described by interested parties who witnessed it. In this regard the appellant’s plans notably omit certain distinctive details of the existing roof top construction. https://www.gov.uk/planning-inspectorate 6

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 33. The demolished pattern house appears to have been a structure appended ad hoc to the side of the compressor house. Though it shared some general details in terms of external appearance, it lacked the specialised design of the compressor house. Its individual significance and the contribution that it made to that of the listed building as a whole appears to have been low. 34. I have been presented with very little detail of the works proposed. The plans, which as noted above, are incomplete, lack any more than the simplest annotation. There is no supporting specification, and no method statements covering basic matters. Though some works are discussed within the supporting Heritage Statement, it was confirmed at the Hearing that some of these works, including replacement windows, are not in fact proposed. Considerable uncertainty thus exists in relation to how the works would be undertaken, and what they would fully entail. Interested parties present at the Hearing complained that the poor level of supporting evidence provided by the appellant contrasted with that normally sought by the Council from householders.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Whilst works proposed to the listed building might in this case form a very minor component of a broader housing scheme, this does not indicate the appropriateness of presenting and assessing such works more or less in outline. 35. The Act sets out provision to attach conditions to listed building consents, and the Council is content to leave consideration of almost all key details to a later stage. But the Act’s provision to attach conditions is made in light of the decision-making duty to have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. This duty cannot be properly discharged in the absence of appropriately detailed information. 36. The appellant’s intention to remove the tank and use its sides as a balustrade for a new flat roof was nonetheless confirmed at the Hearing. As this new construction would not hold water, this one distinctive, specialised and publicly visible feature of the compressor house would be lost. So too would the ability to clearly appreciate its past presence, and to interpret the past function of the building. 37.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Both main parties have advanced the view that the scheme would secure the optimum viable use of the parts of the listed building in question. This is notwithstanding the fact that neither party had apparently considered whether the proposed residential use would be compatible with that of the remainder of the building as a function space. The concept is in any case of doubtful relevance to the pattern shop given that it no longer exists. The Council furthermore confirmed that its reconstruction could be alternatively secured. It was additionally confirmed that apart from low key marketing of the site as a whole, no alternative uses have been considered. The scheme therefore again suffers a lack of supporting evidence, and I cannot conclude that the proposed use is the optimum viable use. 38. Historic England has provided support for reconstruction of the pattern shop and reuse of the compressor house. This support is not however based on the detailed assessment of the works that would be required to deliver reconstruction and reuse. The lack of information would have made any detailed assessment impossible. https://www.gov.uk/planning-inspectorate 7

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 39. The compressor house forms a small part of a much larger listed building, but one which is nonetheless both conspicuous and of specialised design. To the extent that it is possible to assess the works proposed I cannot conclude that the scheme would do anything other than appreciably harm the significance of the listed building as a whole. It follows that the works would undermine the positive contribution that the listed building makes to the OUV of the WHS and the character and appearance of the Conservation Area. (c) Settings, Conservation Area 40. The site’s former use is currently appreciable given the C20th industrial buildings with which it is largely covered. Except for the compressor house and remains of the ‘wing shop’ in the south eastern part of the site, these buildings and structures hold limited significance in themselves. They nonetheless demonstrate the final phase in the site’s long industrial history, and in this way contribute to the OUV of the WHS and the significance of the Conservation Area.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Insofar as it is currently visible from outside, the site also continues to provide a functional setting within which both the listed building, and other listed historic industrial buildings to the north are broadly experienced. This reflects their shared background as parts of the historic Coalbrookdale Company works. 41. The potential for redevelopment of the site is broadly agreed, including by ICOMOS. The manner of redevelopment is not. Here the Framework highlights the importance of taking opportunities to enhance or better reveal significance. 42. The scheme would broadly entail clearing the site and construction of housing. This would include repair of the C18th retaining wall along Wellington Road, and the remnants of the wing shop would be conserved within a ‘reimagined’ form. Each would deliver modest enhancement. The saw tooth roof profile of terraced buildings would otherwise subtly evoke that of the existing sheds, and the layout would provide an echo of the tracks which historically served the site. Exposure of the Coal Brook would additionally allow this important feature to be viewed, albeit within a new position.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. However, though each would be positive features of the scheme, against this must be set the harm that I have already identified above. The designs of the 4-storey block of apartments and 3-storey terrace proposed for the northern part of the site would furthermore demonstrate little connection to the history of the site. 43. The site currently contains some substantial rectilinear metal-clad structures, and historic development on site included at least one relatively modest 3- storey brick building. However, insofar as ‘traditional’ industrial styling has been proposed, neither the building forms nor their detailed designs would find any historic precedent on site. They would instead draw upon the designs of industrial buildings elsewhere. Here the Design and Access Statement confirms that the proposed 3-storey terrace has taken inspiration from a modern development which in turn took its inspiration from part of the C19th ceramic works at Coalport; buildings therefore associated with a different historic industry.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Though it may be that these buildings exhibit some generic warehouse/workshop-like characteristics, the design approach adopted would do little to specifically reinforce the historic identity of the appeal site, or to assist in understanding or illustrating its past use. ICOMOS highlighted the issue at an earlier stage in the process, and its concern was evidently well founded. https://www.gov.uk/planning-inspectorate 8

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Though it may be that these buildings exhibit some generic warehouse/workshop-like characteristics, the design approach adopted would do little to specifically reinforce the historic identity of the appeal site, or to assist in understanding or illustrating its past use. ICOMOS highlighted the issue at an earlier stage in the process, and its concern was evidently well founded. https://www.gov.uk/planning-inspectorate 8

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 44. The appellant has proposed to provide on-site interpretation, but it is unclear how the design approach adopted would be explained. Indeed, the ability of the site itself to convey its historic significance and relationships would be directly compromised by the designs of the buildings in question. More so when also considering that the bulky 4-storey block would substantially obscure part of the site which hosted the C18th works. Though the same location is obscured at present, the existing building is a shed whose design is both authentically industrial and directly related to the past use of the site. 45. The proposed designs could also confuse perception of the relationship between the site and the rest of the historic Coalbrookdale Company works to the north. Ordinary observers could well find it hard to understand the way in which modern buildings exhibiting borrowed historic characteristics fit within the broader industrial landscape.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. As well as diluting the integrity and authenticity of the latter, the role that the site plays in appreciation of the significance of the listed building, and that of other listed buildings to the north would be undermined. This would not be offset by the greater level of visual connectivity that would exist with buildings to the north along the west side of the site, given that this would simply accentuate scope for confusion. 46. Historic England has expressed satisfaction that the scheme ‘speaks to the late industrial character of the valley floor’. But that view is hard to reconcile with the designs of the proposed 3 and 4-storey buildings which, as outlined above, exhibit no obvious affinity with the late industrial development of the site, or its earlier history. Again, as Historic England did not attend the Hearing its reasoning remains unclear. 47. From some external perspectives the site is currently well screened by trees. This screening appears to be of relatively recent origin and its quality is mixed. Maintenance of the site’s screening would not avoid perception of the adverse effects noted above.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Whilst elevated views into the site would continue to exist, the site itself would be publicly accessible and thus more capable of being viewed and experienced within context than it is at present. 48. The site is vacant. The condition of the buildings on it is poor and likely to deteriorate further. But whilst the scheme would see the site tidied and reused, providing some minor heritage benefits in the process, my findings above indicate that its overall effect on designated heritage assets would be to harm rather than to conserve or better reveal their significance. 49. For the reasons outlined above I conclude that the development would fail to preserve the setting of the listed building, and that of other listed buildings, and fail to preserve or enhance the character or appearance of the Conservation Area. For much the same reasons it would also fail to conserve the OUV of the WHS. Balance 50.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. I have concluded above that the scheme would fail to preserve the listed building and its setting, fail to preserve the settings of other listed buildings, fail to preserve or enhance the character or appearance of the Conservation Area, and fail to conserve the OUV of the WHS, with harm to the latter partly due to the likelihood of adverse effects to on-site archaeology. In each case the harm caused to the significance of the heritage assets in question would be less than substantial. Such harm attracts considerable importance and weight in https://www.gov.uk/planning-inspectorate 9

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. I have concluded above that the scheme would fail to preserve the listed building and its setting, fail to preserve the settings of other listed buildings, fail to preserve or enhance the character or appearance of the Conservation Area, and fail to conserve the OUV of the WHS, with harm to the latter partly due to the likelihood of adverse effects to on-site archaeology. In each case the harm caused to the significance of the heritage assets in question would be less than substantial. Such harm attracts considerable importance and weight in https://www.gov.uk/planning-inspectorate 9

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 relation to the Conservation Area and settings of listed buildings, and great weight in relation to the listed building itself and the WHS. In accordance with the Framework, it is necessary to balance this harm against the public benefits of the scheme. 51. Heritage benefits advanced in favour of the scheme have formed part of my assessment above, in relation to which I have already established overall harm. The main parties each otherwise agree that the scheme would deliver the optimum viable use of the site as a whole. As considered above, this is a concept referenced within the Framework, specifically in relation to designated heritage assets. Though the site falls within the WHS and Conservation Area, these are area-based designations to which the concept cannot be meaningfully applied. Insofar as the only designated heritage asset within the site itself is the listed building, I have again already dealt with the matter above. Even were I to apply the concept more broadly, given that little effort has been made to explore sensitive alternative uses of the site, evidence is lacking.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. To the extent that viability has otherwise influenced the scheme this has been specifically in relation to delivery of housing. As it cannot be concluded that the appeal scheme delivers the optimum viable use of the site, this is not a consideration to which I attach weight. 52. The scheme would entail the reuse and remediation of a disused brownfield site, providing a modest boost to the local supply of both open market and affordable housing. I attach moderate weight to the linked social, economic and environmental benefits. 53. Flooding is a problem within the dale, and bringing the culverted brook to the surface might benefit areas downstream by providing increased attenuation. This would also help to meet an objective set out in The Ironbridge Gorge World Heritage Site Management Plan. The site itself falls within Flood Zones 2 and 3. But though national policy clearly sets out the requirement for application of the Sequential Test in these circumstances, this has not been applied, and nor therefore has the Exception Test. The main parties instead take the view that these tests are unnecessary.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Work undertaken in consultation with the Environment Agency has established ‘dry areas’ within the site which correspond to building footprints. It is proposed that these areas would in effect be redistributed within the footprint of the proposed development. Other measures, including works to the culvert, would be taken to ensure both that the development would be safe from flooding during its lifetime, and that flood risk would not be increased off site. These considerations are not however directly relevant to the Sequential Test, whose primary purpose is to direct development to areas at least risk of flooding, and whose concern is therefore with initial site selection. Even assuming that the Sequential Test was passed, the Exception Test sets out the expectation that flood risk should be reduced overall. That being so, and given that the absence of testing raises broader questions over the appropriateness of the location, the claimed improvement is a benefit to which I attach only limited weight. 54.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Though the scheme would therefore be capable of delivering a number of public benefits to which together attract moderate weight, this would not outweigh the harm I have identified in relation to designated heritage assets above. Whilst, in relation to the listed building, it remains doubtful whether public benefits can ever exist as justification for the provision of inadequate https://www.gov.uk/planning-inspectorate 10

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Though the scheme would therefore be capable of delivering a number of public benefits to which together attract moderate weight, this would not outweigh the harm I have identified in relation to designated heritage assets above. Whilst, in relation to the listed building, it remains doubtful whether public benefits can ever exist as justification for the provision of inadequate https://www.gov.uk/planning-inspectorate 10

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 information, clear and convincing justification for the harm that would be caused by the appeal scheme is otherwise lacking. 55. For the reasons set out above I conclude that the effects of the scheme on the WHS and other designated heritage assets would be unacceptable. In relation to Appeal A, the scheme would therefore conflict with Policy BE3 of the Local Plan 2018, which, as outlined above, seeks to protect and enhance the OUV of the WHS, including its archaeology; Policy BE8 of the Local Plan, insofar as the development would be likely to result in the loss of, damage to or otherwise adversely affect archaeology on site; Policies BE4 and BE5 of the Local Plan which support the application of national policy in relation to listed buildings and conservation areas respectively; and Policy BE1 of the Local Plan, given the scheme would not as a whole respect and respond positively to its context. In relation to both Appeals the scheme would fail to satisfy the requirements of the Act, and heritage policy as set out within the Framework. Conclusion 56.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — I have dealt with the appeals together, except where otherwise indicated. For the reasons set out above the effects of the scheme would be unacceptable, and in relation to Appeal A, would conflict with the development plan taken as a whole. There are no considerations which alter or outweigh these findings. I therefore conclude that Appeals A and B should be dismissed.

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — Benjamin Webb INSPECTOR https://www.gov.uk/planning-inspectorate 11

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — Benjamin Webb INSPECTOR https://www.gov.uk/planning-inspectorate 11

Coalbrookdale Works, Wellington Road, Coalbrookedale, Shropshire, TF8 7DX — Telford and Wrekin Council — Benjamin Webb Appeal Decisions APP/C3240/W/24/3340261 and APP/C3240/Y/24/3340266 APPEARANCES For the Appellant John Branson (Flooding/Drainage) Wardle Armstrong Andrew Croft (Heritage) CBA Studios Ian Kilby (Planning) Berrys Carl Hanson (Engineering) Cox Baker Susana Parker (Archaeology) RPS Rob Perrins (Appellant) Shropshire Homes Howard Thorne (Appellant) Shropshire Homes For the Local Planning Authority Penny Stephan (Planning) Telford and Wrekin Council Dr Andrew Wigley (Heritage) Telford and Wrekin Council Valerie Hulme (Planning) Telford and Wrekin Council Andrew Gittins (Planning) Telford and Wrekin Council Lucinda Lycett (Flooding/Drainage) Telford and Wrekin Council Interested parties Marion Blockley Former chair of Ironbridge Gorge WHS Steering Group Maureen Bragg Gorge Parish Council Chris Harrison Local business owner Carolyn Healy Ward Councillor Viv Moore Ironbridge Civic Society Claire Studd Coalbrookdale Flood Action Group Documents presented at/after the Hearing Amended hearing venue notification letter. Former Aga Works – Historic Plans, Maps, Photos and Other Images 25/06/24. Network Rail correspondence. Sabbath walk leaflet. https://www.gov.uk/planning-inspectorate 12