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To campaigners the East Greenwich No1 Gas Holder is as iconic a part of the Thames skyline as the towers of Canary Wharf
[Banner Image:  thePipeLine]

Energy giant SGN and its consultant Firstplan, are facing criticism following allegations that SGN is seeking permission to demolish the historic East Greenwich No 1 Gas Holder on the basis of, what campaigners to save the structure say is, a fatally flawed planning statement.  Critics argue that the statement, submitted by Firstplan on behalf of SGN to the planning authority, the Royal Borough of Greenwich, fails to take into account a key change in heritage policy at the Royal Borough of Greenwich.  Critics of the demolition plan, including the Greenwich Industrial History Society, as well as experts on the history of the gas industry, argue that the document submitted in support of the request to demolish the building as a permitted development which does not require planning permission, is inaccurate in parts and crucially is also out of date.  The allegation is made because the statement fails to quote and ignores a key change to the planning brief for the area around the gas holder, voted by the cabinet of the Royal Borough of Greenwich in November 2017, before the application was lodged.  The policy change recognises the heritage value of the gas holder and asks would be developers to come up with solutions which recognise and enhance that value.  However, Firstplan contradict the council’s view in their planning statement and say that demolishing the gas holder,

“… should not be objectionable in heritage terms.” 

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Having survived the Silvertown Explosion of 1917, as well as attacks by the Luftwaffe and the IRA, the East Greenwich gas holder is one of the last visible signs of the industrial history of Greenwich Peninsula and in particular of the massive East Greenwich Gasworks which many experts agree is of national importance in the history of the UK energy industry.   As a result, campaigners attempting to stop SGN’s bid to demolish the gas holder argue that, in seeking to demolish the building as soon as possible, the company, which still owns and operates gas distribution equipment on the site, is showing contempt for the heritage value of the gas holder.

Critics of SGN also point out that the reuse of gas holders and gas holder sites is seen increasingly as an opportunity for imaginative development and place building.  As a result they argue that the energy company should be engaging with the Royal Borough of Greenwich, along with heritage and tourism bodies and sympathetic developers, to maximise the community value of a significant heritage asset.  Albeit one perhaps undervalued by Historic England which granted SGN controversially a certificate of Immunity from Listing [CoIL] which prevents the structure from being protected by any statutory instrument for five years.

It is also argued that, by going down the route of seeking immunity from listing and demolition, SGN is demonstrating a singular lack of imagination given the successful reuse of similar gas holders all over the world including in Dublin and at Kings Cross, also in London.  This trend was highlighted in a recent competition to run by the Royal Institute of British Architects [RIBA] on behalf of the National Grid, which challenged architects to find new uses for the sites of redundant gas holders.  The competition was won by new architectural practice Outpost.

Instead, in a planning statement submitted to the Royal Borough of Greenwich on behalf of SGN by consultants Firstplan, Firstplan argue that,the proposed dismantling should be considered as a permitted development under Part 11, class B ‘Demolition of Buildings’ of the Town and Country Planning (General Permitted Development) Order 2015 (GPDO).

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The Planning Statement states this explicitly,

“2.12.  The proposed dismantling is considered permitted development under this order,”

However SGN cannot simply move directly to demolish the gas holder because,

“…it is necessary to establish whether prior approval is required for the method of dismantling and proposed restoration of the site, through the submission of the enclosed prior notification application.”

In other words, it is necessary to find out if the Royal Borough of Greenwich must approve the way the gas holder would be dismantled, not the actual principle of dismantling the structure itself.

Firstplan add later that,

3.8 The removal of the gasholder is also a necessary requirement for any future site redevelopment. The proposed removal will enable a more productive use to be established on what will be a redundant brownfield site within the Greenwich Peninsula of good redevelopment potential as potentially earmarked for mixed / residential use.

However, critics of the proposed demolition argue that this assertion on the part of Firstplan is simply is not true.  They point out that, far from demolition being a requirement for future development, the gas holder has been made central to the planning brief for the area around the gas holder.  The revised plan was approved by the cabinet of the Royal Borough of Greenwich in November 2017, before the application to demolish the gas holder was submitted.

In its revised planning brief for the area in which the gas holder stands, the council stipulate,

“Proposals should reflect and respond to the industrial character of the area as a means of relating new development to the local context. In particular, development should build on the heritage value of the gas holder to enhance the character and distinctiveness of the area.

“This could be achieved through a variety of means. For example, the retention of all or part of the structure within a public open space or building, or reinterpretation of the structure and its industrial history through the design of building façade details, public realm/landscaping or the layout of the development. Prior to any work to the gasholder, heritage and structure surveys are required.”

Critics argue that as a result of this failure on the part of the consultants the First Plan/SGN to cite this new policy the document is out of date and any application based upon it is thus fatally flawed.

One of those is local expert Peter Luck who told thePipeLine,

“Although the new clause (4.5.2), as part of the revised Planning Brief does not carry full statutory authority,  it is ‘a material consideration for future planning applications for Site GP3 where the gas holder is located (clause 1.4.3 of the Royal Borough of Greenwich Brief).

In view of this, and the SGN proposal being clearly contrary to the requirements of the new clause, an Article 4 direction under the General Permitted Development Order should be issued as a matter of urgency, revoking the permitted development status of the proposed demolition.”

Ultimately the fate of East Greenwich No 1 lies in the hands of councilors at the Royal Borough of Greenwich.  The decision must be made at a time when those councilors face reelection in the London wide Local Elections in May and one question campaigners are adamant they will face on the doorstep is whether they believe a signature building, on the skyline of a borough which promotes itself largely on its heritage and the presence of a World Heritage Site, can be denied to posterity so easily by what a commercial company claims to be a permitted development?

The question is particularly pertinent as it is increasingly clear from polling and other research that many voters feel local heritage and the sense of place are important to a sense of community and there is evidence from a previous consultation by the Royal Borough of Greenwich that the local community is indeed concerned by the fate of East Greenwich No 1.

Data detailed in Greenwich’s consultation statement of October 2017, showed that of 65 representations made to the council, 47 supported the retention of the holder.  A further 11 were neutral or concerned exclusively with other matters.  A mere 7 submissions supported the proposed demolition, only one of which came from a local resident.  Importantly five expert and amenity groups, the Association for Industrial Archaeology, the Woolwich Antiquarian Society, Victorian Society, Greenwich Conservation Group, and Greater London Industrial Archaeology Society opposed demolition. Another significant local voice, the Greenwich Society, remained neutral.

All of the Royal Borough’s Councillors face reelection in the May Local Elections and in many seats a few votes can make all the difference.  However, before that vote happens, SGN may well be asking its consultant Firstplan why the planning statement which Firstplan authored and submitted as part of a legal process could be subject to risks including potentially a Judicial Review, because it failed to take into consideration a key change in council planning policy.  A policy which names specifically the building which is the subject of the SGN’s application?

The question campaigners would like to ask SGN is was the consultant’s omission down to incompetence in that Firstplan took their eye off the ball in what they saw as a routine application and failed to update their document in key areas, or did Firstplan hope cynically that the Royal Borough of Greenwich Councillors voting on the application, would not remember their own policy and nod through the demolition of one of their borough’s most iconic buildings?

thePipeLine approached Firstplan by e-mail with a number of questions, including asking why the consultancy had failed to update its statement to acknowledge and discuss the revised planning brief citing the central importance and potential reuse of the East Greenwich No 1 gas holder, approved by the cabinet of the Royal Borough of Greenwich.

Up to the time of publication Firstplan have not replied.

SGN, on whose behalf Firstplan submitted the application to demolish North Greenwich No 1 gas holder told us,

“SGN is regulated by Ofgem and we have been tasked with dismantling all of our gas holder fleet by 2029. This is due to the societal risks these redundant structures pose to our workers and the wider public (maintenance, environmental and health and safety risks). In addition, our industry has now found a way to store gas within underground pipe networks.


It’s no longer sustainable for us to keep these structures in a safe and visually acceptable condition long-term. We’re also committed to redeveloping the land they sit on for use that’s more beneficial to the local community, such as housing and business premises.”

thePipeLine approached regulator Ofgem regarding SGN’s assertion that the demolition of East Greenwich No 1 was a requirement.  A spokesperson for Ofgen told us,

“I can confirm that there are requirements through our price controls for the gas distribution networks such as SGN to decommission gas holders.”

thePipeline is awaiting Ofgem’s response to the question as to whether the decommissioning of gas holders, which in any case is not the same as demolition, is a legal requirement, and whether issues such as listing, or the decision by local authority planners to stipulate the retention and reuse of such structures override any requirement to decommission or demolish.  The fate of two other gas holders, Kennington Oval and Old Kent Road No 13, both of which have been listed, suggest that it does.

It is possible to say this because regarding the heritage issues around the demolition of gasholders SGN themselves pointed this out in their statement to thePipeLine,

“Recognising the importance that gas holders represent as part of our industrial heritage and to formulate our dismantling strategy, we commissioned an independent company (Montagu Evans) to carry out a full heritage assessment of all our gas holders. This assessment was presented to Historic England for their review. As part of the review, Historic England required detailed building recordings of a number of gas holders, including Greenwich, which we are committed to doing. Two of our gas holders Kennington/Oval and Old Kent Road number 13 have been listed based on their special architectural or technological rarity.

Historic England’s criteria for listing of industrial structures/sites is available here:

As part of our dismantling programme we are committed to celebrating and capturing the history of our gas holders. We understand that to many, these iconic structures act as a visual reminder of a town’s history. Therefore, we are working with communities, local history groups and museums to ensure each holder we dismantle has its history captured for future generations to learn from.      

Along with local activities and exhibitions, drone surveys and, where possible, time lapse videos are being created. These are being donated to local museums and interest groups.”

However, when this last point was put to one of the Greenwich campaigners the response was pointed,

“Regarding the claimed intention to document and donate to museums and local interest groups, I think Royal Borough of Greenwich (and heritage groups) would be justified in saying ‘let’s see it’ before any consents are given.”

Comments regarding the proposal to demolish the East Greenwich No 1 Gas Holder must be made to Greenwich Council by the end of today [11 January 2018], quoting Application  17/4068/D1

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thePipeLine is an independent news publication that investigates the place that heritage, politics, and money meet.

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