GO AHEAD FOR LINCOLN HOTEL POOL PLAN COULD REDUCE SAFEGUARDS FOR NATIONALLY IMPORTANT ARCHAEOLOGY

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Just months after UK Heritage bodies failed to protect the concept of setting by allowing Shropshire Council to give the green light to a housing development close to the nationally important Old Oswestry Hillfort against the advice of major heritage bodies including Historic England, another planning case, this time in the historic cathedral city of Lincoln, threatens to set a legal precedent further reducing the protection the planning system offers even our most important archaeological sites.

The threat has arisen because local developer Mr Andrew Long has filed a planning application to excavate a swimming pool as part of a programme of work at the Grade 2 listed White Hart hotel in Bailgate, sandwiched in between Lincoln castle and Lincoln cathedral, and close to the historic centre of Roman Lincoln.

The heritage impact assessment submitted with the planning application notes the highest levels of heritage protection within the immediate area of the White Hart, including thirty seven listed buildings, as well as a large number of Scheduled Ancient Monuments, including a scheduling which covers much of the uphill area of Lincoln and which has stood for decades.

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Mr Long’s Travel Sector Property Group purchased the White Hart in 2022 as part of what Mr Long has described on the White Hart hotel website as,

“… a major redevelopment and significant overall enhancement scheme for the St Paul’s Lane, Bailgate and Castle Hill quarter of the city.”

The scheme also includes the Grade 2* listed early 19th century Judges Lodgings which Mr Long purchased from Lincolnshire County Council in 2023 on a 999 year virtual freehold.

However, while archaeology is not a block to sensitive development, Mr Long’s current planning application is controversial because the swimming pool project is sited in one of the most archaeologically important areas of one of the UK most historic cities, which has a history dating back to at least its foundation by the famous Ninth Legion Hispana [of Eagle of the Ninth fame] and where well preserved, deeply stratified archaeology has been observed and recorded since at least the nineteenth century. Archaeology which is protected by legislation and by national and local planning guidelines, which identify Lincoln’s archaeology by default as being of national significance.

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The swimming pool project would result in a slot in excess of thirteen metres by five metres by two metres deep being cut into the stratified archaeology, where an evaluation has already demonstrated that medieval walls are present and which a one of a growing number of critics of the proposed pool, geoarchaeologist and TV Producer Dr Samantha Stein, points out is close to Roman structures recorded in the nineteenth century, but which seem not to have been included in the desk based assessments for the current project.

At the core of the opposition to the proposed pool is the fact that the National Planning Policy Framework [NPPF], which underpins all planning decisions in England, states that the greater the importance of the archaeology thought to be present the greater must be the justification in terms of public benefit for its destruction.

In that light Mr Long’s swimming pool would seem on the basis of his own documents to be at the “nice to have” end of development rather than being economically essential to the success of the business.

An assessment of public benefit also submitted as part of the planning application estimates that the project will deliver just one and a half full time equivalent jobs and
a speculative additional two hundred thousand pounds per year to the local economy based on a claimed additional room occupancy at the White Hart. Even if that figure is accurate that is just five hundred and fifty pounds per day spread across the entire city and to critics of the scheme it hardly falls into the category of critical infrastructure, even critical local infrastructure, which could justify the destruction of nationally important archaeology.

Critics are also concerned that, in what seems to be another break with both the letter and intent of the National Planning Policy Framework, Mr Long’s archaeological impact assessment and statement of public benefits suggest that the existence of the archaeological work could itself represent a public benefit in terms of public engagement, when section 211 of the NPPF is specific that such a public benefit should not be regarded as supporting or justifying in any way the loss of archaeology, least of all nationally important archaeology.

Such statements are serious matter as they could have the effect of materially misleading the officers and councillors making planning decisions, especially as the Desk Based Assessment [DBA] commissioned by Mr Long as part of the planning process reminds both the developer, and the local authority planners, that,

“All open spaces within the boundaries of the Upper and Lower Roman city form part of Lincoln Roman Colonia [Lindum] Scheduled Ancient Monument [NHL 1005049]
and the archaeological remains inside the hotel are of equivalent significance and importance.”

The DBA also admits,

“…the adverse impact of the loss of a small area of nationally important remains cannot be denied…”

Yet as critics of Mr Long’s scheme argue, Lincoln’s planners appear to be allowing local policy and preference, for example for developing boutique hotels to support the City’s tourist offer, to trump national heritage policy set by Government through the NPPF.

Essentially, as was the case at Old Oswestry, in deciding Mr Long’s planning application Lincoln’s planning officers, and if it goes to committee its local councillors, have been placed in the position of interpreting and potentially deciding, national policy towards some of the UK’s most sensitive archaeology and according to critics including Dr Stein, the system of checks and balances which should protect that archaeology have been found wanting.

The critics argue that had the development system been working as it should, at some point before Mr Long’s application was even submitted, somebody in the planning system, either Lincoln’s planning officers, the City Archaeologist, or his own consultants exercising a duty of care towards their client, should simply have told the developer that the project was not compliant with local let alone the national guidelines in the NPPF and from Historic England and then rather than have it rejected out of hand to reconfigure the planned spa in a way which would be compliant.

Indeed, someone, certainly including his own consultants, could have suggested that, with the application of a little imagination, as has been done in a number of similar sites in Canterbury, York, and elsewhere when important archaeology has been uncovered during building works beneath later buildings, the excavations could be preserved for display, possibly even under a glass floor, making for a unique talking point which is arguably of much greater and longer lasting, public value than a boutique sized swimming pool for a boutique hotel.

Summing up what is at stake for the regulation of UK heritage if Mr Long’s application is given the go ahead by Lincoln’s planners Dr Stein told thePipeLine,

“The approval of this private pool development would be a loss for heritage, for archaeology, for national planning policy, and for the public.
It would be a culmination of poor council advice, lack of understanding of planning policy by developers, and lacklustre research.”

Dr Stein concluded with this warning to professional archaeological bodies and regulators, which include statutory consultee Historic England,

“If Lincoln City Council ultimately approve the application of a private pool within the White Hart Hotel, it would set a dangerous precedent for heritage across the country.”

Lincoln Council planning officers are currently deciding if the opposition to Mr Long’s application is such that it must go before a full public planning meeting rather than
simply being decided behind closed doors by council officers.

The consultation closes on 7 March and a decision about the White Hart application could come as soon as 9 April.

Meanwhile, having asserted that there was no significant archaeology present, Mr Long told the BBC Radio Lincolnshire that,

“I am at a loss to understand where Sam Stein is obtaining her information from.”

Dr Stein responded on X Twitter pointing out that she had read his own desk based assessment.

 

You can comment on the White Hart swimming pool development on the Lincoln City Council planning portal HERE.

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