Professional Critique of English Heritage’s current plans


The following is an updated version of the document of representation submitted to Richmond upon Thames Council in November 2017 giving expert evaluation of the planning application.

It should be read as expert evaluation and justification of the Community proposals

Green and italic indicates updates of Feb. 2018 including redactions



It is an approved submission on behalf of all campaigning users

If my grandchildren were to look at me and say “”you were aware species were disappearing and you did nothing, you said nothing”” That I think is culpable. I don’t know how much more they expect me to be doing. I’d better ask them”

David Attenborough, Richmond resident, naturalist and broadcaster.


This Report is dedicated to all the hard working residents across the Borough assisted by leading professionals in their fields. All are motivated by their love of the Park and a wish to save the environment for future generations and protect valued species from irreparable harm,






  • AP 3 TREES
  • AP 4.4 COACHES
  • AP 4.8 ECOLOGY
  • AP6 MINUTES MAY 2017


Photos of height of proposed restaurant in relation to South End House, Car Park AT Full Capacity, Badger activity and Orleans Road Congestion BY SEPARATE SUBMISSON


Writers and historians have often tended to view Marble Hill House in the same light as the majority of grand houses in England: A visible statement of ambition to climb or to consolidate the owner’s place in the aristocratic pecking order.

The Countess of Suffolk did not intend her House as a badge determining her social position. It was the exact opposite: she was quite deliberately turning her back on all things to do with court life and pursuing the one thing denied her to that date: independence. She chose a location fashionable for the rebel glitterati of the times. Her years of acquired skill at flattery and quiet observation, steering the obstinate and powerful to ideas they thought their own, worked well at Marble Hill, The fashion of the time was to be a landscape designer and she had no shortage of friends itching to transform her grounds.

Certainly first in the fray was Alexander Pope but his moods and spitefulness left many of the circle upset and later he cut off contact with the Countess. By 1731 she was having no answers to her correspondence. Charles Bridgeman as the King’s gardener and a professional was introduced for a technical view but confessed his preoccupation with Stowe. So we inherit passing references to certain things started such as ice house and grotto, and others seeming to take many years to fruition. Henrietta’s head gardener was known for his laziness and fondness of drink, not the kind of personality to drive a vision forward. His successor had a work specification that did not indicate a particularly ambitious plan.

The picture that emerges is one where for Henrietta, Marble Hill was a home, and a statement of her independence, where perhaps the luxury of not making decisions or following a plethora of advice was her delight.

We now know, lavish landscape ground plans at Twickenham did not materialise; but instead Henrietta’s friends were praising the meals and farm produce as beyond compare and it needed all the land, by calculation to run grazing and kitchen garden.. She ran a small farm there and delighted in her role as mother provider after a life as prisoner of others. She had friends buzzing with excitement at possibilities, and launched her second husband into tours of examples but he took a long time to assemble the lands and on death Henrietta sank into greater illness and depression and then debt. Meanwhile fashion in landscape changed and her neighbour mentors were transforming the land to natural tree groups and meadow. This was an economic solution to suit her temperament and purse as she was preoccupied with her niece’s security after her death.

“Oh I had wings of a dove, for then would I fly away to Marble Hill, and be at rest! I mean at rest in my mind, I am tired to death with politics and elections….” Letters 1734 pg 67



1.1 Local residents and Park users have formed a coordinated campaign to request the rejection of the current English Heritage proposals for Marble Hill House and Park. While they support the restoration of the House they maintain that the changes to the Park have a disastrous effect on the surrounding neighbourhoods, Biodiversity and traditional use of the park; and argue that a moderate scheme of Park changes should be followed that would necessitate compromise.

1.2 The design of the proposed restaurant is rejected as very harmful to the setting of the major Listed buildings in Montpelier Row, demolishing an historic Listed boundary wall to South End House and replacing it with an intrusive restaurant wall and roof of a far greater height, at the border of the 18th century South End House Garden. This destroys the historic relationship of 18th century Mansions and Gardens, with the Coach House and Gazebo. These views were written of by Walter de la Mare and the Row occupants are referred to in Henrietta Howard’s letters. The building proposals threaten established specimen trees in South End House garden which also form part of the protected view from Richmond Hill.

1.3 There is objection to the excessive size of the restaurant and its impact in terms of noise and smell on the adjoining residents and those generally of Montpelier Row. It impacts also in terms of inappropriate aesthetics and conservation practices as well as sun shadowing and noise from exterior dining crowds on the South End House Garden. There is complaint that no justification is provided by the applicant for the exceptional size and that a new restaurant could be far smaller with a less intrusive design and effect. Concern extends to noise, smells and service traffic, on Montpelier Row and litter and food in the park.

1.4 The loss of the current copses either side of the house is another major issue objected to. The campaign maintains that no serious account has been taken of the loss to wild life and especially endangered species known to inhabit them. This complaint is allied to the extensive loss of trees as now revealed,to te fact that original designs refer to them, and to the transformation of the woods by clearance and addition of paths, hedges and ornamental cultivation into controlled gardens. Campaigners point to the lack of any firm evidence of the actual realisation of historic garden ideas quoted in the application.

1.5 Local people in Montpelier Row, Orleans Road and Cambridge Park complain of traffic congestion and loss of parking already. Campaigners complain that the original application submission was inadequate and full of errors and that subsequent consultation meetings added to confusion by removing elements and then restoring them and changing online information.

1.6 The e mail record indicates that English Heritage was aware of serious traffic impact and directed expert evidence to present information acceptable for public consumption.

1.7 There is further complaint that outcome of discussions between English Heritage and neighbours has been misleadingly reported in the submission.

1.8 The published archaeology investigations to date has uncovered no evidence of the promoted landscape.

1.9 The following technical report addresses these concerns and examines   existing and new evidence. It finds:

  1. The information issued was erroneous and inadequate for the project given the area’s sensitive history. Professionals in the Borough acknowledge that LBRUT sets a high benchmark in the standard of information required for a submission. This fell far short and the support it might have gleaned is compromised by adjoining owners complaining that their comments have been misrepresented.(See Appendix AP1)
  2. Expert Information was instructed to be presented to avoid uncomfortable impact information
  3. The consultation process was misleading and failed to follow Royal Town Planning Institute Public Consultation Guidelines. These place responsibility on the applicant to show clear and unambiguous information suitable for online digest, with non technical summaries of submission, easily navigable and with active participation of locals in shaping the proposals by working party. There should not be sequential changes, verbal or written, that confuse.
  4. The presence of wild life in the copses and park is established and experts state this is now at risk through clearance, and restaurant litter and scraps that harm foraging.
  5. The restaurant is excessive in size and does not conform to Conservation Guidelines of Good Practice in design for a Conservation Area and beside Listed Buildings. It ignores or discounts harmful impact on major historic buildings of importance to Twickenham heritage.
  6. Submitted Traffic studies fail to factor in surrounding planned major traffic and parking generators or the major park events. They are erroneous in the summary of existing car park use. On and off-site surveys confirm existing congestion in Orleans Road.
  7. The issue of pollution is of major and unaddressed concern. The traffic pollution already exceeds intended targets in Richmond Road and the scheme fails to study this and takes no account of other traffic generators soon to come into operation affecting the road and area; and fails to factor- in the pollution from parking still intended on the grass for events. This is of special concern for a park and for school proximity.
  8. Technical Reports submitted have fundamental errors that change supporting conclusions.
  9. The proposed balancing planning gain of additional trees does not exist, as the gain is minimal and simply equates to expected management. It does not outweigh the increase in carbon footprint of proposals, health harm and habitat damage.
  10. The historical case is not supported by any archaeological evidence. Experts disagree with the submission’s original case that Alexander Pope’s design was installed. The applicant now attributes the installed design o others. The weak planning case promoting greater public benefit from the link to Pope outweighing the substantial harm to listed building settings is unproven and the case for an inappropriate design and size of restaurant falls apart. The last archaeology report in September 2017 found no evidence in either the copses or the wider landscape to prove the existence of the design. It confirmed that the land terraces were natural and not, as suggested, evidence of land forming.
  11. The proposals concentrate on events, sport and fitness and fail to present the Park as a medium for physical and mental health across all ages and frailties and disabilities in line with 21st century Good Practice and Natural England recommendations ; In particular the preservation of Park and community legacy and place of repose within the Thames green corridor of Twickenham.
  12. Some supporting organisations have ties to English Heritage that render their views as unobjective where they offer support. This must be checked.
  13. The clearance of the copses is in direct contradiction to the Boroughs LBAP Biodiversity Action Plan which designates the Park.




1.1 The report evaluates the submission in the light of primary concerns of, and registered objection by, local people, neighbours and park users. It is prepared at their request.

  1. TREES AND COPSES. The large number of trees to be felled has major impact, and with the clearance of the copses represents a major change to landscape which is not compliant with policy. E mails show the presentation was misleading (see Appendix3. The copse clearance is in contradiction of the Policies laid down in the Borough’s Local Biodiversity Action Plan to protect ageing scrub and wood and in which Marble Hill Park is designated, The management contracts of the era show the copses were original.
  2. ENDANGERED SPECIES. The clearance destroys habitat in the copses which are home to protected species. Crowd litter and food from mass catering will be harmful to foraging species. The retention unchanged of these reservoirs of natural habitat is required by Planning Policy
  3. LISTED BUILDING IMPACT. The harmful visual impact of the proposed restaurant has been inadequately addressed. It   is intrusive to the setting of adjacent listed buildings and noncompliant with Planning Policy. There are clear alternatives not presented to the public and proven examples under HLF funding of equivalent catering in smaller facilities for similar size parks and visitors.
  4. NOISE AND ODOUR. The noise and odour assessment of the restaurant is not robust. Recordings and projections fail to cover in-use breaches of sound containment, sound shadowing, projection over the wall into the adjoining garden, and external crowd dining noise. It also ignores the peak usage impact for events.
  5. INADEQUACY OF PARKING. Independent data on existing car parking usage and spare spaces shows an overload already exists. The current submission states the streets will take the overflow. It   fails to include the concurrent impact of large Park Events, current growing pitch use, planned nearby major use already approved and other Twickenham events.

POLLUTION. Richmond Road already exceeds its Policy limit on pollution and this will be aggravated in spite of being a designated Pollution Aware Walking Route (1) and passing beside schools. Increase in carbon footprint and lack of sustainable proposals are non compliant with   NPPF Core Policy

  1. HISTORICAL PROVENANCE. The evidence is that Pope’s design for the landscape was never installed and that the drawings found in the Norfolk Record Office on which the submission is based were either not his or were never built. As a result the historical claims are far from robust and a change to design is possible.
  2. INFORMATION AND PUBLIC CONSULTATION .The process of public consultation does not comply with the Royal Town Planning Institute Good Practice Guide for public engagement. Many errors and contradictions in information have been noted by Campaigners. E mails (see Appendix 4)show that the applicant shaped the issue of expert information to minimise apparent harmful impact
  3. PUBLIC INTEREST. The Report concludes that the failure of archaeology to support contentions, and the weakness of case for supposed designers ,taken with flawed impact reports results in the applicant failing to make a case for supporting damaging impact around and in the site.



3.1 The LBRUT Development Management Plan 4.1.2 states that views into and from historic parks and gardens on the register (Designated Major Development “Marble Hill Park” (3) are protected from development which would adversely affect the character. Policy DMOSS requires development to preserve and enhance existing habitat with the aim to attract wildlife and protect biodiversity

3.2 The case is made by objectors that the park as it stands is a long established landscape in its own right, and that the character will be changed; that there has been no issued archaeology evidence that supports a change to gardens as proposed and that the historic justification is thin. (Section 14.1.8)

3.3 The English Heritage argument is that public interest in the creation of a landscape that may or may not have existed over a few decades and the additional new restaurant , outweigh the public interest in preservation of longer established landscape , views and uses and harm to established Listed Building relationships. This is unsound. It has not been proven, and opinion submitted is not robust evidence. The objection is that the proposals misunderstand the particular dual and established role of the park as a public amenity, separate from the house.(Section 14)

Furthermore the only supporting conservation opinion fails to draw distinction between public benefit of house restoration and public benefit of a large restaurant. The implied public benefit is that there is solely benefit in the restaurant’s current form The opinion failed to consider other possible forms.(Section7)

3.4 The restaurant proposals intrude on a centuries old relationship between Listed Houses, gardens, gazebo, walls and Coach House that is an important part of the Twickenham history of residential use, as opposed to estate use. Policy DMDC5 Protects adjoining properties from unreasonable loss of privacy, pollution, visual intrusion, noise and disturbance. The area is a Conservation Area.

3.5 It is again the contention of objectors that the opinion expressed in the submission that the restaurant causes less then substantial damage is based on no submitted robust proof and inaccurate Information. The Listed wall height shown on the South End House side in the application is incorrect and so impact is even greater, there are no photo montages of proven accuracy. No value has been attached to views from and to Listed buildings of equal age. Historic England’ Standard practice now places increasing emphasis on the importance of photographic computer portrayal




This section is based on empirical evidence and does not rely on general desktop assumptions. As a result it is a better measure of local circumstance.

The traffic and parking survey was conducted by a combined group of professionals and local people using methodology and checking by Maybourne Projects Ltd Architects and Project Managers.

Consultation meetings have been attended by residents and users to pinpoint   discrepancies between the Vectos Survey submitted as part of the application and the known experience in and around the grounds. Checking Reference was also to the Traffic Plan ref (3) for Soho House July 2013.


The Traffic Report submitted in support of the planning application:

  • Confined itself to 2015 data from 20th and 22nd June
  • Studied only within the Park
  • Logged 353 vehicles entering the park

The traffic consultants 21/1/17 e mail to the Council admitted it was difficult to predict vehicles. But that the car park, based on a single day assessment was only ever 43% full. i.e. 43 spaces available for additional use. It admitted that the expected coaches would “struggle to turn” into the site.

It maintained there would be no significant increase in car parking and   hospitality events would rely on off-site parking. It further maintained that weddings would be similar to Chiswick House and Kenwood at 500 guests. However the excess over existing capacity would be expected to arrive by public transport.

The implication was that for a wedding 200 cars would have to park in the roads, and that excluded set up and service vehicles. The idea of brides, bridesmaids, waiters and silver service, parents and presents all travelling by train and bus is to put it mildly, farcical.

See Appendix section of e mails AP 4.1, 4.3, 4.4, 4.5 and 4.3.

The submitted report did not:

  • Study concurrent events outside the park and effect on the park and surrounds
  • Evaluate the parking patterns in adjoining roads
  • Provide information on current and future traffic pollution
  • Evaluate public safety for enhanced numbers in the adjoining roads
  • Update for increased pitch/grass usage now underway since 2015
  • Project impact from planning approvals on nearby sites

Local people submitted photos of the car park at full or close to full capacity. It is to be noted that the supporting reasoning by the traffic consultants now seems to have been removed. There is record that by   the 28th April LBRUT had noted basic deficiencies in the Transport Report and has also rejected comparisons to other properties such as Primrose Hill and Greenwich Park.


Twenty eight years ago the English Heritage Report (4)stated that at that time the car park was often full and cars parked on the grass. In examining what to do it stated: “If additional car spaces are required and when the adventure playground requires renewing, it might be possible to relocate the adventure playground “(para 5.47) “The enlargement of the car park and relocation of the adventure playground are recommended for year 5 phase III but work could be carried out in any year,” (9 para 5.47)

The car park was not expanded. The knowledge that the car park at that time was already below necessary capacity places doubt on the Vectos Survey submitted in 2017 that assumes there is adequate capacity for greatly increased visiting and pitch use. (See Appendix AP 4.1)


The submitted Vectos report based its conclusions on a 2015 2 day midsummer visit in order to conclude that there was sufficient capacity in surrounding streets.

By contrast this survey:

  1. Counted photographed and filmed traffic over a period of 6 weeks
  2. Recorded congestion at different times of the day
  3. Spoke to users deviating because of traffic
  4. Researched as many concurrent likely traffic loads as possible


This report suggests the effect of concurrent events greatly reduces any available capacity whether in the park or the adjoining roads:

  • The already reported unexpected levels of Turner House visitors @ 200m
  • St Stephens Church Services @ 50m
  • The Crown and ALBA pub restaurants customer parking @10m and 100m
  • Twickenham Stadium events car parking effect
  • Harlequins car parking effect
  • On-pitch tournament car parking effects @0m
  • Bus and traffic diversions on stadium match days onto Richmond Road@0m
  • Orleans Park school   and St Marys school entry and leaving. @ 10 and 100m
  • Orleans Park and St Mary’s school change from D1 to D2 Use Class for public use.
  • Lidl supermarket operating in Richmond Road @300m
  • Associated new school with Lidl @ 300m

The current traffic report submitted excludes the non house visitors and assumes that Park Events, House and new restaurant visitors will find ample parking in the streets. However Report 8.42 and others refer to

  • 12 weddings a year.
  • Medium events of 300 persons
  • Major event (past practice at 8000 persons)
  • Increased house visiting
  • Increased pitch use

The Traffic evaluation ignores the competition for spaces by other car users attending other premises and events. The primary loads are over the weekends. For example service attendance at St Stephen’s church fills the spaces around Cambridge Park and Richmond Road on the corner of Marble Hill Park. The mid day to afternoon slot has customers parking for lunches at the Alba and Crown Public House restaurants which impact on Orleans Road and Richmond Road. The newly opened Turner House is reporting higher than expected visiting which affects St Margarets Road, Sandycombe Road and Crown Road.

The increasing use of the Twickenham Stadium has a ripple effect as fans not only attend the event but come to the area’s Public Houses. This has brought parking into the Marble Hill vicinity. For example spreading down Crown Road to Richmond Road from The St Margarets PH. along the road from The Crown, or up the river from The White Swan and Twickenham Riverside pubs. Fans gather not just for the stadium, they use the pubs and restaurants   as a focus. They often park to facilitate a walk and meet at these points. This includes the Marble Hill Park area. The current expansion of the Stadium facilities may increase this.

There was for example reported severe congestion around Marble Hill Park on the coincidence of Harlequin matches. Again the RFU stadium is not the only focus.

Studying the events programmes shows frequent weekly matches. For example Harlequin running 12th.Nov. 3rd Dec, 10 Dec. And the Twickenham stadium of 3rd Sept.8th Oct.23rrd Oct, 12 Dec. While it might be argued that these are winter sports there is growing summer use of the Stoop and RFU stadiums and associated parking and traffic diversions, including along Richmond Road.

The flow of traffic along Richmond Road is affected by back-up at Cambridge Parade traffic Lights, Crown Road gyratory and the pedestrian lights outside the school. The mass movement of pupils across the road adds to the tail backs. When normal congestion coincides with Stadium matches and the use of the Park for large events with service trucks and visitors the load will be very high. This will be exacerbated by the planned school D2 use allowing public events.

The misdirection of lost traffic is a factor not discussed or solved. Cars turn into Montpelier Row believing   it is park access, The posting of stewards during events is temporary and does not solve the problem of ongoing usage for Park weddings and restaurant when stewards will not be present. Montpelier Row suffers with Orleans Rd as misdirected traffic links through Chapel Road. November 2017 experience has lost Filming Trucks in Montpelier Row.(See Appendix 1)

The conclusion one draws is that if traffic and pollution are to mitigated then rather than peak large use, small regular occasions are better


Public Voucher spaces that were free were counted. Adjoining   Roads: Cambridge Park, Montpelier Row, Orleans Rd, Richmond Road and the Park Car Park.

Sunday 1st October 2017.All parking spaces in Orleans Road were full and traffic was nose to nose in the single remaining carriage way, causing problems for pedestrians with children. There were 170 car movements in the space of 2 hours and 40 minutes. Cars were illegally parked blocking the Orleans Park Gate; others had been illegally taken into the Orleans play area, Park car park full.

At that time there were 4 pitches in use, including the Surrey Youth Football League on pitch 11, and Richmond Rugby Club Mini Tournament on pitches 4 and 5.

Photographic record

Sunday 16th September 2017 10am and complete congestion of Orleans Road with carriageway full with opposing traffic nose to nose. Cars had to back up to turn in Chapel Road and also Richmond road head and circulating back out into Montpelier Row. Park car park full.

Photographic record

Saturday 28th October 2017 12.30pm Park car park 60 spaces, Richmond Road 1 space. Orleans Road 20.

3.00pm. 1 soccer match, 2 rugby matches. 17 spaces in Park car park.0 spaces available in Richmond Road.3 spaces in Cambridge Park.

Sunday 29th October 2017 8.30am One match gathering. No other Park uses except dog walkers. 4 car spaces available in Richmond Road, 20 spaces in Park car Park. 10 spaces in Orleans Road beside park.

3.00pm. 1 soccer match, 2 rugby matches. 17 spaces in Park car park.0 spaces available in Richmond Road.3 spaces in Cambridge Park.

The Marble Hill planning application states that there is adequate capacity for all surplus demand for car spaces in the surrounding roads. However this double counts capacity. Application 17/777/FUL for the new Lidl store and school in Richmond Road has a traffic impact survey by Gateway. This records the Richmond Road as having “High Stress “on parking bays at weekends and weekdays. The Marble Hill application will not have the available spaces.




The 1st October observations of vehicle movements in Orleans Road were:

8.50am-9.00am =19 cars and 1 van

9.00am-9.15am=17 cars

9.15am-9.30am=23 cars and 1 van

9.30am-9.45am=19 cars and 2 vans

9, 45am-10.00am=12 cars

10.15am-10.30am=14 cars

10.30am-10.45am=15 cars

10.45am-11.00am=15 cars and 1 van

11.00am-11.15am=11 cars

11am-11.30am=25 cars

This 2 hour 40 minute slot with 175 vehicle movements in a single track small and tight cul de sac compares with the Vectos 2015 count for a whole day in the Park car Park of 353 movements. Clearly the surrounding roads are shouldering the brunt of the traffic load. The situation outside the park is serious .


The Gateway study of the Lidl supermarket and school shows an anticipated impact of up to 96% saturation.

The inevitable conclusion is that the Marble Hill application has erroneously assumed there is easy movement capacity for cars   in the surrounding roads when there is not.


4.9.1 The Orleans Road and Montpelier Row experience is particularly acute. From the movements recorded in Orleans Road a theoretical average 54 second car passage interval is implied if unobstructed (and the photos show otherwise). This would not leave enough time for the 120-180 second passage of pedestrians. However   the theoretical   risk exposure was greatly magnified by congestion which resulted in intermingling of pedestrians along the whole combined route.

The survey encountered mothers with pushchairs heading for the playground along Orleans Road, diverting to try to access via Montpelier Row due to blockage by vehicles.

It is usual for combined vehicular and pedestrian surfaces to have adequate safety areas and room for cars to move to avoid obstacles. In this case the parked cars narrow the route way to a single track with a high wall to the West. Again it is normal on such routes to have traffic moving in a single direction. In this location however pedestrians are faced with cars backing blindly and turning and additional persons and animals disgorging from cars.

4.9.2 The general surroundings such as Richmond Road and schools are a further concern. Residents point out a statistical anomaly that the published public accident data does not record child accidents. The area around the park has unusually high child foot fall and notable high proportion in the youngest age group related to schools and the Orleans play ground. As referred to above, accident statistics are misleading and the accident record for the roads quoted by Vectos is not an indicator of the increased risk now occurring, and it is particularly serious as the at-risk parties are the most vulnerable, being children and pedestrians mixing with leashed and unleashed dogs, disembarking from cars or passing, mixed with backing up and jammed vehicles. A proper risk assessment has not been carried out.

4.9.2 Hazard within the park. Users of the park point out that the current vehicle access/egress points and track ways off Richmond Road are already hazardous when commercial vans and trucks use them as they drive at a faster speed, being not used to park discipline. Elderly users say that they are personally unsteady, and not as quick to react,; as well as being slow moving, concentrating on foot fall in negotiating the exposed tree roots . The increased mix of private and commercial vehicle movements is, users say, incompatible with free ranging children, elderly, prams and push chairs.

The point of a park is the freedom of movement, especially for children. These run free immediately on entry and yet vehicles are moving well into the park. There is no defined safety restraint and a speed limit is no guarantor of absence of risk.


This has been discounted in the planning application. Consulting the SOHO House Festival Reports first of 2013 and then of 6th July 2017(2)(5)shows that 8000 people attend. The breakdown anticipated is 3500 drop and collect, 3000 train and walk, 1500 walk, bus and coach.

The measure taken for control is to close parking in Richmond Road and Crown Road. Losing 19 spaces and offer transfer to the park car park. The result is that any spare capacity in the park is lost.

This does not mean a traffic-free solution. Section 7 shows parking for drop and collect of 326 cars on the grass and existing car park. And no count of coach delivery.



5.1 Pollution is not simply a human problem, it threatens all life forms. It is now of grave concern in London and measures to counter traffic pollution are embodied in the Borough’s Planning Policy. The aim is to mitigate, not increase, pollution vectors.   Richmond Upon Thames is designated an Air Quality Management Area (6) for NO2 and PM10. This is because the whole Borough fails to meet standards. Monitoring has taken place at installation site code 15 opposite Marble Hill Park. The last record shows the position as “above the objective limit” of 40ug/m3 NO2 annual average.

In an effort to minimise exposure to pollution the Borough nominates Richmond Road as “pollution aware walking route”. ( website (1) However the route exceeds the required benchmark.

5.2 Major pollution occurs from slow moving traffic and particularly busses and trucks all accelerating and decelerating. The increase in visitors above the current park use will exacerbate this problem and the large park events with a possible 300- 500 cars and service vehicles slowly moving across the grass will be a major pollution generator.

5.3 The relevant Policies are:

  1. Directive 99/30/EC standards for AOLV for NO2 and NOx and sulphur dioxide.
    1. 2000/69/EC   for CO2
    2. 2002/3/EC Long term objectives
    3. 2004/107/EC Health-based limits
  2. Air Quality Standard Objective (AQO) 2010 applying to all areas where public gather
  3. Part IV of Environment Act.
  4. The National Planning Policy states “ The planning system should contribute to and enhance the natural local environment”
  5. Planning Polices should sustain compliance with and contribute towards EU limit values”
  6. The London Plan requires minimising of pollution
  7. LBRUT Core Strategy

5.4 The effect of the Marble Hill proposals can be gauged from application 16/2777/FUL for Lidl superstore and school at Ryde House Richmond Road. Air quality readings covered the development and Richmond Road alongside Marble Hill Park. It concluded   “the proposals have the potential to expose future users to poor air quality”, The proposers were forced to factor-in mitigating features such as the fact that the class rooms will be at first floor and all windows sealed, to reduce calculated exposure. This will not apply to Orleans school and not to the Park. The report observed that the canyon effect of buildings leads to a spill-out of pollution at open spaces. This would apply to the park.

Richmond Road exceeded the relevant AQO of 40 at 52 ug/m3 in 2015 for NO2.

The application projected significant increased traffic flow along Richmond Road with a high percentage of trucks.


All national and world health references categorise traffic pollution as dangerous and life limiting, especially for children. The Park is supposedly on a safe pollution route but the standard is already not met. It has schools close by and children are particularly vulnerable.

This was a major issue in the campaign for st Stephens school pedestrian bridge over the busy A316 which Tfl wanted to remove. The authors of this report involved Brunel University pollution control unit, produced data and Tfl eventually conceded.

The growth of pollution due to the action seeking planning approval has been hidden by the separation or non inclusion of increased   event generators: use of park with pitches, events and weddings and house visits. This is a case of a procession of single events having a very serious cumulative effect. Planning Policy requires the park and the adjoining roads suffer no increase but instead target a decrease objective. It is a contradiction that a park that is supposedly a generator of healthy living and clean air is instead creating substantially more traffic movements and aggravating the effect by the vehicles being slow moving and parking; and if taxis and coaches, particularly high pollution generators.

One concludes that large events particularly aggravate pollution due to the likely public vehicle carriers being diesel, and the long idling times and slow movement when pollution generation is at its worst.


6.1 The applicant has maintained that no change to the proposed restaurant size is possible. It is however very evident that the size is the cause of other inappropriate characteristics. The design makes no attempt at a “good neighbourly relationship” in terms of massing and materials that is the first rule of good practice in Conservation Areas. In this approach there would be no intrusion above the Listed wall. The supporting statements   by English Heritage that the building is “good honest modern design and not pastiche” is a subjective evaluation .A choice of genre is no guarantee of good design. It is the expressed opinion of many conservation and locally based architects consulted that the design is inappropriate.

The   demolition of the Listed boundary wall has now been changed to “possible demolition” but the height of addition above the wall remains, severely intruding into the view from Montpelier House and South End House.

It is stated as 3000mm above the restaurant finished floor though this dimension is also stated 3900 but the lower ground on the other side of the wall increases that height considerably and in different material. Typical section 533-L-20 shows a height of 3900 above finished floor level. Generally the scheme anticipates approximately 1200mm of zinc clad wall added above the listed wall.

The opinion of independent structural assessor advising this report is that, given the standard Good Practice of not interfering with a Listed wall, its current leaning along just 5-7m of 140mm inclination is not in itself instability and is not justification for demolition. The opinion is that the correct approach would be to keep new restaurant wall well away from the Listed wall and design foundations further away still by means of cantilever to the flank. This minimises vibration and reduces intrusion into possible tree root systems. It was also recommended that in pulling away from the listed wall, the roof could be lowered to flat, being a modern look but more concealed from South End House.


The proposal is now vague on whether the listed boundary wall between proposed restaurant and South End House wall is kept or demolished and bricks reused. Whichever solution is followed has a detrimental effect on the old brickwork. Traditional walls , unlike modern walls, have lime mortar that allows movement and relies on the dead weight to keep stable. For as long as they are undisturbed the bricks remain relatively undamaged. Such walls “breathe” and rely on the evaporation of water to protect the bricks from frost damage. The proposal incorporates one side into the new restaurant and adds approximately 32m2 of vertical zinc sheet above. This will greatly increase rain saturation by runoff from above   while inhibiting the drying out. The resulting saturation will quickly destroy the bricks.

The construction of a new wall will be very expensive as it demands careful demolition and sorting and grading of the bricks for rebuilding. There will be inevitable breakage, and the bricks will be particularly friable and prone to flaking, and yet if there are replacement bricks from the interior of the wall used for facing they will not have the age patina.

This is a party wall, and while that does not have planning significance it does demand the cooperation of the adjoining owner. The harm done to the owner’s property disinclines them to cooperate. The application shows access over their land to dig and to build withouttheirpermission. They are not willing to provide this. As a result, to realise the proposal the listed wall, in being rebuilt, will require what is termed “hand over hand” building from the Marble Hill side. This is difficult and expensive and cannot result in satisfactory coursing and jointing necessary for a Listed wall in a Conservation area. Even if old is replaced by new it remains listed and Best Conservation Practice must apply; but it is impossible .

The trees are an additional problem. The specification demands hand digging all tranches and wrapping all tree roots.. This is costly in time and labour.

The conclusion is that the whole matter of the wall and restaurant construction s very difficult and very expensive, and needlessly so.


No justification in figures for the size of restaurant has been issued on grounds of confidentiality. The application has confused covers and places but the plan Drg 533-L102 has apparently 160 internally and externally, which differs from other statements. Again there are inexplicable contradictions on intent. The overall plan of kitchen and associated servery , internal, dining spaces, toilets and storage appears at this stage to be 222m2

For comparison South Gloucestershire Council have completed with a Heritage Lottery Fund Grant, a Park cafe for Page Park Staple Hill, The park receives 2000 visitors a day which broadly equates to Marble Hill projections for 5 years hence. This cafe is 160m2 and achieves a flexible sub dividable space. Such an approach at Marble Hill would provide the Cricket Club with a social area for matches. The Cricket club’s request for social accommodation has previously been rejected by the applicant.

See:…cafe-to-be-built-in-page-park-staple-hill 7.

A working modern example of similar footfall and with HLF funding is convincing evidence that the proposed restaurant is 40% oversized. The provision of kitchen and additional servery is evidence of catering on a large scale beyond the quoted covers. This is therefore a major installation with all the impact in size and servicing and use that implies. It cannot be intended for almost purely local use as is now claimed.


Beside the visual impact there are considerations of:

  • Waste and food scraps harm to foraging creatures
  • Attraction of non park groups such as rugby crowds
  • Noise to Montpelier Row from the service Trucks and waste collection
  • Noise and smell impact from dining areas
  • Adjoining street impact


The application’s acoustic report   8.23 states noise monitoring took place 16th-20th December 2016.This is not a representative   time for park use or ambient noise. The sound receptor was mounted on a single pole on the boundary of South End House at a point not relevant to sound projection when the restaurant is built. It gave a reading of 37db L90 15 mins.

There is evaluation of internal noise (Their Section 4) and mechanical noise (Their Section 7) The acoustic measures are largely preoccupied with prevention of sound spread internally. In this respect no sound control is shown via the kitchen door and yet it is a common experience that commercial kitchen doors stand open for heat and service reasons. There is a consequent   direct sound route from the building at its stated highest acoustic level of 55 db, into Montpelier Row opposite South End House and Montpelier House. This actually breaches the codes because the border of Montpelier Row is private land as garden separated from the houses.

Inside the restaurant dining area the level is stated at 40-55db but the report notes an “acoustically reflective floor” As a result summer use with open windows the restaurant will act as a sound amplification box and will reflect sound outwards to be reflected again from the Coach House wall. No evaluation of this effect has been submitted.

For comparison this report studied acoustic levels in other Richmond Borough restaurants. Gauchos was 58db inside, Orleans Cafe 54db and outside 55db and remaining at 50db 20m away. Gaucho fans were 52db and Nero 57db

One can conclude that the submission is optimistic.

There are errors in the assessment of the impact on South End House. The report states that even though the noise level on the house side of the wall will be above the LBRUT recommendations of 50db, the house has only a drive beside the wall and so can be discounted. This cannot be assumed; the House garden adjoins for a considerable distance. Again as sound halves only with the square of the distance and the wall screen sound shadow is lost, sound will carry into the main area of garden.

Figure 5 of the applicant’s report shows a clear illustration of noise out of the cafe and over the wall by the gazebo into the garden of 57-61dba. This again is dismissed by the report on the grounds the gazebo is not habitation. However it and the garden are private residential area.

The submitted report 9.23 refers to possible evening use 18.00-23.00.This is therefore outside the stated operational hours. No evaluation has been made of the acoustic level of summer dining externally in different forms such as plate collection, crowd noise, children etc. These will occur beside the South End House wall and sound will travel on summer days and nights through open windows in Montpelier Row.

The BREAM evaluation in the application states a sustainability points gain by having windows and skylights opening to use natural ventilation (Their report 8.29) however public consultation had the roof lights removed .On the basis of undertakings by the applicant either the BREAM calculations are incorrect or and the noise nuisance will be is greater than now maintained.


Section 8.25 of the submission states that odour is of “high risk”. There is little in the report to reassure local residents that mitigating measures will be effective, particularly as fans discharge on the north side and fumes may be distributed by prevailing winds. Again as with noise there is a conflict with the BREAM submission.

Checking around the Borough it is notable that the fans at the rear of restaurants in st. Margarets draw complaints from the adjoining Baronsfield Road backing on to Crown Road restaurants. The applicant, in accord with best practice should organise a visit of locals to a similar fan installation as proposed.


Campaigners raise the issue of visual intrusion into the setting of the Montpelier Row Houses. These are listed buildings with the gazebo and wall and an intrinsic part of the Marble Hill and Twickenham history. This visual damage is discounted by the report by a single short note that the restaurant is causing “less than substantial harm”. It was however based on information that was erroneous in terms of the height of the wall on the South End House side. The ground being lower; and no visual in-depth evaluation from   the house. It is also appears from witness statement (see appendix AP1) that EH misrepresented the design as having been agreed with the occupier, even though the original proposal described to them was only in relation to a portion of fence, and was to be to the height of the ivy and subsequently went up far higher. No action was taken on their objections. It is further maintained by the occupier that an invitation to EH to go over the plans onsite was never taken up.

The evaluation failed to assess the history of the House and its 18th century Garden which have major views of the park, river and Richmond Hill. This view is recorded in Walter de La Mare’s writings. Furthermore the Row is bound up with the history of Henrietta Howard due to her correspondence when residents asked for the removal of chestnut trees. (which she refused)

Clearly the proposal would harm the very essence of the historical claim of the applicant:

Photographic record shows that the restaurant roof will be a major change of this view, and also be intrusive in its extremely high zinc cladding It is of industrial size and nature.. The effect on view from windows after leaf fall will be dramatic, especially with the sun glare. Photographic record shows that the addition to the wall will severely obstruct any view of the coach house, its upper elevation, roof hips and wings and its decorative cupola. This obstruction is notable also in views from Montpelier House and beyond.


There are prime specimen trees in the South End House Garden close to the Listed Wall and proposed restaurant that contribute to the setting of the Park, house and the view from Richmond Hill. A view protected by a number of Policies. There has been no study of the affect on root bowls and the risk of damage or death in this vicinity.

The Technical comment on the wall describes the risk and complications.


The design approach would appear to have been to maximise the floor area of the restaurant, without constraint, to fill all possible land behind the Coach House and the far side of the listed wall and claim the wall is owned by Marble Hill House. Expert opinion disputes the wall ownership claim. The technical problems render this a very expensive approach. There is also high risk in legal aspects, work practice, stability, cost over runs, tree loss and performance shortfalls. Given this is public money and property, by whatever route, it is questionable that a state institution (or charity) which is required to be risk averse, should act this way. It also implies that the applicant should take out a performance bond to insure if work does not perform as claimed.



7.1 An independent conservation report establishes that the restaurant design inflicts substantial harm in visual terms on the listed buildings adjoining, and their setting. The application admits this harm but argues it is less than substantial, and that it is justified by the greater public benefit of the application compared to the public benefit of the setting on the South End House side. The new report evaluation dismisses this, stating that the option appraisals were not wide ranging and did not explore alternative roof designs such as flat or stepped, and plan forms set away from the wall.

7.2 The submitted expert view on damage to the Listed houses setting is very short and fails to draw any distinction between the public benefit of house restoration and that of having a large restaurant. They are not intrinsically linked. Were the restaurant to be cheaper, which this technical report suggests, then the   necessary return from revenue to fund the lower capital cost would be lower, benefiting the restoration fund “pot” and removing harmful impact.

The occupants of Montpelier Row have complained of the major impact of the restaurant on the area. In terms of design, setting noise and smell (see rest of report) These are 18th century homes   that are a primary historic examples of Twickenham 18th century living with residents recorded in Henrietta Howard’s letters.(8) As Grade II Listed buildings in a Conservation Area they have protection both of fabric and of views and context.

They have additional historic value insofar as the view from South End House to the Coach House and beyond is written of by Walter de La Mare (9);this more than meets the criteria for protection of visual context.


The application admits visual impact but fails to justify this. The option appraisals submitted explored no other planning solution   other than filling the whole area at the rear of the Coach House up to and including the Listed party wall to South End House. No other configuration was explored for the public understanding and no evaluation of changed footprint to reduce footprint was evaluated or justified.

According to its submitted 3d visualisations It confined itself to evaluating only two roof forms: mid ridged and monopitch, dismissing the former as unacceptable because of gutters on the boundary. However architectural advice states this is a common situation and there are many ways of handling the issue in detail. This solution would have greatly reduced visual impact onto South End House. It would also be one way to address the application’s unconsidered problem of severe water saturation of the reused old bricks (or the retained wall) from the catchment of extensive areas of vertical zinc sheeting above. This was a serious omission and would leave to early failure and loss of a heritage asset.

The other form evaluated, of monopitch roof rising to height on the party wall has computer illustrations in Page 103 and 115 of Design and Access 17. These show extraordinary height as seen from South End House and lack of broad option evaluation. The technical water saturation problems outlined in the previous section would apply to this.

The adverse feedback on this led to the statement that it has been reduced by 0.9m (Planning Statement 6.25) but no illustrations of this from this side are shown.

The evaluation has been almost exclusively focused on the effect on the Park. This is expressed in Lichfield’s Planning Statement 6.6: “the low slung design would remain screened from the park”


Paragraphs 133 and 134 of the National Planning Policy Framework state “where a proposed development will lead to substantial harm….local planning authorities should refuse consent…..unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefit”     This study shows it was not necessary.

CP7A states: “Existing buildings and areas in the Borough of recognised high quality and historic interest will be protected….”


Royal Institute of British Architects approved Conservation expert Richard Woolf states that the accepted Good Practice in Conservation Approach should have been to prioritise minimum impact on the adjoining listed buildings and to adopt a strategy of good neighbourliness in form and materials. The opinion is that other roof forms were perfectly possible but that in the first instance a priority should have been given to non interference with the Listed wall and keeping well away.


The view of this informed report is that the applicant set an unreasonable benchmark of filling the whole site when compromise for conservation reasons was possible. It is also very apparent that in terms of Policy the necessity to achieve public benefit is not proven to be solely by this design. No alternatives of plan form were evaluated in the context of priorities in conservation. It is readily apparent that different designs with, for example, stepped roofs or flat roofs (as at Chiswick House) could have been applied.

There are many visual and environmental impact problems that are all immediately solved by keeping well away from the boundary and being more modest in provision.


8.1 The effect on health is clear from this report’s observations on the growth of traffic independently of the Park, the additional traffic from increased pitch use and events, and the fact that pollution already exceeds the acceptable limits.

Section 8.41 Health Impact Assessment submitted, in Section 1 HUDV Rapid Health Impact is erroneous.(10) Under 4 Air Qualities it fails to register traffic air pollution.

Many policies at national and local level emphasise the role of parks in physical and mental health at all ages and conditions.. The application concentrates on active sport.

8.2 The application’s stated user profile is however:

  1. Dog walkers 19%
  2. Walkers 64%
  3. Push chairs 1%
  4. Sport 17%

The age profile is

  1. 0-19   25%
  2. 20-40 67%
  3. 40+   10%

8.3 One can infer that a quarter of users are therefore in the age group particularly vulnerable to air pollution. While wheel chairs are shown in drawings the predominate numbers in mental and physical frailty do not seem to be catered for. There is no blind or dementia garden for example. A Large restaurant does not provide the quiet and calming atmosphere that many elderly or stressed people prefer.

This suggests an over focused target and that a lot more could have been done to make the park a therapeutic and healing medium..

The application fails to recognise the public health role of open space. There is not simply lost opportunity, there is failure to recognise public parks’ modern and necessary multi-roles.


9.1 The National Planning Policy Framework (11) states Core Planning Principles In paragraph 17:

  1. Empowering local people to shape their surroundings. However local campaigners maintain that while they have been told what English Heritage intends, they have not been able to engage on change to important elements such as traffic, restaurant, adjoining building impact, and copses. This is reinforced by RTPI Good Practice in public consultation.
  2. Support transition to a low carbon future. In spite of this the proposals seek to increase carbon generation by commercial activity and traffic
  3. Conserving natural environment and reducing pollution. In this case the natural environment in the copses is being changed and the increased traffic will further increase pollution.
  4. Conserving heritage assets in a manner appropriate to their significance. This implies compromise to recognise the balance between significant uses.

In addition:

Paragraph 36 requires a Travel Plan where there is significant movement .This is currently absent

Paragraph 66 requires working closely with and taking account of the views of the community. In this respect opposing views as well as supporting ones should be earnestly and publicly evaluated and clear reasons given. Again, the RTPI also calls for arranged visits to examples and a joint working party to shape layout.

Paragraph 109 requires protection and enhancement of valued landscape, minimising impacts on biodiversity and halt decline in biodiversity. It is, by contrast, maintained by independent experts recommended by Natural England that there is harm from the clearances.

Paragraph 118 states that work can be refused where outside an SSSI and likely to impact on it. The Park is known foraging   area for bats from the Richmond Park SSSI and felling, clearance and   static and traffic are known and serious impact events.

Paragraph 136 states a Local Authority will not permit the loss of a Heritage Asset. In this case the Listed wall and the views to and from adjoining South End House and Montpelier Row are Heritage Assets.

Other examples of relevant Policies   are the Designation of the Park as in the Thames Policy Area, and the Development Management Plan for LBRUT 2011 Paras 4.1 (Open Land and Rivers) and 5.4 (Transport and Parking)

See also DMP Policies DM0511 and DMDC5 mentioned in text

The Planning Relevance: There is a strong case supported by scholars, critics, guides and engravings (see rest or report) that Marble Hill was actually realised with a simple lawn and chestnut groves (not avenues) and edged by woods. So the proposals are not a restoration. The heritage gain by park design is minimal given the existence of other examples. The long state of the park as it stands has a greater heritage value.

Metropolitan Open Land, Policy DM OS 2, 4.1.3: New uses will only be considered if they are by their nature open or depend upon open uses for their enjoyment and if they conserve and enhance the open nature, character and biodiversity interest of MOL.

Unitary Development Plan: The Proposals conflict with UDP 2005 which envisages a more more modest treatment.


The question of clamed ownership of the Listed Wall at South End House by English Heritage is a serious one and has not been proven. Yet the ownership line is unambiguously indicated on the application to include the wall in spite of buttressing indicating otherwise. Referring to Government Guidelines : It is an offence to complete a false or misleading certificate” Para 025 Ref10 14-025-20140306 revised 06-03-2014


Objectors await changes promised several months ago. Attention is drawn to Government Guidelines : “It is up to the Local Authority if changes are made to be reconsulted upon” Para 061Ref 10 14-061-20140306 revised 06-03-2014. In this case the planning authority have publicly stated reconsultation will take place.


10.1 Marble Hill Park: its wildlife and the importance of the woodland quadrants and veteran trees:

The proposals are in direct contradiction with the requirements of LBAP: The Local Biodiversity Action Plan embodied in Council Policy. It states “Biodiversity is the Borough’s prime natural asset” and designates Marble Hill Park as a Site of Local Importance” of “particular value to resident and schools” It places high value on untouched wood and scrub.

Independent assessments were carried out with the Environmental Network on site. (Appendix AP 4.10)

 10.1.1 Campaigners argue that the destruction of the woodland quadrants and over eager park woodland management of the copses and other veteran trees would be detrimental to an array of bird, mammal and insect life at Marble Hill Park. The expert opinion is that any mitigation measures for the proposals should leave the copse quadrants as they are.

“Scrub is a natural part of other habitats, such as grassland and woodland; and an important component of the landscape.” RSBP

10.1.2 By contrast English Heritage state that the woodland quadrants are bereft of wildlife as the copses are mostly composed of self-seeded tree specimens.It maintains that the removal of 327 trees from the copses and coppicing of a further 97 would benefit species under a new woodland management scheme of replanting and felling.

10.1.3 We refer to the National Biodiversity Action Plan, Local Biodiversity Action Plan and expert sources such as the Royal Protection of Birds and The People’s Trust for Endangered Species and The British Trust for Ornithology to counter English Heritage’s claims in the hope that Richmond Borough Council will reject plans for the destruction of the woodland quadrants.

10.2 Marble Hill Park – Site of Local Importance to Nature Conservation: There are 22 sites within the borough that are of particular value to nearby residents or schools and are local sites that are particularly important in areas where there may be a deficiency in wildlife sites. Marble Hill Park is one of the last semi-rural green spaces on this side of the river.

10.21 The main aims of the Richmond Local Biodiversity Action Plan are:

  • To conserve, and where possible, enhance Richmond’s variety of habitats and species, in particular those, which are of international or national importance, are in decline locally, are characteristic to Richmond or have particular public appeal, which can raise the profile of biodiversity.
  • To ensure that Richmond residents become aware of, and are given the opportunity to become involved in, conserving and enhancing the biodiversity around them.
  • To raise awareness and increase stakeholder involvement in maintaining and where possible, enhancing species and habitats of importance.


10.3 Woodlands: The Biodiversity Action Plan (12) states there are no ancient woodlands in the borough; however it does outline the importance of secondary woodlands that have naturally regenerated. It also points to the importance of trees with broken limbs whose numerous cavities provide ideal nesting sites for woodpeckers, nuthatches, tree-creepers, owls and bats all known to inhabit Marble Hill Park and feed on the tremendous numbers and diversity of invertebrates which are supported by these trees.

Within the borough veteran trees, standing deadwood and fallen timber contribute to one of our most important habitats for biodiversity including stag beetles. (3.1.1. Woodland, Biodiversity Action Plan)

10.4 Scrub: Is an important habitat for an array of species as it provides ideal cover for nesting, feeding and breeding. (3.1.3. Scrub, Biodiversity Action Plan)

Scrub of varied age, species and structure supports the widest range of wildlife, as some species depend on specific growth stages of certain plants. Some species require particular shrubs and others a range of habitats in a small patch of scrub. It is important to maintain all growth stages, from bare ground through young and old growth to decaying wood. (RSPB)

10.4 Red-List Species: The UK’s birds can be split in to three categories of conservation importance – red, amber and green. Red is the highest conservation priority, with species needing urgent action.


Red list criteria

  • Globally threatened
  • Historical population decline in UK during 1800–1995
  • Severe (at least 50%) decline in UK breeding population over last 25 years, or longer-term period
  • Severe (at least 50%) contraction of UK breeding range over last 25 years, or the longer-term period (RSPB)

10.5 Wildlife sightings within Marble Hill Park

There are three species of woodpecker in England and all can be found in Marble Hill Park. However, the Lesser Spotted is in severe decline and numbers have plummeted in recent decades.

Lesser Spotted WoodpeckerConservation status: UK Biodiversity Action Plan ‘Priority Species’, long term trend UK: rapid decline it is a Red Listed species.

With only 1000-2000 pairs in the UK, mostly in the south east it is exceptional to have this rare bird in Marble Hill Park; regularly seen in the woodland quadrants and in large trees within The Park. The smallest and least common woodpecker in the UK it has declined by over 50 per cent in the last 25 years the reason is thought to be due to the destruction of woodlands, copses and parkland which it relies on. Over eager woodland and parkland management also speeds their decline as the woodpeckers rely on deadwood and trees with cavities.

Continued presence is now strongly associated with heavily wooded landscapes (Charman et al. 2010)(13) Lesser Spotted Woodpecker has been one of the most strongly declining bird species in Europe, with widespread rapid decrease since 1980 (PECBMS 20072010).(14) (British Trust for Ornithology)

Green Woodpecker –Forage on the sports pitches for worms, see

Stag BeetleStatus and conservation: The stag beetle is a UK species of ‘priority’ or ‘conservation concern’ found within the borough and is in decline locally (Richmond Borough Biodiversity Action Plan). It is listed on Schedule 5 of the Wildlife and Countryside Act 1981.

If stag beetles are known or thought to be present at a site where an application for planning has been submitted, and are likely to be disturbed or destroyed whilst work is carried out at the site, it is recommended that someone with an understanding of the insects’ requirements be present to see that any larvae and/or adults are carefully translocated to a suitable natural or purpose-built habitat close by. (Peoples Trust for Endangered Species)

Pecking out ants in the woodlands and breeding in tree holes pecked from dead wood; characteristic of acid grassland in LB Richmond. The green woodpecker is abundant throughout Marble Hill Park and they rely heavily on the park’s grass for worming, they live in pairs and family groups and thrive in the parkland. These woodpeckers are highly sedentary, seldom moving far from where they were hatched and so after nesting in the trees of Marble Hill Park they then continue to live within the park grounds. Over enthusiastic woodland management and park maintenance can be detrimental to the species as deadwood is needed for nesting holes.

Greater Spotted WoodpeckerSeen and heard throughout The Park’s woodlands particularly the north-west quadrant and in mature broad-leaved trees. It is easy to spot in The Park during spring and autumn when trees are bare by following its loud pecking noise. It is abundant throughout Marble Hill Park throughout the year.

Little OwlMarble Hill Park has a small Little Owl population some of which live in the famous Black Walnut Tree in a hollow, they are often spotted and heard within the copses and in tagged trees 0187 and 0183 next to the south-west woodland quadrant. The People’s Trust for Endangered Species is so concerned about The Little Owl’s disturbing decline it has joined forces with The Little Owl Project to protect them. Recorded sightings of this charismatic bird have dropped by around half in the last ten years alone, and 65% in 25 years. Little Owls can be seen throughout the day though they hunt at night and so events in The Park after dark would affect hunting.

Little owls can be found in Marble Hill’s black walnut tree both flying in and out of tree cavities, basking on branches and hopping around the base of the tree on ground level. Throughout the year they can be seen and heard from trees in and around the copses particularly the South-West quadrant. Tagged trees 0187 and 0183 are well used by the owls next to the quadrants as are the line of trees down towards the river parallel to the rugby pitch.

Stag Beetles – Regularly recorded in The Park it relies on decaying wood that is in contact with soil, both to feed on as larvae for up to seven years and in which to lay their eggs. The woodlands of Marble Hill and survival other felled trees left to decay within the park grounds are essential to the stag beetles.

Although males can fly up to 500m, most female stag beetles don’t travel more than 20m and return to where they emerged to lay eggs. This means populations are vulnerable to becoming isolated and if there isn’t enough dead wood nearby, dying out all together.

The most obvious problem for stag beetles is a significant loss of habitat. In addition the ‘tidying up’ of woodlands, parks and gardens has led to the removal of dead or decaying wood habitats which is the stag beetle larvae’s food source. Tree surgery operations such as stump-grinding of felled trees removes a vital habitat for the beetle. Although ‘tidying up’ still continues in gardens, woodlands and park managers are now much more aware of the need to retain dead and decaying wood as part of the woodland ecosystem. Humans are, unfortunately, a direct threat to the stag beetle. Stag beetles are attracted to the warm surfaces of tarmac and pavements, making them vulnerable to being crushed by traffic or feet. The Royal Parks’ management plans for Richmond Park, among others include the retention of suitable dead wood to help encourage stag beetles.

Song-Thrush: Is a UK species of ‘priority’ or ‘conservation concern’ and in local decline (Source: Local Biodiversity Action Plan). Song-thrush rely heavily on scrubland habitat such as the woodland quadrants of Marble Hill Park with its ivy. Audio recordings on 11th and 12th of November identified the song-thrush in the quadrants of Marble Hill Park. This once common bird is now red-listed and so it’s vital that further habitat is not destroyed it has had 49 per cent decrease in woodland habitat.

From one-two decades ago it was possible to listen to half a dozen thrushes, now it is rare to hear more than one. The tendency… has been towards a greater artificiality, it saves for trouble and makes for prettiness to cut down decaying trees. To drape them in ivy and make them beautiful in decay would take some thought and care.”(W.H. Hudson on West London Song Thrushes, Birds in London, Dent & Sons, 1928)

During the breeding season song thrushes need nest sites low in dense vegetation. Over- management of suitable habitat, including reductions in shrub cover or removal of hedgerows, are likely to be detrimental to song thrush numbers by reducing the supply of suitable nest sites and exposing nests to predators. (4.1 Habitat loss, Local Biodiversity Action Plan)

Badgers: Protected under The Badger Protection Act 1991, they actively use the woodland quadrants for foraging there is evidence of dung pits, prolific setts both used and inactive, evidence of hairs and snuffle holes throughout the woodland quadrants and The Park as a whole. Warwick Reynolds, recommended professional by Natural England has undertaken an independent Badger Report on behalf of local campaigners. Campaigners are worried that English Heritage failed to note badger presence at Marble Hill until September 2017 after it was brought to their attention by campaigners.

Excavation works carried out in the summer of 2017 within 20 metres of badger setts went ahead without a ‘Badger Works Licence’ as a result Natural England and the Wildlife Crime Unit were notified. English Heritage responded by saying that an Ecological Survey carried out in 2015 did not flag up badger activity at the site. The concern is that other protected species have also been overlooked such as song-thrush and lesser-spotted woodpeckers but to name a few.

Large D-shape holes are prolific throughout the four woodland quadrants; this one was photographed by Warwick Reynolds one of the country’s leading experts from The Badger Trust and sits within the south-west quadrant.

Tawny Owl – Rarely seen within The Park at night due to The Park’s night-time closure but regularly seen in large trees overhanging Orleans Woods within a few metres of Marble Hill Park indicating that they either live or forage within The Park and along the Thames Corridor. Any night-time events held within The Park would impact the Tawny’s ability to hunt. Preferred habitat is woodland with ivy as in the woodland quadrants of Marble Hill Park and also Orleans Gallery Woods.

 Bats: UK species of ‘priority’ or ‘conservation concern’ and ‘characteristic’ of the borough, the Local Biodiversity Action plan set out to reverse the current population decline of bats in LB Richmond. Marble Hill Park abuts The River Thames which is a Site of Metropolitan Importance for Nature Conservation (SMINC) and an urban flyway for bird and mammal species traveling into and out of this area of south west London. Bats and broadleaved woodland are target species and habitats within Richmond’s Biodiversity Action Plan (BAP).

‘The Park is characterised in nature conservation terms as: period buildings with large or complex roof voids; broadleaved woodland, some veteran trees and vertical habitats (ivy) within an undisturbed location and in close proximity to open water. Many of the above are features of interest to bats and nine species have been recorded within two kilometres of the site. Trees and tree lines are used by bats in order to commute between features as well as produce and shelter insect biomass upon which they feed. They also create a shield against light ingress, which is a factor for some of the less common bat species.’ ( Bat Surveys at Orleans House Gardens)(15)

Desk Study: The desk study showed that nine species of bat are regularly recorded locally, five of which are roosting nearby. Roosts of both Common Pipistrelle bats Pipistrellus pipistrellus and Soprano Pipistrelle Pipistrellus pygmaeus are known within 20 metres. During previous surveys at the Gardens (2006) pipistrelle bats were recorded flying from the Gallery. Daubenton’s bats Myotis daubentonii are recorded navigating over the river and a tree roost of this highly mobile species was recorded within 1.5 km. Noctule bats Nyctalus noctula roost in trees within 1.5 km and Brown Long-eared bats are known to roost at two sites within 1km.

Licence Test: The Habitats Directive under European Law (see 6.1) states that where a bat is to be disturbed and/or a roost will be destroyed a European Protected Species licence should be obtained. A licence will only be granted provided that certain tests can be met i.e. there are Imperative Reasons of Overriding Public Interest (IROPI). The directive requires competent authorities (Wildlife Licensing at Natural England) to assess the impact of plans or projects. A like for like replacement of ALL features that bats are using should be provided amongst the mitigation measures to be presented to the competent authority. This includes mitigation for loss of roosts and foraging sites within a credible environment. Ref Bat Surveys at Orleans House Gardens (15)

Table 1: Status of bats recorded in the local catchment.

Species Frequency Main roosts sites
Common Pipistrelle Common Buildings nearby (LBG) Roosts nearby
Soprano Pipistrelle Common Buildings and trees especially near water (LBG). Large roosts nearby 3 sites
Nathusius’s Pipistrelle Rare Has roosted within the catchment but its local status is variable
Daubenton’s bat Relatively common Trees, structures and underground sites in the local area. Roosts known within 1.5km
Natterer’s bat Infrequent since 2009 at this location Trees and structures
Noctule bat

Nyctalus noctula

Becoming less common in London Known roosts nearby
Leisler’s bat

Nyctalus leisleri

rare No known roosts in the area flight records only but early registrations
Serotine bat Eptesicus serotinus Rare in London A record from Teddington Lock surveys, 2012
Brown Long-eared bat Plecotus auritus Becoming rare in London Roosts nearby, difficult to detect in flight

Adapted from Mitchell-Jones (2007) LBG=London Bat Group records, Briggs et al, 2007

See also Bat Report for Lebanon Park Tennis Club

Other wildlife within the park: This document aims to outline the most vulnerable, threatened and protected species within The Park, it is not a complete breakdown.

Mistle-Thrush: Audio recordings from the woodland quadrants throughout August identified mistle-thrush being present.

Tree-Creepers: Within the woodland quadrants

Siskin: In the park’s foliage

Egyptian Geese: Sat nesting at the top of the black walnut tree and foraging on the floodplains

King Fishers: Perching on park railings along the river boundary

Dragonflies: Throughout late summer can be seen mating above the rugby pitch and along the river boundary


10.6 The proposals show on Design and Access statements Parts 7 and 11 that the copse quadrants will have greatly reduced thicket, addition of hedges, grove planting, gravel paths and specimen trees, orchard and pallisade. Independent landscape and habitat consultants inform this report that this is a major clearance and change.

Wild life experts recommended by Natural England have found clear evidence of badgers and setts in all four copse quadrants with links under boundary to Meadowside. Additionally there is concern for song thrush, bats and a range of other birds and insects. Reports go directly to Council Ecologist about sightings in The Park.

10.7 From the species list the borough is keen to protect the following which are in and around the park:

  1. Tree Creeper (bird)
  2. Lesser Spotted Woodpecker (photos)
  3. Stag Beetle ( photos) also seen them in the copse quadrants.
  4. Song-thrush (audio recordings )
  5. Dragonflies
  6. Badgers (report)
  7. Bats: around 8 species


10.3 The Park is known habitat for bats and foraging extends at height over the park at dusk. This feeding includes the insects at height as the air rises from the river over the park and extends to Petersham Meadows and the cattle dung beetles. In addition the park is categorised as “close to an SSSI” which in this case is Richmond Park.

The recent Planning application for weddings at White Lodge Richmond Park was successfully objected to by experts on the grounds that lights from the guests’ cars would upset foraging patterns. The same   reasons for objection apply to this application, but aggravated by planned flood lighting to nearby pitches and tennis courts.

See also The Bat Report from Orleans Gallery

The same ecologist refers to The Orleans Gallery Bat survey because the tennis club is within 50 metres of the gallery as is Marble Hill park.

Selection of Priority Habitats and Species ref 3.3

An LBAP contains Action Plans for particular priority habitats (HAPs) and species (SAPs) within the local area. This is the most important part of the LBAP and the part, which requires the most ‘input’ from the Partnership. The following section details which habitats and species have been selected for Richmond.

This list will be used to write Action Plans for each of the identified habitats and species, but they cannot all be written and focused on at the same time, so the Plans will be written in rounds, so that as Plans are being implemented and reviewed, new ones can be written.

Habitats Species Species
Ancient parkland/veteran trees Water vole Bumble bee
Meadow Great crested newt Black poplar
Acid Grassland Stag beetle Badgers
Broad-leaved Woodland Skylark Reed warbler
Urban (gardens, allotments, churchyards & cemeteries) Song thrush Small copper butterfly
Reedbeds Bats Kingfisher
Rivers and Streams Bluebell Dragonflies
Tidal Thames Tower mustard Pochard
Standing Open Water Common frog/Common toad Grey heron
Floodplain grazing marsh Tawny owl Great crested grebe
Hedgerows Hedgehog Cardinal click beetle
Purple moor grass/rush pasture Woodpeckers Mistletoe
Urban Wastelands Knapweed


  1. Other owls eg tawny owl seen on boundary f Orleans Road.
  2. Sparrow Hawk in and around seen in Orleans Gardens

Marble Hill Park is designated through the SWLEN Group of which Richmond Thames is an active partner: to monitor and protect biodiversity:

SWLEN supports local initiatives to protect and enhance local parks and open spaces, facilitating the preservation of local biodiversity, and promoting the conservation and improvement of the natural environment.

One such initiative is the Richmond Biodiversity Partnership, which brings together organisations and individuals to conserve and enhance biodiversity in the London Borough of Richmond upon Thames. SWLEN acts as the Partnership’s secretariat as well as chairing the Partnership.

The Partnership is currently hard at work refreshing the Biodiversity Action Plan (BAP) to launch in early 2018. The Partnership set up in 1996 relaunching in 2005 to identify and protect wildlife habitats and species through the creation and overseeing the implementation of the BAP. The BAP is also used by Richmond Council’s Planning Department to ensure the impact of new developments and changes to existing developments are minimised to the species and habitats featured in the BAP.

Other activities have included tours to biodiversity-rich green spaces in the borough to share best practice, habitat management and projects; leaflets on the importance of certain species, and garden surveys to encourage local residents to take an interest in their gardens.

Members represent a range of local interests concerned with wildlife and biodiversity, including:


11.1 The submitted tree felling drawing gives a misleading summary of trees to be felled as it pinpoints approximately 8 in the copse quadrants. This is however contradicted by a later English Heritage e mail to locals that stated 347 trees will be felled. (see appendix AP3)

The email is far more explicit than readily readable on line information. It states:

13 trees are removed related to cafe proposal work.

331 trees are removed from the copses either side of Marble Hill House and also 97 coppiced

181 retained.

This results in the removal of 70% of the currently visible tree growth in the copses. It has a major effect on the perceived landscape not only at close proximity but at a distance. There is a major thinning and therefore loss of strategic tree belts either side of the house.

11.2 Consultant landscape experts Terra Firma and tree expert Bernie Haverson co-authored the Thames Strategy and advised on the Orleans Gardens   Gloriana campaign to prevent tree loss. The advice is that there is a contradiction between proposed action as long term practice and what is necessary in the immediate term   and this greatly harms the habitat.

11.3 Clearance of the copses will damage the current ecological balance and the beneficial effect to these species, if any, of replacement trees around the park is measured in a delay of decades and may not produce the necessary refuges. Certainly not in the near term.

11.4 The application states 347 removals and 401 new trees. This is a 2.2% increase. (not counting coppicing). This is not a planning gain but the minimum to be expected as part of normal stewardship and management. The effect of replacements will only be felt in 20-30 years.

The conclusion is that the application attempts a tick box approach to Planning requirements and fails in detail and overview



Good Practice in Public Consultation is defined by the Royal Town Planning Institute. It places great emphasis on the means of communication and carrying the pubic forward .Ref Guidelines on effective community involvement and consultation, RTPI Good Practice Guide Note 1. (16)

Features noted by the RTPI not followed by the applicant of this application are:

  1. Clear information, explaining what could be changed and inviting new ideas and considering alternatives.
  2. Involving participants in evaluation.
  3. Running visits to similar installations.
  4. Clarity particularly of online information and issue full paper plans and reports on the basis many persons are not viewing online
  5. Written documents that are easy to navigate and with a non technical summary
  6. Establishing a residents/community steering group.
  7. Consider independent mediators to find a solution if disagreement cannot be resolved

The essence of the process required is sequential: from a base of exhaustive and easily understood information, transparently presented, discussing and amending the scheme, having stake holder representatives on board to shape the scheme, providing visits to examples, and resolving differences of opinion and bringing in mediators where disagreement remains.


The scheme is complex, having three primary roles. There is the restoration of the historic house, the generation of funds and there is the role as an established green open space serving as a public park.

Local users and neighbours report that when concerns over features of the application have been raised, verbal reassurances at consultation meetings have downscaled or eliminated the original description. Then at further meetings they were apparently still on the agenda.

Quoted examples of contradictions and errors are:

Neighbours complain of misrepresentation of the outcome of personal meetings (see Appendix AP1)/ Non action on agreed outcomes (see Appendix 4.10)The application originally had reference to weddings and marquees. English Heritage then announced in consultation meetings and they were dropped and it was said they would be a separate application. / The car park was originally described as only approximately ever half full. Locals stated otherwise. Data on car park capacity now appears to be discarded. /The Management Plan of January 17 para 4.5 implied at first sight little in the way of public events. “Main Event…one day music festival run by members of Soho House” but later referred to “food festivals and concerts” and “can be booked for weddings”/ The Traffic Report ignored overall impact by para 4.6 stating: “separate large events are at Marble Hill Park and operate under separate planning submissions and as such do not form part of the assessment”. /Consultation meeting stated restaurant roof lights would be removed but they remain. /The height of the listed wall on the South End House side was drawn and noted significantly less than in practice. /Reports of local and neighbour support by EH are disagreed with/Acoustic reports mentioned out of hours operation of restaurant. Yet there are statements on strict hours. / There has been online application reports for the restaurant of licensing, and then a retractment. /Coaches were a feature of the early submission and there handling seems unresolved. / The submitted tree felling drawing recorded just a few trees to be removed. Subsequent reports put the number in triple hundreds. /residents complain of misrepresentation of outcome at meetings./ No evaluation of the impact of later event approvals in the intended management plan.

The ground plan of the cafe proposal has serious inconsistencies with the survey in measurement, boundary distance and areas, and with subsequent on-site measurements. The sports change plan is inaccurate.

The application presents what are normal management duties expected of the stewardship as planning gain. One example is tree removal and replacement . The minimal increase in trees the applicant proposes (2.2%) is the very least expected in a management programme that should be occurring anyway to compensate for loss due to disease, and human damage. It is therefore not planning gain.

Paragraph redacted


The conclusion of the majority of involved local residents is that public consultation has been so piecemeal that there has been no continuity of message and proposals. Meetings have been held with certain undertakings made; these have changed at later meetings. Professionals have found the submission difficult to unravel and when achieved, many errors, omissions and manipulations appear. As result the whole process has been compromised,



13.1 A standard practice in cases of Pollution and high carbon footprint is to offer mitigation measures. However the standard ones for buildings such as enhanced insulation, low energy envelopes, sealing of windows and eco heat generation cannot be offered here. The high and damaging pollution impact, for example, cannot simply be mitigated by mimimal tree planting that barely replaces what is felled, and increased sport, and is actually aggravated by decanting traffic to surrounding roads. New planting is very long term and sport is not beneficial to large proportions of the disabled, frail and elderly. Tick box assessments are a crude tool and do not adequately reflect the demands of Policy.

13.2 The addition of tree stock represents an increase in stock according to the applicant’s own estimate of only 2.2% and there will inevitably be loss of some individual new trees in the early years. Any sustainability gain is only felt beneficially after decades. However in this case such a small increase is not a mitigation as the carbon footprint of mechanical cutting, felling, trucking, redigging and planting, not to mention the loss 20 yearsof mature leaf performance, is higher than the carbon offset of the few additional trees. It has no bearing on the carbon footprint and sustainability harm of the restaurant construction and operation, the event carbon impact and the increased traffic and pollution. The number increase is the bare minimum allowance for natural wastage. There is no mitigation.

13.3 The application has in effect removed problems it cannot solve and pushed them into surrounding areas where no calculations are being carried out.

The correct approach is finding the proper balances.



The history of the landscape is long and complicated and for brevity in this core report more detail is covered in Appendix 5.

A number of scholars agree that while Pope was given credit for design of the grounds, it was not actually what materialised (Dr Paul Jaques,and F E Salfor et al ).It seems his self promotion slanted history in his favour and this has been recycled in most non academic peer reviewed papers. He was undoubtedly a leading exponent of the art, lived close by and spent much time managing the land in Henrietta Howard’s early absence; but his style was on the point of waning. He walked the site with Charles Bridgeman and Henrietta, but Bridgeman’s recorded opinion of preparatory work was very restrained. The English Heritage Table of technical dates of construction of features is only able to loosely mention Pope as a possible proposer of a bowling green. The table also contradicts itself on archaeoligical findings compared with Dr.Jaque’s theories.

At the time many aristocrats were building stately piles and often left the design to committees of gentry and aristocratic friends which they oversaw. Henrietta was a flame around whom enthusiastic moths gathered, many with landscape interests, jostling for influence. She relied on Lord Burlington to be decisive, who also protected Pope who had many enemies as a Catholic. Her successful years at court had honed her skills of rejection without offence. It is noticeable she brought in Charles Bridgeman early on but he was apologetic in being preoccupied with his great work at Stowe. A scenario of many hands and too little single minded drive emerges.

The probability is that while seductive plans abounded, nothing could actually take shape until the building was finished. Not simply that land had yet to be acquired and building took up a great deal of space, but there were severe delays due to the King’s death.

Pope’s own garden was quite unique in its problems consisting of a small “front” open to the river and offering no privacy, and then a rear portion beyond the road. The layout of the main garden offers little that could be described as a template for Marble Hill House as even the bowling green , while ovoid, has no pergola edging and no axial relationship to key points such as Marble Hill offers between House and river.. Ref J Serle 1748 (29)

We do know that the aquisition of plants and trees occurred predominantly from the 1750’s onwards, long after Pope and Bridgeman’s deaths. The replacement gardener had a work specification that pointed to a relatively simple garden, rolling gravel paths, cutting grass, bringing on seeds. It is very noticeable that one task was to maintain the “wild quarters and shrubs” It was a well established fashion to have houses in areas of coppice planting and this was a long process: as one author observes even “wildernesses took years to design and arrange”..

The practicalities of construction are rarely addressed in the historical accounts: In the first instance the basements would be dug and drains laid across the land, with large piles of spoil set aside. Building material would have been landed by barge from the river frontage or carted across the land from the north. They would be stockpiled, and areas given over to stone and brick working, storage of timber to mature, log sawing pits, carpentry work areas, and fine carving work. Wet trades such as plaster and stucco would have been worked up on site demanding supplies of water. Many of these processes needed cover and there was also the question of housing itinerant workers. The archaeology reports show the grotto was not, as originally supposed, an excavation for building material such as clay, so we have to presume brick firing took place off site. The result would have been, like all large building sites today, a quagmire of mud and collected water, track ways, scattered huts and mixed soil and gravel. All this could only be remedied after the house was complete and would take several years before planting,

We do know that the kitchen and dairy at the far north east were admired, and drawn in detail on the supposed Bridgeman Plan. These would sensibly have been brought on early as they were away from the construction area and would mature for food production in time for occupation. These were much admired by Henrietta’s circle so it is important to note that no such praise or comment ensued for the main gardens and pleasure grounds.

The much praised entertaining by dining with friends complimenting the freshness of vegetables and dairy dishes has important implications. In the first place this was rebellious cuisine to suitHenrietta’s circle, as Georgian England eschewed vegetables as virtually poisonous. Henrietta ran a small farm and basedon the amount of milk needed for entertaining and the required grazing for cows of the time , It accounts for most of the land acquired before the 1750’s.

It is known that the land acquisition was a long and tedious business involving in some cases clever legal footwork, and so the prime river frontages were only available long after Pope and Bridgeman’s deaths.

There are indications that the grounds were never reformed into anything matching the initial ideas. Jonothan Swift wrote of the lazy approach of the gardner Mr Moody, spending too much time drinking, and the contract of work for his successor, Daniel Carter, speaks of very modest responsibilities. This was not materialising into a visionary and showpiece garden.

Finally we have not a single mention in Henrietta’s letters of her excitement over what had been created.,orfriends praising it. The only praise among her contemporaries was over her dairy and kitchen garden (indeed very fashionable)

It is strange that in all her letters she never referred to anticipation of planting as the proposed pleasure gardens were supposed to be taking shape. It ‘s lack of external entertainment is perhaps explained bt Henrietts’s letter to Berkley in 1741: “ Though I am very fond of the place, I do allow it will not afford much for your amusement…” (30 page 193)

The conclusion one has to draw is that the original vision, was deftly adjusted by Bridgeman and never materialised. It certainly seems Bridgeman kept clear, first because Pope was a pain to work with as friends knew, and secondly he was the King’s Gardener; a King who bore grudges. It is unlikely therefore that Bridgeman continued any relationship after Henrietta left the court under a cloud in 1734. Bridgeman and his widow up to 7 years after his death immortalised all his works in famous and skilful etchings by Jacques Rigaud, and yet Marble Hill is absent, Finally we have the archaeology evidence that shows nothing of the original concepts were in place in the end. And even the grass terracing is natural, Many independent etchings of the period showing what we see now is what existed then.

Eye witness accounts talk of grass meadows down to the river, celebrated etchings concur, and John Spyer, the landscaper and draughtsman celebrated by Royal Palaces and the British Library for his accuracy, again drew meadows and cattle.

One must add that the “Norfolk drawings” are discredited, as they were clearly representing the whole ultimate land holding achieved when Bridgeman was long since dead. In addition, with the death of her second husband Charles Berkeley, Henrietta began to form a new circle one member of which was landscape expert Richard Owen Cambridge who transformed the neighbouring plot in what has become known as Cambridge Park and was praised for his meadows down to the River. As a result, by the time she bought her plants according to record, landscape fashion had changed and influences were of the very naturalistic approach. And that is exactly what is described by eyewitnesses .


15.1 The overriding characteristic of the planning application is the maximisation of footfall and income at the expense of a rationed and moderate level appropriate to impact. There are stated ambitions of leading a coordinated marketing campaign of all the surrounding Heritage Mansions together as a tourist destination. The Design and Access Statement Part 17 has Historic England acknowledging the aim to “unlock potential” The campaigners maintain that what appears an aim for maximum commercial potential is inappropriate at Marble Hill park in its ambition and impact, but no figures are released.

15.2 The applicant has failed to follow Good Practice as recommended by the RTPI in community consultation engagement, by only engaging in top-down presentation. There is no joint evolution of primary elements with the community (such as restaurant and woodland), indeed no discussion, and no local representation as a working party, and no organised visits to other sites and installations.

15.3 There remain many serious errors in the submission such as the BREAM assessment, Health assessment and Traffic and Pollution. The record of discussions with neighbours is disputed and drawing errors of relationships incorrect at South End House. With regard to studies, the external site visual impact and history is discounted. The Traffic impact on surrounding roads is demonstrably incorrect and not cognisant of other impacts, The question of whether weddings and marquees are a feature or not and just how many events and what size will occur remains a mystery. Lack of clarity remains on what might remain of the copse habitat given a contradiction between drawings and statements.

15.4 There is recorded evidence that the surrounding roads are subject to increasing congestion. Expert reports for other developments   record   Richmond Road at already 96% saturation and parking under “high stress” and with poor air quality. The cause is supported by interviews with sports teams, that agree that the parking difficulties result from the current heightening of pitch use . This is before factoring –in the increase in House visitors, Park events and restaurant .

15.5 There are public safety considerations for the haphazard traffic and child-centred pedestrian movements in Orleans Road, and Public Health concerns for the locality due to increased pollution in an already non compliant zone. The result of the increased visiting and events will exacerbate the problem and the resulting pollution is unacceptable on health grounds with particular sensitivities for a park and the schools.

15.6 The submitted application traffic study failed to be comprehensive and was park-centric, when all the evidence demonstrates the impact is mainly outside the park. These effects are in contradiction to planning policy

15.7 There is evidence that the expert reports were managed to promote an inaccurate overall impact.

15.8 The Park is a contiguous reservoir of habitat with The Thames, Petersham Meadows , Richmond Park, Orleans Gardens and House Grounds , and as a result harmful environment impacts rejected at other nodes in the complex organism , should not be nurtured and grown by degrees at Marble Hill Park. There has been no appreciation of the park as a lung, meeting place and nature reserve for the local community.

15,9 The presentation of community gain   by increased tree numbers is not a planning gain as the minimal increase is a normal landscape management expectation. The new trees do not offset the carbon footprint of the proposals and the whole proposal does not satisfy sustainability requirements .

The carbon footprint and pollution of the proposals greatly increases the neighbourhood negative experience. The net effect is increased harm to health by pollution, threat to public safety and inhibition of normal life.

15.10 The overall conclusion is that the application is harmful and   immoderate, fails to achieve balance to meet criticism and is not as holistic in the way it serves the frail of the community as it should be.

15.11. An overriding consideration is the salami-slicing of natural habitat where each loss is discounted as inconsequential and balanced by tick box sustainability points. The Marble Hill/Orleans/Petersham/Richmond Park and Thames eco system is a world admired achievement ,even more miraculous for being in a city. The starting point for the applicant should have been that very asset.

15.11 The recommendation is that the application requires moderating by withdrawal and change in conjunction with a local representative working party in accord with RTPI Good Practice followed by a new submission with its support.

This report is signed off by:


Martin Habell Dip Arch ATP RIBA FRSPH Chartered Architect

Representing all campaigners and following proof reading circulation





This report is long, for which apologies are offered, but in the circumstances campaigners could see no other way of getting the message across to the planning authority on the absence of technical credibility in the submission. It should however be seen as an optimistic springboard to something exciting. The ambitions of English Heritage for the house are applauded , It is the park that presents a problem. It is not insoluble. There are many imaginative ways by which income could be generated without recourse to excessive footfall, conservation transgressions and traffic. More could be made of this. English Heritage really ought to tap into the wealth of entrepreneurial skills that exist in the Borough. Given the lack of pedigree of the landscape as installed , the applicant could seize the opportunity to blend biodiversity into modern interpretations of landscape. (As some historic estates are now doing) This could provide an exciting draw when taking in Ham House and Strawberry Hill and solve the practical problems of the current plans. A biodiverse-led approach is educational and ecologically vital. An historic reference is still possible in part and there are ways these days to generate virtual reality experiences. Marble Hill could be made much more of a marketable brand without the wear and tear. The hard work done by English Heritage should not be regarded as wasted so much as a necessary stage reached to bring on board a small local panel in accord with RTPI public consultation recommendations to push the next stage forward. This worked for Twickenham Riverside .

Representatives of the campaigners would be only too willing to share these ideas to assist.




17.1 Reference is made to Reports on bats by Ecology Consultant Alison Fure. Also to the traffic and pollution reports of Gateway for the planned Lidl supermarket and school.

In accord with planning requirements that expert submitted work should be a relevantly experienced professional in a given field the following are:

Mandie Adams MBE :Organisation

Robyn Butcher Ba (Hons)Dip. LA CMLA: Landscape Impact

Paul Bigley Director

Caroline Dyball: BA History/ Law Society : FOI’s and research (Local resident)

Mary Farmer, Special Education : Research

Janine Fotiadis-Negrepont BA(hons) Bsc : EH In-house reviews, FOI’s (Local resident)

Martin Habell : Dip ARCH ATP RIBA FRSPH Chartered Architect , Urban Designer, Fellow of the Royal Society for Public Health and institutional adviser, University Design Board Member, Arts and Humanities Council, Director: Research and Statement, (Local Resident)

Lady Shiela Hale, Trustee of Venice in Peril, Author.

Bernie Harverson M.Arb, : Trees

David Mills Planning Lawyer: Planning arguments

Ian Mortimer: BSc CENG MICE MIStructE Chartered engineer : Structure, development operational and capital costs

Richard Woolf Chartered Architect and RIBA Approved Conservation expert : Conservation Best Practice.


Photography (see appendix) documents will be issued independently from additional experts






Subsequent to my previous objection I wish submit the following;


Dear Mr. Lamont,

I wish to issue a statement in response to English Heritage’ Design and access statement. 

On page 103, “Engagement with Neighbours” it has been suggested a higher boundary wall would be welcomed if this effectively mitigates the potential acoustic issues.

This comment is totally misleading.  What was welcomed was the replacement of a picket fence with a brick wall to our main driveway section of the boundary. 

In the initial meeting with English Heritage the true height of the proposed brick boundary wall was never fully discussed and was thought to be no higher than the Ivy growing on top of the wall.  It was only much later demonstrated just how much of an increase there would be impacting our property and our neighbours.  It was communicated that such a height was wholly unacceptable and intrusive.  In March this year, I invited Alex Sydney (from English Heritage) on-site to go over the latest plans which he never took up and was concluded by English Heritage submitting the application.  Furthermore, a later Email was sent to Alex Sydney highlighting our concern.

Since our full objection, to date, we have only had a conservation officer to site to look at the brick wall boundary and I am surprised that a planning officer has not made an appointment in response to my objection overall to look at the site as a whole. 

The impact to South End House, its listed Gazebo, grounds and the surrounding conservation area will be devastating and irreversible.  I would direct you back to my objection previously made and hope all policies that were put in place to protect our historic buildings and environment, procedures to be closely followed irrespective of the applicant.  The size and scale of the stable café proposals are totally inappropriate and it has been proven on many other sites such scale is not justified.

Yours sincerely,

James Winn for and on behalf of WINN & COALES INTERNATIONAL LTD

South End House, 30 Montpelier Row, Twickenham, TW1 2NQ



22November 2017


Hi Abi 

A medium sized lorry – contact Cheyenne at EH (Vanity Fair Filming?)  – has just got ‘lost’ at the end of Montpelier Row.  The car behind him trying to get into South End House for a meeting had to reverse and wait for the poor driver to reverse back down the road.  This is not easy to do in a large vehicle.  

EH has promised that all delivery drivers for the house would be told not to drive down Montpelier Row.  If drivers reverse at the end they damage my plants and trees.  This is an on-going problem which EH has failed to solve.  How will we manage if current plans are approved by the council?

And, as I type, a large white Ford pickup van is also ‘lost’ trying to find Marble Hill House.  There is no turning space for your deliveries and any associated with Marble Hill House.

Tanya Boyd 


From: “Marsh, Abi” <>
To: tanya boyd <>; James Winn <>; “Sydney, Alex” <>
Sent: Friday, 30 June 2017, 10:34
Subject: RE: Montpelier Row – Marble Hill Park event

Dear Both

Thank you for your emails.

I am truly sorry that you have had to deal with this issue this morning. I have immediately rung the site and spoken to the event organisers and asked that they deal with this. There should indeed be a steward at the entrance to the park and your road who is managing this and preventing this known issue. I have also asked our Ranger Gary to go to your road straight away and ensure that this is in place and if need be fulfil this role himself and report back to me.

I am, like you, frustrated that this has happened and have taken steps to ensure that it is resolved. I hope this will be the end of the issue. If you have any further concerns please do not hesitate to give me a call or drop me another email.

Many thanks


Abi Marsh | Area Manager, London | Historic Properties London and East

 English Heritage, Eltham Palace

Court Yard, Eltham, London, SE9 5QE

Mob:  07584 883822


From: tanya boyd []
Sent: 30 June 2017 10:25
To: James Winn; Sydney, Alex
Cc: Marsh, Abi
Subject: Re: Montpelier Row – Marble Hill Park event

It’s true – started early this morning.  We have no turning space for large vehicles.  James’ wall and gates were damaged last night by a police chase so we absolutely cannot risk anyone hitting the wall between South End House and the drive way at 29.  




30th June 2017

From: James Winn <>
To: Alex Sydney <>
Cc: “Marsh, Abi” <>
Sent: Friday, 30 June 2017, 10:22
Subject: Montpelier Row – Marble Hill Park event


For the last three hours since I have been at home there have been numerous event vehicles coming down to the bottom of Montpelier Row looking for the ‘House Festival site’.

I had assumed this year you were not permitting event traffic until Monday due to not having the entrance of Montpelier Row marshalled until then. 

 Moving forwards with the recent proposals for Marble Hill Park it is clear further traffic prevention methods need to be considered.

Can you please act upon this before the residents are further inconvenienced or damage is caused.

Many thanks,

 James Winn.

30 Montpelier Row




Warwick Reynolds: East Surrey Badger Protection Society and Badger Trust Recommended by Natural England  Home: 020-8688 9905 Mobile: 07973 327017 

He made a site visit at the beginning of October and established badger activity from previous evening or the night before that; hairs, scratchings and dung. Dung found in quadrant next to the house on the right as you stand on the river side. Also badger trails (very obvious). Setts throughout the four copses though couldn’t find the ones on the left near the house on my last visit.

Wasn’t sure if the setts were in use but established that this would have once been a prolific community. Questionable whether the works over the years within the copses had pushed the badgers out.

Asked me to establish where the main sett is now within ¼ of a mile to ½ a mile maximum away from copses – likely within the park. 

Badgers like slopes for their setts. We also established abandoned setts within Orleans woods and the abandoned house/garden that is owned by Orleans Gallery Trust. An old lady lived there until she recently passed away The Gallery now plan to develop this house. This could potentially open access to the playing fields of Orleans School from Orleans Road where the house sits backing onto the woods.


English Heritage did not get badger licences for archaeological works within the front right quadrant (they should have). Photographs were online of the dig there.

My contact at Natural England is


Janine Fotiadis-Negreponte




From: Janine Fotiadis-Negreponte <>

To: Andrew Vaughan <>

Cc: Tasha Hunter <>

Sent: Friday, 24 November 2017 13:40:49 GMT

Subject: Detailed Tree Removal documents from English Heritage (Marble Hill Park)

Dear Andrew,

I hope you’re well, I’d be grateful if you could forward this email to Craig Ruddick, Tree Officer as I do not have his contact.

We are concerned that information regarding trees on the planning portal in reference to The Marble Hill scheme has not been updated.

We would like to request that this information is made public as part of the consultation process (please see below). Many, many local people are convinced that just 30 trees are to be removed from our park as the public information suggests. We feel that this information is germane to the planning application.

A further concern also follows an email from Kate Pitt on Wednesday in relation to the proposed replanting scheme by English Heritage at Marble Hill Park. In it she says,

RESPONSE: Dear Janine

Thank you for your requests to view any replanting scheme currently in existence as part of the Marble Hill Revived project.

I believe our Freedom of Information team has already informed you that as yet, there is no definitive scheme. Though our landscape historians know where trees and plants would have been situated thanks to the plans, survey and other documents we have been studying,  they are gathering evidence as to what might have been planted in Henrietta Howard’s garden.

Detailed work – and indeed consultation – on the planting scheme and its schedule must wait until we have the funds to resource this stage of our research and development. Thus, we are unable to advance it until planning permission has been agreed and our funding from the Heritage Lottery Fund released.

I look forward to discussing this with you when we reach this stage.

Best wishes 


Kate Pitt

Audience Development Manager


I hope you can appreciate that it is worrying to hear that planning permission could go ahead without a detailed replanting programme in place. How can we be sure of the impact on biodiversity if there isn’t a concrete plan to mitigate? And what’s to say English Heritage scrap a replanting programme altogether? These trees are community assets and intrinsic to the park’s biodiversity can you please reassure us that this matter will be looked into.

Thank you for taking the time to read this.

Kindest regards

Janine Fotiadis-Negrepontis




From: “Pitt, Kate” <>
Date: 22 September 2017 at 14:00:33 BST
To: ‘Janine Fotiadis’ <>
Subject: Marble HIll Tree

Hello Janine,

Here is the information I discussed earlier from our Head of Landscape and Gardens. The map will be available soon on Richmond Planning Portal – I’m just trying to get clarity of when this will be.

There are 1837 trees in Marble Hill Park. We are proposing to remove 347, of which 326 come from the woodland quarters. The 347 tree removals equate to 18.9% of the tree stock. We will be planting 401 new trees, this is a 2.2% increase in the number of trees on site. It is estimated that after all the proposed tree removals and the proposed re-planting programme is completed, tree cover will extend by 0.5 ha to 42% of the site.

The tree survey exercise has focused on the proposed areas of park improvements and identified 66 (sixty six) individual specimen trees and 24 (twenty four) groups of trees. Within these groups, 234 (two hundred and thirty four) trees were considered worthy of note. The development works focus on three areas of the park; improving the existing café facilities within the stable block area; improving the play facilities adjacent to the stable block and reinstating the landscaping around Marble Hill House and down to the River Thames.

Improvements to the café facilities at the stable block will require the removal of 3 (three) trees, an additional group of 9 (nine) trees to the right of the café, and 1 (one) low grade tree to the south of the café will be removed to improve the growing conditions for the remaining trees within the group.  Next to the house 3 (three) trees are proposed for removal and amongst the Western avenue towards the Thames a further 4 (four) trees are proposed for removal.

There are 609 trees within the four woodland quarters south of the house of these 326 are proposed for removal to reduce the significant overcrowding and enable the remaining and newly planted trees to grow under better light conditions and the generation of a ground flora which will improve biodiversity.

Improvements to the play area adjacent to the stable block do not require any trees to be removed as a direct result of the works. One poor quality tree (Sambucus nigra) will be removed due to its condition. The proposed play equipment is to be positioned to avoid tree protection zones.

The landscape reinstatement works to the four quarters around Marble Hill House and part of the grounds down towards the River Thames will require the management of these areas through the removal of a number of trees, the coppicing of trees, the retention of trees and the replanting of trees.

The south-east quadrant (Group 7) will require the removal of 88 (eighty eight) trees, the retention of 73 (seventy three) trees and the coppicing of 44 (forty four) trees.

The north-east quadrant (Group 8) will require the removal of 74 (seventy four) trees, the retention of 21 (twenty one) trees and the coppicing of 7 (seven) trees. (One tree has been removed since the original survey).

The north-west quadrant (Group 9) will require the removal of 86 (eighty six) trees, the retention of 55 (fifty five) trees and the coppicing of 15 (fifteen) trees. (One tree has been removed since the original survey and one was a duplicate tree).

The south-west quadrant (Group 10) will require the removal of 83 (eight three) trees, the retention of 32 (thirty two) trees and the coppicing of 31 (thirty one) trees.

Five trees are recommended for removal for reasons of sound arboricultural management regardless of any development proposals. Therefore the removal of these poor quality trees should not have a bearing on this development proposal.



Redacted in consideration of community relations


REF: 17/1663 dated 25 September. Information concerning ‘lost gardens’ or landscaped gardens at Marble Hill.

REF: 17/1678 dated 29 September. Information concerning the 1752 garden plan/ survey and its legitimacy.

Campaigners comment: It is known that English Heritage has tried on numerous occasions to lay-out gardens at Marble Hill Park. Each time the gardens are from the time of a different owner of the house. There is growing concern that the gardens from the plan dated ‘about’ 1752 and for which Heritage lottery Funding has been awarded funding to lay out an interpretation, were never executed but rather just a plan. There’s mounting scholarly evidence to suggest Pope made his plan as a ‘Homeric conceit’ (Notes: Alexander Pope and Circe’s Dome. Salfour F.E. Oxford University Press.1991).

Famous paintings of Marble Hill during the 1700s show no signs of such an intricate garden. The literature on English Heritage’s website does not substantiate claims that these so-called ‘lost gardens’ ever existed.

The provenance of the survey quoted by English heritage and the date given to it is in the public interest, 326 trees will be felled from a public park to make way for Henrietta’s garden. Railings will likely be put around the garden forever changing this semi rural landscape. Wildlife habitats and foraging woodland will be eradicated as part of the landscaping. I, and many others believe the gardens were never implemented and we would like English Heritage to provide further information regarding the gardens.

One figure absent from histories is Robert Owen Cambridge after whom Cambridge Park is named. A polymath, he was celebrated at the time to as great a degree than Pope, as historian, designer, poet and writer to such a degree he drew admiring comment from Pope as “Cambridge the everything”. He laid out his estate adjacent to Marble Hill to so much praise that Capability Brown came to visit. Cambridge was a close friend of Henrietta Howard and his friendship blossomed after Pope had faded from contact but coincided with the acquisition of the key elements of the estate. It is entirely possible he was a part of the coterie of persons who realised the final gardens and English Heritage may find it worthwhile researching this further.


EF: 17/1664 dated 25 September. Copy of the full agenda, minutes, notes and actions from the meeting that took place on 24 May 2017.

Campaigners comment: The information requested here is important because we are left wondering how much park will be left after the 11 sports pitches are drawn up, the landscaped gardens fenced off, the 140 seat café built, the extension of the car park etc etc.

Our public park is semi rural today however once English heritage’s plans go ahead people who wish to simply walk in the park and use it in its natural form and not visit the café or play organised sport will it seems be pushed to the periphery as the green space becomes designated space.

This information is incredibly important to the public as The Park is designated Open Metropolitan Land protected under law.


REF: 17/1666 dated 25 September. Information concerning coach parking and coach drop off points for Marble Hill. You have also asked for information concerning boat services to and from Hammerton’s Ferry for Marble Hill visitors and their destinations.

Campaigners comment: It is important for us to establish where the coaches will be parked as Alex Sidney mentioned at a public meeting that coaches would be parked at Orleans Gallery. This road is a narrow joint vehicular and pedestrian and would present many dangers to pedestrians if coaches used this busy residential road and there’s no alternative route available to the gallery.

And so its of great importance to local residents to know where the coaches will drop off. English Heritage has said it cannot use the parking onsite as coaches cannot turn into Marble Hill Park from Richmond Road and so we would like to know where the coaches will park.

We know that English Heritage lease the moorings to Hammerton’s Ferry and would like to ascertain whether boat services will be arriving at the site as a way of getting new visitors to Marble Hill as intimated by Alex Sidney at a minuted meeting held at York House recently.

We are trying to understand how an extra 40,000 visitors from further afield (EH projections) will get to the site without having an impact on our local infrastructure as English heritage states.


REF: 17/1676 dated 29 September. Information concerning the future staging of special events at Marble Hill, including financial forecasts and projected visitor numbers.

Campaigners comment: We know there will be a maximum of 12 weddings a year of 150-200 people but what isn’t clear is how many ‘special events’ will be held in our public park. These ‘special events’ fall under a different license and English Heritage will not provide the details of how many it wishes to hold.

In recent years The House Festival held at The Park meant that ‘controlled access’ was used at the gates. Meaning the public were locked out of the park during the event. Of course it is in the interest of park-goers to know how often this is likely to happen. We have not been informed about the proposed scale of the ‘special events’ whether they will be pop concerts, classical concerts or house festivals. This is concerning because the local infrastructure cannot cope with large-scale events and so it should be information available to the public.

We requested financial forecasts because this would be the best way to ascertain the scale of the ‘special events’. After all this is a public park, it is Open Metropolitan Land and the public have a right to know how their park will be used and to know the likely impact on the immediate vicinity; noise, traffic, rowdiness etc


Extract from English Heritage’s “Outline Business Plan And Justification for Long Term Sustainability”

Marble Hill sits in the middle of a cluster of historic visitor attractions – Ham House (114,662 visitors in 2014/15), Strawberry Hill (estimated 72,838 visitors in 2014/15), Orleans House, and now Turners House are all in close proximity. There is already a relatively high level of visitation from outside the borough to the first two of these properties, and we anticipate that 6.7% of these visitors (12,500) is very unachievable – particularly given the fact that Marble Hill House will be free entry.


Furthermore, although it has been talked about before many times, these properties have never before actually managed to galvanise themselves into a coherent marketing package. EH plans as part of this project to take a lead in establishing a Thames-side villas marketing offer which we hope to publicise far more effectively (and cost effectively through PR opportunities and social media opportunities). Representatives from all the other organisations have already indicated their strong support for us offering to take this initiative. Marble Hill sits in the middle of a cluster of historic visitor attractions – Ham House (114,662 visitors in 2014/15), Strawberry Hill (estimated 72,838 visitors in 2014/15), Orleans House, and now Turners House are all in close proximity. There is already a relatively high level of visitation from outside the borough to the first two of these properties, and we anticipate that 6.7% of these visitors (12,500) is very unachievable – particularly given the fact that Marble Hill House will be free entry.


Furthermore, although it has been talked about before many times, these properties have never before actually managed to galvanise themselves into a coherent marketing package. EH plans as part of this project to take a lead in establishing a Thames-side villas marketing offer which we hope to publicise far more effectively (and cost effectively through PR opportunities and social media opportunities). Representatives from all the other organisations have already indicated their strong support for us offering to take this initiative.


AP 4.7 Redacted


EF: 17/1664 dated 25 September. Copy of the full agenda, minutes, notes and actions from the meeting that took place on 24 May 2017.

Campaigners comment: English Heritage held a meeting on 24 May 2017, the meeting was attended by EH’s Project Manager, Landscaping, Planning Consultants, Transport Consultants, Arboriculturalist consultant and the Ecologist.

There are many unanswered questions regarding the trees, the wildlife and ecology of The Park, traffic and congestion and parking, the landscaping of our woodland quarters where 326 trees are proposed to be felled. This meeting was attended by most of the key-players in the Marble Hill Revived Project and we believe that this meeting was solely to discuss our public park and as such feel validated to ask for a copy of the minutes.

Again, this should not be time consuming as Frances Gibbons (FOI team) has already located the minutes and sent me a section to do with ‘sport intensification’. All we are simply asking is for the complete document to be released.

 REF: 17/1660 dated 25 September. Copy of the Ecology Report concerning the Marble Hill Revived project.

Campaigners comment: Alex Sidney said he would get a copy of the ecology report to me at a minuted meeting in York House, Twickenham months ago attended by two local councillors and a spokesperson for LBRuT planning department. I also asked Kate Pitt for a copy but have yet to receive it. And so I am forced to use The Freedom of Information Act to locate a document that should be freely available considering the scale of the project and the planned loss of so may trees. English heritage have a duty to release this information as part of the consultation process.

We are in contact with The Wildlife Crime Prevention Unit in regards to the badger population of Marble Hill Park as unlicensed works appear to have been carried out within close proximity to numerous setts.The ecology report is invaluable as plans for the park include the felling of more than 340 trees and the park’s wildlife may be affected by this including other protected species such as bats and stag beetles.It is in the public interest that this document should be released. The woodland quarters where 326 trees are earmarked for removal provides foraging for bats and badgers and public interest is extremely high on this topic.

REF: 17/1661 dated 25 September. Information concerning badgers at Marble Hill Park.

Campaigners comment: This refers to the badger population of Marble Hill Park. Having visited the site with a professional from The Badger Trust recommended by Natural England it is apparent that badgers have not been mentioned in any information publicly available.

We have on going communications with the Thames Wildlife Police Unit regarding the badgers and it is in the public interest that any information pertaining to the badgers is released.

It is our belief that the badger population is known to English Heritage yet digs have taken place contrary to The Badger Protection Act 1992.

Again this information would not be time consuming to locate and is of the upmost importance considering 326 trees are to be taken down from the woodland quarters where badgers visit and possibly live.



REF: 17/1662 dated 25 September. The amount of timetabled sport at the park and revenue generation. Emails concerning intensification of sport at the park.

REF: 17/1677 dated 29 September. Information concerning the intensification of sport at Marble Hill, including estimated forecasts both monetary and visitor/ participant numbers.

Internal emails state that there will be a programme of ‘sport intensification’ at Marble Hill in the future. The agenda from The LB Richmond & Project Team Meeting on Wednesday 24th May 2017 (10:00) states: ‘Intensification of use implications of sports facilities.’ Internal emails also refer to the impact of sport intensification and the impact on parking and traffic will be left out of traffic reports unless LBRuT ask for it specifically.

In an email dated 12 January 2017 from Chris Elliot to Jennifer Rimmer, Ndai Halisch, Luke Kelly and Ian Dix. Chris Elliot writes,

‘How have the future forecasts been calculated? i.e. the anticipated increase in park users/sports pitch users/visitors to the house? Chris – please speak to Luke Fisher – or 0131 4406750. He is expecting your call. He has been extrapolating the figures.

Campaigners comment: It would not be time consuming to gather this information as Luke Fisher has it to hand and if English Heritage plan sports intensification at our local park local residents should be aware of this as there will already be a 40,000 person increase to the park yearly as part of English Heritage’s Marble Hill Revived Project.

More sports pitches have been added to Marble Hill Park in recent years and we would like to assess what impact the ‘Sports intensification’ will have on the local infrastructure. We Campaigners ask for information relating to current timetabled sport at the park in order to make a comparison with future projections. As noted in the agenda for the meeting it says ‘implications’ of sports facilities. And so English Heritage acknowledges a foreseeable problem privately.

REF: 17/1663 dated 25 September. Information concerning ‘lost gardens’ or landscaped gardens at Marble Hill.

REF: 17/1678 dated 29 September. Information concerning the 1752 garden plan/ survey and its legitimacy.

Campaigners comment at the time

It is known that English Heritage has tried on numerous occasions to lay-out gardens at Marble Hill Park each time the gardens are from the time of a different owner of the house.

There is growing concern that the gardens from the plan dated ‘about’ 1752 and for which Heritage lottery Funding has been awarded funding to lay out an interpretation were never executed but rather just a plan.

There’s mounting scholarly evidence to suggest Pope made his plan as a ‘Homeric conceit’ (Notes: Alexander Pope and Circe’s Dome. Salfour F.E. Oxford Universit Press.1991).

In 2006 English Heritage said that Charles Bridgeman designed the garden at Marble Hill but today they say it was mostly Alexander Pope. There’s a very strong argument to suggest that the date on the undated 1752 plan is wrong and English Heritage have chosen this date to suit its agenda.

Famous paintings of Marble Hill during the 1700s show no signs of such an intricate garden. The literature on English Heritage’s website does not substantiate claims that these so-called ‘lost gardens’ ever existed.

The provenance of the survey and the date given to it is in the public interest, 326 trees will be felled from a public park to make way for Henrietta’s garden. Railings will likely be put around the garden forever changing this semi rural landscape. Wildlife habitats and foraging woodland will be eradicated as part of the landscaping. I, and many others believe the gardens were never implemented and we would like English Heritage to provide further information regarding the gardens.



The archive maps have no date and were obtained from: Chloe Phillips | Strong room Assistant

Norfolk Record Office, The Archive Centre, Martineau Lane, Norwich, Norfolk, NR1 2DQ

+44 (0) 1603 222599 | |

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AP5.1 Doubts on design history.

While there has been a long standing tradition that Alexander Pope designed the Marble Hill gardens there has of late been a realisation of a distinction between an early design and the finished scheme. Dr Jacques discounted Pope’s authorship of the completed work in the 1989 EH Report. There are a number of academics who dispute Pope’s involvement in an implemented design: “There is no evidence to support a suggestion that the design was ever executed at Marble Hill and seems instead to be an intriguing Homeric conceit which Pope entertained during September 1723” F.E. Salon.(17)

The reality, as the following suggests, is that many friends and associates who were keen on landscape gathered round Henrietta as she embarked on her enterprise, producing ideas. She was surrounded by landscape enthusiast such as Robert Walpole, Lord Burlington, William Kent as well as her oracle of satirists: John Cay, Jonathan Swift, J. Arbuthnot and Richard Owen Cambridge who formed the satirical Scriblerious Club. It is known that Henrietta was shrewd enough to bring in a professional and the time spans and land availability point to an overlay of different ideas as time progressed, many not being realised. As far as Richard Owen Cambridge is concerned he is acknowledge in Pope’s gardner’s book as “ donating large pieces of gold chift” for his grotto ;Being an immediate neighbour of Henrietta in what is now Cambridge Park there may be more to discover on the relationship to the grounds.

A collective effort with unknown authorship downgrades the planning   imperative of “approval at a cost” as there is reduced public interest benefit. The public interest evaluation in planning terms revolves around three aspects:



AP 5.2 The personality

The English Heritage proposal for Marble Hill House promotes Henrietta Howard as a figure of admiration for the 21st Century as she overcame disadvantages. However campaigners argue that she has no relevance to today’s generation and its handicaps, and is a very inappropriate role model: It is their case that to be born to and seek to regain and maintain privilege, adopt a morally dubious lifestyle and make money from the slave trade, whatever the personal circumstances of the time, should not be promoted by a public body today.( ref “Tart of the week: Henrietta Howard of Suffolk. (18) As Lucy Worsley writes: she “learned to be fluent in the courtiers’ language of half truths and flatteries” ( ref: The secret History of Kensington Palace  (19)

Pope, as one of her friends, has been accused as being an apologist for the oppressive upper classes.

The historical record shows that she married badly to start, was successful by determined use of connection and was heavily protected by the most powerful people in the land during and after her role as mistress to the King, notably Lord Islay and her brother Lord Buckingham. In her later years of independence she was seen by Walpole as a route to renewed royal favour by those who had fallen from royal grace. Hence an attentive court of her own.(8 pg 27)

AP 5.3 Demeaning association for modern minority ethnic groups

Campaigners argue that It is unwise today to celebrate a house built by and quite explicitly celebrating slavery. Marble Hill House was directly financed by profits from the trade. This is verified in depth by research at the University of Manchester ( ref The slavery connection of Marble Hill House” (20) . Henrietta’s family had a documented ownership of African slaves in England, but she invested herself in the trade. She then received a pension from the king consisting of 70% slave trade stock and took a keen direct interest in the value; key materials such as the mahogany usedin the housewere slave produced materials from Africa. The house interior paintings celebrate slavery.


AP 5.4 Rising wealth in slavery and favours.

At that time people had gambled in the South Sea Bubble (21) that brought ruin to many, which later analysis put down to insatiable greed. She too invested in  the South Sea Company, founded to sell slaves to Spanish America. She withdrew just before the crash, at considerable profit. Her lucky foreknowledge was probably due to Earl of Islay and his close association with the Company. Henrietta gained a £2000 a year pension (worth £250,000 a year today) from 1718. Later the Prince offered her £11,500,a set of gilt plate, jewellery, ruby, gold watch and an extremely valuable shipload of mahogany as a means to preserve her independence from her husband.(ref Kings mistress, Queen’s servant (22)

Slavery connections ran through the whole Marble Hill project. The Earl of Islay was close in advising as well as Trustee of her pension with stock in the South Sea Company. The Trust was set up by the King to protect her from predations on the money by her first husband. The Earl was also Director of the South Sea Company. He directed the purchase of the Marble Hill land with its funds and financed the house. The land bought for it was in the ownership of Thomas Vernon a Director of the same company. (Who also leased out Pope’s lands at Cross Deep). Henrietta’s stock in the South East company, majoring in slaves, tripled in value simply in the spring of 1720.

She had a pension from the King, investment gains and later a large inheritance.


AP.5.6 Historic Landscape plans (ref Appendix AP5)

The Planning proposals revolve around plans in a Norfolk Registry in 1991.Referred to as the Hotham Papers. There are four plans.

MC 184-10-1-001 A monochrome of house and grounds undated and but labled

MC 184-10-2-001 Faint colour and monochrome of house and grounds undated but labelled

MC184-10-2-002   A detail on a damaged scrap undated and unlabled

MC 184-10-3-001 A decorative undated and un labelled colour layout


There is no clear provenance for theseplans. On the first, English Heritage say “about 1752” As a source Henrietta Hotham was Henrietta’s niece and they were close in the Countess’s final years


AP5.7 The applicant’s consideration of installed landscape design authororship:

Alexander Pope.

“ Histories are more full of examples of the fidelities of dogs than of friends”

  1. Pope

Pope was born to be resented and disliked and his talents were such that friends forbore his poor traits. His was a brilliant mind but in a deformed body given to many Illness’s including Pott’s disease, a tubercular ailment, and diminutive in height. His Catholic Faith barred him from social advancement and academic career, and he was heavily protected by Lord Burlington at the time of the Jacobite rebellion. He had a capacity for falling out with friends and was renowned for spitefulness and was unjust and bad tempered. This was compounded by his late in life affair with Martha Blount of whom society disapproved.

It might be said he was an ideal candidate for Henrietta’s court of rebels after she came to Twickenham and her well known patience may have been the secret to her friendship.

However the importance of Henrietta to Pope seems exaggerated as she is rarely mentioned in his biographies.

We have in her letters Henrietta’s first mention “ Mr Pope has been to see me, Lord Burlington brought him” (8 pg 435) Lord Burlington was the leading figure known for his architecture and landscape accomplishments. By 1730 Mr Gay, a close companion had written “Lord Burlington and Pope had jointly laid out the gardens” (8 pg 437). And later Henrietta wrote “Mr Bridgeman is here and I have spoken to him about the gardens .He says they are kept as they ought to and at a very reasonable expense, but he will soon bring me the account and the positive agreement if it be such as the duchess approves” (8pg 439). A certain politeness is detected here: that Bridgeman was not enamoured by what he saw and had the opportunity to work it over.


There are a number of sources that argue that Pope’s vision, however enthusiastically broadcast by him, never materialised to any degree on the ground.

Pope’s ideas on Homeric landscape resulted in angular layouts as MP-10-3-001.A layout very reminiscent of Stowe. This was going out of fashion and perhaps was good at the project commencement but fell out of favour. Charles Bridgeman was part of a new movement espousing naturalism. The 3-001 plan shows an early version of the house design by Colin Campbell who was introduced by Lord Herbert and, according to the Marble Hill Society, is not credited with the final house design. They state it was “almost certainly” by Henry Lord Herbert 9th Earl of Pembroke, and Roger Morris. Walpole himself said Henrietta credited Herbert and Morris. The Society also points out Campbell never claimed credit and did not as he usually did, apply an inscribed plaque of authorship. As to what evidence survives of Pope’s hand in the making of Marble Hill, there is none. English Heritage’s technical rosta of constructions and work orders for the grounds with dates, can only point to mention of a bowling green as a link to Pope. However this was a fashion, and it is true Pope had a bowling green in his rear, non riverside, garden but that does not suggest he designed the Marble Hill garden.


Pope was certainly a friend (along with Swift and Gay) and he essentially oversaw the estate in the early years when she was away. He was active at inception, but upset people: Berkly complained: “ Pope endeavours to find faults here, but cannot, and instead of admiring what is already executed,he is everyday drawing a plan for some new building or other and then is violently angry that it is not set up the next morning,,,” (page 81 30) This certainly implies other work proceeding that he disliked. A plan did exist which Gay stumbled across in 1723 but was sworn to secrecy, however there is no record of the authorship of the plan. It may have been a Bridgeman. early draft. It is also possible that the reason the Countess wanted it kept secret was because she had no intention of following it but that is pure surmise. The noticeable strains of Pope’s personality circulated around the whole Henrietta court.The Countess complained:” I never see Mr Pope or Mrs Blount….although I never go to Marble Hill without sending to them…” (1731 page 7 and her friend Mr Gay complained “ Mr. Pope , I fear, is determined never to write to me…”

The MP-10-3-001 Plan has a building with symmetrical wings to subsidiary accommodation and a centralised hierarchical elevation.

This agrees with the unbuilt Campbell design so placing it very early before final design.

It is noted now that original assertions at the time of the English Heritage application that Pope designed the grounds then that it was Bridgeman , have been dropped.


AP 5.8 Charles Bridgeman The second promoted candidate for design is the King’s gardner Bridgeman. He  had written to Pope on September 28th 1724 to say he had “begun the plan”. Henrietta certainly valued him and was angry at his absence. (!731 pg 20 30)However this was a long way from realisation and it was not until eighteen years later much of the land was purchased. Pope’s contact fell away and no longer exchanged correspondence after 1739.So Bridgeman may have continued in order to realise his design alone. He did considerable work with William Kent, such as Chiswick House. On these Kent was the conceiver and designer, Bridgeman the technical realiser. Unlike a pure design layout, the two plans 184-10-1-001 and 184-10-20 carry technical information on costs. The first is clearly copied by the second . It uses the identical key coding and lines and style but has poor writing style. This suggests the second was a copy made by the technique of pin prick and coloured chalk which produced reasonably accurate lines but requiring writing to be renewed. That it was a working document is supported by amendments of crossing out from what was in the first copy and some lop sided writing.

The detail 184-10-2-002 shows the South East corner. It appears to match the other two but puts in a little more information as if to negotiate or realise a new acquisition (Cottages and Friedland land)

It seems to indicate a possible ha ha.(a trademark of Bridgeman) However, given the high tide line and current spring overflow into Marble Hill grounds one wonders how this could actually have worked.

The time taken to build such an edifice tends to be discounted in historical reference. Quite how Henrietta was able to entertain there early on is mystery unless there was careful phasing. We note that even by 1766 Horace Walpole bemoaned “ not an inch of curtain is drawn up yet…” (1766 page 321 30)

Charles Bridgeman was an adept self publicist and is credited with pioneering middle class and professional involvement and gentleman interests in landscape when previously it had been an aristocratic concern. His work at Stowe is well known and, uniquely for the time in 1733, he commissioned the celebrated engraver Jacques Rigaud to come to England to create a suite of 15 views. These were published by his wife Sarah Bridgeman after his death. Likewise 8 views of Chiswick House landscape were commissioned.(23) It is significant that if Bridgeman’s work had included a final installed design at Marble Hill it would have been included in such a promotion..

It is perhaps symptomatic of a broken relationship that in all her letters she fails to mention Pope’s death in 1744.


AP5.9 Plan authorship evidence from the Hotham Papers

There is strong evidence in style and lack of dedication that MP 184-10-3-001 was by Pope expressing his approach that was soon to go out of fashion. It is unlabled but attractively presented suggesting a scheme prepared not under patronage but perhaps as a self motivated indulgence or gift. The building plan is erroneous, showing a form as conceived early on by Colin Campbell who is not recognised as the ultimate architect (24)

MP-184-10-1-100 and 184-10-2-001 bear the characteristics of Charles Bridgeman insofar as they have the technical detail he was known for. They also incorporate his hallmarks: parterres, avenues, kitchen gardens, paths through woods and (apparently) ha has.

However a plan of intent does not suggest a scheme was realised and they lack the standard acknowledgement in the obsequious language of the time,of patronage (compare for example the ornamental dedication to patronage for Stowe with its absence here)


AP 5.10 The realised scheme

If one then compares Augustus Heckler’s painting  of the landscape eleven years after Bridgeman’s death one sees ground similar to today with open lawn and  chestnut trees as the Saulthier plan. There are no visible pleasure gardens.

There is no doubting Pope was a friend and offered to design the grounds, and it seems the coloured plan MC 184-10-3-001 was an enthusiastic early idea. Its incorrect layout of the house shows it was prepared before the house design was finalised. Henrietta had a number of like enthusiasts. So we have his keenness alone in describing: “I have spent many hours here in studying here and drawing new plans for here” . He described avenues of chestnuts and a 180 foot bowling green between house and river. The archaeology now demonstrates the terraces are natural and so a bowling green of that dimension is impossible. This description is completely different from the angular layouts in 184-10-3-001.

So clearly he had explored varied ideas in his enthusiasm. It is believed he was inspired by the grounds of  Sherbourne Castle owned by the Digby family in Sherbourne, Dorset. The grounds were laid out by Capability Brown and Pope visited in 1720 and the architect Henry Holland built “Pope’s seat” there. The land is an essay in views and spaces unlike the supposed creations at Marble Hill.

There is certainly a possibility that a bowling green did exist, The dimensions in the 18th century were 16 feet by 120 feet which may well have fitted on the natural terraces, but of course it may have been on the north side.

Further Published illustrations show:

1749 Groves of trees either side of the house set well back from the river leading back; and a single line of trees marking the edges of the main plot with clear terraced lawn between . There are no tree avenues.

1753 Clearly a copy of 1749 with different boats : similar set-back groves either side, not avenues to the river. Groves were groups of trees at that time often for fruit or nuts.

1770 Clearly a copy of 1749 or 1753 but with altered boats and moved people and horses of the 1749 version.

1815 An oblique cross-river view shows irregular trees but agreeing with 1749

1832 Different artist and technique and showing major woods either side of the house and terraced laws.


So there is a disparity between intent and realisation. In 1760 a description records simply ” a fine green lawn adorned on each side by a beautiful grove of chestnut trees” Note “grove”, not avenue. The cooling of the relationship between Pope and Henrietta and his death suggests that while he was a keen estate manager from time to time and suggested ideas, by the time of realisation of landscape others were involved to different ideas.


As to the survival of unattributable plans, it is by no means any evidence of realisation. All estates offered patronage to professionals and enthusiastic gentlemen amateurs. Huge numbers of presented schemes resulted. An estate would keep these as a record of ideas in their libraries. Likewise even today Institutions keep unbuilt plans as a record of ideas of the day.


We have therefore possibly  sycophantic recommendations by celebrities and also professionals .

Of late English Heritage has explained the lack of features in the engraving landscapes as simply a simplicity of approach by the artist. This does not reflect the known accuracy of an art form at the very height of its skills, and when one notes theparticular lengths of the artists to show every tree trunk and distant house detail the argument is weak to say the least.


A Georgian guide for river tourists describes Marble Hill: ” it stands in a woody recess with a fine lawn descending to water, and well adorned with wood well disposed” This is far closer to the current state and very importantly, confirmed by earlier maps, surrounded by woods.


AP 5.12 Archaeology evidence.

The 2015/16 document shows in Figure 15 river and house and a 1902 road and possible boundary structures to the north and south. Recording these as from the last two centuries. The South area between House and River was at best inconclusive.

It does not however, correlate with the Norfolk Plan or the current proposals.

The Lidar plans used to detect anomalies in the ground show nothing that agrees with any of the possible plans. The major disturbance of tree avenues as the application suggests, and the ground disturbance are not shown at all. Neither are the hall mark ha has as pionered by Brdgeman at Stowe.

The fact that trees from the 18th century can be rediscovered is borne out by the uncovering of stumps of the original Charles Hamilton plan at Painshill, (25) No stumps are found at Marble Hill.

The last archaeology report dated September 2017 following two seasons of digs, first in the copse and then in several positions in the south land states no evidence of 18 century landscape had been found below ground that concurred with the Hotham Papers design. The supposed evidence of terracing as being land modification has been confirmed as natural land profile. No evidence of Italian gardens was found. No evidence of the pergola was found.


AP 5.13 Other evidence of different design

Finding true authorship of garden designs is notoriously difficult, as testified by Dr. Peter Willis, the authority on English Garden Design ((1933-2016); but even his vast archive on Bridgeman and his contemporaries carries no mention of Marble Hill. He makes the point that often a garden was created by a committee of amateurs,” where the owner or patron acted as chairman advised by amateurs and poets” Willis notes that Bridgeman’s talents” were best demonstrated by his choice of trees shrubs, the repair of groves and the planting of fields.”(26)

Given the enthusiastic accounts of Henrietta’s Kitchen Garden and Dairy it is noticeable that there are no references in the same praise for pleasure gardens. praise was lavished on her arrangements of ice house, kitchen garden, and dairy, and the commissioning of a cottage in the grounds.

It is a matter of record that HenriettaHoward was surrounded by enthusiasts eager to participate in the progression of the landscape design: Lord Bathhurst who was rumoured to be her lover, was a friend of Pope, but was warned off by the Prince. Henrietta was, however , determined not to leave matters to amateurs, and engaged Charles Bridgeman. Delay followed as he claimed to be very busy on Stowe but later announced he had “ begun plan”.

However work halted in 1726 over the protracted deaths of Sophia the estranged wife of the King followed by the King himself.The releationship with Pope was on and off with long periods where he would not reply to the Countess’s letters;perhaps a sign he was not happy plans were not advancing as he had envisaged.

There was in later years when land became available, Richard Owen Cambridge next door whose landscaped estate was much admired by Capability Brown, (26) and we have Horace Walpole acknowledging how close Cambridge was to the Countess (letters 1776 pg 323) and who supplied materials for Pope’s grotto. Surely a vein to be researched?

For all the possible gand plans we also have Henrietta’s own views: “There is at the bottom of a sloping hill a most delightful stream which runs thence to Marble hill and in no small addition to the directly beauty of the t place “(letters 1734 p6 76) It is strange that so important a delight to Henrietta should be missing from the surviving plans.

So we have a long history of different hands having a go at the grounds on an intermittent basis and a worrying lack of care confirmed by Jonothan Swift’s disparaging poem on the then gardner of 1727 Mr Moody:


My house was built for a show

My Lady’s empty pockets know;

And now she will not have a shilling

To raise the stairs or build the ceiling…..


……We gardens, and you wildernesses,

Assist all poets in distresses.

Him twice a week I here expect

To rattle Moody for neglect,

An idle rogue’ who spend his quartridge

In tippling at the Dog and Partridge(28)


If Moody was renowned for garden neglect his successor, Daniel Craft had a contract that required mowing lawn, weeding, rolling gravel paths, care of greenhouses, plants and fruit trees and produce in the kitchen garden. This is not the grand estate as envisaged in early designs.


Further unenvisaged features: Walpole and the Priory of St Hubert. Walpole was a close friend. He had transformed Strawberry Hill into a Gothic Villa. He persuaded Henrietta Howard to convert old farm buildings into the “The Priory of St Hubert” with spire, buttresses, cloisters and nave, as a garden folly. This was demolished a decade later but may have given rise to the local legends of a medieval monastery. We have no reference to this by English Heritage. However this contributes evidence that people other than Pope and Bridgeman had access to Henrietta and persuaded significant sums to be spent on features other than the applicants’ proposal.

A piece of evidence that what is seen was not necessarily Henrietta Howard’s creation is the bordering trees at the west side along Montpelier Row. Her letter archive shows a resident, Mrs. Elizabeth Grey, writing to ask if the walnut trees could be cleared to afford a view from the houses and to avoid the throwing of objects to dislodge the nuts by the public that were breaking windows.. She declined . Given the long time to grow and that they obscured a view from elevated windows, these trees must have been in place before her ownership.

AP 5.14 Land Plot acquisition. The application is weak on the timeline of when people lived, died and land was progressively acquired. This has a bearing on whose design was ultimately realised. There are certain practicalities here, the people with the recognised skills in design and when they were around when land was available.

Henrietta Howard’s later life away from court, enabled by a large inheritance, allowed her to form a new set of friends in Twickenham among the glitterati of the day. They formed around her, many with interests in landscape with early ones fading and departing with time. For example Richard Owen Cambridge who landscaped his estate adjacent to Marble Hill and won the praise of Capability Brown. (Giving his name to Cambidge park)

The adjoining land by the river was owned by J. Vernon, who also owned Pope’s land. He was also a leading director of the South Sea Company. He resisted attempts to buy and even his widow resisted. Even in 1755 there were other building and land occupiers in the way. On that date Henrietta instigated legal action against John Friedenberg who owned two cottages on the river on the east side and who insisted on taking laden carts across her land. It took 7 years to win her case. Clearly, if carts were crossing, she had no dense ornamental gardens by then, and in any case by then Bridgeman and Pope were long dead. The main river land owned by Mr Vernon was only acquired in 1742 four years after Bridgeman’s passing and there were problematic uses of river terrace by Friedenbeg that were only resolved by Henrietta turning her property over to her brother so he could claim a Lord’s right of Breach of Privilege to counter Friedenberg. Henrietta could not because she had now married a commoner. On her brother’s, Lord Buckingham, death the property reverted to her.

And Dole Mead plot at the riverside west was acquired in 1749 and the transfer of wayleave from Friedenberg 1750

AP 5.15 The planning relevance

The applicant’s historic case is weakened by the fact that in the Saulthier survey of Middlesex all gardens were plotted around the neighbourhood but not Marble Hill’s as currently promoted.
There is much to suggest the promoted plan is simply a proposal plan as described on the paper, not a survey and it is undated and unsigned. The costings list indicates the stage of writing was before installation and not a survey. There is then successive evidence such as Henckle’s picture which shows no such gardens.
There is furthermore only passing mention of the gardens in all of Henrietta’s extensive letter collection (27.)
and the Archeology report has uncovered no evidence, and in fact provides contradicting evidence that the land was landscaped by earth movement into terraces.

It has been noted in many histories of 18th century gardens that they were the product of committees under the patron. Given the time to create a landscape and the deaths and appearances within Henrietta’s “court” the likeliest scenario is that first efforts went into the available land at the north east for a kitchen garden and dairy particularly as “playing dairymaid was written of by Henrietta’s associates. (8) The original ambition was overtaken by pragmatism, change of fashion ,new people and delays acquiring land and finally failing finance.

There is a strong case supported by scholars, critics, guides and engravings that  Marble Hill was actually realised with a simple lawn and chestnut groves (not avenues) and edged by woods.

It was not an Alexander Pope design and probably in the end not a Charles Bridgeman design realisation. Archaeology has found nothing to persuade that the landscape was not greatly different from today.

So the proposals are not a restoration. The heritage gain by creation is minimal given the existence of other examples. The long period of the park in its current state might be argued to be greater heritage value.


EF: 17/1664 dated 25 September. Copy of the full agenda, minutes, notes and actions from the meeting that took place on 24 May 2017.

English Heritage held a meeting on 24 May 2017, the meeting was attended by EH’s Project Manager, Landscaping, Planning Consultants, Transport Consultants, Arboriculturalist consultant and the Ecologist.

Campaigners comment: There are many unanswered questions regarding the trees, the wildlife and ecology of The Park, traffic and congestion and parking, the landscaping of our woodland quarters where 326 trees are proposed to be felled. This meeting was attended by most of the key-players in the Marble Hill Revived Project and we believe that this meeting was solely to discuss our public park and as such feel validated to ask for a copy of the minutes. Again, this should not be time consuming as Frances Gibbons (FOI team) has already located the minutes and sent me a section to do with ‘sport intensification’. All we are simply asking is for the complete document to be released.


EF: 17/1664 dated 25 September. Copy of the full agenda, minutes, notes and actions from the meeting that took place on 24 May 2017.

“Campaigners comment: The information requested here is important because we are left wondering how much park will be left after the 11 sports pitches are drawn up, the landscaped gardens fenced off, the 140 seat café built, the extension of the car park etc etc. Our public park is semi rural today however once English heritage’s plans go ahead people who wish to simply walk in the park and use it in its natural form and not visit the café or play organised sport will it seems be pushed to the periphery as the green space becomes designated space.

This information is incredibly important to the public as The Park is designated Open Metropolitan Land protected under law. 

We know that English Heritage lease the moorings to Hammerton’s Ferry and would like to ascertain whether boat services will be arriving at the site as a way of getting new visitors to Marble Hill as intimated by Alex Sidney at a minuted meeting held at York House recently.

We are trying to understand how an extra 40,000 visitors from further afield (EH projections) will get to the site.

In recent years The House Festival held at The Park meant that ‘controlled access’ was used at the gates. Meaning the public were locked out of the park during the event. Of course it is in the interest of park-goers to know how often this is likely to happen. We have not been informed about the proposed scale of the ‘special events’ whether they will be pop concerts, classical concerts or house festivals. This is concerning because the local infrastructure cannot cope with large-scale events and so it should be information available to the public.

We requested financial forecasts because this would be the best way to ascertain the scale of the ‘special events’. After all this is a public park, it is Open Metropolitan Land and the public have a right to know how their park will be used and to know the likely impact on the immediate vicinity; noise, traffic, rowdiness etc”


As adjusted for English Heritage Comment and reissued 18/11/17 No comment of affirmation received at time of report issue

Wednesday 20 September 2017

Present: Cllr Susan Chappell, Nikki Dale (Planing Officer, LBRuT) , Caroline Dyball (Lebanon Park), Janine Fotiadis (Riverside), Cllr Helen Hill, Jill Jones (Montpelier Row) , Caroline Mills (Montpelier Row), Kate Pitt (English Heritage), Angus Russell (Montpelier Row), Alex Sydney (English Heritage)

Concerns raised as to why English Heritage (EH)  had not looked at other sites within Marble Hill Park (MHP) . EH stated that application had gone in for larger cafe in stable block because it doesn’t require a change of use (as existing cafe already on site), they argued that it was a central location within the park and that the park is Metropolitan Open Land so no new buildings would be given planning permission. Assertions questioned repeatedly by residents and councillors, with residents pointing out how close the new cafe would be to residential properties.

AR asked why EH had been sending emails stating that LBRuT had ‘corporately approved’ the plans for MHP and provided a copy of that email. ND confirmed that no such ‘corporate approval’ had been given and that the plans would be determined at Planning Committee. AS agreed that he would correct the position with HLF

AR asked why EH had not carried out a survey of local residents as per the Heritage Lottery Fund’s (HLF) recommendation. He stated that using software such as Survey Monkey, it would be easy to target local householders and park users and suggested that the reason the survey hadn’t been carried out was because EH would discover overwhelming opposition to their plans. AR requested that such a survey be undertaken. AS agreed that EH would consider undertaking such a survey.

EH confirmed that they have completed a Heritage Impact Assessment and that this had already been submitted as part of the original planning application.

AR asked for a copy of the business plan for the cafe. AS stated that the business plan contains commercially sensitive information. Residents stated that they believe the reason EH won’t release the business plan is because the plan for MHP contains ‘gaping holes’; further mistakes (such as the omission of the House Festival income); it would reveal information that EH don’t want revealed such as income from events. EH responded that they are confident that their commercial modelling for the proposed café is financially robust. Residents stated that they believe it will be an expensive mistake.

EH (AS) stated that they don’t feel that Marble Hill is an events site and at no stage would they hold more than two large scale events per year, but that in reality, the usual number is likely to be either one, or even none. They currently hold six weddings per year and would want to increase this to no more than 12, but this would form part of a separate planning application as planning permission would be needed to install marquees on site near Marble Hill House. CM asked about the vegetation on either side of the house and AS stated that they were looking at opening this up to create elements of the garden restoration (woodland walks) and on the site of the old Service Wing, a an orchard and a screened area of sufficient size to accommodate a marquee. CM stated that this was valuable natural habitat for bats and other wildlife.

AS was asked if EH would go back to the Heritage Lottery Fund (HLF) and ask them if they would still be in a position to provide the 4 million pound grant if EH resubmitted designs for a smaller cafe on the site that had the support of local residents. Question was asked repeatedly and AS noted that this change would potentially make the scheme financially unviable, but did agree to discuss this with the senior team at EH and with the HLF and provide feedback to the group on this point.

Providing further information about the financial importance of the café to the scheme, EH stated that they are looking for a 0.5 million pound turnover per annum from the cafe. They stated they are aiming to reduce their operating costs by 100,000 to circa 150,000 pounds per annum.

There was a discussion about an alternative arrangement for the café: no external building; renovation of the existing building; outside seating on the MHH side.  AR said that this would have a number of advantages: it would not have any “heritage” issues or material planning consequences; it would likely have the support of local residents; it would involve a significantly lower capital spend; net income would probably not be much reduced because running costs would be lower and the times when people use the park most (when it is sunny) would be appropriate for the outside seating.  Residents also encouraged EH to consider other formats for the café, such as packed lunches which have been successful in other park cafes locally.

AS indicated that he would give active consideration to such a change.

 There were multiple questions from residents about the basis for the ornamental garden plans.  AR presented a detailed etching of the view of MHH from the river dated c.1740 which he stated showed no such garden KP cited a drawing from 1752 (estimated date) which showed a survey of the garden on which the proposals are based and which English Heritage state provides evidence for its existence.  English Heritage and residents have opposing views on whether the ornamental gardens were ever in existence on the site.

Residents raised concerns about the 60 workshops for schools planned by EH. EH stated that they had originally looked at a coach drop off point on Richmond Road, but that this was not viable and they acknowledged there was nowhere to park coaches locally. JF stated that it was residents understanding that Orleans House was to be used for school coaches to visit MHP. AS clarified that the confusion around this point had arisen from a misunderstanding on his part. All residents and councillors stated that it would be impossible to get a coach down Orleans Road. EH agreed with this, and clarified that no arrangements had been made with Orleans House to drop coaches, and that on the contrary, school groups would be advised to use public transport and not to come in coaches which the road network would not accommodate.

Residents raised the issue of parking and traffic for increased visitors to the cafe and those using the sports pitches. EH confirmed that they have carried out a parking survey in line with the Planning Department’s methodology and that this would be available publicly shortly. CD stated that any transport survey carried out in the school holidays should not be considered as it is not an accurate reflection of the usage of local roads.

EH stated that a number of changes had been made to the application, but these were not yet on the council’s website as they had been asked by the Planning Team to re-submit all revised documents in full and at one point in time. AS stated that he understood that this was due to happen in the next few weeks.

JJ asked that it was made clear what changes had been made to the application. ND stated that all documents showing the latest version will go online as revised and any documents that relate to the original application will be marked superseded. ND also stated that once the changes have been received and are available to view publicly, a new consultation would begin, lasting a minimum of 14 days.

Residents raised concerns about the ‘intensification’ of the use of the sports pitches. EH stated that they were planning to upgrade the pitches and provide better drainage to encourage more use at weekends and during school holidays. Residents remain of the belief that EH haven’t factored in that more people using the pitches will lead to an increase in cars wanting to park nearby. SC stated that parking and traffic is already an issue because of attractions such as Turners House and traffic would be impacted by the opening of the Lidl supermarket on the Ryde House site. AS agreed to consider whether this had been taken into account.

CM raised the issue of the amount of trees that EH plan to remove. KP stated that there are 1837 trees in the park and that EH plan to remove 326 trees from the woodland quarter. AS stated that a lot of these would. be saplings, which are classed as trees. The removal of these trees represents 19.5% of the tree stock and they plan to plant 400 new trees. The tree cover will extend by half a hectare but CM raised concerns about when this would be – would residents have to wait 30 years for this? EH confirmed that a full tree survey is carried out every year in MHP. AS also confirmed that a bat survey has taken place and will be publicly available online at the same time as the other updated planning information on the issue of badgers on the site. ND stated that if there were badgers on the site it would be a sensitive issue and the location of the sets would not be put in the public domain. EH did not acknowledge, or deny the presence of badgers onsite, but stated that the presence of badgers would be covered by an ecology report. JF asked for a copy of the ecology report. EH stated this would be submitted to the LBR at the same time as the other planning information and added to the councils website shortly afterwards. 

JJ raised concerns about the fenced off play area by the cafe. EH have plans to add equipment to this site and it is felt by residents that this is not needed – the adventure playground and One O’Clock club are both situated within the park and there is a children’s playground in Orleans Park just next door. EH stated that they had spoken to parents and children using the park as well as local schoolchildren who had stated that they did want a playground with equipment on that site. JF and CD stated this just reinforced local resident’s beliefs that EH had asked a niche audience to get the answers they wanted.


– AR re-iterated that EH’s plans as currently proposed would have sustained opposition from local residents on many well founded grounds, including substantive planning isues. SC encouraged EH to compromise and work with local residents in order to get support.  She cited the example of another planning application which faced local opposition and was declined by the planning committee, but adapted in co-operation with local residents and ultimately approved by the planning committee

– AS agreed to speak to the team at EH and to the HLF to clarify the implications for both parties ofrevising, or withdrawing and resubmitting the planning application, with a view to working in conjunction with local residents to ensure that both parties were satisfied. AS stated he would feedback through local councillors HH and SC by 20 October 2017. 

– AS agreed that this process would involve giving active consideration to the alternative plan for the cafe

 – AR reiterated the request for a survey to take place. AS promised to consider it. 

 – AR asked for a written retraction of the statement made by EH that LBRuT were ‘corporately supportive’ of the proposals AS stated that he would ensure that HLF were aware that there was greater local opposition to the scheme that the e-mail implied, and would confirm to them that LB Richmond had not formally agreed to corporately support the proposalsecember. dt few weeks and osals.reed to corporately support the proposals.scheme that the e-mail implied, and would confirm that.  

– AR again requested a copy of EH’s business plan. AS would not commit to providing this. 

– EH agreed that copies of revised documents (to be marked superseded) and the traffic survey and ecology report would be submitted to the LBR with the other planning documentation in the next few weeks and added to the LBRuT we

bsite shortly afterwards. 

 – ND stated that this was not likely to come to committee before late November/early December. 




2.CTM Ltd Traffic Survey Soho House

  1. LBRUT Major Development: “Marble Hill Park”
  2. English Heritage 1989 Report

5 CTM Ltd Soho traffic Plan 2017

6 Air Quality Management Area (AQMA 6) for NO2


8 Letters to and from Henrietta Howard, Countess of Suffolk, 1712-1767 Harvard College Library

9.The Life of Walter de La Mare by Theresa Whistler 2003  

10 Section 1 HUDV Rapid Health Impact Assessment Matrix (NHS)

11 The National Planning Policy Framework

12 The Biodiversity Action Plan

13 Characteristics of woods used recently or historically. Charman et al. 2010)

14 Pan European common bird monitoring scheme. PECBMS 20072010

15Fure, A, (2006) Bat Surveys at Orleans House Gardens

16 Guidelines on effective community involvement and consultation, RTPI Good Practice Guide Note 1. 16

17 F.E. Salfon. Oxford University press.

18 . Tart of the week: Henrietta Howard of Suffolk.Jan 2010

19 Courtiers: The secret History of Kensington Palace Lucy Worsley Faber and Faber 2010

20 The slavery connection of Marble Hill House” Lawrence Brown University of Manchester also Slavery and the English country House Madge Dresser and Andrew Hahn. Swindon

21 South Sea Bubble The new economy of the 18th Century Robert Wernick.aslo Slavery and the English Country House ed madge Desser and Andrewhahn Swindon.

22 Kings mistress, Queen.servant Tracy Barman Random House 2007

23 Unamed celebrities of 18th century gardens: Jaques Rigaud’s topographical Prints by Richard Quaintance. Rutgers University. 23)

24 Marble Hill Society Founded 1987 and repositiory of history of the house.

25 Restoration of the18th century planning of pleasure grounds, Jackson.S

26 Charles Bridgeman and the English Landscape Garden by Peter Willis 2002 and Charles Bridgeman, Royal gardner by Peter Willis University of Cambridge

27 Alexander Pope Laura Brown author Oxford Blackwell 1985

28 A Pastoral Dialogue between Richmond Lodge and Marble Hill. The works of the Rev Jonothan Swift/7 Volume 7/ Concerning the changing fortunes as a dialogue between Richmond Lodge and Marble Hill on the death of the King.

29 A Plan of Mr Pope’s Garden by J Serle his gardener 1748

30 Letters to and from Henrietta, Countess of Suffolk and her second husband, The Hon. Georgeberkely, from 1712-1762 Vol2 . John Wilson Croker, Henrietta Hobart Howard Suffolk, pub. John Murray, Albermarle St 1824.




The Council list outstanding reports and raise concerns in April yet the reports are still unavailable

Marble Hill Park, Twickenham

LB Richmond References: 17/1094/FUL & 17/1096/LBC

Site: Marble Hill Park, Richmond Road, Twickenham TW1 2NL

28 April 2017

Proposal: Comprehensive redevelopment, including Marble Hill House renovation and alteration; Stable Building extension (to form 140 cover café) and service yard access; park landscaping and drainage; sports building alterations; sports pitch and play area improvements; and associated works (including to walls), installations and services.



1. Redacted

2. Trees (and Landscape)

(a) Introduction / Overview &
BS5837: 2012: ‘Trees in relation to design, demolition and construction’

The scale of tree removal on this site is such that a commitment to re-planting is required to mitigate for the loss of amenity. Currently the detailed planting plans are to be developed in consultation with park users as part of a long term strategy. Policy DM DC4 states that there will be a presumption against schemes that result in a significant loss of trees, unless replacements are proposed. The removal of trees is recognised in Policy DM DC4 as part of a historic restoration scheme but without a commitment to replacement trees, this proposal is not currently acceptable.

The applicant’s confirmation of their intentions in this regard is required in accordance with the BS 5837, as summarised under the following headings:-

  1. (b)  Woodland Quadrant Plans / DetailsA detailed plan is required for each woodland quadrant that clearly shows the quantity, scale, species and size of trees due for removal and/or coppice.

    Reasons / background: In order to facilitate the re-landscape elements for each woodland quadrant garden a significant number of trees will need to be removed and/or coppiced (G8, G9, G10 and G7). Within in each woodland quadrant it is unclear which trees are designated for removal, and/or coppicing and which has been categorised as a ‘specimen tree’ for retention. The drawing number CBA10677.04 is unclear on the trees advised for removal (red circle) and those being retained.

  2. (c)  Quadrant Demolition / Construction WorksA detailed plan is required that clearly shows the implications and effects, within each woodland quadrant, for specific demolition/construction works. This should include larger scale drawing details (superimposing Streetwise Tree Removal Plan on the Illustrative Landscape Plan) of the following areas:
    1. The four Quadrants;
    2. The West Grove line;
    3. The Line of the Proposed Tree works extending westwards, along the river, at the south end of the East Grove.
      4(d)  Smaller Landscape Works DetailThe smaller landscape works need to be specifically detailed, including:

      • ninepin alley;
      • gravel paths
      • marquee (bases? and anchor points)* (See covering email)[Details, such as benches in the play area, waterproof buggy store may be Conditioned.]

        It is currently unclear what impact these will have on the trees and where exactly some of these will be sited.

        5. (e)  Play Area : No-Dig Footpath (or ‘minimal dig’ Detail)Revised drawings confirming a no-dig footpath should be provided; or details of the proposed ‘minimal dig’ footpath should be provided.

        Reason: The proposed new play area is shown within the middle of a group of mature trees a category A Red Oak (T27), category C Common Lime (T18) and a category B (T17) Lime with the main play area outside of the RPA’s of the trees.

There is no objection to this element of the proposal although details relating to the minimal dig footpath are lacking.

(f) Stables: Proposed Extension & Service Yard

Details are required in respect of the proposed removal of T12, including the requisite arboricultural justification.

[The café and service yard will require the removal of a category B mature Horse chestnut (T12) within the service yard.]

Details are required of proposed service arrangements. [However, while it may be prudent for the applicant’s interest to identify these at planning application stage; in the event that the Council should be minded to approve, this matter may be deferred by a Condition.]

  1. (g)  Montpelier House (Garden)Details are required, in respect of:
    • the proposed foundations which are within close proximity to the site boundary with the Montpelier House Root Protection Area (RPA); and
    • the effects of the proposed foundations upon the Montpellier HouseRPAs and trees; and
    • the trial holes dug nearby.Reason: The proposed café would sit within the root protection area (RPA) of trees T53, T54 and T55 three early mature Hornbeams and T52 (Sycamore) and T51 (Yew) in the rear garden of Montpelier House. The incursion into the RPA’s of these trees has not been detailed; and the results of trial holes dug nearby have not been provided.

      [Details of services / routing will be required (tree effects). While these could be Conditioned, the applicant may consider it prudent to investigate / propose these at application stage.]

      8 (h)  Wetland: Existing Vs Proposed?Improved clarity is required in respect of the existing and proposed wetland areas.

      The main flooding area is directly in the view from the main house to the River Thames seen by the lush green vegetation and amounts of stinging nettles and docks that grow there. However, the Illustrative Management Plan (581_PL_L_01 C) shows improved wetland areas to the east of the site, with no reference to the extant wetland area. Clarity is required in respect of the principles of the works proposed to the extant wetland area; and in respect of the proposed wetland area.

3. Ecology

The Park is a site of local nature importance, where biodiversity and opportunities to create new habitats is encouraged [LDF Core Strategy 2009]. The Council’s Ecologist has recommended refusal, following concerns in respect of the absence of

details of appropriate protected species surveys and the proposal (e.g. details for woodland landscaping). These issues, together with actions for productions, have been summarised below.

(a) Bats [European Protected Species and a UK Priority Species]

  1. Omitted Baseline Survey Data – London Bat GroupThe requisite information should be obtained from the London Bat Group, in respect of the holistic activity across the site, to provide the full complement of baseline information to inform a revised Bat Survey and Report.

    The Survey report also recommended that the LBG bat data was requested as this data is not included within data provide by GiGL. However, there does not appear to be any reference to this.

  2. Holistic Survey of Bat ActivityThe Survey needs to be extended to a more holistic survey (i.e. how the bats use the whole site), as prescribed in the Preliminary Ecological Appraisal (PEA).

    The FAO Bat Survey is limited to a Roost Survey. It needs to be extended to an expanded holistic study. The PEA recommended having a bat survey carried out to understand how bats use the whole site.

  3. Incomplete Bat Surveys: Stables, Service Yard and Sports Building (and pagoda/ticket shed and disused toilet block)All the bat surveys should be completed, as prescribed in the FOA Ecology report, for the following remaining areas: Stables, Service Yard and Sports Building, pagoda/ticket shed and former WC block. These need to be provided seasonally / urgently Reason: The FOA Ecology Bat Report identified further bat surveys for a number of areas which have not been provided. Therefore, the bat surveys are incomplete. These omitted studies cannot be addressed by Conditions of a PP; and one cannot apply for a protected species licence ‘just in case’ there may be harm to the species.
  4. Inconsistency / Incompatibility of Illustrative Masterplan and Tree Removal PlanAll documents / drawings submitted should be reviewed to ensure that they provide unambiguous details of the proposal definition and are mutually compatible. This will include, for example, addressing the issue of consistency of the Illustrative Masterplan and Tree Removal Plan:-

i. The Site Wide Tree Removal Plan (581_PL_L10) shows only the understory yew and holly to be coppiced; with seven specifically identified trees. However, the Illustrative Masterplan (581_PL_L_01 C) shows amenity grassland paths running through the woodland [which would surely require more extensive permanent tree removal (rather than simply coppicing)]. This should be appropriately reflected in the Tree Removal Plan [i.e. creating these formal/direct path-lines will involve more than ‘Coppicing (e.g. the removal of a mature holm oak on the east side)].

ii. The Illustrative Management Plan (581_PL_L_01 C) also proposes the removal of mature trees that have been identified by the PEA as being high value trees, which is contradictory and those trees will be important trees for bats to use.

  1. West Grove: Tree Corridor ProtectionThe landscape scheme needs to be revised to address the importance of the wildlife corridor that is established along the area of the proposed West Grove.

    The proposal involves removal of a number of mature trees (the crack willows etc) along the West Grove that will potentially sever the tree corridor that the bats use to get to the river to feed which would be detrimental (e.g. tree cover provides protection from light/predators, insect feeding grounds). Severing the effectiveness of this wildlife corridor will potentially impact bats moving around the site and travelling to / from feeding sites.

  2. Ground Level Roost Assessment (Trees to be Felled)A report on a daytime ground level roost assessment, of all trees to be felled, should be submitted, as recommended in the FOA Bat Report.

4. Transport

A revised transport assessment is required, based on more accurate baseline details and which addresses the issues summarised below. This should inform the submission of a revised Transport Statement (TS).

a. Erroneous Baseline
There are basic deficiencies in the TS e.g.

  • Richmond Road (adjacent to Marble Hill Park) is not 20mph, as stated in the TS. It is a 30mph road.
  • There is no way to check that pedestrian visitors to the park have driven but parked on street with a residents permit.
  • Incomparable Base Cases of Primrose Hill and Greenwich Park-Greenwich Park sits adjacent to two CPZ’s one is operational Mon-Sat 9am-5pm and Sundays 9am-6pm and the other is operational Mon-Sun 9am-6.30pm. There are also many other destinations locally such as Maritime Museum, Royal Observatory, Naval College, Cutty Sark – that would generate joint trips rather than specific trips just for Greenwich Park. Also the university campus opposite would generate student visitors to the park due Coach Parking to its proximity. Visitors to this park would be well in excess to those that may attend Marble Hill Park.

Primrose Hill is also within a CPZ that operates 8.30am-6pm Mon- Fri. It has no parking availability in its own right, only the car park that is available opposite in Regent’s Park. Again, it could attract people from Regents Park for the protected views.

Additionally: The information for both Greenwich and Primrose Hill Parks is from 2008, so nearly 10 years old.

  •   There has been no submitted data used from these two parks.
  •   As Marble Hill House visitors are currently restricted to weekends, the TS needs to clearly explain how the projected visits proposed for week days (and weekends)

Coach parking in the location proposed would result in the loss of resident parking which would not be acceptable. Parking a coach within the area of the double yellow lines would also not be acceptable as it would be too close to the Montpellier Row junction and sightlines for exiting drivers from Montpellier Row would be compromised.

c. Proposed Café (140 Covers)

The TS has failed to demonstrate that the area retained for servicing of the proposed café is sufficient. Such details should include manoeuvring tracks for servicing vehicles.

d. Sports Pitches (Intensification of Use) Further clarification is required in respect of:

  • the impact of the intensification of use of the sports pitches.
  • in the calculation presented in the TS, it has only increased the figures forcurrent usage levels.

The revise TS will also need to demonstrate, with specific sports pitch usage:

  • The current and possible increased future use of the pitches, that users can be accommodated on site if driving and will not cause on street parking issues after CPZ operation times have finished (particularly in the summer months with longer daylight hours).

5. External Consultee Responses a. Sport England

This Holding Objection has been the subject of further productions from your agent, which are currently with SE for review.

d lamont (28.4.17)


English Heritage’s Tree Removal Scheme

Below, is an unedited email from Kate Pitt, Audience Development Manager and Head of Landscape and Gardens, English Heritage, received 22nd September 2017.

‘There are 1837 trees in Marble Hill Park. We are proposing to remove 347, of which 326 come from the woodland quarters. The 347 tree removals equate to 18.9% of the tree stock. We will be planting 401 new trees, this is a 2.2% increase in the number of trees on site. It is estimated that after all the proposed tree removals and the proposed re-planting programme is completed, tree cover will extend by 0.5 ha to 42% of the site.

The tree survey exercise has focused on the proposed areas of park improvements and identified 66 (sixty six) individual specimen trees and 24 (twenty four) groups of trees. Within these groups, 234 (two hundred and thirty four) trees were considered worthy of note. The development works focus on three areas of the park; improving the existing café facilities within the stable block area; improving the play facilities adjacent to the stable block and reinstating the landscaping around Marble Hill House and down to the River Thames.

Improvements to the café facilities at the stable block will require the removal of 3 (three) trees, an additional group of 9 (nine)trees to the right of the café , and 1 (one) low grade tree to the south of the café  will be removed to improve the growing conditions for the remaining trees within the group.  Next to the house 3 (three) trees are proposed for removal and amongst the Western avenue towards the Thames a further 4 (four) trees are proposed for removal.

There are 609 trees within the four woodland quarters south of the house of these 326 are proposed for removal to reduce the significant overcrowding and enable the remaining and newly planted trees to grow under better light conditions and the generation of a ground flora which will improve biodiversity.

Improvements to the play area adjacent to the stable block do not require any trees to be removed as a direct result of the works. One poor quality tree (Sambucus nigra) will be removed due to its condition. The proposed play equipment is to be positioned to avoid tree protection zones.

The landscape reinstatement works to the four quarters around Marble Hill House and part of the grounds down towards the River Thames will require the management of these areas through the removal of a number of trees, the coppicing of trees, the retention of trees and the replanting of trees.

The south-east quadrant (Group 7) will require the removal of 88 (eighty eight) trees, the retention of 73 (seventy three) trees and the coppicing of 44 (forty four) trees.

The north-east quadrant (Group 8) will require the removal of 74 (seventy four) trees, the retention of 21 (twenty one) trees and the coppicing of 7 (seven) trees. (One tree has been removed since the original survey).

The north-west quadrant (Group 9) will require the removal of 86 (eighty six) trees, the retention of 55 (fifty five) trees and the coppicing of 15 (fifteen) trees. (One tree has been removed since the original survey and one was a duplicate tree).

The south-west quadrant (Group 10) will require the removal of 83 (eight three) trees, the retention of 32 (thirty two) trees and the coppicing of 31 (thirty one) trees.

Five trees are recommended for removal for reasons of sound arboricultural management regardless of any development proposals. Therefore the removal of these poor quality trees should not have a bearing on this development proposal.’

Description: Description: cid:image004.png@01D33167.96225020

Description: Description: cid:image005.png@01D33167.96225020

The Truth about Trees

Please find a breakdown of the tree removal scheme for Marble Hill Park from English Heritage’s Head of Landscape Gardens.

September 22nd 2017

Kate Pitt, Audience Development Manager, English Heritage says, ‘The map will be available soon on Richmond Planning Portal – I’m just trying to get clarity of when this will be.’

Head of Landscape Gardens for English Heritage:

‘There are 1837 trees in Marble Hill Park. We are proposing to remove 347, of which 326 come from the woodland quarters. The 347 tree removals equate to 18.9% of the tree stock.

Improvements to the café facilities at the stable block will require the removal of 3 (three) trees, an additional group of 9 (nine ) trees to the right of the café , and 1 (one) low grade tree to the south of the café  will be removed to improve the growing conditions for the remaining trees within the group.  Next to the house 3 (three) trees are proposed for removal and amongst the Western avenue towards the Thames a further 4 (four) trees are proposed for removal.

There are 609 trees within the four woodland quarters south of the house of these 326 are proposed for removal.

The south-east quadrant (Group 7) will require the removal of 88 (eighty eight) trees, the retention of 73 (seventy three) trees and the coppicing of 44 (forty four) trees.

The north-east quadrant (Group 8) will require the removal of 74 (seventy four) trees, the retention of 21 (twenty one) trees and the coppicing of 7 (seven) trees. (One tree has been removed since the original survey).

The north-west quadrant (Group 9) will require the removal of 86 (eighty six) trees, the retention of 55 (fifty five) trees and the coppicing of 15 (fifteen) trees. (One tree has been removed since the original survey and one was a duplicate tree).

The south-west quadrant (Group 10) will require the removal of 83 (eight three) trees, the retention of 32 (thirty two) trees and the coppicing of 31 (thirty one) trees.’

Our campaign acknowledges that English Heritage has a proposed replanting scheme for the 347 trees it plans to remove plus the 97 that will be coppiced. However, we are concerned that once the woodlands are removed our park’s wildlife will suffer. English Heritage hasn’t adequately acknowledged the importance the wooded areas for The Park’s badgers, song-thrush, stag beetles, bats (all protected species) and other wildlife.

Much of The Park’s wildlife relies heavily on the tree canopy for foraging and habitat and it serves an important job on the ground too by creating ideal conditions for insects, an important part of The Park’s food chain. We have not seen English Heritage’s replanting scheme and worry that small specimens and ornamental gardens will not adequately replace what is already there. The woodlands or copses play an instrumental part of our park’s biodiversity and once gone they’ll impossible to replace.

The story so far…


English Heritage has been awarded millions from the Heritage Lottery Fund for Marble Hill Revived. A project centred on renovating Marble Hill House, the construction of a large cafe, a new adventure playground, the updating of certain park facilities and newly landscaped gardens.

At first glance the plans sounds wonderful but scratch beneath the surface a little and certain elements seem at odds with our current semi-rural green space.

Not least plans to fell over 50 per cent of the woodland quadrants where certain species of The Park’s wildlife currently thrive. Of the 609 trees that make up the copses 326 will be felled and a further 97 coppiced, a method whereby trees are repeatedly cut down near ground level. Only 186 trees from within the quadrants will be left untouched.

The idea behind this is so that English Heritage would then have an area for its landscaped gardens and a home for the 200 person wedding marquee. It argues that the woodlands are bereft of wildlife and unimportant.

Our own expert from the Badger Trust found during his field visit obvious signs of badger activity within the woodlands and said the prolific badger setts had been there for perhaps 30 years yet when alerted to our findings English Heritage said it was unaware of the badgers until September this year and as a result is currently doing its own badger survey. It’s concerning that a protected species had gone unnoticed for so long especially after sustained scrub clearance over the last three years and archeological digs in the immediate locality.

Whilst the bat survey acknowledges that bats are active just one minute after sunset in The Park which indicates they live within The Park the report fails to establish roosts. As well as soprano and common pipistrelle bats, Nathusius’ pipistrelle, Nyctalus species (noctule or Leisler’s), probable Leisler’s and also a long-eared bat has been detected.

We know this area is of vital importance to bats thanks to The Thames Landscape Strategy and trees that make up the bats’ foraging lines are essential to their survival. And so the idea that the woodlands within The Park will be destroyed is of real concern.




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