Object to the Berwick Maltings design

SORRY: the application has now been permitted, and so it's no longer possible to object. The rest of this page is retained for information only.

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Welcome to our Objection Centre! Here you'll find the links and information you need to make an objection to the crass new Maltings design, helping to preserve Berwick's fragile charm.

Anyone can object, wherever they live. Objections are the most important tool we have to send a message to the decision-makers in the council. If you need help or information, don't hesitate to email us on info@berwick-heritage.co.uk or phone us on 0771 670 3490. We can help you with your objection by email, on the phone or in person if you prefer.

Some of the grounds you might cite are:

More detail is provided below, and you can see some of the images from the application on our main Maltings page for convenience.

How to object

There are three ways you can object.

Using the planning portal

Click on 25/00792/CCD, and you will see a list of documents. On a computer, there will be tabs for Documents and Comments, which are the important ones. On a phone, you will need to scroll down to see the Comments link.

The list of documents shows the application plans, consultee responses, and comments that were submitted as documents. If a document you are trying to view fails to load, refresh the Documents page and click again on the document (it's related to the way documents are cached).

One of the most important documents is the Heritage Statement, written by the applicant. Here you will find many attempts to minimise the extraordinary harm done by the building.

Click on Register here to create an account, and then you will be able to comment.

Commentary on the plans

We have shared our detailed analysis of the proposal in our report, The New Berwick Maltings: A Flawed Proposal. It includes these chapters:
1. Introduction: Unveiling the Proposal’s Shortcomings | 2. Heritage at Risk | 3. Inadequate Community Engagement | 4. Overstated Economic and Social Benefits | 5. Environmental Shortcomings | 6. Traffic and Accessibility Challenges | 7. Harm to Wellbeing and Tourism | 8. Procedural and Transparency Failures | 9. Conclusion: A Call to Protect Berwick

These are two of the most significant documents, since you may not have time to plough through all of them. Unfortunately we can't link directly to them due to the way the portal works.

Grounds for objection

Don't feel obliged to put anything like this level of detail in your objection, but you might find the sample below a useful reference. Please use your own words, or it may not be counted as a unique objection.

See also two actual objections, as submitted to the planning portal: Example 1 (PDF) | Example 1 (plain text) | Example 2 (PDF) | Example 2 (plain text). Most people won't want or need to submit such a long objection!

SAMPLE OBJECTION

We strongly object to the proposed development in the heart of Berwick upon Tweed’s conservation area, as it risks substantial harm to the historic environment, contrary to national and local planning policies.

This objection is grounded in the National Planning Policy Framework (NPPF, December 2024), the Northumberland Local Plan (adopted March 2022), and Historic England’s guidance on planning and development, particularly concerning conservation areas and heritage assets.

1. Substantial Harm to the Conservation Area (NPPF Paragraphs 202–215)

The NPPF, in Chapter 16 (‘Conserving and Enhancing the Historic Environment’), places great weight on the conservation of designated heritage assets, including conservation areas (Paragraph 202). Any harm to their significance requires “clear and convincing justification” (Paragraph 213), and substantial harm to assets of the highest significance should be “wholly exceptional” (Paragraph 213(b)). Where substantial harm is identified, Paragraph 214 stipulates that consent should be refused unless outweighed by substantial public benefits or specific exceptional circumstances apply—none of which are convincingly demonstrated here.

The proposed Maltings Trust design, situated in the core of Berwick’s conservation area, threatens substantial harm through its inappropriate, boxy, flat-roofed design.

The scale of the development exceeds the prevailing grain and character of this historic small town, where modest building heights and traditional forms define the area’s special architectural and historic interest. Historic England’s Conservation Area Appraisal, Designation and Management (Advice Note 1) emphasizes that new development must preserve or enhance the character of such areas.

The design style jars with the pitched roofs and vernacular materials that typify the conservation area. The conscious ‘modernist’ style fails to reflect the “local character and distinctiveness” promoted by NPPF Paragraph 203(f), risking a precedent that undermines the area’s integrity.

The proposed scale, form and materials do not respect the conservation area. The Northumberland Local Plan (Policy STC 6: ‘Conserving and Enhancing Heritage Assets’) requires development to respect the scale, form, and materials of its historic setting. The proposed building’s size is disproportionate to the tight urban fabric of Berwick’s conservation area, where narrow streets and small-scale plots dominate. This overbearing presence would erode the area’s intimate, human-scaled character, a key attribute identified in Historic England’s guidance on assessing significance (‘Making Changes to Heritage Assets’, Advice Note 2). The flat-roofed, modernist aesthetic further clashes with the traditional architectural language of stone, slate, and pitched roofs, introducing an alien typology that Historic England warns against in sensitive historic contexts. Such a design neither preserves nor enhances the conservation area, as mandated by the ‘Planning (Listed Buildings and Conservation Areas) Act 1990’ and reflected in NPPF policy.

The application's Heritage Statement claims that the materials and articulated form (broken-up boxes) reflect the building's setting and soften its impact. And yet such a large mass of brick—however carefully chosen—is not remotely a vernacular style, and neither is the metal cladding. Likewise, the large expanses of frameless glazing are alien to Berwick's typology.

2. Destruction of a Culturally Significant View

The development would obliterate an elevated, much-loved view that contributes significantly to Berwick’s cultural identity and the conservation area’s setting. NPPF Paragraph 212 requires great weight to be given to the conservation of a heritage asset’s significance, including its setting, while Historic England’s ‘The Setting of Heritage Assets’ guidance underscores the importance of key views in defining historic character. This view, cherished by residents and visitors alike, frames the town’s historic skyline and river context, embodying its cultural narrative. Its loss would sever a vital link to Berwick’s heritage, amounting to substantial harm under NPPF Paragraph 214, with no commensurate public benefit to justify it.

3. Harm to the Significance and Interest of the Conservation Area as a Result of Developmental Creep

Berwick, as a small town, is particularly vulnerable to developmental creep, a phenomenon less absorbable here than in larger cities. The NPPF (Paragraph 203) recognizes the need to balance development with the conservation of the historic environment, but small towns lack the capacity of urban centers to dilute the impact of incongruous projects. Historic England’s guidance warns that incremental changes can cumulatively degrade conservation areas, a risk heightened in Berwick given its finite historic core. The Maltings Trust proposal, if approved, could embolden further inappropriate developments, weakening the conservation area’s cohesion and contravening the Northumberland Local Plan’s aim (Policy STC 1) to maintain the distinct identity of its settlements. This fragility demands a precautionary approach, not the speculative imposition of an oversized, modernist structure.

From Historic England guidance on conservation areas: “The special interest of areas designated many years ago may now be so eroded by piecemeal change or by single examples of poorly designed development that parts of the area may no longer have special interest. In such cases, boundary revisions will be needed to exclude them or, in exceptional circumstances, reconsideration of the overall conservation area” (from HEAG268).

4. Repelling Tourists and Damaging the Local Economy

Proponents may argue that the development delivers public benefits, such as cultural or economic gains, sufficient to outweigh heritage harm under NPPF Paragraph 214. However, this claim is flawed. Far from attracting visitors, the oversized, modernist design risks repelling tourists who are drawn to Berwick for its authentic historic charm, not incongruous contemporary intrusions. The Northumberland Local Plan (Policy ECN 12: ‘Tourism and Visitor Economy’) emphasizes sustainable tourism that enhances the county’s heritage assets, not undermines them. A large, flat-roofed structure dominating the conservation area would disrupt the town’s appeal as a destination for history and culture, potentially driving visitors to rival heritage towns instead.

Moreover, the construction phase—likely spanning at least two years given the project’s scale and the site’s constraints—would clog Berwick’s narrow streets with heavy vehicles and disrupt access to key tourist areas. This would devastate an already struggling tourist trade, which relies heavily on seasonal footfall. The NPPF (Paragraph 203) requires economic benefits to be weighed in planning decisions, but here the short-term disruption and long-term deterrence reduce any speculative gains. Historic England’s ‘Heritage and the Economy’ (2020) underscores that heritage tourism thrives on authenticity and accessibility, both of which this proposal jeopardizes. The alleged public benefits are overstated and fail the “substantial” threshold of NPPF Paragraph 214, while the harm to Berwick’s heritage and economy would be severe.

5. Public Health and Public Amenity

An increase in bird activity due to the flat roof will be extremely unwelcome and harmful for Berwick’s town centre and may constitute a risk to health through droppings and a public nuisance through increased noise, potential attacks on pedestrians, and damage to property. in their droppings in the centre of town may impact local quality of life and tourism. This was also noted in the objections to the new Berwick hospital, in particular Thomas Stewart’s objection. Any mitigation is likely to be unsightly, and add to the harm to the historic roofscape.

There are seagull colonies on flat roofs and in parapet gutters in the Conservation Area, for example on the roof of B&N Bargains, as can be seen from the Ramparts. The presence of nets on flat roof areas of Morrisons shows mitigation’s visual impact. The applicant must have a strategy in place for dealing with this consequence of the flat roof design. At present the applicant has not demonstrated the visual harm or otherwise of mitigation, although it is an essential component of the design, and therefore the application must be considered incomplete.