New Imperial House Planning Application – Our submission objecting to the proposals, February 2016

These are the comments we have submitted to SDC in response to the cladding proposals for New Imperial House – planning reference S.15/2849/FUL – details of the application are available here:

NB Another similar application by Ecotricity for another building, Axiom House, has also recently been submitted. Our comments on that, which complement our comments below, can be read by clicking here.

Comment: Stroud Civic Society objects to the proposed cladding and alterations to the elevations of a prominent building occupying a key location in an important civic space.

New Imperial House lies within the Stroud Town Conservation Area and next to the Stroud Station and Industrial Heritage Conservation Areas. It is a prominent part of one of the two finest civic spaces in Stroud—the other being the space in front of the Subscription Rooms. Both of these spaces, ironically, lack their own designation and are described merely as ‘forecourts’.

Imperial Hotel

Station forecourt is the gateway to Stroud for those arriving by train and comprises one of the best assemblages of buildings in the town. Brunel’s Grade-II listed station of 1845 (extended in 1914)—with his signature tall chimneys twisted through 45 degrees—faces Benjamin Bucknall’s magnificent and imposing Imperial Hotel of 1870, bristling with characteristic and quirky details.

Stroud Station and Hill Paul Building beyond

To the south-east is the single-storey brick extension providing vehicular access to the former GPO sorting office and, beyond, a glimpse of Brunel’s Grade-II* listed stone-built Goods Shed of 1845. To the south-west the redbrick and stone trim of the Hill Paul building towers unexpectedly over the single-storey ranges of the station buildings.

Imperial House as it was

The station is flanked on the north-west by the Grade-II listed stationmaster’s house of c1883, built to the Great Western Railway’s Standard Class ‘C’ house design, carefully proportioned and beautifully executed in brick. This is immediately followed by Imperial House (1956), which used to look like this (apart from the green glazing in the windows on the side wall).

Imperial House is a postwar stone-clad concrete-framed building. The main façade is articulated in three vertical bays divided by chamfered concrete piers with infill fenestration and rendered spandrel panels. Ecotricity’s website calls it ‘an ugly façade’.

Next door is Holloway House of 1934, which in turn adjoins Stroud House (originally the Holloway Institute), a towering and monumental design of 1894-6 by William Clissold, its ground floor sadly mutilated by horizontal shop windows.

Pevsner’s Buildings of England / Gloucestershire: The Cotswolds says non-committally of Holloway House and Imperial House that they are ‘both thoroughly typical of their date’. On the contrary, Holloway House is an excellent building that respects and relates to the architecture of Stroud House while responding to it imaginatively with a range of subtle modern details.

Not so Imperial House, which neither respects its neighbours nor relates to its surroundings. It could be anywhere, except for the use of Cotswold stone on the side wall. It is this wall, rather than the rather dull and pedestrian façade, which is surprisingly prominent in views leaving the station by either the main or the side entrance. The wall boasts a quirky diagonal grid of tiny windows which is distracting while adding little if anything to the design. This has been made worse by their being reglazed in Ecotricity green.


New Imperial House as it is at present, with that flag

Imperial House is certainly not a distinguished addition to the assembly of buildings that make up the civic space in front of the station, but it is at least a relatively quiet addition in its choice of materials and colours, and (except for the fenestration of the side wall) does not draw attention to itself at the expense of the rest.

This cannot be said of its current incarnation, with new ground-floor fenestration dominated by a supergraphic of the ‘ecotricity’ logotype and the upper storeys concealed behind an Ecotricity green union flag stretched across the façade.

New Imperial House with flag in street context

New Imperial House with flag in street context

The flag’s function, apparently, is to reduce the solar gain on this side of the building, but the design has the unfortunate effect of turning the entire façade into a crude billboard. Together with the new ground-floor glazing it also conceals the chamfered concrete piers that are an elegant and distinctive feature of the original façade. The diagonal grid of tiny windows in the side wall had previously been reglazed in green, drawing even more attention to them.

Altogether these alterations have turned a shy wallflower of a building into a brazen strumpet, to the detriment of the civic space and the setting of the other buildings.

New Imperial House cladding proposal

The proposed cladding takes this further by treating the whole building as a branding exercise and cladding it in a jumble of five colours vaguely related to Ecotricity’s corporate colours.

The application states: ‘The proposal is to update and modernise the functional but quite unsightly building and also link the design with Ecotricity and to use an Eco-friendly but modern material to do this. The cladding colours chosen are as close as possible to Ecotricity colours’.

Which they are not. The design uses five colours (green, white, light grey, mid grey, dark grey, black), and the green is a sludge colour nothing like Ecotricity’s bright green. The Ecotricity trademark green union flag uses just three colours (green, white and black).

And it is just these three colours that are applied very effectively to (for example) Ecotricity’s vans.

By using five continuously-alternating colours, the proposed cladding is restless, unsettling and garish:


It degrades the setting of the stationmaster’s house and introduces a discordant and inappropriate element into Station Road and the station forecourt, which features stone-clad buildings from several periods, together with the redbrick of the stationmaster’s house and the brickwork of the vehicular entrance to the former GPO sorting office.

The proposed cladding scheme has been compared unfavourably with Lego, Minecraft, and to the Morrisons Regional Distribution Centre near Bridgwater on the M5.


This sort of variegated cladding is normally used in an attempt to camouflage very large sheds in rural locations. Despite which, in a poll run by the local paper, the Bridgewater Mercury, 75% of readers stated that they thought the Morrisons Regional Distribution Centre was an eyesore.

It is therefore even more inexplicable to propose such a cladding system for a town centre conservation area surrounded by listed buildings and other heritage assets.

In her submission, Conservation Officer Kate Russell argues:

‘Were the cladding to be truly removable, with no major impact on the fabric of buildings themselves, then I would say that whilst the works would be unorthodox, they would cause no lasting harm to the identified heritage assets. However, it would appear that the proposals would have the potential to create a significant impact on the fabric of existing buildings; should this be the case, then the works would [cause] lasting harm to the character of their historic surroundings.

‘Whilst the visual impact of the cladding on New Imperial House would be the greatest, the physical impact would be less. I am reasonably confident that were the building to go into new ownership, the cladding could be easily be removed and the architectural integrity of the building restored; therefore, although in the short term the cladding could be deemed by many to cause harm to the character and appearance of the Conservation Areas, and to the setting of the nearby listed buildings, in the long term the character and historic interest of the heritage assets would not be affected.’

We emphatically reject this view. There is a world of difference between a cladding system, however reversible, and (say) Christo’s wrapping of the Reichstag as a temporary artistic transformation.

Whether the cladding can be removed without damage to the building is a secondary consideration. The cladding may never be removed and, once it is installed, for however long it remains the character and appearance of the conservation area and the setting of nearby listed buildings will have been egregiously and unnecessarily damaged. Reversibility is not an argument for allowing an inappropriate cladding system in the first place. And in the long term we’re all dead…

The stone flank wall of Imperial House is amenable to internal insulating at a fraction of the external cladding cost. The present proposal does not address the real problem of this building, which is heat gain and glare to the main façade. And there is no proposal to alter the rear elevation (overlooking Rowcroft) in any way. This façade is single-glazed and does not benefit from solar warming (unlike the stone flank wall). It is also invisible from the road and scarcely visible from the raised pavement—which confirms that insulation is not a real consideration in this application, it is all about the branding.

We are strongly of the view that, while the proposed cladding is unnecessarily garish and distracting, any appliqué cladding system is inappropriate in this location.

The Imperial Hotel used to boast a luxuriant growth of Virginia creeper the length and breadth of both façades.

This was savagely cut back some years ago but is making a slow but determined recovery.

Surely far more in keeping with this location and with Ecotricity’s core values would be a ‘living wall’?

The Driver 2009

There are many more spectacular examples, but this transformation (left) of a modest interwar pub near Kings Cross station shows what can be achieved. The planting respects and conforms to the original architecture while adding colour, texture, visual richness and a real ‘wow’ factor.

Oasis d’Aboukir , Patrick Blanc, gable wall planted with waves of 7600 different plants

Living or green walls are self-sufficient vertical gardens attached to the exterior of a building. They differ from green façades (walls with ivy or creeper growing on them) in that the plants root in a structural support system fastened to the wall. The plants receive water and nutrients from within this support structure instead of from the ground.

Living walls consist of a variety of plants and some sort of growing medium, supported by a structure. They utilise the vertical surfaces of a building that would normally be ecologically barren, creating habitats for wildlife. Living walls provide insulation, thermal shielding and sound absorption as well as enhancing their surroundings and creating an attractive environment for people. And everyone loves them! A green wall in an urban area can help improve local air quality, both by absorbing carbon dioxide and releasing oxygen, and by trapping dust and other pollutants. Green walls also make graffiti almost impossible.

Musée du quai branly

Stroud prides itself on its green credentials, but has not a single example of a living wall. Greening the environment and zero carbon are part of Ecotricity’s DNA, so surely it’s a no-brainer? What could be more appropriate for Ecotricity and for one of the first buildings visitors to Stroud see when arriving by train? A living wall would show real commitment on Ecotricity’s part and do so much more for its image than a facile branding exercise.

The current flag/billboard facade to Imperial House is widely disliked—as is its replacement—judging by many of the comments on this planning application. And when Ecotricity’s cladding proposals were first published in the Stroud News and Journal and Stroud Life, in the online comments and on related Facebook pages there was considerable hostility to the ‘Lego’ look proposed and support for the idea of a living wall.

Tim Mars
for and on behalf of
Stroud Civic Society
Rose Cottage
The Street

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