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Dear Mr Barber

Warwick Local Plan - Revised Development Strategy Consultation

Thank you providing English Heritage the opportunity to comment on the Revised Development Strategy.

My response is mindful of the expectation the Warwick Local Plan enables the delivery of sustainable development in accordance with the policies in the NPPF , with one of the core dimensions being the protection and enhancement of the historic environment .

This letter responds to the proposed strategic site allocations at Thickthorn, Whitnash and south of Gallows Lane, and also considers the implication of the infrastructure provision to accommodate such growth.

Thickthorn, Kenilworth

"There is the potential for significant long term negative effect on heritage as Thickthorn Manor and Stables (Grade II Listed Buildings) are adjacent to the site and a small portion of the north east of the site contains part of a Scheduled Monument (Roman settlement at Glasshouse Wood). Stoneleigh Abbey Historic Park and Garden (Grade II) is also adjacent to the eastern boundary of the site, albeit separated by the A46".
(Paragraph 4.58 Warwick DC Local Plan Interim SA Report June 2013).

It is surprising that section 5.4 (Thickthorn) of the Revised Development Strategy makes no reference to the number of heritage assets directly and indirectly affected despite the above comments in the SA and similar references in the SHLAA. There appears an absence of evidence to demonstrate there has been a proper assessment establishing what it is about each of the affected heritage asset that is important; how the land/site proposed for development contributes to that significance, and; what in turn this means for the principle of development, and any future design response (mitigation).

You should note that this explicit point has been made to you in previous correspondence.

You will also appreciate that due to the former Roman occupation of the site there also needs to be an assessment of the likelihood that currently unidentified heritage assets (of potential national importance) will be discovered .

Without such assessments you may not be able to assert that the objectives for sustainable development have been understood and therefore cannot say whether the objectively assessed development needs of the District will be met or not in accordance with the presumption in favour of sustainable development. Consequently the Plan may be considered to be inconsistent with the provisions of the NPPF and therefore unsound.

It is expected that evidence has been taken into account when considering the impact of the proposal on heritage assets, to avoid or minimise conflict between the heritage asset's conservation and any aspect of the proposal .

You will appreciate that great weight should be given to the conservation of heritage assets and there is a legislative expectation that special weight is paid to the desirability of preserving the setting of any affected heritage asset.

The Setting of Heritage Assets (English Heritage Guidance October 2011) provides a robust assessment methodology to help determine the extent to which this and other strategic allocations would impact upon the significance of any affected heritage asset and how decision making and potential mitigation may respond. We strongly recommend you apply this guidance before the principle of development is determined.

www.english-heritage.org.uk/publications/setting-heritage-assets/

Whitnash

I note this sizeable development is proposed at the end of Church Lane, near the historic core of Whitnash and village conservation area that includes a number of listed buildings. Has the impact been considered?

South of Gallows Lane/west of Europa Way

As this particular site to the south of Warwick clearly has the most acute and evident impact on the significance of the historic environment I will focus my response accordingly. Nevertheless you should be mindful of the cumulative impact of progressive encroachment into the rural landscape from the number of proposals via this Plan and from adhoc planning applications. The Local Plan needs to determine a coherent landscape policy.

The site to the south of Gallows Lane is adjacent to Warwick Castle Park, which is included on the English Heritage Register of Historic Parks and Gardens at grade I. This encompasses Warwick Castle which is partially grade I listed and partially scheduled as an ancient monument. The setting of the park to the north-west is the historic town of Warwick. The key building of the town which dominates views from the park in that direction is the tower of St Mary's Church. The site in question lies to the east of the park and is visible in distant views from the towers of the castle and the roof of St Mary's Church tower.

The park would have spilled over into this area and is therefore a consideration for how the park as a heritage asset is experienced.

We have inspected this area, including viewing the site from the roof of St Mary's Church tower, and from within the historic park. It seems to us that there will be an impact on the setting of the park, which is a part of its significance, and that it is such that it brings the development if this site into question.

The park was bounded by a circuit drive which ran through the woodland belt on the east side of the park adjacent to the site and in places was close enough to the edge of the park to permit views out. Whilst this historic tree belt provides a degree of screening it is relatively narrow and composed mainly of deciduous trees so when leaves are shed considerably less screening is provided.

As you would expect, the park incorporates a number of viewing points including, for example, Lord Brooke's clump, with a drive running to it; and the dam over New Waters. No assessment has been made of the impact of development on these viewpoints.

It should be noted that experience has shown that even vegetative barriers or shelter belts of a depth of 50m+ may be ineffective if the objective is total screening (as opposed to baffling development), especially if predominantly deciduous species are planted (native planting likely to be requested), which will be ineffective in winter.

It should also be noted that the historic park was intended to extend beyond this boundary into this proposed development site and also that modern traffic has considerably more impact now than during the eighteenth and nineteenth centuries.

Even allowing for relatively low scale development and landscaping development is still likely to impact on the significance of the park during both day and night time. There will be increased urbanisation as the result of, amongst other matters, lighting, increased traffic and noise. Impact will be accentuated by proximity.

The implication for the sense of arrival to Warwick, the setting of the Park, the Castle and the Warwick Conservation area appears not to have been thoroughly considered; an important material consideration and therefore a serious omission. As we know, visual impact is but one contributor to the setting of a heritage asset and in focusing only on visual impact any assessment is deficient.

I repeat the point made with regard to development at Thickthorn, that you should appreciate that great weight should be given to the conservation of heritage assets and there is a legislative expectation that special weight is paid to the desirability of preserving the setting of any affected heritage asset.

The Richard Morrish Landscape study objects to the principle of development at the Asps but surprisingly not to the site south of Gallows Lane/west of Europa Way which is a similar area of land immediately to the north i.e. closer to the town. Surely the very same concerns relating to the Asps also apply to the site south of the Gallows/west of Europa Way i.e. it "...provides a historic context to the castle park. As open land it is prominent in terms of approaches to Warwick and provides a valuable setting to the town." In consequence, surely the Richard Morrish Landscape study should come to the same conclusion i.e. the development is unacceptable in principle?

Whilst the attempt to militate against harm is noted we are not confident that even if development were one field depth back, and reinforced by a narrow shelter belt it would provide a sufficient response as screening/ filtering belts of trees are seldom effective in winter, even at 100 metres depth.

The SA considers development of this site would have significant medium and long term negative effects on the landscape, the town and the historic park. This is a significant statement.

Surprisingly however it does not question the principle of development on the site due, we deduce, to the principle being established by the SHLAA. It is not clear why this should be the case as the SHLAA is a fairly crude assessment which has not fully applied the policies of the NPPF; an example being that this site conflicts with policies for the protection of heritage assets in the NPPF (impact on the setting of Grade listed Castle Park) but the SHLAA considers it to be "suitable".

The SA suggests the significant medium and long term negative effects on the landscape, the town and the historic park can be mitigated by design. However it does not clearly set out what the negative effects are (views from the Castle; approach to Warwick from the south etc.?) so one can judge whether the design response would overcome those concerns.

One would have expected that a transparent methodology such as English Heritage's Guidance on the assessment of setting published in 2011, and by English Heritage's Conservation Principles would have been undertaken and applied to explain the rationale for including this strategic allocation. As it has not there is no evident justification.

District wide transport works to facilitate future development (section 5.6)

Direct, indirect and cumulative effects of proposals on the historic environment must be appreciated. An example of an indirect effect could be the infrastructure required to accommodate additional traffic movements from major new development through historic towns such as Warwick and Kenilworth which may in turn have a profound impact on historic character and significance of affected heritage assets. Such potential harm must be considered at this stage of the Plan.

The Plan proposes a number of major highway engineering interventions with the potential to have an extreme adverse impact. English Heritage is particularly concerned regarding proposals 11, 12, 13 and 24 and the subsequent substantial harm to a number of nationally significant heritage assets.

It is surprising there is no reference to the townscape/landscape implications of these proposals in either the Revised Development Strategy, or SA - a serious omission.

An increased in traffic using the A425 (Banbury Road) adjacent to Castle Park.

The consequence of further increased use of the road in terms of noise, light pollution and visual intrusions from highway paraphernalia such as signage does not appear to have been considered; again an important material consideration and therefore a serious omission.

What are the implications for the sense of arrival to Warwick? What are the implications for the setting of the Park, the Castle and the Warwick Conservation area?

In accordance with the expectations of the NPPF, how has the Plan demonstrated that it has considered the opportunities to enhance the setting of the historic town and its nationally important assets between the Toll House (at the junction of Banbury Road and Gallows Hill) and the East Gate, a stretch of road blighted by past 'dramatic' road works particularly the Caste Hill Gyratory?

A substantial increase in traffic through the south and east of the historic town will have significant implications. Is there evidence of an appropriate assessment of the consequences for the historic environment, in particular for St Nicholas Church Street?

Castle Bridge - circa 1790 schedule monument and grade II* listed building.
This is another significant heritage asset that may be affected by the cumulative impact of development in the area. The direct impact on the bridge of considerably increased traffic movements and the inevitable 'highway works' in the vicinity will affect its setting which needs to be considered and resolved at an early stage.

Is there evidence available to reassure that this historic structure actually has the capacity to accommodate a significant increase in traffic?

The Warwickshire CC Strategic Transport Assessment Overview Report 2012 recognises at para 2.2.3 the national policy context to inform its transport planning in the District, and in particular makes reference to the need to accord with the NPPF and conserve heritage assets "in a manner appropriate to their significance" . However subsequent reports in the evidence base do not appear to address this matter at all; again a significant omission.

An objective for these schemes should be that they cause little or no damage to the historic environment. This means minimising any adverse impact on the rural context of Warwick from the south and the landscape setting of the Warwick Castle and nationally important Park. It is imperative that proposals are designed with utmost care. The NPPF expects those assets of the highest level of importance, such as these, be given the highest level of protection.

How compatible are the proposals with the ambitions of the Warwick Town Centre Action Plan regarding public realm and townscape improvements? How will these proposals enhance the experience of historic Warwick?

How can the Plan reassure English Heritage that these highway schemes will protect, and where appropriate, enhance the historic environment including the setting of individual heritage assets?

The Local Plan must be absolutely clear what it expects in terms of the design execution of these schemes. I refer you to the Manual for Streets (versions 1&2) (Department for Transport, March 2007 and September 2010).

You may wish to confirm that these traffic schemes will be sensitively designed having regard to Manual for Streets, and Streets for All to ensure they are all integrated into the landscape/townscape and take the opportunity to enhance the experience of the historic environment.

I hope this comprehensive response and further constructive involvement can help you to ensure a sound Plan and in doing so secure an effective conservation of the historic environment and the delivery of sustainable development.

If there any issues you wish to clarify please do not hesitate in contacting me.