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Revised Development Strategy

ID sylw: 59299

Derbyniwyd: 24/07/2013

Ymatebydd: Historic England

Crynodeb o'r Gynrychiolaeth:

South of Gallows Lane/west of Europa Way: site to the south of Warwick has the most acute and evident impact on the significance of the historic environment.

Council 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 EH 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.

EH have inspected this area, including viewing the site from the roof of St Mary's Church tower, and from within the historic park. EH consider 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.

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.

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.

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. Visual impact is but one contributor to the setting of a heritage asset and in focusing only on visual impact any assessment is deficient. Council 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. In consequence, surely the Richard Morrish Landscape study should come to the same conclusion i.e. the development is unacceptable in principle?

The attempt to militate against harm is noted but EH 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. However, it does not question the principle of development on the site due to the principle being established by the SHLAA. 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 EH's Guidance on the assessment of setting published in 2011, and by EH'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.

Testun llawn:

Dear Mr Barber

Warwick Local Plan - Revised Development Strategy Consultation

Thank you provi...
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