Testun llawn:
Warwick District Council Local Plan - Focussed Modifications and associated Sustainability Appraisal
Proposed additional Gypsy and Traveller site off Stratford Road, Warwick and associated Sustainability Appraisal
Thank you for providing an opportunity to comment on these proposals.
My consideration and response is based on the expectation there has been a proper assessment of the significance of heritage assets affected, including their settings ; and the proposals support the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework (NPPF), with one of the core dimensions being the protection and enhancement of the historic environment .
The NPPF requires Local Plans, as a whole, to set out a positive strategy for the conservation and enjoyment of the historic environment. This means ensuring that the sites which it is proposing to put forward for development, will assist in delivering such a strategy and not contradict it.
Employment land allocation on land off Stratford Road, Warwick
This stretch of the Stratford Road is a surprisingly understated and pleasant entrance to Warwick from the M40. It's positive characteristics should be recognised to inform strategic landscaping and moderate highway works which may be required to facilitate any future development.
The proposed allocation is adjacent to Longbridge Manor, a Grade II* listed building with circa 14/15 century origins. The Manor is served to the south by a pleasant 'rural' lane and entrance. Development immediately to the east will affect its significance.
Opposite the site is the Old House and its ancillary barn, both Grade II listed buildings. Beyond to the east are the Warwick Castle Park (Grade 1) and Warwick Conservation Area.
Unfortunately there appears to be no evidence to demonstrate a consideration of how the proposed allocation site contributes to the significance of these designated heritage assets, particularly Longbridge Manor (NPPF Paragraph 129). Neither is there evidence to demonstrate where development may be inappropriate because of its positive relationship to adjoining heritage assets (NPPF Paragraph 157), or how harm might be avoided (NPPF Paragraph 152). The commentary in the SA is rather rudimentary and dismissive, failing to provide an accurate or reasonable assessment of the impact of future development.
The selection of sites for development needs to be informed by the evidence base and the Plan should avoid allocating sites which are likely to result in harm to the significance of heritage assets. Where adverse impacts are unavoidable and justified, in accordance with the NPPF, the Plan should consider how that harm might be reduced and any residual harm mitigated. This could include measures such as a reduction of the quantum of development, avoiding locating development within a particular part of the site, ensuring reinforced strategic landscaping, and limiting the height and volume of development.
Without such evidence Warwick DC cannot assert that the allocation and the amount of development proposed (11.7ha) can be delivered without causing harm to heritage assets of national importance contrary to explicit legislation and national planning policy. Consequently I remain concerned that the Local Plan as proposed is unsound.
It is important to note that:-
- great weight should be given to an assets conservation and the more important the asset, the greater the weight to the assets conservation there should be (NPPF Paragraph 132);
- special regard must be given to the desirability of preserving the setting of a listed building (S66, Planning (Listed Buildings and Conservation Areas) Act 1990;
- development will be expected to avoid or minimise conflict between any heritage asset's conservation and any aspect of the proposal (NPPF Paragraph 129).
Following the ruling in Barnwell Manor Wind Energy Limited v East Northamptonshire District Council, English Heritage, the National Trust and the Secretary of State for Communities and Local Government [2014] EWCA Civ 137, considerable importance and weight should be given to the desirability of preserving the setting of a listed building. Less than substantial harm does not equate to a less than substantial planning objection. There is a presumption that preservation is desirable.
Further analysis is therefore vital. I would strongly recommend the application of The Setting of Heritage Assets (English Heritage, 2011).
Gypsy and Travellers Site on land off Stratford Road, Warwick
The secondary/indirect impact of the proposal should be considered. For example could the 'rural' character of the lane serving the site, and the Grade II* Longbridge Manor, be retained as a consequence? Are intrusive highway works to facilitate the development required? How might these issues be addressed?
Change of proposed uses on Land North of Gallows Hill, Warwick
English Heritage acknowledges the potential for development to the north of Gallows Hill /west of Europa Way, but the implications of a stadium on Castle Park and the intermediate historic landscape must be appreciated, as should the consequences of accommodating additional traffic through the town. I will avoid repeating again the reasons why evidence to inform the principle and form of allocations is required. Needless to say I consider further work is necessary.
I look forward to further updates in due course. Do contact me to discuss any of these matters at your convenience.