CONSERVATION CASEWORK LOG NOTES MAY-SEPTEMBER 2014
The GHS conservation team received 698 new cases in England and 17 new cases in Wales betweenMay and September (inclusive), inaddition to ongoing work on previously logged cases. Written responses were submitted by GHS and/or CGTs for the following cases. In addition to the responses below,19 ‘No Comment’ responses were lodged by GCTs in response to planning applications included in the weekly lists.
Please note that the dates given may reflect the date the response was added to the Casework Log rather than the date submitted to a Council
Site / County / GHS ref / Reg grade / Proposal / Written ResponseTechnical Consultation on Planning / E14/0721 / GENERAL CORRESPONDENCE Consultation on a range of proposals to streamline the planning system building upon improvements already made. / GHS WRITTEN RESPONSE 19.09.2014
Dear Sir
Technical Consultation on Planning
The Garden History Society has reviewed the above consultation document, and the specific proposals with regard to the Society and its role in the planning system (para 4.44). We now respond to this specific point.
We note that the Government proposes to amend the means by which local planning authorities are instructed to consult The Garden History Society, in its role as Statutory Consultee, on proposals for development affecting sites included by English Heritage on the Register of Parks and Gardens of Special Historic Interest, or the setting of such sites.
We understand that the effect of this proposal is to move the requirement for consultation from Secretary of State Direction, to the Development Management Procedure Order.
Experience since 1995 (when the Society became a Statutory Consultee in the planning process) shows that the present arrangement leads to confusion on the part of some local planning authorities, which, in turn, has contributed to uneven and inconsistent levels of consultation across England – and a correspondingly inconsistent level of expert advice provided to planning authorities when considering proposals affecting nationally designated designed landscapes.
We conclude that the proposal outlined in the consultation document (para 4.44) is likely to remove potential for misunderstanding and confusion within the planning system, by removing the direction for consultation from Secretary of State Direction to the DMPO, a document with which we assume all planners will be fully conversant. The proposed change should, we believe, increase the level of consultation and consistency of consultation with the Statutory Consultee; and therefore the level of expert advice provided to planning authorities considering applications for change affecting nationally designated designed landscapes by the Statutory Consultee. The Garden History Society therefore has no objection to the proposal outlined in para 4.44 of the consultation document.
We note that no change is proposed to the Society’s status as Statutory Consultee.
While not wishing to comment in detail on the detail of the other proposals contained in the consultation document, we note, and fully concur with concerns raised by the other National Amenity Societies whose remit relates primarily to the built heritage with regard to the threshold for consultation where demolition or partial demolition of a listed structure of any grade is proposed.
Our concerns relate especially to listed structures within historic designed landscapes, especially where such landscapes are not themselves the subject of national designation and therefore not subject to any requirement to consult The Garden History Society in its statutory role when change is proposed. Such listed structures are often integrally linked to the aesthetic and historic significance of such designed landscapes, and the loss or partial loss of such structures has the potential greatly to diminish the significance and contribution of designed landscapes to local, regional and national heritage.
We would therefore welcome reconsideration of this aspect of the Government’s proposals, and take this opportunity to highlight our support for the submission of the Joint Committee of the National Amenity Societies.
Yours faithfully
Jonathan Lovie
Principal Conservation Officer and Policy Adviser
The Garden History Society
CGT WRITTEN RESPONSE BUCKINGHAMSHIRE GARDENS TRUST27.09.2014
Review of requirements for consulting with English Heritage
Question 4.3: Do you agree with the proposed changes to the requirements for consulting and notifying English Heritage set out in Table 3? If not, please specify what change is of concern and why?
Yes
Comments
The retention of the requirement to consult EH on applications affecting Grade I/II* parks and gardens is essential to the protection of these important heritage assets, and is welcomed. The introduction of a parallel requirement in respect of battlefields is also to be welcomed, as is the greater overall consistency between consultation requirements: greater clarity is likely to support greater effectiveness and efficiency.
Question 4.5: Do you agree with the proposed minor changes to current arrangements for consultation/notification of other heritage bodies? If not, please specify what change is of concern and why.
Yes
Comments
The proposal to move the requirement to consult the Garden History Society (GHS) into the Development Management Procedure Order (from the current freestanding Direction) is very much to be welcomed. Recent doctoral research into the effectiveness of the planning system in protecting historic parks and gardens (including a nationwide survey of LPA practice), has demonstrated a high degree of confusion regarding the relevant consultation requirements, and the omission of some consultation as a result (notably in relation to the GHS), with an inevitable reduction in the protection available to parks and gardens in consequence. Moving the requirement to a more visible location will increase clarity, and also send a clearer message that registered parks and gardens are important heritage assets (the aforementioned research also demonstrates that historic parks and gardens are often neglected in the planning process, in favour of ‘higher profile’ listed buildings, that profile stemming in part from the visibility of the associated statutory requirements).
[Details of the findings from the research cited here are available on request].
Question 4.6: Do you agree with the principle of statutory consultees making more frequent use of the existing flexibility not to be consulted at the application stage, in cases where technical issues were resolved at the pre-application stage?
No
Comments
Pre-application consultation is a valuable and important part of the planning application process, but follow-on engagement by the statutory consultees in the form of responses to the consultation on the final planning applications remains essential. Proposals do change, and a final assessment by the statutory consultees is very much needed. Some applicants represent the outcome of pre-app engagement more positively in their own assessments than the statutory consultees they engaged with may recognise, whilst the LPA may not have the expertise to assess the impact on, say, heritage assets, of apparently minor changes since pre-app: overall, the risk of something slipping through the net is too great. Furthermore, the effort put in to pre-app by statutory consultees is not adequately weighted in current monitoring systems, and more comprehensive final input on a planning application is effectively incentivised. Finally, the benefits of the proposed changes do not outweigh the risks: if a scheme has been revised wholly in accordance with extensive pre-app discussions, there is little additional burden to the statutory consultees in assessing the final scheme; if changes have not been made as agreed, or the scheme has been further revised, statutory consultee input remains very necessary.
Victoria Thomson
Buckinghamshire Gardens Trust
Bristol Rugby Memorial Ground / Avon / E14/0082 / N / PRE-APPLICATION The Memorial Ground is a war memorial in the form of a sports ground, an inspirational and important war memorial in Bristol. It was constructed in the 1920s as a way of commemorating the 300 rugby players who had died in the First World War. It is a practical and living memorial and was set up to be of benefit to future generations. To this day, rugby and football matches are played there. Plan to demolish the Memorial Stadium and build a Sainsbury's superstore on the site. An application to English Heritage has been made, to consider listing the war memorial (EH ref: 1419835). English Heritage have completed their initial assessment and are considering whether the war memorial sports ground merits inclusion on the National Register of Parks and Gardens of Special Historic Interest. English Heritage have invited representations. The Memorial Stadium (Bristol Rugby Memorial Ground), Filton Avenue, Horfield, Bristol. / CGT WRITTEN RESPONSE 23.04.2014
Thank you for your email about the Memorial Ground in Bristol, which has been forwarded to me by the Garden History Society. You say that you have made an application to English Heritage for the inclusion of the Memorial Ground as a war memorial sports ground on the Register of Parks and Gardens of Special Historic Interest. You asked for guidance about how to make an effective case for such a designation.
English Heritage has published a 'Register of Parks and Gardens Selection Guide Landscapes of Remembrance' which will help you. Page 8 gives nine general criteria (five relating to date and four to other considerations) that a site must have to give it a level of 'special historic' interest nationally which would justify its inclusion on the Register.
English Heritage has also published guidance called 'Conservation and Management of War Memorial Landscapes'. The first stage of this about 'Understanding the significance of the current site.'
Looking at English Heritage's guidance, however, it seems unlikely that the Memorial Ground would meet the selection criteria to merit its inclusion on the Register, unfortunately.
Furthermore, the Memorial Ground has been not been considered to have value at a local level. A survey was carried out in the 1980s of parks, gardens and other designed landscapes in Avon to assess whether they had local historic interest. Those selected were designated as such for planning purposes by Avon County Council, and subsequently by the four unitary authorities which replaced Avon. Bristol C.C. therefore does not consider the Memorial Ground to be a historic designed landscape of local interest. Had this been the case, it would have been taken into account by Bristol C.C. when considering the application to redevelop the Memorial Ground.
You also asked whether the inclusion of the Memorial Ground on the national Register would be sufficient to halt the supermarket redevelopment. Whilst I suggest you take legal advice about this, I believe it is the case that such designation would not affect the validity of the planning permission which has been granted.
I am sorry that I cannot be more helpful.
Yours sincerely
Ros Delany (Dr)
Chairman, Avon Gardens Trust
Tyntesfield / Avon / E14/0071 / II* / PLANNING APPLICATION Construction of a fenced compound for garden composting, processing of cardboard waste and storage of topsoil, bark/woodchip and gravel to be constructed of 2no rows of storage bunkers, north and south of a central gangway, with 2no smaller bunkers to east of northern row and constructed of timber sleepers with steel RSJ supports within a woodland clearing on south parkland of Tyntesfield Estate. Land off Wraxall Drive, Tyntesfield, Wraxall, BS48 1NU. MISCELLANEOUS / CGT WRITTEN RESPONSE 08.05.2014
Tyntesfield House is Grade I listed and the Historic Park and Garden surrounding it is Grade II*. This application affects the Heritage Site that it is situated within.
Land off Wraxall Drive, Tyntesfield, Wraxall, BS48 1NU
Summary: The Avon Gardens Trust supports this application.
We are grateful for the opportunity to comment on application 14/P/0725/F which seeks permission for the Construction of a fenced compound for composting and processing of cardboard waste and storage of topsoil, bark/woodchip and gravel to be constructed of two rows of storage bunkers north and south of a central gangway with two smaller bunkers to the east.
We have made a site visit and undertaken further research. The significance of moving the composting and storage site out of the West Slip is to open this area to visitors and extend the appreciation of the old productive gardens of the estate.
The proposed new site within the woodland fringe to the parkland has the advantage of seclusion balanced against its accessibility.
We would ask that the following points should be taken into consideration when a decision is made.
To reduce any adverse impact on the significance of the heritage asset, please ensure that new deep, evergreen hedges are planted along the north-west side of the composting site, where it borders the parkland.
We appreciate planning decisions have to be balanced based on prevailing planning policy. We would ask you to consider the proposal against the National Planning Policy Framework particularly Section 12 which serves to Conserve and Enhance the Historic Environment.
The Avon Gardens Trust works closely with the Garden History Society, (the statutory consultee on Registered Parks and Gardens) to comment on planning applications affecting Registered Parks and Gardens and their setting and our comments on applications are forwarded to, and kept by, the Garden History Society.
We would be grateful to be advised of your decision.
Yours faithfully
Dr R Delany
Chairman of Avon Gardens Trust
Leigh Court / Avon / E14/0087 / II / PLANNING APPLICATION Retrospective application for the erection of detached store structure and single storey extension to tea room and tea room kitchen, creation of outside seating area for tea room use (removal of condition 2 attached to planning permission 09/P/0364/F). Brackenwood Plant & Garden Centre, Leigh Court Estate, Pill Road, Abbots Leigh, BS8 3RA. CATERING / CGT WRITTEN RESPONSE 08.05.2014
Heritage Asset: Leigh Court Historic Registered Park and Bristol-Bath protected Green Belt area.
Summary: The Avon Gardens Trust has no objection to this retrospective planning application.
We are grateful for the opportunity to comment on application 14/P/0770/F which seeks retrospective permission for the erection of a detached store structure and single storey extension to a tea room and tea room kitchen, creation of outside seating area for tea room use, (removal of condition 2 attached to planning permission 09/P/0364/F).
We have made a site visit and undertaken further research.
The significance of this application related to North Somerset Core Strategy [CS5] is that, “the council will conserve historic parks and gardens”. Brackenwood Nursery and Garden Centre lies within the Leigh Court Garden of Special Historic Interest.
However, having visited the site, the surrounding area is heavily landscaped and lies within a topographic bowl, which restricts visibility to and from the existing garden centre and its current tea room.
Any nursery and garden centre arguably needs a suitable refreshment area. Although the extension itself may not be architecturally significant, it is well shielded from its historic surroundings, and therefore would have a negligible effect on the historic landscape.
We would ask that the following point should be taken into consideration when a decision is made.
That the trees and shrubs around the refreshment area are kept to a height that will
screen the building and outside seating area.
The Avon Gardens Trust works closely with the Garden History Society (the statutory consultee on Registered Parks and Gardens) to comment on planning applications affecting gardens and landscapes that are heritage assets and our comments on applications are forwarded to, and kept by, the Garden History Society.
We would be grateful to be advised of your decision.
Yours faithfully
Dr R Delany
Chairman of Avon Gardens Trust
Burwalls House / Avon / E14/0206 / II / PLANNING APPLICATION Conversion and sub division of the grade II Burwalls House from use class Sui Generis to use class C3 (residential) to 5no. residential flats. Demolition of existing buildings in the annexe (excluding the former coach house and Lodge) and replacement with 6no. residential dwellings (excluding The Lodge). Associated infrastructure, parking, open space and landscaping. Burwalls, Bridge Road, Leigh Woods, Long Ashton, BS8 3PD. BUILDING ALTERATION, RESIDENTIAL / CGT WRITTEN RESPONSE 12.06.2014
Dear Mr Stevenson
Burwalls is grade II listed. It is within the view of grade I listed Clifton Suspension Bridge and Toll Houses. Burwalls, Bridge Road, Leigh Woods, Long Ashton.
Summary: The Avon Gardens Trust does not object to this application, but would suggest that a detailed landscaping scheme be submitted and agreed prior to the commencement of development.
We are grateful for the opportunity to comment on application 14/P/0944/F which seeks permission for the Conversion and sub division of the grade II Burwalls House to use class C3, to 5 residential flats. Demolition of existing buildings in the annexe [excluding the former coach house and Lodge]. Within the stable area six new houses are proposed.
We have made an area visit and undertaken further research. The developer has proposed a conservative approach to the garden and grounds. The historic landscape of Burgh Walls camp is to remain intact. The parkland setting will also be subject to minimum interference. The landscaping around the stables does not seem to impact on the surrounding properties or cause problems with access.