HE Hearing Statement Matter 4 Site GTA1
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MATTER 4 SITE ALLOCATIONS (PART 2 ALLOCATIONS) Site GTA1: Skottowe Crescent, Great Ayton Historic England HAMBLETON LOCAL PLAN EXAMINATION MATTER 4 - SITE ALLOCATIONS (PART 2 ALLOCATIONS) Issue 7 - Stokesley Area Sites Site GTA1: Skottowe Crescent, Great Ayton 1 Introduction 1.1 This hearing statement should be read alongside Historic England’s comments submitted at previous consultation stages of the Hambleton Local Plan. 1.2 The allocation of Site GTA1 for residential development is not sound as it is neither justified nor is it consistent with either the emerging Policies in the Local Plan or with national planning policy. 1.3 Paragraph 184 of the NPPF sets out a requirement for Local Plans to conserve heritage assets in a manner appropriate to their significance. When considering the impact of a proposed development upon the significance of a designated heritage asset, Paragraph 193 of the NPPF makes it clear that great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). Paragraph 194 meanwhile acknowledges that significance can be harmed by development within its setting, and explains that any harm to the significance of a designated heritage asset requires clear and convincing justification. This site lies close to the boundary of the Great Ayton Conservation Area and opposite a group listed buildings including the Grade I Listed Church of All Saints and the Grade II* Listed Ayton Hall. The loss of this site and its subsequent development will harm elements which contribute to the significance of these designated heritage assets. 1.4 Consequently, the allocation of Site GTA1 as proposed in the Submission Local Plan is considered to be in conflict with the following aspects of the emerging Local Plan: • The Local Plan Vision – in that it conflicts with the intention that new development will reinforce the distinctive character of Hambleton’s settlements and landscapes, and to preserve heritage assets. • Outcome 4 - in that it will not protect or enhance Hambleton’s special qualities with regard to the historic environment. - 1 - MATTER 4 SITE ALLOCATIONS (PART 2 ALLOCATIONS) Site GTA1: Skottowe Crescent, Great Ayton Historic England • Policy E5 – in that it will not conserve elements which contribute to the significance of designated heritage assets, and the likely harm caused is not clearly justified or outweighed by public benefits resulting from the proposed development. • Policy E7 – in that it would be harmful to the character and setting of the village, damaging the historic form and layout of Great Ayton. 1.5 It would also be contrary to national planning policy as set out in the NPPF insofar as it would not: • Help to deliver a “positive strategy for the conservation and enjoyment of the historic environment” as is required by NPPF, Paragraph 185. • Contribute to protecting or enhancing the historic environment. Therefore, it will not deliver sustainable development in terms of the conservation of the historic environment [NPPF Paragraph 8]. • Conserve heritage assets in a manner appropriate to their significance [NPPF, Paragraph 184]. • Give great weight to the conservation of the area’s designated heritage assets [NPPF, Paragraph 193] • Provide clear and convincing justification that the harm it would cause to the heritage assets is outweighed by the public benefits [NPPF, Paragraphs 194-196]. • Be sympathetic to local character and history including the surrounding built environment and landscape setting [NPPF, Paragraph 127]. 2 Responses to the Inspector’s Questions Q9. How have the effects of development on the Great Ayton Conservation Area and the setting of neighbouring listed buildings been considered as part of the site allocation process, having particular regard to the setting of, and views towards, the Grade I listed Church of All Saints and the Grade II* listed Ayton Hall? Is the allocation justified? Q10. What effect will the allocation have on the rural setting and character of Great Ayton? How has this been considered as part of the preparation of the Local Plan? 2.1 There are several Listed Buildings to the south of site GTA1 along the northern boundary of the Conservation Area, including two assets of the highest significance – the Grade I Listed twelfth Century Church of All Saints, and the Grade II* Listed late seventeenth Century mansion Ayton Hall. In addition there are a number of Grade II Listed buildings and structures in the vicinity of the - 2 - MATTER 4 SITE ALLOCATIONS (PART 2 ALLOCATIONS) Site GTA1: Skottowe Crescent, Great Ayton Historic England site including the wall, gates, piers and fences to the Church of All Saints along with the Cook headstone (to brothers and sisters of Captain James Cook), the altered early eighteenth Century farm buildings to the north of Ayton Hall, and the imposing Christ Church whose red sandstone banded spire is prominent in the surrounding landscape. 2.2 The Heritage Background Paper [SD24] considers that the development of this site will harm elements which contribute to the significance of these assets but that there is an opportunity for enhancement through reinstatement of the historic strip field alignment. We disagree with that conclusion and consider that it has failed to properly articulate the contribution which this undeveloped site makes to the setting and appreciation of the highly-graded listed buildings in the vicinity of the site and the Great Ayton Conservation Area. As a result, it has underplayed the harm that the loss and eventual development of this site might have upon the significance of these assets. 2.3 Moreover, we do not consider that the harm to the setting of these designated heritage assets is capable of effective mitigation by the measures suggested in the Heritage Impact Assessment. The re-establishment of a single strip field alongside the sites western edge in an area where the field pattern has substantially changed as a result of modern farming practices would be largely tokenistic and not outweigh the harm caused by the loss and development of the remainder of the field. Secondly, landscaping should in most cases only be considered partial mitigation as they are a transient feature in the landscape that are subject to seasonal changes and can be affected by ownership and management practices. Indeed, the introduction of additional landscaping could itself result in harm in having an intrusive an effect on the open rural character it seeks to mitigate. 2.4 Historic England’s advice on cumulative change is clear that where the significance of a heritage asset has been compromised in the past by unsympathetic development affecting its setting, to accord with NPPF policies, consideration still needs to be given to whether additional change will further detract from, or can enhance, the significance of the asset [Good Practice Advice in Planning Note 3: The Setting of Heritage Assets, Historic England, 2015]. The heritage assessment does not give proper consideration to the matter of cumulative change. The development of this site will only serve to compound the harm already caused to the setting of these designated heritage assets by the 1970s residential development to the west of A173 Guisborough Road. - 3 - MATTER 4 SITE ALLOCATIONS (PART 2 ALLOCATIONS) Site GTA1: Skottowe Crescent, Great Ayton Historic England 2.5 There is also a contradiction between the conclusions of the Heritage Background Paper [SD24] and the assessment of this site in the Sustainability Appraisal Site Assessments - Stokesley Area [LP04.4]. The site is given a red score under sustainability assessment objective 5 relating to the built environment with the accompanying commentary stating that the site is highly sensitive location where harm caused by development cannot be mitigated. The assessments concluding remarks highlight that the site would have an adverse impact on character and that the site performs poorly against objective 5. 2.6 Although Great Ayton has experienced considerable change over the years, the area to the northwest and west of this group of designated heritage assets has remained relatively unchanged. Comparison of the first edition OS county series of 1856 (as shown on page 62 of SD28 Settlement Character Assessments) with the current map shows the degree to which historic settlement of Great Ayton has expanded to its north and east. The proposed allocation site forms part of the last vestige of the rural setting of the village. This agricultural character makes an important contribution to the setting and appreciation of the listed buildings and conservation area. The existing residential development to the west of the A173 already impinges on views from the churchyard of the All Saints Church and from Ayton Hall. The loss of the site of this proposed allocation would effectively sever these buildings from their rural setting harming their setting and appreciation. It would also diminish the significance of the historic relationship between the hall and the church. 2.7 Contrary to the conclusions in the Heritage Impact Assessment, it is difficult to comprehend how any housing on site GTA1 could be successfully developed in a manner which would not harm the rural character of this area and the setting of the designated heritage assets opposite. Whilst new development on this site would obscure views of the poor quality 1970s housing development to the west of the A173, the resulting loss of the agricultural land and its development would cause even greater harm to the setting and appreciation of the heritage assets in the area, both when viewed from the assets themselves and as a result of the high level of inter-visibility between the heritage assets and their setting afforded from the public rights of way crossing the fields to the north of the village. - 4 - MATTER 4 SITE ALLOCATIONS (PART 2 ALLOCATIONS) Site GTA1: Skottowe Crescent, Great Ayton Historic England Q11.