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CONSERVATION CASEWORK LOG NOTES JANUARY-FEBRUARY 2015

The GHS conservation team received 281 new cases in England and 7 new cases in Wales in January and February in addition 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, 16 ‘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 Response Lumley Castle County E14/1299 II PLANNING CGT WRITTEN RESPONSE 06.02.2015 Durham APPLICATION We are grateful for the opportunity to comment on this application. Temporary events The Northumbria Gardens Trust wishes to raise a number of serious marquee and extension of concerns in relation to the proposed marquee. existing car parking area. By way of background, we appreciate planning decisions have to be Lumley Castle Hotel, balanced, based on prevailing planning policy. We would ask you to Chester-le-Street, consider the proposal against the National Planning Policy Framework Durham DH3 4NX. particularly Section 7 (Requiring Good Design) and Section 12 MARQUEE, PARKING (Conserving and Enhancing the Historic Environment) and the relevant Durham County Council design and conservation policies. As you are aware the inclusion of this site on the Register is a material consideration when determining an application. As previously notified to you, The Garden History Society, who is the statutory consultee on matters concerning registered parks and gardens, is now working closely with County Garden Trusts, and the responsibility for commenting on planning applications in this context is now passed to the Trusts. The inclusion of this site on the national register is a material consideration. Lumley Castle park and gardens are significant for the following reasons; • The parkland was developed during the early eighteenth century and is an overlay of the work of several, nationally important, landscape designers who were consulted by Lord Scarborough including; George London (d.1714), Sir John Vanbrugh (d.1726), 1 Stephen Switzer (d.1745) and Charles Bridgeman (d.1738). Thomas White produced a plan in 1768 and Mr Mickle (likely to have been Adam Mickle d.1828) also produced estimates for work. • A substantial amount of the original layout has survived and reflects the original intentions for a landscape setting to the castle. This includes the pleasure grounds ha-ha, parkland and parkland trees, extensive woodland, a perimeter belt of woodland, kitchen garden, remains of lime tree avenue, earthworks from an earlier landscape scheme, and principal approach. • Lumley Castle park and gardens are well documented in plans (private collection) and were depicted by Buck in 1728. • The origins of the park are discussed in publications by a number of renowned garden writers including Green, D. Gardener to Queen Anne (1956), Jaques D. Georgian Gardens (1983), Downs K. Sir John Vanbrugh (1987), Willis P. Charles Bridgeman and the English Landscape Garden : New documents and Attributions (1993) • The castle is a landmark, visible from Chester le Street town and approaches, the railway, the cricket club and Riverside Park and its imposing presence above the sloping land to the river is depends upon its landscape setting. The revised location for the marquee does not maintain or enhance the architectural and landscape setting of the Castle, gardens and parkland in which it is to be sited. Quite clearly it is a detractor, asserting a negative influence on the castle building and landscape. The additional car parking will also detract from the landscape setting to the west front the castle. We suggest that the marquee will be required long-term and renewed applications will be made in order for the continued use of the additional space. We suggest that more serious exploration of all site options should be carried out together with any mitigating landscaping works that might shield the structure without impacting on the significance of the historic landscape. In conclusion, NGT oppose a five year only approval for this marquee. We would be grateful to be advised of your decision. Yours faithfully Martin Roberts - On behalf of the Northumbria Gardens Trust Brockhole Cumbria E14/1271 II PLANNING CGT WRITTEN RESPONSE 31.01.2015 APPLICATION Re- Our comments focus on a number of points of detail, but also on opening and widening of some important aspects of planning principle, which we would like to the historic entrance on first address. the A591 to become the 1.00 Planning Overview 2 new entrance to When the National Park acquired Brockhole it also took on the Brockhole. Re-surfacing responsibility of managing a Grade 2 listed house and a Grade 2 to existing vehicular and registered garden. At the time the Authority had an educational use pedestrian routes and that was sympathetic to the exercise of the conservation minor amendments to requirements involved. It is our contention that ever since there has existing road alignments. been a progressive erosion of this primary responsibility, to the point Installation of a new where conservation has become of secondary importance to the footpath and creation of exploitation of the estate. waiting areas, including In particular, we are concerned that the context of the gardens has feature seating and way been diminished by the imposition of over intensive use. marking. New feature In our view, the garden and immediate landscape are of paramount gates and signage importance both in their own right and also as an important element adjacent to the A591. in the garden and cultural heritage of the Lake District. We would Installation of low level urge the following; lighting. Demolition of - That the Park Authority now ring fence the garden and associated lean to structure and landscape from any further intrusions. creation of an informal - That the Park Authority revisit the Master Plan to ensure that the staff car park. Lake conservation obligations are being consistently met and budgeted District National Park for. Authority, Brockhole, - That the opportunity be taken to evaluate the place of gardens Windermere, Cumbria within the “cultural landscape” of the Lake District, in the context of ACCESS/GATES the World Heritage Site application. (We would be happy to discuss this) - We would like to see The Park Authority give itself new guidelines governing the approach to garden and landscape conservation. For example, the Park Authority recently sanctioned the felling of a prize specimen monkey-puzzle tree at Brockhole, in the face of fierce opposition from ourselves and others. This was evidently justified on the absolutist grounds that the tree was not planted by Thomas Mawson and therefore such an intervention had no place in a garden designed by him. From these applications, it now seems that the Park Authority are prepared to propose much more damaging interventions, if it suits them, by spoiling the entrance as designed by Dan Gibson and Thomas Mawson. We consider that this is unacceptable and the proposals should be refused by the Committee. - The applications suggest uncertainty about the role of modern design in relation to listed buildings and gardens. Whilst we applaud the Park Authority’s general acceptance of the need for good modern design, the parameters do not seem to be very clear. Where listed properties are concerned, we suggest the aim should always be to preserve the integrity of house and/or garden. In our view, approval 3 would breach the Park Authority’s Core Policy CS03, which requires the protection, maintenance or enhancement of local distinctiveness, character and landscape setting. The policy also states that the loss of green infrastructure or natural features, which are important in the relationship with existing buildings should not result from any development. The use of modern design should therefore be unobtrusive. In our view, these proposals step well beyond this line. 2.00 Comments on details of Applications 2.01 Need It is not made clear why the provision of coach access and unloading is needed, other than to ease congestion on the main car park, Our comments are as follows:- - We accept that there is a need to provide drive access to the mansion, but see nothing to suggest that this existing access is not adequate. - If there is a need to accommodate a projected increase in numbers and coaches to the Treetop site, this should be achieved strictly outside the curtilage of the mansion, the drive and the Mawson garden. - In our view the assertion that the proposals would bring needed activity to the entry part of the site reveals a serious misunderstanding of the need to conserve and safeguard the character of the area. - We concede that there may be an incidental need to improve the connection between the main carpark and the drive to the Mansion, for service vehicles, disabled etc and would have no objection to this if kept to a modest scale and is simply detailed. - we have no objection to the lean-to sheds being removed. - we see no evidence that the gate pillars were ever rendered as alleged and trust that they will be retained as existing. 2.02 The proposal to widen the existing drive opening As stated above, we do not consider that the need to enhance the entry has been demonstrated and urge that the existing north entry be conserved as existing. We make the following additional comments. - The entry and drive are a major element in Thomas Mawson’s design of the Brockhole landscape and should be treated as sacrosanct, under the provision of the garden Grade 2 registration and Core Policy nos. CS03, CS10 & 25. - We note that the proposal is silent on how it would fit in with measures to cope with the traffic access problems off and on to the busy A591. There is already an acute problem and there is no 4 mention of how increased visitor numbers and coaches could be accommodated. In our view the application should not be determined until these issues are fully understood and resolved. - We suspect that creating two busy access points so close to each other will create a significant traffic hazard. Slowing traffic would inevitably cause bunching and add to the hazards involved - We further note that no mention is made of all the intrusive signs that would be necessary to direct traffic to select the right entry point, without which there would be further confusion. - It is not clear how the coaches would exit Brockhole other than by weaving their way through the main car park. This implies that the coaches could just as easily park in the main car park and that there is no necessity to disturb the Mawson entry. A redesign of the car park is needed. - the proposals to “enhance” the drive, to accommodate coaches are an unwarranted intrusion. The scale of the drive should not be compromised by widening and the hard landscaping should not be given a modern makeover, with such materials as sets and resin bonded aggregate surfaces, not used in Mawson’s day. - The modern gate design might be appropriate for a new development but, in our view, is not acceptable where the imperative need is to preserve Mawson’s concept and design. Such a change in design would in our view be contrary to Core Policy BE1, requiring the use of vernacular materials. 2.03 Proposed Signs outside widened entry As described above, we feel the need for the altered access has not been proven and thus we consider that additional signs are not needed. We however add the following comments:- - The probability is that on seeing the signs motorists will become confused as to which is the right entrance to Brockhole and this will create a traffic hazard. - The current and proposed style of the signs is flashy and in our view inappropriate for the entrance to a registered garden and listed Arts and Craft property. The design would be fine in a new town business park, but we suggest not appropriate in this context and in a National Park. - To make the signs would involve a lot of craftsmanship to manufacture (and expense), but certainly do not demonstrate the Arts and Craft ethos, as suggested. - The detailed design needs scrutiny. For example, the gap between the wall and the sign soon become clogged with leaves and litter. The “silver” oak work would suffer since it would be out of sunlight, and 5 would soon turn black or green and become liable to rot. (see photograph of the existing vegetation) - If any signs are need, they should be minimalist. - in our view, the changes would also be in breach of Core Policy BE1. 2.04 Banner Signs behind the boundary Wall In our view the signs proposed would look grotesque in the National Park. Our comments are:- - Their somewhat brutal design would be out of keeping with the conservation imperatives of the site. - The signs would heighten fears that the Lake District is becoming urbanized to the detriment of its special scenic character and culture and woujld be contrary to Core Police BE1. - reading these banner signs would be distracting for drivers and liable to create a traffic hazard, especially in the midst of an area of such confusing traffic movements. - The proposal for these quasi-commercial signs calls into question the efficacy of the Park Authority’s stewardship of Brockhole and the Masterplan. Whilst it is clearly important that the National Park helps to accommodate tourist needs, arguably it is not there to create these needs by advertising, especially when the process threatens to damage what they are there to protect. In our view the National Park seem to be overstepping the mark at Brockhole. These signs are not necessary. - Signage should be limited strictly to direction signs. We urge that these sign proposals be rejected and the design of the existing entrance be re-examined to see how it could be more clearly and tastefully done. 2.05 Trees We note that a number of the trees identified as Lawson Cypresses are in fact Western Red Cedars. In our view, there were probably planted under the Mawson plan and should be retained. The trees in question appear to be healthy and there is no justification for them to be removed on safety grounds. It is also noted that the drive enlargement would encroach significantly into the Tree Root Protection Area (TRPA) of the adjacent oak, again probably planted in Mawson’s day. This would directly harm the tree and may reduce its life expectancy. We have not measured the trees, but from the plan it appears that the TRPAs allowed are much smaller than would be expected and that serious damage would thus ensue. In our view, the proposal should be rejected on tree preservation grounds alone and we maintain that 6 approval would breach Core Policy NE 12 for the protection of trees with no outweighting need having been established. 3.00 Carpark Reception Building We have no objections to the proposals for the building, which seem to elegantly separate the activities of the car park and Treetop site area from the Mawson Garden. We would only add; - We would prefer the footpaths to be kept as simple as possible, paved in tarmac, rather than resin bonded aggregate. Neither should they be over detailed with modern sets, too many signs and road markings. - We would like to see a more comprehensive indication of the planting proposed. 4.00 Some final comments: We apologise if the above comments appear over negative. However, on the evidence of these applications, our concern is that the National Park seems to be slipping away from the conservation values that have served to sustain the Park’s integrity since its inception. This fear is not helped by the documents declared aim to improve Brockholes “on street image.” With respect, we suggest the Park’s purpose is not to follow every passing fashion and to court popularity. Likewise, the documents extol the ideals of “Grab/Gasp/Grasp” as being the “overarching headings”. Is this really what now drives the National Park? In our view, the Masterplan is proving to be over ambitious and is progressively threatening conservation. We urge the Park Authority to urgently review the Masterplan and give serious thought as to where Brockhole and its garden is going. David Matthews RIBA, Dip Arch Chairman, Cumbria Gardens Trust Kedleston Park Derbyshire E14/0936 I PLANNING GHS WRITTEN RESPONSE 26.02.2015 APPLICATION Outline We are in receipt of your email correspondence of February 6th 2015 application for the relating to the above and have considered the ‘Amended Plans’ erection of up to 400 posted on the Amber Valley website. dwellings (Use Class C3), Our response below relates in particular to points raised in the convenience store (Use supplementary EDP document: “Statement in Respect of Heritage Class A1 up to 500 sqm Issues (January 2015) ref EDP2130_10a”. floorspace) with That document considers at length various appeal judgements associated access, relating to several properties in other parts of the country, in earthworks and other particular those relating to significance and the part that setting ancillary and enabling plays in significance. works. All other matters It largely fails however to address the substance of our previously (appearance, stated grounds for objecting to the proposed development which are 7 landscaping, layout and as follows (summarised from our letter of December 5th 2014): scale) reserved. This is a  it will adversely affect the setting of the Grade I Registered Departure from the Kedleston Park; Development Plan. Land  it will similarly impact upon the setting of the Grade I Listed Off Kedleston Road, Kedleston Hall, with other Grade I Listed buildings at Quarndon, Derby, Kedleston, as previously detailed; Derbyshire.  it is likely also to impact upon the setting of a number of RESIDENTIAL other Grade II* and Grade II Listed buildings at Kedleston;  it lies within the “defined setting” of the Historic Park and Garden at Kedleston Hall as outlined in the Amber Valley Local Plan (2008) and specified in Policy EN33;  it may also contravene Amber Valley’s Policy EN27 as this relates to the Kedleston Conservation Area. The document describes our previous statement that “the proposed development would potentially be visible from large areas of Kedleston Park itself and hence also from the Kedleston Park Conservation Area” as ‘clearly inaccurate and misleading’ (para.3.9) . This however is based on the applicant’s own plot of the Zone of Theoretical Visibility (ZTV) as viewed from the proposed development site (Plan EDP 7) which shows areas in brown (i.e. “theoretically visible”) spread across the larger part of the Registered Park area (and the Kedleston Conservation Area), and indicates also that the proposed development would be clearly visible from the larger part of its eastern boundary as well as from the public approach to it (i.e. the Kedleston Road itself) . The document also states that in our earlier response ‘no attempt is made to identify either the significance of the numerous heritage assets that are alleged to be affected, or the contribution made to that significance by their setting’ (para.3.8). Firstly, we consider that the Listed Buildings designations applied by English Heritage to the various buildings and structures at Kedleston are themselves a good indicator of their significance. These are described as: • Grade I buildings are of exceptional interest, sometimes considered to be internationally important; only 2.5% of listed buildings are Grade I • Grade II* buildings are particularly important buildings of more than special interest; 5.5% of listed buildings are Grade II* • Grade II buildings are nationally important and of special interest; 92% of all listed buildings are in this class and it is the most likely grade of listing for a home owner . We consider also that the significance of the Grade I Registered 8 Parkland at Kedleston (defined by English Heritage as ‘of exceptional interest’) is similarly described (8.7% of all Registered Parks and Gardens are designated Grade I). Secondly, we consider it sufficient at this stage to highlight that the setting of these heritage assets will be adversely affected by the proposed development. As stated in the NPPF, it is the task of the developer to demonstrate convincingly that these impacts will not be significant and this to a large extent appears to have been the task of the original Heritage Setting Assessment (October 2014). This is a document which demonstrates an almost wholly superficial understanding and appreciation both of the general history and development of designed landscape as a whole, and of the history, development and design intentions of Kedleston Hall and its parkland landscape in particular. It repeats the accepted fiction that Robert Adam was responsible for the overall landscape design at Kedleston, assumes in addition that it knows what his design intentions were, and consistently ascribes this development to the ‘mid-late 19thcentury’ (paras.5.146 et seq.), when in fact Robert Adam’s involvement at Kedleston (and then primarily with the design only of those of its buildings that he was required to by Lord Scarsdale) extended only from c.1759 to the mid-1770’s, at the latest. It suggests that Charles Bridgeman’s earlier design was almost wholly eradicated by Adam’s (supposed) landscape, when it was in fact modified and largely incorporated into the later design. On this point, it correctly identifies that the first portion of the main entrance drive from Adam’s North Lodge is a surviving element of the earlier Bridgeman landscape, but then mistakenly suggests that this northern approach to Kedleston Hall is through the area now occupied by the Golf Course. The document also seemingly fails to appreciate and/or properly to present in its analysis the subtleties inherent in the concept of setting . As an example (one of many such), in considering the possible effects of the proposed development on Kedleston Hall, it says only that “the setting of the hall is its landscape park and the interrelationship with the various structures and area within it” . In this, it appears to conflate and partly to confuse setting with design, failing to appreciate not only the obvious views from Kedleston Hall into the wider landscape beyond the immediate park , but also the wider and more subtle relationships between the Hall itself and those areas outwith its immediate visual sphere (e.g. the presence of and links, both physical and historical, to nearby Meynell Langley, to name but one ), all of which are part of its setting. 9 It is hardly surprising therefore that it can conclude that ‘The house is the main focus of the park with the landscape designed to fully appreciate its layout and position in the landscape. The Hall cannot be seen from the proposed development site. On this basis, it is considered that the setting and therefore the significance of this designated heritage asset will remain unaffected by the development of the site’ . This despite repeated references to the planting of the ‘Derby Screen’ as a response to changes in the setting both of Kedleston Hall itself and of its designed parkland landscape, caused by the westward expansion of Derby city in the mid- to late-20th century. It was in response to these changes, and the likely pressure for further erosion of the setting of Kedleston Hall (including its parkland) that the National Trust commissioned a Landscape and Visual Impact Assessment from the Derek Lovejoy Partnership (2001), culminating in the adoption by Amber Valley of the defined setting for Kedleston (Policy EN33) in 2008. This states clearly that: “Within the defined setting of the Historic Park and Garden at Kedleston Hall, as shown on the Proposals Map, planning permission will not be granted for any development proposals that would have an adverse impact on the landscape setting, including views into and out of, the Historic Park and Garden”. The wording of this policy is comprehensive and unambiguous. It includes views as a part of setting, clearly signifying that the two are not synonymous. It also plainly states that planning permission ‘will not be granted for any development proposals that would have an adverse impact [my emphasis] on the landscape setting…of the Historic Park and Garden’. This policy is still in effect, notwithstanding misleading statements by the applicant about an ‘emerging Local Plan’ and ‘emerging policies of the Amber Valley Local Plan’ which run counter to it (and coincidentally, would allow the proposed development) , or descriptions of the Policy itself as ‘outdated’ , or indeed to attempts by the applicant to redefine the setting of Kedleston Hall Registered Park and Garden itself, based on their more ‘up to date and robust assessment’ . A similar situation exists in relation to the Kedleston Conservation Area. This is covered by Amber Valley Policy EN27 which states: “Planning permission will only be granted for development proposals within and adjacent to Conservation Areas…if they would contribute to the preservation or enhancement of the Conservation Area. Special consideration will also be given to proposals for development adjacent to and affecting the setting of a Conservation Area”. 10 Notwithstanding that the EDP Heritage Impact Assessment (2014) accepts that ‘the proposed development will impact upon the setting of Kedleston RPG – and by implication the contiguous conservation area…’ , it unsurprisingly concludes that the impact this will have on the setting of both these areas is ‘minor’ and indeed, that mitigation proposals will actually enhance their setting through the upgrading of street lighting along the Kedleston Road, at Woodlands School, Allestree and at Kedleston Golf Club . This is conveniently in accord with the requirements of Policy EN27, as outlined above, although it is difficult to see, given the degree and extent of light pollution currently emanating from Derby city as a whole, how such grandiose promises might actually be realised. It is not our intention at this time to produce a detailed critique or rebuttal of the many inaccuracies and misunderstandings contained in the original Heritage Setting Assessment or to produce a similarly itemised response to its successor, apart from our reply to the latter’s erroneous criticisms of our previous letter, as we have done. We end by repeating our previous contentions, that: 1. The proposed development would adversely affect the setting of both the Grade I Registered Park and Garden at Kedleston Hall, as well as a number of Grade I, Grade II* and Grade II Listed buildings within it. 2. It would similarly adversely affect the setting of the Kedleston Conservation Area. 3. It is contrary to policies within Amber Valley’s existing Local Plan. 4. It fails the test of sustainability enshrined in the NPPF. 5. Finally, that the understandable need for housing provision within the city of Derby and the Borough, does not over-ride the obligation to protect the heritage assets at Kedleston Hall as outlined above, including its defined setting. Yours sincerely Jonathan Lovie Principal Conservation Officer and Policy Advisor The Garden History Society Powderham Devon E14/1287 II* PLANNING CGT WRITTEN RESPONSE 20.01.2015 Castle APPLICATION Request Thank you for consulting The Garden History Society and the Devon for a screening and Gardens Trust on the above request for a screening opinion on a scoping opinion for Exe proposal which would affect Powderham Castle, an historic designed Estuary Compensatory landscape of exceptional interest, which is included by English Habitat Scheme. Heritage on the Register of Parks and Gardens of Special Historic MISCELLANEOUS Interest at Grade II*. 11 The Devon Gardens Trust, formed in 1987, has considerable knowledge, expertise and experience of developments affecting historic designed landscapes. One of its roles is to help safeguard the heritage of historic landscapes within the County of Devon by advising local planning authorities on statutory and non-statutory parks, gardens and designed landscapes of importance. We have visited Powderham on several occasions previously, but not in response to the above request. We have studied the documents on your web site and ask you consider the following comments: The National Planning Policy Framework states a presumption in favour of sustainable development in both plan making and decision making, but recognises that there is a need to balance any adverse impacts against the benefits. The NPPF sets out 12 core planning principles that should underpin both plan making and decision making. Principle 10 states that planning should “conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations.” NPPF para 126 states that ‘heritage assets are an irreplaceable resource …. and conserve them in a manner appropriate to their significance.’ It reiterates the previous advice of PPS5 that LPAs, in determining applications, should require the applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The significance of Powderham Castle is as a grade I listed building set in a designed historic landscape comprising a deer park landscaped in the mid and late C18, early C19 pleasure ground & picturesque improvements and mid C19 formal terraced gardens designed by Charles Fowler. Powderham has wide panoramic views towards Topsham and the Exe Estuary; these are historically important vistas from the designed landscape. We do not have the opportunity or the time to visit the site within the timescale, but would advise that the proposal has the potential to have a significant impact on the historic designed landscape of this grade II* Registered park. The proposal also lies within an Area of Great Landscape Value and within the Exe Estuary & Farmlands Landscape Character Area. It is therefore important that the proposal enhances the character or quality of the AGLV and would not represent an adverse impact. The Devon Gardens Trust works in partnership with The Garden History Society in responding to consultations and advises that 12 development which adversely impacts upon the historic environment should not be permitted. In our opinion, the proposal has the potential to cause harm to the significance of Powderham Castle and its setting. For this reason, the Devon Gardens Trust suggest that the applicant should be required to submit an Environmental Impact Assessment and a fully detailed Visual Impact Assessment of the proposed development and its effect on the landscape as part of any planning application. We would be be pleased to visit the site and discuss the proposed works with your officers and the applicant after the 23 February 2015 Yours faithfully John Clark Conservation Officer Civic Square Devon E14/1316 II PLANNING CGT WRITTEN RESPONSE 23.01.2015 Plymouth APPLICATION Thank you for consulting the Garden History Society on the above SEPARATION OF THE application which affects the Civic Centre, an historic designed CIVIC CENTRE FROM landscape included by English Heritage on the Register of Parks and THE COUNCIL HOUSE, Gardens of Special Historic Interest at grade II. REFURBISHMENT OF The Devon Gardens Trust works in partnership with The Garden THE LOWER GROUND History Society in responding to consultations. We have visited the FLOOR OF THE site previously and consider that the proposed development would COUNCIL HOUSE TO not have a significant impact on the Registered FORM A NEW CCTV landscape. CONTROL ROOM AND Yours faithfully TRENCHING WORK John Clark BETWEEN THE Conservation Officer COUNCIL HOUSE AND PLYMOUTH GUILDHALL. CIVIC CENTRE, ARMADA WAY, PLYMOUTH, PL1 2AA. MISCELLANEOUS Greenway Devon E14/1275 II PLANNING CGT WRITTEN RESPONSE 23.01.2015 Sharpham II* APPLICATION Erection of Sandridge Park N wind turbine (50kw) with Thank you for consulting The Garden History Society on the above Wadderton Court N 24.6 metre hub height, planning application which would appear to affect Sharpham, and 34.2 metre tip height. possibly Greenway, Sandridge and Waddeton Court. Field at SX 2839 5364, The Devon Gardens Trust acts for The Garden History Society in Capton, Dartmouth. WIND responding to consultations on planning applications. The Devon Gardens Trust, formed in 1987, has considerable knowledge, expertise and experience of developments affecting historic 13 designed landscapes. One of its roles is to help safeguard the heritage of historic landscapes within the County of Devon by advising local planning authorities on statutory and non-statutory parks, gardens and designed landscapes of importance. We have studied the documents on your web site and ask you consider the following comments: The proposed 112ft high wind turbine at Capton would be in an Area of Great Landscape Value adjoining an Area of Outstanding Natural Beauty. Wind turbines are often seen from many view points across the wider landscape of Devon and can be highly visible alien features which would have a seriously detrimental visual effect. It seems inconceivable that the applicant should consider that a 112ft high wind turbine would be acceptable in this outstanding landscape. The wind turbine would be visible from the carriage drive to Sharpham House, an historic designed landscape of exceptional interest, which is included by English Heritage on the Register of Parks and Gardens of Special Historic Interest at grade II*. The proposed wind turbine may also affect Greenway, an historic designed landscape of exceptional interest, which is included by English Heritage on the Register of Parks and Gardens of Special Historic Interest at grade II. It may also affect the heritage assets of Sandridge Park and Waddeton Court, both of which are historic designed landscapes on the Devon Gazetteer of Parks and Gardens of Local Historic Interest. The Devon Gazetteer can be accessed at http://www.devongardenstrust.org.uk/?q=devon-gazetteer The National Planning Policy Framework states a presumption in favour of sustainable development in both plan making and decision making, but recognises that there is a need to balance any adverse impacts against the benefits. The NPPF sets out 12 core planning principles that should underpin both plan making and decision making. Principle 10 states that planning should “conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations.” NPPF para 126 states that ’heritage assets are an irreplaceable resource …. and conserve them in a manner appropriate to their significance.’ In pare 128 the NPPF reiterates the previous advice of PPS5 that 14 LPAs, in determining applications, should require the applicant to describe the significance of any heritage assets affected, including any contribution made by their setting.’ Country estates such as Sharpham, Greenway, Sandridge and Waddeton Court are set in parkland landscapes designed to enhance their presence. The carriage drives were aligned to provide visual interest, drama and sometimes surprise, on the approach to the principal building. The C18 parkland at Sharpham is attributed to Capability Brown, who was adept at creating views and vistas, including lines-of-sight to more distant heritage assets or natural features beyond the boundary of the estate. The view of the 120ft wind turbine would seriously detract from the significance of Sharpham. The Supporting Planning Statement makes no reference to the impact of the proposed 112ft high wind turbine on the setting of the designed historic landscapes of Sharpham, Greenway, Sandridge and Waddeton Court. We consider this to be a serious omission. In the absence of an assessment of significance and potential impact on these heritage assets we would suggest that the application has failed to comply with para 128 of the NPPF. Whilst the The Garden History Society and the Devon Gardens Trust support the principle of renewable energy, we have to consider the impact of such development on historic landscapes. Historic landscapes are a limited resource. In our opinion, the siting of wind turbines or solar arrays in or near Historic Parks and Gardens should, wherever possible, be avoided because of the effect on the character and appearance of these extremely important heritage assets. The Devon Gardens Trust, together with The Garden History Society, advise that development which adversely impacts upon the historic environment should not be permitted. In conclusion, we are concerned about the possible adverse visual impact of the proposed wind turbine on the heritage asset of Sharpham, and possibly Greenway, Sandridge and Waddeton Court . We recommend that your authority should refuse consent for this proposal as it clearly conflicts with national planning policy with regard to the conservation of the historic environment. Yours faithfully, John Clark Conservation Officer Lindridge Devon E14/1305 II PLANNING CGT WRITTEN RESPONSE 15.01.2015 APPLICATION Installation Thank you for consulting The Garden History Society and the Devon Of Ground Mounted Solar Gardens Trust on the above which affects Lindridge, an historic 15 Array (Area Of Solar Pv designed landscape of National importance included by English Array 175,600 M2), Heritage on the Register of Parks and Gardens of Special Estimated Output Of 5650 Historic Interest at grade II. Megawatts-Hour (Mw), The Devon Gardens Trust acts for The Garden History Society in And Associated responding to consultations on planning applications. The Devon Infrastructure Including Gardens Trust, formed in 1987, has considerable knowledge, Track/Buildings. Land At expertise and experience of developments affecting historic designed Higher Humber Farm, landscapes. One of its roles is to help safeguard the heritage of Bishopsteignton SOLAR historic landscapes within the County of Devon by advising local planning authorities on statutory and non-statutory parks, gardens and designed landscapes of importance. We have studied the documents on your web site and ask you consider the following comments: The National Planning Policy Framework states a presumption in favour of sustainable development in both plan making and decision making, but recognises that there is a need to balance any adverse impacts against the benefits. The NPPF sets out 12 core planning principles that should underpin both plan making and decision making. Principle 10 states that planning should “conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations.” NPPF para 126 states that ’heritage assets are an irreplaceable resource …. and conserve them in a manner appropriate to their significance.’ In pare 128 the NPPF reiterates the previous advice of PPS5 that LPAs, in determining applications, should require the applicant to describe the significance of any heritage assets affected, including any contribution made by their setting.’ The heritage asset of Lindridge comprises the grade II Registered landscape, the water tower, the gateway including gates, and lodge, all listed at grade II. The English Heritage Register of Parks and Gardens is a highly selective designation comprising some 1,600 sites, of which there are only 54 in Devon, identified as designed landscapes of special historic interest in the National context. The Design & Access Statement states: In terms of impacts on the adjacent RPG, the DBA concludes that: “Given the close proximity of the Registered Park and Garden to the application area it is considered that the proposed development will potentially have a minor impact upon the wider landscape setting of the park, and a minor impact upon its significance”. and goes on to 16 make a series of comments about the impact of the solar array on views from the historic designed landscape and some proposals for mitigation. and concludes ‘In terms of the NPPF, it is considered that, for the reasons above, there will be less than substantial harm to the significance of the RPG, and this minor harm is outweighed by the public benefits of the Proposals’ We cannot agree with the applicants conclusion or the assessment of the impact of the proposed solar array on the heritage asset of Lindridge. Rather than to go into detail at this stage, we would suggest that the best way forward would be to meet with your officers and the applicant’s advisers on site to discuss these issues after the 19 February 2015, so we could properly assess the impact and the effectiveness, or otherwise, of the proposed mitigation. Whilst the The Garden History Society and the Devon Gardens Trust support the principle of renewable energy, we have to consider the impact of such development on historic landscapes. Historic landscapes are a limited resource and any proposal for a solar array scheme should pay due regard to its potential impact on the historic designed landscape. In our opinion, the siting of solar arrays in or near Historic Parks and Gardens should, wherever possible, be avoided because of the effect on the character and appearance of these extremely important heritage assets. The Devon Gardens Trust, together with The Garden History Society, advise that development which adversely impacts upon the historic environment should not be permitted. In conclusion, we are concerned about the adverse visual impact of the solar array which would cause substantial harm to, rather than a minor impact on, the significance of the heritage assets of Lindridge and its setting. We recommend that your authority should refuse consent for this proposal as it clearly conflicts with national planning policy with regard to the conservation of the historic environment. Yours faithfully, John Clark Conservation Officer Greenway Devon E14/1313 II PLANNING CGT WRITTEN RESPONSE 10.02.2015 Lupton Park II* APPLICATION Erection Thank you for consulting The Garden History Society on the above and operation of 1no. planning application which is in an Area of Great Landscape Value, is wind turbine (with in close proximity to the South Devon Area of Outstanding Natural estimated output of 0.225 Beauty and affects the South Devon Heritage Coast and the South megawatts) 30.52m hub West Coastal Footpath. height, 45.07m tip height The proposed 148ft wind turbine might possibly affect the setting of 17 and associated. Proposed the Britannia Royal Naval College, Greenway, Lupton Park, Sandridge wind turbine at SX 8565 and Widdecombe House. 5259, Downton Park The Devon Gardens Trust works in partnership with The Garden Farm, Dittisham TQ6 0JD. History Society in responding to consultations. The Devon Gardens WIND Trust, formed in 1987, is one of the earliest county gardens trusts to have been established. One of the roles of the Trust is to help safeguard the landscape heritage of the County of Devon. We have studied the documents on your web site and ask you consider the following comments: Greenway and Lupton Park are historic designed landscapes included by English Heritage on the Register of Parks and Gardens of Special Historic Interest at grade II and grade II*, respectively. The Britannia Royal Naval College, Sandridge and Widdecombe House are historic designed landscapes on the Devon Gazetteer of Parks and Gardens of Local Historic Interest but are also recognised by English Heritage as sites of National importance which should be included on the EH Register. Whilst the The Garden History Society and the Devon Gardens Trust support the principle of renewable energy, we have to consider the impact of such development on the heritage landscape of Devon. The South Devon AONB,the AGLV, the Heritage Coast and historic designed landscapes are a limited resource. In our opinion, the siting of wind turbines and solar arrays should, wherever possible, be avoided in these landscapes because of the harmful effect on their character and appearance. The Landscape and Visual Impact Assessment 6.4 states that ‘it does not predict any significant effects on the intrinsic quality …on the South Devon AONB…..’ This statement is misleading as the proposed 148ft high wind turbine would be seen from many viewpoints across the wider landscape of the South Hams. The full cumulative impact of this and other approved and pending wind turbines and solar arrays in the AGLV and AONB is of considerable concern. Wind turbines can be highly visible alien features which can have a seriously detrimental visual effect, individually and cumulatively. It seems inconceivable that the applicant should consider that a 148ft high wind turbine would be acceptable in the outstanding landscape of the South Hams. In conclusion, the Devon Gardens Trust are concerned about the adverse visual impact of the proposed wind turbine on the highly sensitive landscape. The proposed turbine would, by reason of its large scale and prominent siting, result in significant harm to the landscape character of the South Hams. We strongly recommend 18 that your authority refuse consent for this proposal. Yours faithfully John Clark Conservation Officer Courtlands Devon E14/1347 N PLANNING CGT WRITTEN RESPONSE 27.02.2015 House APPLICATION Courtlands is an historic designed landscape included on the Devon Renovation, restoration Gazetteer of Parks and Gardens of Local Historic Interest. and extension of We have visited the site and studied the planning application Courtlands House estate documents on your website and we consider that it is a well thought from a wedding venue out scheme which the Devon Gardens Trust are happy to support. into a 21 bedroom luxury Attached is the entry for Courtlands on the Devon Gazetteer of Parks country house hotel and and Gardens of Local Historic Interest and an extract from the fine dining restaurant. Journal of the Devon Gardens Trust ' A stroll in the eighteenth Including refuse and century around a ladies walk’ by Helen Whitmore. maintenance store, staff The Devon Gardens Trust would be pleased to advise on the historic accommodation and landscape, but would suggest that the best way forward would be for kitchen facilities, Michael Caines to seek the advice of a landscape architect landscaping of private specialising in historic designed landscapes to advise on the gardens and parkland preparation of a Landscape Strategy and Management Plan for the including a nature trail, whole site in order to give clear guidance and priorities landscape tennis court and croquet improvements. lawn and access to the Yours faithfully Exe Estuary cycle way. John Clark Courtlands House, Courtlands Lane, Exmouth EX8 3NZ. HOTEL/HOSPITALITY Waterston Manor Dorset E14/1309 II PLANNING CGT WRITTEN RESPONSE 16.01.2015 APPLICATION Erection of The Dorset Gardens Trust has been notified of this application by the six wind turbines and Garden History Society [GHS], which is a statutory consultee for the construction of associated application. As you will be aware, the statutory function of the GHS infrastructure. (Full). has been passed nationally to county Gardens Trusts, and this letter LAND ADJACENT can therefore be taken as the formal response. SLYERS LANE, It can be said at the outset what this letter does not deal with. It WATERSTON. WIND does not consider the issue of the impact of the proposal on the AONB or the wider landscape. It does not deal with heritage assets other than parks and gardens, other then where their consideration indirectly relates to listed buildings. Also, it does not make any comment on the quality of the EIA submitted, and whether it follows accepted guidelines. This proposal will have the result of affecting a number of parks and gardens that are registered by English Heritage, and also some that 19 are identified by the Trust as being of local interest. Local interest sites were published by the Trust in 2014, and discussions are underway to have these sites added into the County Historic Environmental Record. The planning submission identifies the issues of relevance in the Planning Statement. The Trust notes the acceptance of the relevance of s.66 of the 1990 Act, and also the impact of policies SA16 and SA17. Vol2 of the EIA also appears to be comprehensive. The issue is therefore whether the assessments that have been carried out are correct or wide-ranging enough. It is noted that the Statement states ‘cultural heritage assets pervade the English countryside and this location is no different with a number of assets existing within the immediate and wider landscape’, which is fine provided that this comment is not then used to minimise the importance of such assets. THE ISSUE OF BALANCE Some comment is needed in relation to the question of balance. The Planning Statement suggests that the requirements of the 1990 Act (in this case, ss 72 and 66) are capable of being overturned if wider benefits of a proposal can be seen to be more important. The Forge Field case is cited as setting out this argument. While that may be true for Forge Field, more recent decisions, particularly where the Secretary of State has taken the decision for himself, suggest that the legal requirement to safeguard an asset as set out in the 1990 Act is not to be overturned lightly. Recent SoS appeal decisions help to show the clear distinction to be made between the level of harm to a heritage asset and the weight to be given to that harm. It may be concluded that only minor – or less than substantial - harm is assessed, but that does not mean that it will have no importance. Decisions show that considerable importance can be attached to a less than substantial harm: it depends on the precise circumstances, and no generalised conclusion can be made. It follows that decision-making is not just to be made on the basis of the arguments on balance set out in NPPF. There are three parts to the Trust’s evaluation of parks and gardens - a) those EH-registered gardens identified in the EIA; b) those EH-registered sites not assessed in the EIA, and c) DGT Local List sites not assessed in the EIA. Each is dealt with in turn. EH-REGISTERED GARDENS IDENTIFIED IN THE EIA These are Kingston Maurward II* and Dorchester Town Walks II, and they are considered at 3.2.10 of the EIA Vol2. In both cases, the test is whether there is ‘adverse’ effect on the asset from the 20 development, tempered by the NPPF which introduces the issue of balance. The assessment concludes that, although the adverse effect on both sites will be minor, this would be sufficient for the proposal to be in conflict with Policy SA16, but this this has to be tempered by the balancing statements within the NPPF. The Trust agrees that the impact of the development on Dorchester Town Walks would be minor because of the urban nature of the Walks, and the considerable filtering of the turbine masts from them and from Salisbury Field. At Kingston Maurward however (1.1km from the nearest turbine) the impact is considered to be greater, as the turbines would be visible from the entire park except where screened by the house itself. It should be remembered that the registered park extends well north of the formal gardens at the house, extending as far as the Higher Kingston Farm turning. The impact here is considered to be substantial. Kingston Maurward is considered worthy of detailed assessment due to the impact of the proposal at pp253-7 in the EIA Vol2. An adverse effect of slight magnitude to both House and garden is concluded, enough for planning policy and the NPPF not to be met. However, this is set aside by the applicants due to be issue of balance in the NPPF, and also the fact that the development is judged ‘temporary’. However, it cannot be the case that a significant effect such as that accepted here can be set aside in this way. Planning Policy Guidance, at the section on Core Planning Principles (paragraph 17 b/pt 8 ) states that “heritage assets [must be conserved] in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations”. It is not acceptable to set this aside in the manner proposed purely on the grounds of a 20-year+ temporary development. This is not temporary – it is a generation. EH-REGISTERED GARDENS NOT ASSESSED IN THE EIA The Trust has a concern regarding two EH-registered sites: Athelhampton and Waterston. Both gardens are registered II. Waterston is one of the closest registered gardens to the application site. The site is asessed as having no impact from the development, which is surprising given the short distance. While the landform to an extent reduces this impact, the Trust believes that there will be an effect from the tops of turbines, and any screening that derives from trees will only be seasonal as the cover is very largely deciduous. Athelhampton is further away, but the same arguments apply. The Trust believes that there will be minor impact from turbine blades across Troy Hill. 21 DGT LOCAL LIST SITES NOT ASSESSED IN THE EIA There are a number of sites within the area of search for this application that are not registered by EH, but which are on the Local List of sites assessed by the DGT. These are not yet incorporated into the County HER, but they are known to the District Council, and they are covered by Policy SA17. The Trust was not consulted on any site prior to submission, and it is not believed that the GHS was either. These sites are Came House, Little Court, Stinsford House, Stafford House and Wolfeton House. Came House, Stafford House and Wolfeton House are also listed buildings grade I: Stinsford House and associated structures, and Little Court, are listed grade II. Other than Stafford House and Little Court, these are assessed as listed buildings at pp233/234 of EIA Vol2: it is assessed by the applicants that there will only be some impact due to visibility of blade tips, which may be seasonally filtered, and it is probable that the same conclusion applies to the garden in each case. Stafford House lies about 1.5kms south-east of Kingston Maurward House in an almost direct line from the development. Lying in the Frome valley, the turbines will be visible from this listed grade I house, and hence also from its garden which was designed initially by Repton, who created a Red Book for it. Although the distance between house and turbines is about 3.5kms, the effect will be substantial. Little Court lies on the east side of Charminster, and lies on the plateau running eastwards on which the turbines will be located. This property is one of the closest to the development, and with its locally listed garden will be affected by the development perhaps more than any other. The effect on this property will be substantial, and there will be no mitigation. In conclusion, there are a multiplicity of issues and sites which are likely to be affected. Then EIA has generally considered many of these, and overall concludes that the effects will be minor. There is only one site where a more major impact is assessed, which is Kingston Maurward, in relation to the House. There are other sites which the Trust believes will also experience a major impact. These are Little Court and Stafford House, where house and garden can be considered as distinct elements of an important entity. The Trust concludes that – a) the large number of sites assessed where only minor impact is suggested indicates that harm – albeit possibly minor - will be felt over a very wide area. To return to the quote from the submission noted at the start of this letter – “cultural heritage assets pervade 22 the English countryside and this location is no different with a number of assets existing within the immediate and wider landscape” – it can be concluded that this high number of sites of importance suggests that this is not an acceptable site for a wind-farm development due to this all-pervading low-level impact. b) It will always be possible for any developer to argue that the public benefit of a proposal will overcome all other objections. That is a question of balance for the decision-maker: from what is said in (a) above, it can be concluded that in this case it does not. c) It is clear that the major impact will fall on Kingston Maurward grade I and its park grade II*. It is only by arguing for the greater public benefit and the fact that the proposal is ‘temporary’ that the applicants can argue for its acceptance, but this contrary to guidance in the PPG. Without these arguments, the application fails on policy grounds. d) The fact that a development of this magnitude will be taken down in possibly 20 years is not a justification for it when such a magnitude of low-level harm will be the result. In any event, there is nothing to prevent a developer asking for re-powering at the end of this period, and no legal agreement entered into will prevent this being sought. It will always be difficult for a planning authority (or the Secretary of State) to resist such an application in say 2035. The Trust notes the argument by the applicants that the NPPF is more recent than the Local Plan, and therefore has greater weight. In the same way, the NPPF introduces the concept of ‘heritage assets’, which could in the same way be regarded as providing a re- interpretation of the wording of the 1990 Act, so that ‘listed buildings’ as a concept can be widened to refer to all ‘heritage assets’. In that way, the provisions of the 1990 Act can be held to apply to registered and locally listed parks and gardens as well. In any event, gardens (whether EH-registered or locally listed) must form part of the setting of a listed building and should be considered as such. The Dorset Gardens Trust therefore asks that this application be refused. Will you please advise us of any amendments to the submission, and if there are none, of the decision. Yours faithfully, C Clarke for the Dorset Gardens Trust Toddington Gloucester- E14/1268 II PLANNING CGT WRITTEN RESPONSE 25.01.2015 Manor shire APPLICATION Erection of The Gloucestershire Garden and Landscape Trust (GGLT) has been 23 a single storey portal notified by the Garden History Society - the Statutory Consultee for frame building for use as development that impacts on Listed Parks and Gardens, that a a Waste Treatment and Planning Application has been made at the Old Sawmill , Toddington Transfer facility within an for the proposed erection of a portal framed industrial building for existing processing waste. industrial/commercial site The Sawmill, whilst within the boundary of the Registered Parkland used for waste associated with Toddington Manor, has been a site that has had the management. The Old benefit of industrial use for some 50 years forming an intrusion into Saw Mill Site, Evesham what had been the Ladies Walk. The relict planting of this feature Road, Toddington, largely screens the Sawmill site from the main area of the parkland, Cheltenham, which in itself one must admit has been quite seriously neglected and Gloucestershire, GL54 degraded by inappropriate management over many decades. 5DF. MISCELLANEOUS Immediately north of the Application site there has been a recent approval for a liquid waste facility that is now complete. Within this context therefore, GGLT would not wish to raise an objection to the principle of siting a portal framed industrial building in this broad location. However, as very much a matter of detail, the southern site boundary screening is very patchy volunteer trees and shrubs. By siting the building close up to that boundary, it will mean that any potential screening most likely will be destroyed during its construction, It is suggested that the building might be moved about 5.000m into the site and some new planting used to reinforce the boundary. Finally, the drawings do not appear to be explicit on the precise colours of the roof sheeting, sidings, brickwork type and door colours. Detail I know, but quite important in bedding a building of this size into the wider landscape. Yours sincerely, David Ball. ( on behalf of Gloucestershire Garden and Landscape Trust ) Toddington Gloucester- E14/1268 II PLANNING CGT WRITTEN RESPONSE 25.01.2015 Manor shire APPLICATION Erection of The Gloucestershire Garden and Landscape Trust (GGLT) has been a single storey portal notified by the Garden History Society - the Statutory Consultee for frame building for use as development that impacts on Listed Parks and Gardens, that a a Waste Treatment and Planning Application has been made at the Old Sawmill , Toddington Transfer facility within an for the proposed erection of a portal framed industrial building for existing processing waste. industrial/commercial site The Sawmill, whilst within the boundary of the Registered Parkland used for waste associated with Toddington Manor, has been a site that has had the management. The Old benefit of industrial use for some 50 years forming an intrusion into Saw Mill Site, Evesham what had been the Ladies Walk. The relict planting of this feature Road, Toddington, largely screens the Sawmill site from the main area of the parkland, Cheltenham, which in itself one must admit has been quite seriously neglected and 24 Gloucestershire, GL54 degraded by inappropriate management over many decades. 5DF. MISCELLANEOUS Immediately north of the Application site there has been a recent approval for a liquid waste facility that is now complete. Within this context therefore, GGLT would not wish to raise an objection to the principle of siting a portal framed industrial building in this broad location. However, as very much a matter of detail, the southern site boundary screening is very patchy volunteer trees and shrubs. By siting the building close up to that boundary, it will mean that any potential screening most likely will be destroyed during its construction, It is suggested that the building might be moved about 5.000m into the site and some new planting used to reinforce the boundary. Finally, the drawings do not appear to be explicit on the precise colours of the roof sheeting, sidings, brickwork type and door colours. Detail I know, but quite important in bedding a building of this size into the wider landscape. Yours sincerely, David Ball. ( on behalf of Gloucestershire Garden and Landscape Trust ) Toddington Gloucester- E14/1394 II PLANNING CGT WRITTEN RESPONSE 09.02.2015 Manor shire APPLICATION 2 storey The Garden History Society, as Statutory Consultee for planning extension of the existing proposals that have an impact on Listed Parks and Gardens, has dwelling to provide notified the Gloucestershire Gardens and Landscape Trust to respond additional. Camelot, Olde to this Application on its behalf. In the opinion of the Trust, this Lane, Toddington. proposed extension of a residential property, that happens to be BUILDING ALTERATION within the Scheduled Parkland associated with Toddington Manor, will have little impact on the quality and character of the Scheduled Parkland or the setting of the Manor itself. Having recently looked at another planning proposal within the Old Sawmill industrial area- again sited within the Scheduled Parkland, I would recommend that the Scheduling should be the subject of review. Originally this Manor had a very extensive garden and parkland. Over at least 60 years, the parkland has been subject to a whole raft of poor land use decisions and land management mistakes- so that in my opinion, it needs a thorough review. It was significant historically, but is it now an exemplar in physical terms: possibly not. David Ball Batterse Park Greater E14/1146 II* PLANNING CGT WRITTEN RESPONSE 16.01.2014 London APPLICATION Dear Sir or Madam Development of a I am writing as Chairman of the Planning and Conservation working temporary motor racing group of the London Paris & Gardens Trust to raise strong and circuit within the boundary fundamental objections to the proposals detailed in the above of Battersea Park for the planning application. 25 purpose of the FIA The LPGT is the county gardens trust for Greater London, and as such Formula E Championship comments on planning applications affecting parks and gardens in the on 27th and 28th June capital included in the English Heritage Register. The Garden History 2015. Society remains the statutory consultee, but the GHS and the Development will also Association of Gardens Trusts are in the process of formal comprise of civil works to amalgamation and most responses to planning notifications are now access roads within the made by the relevant county trust rather than by the GHS, which park, the installation of because of reduced funding and resources generally confines its temporary infrastructure observations to proposals and policies of national significance. including safety barriers The proposal to hold motor race meetings at Battersea Park has been and fencing and provision considered by the Planning and Conservation working group of the of temporary LPGT and is considered unacceptable and damaging to the registered structures associated with historic park and to the conservation area. the Event operations, Battersea Park is one of the oldest public parks in the country, hospitality, broadcast and created specifically as an amenity freely accessible at all reasonable technical systems. hours to the general public, and is included at grade II* in the EH Event set-up to begin on Register. It is described at length in the Register, and as a very early 15th June 2015 with example of the public park features significantly in "The Park and the dismantling and Town", a pioneering and authoritative study of urban parks written by reinstatement to be George F Chadwick and published in 1966 by the Architectural Press. complete by Battersea Park was restored with the aid of Heritage Lottery Funding 3rd July 2015. Battersea a decade ago, and I consider that your Council should consult the HLF Park, Albert Bridge Road and examine whether the current proposals are considered SW11. compatible with any agreements and undertakings made at the time MISCELLANEOUS of the grant aid. Our objections may be summarised as follows: 1. Exclusion of the general public from all or substantial parts of the public park on race days and for setting up and demounting the barriers, signs, grandstands and other temporary structures. 2. Damage to trees through removal or tree surgery or root compaction. 3. Damage to other planting, especially through the erection of grandstands. 4. Damage to drainage and infrastructure of the park. 5. Increased likelihood of vandalism and damage to trees, other planting and historic structures as a consequence of greatly increased and concentrated numbers of spectators. The park was created for the quiet enjoyment of all users, with any sporting uses kept low-key and unobtrusive. The current proposals are wholly incompatible with the primary and intended purpose of the public park as well as being damaging to its physical and its historic character, and we urge your council to REFUSE the planning 26 application. Yours faithfully Chris Sumner Chairman of Planning & Conservation Working Group London Parks & Gardens Trust Brompton Greater E14/1349 I GENERAL CGT WRITTEN RESPONSE 25.01.2015 Cemetery London CORRESPONDENCE I have recently visited Brompton Cemetery with colleagues from the Brompton Cemetery London Parks and Gardens Trust, and we inspected the proposed Conservation Project: building and landscaping works. Redevelopment of the I am pleased to report that we consider the proposals acceptable and North Lodge with sympathetic to the most important registered cemetery (one of the information centre, shop, so-called "Magnificent Seven") and to the equally important listed WCs and cafe buildings and monuments that are integral to it and contribute to its Restoration of the Chapel, historic significance. Central Colonnades and We consider the proposals acceptable in principle, subject to detail, Catacombs Conservation and wish you well with your bid for funding to restore and consolidate of historic landscape, the cemetery and its buildings for the benefit of users and visitors. buildings and monuments With best regards Wildlife conservation to Chris Sumner maintain and improve Chairman, Planning and Conservation Working Group London Parks & existing habitats Gardens Trust Community engagement and access improvements Volunteers helping to conserve and interpret the cemetery Financial sustainability with enhanced visitor facilities and funerary business https://www.royalparks.or g.uk/parks/brompton- cemetery/brompton- cemetery-conservation- project BromptonProject@royalp arks.gsi.gov.uk CEMETERY St Paul's Walden Hertfordshire E14/1264 I PLANNING CGT WRITTEN RESPONSE 23.01.2015 Bury APPLICATION Form new Thank you for consulting the GHS and HGT on this planning ground floor window in application. We are aware that the Garden House lies within the area east elevation. Garden covered by the St Pauls Walden Bury Grade I Registered landscape House, St Pauls Walden, and would affect a Grade II listed wall. 27 Hitchin, SG4 8BP. However, we consider that the addition of a window, of the design BUILDING ALTERATION and position in the application, would not adversely affect the landscape and the significance of it . We therefore have no objections to the proposed changes as detailed in the application. Kind Regards Kate Harwood Conservation & Planning Hertfordshire Gardens Trust Knebworth Hertfordshire E14/1267 II* PLANNING CGT WRITTEN RESPONSE 28.01.2015 APPLICATION Thank you for consulting the GHS and HGT on this proposal. We note Replacement rear that this site is within the Grade II* Knebworth Park Registered site conservatory. Park and within Old Knebworth Conservation Area. There are important Springs, Park Lane, Old views across the park towards the line of Jubilee Avenue running Knebworth, Knebworth, down from the war memorial. We have not seen any Heritage SG3 6QD Statement with this application and do not know whether the impact REPAIR/RESTORATION from glare of the increased amount of glass has been considered. We would suggest that this be addressed and if mitigation is necessary then suitable provision be made as a condition of granting permission Kate Harwood Conservation & Planning Hertfordshire Gardens Trust North Hertfordshire E14/1204 LOCAL PLAN Public CGT WRITTEN RESPONSE 02.02.2015 Hertfordshire consultation the Local Thank you for consulting the Garden History Society and the Local Plan Plan Preferred Options Hertfordshire Gardens Trust on this proposed plan. 2011 – 203 We have the following comments: 1. HGT would welcome working with NHDC to identify non-designated historic parks and gardens as in para 10.10. HGT has already done much research on the NHDC area sites. 2. There is 1 historic park, Chesfield Park, whose setting and therefore significance would be harmed by proposed housing development at NS1 (North of Stevenage) and GA 1 (Great Ashby) 3. There is 1 historic allotment/smallholding site in Letchworth, LG6 (Land off Radburn Way) allocated for housing. Although only part of this area is currently allotments (which will remain), the other section is shown on the 1912 Letchworth map (and others) as smallholdings and thus part of the original design intent of Barry & Unwin, reflecting the self-sufficency vision of Ebenezer Howard. We are aware of a proposal to develop an orchard there using grafts from historic fruit trees being uprooted in the Gaping Lane Allotments at Hitchin (the only remaining urban detached gardens in Hertfordshire - formerly Park Piece Gardens formed from the medieval deer park- which are now being destroyed). This would seem an entirely 28 appropriate use of this land. We therefore object to the inclusion of NS1,GA1 and LG6 as causing harm to an undesignated heritage asset or its significance, and therefore contrary to NPPF which states (para 132) 'as heritage assets are irreplaceable, any harm or loss should require clear and convincing justification'. We have seen no convincing justification for inclusion of these particular sites in the Plan proposals. Kate Harwood Conservation & Planning Hertfordshire Gardens Trust Clifton Hall Lancashire E14/1171 N PLANNING CGT WRITTEN RESPONSE 23.01.2015 APPLICATION Thank you for your consultation notice to Garden History Society VARIATION OF (GHS) inviting comments on the above application(s) in connection CONDITION 2 ON with development within the setting of Clifton Hall. The Lancashire PLANNING PERMISSION Gardens Trust (LGT) responds on behalf of the GHS 12/0517 AND LISTED which devolves its cases to the regions. BUILDING CONSENT We have reviewed the application documentation, however no site 12/0518 IN ORDER TO visit has been undertaken. Based on the submitted plans and SUBSTITUTE THE documents, the LGT has a number of concerns as the proposals APPROVED SITE PLAN impact upon the garden and the setting of Grade II listed Clifton Hall. LAYOUT AND TO As noted in our response to the 2012 application, the LGT potentially REMOVE ALL FLOOR welcomes the principle of expansion, enhancement and significant PLANS AND investment in the gardens of Clifton Hall, but there are concerns in ELEVATIONAL PLANS the manner of the approach to the proposals, the lack of RELATING TO THE investigations into the garden archaeology, and the absence of APPROVED GARAGE some important details of the specific intended works as well as an AND SWIMMING POOL absence of explanation of the impact on the listed Hall, the curtilage BUILDING. CLIFTON listed buildings and its setting. HALL, LODGE LANE, Clifton Hall and its Grounds NEWTON WITH Clifton Hall is a site of some significance, the core of which is formed CLIFTON, PRESTON, by the Grade II listed principal house, formal gardens, domestic PR4 0YA. BUILDING offices, entrance lodge and ancillary buildings which include dog ALTERATION kennels (which it is assumed are still extant), although these latter now have permission for demolition. It is recalled that in 2012 the consultation response by English Heritage stated that the dog kennels in particular were recognised as having specific value and rarity interest. Although the Clifton Hall gardens do not have any formal designation by English Heritage, they are identified as Category B (potentially Regional/County significance) in A Local List of Lancashire’s Unregistered Historic Designed Landscapes (2013). In 2010, as part of the research for the above the LGT undertook a validation exercise 29 for Clifton Hall garden which did not include a detailed site inspection. This work identified Clifton family connections with the Veitch Nursery (Exeter and London) through plant and seed purchases made by Thomas Clifton, and family connections between estate staff and those at the nursery. Further research was recommended by the validation including site visits. A more complete evaluation of the significance of Clifton Hall garden would be envisaged by the LGT at a future date but this will not to be available for the present application. It is noted that the current 2014 applications are in respect of a partial subterranean annexe which is intended to supercede the earlier permission for pool, gym and garaging within the proposed gardens. It is understood that the proposed garden layout for which permission was granted in 2012 is to remain in place. In relation to the 2012 application, the LGT had numerous concerns about the integration of these buildings into the proposed garden, with vehicular routes crossing through the garden features which would have appeared severed and disjointed. It is welcomed that some of these conflicts are eliminated in the current scheme. LGT Concerns Whilst the LGT supports the broad aspirations of the property owner in seeking to give an enhanced setting and gardens to Clifton Hall, the approach to the process anddocumentation in the application falls short in a number of respects. The result is that the proposals are not fully thought through and justified, and their impacts are not identified and understood.  The proposed annexe appears to be built in isolation from the Hall, with no proposed direct link between the existing residential accommodation in the Hall and the proposed leisure facilities. Furthermore there is limited outside surfaced space shown beyond the glazed frontage. In preference to a proliferation of subsequent ad hoc changes, the current application needs to deal with these issues of access and external detailing so that these are fully thought through.  The LGT notes the conservation and heritage studies which have been undertaken as part of this and the earlier applications. However, although these appear to be fairly comprehensive high level investigations of mapping and other evidence, it appears that no evaluation has been undertaken as part of the planning application on the significance of the existing gardens, either by recording existing features or through identifying more subtle 30 evidence of previous historic features. Further work is required which should include a site survey of existing hard features and garden plants which may date from earlier phases of the designed gardens. This point is a restatement of that made in relation to the 2012 application, and it is noted that the LCC archaeologist has drawn attention to these requirements in his current response.  The Arboricultural Report covers the three mature trees which surround the proposed annexe, all of which are at risk from the current proposals. Whilst protection provisions are stipulated within the recommendations which may address the long term interests of these trees, the concept of a no dig area under the canopy of the very important yew tree is unrealistic. This tree appears to be of considerable age, and could predate the current Hall, and therefore being part of the earlier arrangement of the gardens. The significance and existence of such veteran trees would be clarified through the research required above. The only satisfactory solution is to relocate the access driveway completely away from the canopy and root protection zone of this yew tree.  There is no indication given of the intentions for the disposal of excavated subsoil arising from the construction of the underground annexe. The DAS currently states that there is no landscaping intended as part of the application. Only in the improbable event that all the material is intended to be removed from site would this be the case. The presumption is that there is a risk that the material will be ‘lost’ on site potentially burying archaeological features, as well as other unintended difficulties. This matter, as well as the location of haul routes and the provision of appropriate protective measures needs clarifying and detailing in the application and drawings.  The Design and Access Statement is missing a detailed justification to the approach to the proposals, and the impact on the listed buildings. Of particular concern is the proposed new large terrace which is to cover the annexe. As these are within the immediate setting of the listed Hall, they require very sensitive consideration in terms of the concept, the detailing, materials and planting. For instance it is noted that metal railings will edge the terrace above the glazed front of the annexe. This will be a very dominant feature in the view from the main rooms of the Hall, as well as views towards the Hall from the wider landscape. The DAS provides no details of the design of the new terraces and balustrading. In addition, there is no indication of what is being swept away or covered over by the hanges to other sides of the Hall. There is no assessment of the likely 31 impacts of the proposals on the listed building and other features.  The frontage to the annexe is intended to be in timber cladding. It is suggested that a local brick to match the existing building would be more appropriate and assist in relating the new work within its overall setting. Conclusion The LGT has fundamental issues with this this application as described above. These are summarised as:  lack of survey into trees and garden plants, and garden rchaeology;  potential for damage and loss of significant trees;  no explanation of intended use of subsoil arising from the excavation;  absence of assessment of impacts of the proposals on the site archaeology, and listed buildings  limited justification for the approach to the design, and detailing of the proposed works, and intended materials The LGT recommends that this application requires further work to deal with heritage issues, on the DAS and likely amendment to the proposals resulting in a more thorough and carefully judged approach to the design. If however the Council is minded to consider the application for approval, then as a minimum, conditions will be required to prevent commencement until fully detailed proposals are approved. There has been a series of applications for work at Clifton Hall, without any overall agreed management plan. It is difficult to establish details of exactly what is approved and intended to be built in relation to the gardens from the approved 2012 application. To some extent this is due to vague layout drawings devoid of annotation where it is not clear what exactly is intended to change. The LGT recommends that the applicant is encouraged (or requested if possible) to produce an approved Conservation Management Plan for the estate at Clifton Hall as soon as practicable. In this instance, the LGT does not envisage making a request to speak at the Committee Meeting. However we would ask to be kept informed of progress of the application and included in the process of addressing the matters raised in this response. If any matter within the consultation response above requires clarification please contact me. Yours faithfully S E Robson BSc BPhil MA(LM) DipEP CMLI MRTPI Chair, Conservation & Planning Group 32 Clitheroe Castle Lancashire E14/1261 II PLANNING CGT WRITTEN RESPONSE 26.01.2015 APPLICATION Proposed Thank you for your consultation notice dated 9 January to Garden dismantling and rebuilding History Society (GHS) inviting comments on the above application in of historic pinnacle from connection with repairs to the Rose Garden Pinnacle in the Castle the Houses of Parliament Grounds. The Lancashire Gardens Trust (LGT) responds on behalf of to remove corroded the GHS which devolves its cases to the regions. We also acknowledge ferrous cramps, dowels the pre application consultation direct to the GHS and LGT from etc. with necessary stone Clitheroe Civic Society and the Conservation Architect, which allowed repairs made using the opportunity to start an earlier review of the comprehensive concealed stainless steel drawings. fixings. Pinnacle in rose We have reviewed the application documentation; however no site garden, Clitheroe Castle visit has been undertaken. Based on the submitted plans and grounds, Clitheroe. documents, the LGT supports the proposals to repair the historic REPAIR/RESTORATION pinnacle. Clitheroe Castle Park is a Registered Park and Garden Grade II, which includes a number of important listed structures notably the Grade I listed Castle keep, as well as a number of Grade II listed structures, the Stables and Outbuildings, the Old Courthouse, Castle House and the Pinnacle (Turret from the Houses of Parliament). It is recognised that the eventual scope of some important areas of the work depends on decisions to be taken once dismantling and repair has commenced. This is unavoidable, and it is assumed that the funding will permit the ultimate extent of the work to be completed. In particular the ‘apparent’ lean on the overall structure itself (Item SE9) although hopefully minor at 1° is not clarified and depends on further surveys. It is to be hoped that this is not a progressive matter caused by a below ground issue, and that this will be understood at an early stage in the works. It is noted that English Heritage has commended the approach to and proposals for the repairs. The LGT notes the comprehensive documentation provided and fully supports the project. We look forward to this project progressing through the HLF bid and leading to implementation in the current year. If any matter within the consultation response above requires clarification please contact me. Yours faithfully Stephen Robson S E Robson BSc BPhil MA(LM) DipEP CMLI MRTPI Chair, Conservation & Planning Group Woolton Manor Merseyside E14/1415 N PLANNING CGT WRITTEN RESPONSE 13.02.2015 APPLICATION To erect The Lancashire Gardens Trust (LGT) has been made aware of the new school with above proposals at Woolton Woods and Woolton Hall. We note that 33 associated ancillary the Garden History Society (GHS) was not invited to comment in this facilities and widen case, although they are now aware of the application. The existing vehicular access Lancashire Gardens Trust responds on behalf of the Garden History to Speke Road and Society which devolves its cases to the regions. demolish existing school. In this instance the LGT objects to the encroachment of the proposed St Julies Catholic High school site beyond the current north boundary, and into former School, Speke Road, parkland associated with the Hall. Liverpool L25 7TN. The LGT recognises the importance of the heritage assets at Woolton EDUCATION Hall Listed Grade I, and its setting, as well as a number of other listed lodges and important boundaries associated with the Hall, and the very significant and extensive Woolton Conservation Area. It is recognised that the site has been the subject to much development and change over the last 50 years, which has removed much of the garden setting of the Hall. However it is important that the current proposals for the redevelopment of St Julies High School must not further weaken the historic integrity of the locality. It is welcomed that the final layout gives some recognition to the setting of the Hall by locating playing fields in areas where currently school buildings are sited within a few metres of the Hall. It is noted that a comprehensive consultation process took place during September 2014 at which a number of options for complete relocation of the School were considered and finally modified to leave a more modest intrusion into the public open space to the north of the current school site, with a net loss of public open space. This breaks through a historic boundary line of late nineteenth century origin, and results in the loss of a significant sandstone boundary wall. We are aware that considerable care has been given in determining phasing of the replacement of the buildings with the objective that the minimum of initial demolition is undertaken to make the complete construction site available whilst the school continues to operate throughout the works. We suggest that further thought is given to this matter to enable all the new buildings to be contained within the existing site, possibly with some of the intended housing land being given back to school use. This will possibly require a more complex phasing of the new build as opposed to the single phase currently intended. If it is resolved to approve the current layout with the wall being breached, the minimum requirement should be for the stone boundary wall to be completely rebuilt on the new line. It is noted that the current proposals are for reuse of stone arising from the 34 wall within gabions, with part of the boundary being fenced. Whilst this proposal may have the support of English Heritage we would expect to see a solution which reinstates the wall and is more in keeping with the conservation area. If there are any matters arising from this letter please contact me. Yours faithfully Stephen Robson S E Robson BSc BPhil MA(LM) DipEP CMLI MRTPI Chair, Conservation & Planning Group Woolton Manor Merseyside E14/1416 N PLANNING CGT WRITTEN RESPONSE 13.02.2015 APPLICATION To carry Please see response to E14/1415 above out alterations to boundary wall in connection with widening of vehicular to Speke Road. St Julies Catholic High School, Speke Road, Liverpool L25 7TN. ACCESS/GATES Sefton Park Merseyside E14/1328 II* PLANNING CGT WRITTEN RESPONSE 16.02.2015 APPLICATION To erect Thank you for your letter of 21 January inviting the Garden History 34 dwelling houses with Society to comment on the above application. The Lancashire associated parking and Gardens Trust (LGT) responds on behalf of the Garden History Society garages. Land off Park which devolves its cases to the regions. Avenue,(Sefton Park The LGT objects to this development adjacent to Sefton Park which is Meadows), Mossley Hill, a Grade I Registered Park and Garden. Liverpool, L17. In this instance, we do not propose to add further comments to those RESIDENTIAL already set out by other objectors who have made the detailed case objecting to the loss of public open space and against development which fundamentally affects the setting of this nationally important site. We support these objections. If there are any matters arising from this letter please contact me. Yours faithfully Stephen Robson S E Robson BSc BPhil MA(LM) DipEP CMLI MRTPI Chair, Conservation & Planning Group Fawsley Hall Northampton E14/1239 II* PLANNING CGT WRITTEN RESPONSE 14.01.2014 shire APPLICATION Installation I have not sent a letter but I left a comment on behalf of the NGT in of three new low pressure the box on the council web site. gas tanks, screen wall Northants GardensTrust ask that the hedge be maintained to screen and new flue at Staff the gas tanks. House and associated Best wishes 35 underground pipelines to Michael Brown MA connect to main building. The Historic Gardener Fawsley Hall Hotel, Garden Historian and Horticulturalist Fawsley Road, Fawsley, Northamptonshire, NN11 3BU. ENERGY/UTILITIES SUPPLY Walcot Hall Shropshire E14/1298 II PLANNING CGT WRITTEN RESPONSE 16.01.2015 APPLICATION Erection of We have received notification of the above proposal, which was agricultural buildings for forwarded to us from the offices of the Garden History Society on barn egg production, January 15th 2015. together with attenuation We note that the proposed development site lies immediately pond and access visibility adjacent to the boundary of Walcot Park, which is included at Grade splay improvement. II on the English Heritage Register of Park & Gardens of Special Walcot Farm, Lydbury, Historic Interest in England. The National Heritage List entry clearly North Shropshire SY7 indicates that the Registered park boundary to Walcot park includes 8AA. AGRICULTURE the southern half of the field in which the proposed development is located. Historically, the park was much larger than this, while what is now referred to as Walcot Farm is identified within the then parkland shown on the OS 1st Edition 6” plan (Shropshire Sheet LXIII.SW 1883) as ‘The Dairy’. Notwithstanding recent additions to the west, the core of this building complex remains largely unaltered since that time. Cedars within parkland to the west and a footpath then leading to The Dairy from the nearby Walcot Hall confirms that it was an integral feature in the landscape and this is confirmed by a ‘ha-ha’ (a sunken wall, allowing views across it) on its southern side. A similar ‘ha-ha’ to the south and east of Walcot Hall, facing ‘The Dairy’ confirms that it was intended to be seen from the Hall as a feature in the landscape. The designed landscape at Walcot and especially the gardens around the Hall date to at least the 17th century, while the parkland is of especial note for having been laid out around 1774 by the landscaper William Emes, who was described by Dr. Paul Stamper in his Historic Parks & Gardens of Shropshire (1996) as ‘probably the leading later- 18th century landscape architect’. The lakes at Walcot in particular are characteristic of his style and recall the great meandering lake at Hawkstone (also in Shropshire, Registered Grade I). Walcot is additionally noteworthy as having once been associated with nearby Powis Castle and with Lord Clive (also known as ‘Clive of India’). It is clear from the above therefore that the proposed development will have a substantial negative impact upon not only the setting of 36 the Registered Park & Garden at Walcot, but also directly upon the fabric of the historic park itself. Given the above, it is clear that the proposed development is likely also to impact detrimentally upon the setting of the Grade II* Listed Walcot Hall, and potentially on the setting of a number of other Listed buildings, including the Grade II* Listed Garden House, and 8 other Grade II Listed buildings within the site. It may also have a negative visual impact upon the setting of the nearby Scheduled Ancient Monument at Lower Down Farm, some 2km to the west. Notwithstanding the complex of designated heritage assets within the immediate environs of the proposed development, no attempt appears to have been made within the application to assess its impact upon these, as required by the National Planning Policy Framework. Even if one were undertaken, it is difficult to see how it could reach a conclusion other than that expressed above. The ‘Landscape and Visual Impact Assessment’ submitted as part of the application, is cursory at best and simply does not do justice to the sensitive landscape environment within which it is proposed to site the structures described within the application. We urge you therefore to reject this application as it currently stands. Yours sincerely, Christopher Gallagher for Shropshire Parks & Gardens Trust & The Garden History Society Polesden Lacey Surrey E14/1278 II* PLANNING CGT WRITTEN RESPONSE 16.01.2015 APPLICATION Erection of Polesden Lacey is included as a Grade II item on the English Heritage 2 No. amenity blocks in Register of Historic Parks and Gardens. The proposed campsite is association with use of within the Register site where the landscape still seems to be land as campsite following substantially as shown on the OS plans of 1871 – 82. This part of the removal of existing Register site does not appear to be especially mentioned in the buildings. Campsite at Register description but clearly contributes to the wider character of Polesden Lacey, the historic estate with its open field and its fully planted Polesden Road, boundaries. The applicant has done little to address these issues by Bookham, Surrey. way of an Historical Assessment. However, the proposed seasonal, CAMPING tented campsite is a low-key activity with limited physical and visual impact on the historic landscape. The proposed replacement buildings are of modest size and their materials, as illustrated and described, are mostly traditional. No site inspection has been made and there may be opportunities to require enhanced planting around the margins to secure the visual enclosure. The management of the site will be important and there should be no use by campers of vegetative materials growing or 37 otherwise found onsite. Nor should the planted boundaries be used in any way detrimental to their survival. Subject to the above comments the Surrey Gardens Trust would not object to the submitted application. Don Josey On behalf of Surrey Gardens Trust The Jellicoe Roof Surrey E14/1368 II PLANNING CGT WRITTEN RESPONSE 10.02.2015 Garden, Guildford APPLICATION A mixed "Objection - This representation is made on behalf of the Surrey use redevelopment Gardens Trust and relates particularly to the Jellicoe Roof Garden. comprising 445 residential This is a grade II site included on the English Heritage (EH) Register of dwellings (Class C3 use); Historic Parks and Gardens. The Register entry was written in 2000 station retail/financial and and edited in 2003. The applicant's agents have recorded and professional services/food analysed the history and design characteristics of the garden. They and drink and leisure have drawn attention to changes since the original construction and floorspace (Class in the restoration completed after the Register entry was prepared. A1/A2/A3/Sui Generis and (Chapter L, paras. L4.210-224 inc.).The Surrey Gardens Trust would D2 uses); station and have no disagreement with these paragraphs. general office floorspace The Trust has had a long interest in this site from the late 1990s (Sui Generis and Class when the store was refurbished and in 2000/01 when the garden was B1 uses); station restored. In 2003 the Trust provided the design for an onsite improvements including information board funded by the Borough Council and the House of new station building with Fraser. The Roof garden is an important work of Sir Geoffrey Jellicoe, booking hall and an eminent 20th century landscape designer with other works in concourse (Sui Generis Surrey at Sutton Place and the Kennedy Memorial at Runnymede. use); replacement station The EH entry refers to a viewing platform and to views although and office car parking, there is perhaps more emphasis on the innovative design details. In new residential car relation to the views the applicant's agents suggest at L4.225 that the parking, cycle parking, a application site is predominantly screened by intervening Station Plaza including development. This is only true in terms of the ground level of the site new public realm with although it has to be acknowledged that the view from the roof hard and soft garden has changed with many new developments in sight. For the landscaping, new access proposed buildings the agents note that the garden "Provides an and servicing elevated view across the townscape directly towards the site" arrangements, plant and (L5.10).At a later paragraph (L5.141) they note that "The proposals associated works. will form a visible and recognisable new element within the wider Guildford Railway Station, setting of the roof garden". This paragraph also states that "the Station View, Guildford scheme, including the tall building .... will be of a scale and massing GU1 4UT. MAJOR that is not seen elsewhere in Guildford. It will compete in HYBRID prominence with the cathedral ..."in the garden's views. The Trust would strongly agree with these assessments. This overall situation is recorded by the agents as a "moderate adverse effect" on the setting of the roof garden. The Surrey Gardens 38 Trust would consider there to be a "high adverse effect" by reason of the above assessments and especially from the linear orientation, massing and height(s) of the proposed development. The scheme is a quite exceptional proposal and for the applicant's agents to suggest at L5.1 ii that Guildford needs a "Marker building" as a "gateway" to the Town Centre seems a perverse logic for this historic town." Best wishes Don Josey Royal Surrey E14/1369 II* PLANNING CGT WRITTEN RESPONSE 10.02.2015 Horticultural APPLICATION Outline "Neutral - This comment is made on behalf of the Surrey Gardens Society's planning permission for Trust. The Heritage Statement within the EIA has been considered in Gardens, Wisley the phased development so far as it relates to RHS WIsley a Grade II* site on the English of a new settlement of up Heritage (EH) Register of Historic Parks and Gardens. The EH letter of to 2,100 dwellings 23 January has also been reviewed. The Trust would concur with the incorporating up to 100 conclusions in each document as to the limited impact on the sheltered accommodation Register site. units and associated The EH letter also refers to the parkland of Ockham Park House as infrastructure including enclosing the Grade I Church. This parkland is a site on the Borough accesses onto the A3 Council's adopted list of Historic Parks and Gardens of local interest (Ockham Interchange), and is therefore a heritage asset to be considered in relation to the Ockham Lane and Old planning application. To the east in the Borough of Elmbridge is Lane and revised access Hatchford Park a site identified in the Historic Environment Record as to Elm Corner, a primary an historic park or garden, and is therefore a heritage asset to be school, community considered. Neither site is affected physically by the proposed provision, nursery development nor do their designed landscapes have outward looking provision, health facility, a views. However, the elongated mass of the proposed housing etc may local centre (incorporating well intrude on glimpsed views from their margins. This would seem food & drink, retail, a to be a minor adverse effect. This comment will be reported to the visitor centre and offices), Garden History Society - the statutory consultee." employment area, 8 Best wishes travellers pitches, sports Don and recreational facilities (incorporating a floodlit sports pitch and pavilion). Sustainable Drainage Systems and an area of Suitable Alternative Natural Greenspace (SANG) incorporating a landform feature and car parking. The erection of associated utilities

39 infrastructure. The development proposal to incorporate the demolition/ removal of the runway and VOR Beacon (and any associated outbuildings). Matter for determination is access (with matters of scale, appearance, landscaping and layout reserved). Land at Wisley Airfield, Hatch Lane, Ockham, GU23 6NU. MAJOR HYBRID Woolsington Park Tyne and E14/1245 II PLANNING CGT WRITTEN RESPONSE 04.02.2015 Wear APPLICATION Demolition We are grateful for the opportunity to comment on application of courtyard buildings, 2014/1925/01/DET located within Woolsington Park which is World War II hospital registered Grade II by English Heritage. buildings, stable block The Northumbria Gardens Trust wishes to lodge concerns about this extensions, outbuildings, application because of the seriously adverse impact on the two farmhouses and farm significance of the site. The proposal affects the entire area buildings and two registered by English Heritage as being of special historic interest and dwellings to facilitate the would counteract the registration (with the exception of the restoration, conversion proposed marquee in the garden which is considered as reversible). and extension of As previously notified to you, The Garden History Society, who is the Woolsington Hall, Stables, statutory consultee on matters concerning registered parks and Coach House and gardens, is now working closely with County Garden Trusts, and the Orangery with the responsibility for commenting on planning applications in this context erection of one and two is now passed to the Trusts. The inclusion of this site on the national storey extensions and register is a material consideration. outbuildings to form a 32 Northumbria Gardens Trust have undertaken research using the bed Hotel (Class C1), English Heritage Register Description, Guide to Historic Parks and restaurant (Class A3) and Gardens in Tyne & Wear and contemporary descriptions Mackenzie E staff accommodation; View of the County of Northumberland (1825), Dodds History of Erection of spa complex Northumberland (1930), county maps and ordnance survey maps. (Class D2) with Northumbria Gardens Trust are of the opinion that the proposal for 72 associated Energy dwellings, chalets, golf course and club house, would have a seriously Centre; Conversion and adverse impact on the significance of the site in view of the impact extension of gardeners on the setting of the hall, the setting of the landscape, the intactness cottage to form cookery of features and rarity of the site. school with ancillary guest Woolsington Park is significant for the following reasons; 40 accommodation (Sui • The parkland laid out in the ‘English Landscape Style’ was Generis) and erection of developed during the late 18th century and is shown on John Gibson’s marquee within walled plan of collieries on the rivers Tyne and Wear published in 1788. garden and potting sheds • A substantial amount of the original layout has survived and reflects for assembly and leisure the original design intended to form a setting to the hall. This events (Sui Generis); includes the pleasure grounds, shrubberies, walks and rides, Erection of 10 woodland orangery, walled garden, parkland and parkland clumps, perimeter lodges (Class C1); belt of woodland, lake with ornamental weir and bridge incorporated formation of 18 hole golf into ride, bath house and principal approach. course, grassed playing • The estate was developed by a member of Newcastle gentry pitch, and erection of golf Matthew Bell, Alderman Sherriff and Mayor of Newcastle. club house; and Woolsington Park is a rare survival of similar estates developed in restoration of ornamental Tyneside by gentry and industrialists such as Axwell Park, Gosforth lake and Monks Hut all Park, Dunston Hall, Fenham Hall, Heaton Hall, which are now with associated car considerably fragmented and are not registered sites. parking for 238 vehicles We appreciate planning decisions have to be balanced based on and associated prevailing planning policy. We would ask you to consider the proposal landscaping works; against the National Planning Policy Framework particularly Section 7 Erection of 72 dwellings (Requiring Good Design) and Section 12 (Conserving and Enhancing with ancillary estate road, the Historic Environment). 10 visitor parking bays, The Northumbria Gardens Trust works closely with the Garden History landscaping and Society (the statutory consultee on Registered Parks and Gardens) to substation; and the comment on planning applications affecting gardens and landscapes creation of new vehicular that are heritage assets and our comments on applications are access through existing forwarded to, and kept by, the Garden History Society. stone wall onto Ponteland We would be grateful to be advised of your decision. Road. Woolsington Hall, Yours faithfully Woolsington, Newcastle Martin Roberts –Northumbria Gardens Trust upon Tyne, NE13 8DQ. MAJOR HYBRID Harewood House West E14/1251 I PLANNING GHS WRITTEN RESPONSE 09.02.2015 Yorkshire APPLICATION Change of Thank you for consulting The Garden History Society in its role as use of film production set Statutory Consultee on the above application which affects the to accommodate ancillary setting of the designed landscape of Harewood House which is visitor tour attraction designated by English Heritage on the Register of Parks and Gardens (Emmerdale village). Land at Grade I. At Stub House Farm, As you will be aware, the Register of Parks and Gardens is a highly Harewood Estate, selective designation, with only some 10% of the 1,600 sites thus Harrogate Road, designated being included at Grade I. As the National Planning Policy Harewood. VISITOR Framework makes very clear, harm to such heritage assets or their ATTRACTION settings should be wholly exceptional. 41 We are very concerned to learn that your Authority has chosen not to consult our fellow Statutory Consultee, English Heritage, on this application. Government directions on consultation and the National Planning Policy Framework both make clear the requirement to consult both ourselves and English Heritage in this case. We must therefore advise you that in the absence of this necessary consultation, your Authority is not in a position properly to determine this application. The Garden History Society object to the present proposals on the grounds of their adverse impact on the setting of the Grade I nationally designated designed landscape. In particular we consider that the proposed vehicle movements through the designed landscape will have a significantly adverse impact on the appreciation and understanding of that designed landscape, and upon the special character and interest which provide part of the basis for its national designation. We advise that the present application conflicts with national planning policy set out in the NPPF, and with guidance put listed by English Heritage on the protection of the settings of designated heritage assets from adverse change. We therefore advise your Authority to reject this proposal. Yours sincerely, Jonathan Lovie Principal Conservation Officer and Policy Adviser The Garden History Society

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