Response to Inspectors’ Note INSP.S14 In relation to Penzance & Newlyn 28 June 2018 Introduction This note sets out Cornwall Council’s response to matters relating to Penzance raised by the inspectors in relation to note INSP.S14. This note is set out in the form of five chapters: Chapter 1 – sets out a review of any cumulative impact in relation to heritage and landscape Chapter 2 – sets out the cumulative flood impact assessment Chapter 3 – sets out response to questions raised with regard to transport related matters Chapter 4 – sets out a response to the points raised regarding over supply of industrial land Chapter 5 – summarises actions as a result of the assessments 2 Chapter 1 Landscape & Heritage Cumulative Impacts Review Introduction 1.1 This note has been prepared in response to Note INSP.S14 from the Inspectors conducting the examination of the Cornwall Site Allocations Document (CSADPD), in particular in response to para’s 16 to 19 which raise concerns around potential cumulative impacts from allocations H4, H5, H6, H7 and H8 on the arc of landscape between Heamoor and Gulval and resulting impacts on those settlements, which could lead to conflict with strategic aims 8 and 9 within the CSADPD. Para 19. of INSP.S14 seeks further evidence relating to cumulative effect of allocations on local character, distinctiveness and heritage. 1.2 The submitted evidence base for the CSADPD, includes the Penzance Housing Evidence Base Report (ref: D15.1) including a Landscape Character Assessment (undertaken by Landscape Officers from the Councils Environment Service) of all the land adjoining the urban area of the town. The full landscape assessment is within Appendix D (ref: D15.1.4). The submitted evidence base also includes a Heritage Impact Assessment (D3) of all allocations, following national planning guidance and prepared in consultation with Historic England. 1.3 This note briefly reviews the existing evidence base in the context of the potential for cumulative impacts of site allocations H4, H5, H6, H7 and H8, together, rather than individually. For specific detail on each individual allocation, the Housing Evidence Report (D15.1) and Heritage Impact Assessments (D3.3 – D3.7, D3.9 and D3.18) should be referred to. This note has been prepared in consultation with Historic England. Landscape Assessment 1.4 The below map shows the overall map from the Penzance and Newlyn Landscape Character Assessment with location of site allocations H4, H5, H6, H7 and H8, overlaid: 3 1.5 The individual landscape character assessment maps for cells 6, 7, 8 and 9 are shown below along with the location of allocations H4, H5, H6, H7 and H8 and a brief assessment comment. For further specific detail refer to the complete Landscape Character Assessment Appendix D (ref: D15.1.4) of the Penzance Housing Evidence Report (D15.1). 4 Landscape Assessment Cell 6 & Allocations PZ-H4 and PZ-H5 1.6 Cell 6 is split into two sub cells 6a and 6b, reflecting the different character areas within the one original cell. 6a is scored highest landscape value (red) and 6b is intermediate value (yellow). PZ-H5 is within 6a and highest value landscape. However, PZ-H5 is a relatively small site on the edge of the existing settlement and the site would still sit within the wider backdrop of rising ground, so any development would not break the skyline. 1.7 Around 60% of allocation PZ-H4 is in an area classified as having an intermediate value, within cell 6b, and 40% higher value (6a). However the western part of PZ-H4 which is higher value is quite steep and facing the A30 road, indicated by a notation on the landscape map which highlights this location’s lack of tranquillity, compared to other areas. Furthermore, the site area was previously reduced in size; drawing away from the settlement of Gulval (to the east) that is over and below a landscape ridge line, which is classified as higher value landscape and south of Polmennor Rd, in order to protect the identity of Gulval itself and the wider landscape setting. 5 Landscape Assessment Cell 7 & Allocation PZ-H6 1.8 Cell 7 which is the highest landscape value (red) includes Allocation PZ-H6 at its south western edge. However, PZ-H6 is a relatively small site on the edge of the existing settlement. The site sits within the wider backdrop of rising ground, so any development would not break the skyline. 6 Landscape Assessment Cell 8 & Allocation PZ-H7 1.9 Cell 8 which is the highest landscape value (red) includes H7 in the south east. However, the site is set within and well contained on all sides by mature trees, so would not represent a significant intrusion into the landscape; further the site boundary was drawn to minimise any impact on the adjacent listed building. 7 Landscape Assessment Cell 9 & Allocation H8 1.10 Cell 9 is split into two sub cells 9a and 9b, reflecting the different character areas within the original cell. The majority of the overall cell, 9a, is of highest value landscape (red), and 9b in the north east is scored low landscape value (green). Allocation PZ-H8 is mostly within cell 9b which is of low landscape value, whilst the southern of the parcels of land, within the higher landscape value, is designated as public open space (within CSADPD Proposed Policy PZ-H8). Furthermore, it should be noted that the Landscape Character Assessment represents the first of various assessments for this site; the more detailed Heritage Impact Assessment (ref: D3.3) of PZ-H8, demonstrates that the western parcel of land allocated, which is within the higher value area, has little to no impact on surrounding heritage assets, in particular Trengwainton. Landscape Overview – Cumulative Impacts 1.11 Viewing the landscape as a whole from PZ-H4 in the east, in an arc following Polmennor Rd west incorporating H5, H6, H7, and H8 south of Boscathnoe Lane, it is apparent that the three smaller scale sites H5, H6 and H7 are all located wholly within areas designated as being of the highest landscape value. Whilst the scale of PZ-H5, PZ-H6 and PZ-H7 would help to mitigate impacts, of greater significance is that all three allocations are also situated north of Polmennor Rd, Josephs Lane and 8 Boscathnoe Lane. Polmennor Rd, Josephs Lane and Boscathnoe Lane represent a natural northern edge to the settlement, with only sporadic individual dwellings to the north of these roads. 1.12 In comparison PZ-H4 and PZ-H8 contain areas of both intermediate and low landscape value, while also containing some smaller areas of higher value, which are either identified primarily for open space, in the case of HZ-H8, or are recognised to be of lesser significance when further, more detailed assessment has been undertaken. Furthermore, PZ-H4 and PZ-H8 are both wholly contained to the south of Polmennor Rd / Boscathnoe Lane, a definable edge to the settlement. In terms of cumulative impacts, it is acknowledged that allocations H5, H6 and H7 do break the historic boundary of Polmennor Road, into an area of countryside which could set an unwelcome precedent for future planning related considerations, with resultant impacts on landscape character. If the three allocations (PZ-H5, PZ-H6 and PZ-H7) were deleted, there would no longer be an arc of allocations around Heamoor. In turn, the two remaining allocations, PZ-H4 and PZ-H8, are located on opposing sides of Heamoor; with the two sites being located 1km apart, together with the built land form, topography and orientation of the sites, it is not felt there would be any significant cumulative landscape impact from these two remaining sites. Heritage overview 1.13 The following is the map from the Penzance & Newlyn Heritage Impact Assessment (HIA) (ref: D3.18) showing potential for any harm to designated and undesignated heritage assets: 9 1.14 In relation to the sites PZ-H4, PZ-H5, PZ-H6, PZ-H7 and PZ-H8 the initial HIA concluded the following: PZ-H4 scored yellow – with potential for minor impacts PZ-H5 scored green - with potential for neutral impacts PZ-H6 scored green - with potential for neutral impacts PZ-H8 scored yellow - with potential for minor (to moderate) impacts 1.15 Further extensive heritage impact assessments have been prepared on the Heamoor site, PZ-H8, (D3.3 – D3.7) with the detailed involvement of Historic England, including their Registered Parks and Gardens Officer, to ensure harm to Trengwainton Registered Park & Garden is avoided and / or mitigated. In relation to PZ-H4, Trannack, the site area was previously reduced in size drawing away from the settlement of Gulval (and the area identified as orange hatched on PZ-Ex3A on the HIA map, with potential for moderate impacts), which is located to the east, over and below a landscape ridge line, south of Polmennor Rd, in order to protect the identity of Gulval itself and the wider historic landscape setting. In this way it is felt that PZ-H4 would not be visible from within Gulval village, so a clear separation of settlements would be retained. 10 Heritage Assessments - Cumulative Impacts 1.16 The following table lists the designated heritage assets that are highlighted as potentially being affected by each of the sites within the submitted evidence base. These are taken from the HIA Penzance Town Assessment (ref: D3.18) and the HIA for Heamoor (ref: D3.3): Table 1: Designated Heritage Assets Allocations with potential for impacts Setting of Lescudjack Hillfort SM PZ-H4 Trannack; Poltair Grade II Listed Building PZ-H7 Poltair Wider setting of Trengwainton PZ-H8 Heamoor Registered Park & Garden Lesingey Round Scheduled Monument PZ-H8 Heamoor Grade II listed stone cross PZ-H8 Heamoor Roscadghill House and Cottage Grade PZ-H8 Heamoor II listed buildings Rosehill House Grade II listed building PZ-H8 Heamoor Nancealverne House Grade II listed PZ-H8 Heamoor building Castle Horneck Grade II listed building PZ-H8 Heamoor Madron Conservation Area PZ-H8 Heamoor 1.17 It should be noted that the heritage assessment (ref: D3.18) identifies non designated heritage assets in relation to each of the allocations such as altered anciently enclosed land, and buried archaeological potential.