Pearson, Jennifer Page 1 of 2 05/06/2014

Page 1 of 2

Pearson, Jennifer

Subject: FW: Proposed development in Trefonen 14/00536/OUT Attachments: PROPOSED DEVELOPMENT AT TREFONEN.pdf From: Andy Wigley [andy.wigley@shropshire.gov.uk] Sent: 01 May 2014 16:31 To: Klemperer, Bill Subject: RE: Proposed development in Trefonen (14/00536/OUT) Bill,

I thought you should be aware that the Council in now in receipt of the heritage assessment from objectors to this above application. In the circumstances, would you wish to be re‐consulted on the application?

Kind regards,

Andy Please note that my mobile no. has changed ______Dr Andy Wigley Historic Environment Manager Historic Environment Team Shropshire Council Shirehall Abbey Foregate SHREWSBURY SY2 6ND

Tel. (01743) 252561 Mob. 07990 085329 ______

From: Mark Perry Sent: 01 May 2014 16:00 To: Andy Wigley Subject: Proposed development in Trefonen (14/00536/OUT)

Hi Andy,

For your information please find attached a heritage assessment that I have just received. This has been commissioned by the objectors for the site at Whitridge Way in Trefonen. Hopefully the archaeology report from Dave Parker will also be with us by the end of the week, so you’ll have two to read, compare and contrast!!

Regards,

Mark Perry Senior Planner

Development Management Shropshire Council Castle View

05/06/2014 Page 2 of 2

Oswestry SY11 1JR

: 01743 258774 : [email protected] : www.shropshire.gov.uk

From: Liz Kilvert On Behalf Of planningdmnw Sent: 01 May 2014 15:51 To: Mark Perry Subject: FW: Proposed development in Trefonen

From: Sent: 01 May 2014 14:54 To: planningdmnw Cc: Subject: Proposed development in Trefonen

Dear Sir,

On the behalf of Trefonen Rural Protection Group, I enclose an attachment to be placed on the Planning Portal, with regard to the proposed housing development in Trefonen ‐ Ref. 14/00536/OUT.

This is to be described as ‐ Consultee Comment and be given the description ‐ Heritage Assessment – Dr. George Nash (George Nash being author, of the Heritage Assessment)

It would be appreciated, if this documentation could be placed on the Planning Portal at the earliest opportunity.

Yours sincerely

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05/06/2014

2014

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN, SHROPSHIRE

HERITAGE

STATEMENT

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN i Heritage Statement April 2014

HERITAGE STATEMENT Dr George Nash

Produced on behalf of the Trefonen Rural Protection Group PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN ii Heritage Statement April 2014

CONTROLLED DOCUMENT

Document No:1

Status: Final Copy No: 1

Name Signature Date

Prepared by: George Nash 28st April 2014

Checked: Laurence Hayes 29th April 2014

Amended and George Nash dispatched: 30th April 2014

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN iii Heritage Statement April 2014

CONTENTS

NON-TECHNICAL SUMMARY ...... 1 1.0 INTRODUCTION ...... 2 2.0 STUDY AREA DESCRIPTION AND CONTEXT ...... 3 3.0 BASELINE CONDITIONS ...... 4 4.0 PLANNING HISTORY ...... 9 5.0 THE WALKOVER SURVEY ...... 9 6.0 LANDSCAPE COMPLEXITY ...... 12 7.0 STATEMENT OF ARCHAEOLOGICAL POTENTIAL ...... 12 8.0 SIGNIFICANCE ...... 13 9.0 IMPACT ASSESSMENT ...... 14 10.0 DISCUSSION ...... 17 11.0 SUMMARY ...... 18 12.0 RECOMMENDATIONS AND OBSERVATIONS ...... 18 13.0 REFERENCES CONSULTED ...... 21 14.0 CLOSURE ...... 22

APPENDIX 1. Correspondence from the Prehistoric Society...... 36 APPENDIX 2. Correspondence from RESCUE...... 37 APPENDIX 3. Correspondence from CBA...... 39

ABBREVIATIONS

BGS: British Geological Survey

HER: Historic Environment Record

NPPF: National Policy Framework

PPS(5): Planning Policy Statement

SM: Scheduled Monument

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 1 Heritage Statement April 2014

NON-TECHNICAL SUMMARY

A Planning Application to construct 12 dwellings (one as an affordable option) has been submitted to Shropshire Council. The proposed development stands within the northern part of the village of Trefonen, North Shropshire and is located close to the scheduled Offa’s Dyke and other heritage assets.

This report includes the results of a walkover survey which identified 17 previously recorded and unrecorded heritage assets within a 300m radius of the proposed development. Based on the walkover survey, along with supporting documentary evidence, direct and indirect impacts will occur to a number of significant heritage assets. This report also identified potential sub-surface damage/destruction to the western extent of Offa’s Dyke; possibly a ditch section which forms the eastern boundary of the proposed development. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 2 Heritage Statement April 2014

1.0 INTRODUCTION

Dr George Nash was commissioned by the Trefonen Rural Protection Group (TRPG) to prepare a Heritage Statement for land that partly abuts the eastern rampart of Offa’s Dyke within the village of Trefonen, Shropshire. The area is the subject of an application for housing development known as Whitridge Way, and is referred to throughout this report as the proposed development (Figure 1). The proposed development incorporates an area in which extensive early post-medieval industrial scowling of the land surface has taken place, underlying an historic (late post medieval) ridge and furrow agricultural regime.

This heritage statement has been prepared in accordance with statutory policy within National Policy Planning Framework (NPPF) (Chapter 12), and technical guidance within the Institute for Archaeologists (IfA) document Standard and Guidance for Historic Environment Desk-based Assessment (2012) and English Heritage’s The Setting of Heritage Assets (2011).

Within Chapter 12 of NPPF, the Local Planning Authority (LPA) should: [para 128] In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary.

Based on this statement, the author of this report has undertaken a thorough review of available archaeological and historical data, along with aerial reconnaissance (Plates 1 to 6) and a walkover survey (see Plates 7 to 26). Identified during the site visit were a number of designated and non-designated heritage assets including one Scheduled Monument: a near-continuous section of Offa’s Dyke (see Table 1). In addition were a number historic buildings and structures that stand within a 300m radius of the proposed development; several of these are included within Shropshire Historic Environment Record (HER).

The author of this report is a Member of the Institute for Archaeologists (IfA), at MIfA Level and an affiliate member of the Institute of Historic Building Conservation (IHBC).

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 3 Heritage Statement April 2014

Figure 1: Approximate area of the Application Site (in red outline)

2.0 STUDY AREA DESCRIPTION AND CONTEXT

The proposed development (Planning Application Ref No.: 14/00536/OUT) comprises a sub-rectangular plot of land that occupies the southern extent of a large field that is, itself, bounded on its eastern side by a section of Offa’s Dyke and an ancient bridleway on its western flank. The southern boundary comprises an east-west drystone wall which provides the northern extent of the rear garden plots belonging to dwellings of Carneddau Close. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 4 Heritage Statement April 2014

The proposed development does not stand within a Conservation Area. No Scheduled Monuments (SMs), Listed Buildings or other known heritage assets recorded by the Shropshire Historic Environment Record (HER) are present within the development boundary.1 The area of the proposed development does not stand within or constitute part of a World Heritage Site (WHS).

The proposed development is situated within c. 1m of a section of Offa’s Dyke, a Scheduled Monument. Up to 16 further designated and non-designated heritage assets are located within 300m of the proposed development (TRE 001 to TRE 017 - see Table 1).

3.0 BASELINE CONDITIONS

3.1 GEOLOGY Based on British Geological Survey data (BGS), the proposed development site overlies two geological formations. Within the west half of the field and extending across most of the settlement is a Cefn-y-Fedw Sandstone Formation (CFS); the age of this bedrock is Visean – Namurian epoch. However, inspection of the field suggests limestone bedrock covered by thin calcareous soils. The limestone, which outcrops across the study area, is continuous. According to the BGS, coal measures underlie this formation (belonging to the Pennine Lower Coal Measures Formation and Pennine Middle Coal Measures Formation [undifferentiated] – PLMC).

Concerning coal deposits, correspondence between The Coal Authority and Mr Perry, the Case Officer at Shropshire Council, dated 22nd March 2014 considers the proposed development to be set within what is termed a Development High Risk Area and as a result objects to the planning application (14/00426/OUT) as a Coal Mining Risk Assessment report has not been submitted. This is a requirement under Policy CS6.

3.2 BRIEF HISTORY AND DEVELOPMENT OF TREFONEN AND THE SITE Trefonen stands within the north-western part of the county of Shropshire and has its origins dating to at least the construction of Offa’s Dyke, which runs through the centre of the village. Distinct traces of the earthwork are clearly visible within the northern and southern sections of the village (Plate 21).

Until recently, the date placed on this significant linear earthwork was late 8th century (probably constructed between AD 757 and 796), during the reign of Offa, King of Mercia.2 At this time, it is more than likely that this area of the Welsh Marches was a sub-kingdom which was probably administered by one of Offa’s family (Finberg 1961). Although difficult to visualise, the earthwork comprises a large turf and stone bank with accompanying ditch; the ditch is located along the western side of the earthwork. A substantial [Scheduled] section of this monument stands within 40m of the northern boundary of the proposed development with a disturbed section standing less than 1m from the site boundary (located at NGR SJ 25948 26997). Other disturbed sections probably occupy the front garden plots of

1 HER records are referred to by their Primary Record Numbers (PRNs) 2 Recent OSL dating places sections of this linear earthwork to between the early 5th and late 7th century (CPAT Press Release April 2014). PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 5 Heritage Statement April 2014

dwellings that stand on the western side of Chapel Lane (at Church View, NGR SJ 29535). Late 19th century mapping clearly shows the extent of the Chapel Lane section of the dyke as a series of small rectangular plots that stand on the western side of the lane (Figure 3).

Based on place-name evidence, Trefonen is clearly of Welsh origin. The ‘Tre’ element refers to ‘home of’ or ‘homestead of’. The ‘fonen’ element probably refers to the ash tree; therefore ‘the home of the ash tree’.

During the medieval period, Trefonen was contained within the lordship of Oswestry; however, given the close proximity of settlement to Offa’s Dyke and its place-name, it is more than likely that its origins are rooted in an early Celtic/Welsh tradition when this part of Shropshire was once occupied by the Kingdom of Powys. Following the Norman conquest of England, this area was controlled by the Baron of Oswestry - Alan Fitz Flaad- whose family held the area throughout the medieval period. It is during this time that much of the Welsh Marches (borderlands) was engaged in sporadic skirmishing, in particular during the latter part of the 15th century when Owain Glyndŵr and the [English] Mortimer family were disputing various tracts of land either side of the border. Following the Laws in Wales Acts (1535 & 1542) and unification between Wales and England in 1538, the parish of Trefonen (and neighbouring parishes) was annexed to Shropshire.

Following a period of relative peace and stability, the area around Trefonen became the focus for quarrying and mining.3 The underlying geology, comprising [carboniferous] coal, limestone, sandstone and shale formations served a number of allied industries including brick making, ceramics and building/construction; however, the prime material was coal. Between the 17th and 19th centuries, the area north of Trefonen was mined; the locality forming part of the Oswestry Coalfield.

It appears that industrial activity within the north of the village ceased by the late 19th century; reasons for which are not fully understood. The scowled area that occupies most of the proposed development site is covered by extensive later ridge and furrow, the date of which is difficult to determine. The buildings (including private dwellings) all appear to date from the mid- to late-18th century suggesting the village had at this time expanded (and had become locally prosperous). During this time there were three public houses in use (The Barley Mow, Efel Inn and the Royal Oak), along with All Saints Church, the Congregational Chapel and the Calvinistic Methodist Chapel. The Royal Oak stood once stood on Offa’s Dyke, opposite Plas Offa Cottage (TRE 010) and south of the now Scheduled section of the Dyke.

The site of All Saints Church, parish church was given to the parish by the Sir Watkin Williams-Wynn in 1821; the church was consecrated in the same year. At around the same time the Congregational Chapel was constructed for the benefit of the non- conformists members of the village.

In terms of the survival of industrial remains from this period, Frost (2014) has identified a number of features including banks, bell pits, rectangular and sub- rectangular enclosures and inter-connecting trackways, suggesting a complex

3 The author suggests that some form of small-scale industrial activity was already ongoing during the medieval period. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 6 Heritage Statement April 2014

industrial process (extractive industry) was in operation. By the mid- to late-19th century a number of coal pits had been closed mainly due to flooding, including the Old Trefonen Pit (owned by the Trefonen Coal Company). This pit, opened in 1860, was working at a depth of c. 82m but closed in 1886. Earlier pits include the Trefarclawdd Colliery which was opened in 1792 but closed around 1833 due to flooding. During the latter part of the 19th century, two new pit shafts named The New Trefonen were sunk south of Pottery Cottages in 1881. These were mined for about 10 years; their closure marked the demise of the Oswestry Coalfield.

Following around 300 years of intense industrial activity, the landscape around the north of Trefonen reverted to agriculture. It is probable that the ridge and furrow marks identified on the aerial photographs date from the 19th century, although one can consider that the scowling within the area of the proposed development occurred much earlier.

3.3 MAP REGRESSION For this section of the report, seven historic maps where consulted, the earliest dating to 1838. The Cassini Map of c. 1838 (not reproduced) shows Trefonen as a dispersed settlement, occupying much of the land east of Trefonen Hall (around SJ 257 268). Also present on this map is the continuous north-south line of Offa’s Dyke, apparently running some way west of Chapel Lane but converging towards the road junction within the centre of the village.

The Tithe Map (Figure 2) (and its accompanying Apportionment) of 1838 shows the field in which the proposed development is located (Plot Nos. 189, 190 and 191, the proposed development falling within the southern part of Plot 189). A further two plots – Nos. 192 and 193 occupy the eastern side of the field (Figure 2). It is probable that each of the five plots are delineated by turf and/or drystone walling, some sections of which are visible as fossilised features from aerial images taken in April 2014 (see Plates 1 to 6). The boundary of this five-plotted field has, since the publication of this map, remained unchanged. Within Plot 190, a square building stands; its use and date unknown; whilst several buildings occupy sections of the Dyke within Plots 192 and 193. The presence of the buildings would have greatly disturbed the upper form of the Dyke. Fron Farm (also known as Vron) and its outbuildings occupy Plot 184 (Plate 13). The bridleway, identified from the walkover survey (TRE 014) was, at this time a trackway which would have provided access to dwellings within the western section of the village (see Plate 14).4 To the west of the trackway and south of Fron Farm are Fron Cottages - a terrace of two dwellings (TRE 017).5 Visible within this recently refurbished terrace, is the original 18th century stone plinth (Plate 15).

The 1st Edition Ordnance Survey Map published in 1870 (scale 1:2500) (Figure 3) shows the field in which the proposed development is situated (referred to as Plot 1677). Between the publication of the 1838 Tithe Map and the publication of this map many of the internal field boundaries were removed, the area comprising just three plots; two of these delineate the southern section of the Dyke. The northern plot was occupied by the Royal Oak Public House, a rectangular building fronting Chapel Lane. The cartographers have also included the earthworks belonging to Offa’s Dyke which extend northwards from the northern plot boundary of the Royal

4 Plots to the east of Chapel Lane and west of Oswestry Road have been described by Frost (2014). 5 This terrace was probably once tied cottages belonging to Fron Farm. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 7 Heritage Statement April 2014

Oak public house.6 To the south of the field, the line of the Dyke continues towards the central part of the village where five roads/lanes/tracks converge. One of these plots belongs to the Congregational Chapel (and associated burial ground to the south) – see Plates 8 & 9.

At this time there was no development south of the field, within Plot 1797; this field remained rough pasture until relatively recently.

The Ordnance Survey map of 1881 (not reproduced) shows little change to this area of the village; however, the OS map of 1901 shows that the Royal Oak public house had been demolished (Figure 4). The earthwork of Offa’s Dyke is clearly visible within the northern section of the field but is merely a boundary within the field to the north of Chapel Lane (within Plot No 679). The Ordnance Survey map of 1926 (Figure 5) shows little change to this section of the village; although at this time the industrial activity in and around the village was in terminal decline.

The National Grid map of 1970 shows little change in terms of development; however, this map does show greater detail of the survival and form of Offa’s Dyke, in particular, within the area that had previously occupied by the Royal Oak public house. Further detail of this earthwork is shown at the western end of the northern boundary belonging to Church View.7 According to this map, this small earthwork section measures c. 20m (N-S) x 10m (E-W). Surprisingly, this small section of the Dyke is not Scheduled, and therefore not statutorily protected. Potential subsurface sections of the Dyke may survive within the four plots and a Non-conformist burial ground to the south.

Figure 2: The Tithe Map of 1838

6 Also marked on this edition are individual (mature) trees; three along the southern boundary of the field (TRE 003). 7 Recent inspection by the author of this report confirms this. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 8 Heritage Statement April 2014

Figure 3. Ordnance Survey map of 1870 (scale 1:2500), showing approximate area (in red) Figure 4. Ordnance Survey map of 1901 (scale 1:2500), showing approximate area (in red)

Figure 5. Ordnance Survey map of 1926 (scale 1:2500), showing approximate area (in red) Figure 6. National Grid map of 1960 (scale 1:10000), showing approximate area (in red)

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 9 Heritage Statement April 2014

4.0 PLANNING HISTORY

As far as the author of this report is aware, there have been no previous archaeological or cultural heritage investigations conducted within the curtilage of the proposed development. The planning history of the site is limited to the current Planning Application (Planning Ref No.: 14/00536/OUT).

An archaeological report has been commissioned by the applicant for the Whitridge Way development; however, this report has yet to be published and circulated.

To the east of the proposed development, on land off Oswestry Road (NGR SJ 2610 2685) a heritage statement was produced in advance of further proposed development that includes housing (Castlering Archaeology, January 2014).

Shropshire Council’s HER and English Heritage recognises two Scheduled Monuments (SM) and six HER Primary Record Numbered sites (PRNs) within a 0.5km radius of the proposed development.

The Historic Environment Record identifies eight designated and non-designated heritage assets within a 500m radius of the site (included into Table 1). Included within this list is a Scheduled section of Offa’s Dyke (EH 10166808) and the earthworks and buried remains of an 18th century colliery known as Trefarclawdd (EH 1016680 [HER 04276]).

In addition, a Planning and Design Access Statement, was published February 2014 by Tim Morris (of David Parker Planning Associates, Oswestry). This document reports on various correspondences between the applicant and the various statutory bodies including English heritage and Shropshire Council. However, based on research by the author and Frost (2014) much of what has been sited within this report is flawed evidence including the issues of setting and development screening (p. 17).

The Oswestry Borough Local development Framework (LDF), published in December 2005, defines the landscape around Trefonen as an Area of Special landscape Character (see LDF Policy NE1). This definition includes the area north of the village.

5.0 THE WALKOVER SURVEY

A walkover survey was undertaken on the 15th April 2014 and included a study area of 0.3km radius from the proposed development. Identified from the walkover survey were 17 designated and non-designated heritage assets (see Plates 7 to 26). Excluded from this list are three listed buildings – Trefonen Hall (LB 1367331), Pen-y- Llan Hall (LB 1177543) and a stone bridge (LB 1054240); all three structures/sites are located outside the study area. In addition to the omission of the three Listed Buildings is a Registered Park known as Woodhill [also known as Wood Hill] (centred upon NGR SJ 270 260); this site stands 2km south-west of the study area. The walkover survey was supported by an aerial photographic survey which was undertaken on the same day as the walkover survey (Plates 1 to 6).

8 Referred to as Offa’s Dyke Scheduled sections 100yds (90m) and 350yds (230m) long, NE of Fron Farm). PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 10 Heritage Statement April 2014

Table 1: List of heritage assets from the walkover survey and Shropshire’s HER

ID No. Site Grid Ref. Description Name TRE 001 Offa’s SJ 25821 27347 - Well-defined section of Offa’s Dyke, SM: SA238 Dyke SJ25888 27129 orientated roughly north-south. Route (section of the dyke forms part of an ancient field of) boundary. Based on historic mapping, smaller field boundaries run off the dyke, towards Fron Farm (see Plate 13). No trace of any ditch on the western side. 18th/19th century revetted leat cuts into the eastern side of the dyke at SJ 25858 27218 (see Plate 16). Southern extent is cut by Chapel Lane – section shape is well-defined and is clearly defined within the verge sections of Chapel Lane (Plates 22 & 23). TRE 002 Offa’s SJ 25895 27120 - Defined section of Offa’s Dyke extending Dyke SJ 25948 26997 to the northern plot boundary of Church (section View (cottage); part of the dyke was of) occupied by the Royal Oak public house during the late 19th century. Northern section survives as a cut feature on the southern side of Chapel Lane. The southern extent of the dyke is disturbed; however, the linearity and form remains clearly defined. Probable buried sections of the dyke survive within the garden plots of dwellings that front Chapel Lane, as well as the burial ground that was originally associated with Chapel Cottage (see Plates 8 & 9). TRE 003 Field SJ 25849 26919 – Drystone-walled boundary, orientated boundary SJ 25954 26957 east-west and present on the 1st Edition OS map of 1870 (scale 1:2500). The boundary forms the northern extent of a recent housing development that fronts Carneddau Close. TRE 004 Barley SJ 25982 26820 Two-storey multi-phased public house, Mow dating to c. 1760; standing on the public western side of Oswestry Road. The house main building, comprising two interconnecting buildings forms part of the historic core of Trefonen. Building complex includes former stables. TRE 005 All Saints SJ 26085 26867 Stone-constructed church, located on Parish the eastern side of Oswestry Road, Church constructed in 1821. Cleared churchyard immediately south; relocated further south. Current church building probably replaces a much earlier structure (Plate 7). PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 11 Heritage Statement April 2014

TRE 006 Non- SJ 25981 26914 Stone Congregational Chapel HER 14320 conformist (chapel) constructed in 1834 with associated chapel & SJ 25983 26877 chapel burial ground (purchased in burial (burial ground) 1868). Chapel and burial ground stands ground over a short section of Offa’s Dyke; possible survival of the dyke’s form within the burial ground (Plate 8). Chapel has been recently converted to residential use (Plate 9). TRE 007 Offa SJ 25980 26934 Probable late 18th/early 19th two-storey Cottage dwelling constructed of stone. Dwelling and associated plot has recently undergone (unfinished) refurbishment. Garden section fronting Chapel Lane may contain surviving elements of Offa’s Dyke (Plate 26). TRE 008 Church SJ 25968 26968 Two-storey stone dwelling located on View the western side of Chapel Lane. Garden section fronting the lane may contain surviving elements of Offa’s Dyke (Plate 25). The northern boundary of the plot truncates Offa’s Dyke. TRE 009 Rose SJ 25973 27016 18th/19th century stone two-storey Cottage dwelling, one of four located along the eastern side of Chapel Lane. Building appears to form part of a single building complex, possibly a farm (Plate 10). TRE 010 Plas Offa SJ 25972 27035 Mid- to late-18th century two-storey HER 26398 Cottage stone dwelling, one of four located along the eastern side of Chapel Lane (Plate 11). TRE 011 Plas SJ 25957 27042 Mid- to late-18th century two-storey Dympling stone dwelling, one of four located along the eastern side of Chapel Lane (Plate 12). TRE 012 Leat SJ 25858 27218 – Stone revetted leat, oriented east-west, SJ 2599 27245 extending east of Offa’s Dyke. Leat appears to have been gravity-fed. Leat is associated with a series of earthworks located to the south and east (see Plates 6 & 16) – see TRE 015. TRE 013 Fron Farm SJ 25966 27097 Stone farmhouse and associated barn/outbuildings complex arranged around a rectangular courtyard (Plate 13). Farm complex appears to date to late post-medieval period but could be much earlier. TRE 014 Bridleway SJ 25775 27137 – Linear north-south track, currently SJ 25849 26919 designated as a public bridleway, present on mid- to late-19th century mapping (Plate 14). TRE 015 Industrial SJ 26038 26959 Industrial workings (scowls) and linear Workings (centred upon) and sub-linear earthworks extending across a number of fields within the northern section of the village, including the field where the proposed PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 12 Heritage Statement April 2014

development site is located (see Plates 5 & 6). The earthworks extend to Oswestry Road where a former brickworks and colliery area is identified (HER 28315)9 TRE 016 Ridge & SJ 25 27 A series of distinct areas of (early) post- Furrow medieval ridge and furrow marks marks extending across the field where the proposed development site is located (Plate 6). TRE 017 Fron SJ 25816 26989 A terrace of two dwellings which have, Cottages in recent years, been refurbished; however, several 18th century features are visible including a stone plinth.

6.0 LANDSCAPE COMPLEXITY

Based on data within the Shropshire’s HER and various grey literature reports (e.g. Frost 2014), the heritage character and distinctiveness of the landscape within the Study Area can be considered multi-faceted and multi-layered. Despite the visible evidence of the Early Medieval, medieval and post-medieval archaeology, the human presence within this landscape probably extends a further 2000 years, to the Bronze Age - if not earlier (lithics have been found within the vicinity of Trefonen).

The historic mapping, along with supporting documentary evidence, further indicates the landscape complexity of the area, especially the landscape to the north and south, following the route of Offa’s Dyke. Further landscape complexity is witnessed within the area to the north and east where post-medieval industrial activity is recorded in the form of colliery workings, brick making and pottery manufacture (Frost 2014) – see Plates 1 to 6. The earthworks, including a series of probable bell pits, surface workings, an integrated leat system and possible tramway sections is as yet not fully understood. Remarkably, these features have survived in the archaeological record since the area ceased to be an industrial centre during the latter part of the 19th century.

7.0 STATEMENT OF ARCHAEOLOGICAL POTENTIAL

To summarise the findings of this report and to broadly assess the potential for survival or presence of archaeological remains from the various chronological periods discussed above, the table below outlines the known archaeological and historic evidence within and surrounding the site (Table 2).

9 Further industrial activity in the form of Old Trefonen Pits (HER 06624) and Clay/Coal workings at Pottery Cottages (HER 04277) stand to the east and north respectively. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 13 Heritage Statement April 2014

Table 2: Broad Assessment of Archaeological Potential PERIOD EVIDENCE POTENTIAL

Palaeolithic- No Early Prehistoric sites or finds are within or outside LOW Neolithic the Application Area. Bronze Age - No Late Prehistoric sites or finds are within the LOW Iron Age Application Area. Romano-British No Romano-British sites or finds are within the LOW Application Area. Early Medieval Offa’s Dyke forms the eastern section of the boundary HIGH of the field in which the Application Site is located. Arguably, the course of the dyke’s ditch forms the eastern boundary of the Application Site. Medieval The Application Site is located within the northern MODERATE section of the village of Trefonen which has its origins within the medieval period (if not earlier). Post-Medieval The Application Site stands within a fossilised primary HIGH industrial quarrying and processing area which ceased operations during the latter part of the 19th century. The origins of such an industry probably date to the early post-medieval period (if not earlier). Conservation The Application Area does not stand within the N/A Area Conservation Area. Listed Buildings There are no Listed Buildings within the Application N/A Area. However, there are a number of buildings that flank either side of Chapel Lane that date to the mid- to late-18th century that form the original settlement of Trefonen – two of these are included with Shropshire’s HER. Locally Listed There are no Locally-Listed Buildings within the N/A Buildings Application Area. Scheduled There are no Scheduled Monuments within the HIGH Monuments Application Area; however, a disturbed section of Offa’s Dyke does extend to the NE corner of the Application Area and the associated ditch extends as a subsurface feature along the eastern boundary of the Application Area. Registered There are no Registered Parks and Gardens within the NONE Parks and Application Area, although a Registered Park known as Gardens Woodhill stands several kilometres to the SE. Registered N/A NONE Battlefields World Heritage N/A NONE Sites

8.0 SIGNIFICANCE

There is a low potential identified for assets to be present of Prehistoric or Romano- British date. No known assets of these periods are present within the area of the proposed development. Should unknown remains be present, these are likely to comprise heavily truncated deposits beneath later disturbed soils/plough soils. Such features may be of low (local) significance. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 14 Heritage Statement April 2014

While the section of Offa’s Dyke which fringes the eastern limit of the proposed development is not Scheduled (presumably on the grounds that the upstanding elements of the monument do not survive to the extent visible in other sections), buried deposits associated with the dyke, including ditch and bank foundations, would be considered to be of equal importance to those scheduled sections.

Scheduled Monuments are considered under NPPF to be ‘assets of the highest significance’ (NPPF para 132, usually accorded with National Importance). In a consultation response from English Heritage to another application affecting Offa’s Dyke in Trefonen it was stated that (see also Section 10 below):

Offa’s Dyke is the largest, most impressive, and most complete purpose built early medieval monument in Western Europe. It is the largest civil engineering project ever undertaken by an Anglo-Saxon state, and the most impressive Anglo-Saxon monument to now survive in the UK.

As such, it may be considered that the monument transcends national importance and is of international significance.

Under NPPF (para 139), it is stated that ‘Non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments, should be considered subject to the policies for designated heritage assets’. This situation is considered to apply to the non designated section of Offa’s Dyke adjacent to the current proposed development site.

A moderate to high potential for features to be present associated with medieval and post medieval agriculture and industry is identified. Any such features are likely to be of no more than low (local) significance.

9.0 IMPACT ASSESSMENT

Impact, either directly or indirectly will have an adverse effect on cultural heritage and as such, non-statutory criteria in the form of guidance within National Planning Policy Framework will assess the magnitude of impact albeit in a brief statement. In addition to this, there are a number of local frameworks in place that complement and enhance specific areas of the landscape. The Oswestry Borough Local Development Plan (published December 2005) is a saved policy (and therefore valid) and yet to be upgraded into the current Core Strategy. Elements within this document suggest that any further housing proposals should be ‘deleted from the development area’ and that Oswestry Borough Council has a duty to protect, enhance and preserve sites of archaeological importance (e.g. Offa’s Dyke and Trefonen’s mining heritage).

Direct impacts

It is the view of Dr George Nash that the current plan to develop on land north of Carneddau Close (the proposed development known as Whitridge Way) will have a direct impact on the western section of Offa’s Dyke, between NGR SJ25954 26937 and SJ 25948 26997. Such impacts may come about through landscaping or construction activities which result in disturbance of buried deposits. The author of this report has ascertained that at least a 5m tract of land within the proposed PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 15 Heritage Statement April 2014

development area could contain the subsurface remains of the ditch that belongs to Offa’s Dyke (see Figure 7).

Further direct impacts would also occur to the various surface and sub-surface features that extend across the area of the proposed development including the quarrying scowls (and their associated features and structures) and the overlying agricultural landscape (see Plates 5 & 6).

The significance of effect resulting from direct impacts on assets of high/very high importance would be considered to be Very Large and Adverse.

Indirect impacts

Indirect impacts on designated and non-designated heritage assets may include a reduction in their heritage significance by causing visual or sensory changes within their settings (English Heritage 2011).

English Heritage interprets setting as:

….the surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral.10

Based on this definition, any potential development within the Study Area should consider:

….the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification (NPPF Chapter 12, paragraph 132).

Based on these criteria within NPPF, the unique setting of Offa’s Dyke and other recognised heritage assets will be significantly harmed because the imposition of the development within the current landscape setting of the monument will further erode the ability of the observer to appreciate its location, alignment and form.

10 See also English Heritage 2011a, 2011b & 2011c. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 16 Heritage Statement April 2014

Figure 7: Potential direct and indirect development impacts to Offa’s Dyke

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 17 Heritage Statement April 2014

10.0 DISCUSSION

Based on the large body of evidence including comments made by RESCUE (Appendix 2), The Prehistoric Society (Appendix 1) and English Heritage, there is mounting concern that this development will cause substantial harm to this multi-phased landscape, should permission be granted.

In August 2013 English Heritage objected to Planning Permission being granted to construct a detached dwelling on Land Adjoining Rosedale, Chapel Lane, Trefonen (Application No. 13/01025/FUL).11 English heritage claimed that: Offa’s Dyke is the largest, most impressive, and most complete purpose built early medieval monument in Western Europe. It is the largest civil engineering project ever undertaken by an Anglo-Saxon state, and the most impressive Anglo-Saxon monument to now survive in the UK. Based on this impressive description, English Heritage claimed that Development close to the Dyke does have the potential to damage the overall significance by detracting from the rural setting and interrupting the linearly of the monument (in other words, the setting of this monument would be harmed).

Within the same correspondence English Heritage summaries their reasoning using NPPF (Chapter 12), outlining the following:

 The development proposal is within an area in which the lower part of the eastern bank of the Dyke survives;

 The development would impact upon the setting of the monument by being within a prominent addition within a largely rural landscape, and elevated for the adjacent linear development to the south;

 The proximity to the piercing of the Dyke by the minor road would increase the impact of the development with a new entrance and boundary works being created a few metres from the Dyke; and

 Although landscaping and screening has been offered we do not feel that this would successfully compensate for the visual impact of the development which would be visible from the national trail to the west and a footpath to the north.

Much of the reasoning for objecting to this particular planning application can also apply to a greater extent to the current planning application for the proposed Whitridge Way development. However, in a letter dated 13th March 2014, between English Heritage and Shropshire Council (Planning North), the above criteria has been largely overlooked; indeed, the letter claimed that English Heritage does not object to this application in principle.12 The letter claims that the Dyke does not pass through the Application site, although research by the author of this report suggests otherwise.

11 The then proposed development stood within view of the northern part of the village and around c. 100m east of Offa’s Dyke. 12 This view remains unchanged since a site visit was made on the 10th March 2014. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 18 Heritage Statement April 2014

11.0 SUMMARY

Based on the surviving archaeological evidence in and around the proposed development, three clear phases of chronology are recognised:

 Offa’s Dyke (Phase 1)

 Industrial development (Phase 2)

 Remediation and agricultural (Phase 3)

The earliest phase recognised dates to the Early Medieval period, at a time when Offa’s Dyke was being constructed and in operation. Recent chronometric evidence for this imposing structure, at Chirk, suggests that this linear earthwork could date from the late Roman period, between the 5th and 7th century.13 The accepted date for the construction and use of the dyke though is mid-8th century (Hill & Worthington 2003).

During the latter part of the medieval period, the area around Trefonen becomes an important quarrying and mining area. Limestone extraction in the form of surface scowling for building stone and the production of agricultural lime is evident across most of the southern section of the field where the proposed development area is located. Along with quarrying, there appears to have been processing areas located to the east of the field within fields that extend to Oswestry Road (see Plates 3 to 5); however, little is known on what these earthworks are and how they functioned.

The final phase, the reverting back to an agricultural regime occurs during the latter part of the 19th century. There is clear evidence of ridge and furrow; however, the author of this report suggests that this feature could be much earlier and that surface scowling within this area ended during the 18th century (if not earlier).

12.0 RECOMMENDATIONS AND OBSERVATIONS

It is the view of Dr George Nash that the proposed development will directly and indirectly impact upon the archaeology and cultural heritage that lies both inside and outside its boundary. In essence, there are acute setting issues between the proposed development and Offa’s Dyke. Moreover, within the eastern area of the proposed development (<5m) is the possibility of the subsurface remains of a linear ditch that belongs to the Dyke complex. Any development within this area could inflict substantial harm to the (remnant) Dyke complex.

In summary, and quoting NPPF, paragraph 133, the proposed development exposes a number of fundamental issues, in particular:

Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss……

13 http://www.bbc.co.uk/news/uk-wales-mid-wales-26921202 PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 19 Heritage Statement April 2014

In addition to issues between the proposed development and Offa’s Dyke, one needs to consider the industrial working in and around the proposed development. There are still many research questions concerning what each of the features represent, their relationship with features (earthworks) within the northern part of Trefonen and their date. Based on aerial photography (commissioned for this report), extensive [post-medieval] ridge and furrow marks are clearly visible across most of the field, including the proposed development area (Plate 6).

The author of this report identifies and recommends the following:

 The northern part of Trefonen (and its hinterlands) constitutes an important archaeology resource that includes a series of visible earthworks that represent three clear periods of use/occupation. Little of this landscape is understood, in particular the hinterlands either side of Offa’s Dyke and the medieval/post-medieval industrial landscape;

 Within the proposed development site boundary are visible surface industrial workings (scowls), along with overlying post-medieval ridge and furrow marks. Any development would cause severe harm to these and any subsurface archaeological features, structures and deposits; thus destroying potentially important medieval and post-medieval remains;

 There are clear setting issues between Offa’s Dyke and the proposed development. The north-south route of the visible intact sections of the Dyke stands several metres away from the northern boundary line of the proposed development. The proposed development contravenes English Heritage’s stance on setting (e.g. The Setting of Heritage Assets 2011). It is advised that a Landscape and Visual Impact Assessment be undertaken by a suitability qualified organisation. In addition to this, it is advised that a detailed Settings Assessment report is undertaken to determine the facets of heritage value that contribute to the monument’s significance and its setting at this location.

 Based on the above criteria, the proposed development should be rejected on the grounds that substantial harm could be inflicted on surface and subsurface remains that are associated with the western section of the Dyke (i.e. the ditch on the western side of the monument) (see Figure 7).

 Both RESCUE and the Prehistoric Society have each expressed concern over this and other development projects in this part of the county, RESCUE remarking:

The application is seriously deficient in that it does not include either the required heritage statement or an assessment of the archaeological significance of the site. On this basis, the application should not have been validated, and it does not contain sufficient information to enable a determination to be made. RESCUE therefore strongly recommends that this application be either refused, or that any planning decision should be deferred until sufficient documentation is submitted in line with national planning policy, and further opportunities for consideration are allowed.

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 20 Heritage Statement April 2014

 Given the fact that other planning applications have been recently submitted to develop in and around the village, Trefonen is slowly but surely losing its cultural heritage identity.

It should be noted that English Heritage regard Offa’s Dyke (and its rural setting) as Offa’s Dyke is the largest, most impressive, and most complete purpose built early medieval monument in Western Europe. It is the largest civil engineering project ever undertaken by an Anglo-Saxon state, and the most impressive Anglo-Saxon monument to now survive in the UK.

Given these facts, I am concerned that current views on this and other proposed developments with Trefonen (and elsewhere) are slowly eroding the heritage value of this internationally-important site, as well as seriously damaging the character and distinctiveness of this village. The OSLPAN (dated November 2004) clearly stated that Trefonen had witnessed more than sufficient development over the last few years and had reached its ‘environmental capacity’.

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 21 Heritage Statement April 2014

13.0 REFERENCES CONSULTED

Davis, D., Undated. Welsh place-names and their meanings. The Cambrian News, Aberystwyth.

Department for Communities and Local Government. National Planning Policy Framework (NPPF). March 2012.

English Heritage, 2006. Understanding Historic Buildings: A guide to good recording practice.

English Heritage 2011a. Understanding Place: Conservation Area Designation, Appraisal and Management. London: English Heritage.

English Heritage, 2011b. Seeing the History in the View: A Method for Assessing Heritage Significance within Views. London: English Heritage.

English Heritage, 2011c. The Setting of Heritage Assets.

Finberg, H.P.R., 1961. The Early Charters of the West Midlands. Leicester: Leicester University Press.

Frost, P. 2014. Land odd Oswestry Road/Chapel Lane, Trefonen, Shropshire. Castlering Archaeology. Report No. 436.

Hill, D. & Worthington, M., 2003. Offa’s Dyke: History and Guide. Gloucester: Tempus Publishing.

Malim, T. & Hayes, L., 2008. The Date and Nature of Wat’s Dyke. Anglo-Saxon Studies in Archaeology and History 15, 147-79.

Thomas, R.D., 1939. Industries of the Morda Valley: Life and Labour in the 19th Century. Border Counties Advertiser.

Wigley, A., 2007. The Shropshire Historic Landscape Character Assessment. English Heritage & Shropshire County Council (online resource).

Cartography

Cassini Map of Shropshire, dated c. 1838

Oswestry Rural Parish Tithe Map of 1838

1st Edition 25” (scale 1: 2500) Ordnance Survey map of 1870

2nd Edition 25” (scale 1: 2500) Ordnance Survey map of 1881

3rd Edition 25” (scale 1: 2500) Ordnance Survey map of 1901

4th Edition 25” (scale 1: 2500) Ordnance Survey map of 1926

National Grid Plan (scale 1: 10000) Ordnance Survey map of 1970 PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 22 Heritage Statement April 2014

14.0 CLOSURE

This report has been prepared with all reasonable skill, care and diligence, and taking account of the manpower and resources devoted to it by agreement with the campaign group. Information reported herein is based on the interpretation of data collected and has been accepted in good faith as being accurate and valid.

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 23 Heritage Statement April 2014

PLATES

AERIAL IMAGES

Plate 1. Oblique aerial image of the northern part of the Trefonen settlement, looking north (image taken in April 2014)

Plate 2. Oblique aerial image showing the Application Site, looking east

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 24 Heritage Statement April 2014

Plate 3. Oblique aerial image showing the Application Site, looking NE

Plate 4. Plate 3, using D-stretch, revealing a number of features including the clear western line of Offa’s Dyke and late post-medieval industrial features within the surrounding fields, looking NE.

Plate 5. Aerial view of the Application Site showing clear ridge and furrow marks; neighbouring field reveals industrial workings, looking east PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 25 Heritage Statement April 2014

Plate 6. Oblique aerial image of the Application site and the neighbouring fields, looking south

HERITAGE ASSETS

Plate 7. The western gable of All Saints Church, facing Oswestry Road, looking east

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 26 Heritage Statement April 2014

Plate 8, Burial ground located south of Chapel Cottage; rectangular plot delineates a section of Offa’s Dyke

Plate 9. Chapel Cottage, mid-19th century in date, looking NW

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 27 Heritage Statement April 2014

Plate 10. Rose Cottage, located on the eastern side of Chapel Lane, looking north

Plate 11. Plas Offa (18th/19th century in date), looking north-east

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 28 Heritage Statement April 2014

Plat 12. Plas Dymplling (18th/19th century in date), looking south-east

Plate 13. Barns belonging to Fron Farm, looking south

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 29 Heritage Statement April 2014

Plate 14. Ancient bridal way, delineated on its western side by a drystone wall, looking south

Plate 15. Fron Cottages; new terrace with earlier foundations, looking west PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 30 Heritage Statement April 2014

Plate 16. East-west line of a revetted post-medieval leat, looking east

Plate 17. Fenced section of Offa’s Dyke, overlooking the Application Site, looking south PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 31 Heritage Statement April 2014

Plate 18. Remnants of an ancient field boundary, located within a field immediately east of Fron Farm, looking west

Plate 19. Field boundary wall delineating the western line of Chapel Lane, looking north PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 32 Heritage Statement April 2014

Plate 20. Stone steps leading from Chapel Lane to the eastern line of Offa’s Dyke, looking west

Plate 21. Clear section of Offa’s Dyke, looking north PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 33 Heritage Statement April 2014

Plate 22. Western cut of the dyke within Chapel Lane, looking NW

Plate 23. Eastern cut of the dyke within Chapel Lane, looking SE PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 34 Heritage Statement April 2014

Plate 24. Southern section of Offa’s Dyke and the plot belonging to Church View. Application Site is located to the right, looking south

Plate 25. Elevated plot section belonging to Church View, looking north PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 35 Heritage Statement April 2014

Plate 26. Elevated plot section belonging to Offa Cottage, looking north

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 36 Heritage Statement April 2014

Appendix 1: The Prehistoric Society’s Response

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 37 Heritage Statement April 2014

Appendix 2: RESCUE’S CORRESPONDANCE

15a Bull Plain, Hertford Hertfordshire, SG14 1DX

1.0 TELEPHONE: 01992 553377

Office hours:: Tuesday and Friday mornings. Otherwise please leave a message on the answerphone. th 4 March 2014 [email protected]

Mark Perry (Senior Planner) www,rescue-archaeology.org.uk Development Management Shropshire Council WWW Castle View Oswestry SY11 1JR

Dear Mr Perry

Planning Application 14/00536/OUT

RESCUE, The British Archaeological Trust objects to this application, believing it to be seriously deficient in that it does not include either a heritage statement or an assessment of the archaeological significance of the site.

This application affects an area close to a Scheduled Monument (Offa's Dyke) and evidence suggests that there may be other heritage assets detrimentally affected by the proposal, including an important 'stone hedge' thought to be at least 300 years old, and a construction more common in the south- west and north of England and the first recorded in this area. Other hedges in the immediate area show evidence of layering and require further investigation to establish their historic environment value. These may all form a boundary or marker that relates to the Dyke itself. In addition it is reported that there are various earthworks on the site which may or may not be archaeological in origin. The lack of a heritage statement and an archaeological assessment means that it is not possible to adequately understand the impact that the proposal would have on either Offa's Dyke, the footpath, the 'stone hedge' or other potential heritage assets. In these circumstances it is not possible for an informed judgement as to the sites significance to be made.

RESCUE notes that the design and access statement records that an assessment has been commissioned, however NPPF (para 128 - below) requires that this information is available to inform the determination of an application.

128 In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 38 Heritage Statement April 2014

Yours sincerely

Jo Caruth Secretary, RESCUE, The British Archaeological Trust

RESCUE is a non-political organisation dedicated to supporting archaeology and archaeologists in Britain and abroad (www.rescue-archaeology.org.uk). We do not receive any state support and are entirely dependent on the contributions of our members to support our work. PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 39 Heritage Statement April 2014

Appendix 3: CBA’S CORRESPONDANCE

PROPOSED DEVELOPMENT AT WHITRIDGE WAY DEVELOPMENT, TREFONEN 40 Heritage Statement April 2014