The Range, Land off the A350, Chippenham, Wiltshire

Addendum to Heritage Assessment

March 2015

The Range, Land off A350, Chippenham Addendum to Heritage Assessment First Industrial Developments

1. INTRODUCTION 1.1. We have re-evaluated the impacts on the designated heritage assets affected by the proposed development on land off the A350, Chippenham as requested by English Heritage and the Wiltshire Conservation Officer in their comments to Wiltshire Council.

1.2. The Conservation Officer argues that the development proposed, as currently configured, would cause significant harm to the conservation area and to the settings of the listed buildings contrary to the provisions of the NPPF, associated guidance and the Wiltshire Core Strategy policies 57 & 58. We were made aware that the Conservation officer had not visited the site at the time of her response.

1.3. The English Heritage Inspector considers that this development will cause considerable harm to the significance of the archaeological remains of the Romano- British settlement on the site. As far as we are aware English Heritage Inspector had not visited the excavations at the time of her response and based her assessment of the site’s significance on incomplete information. She further states that there would be harm to the setting of Allington Conservation Area and Bolehyde Manor and should be refused on the grounds that it does not comply with Paragraphs 128, 132, 134 and 137 of the NPPF.

1.4. Additional assessment work has been undertaken to address the comments of the Wiltshire Council Conservation Officer and English Heritage Inspector. This has included an intensive site walkover and review of new material considerations.

1.5. This reassessment addresses the specific concerns raised by the Conservation Officer and English Heritage by taking into account the English Heritage guidance (2011) but also recent case law on how heritage duties have to be applied including Barnwell 2014 and Forge Field 2014. In addition, the appeal decision by the Secretary of State in respect of Land at Javelin Park, Near Haresfield, Gloucestershire in January 2015 is relevant, as this highlights the lack of relevance of inter-visibility to harm to the significance of the setting of a designated asset. This has resulted in a change to the conclusions relating to impacts on designated heritage assets reached in the Heritage Assessment dated November 2014.

2. THE POLICY CONTEXT

THE PLANNING (LISTED BUILDINGS AND CONSERVATION AREAS) ACT 1990 2.1. This Act states that:

“In considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.” (s.66.1).

2.2. This is a statutory duty, and recent High Court Judgments have established that the intention is that decision makers should not simply give “careful consideration” to the desirability of preserving

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listed buildings and their settings, but “considerable importance and weight” (Barnwell Manor Wind Energy Ltd v. East Northamptonshire District Council, 2014, Forge Field Society v. Sevenoaks District Council, 2014).

NATIONAL POLICY: NATIONAL PLANNING POLICY FRAMEWORK (NPPF) 2.3. The NPPF is clear in defining the protection of the historic environment as an integral part of the ‘golden thread’ of ‘sustainable development’.

2.4. In para.7 it is stated that to achieve sustainable development the planning system must perform a number of roles, including “an environmental role – contribution to protecting and enhancing our natural, built and historic environment….”

2.5. Effectively the NPPF defines sustainable development as development that satisfies the Framework set out within it, and this includes policies set out in Section 12 ‘Conserving and enhancing the historic environment’.

2.6. The NPPF defines ‘Significance’ as follows: “The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic.

Significance derives not only from a heritage asset’s physical presence, but also from its setting” (Annex 2: Glossary)

2.7. Para 131 of NPPF states that “In determining planning applications, local planning authorities should take account of: the desirability of sustaining and enhancing the significance of heritage assets…” and “…the desirability of new development making a positive contribution to local character and distinctiveness”.

2.8. Para 132 reiterates the Act in stating that “great weight” should be given to the conservation of heritage assets and their significance, clarifying that “significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting”. It states that: “As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification.”

2.9. When read in conjunction with the Act and the presumption against harm to the significance of heritage assets, it seems that any such ‘clear and convincing justification’ for development must be given in terms of factors having considerable weight sufficient to outweigh the Act.

2.10. Para 134 of the NPPF states where the development would lead to less than substantial harm that harm should be “weighed against the public benefits of the proposal, including securing its optimum viable use”. It is noted here that the reference to ‘optimum viable use’ applies to the heritage asset in question, and not to the application site.

2.11. Para 135 states that “The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgment will be required having regard to the scale of any harm or loss and the significance of the heritage asset.” relevance

2.12. Para 137 states that “Local planning authorities should look for opportunities for new development …. within the setting of heritage assets to enhance or better reveal their significance.” relevance

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LOCAL POLICY: THE WILTSHIRE CORE STRATEGY DEVELOPMENT PLAN DOCUMENT 2.13. Since preparation of the Environmental Statement, The Wiltshire Core Strategy Development Plan Document was formally adopted by Wiltshire Council on January 20th 2015 and replaces policies in the North Wiltshire Local Plan 2011. Policies HE5-HE8 of the Local Plan have been replaced by Core Policies 57 and 58

Core Policy 57: Ensuring high quality design and place shaping A high standard of design is required in all new developments, including extensions, alterations, and changes of use of existing buildings. Development is expected to create a strong sense of place through drawing on the local context and being complimentary to the locality. Applications for new development must be accompanied by appropriate information to demonstrate how the proposal will make a positive contribution to the character of Wiltshire through: i. Enhancing local distinctiveness by responding to the value of the natural and historic environment, relating positively to its landscape setting and the existing pattern of development and responding to local topography by ensuring that important views into, within and out of the site are to be retained and enhanced iii. Responding positively to the existing townscape and landscape features in terms of building layouts, built form, height, mass, scale, building line, plot size, elevational design, materials streetscape and rooflines to effectively integrate the building into its setting iv. Being sympathetic to and conserving historic buildings and historic landscapes

Core Policy 58 Ensuring the conservation of the historic environment

“aims to ensure that Wiltshire’s important monuments, sites and landscapes and areas of historic and built heritage significance are protected and enhanced in order that they continue to make an important contribution to Wiltshire’s environment and quality of life.”

Development should protect, conserve and where possible enhance the historic environment. Designated heritage assets and their settings will be conserved, and where appropriate enhanced in a manner appropriate to their significance, including:

i. Nationally significant archaeological remains ii. World Heritage Sites within and adjacent to Wiltshire iii. Buildings and structures of special architectural or historic interest iv. The special character or appearance of conservation areas v. Historic parks and gardens vi. Important landscapes, including registered battlefields and townscapes.

2.14. The Core Strategy goes on to say that

“Distinctive elements of Wiltshire’s historic environment, including non-designated heritage assets, which contribute to a sense of local character and identity will be conserved, and where possible enhanced. The potential contribution of these heritage assets towards wider social, cultural, economic and environmental benefits will also be utilised where this can be delivered in a sensitive and appropriate manner in accordance

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with Core Policy 57. Heritage assets at risk will be monitored and development proposals that improve their condition will be encouraged. The advice of statutory and local consultees will be sought in consideration of such applications. (6.130)

2.15. It also states that

“Designation of a Conservation Area, listed building, or scheduled ancient monument does not preclude the possibility of new development and the council is committed to working pragmatically with owners to find positive solutions which will allow adaptation of such buildings to reflect modern living aspirations. ….In considering applications for new development in such areas, the council will seek to ensure that the form, scale, design and materials of new buildings are complementary to the historic context.” (6.131)

2.16. The impact of the proposed development in all cases is indirect as no physical alteration will be made to any of the Listed Buildings or the Conservation Area. It is necessary therefore to establish whether their setting contributes to their significance and if that significance is changed by any changes to that setting

3. CASE LAW 3.1. A number of recent appeals and attendant decisions by the Secretary of State regarding the implementation of policies relating to the setting of designated heritage assets provide additional guidance in the application of said policies. The most relevant of these are:

 Barnwell Manor Wind Energy Limited vs. East Northamptonshire District Council, English Heritage, National Trust & The Secretary of State for Communities & Local Government (18th February 2014) [Hereafter called Barnwell Manor]  The Queen (on the application of The Forge Field Society, Martin Barraud & Robert Rees) vs. Sevenoaks District Council (12 June 2014) [Hereafter called Forge Field]

3.2. Barnwell Manor established that whether substantial or less than substantial harm on the setting of a designated heritage asset is proven, considerable weight should still be given to the “the desirability of preserving the setting of all listed buildings, including Grade II listed buildings”. Forge Field further establishes this position stressing that there is a statutory requirement to preserve the setting of a listed of a listed building noting that “preserving means doing no harm”.

3.3. The Forge Field decision also notes however, that whilst the presumption is a statutory one, “It can be outweighed by material considerations powerful enough to do so”. Importantly it notes that “An authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of a statutory presumption in favour of preservation”. In short, the case for greater planning benefit can only be made if the presumption for preservation is fully recognised in the assessment.

4. MATERIAL CONSIDERATIONS Appeal by Urbaser Balfour Beatty - Land At Javelin Park, Near Haresfield, Gloucestershire Application Ref: 12/0008/STMAJW (January 2015) [Hereafter called Javelin Park]

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4.1. In the recent Javelin Park appeal (January 2015), the Secretary of State found that there had been “continual conflation of visual change within the setting of heritage assets with harm to the significance of those assets”. The English Heritage guidance on assessing impacts on setting specifically requires a staged process that includes “Assessment Step 2: Assessing Whether, How And To What Degree Settings Make A Contribution To The Significance Of The Heritage Asset(s)”. Visual change does not necessarily cause harm to the setting of a heritage asset and the significance of the setting must be assessed in order to justify any identification of harm.

5. GEOLOGY AND TOPOGRAPHY 5.1. The application site lies within the Limestone Lowland Landscape Type, 16A: Malmesbury-Corsham Limestone Lowlands. The area is characterised by gently undulating lowland farmland, a peaceful and rural landscape with a mix of permanent pasture and arable farmland. Settlements in the form of historic market towns, villages and scattered farmsteads distributed throughout the type linked by network of rural roads. Traditional buildings of local limestone buildings are an outstanding feature. Villages are peaceful and rural, often centred around a village green, pond or area of common land. Buildings are traditional in style, with many dating from the 17th and 18th centuries. The A350, which defines the western edge of the town and acts as a main north/south route through the area.

5.2. The Wiltshire Historic Landscape Characterisation project began in 2012 and is due to be completed in November 2015. Characterisation of the application site is not available.

6. DESIGNATED ASSETS 6.1. The Site lies within view of the Allington Conservation Area and Listed Buildings within the Conservation Area. A Roman villa within the Site has recently been added to the list of scheduled monuments (NHL 1425267). An appeal against the scheduling will be lodged on Tuesday March 25th to DCMS by Prospect Archaeology. The English Heritage Advice Report dated February 26th 2015) in support of the scheduling contained factual errors about the Roman site, resulting in an inflated assessment of its significance, based on erroneous assumptions. The haste with which this application, and subsequent designation, was made has meant that additional information from site evaluation work could not be taken into account when assessing the full significance of the site. No other designated heritage assets are located within the Site.

7. CONSERVATION AREAS 7.1. The Conservation Areas of Chippenham Kington St Michael and Kington Langley lie more than 2km from the site and are not considered further.

7.2. The village of Allington lies north-west of the application site and its Conservation Area, first designated in 1998, encompasses nearly the entire village, many of whose buildings are listed (http://www.wiltshire.gov.uk/allington-conservation-area-statement.pdf; North Wiltshire District Council 2002).

7.3. Almost all of the Conservation Area lies within 1.5km of the application site and about one third is within 1km of the application site. When Allington Conservation Area was reviewed in 2002 it was extended to the south and west. It comprises a block of land that straddles The Lane and extends north from the A420 to include land around Allington Grange at the north end of the Conservation Area and beyond the 1.5km study area.

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7.4. Despite its close proximity to the A350 and Chippenham, Allington sits in relative isolation and the key elements which define its special interest and character include the dispersed settlement pattern in a predominantly rural landscape setting. The settlement and surrounding land belonged to the manor of Allington, in the parish of Chippenham, now Chippenham Without. Bolehyde Manor lay within the adjacent parish of Kington St Michael until the boundary changes of the early 1970s; historically it is not part of the same settlement.

7.5. In 2002 when the Conservation Area Statement was prepared much of the land within the Conservation Area was pasture (Fig. 2.3). Only a few areas of pasture survive in 2015, mainly surrounding residential properties, with the remainder now under arable cultivation.

7.6. The Conservation Area has been divided into five Character Areas which comprise Zone 1, The Lane itself, Zones 2, 3, 4 and 6 to the west of The Lane and Zone 5 to the east. Access through the Conservation Area is along Zone 1 which forms the central spine to the area. Paths CHIW3, 12 and 19 to the east of The Lane cross Zone 5. To the west of The Lane path CHIW 2 runs south through Zones 4 and 6. Path CHIW1 runs north-west through Zone 6, beyond the study area.

7.7. The proposed development site may be seen from within the Conservation Area at points along footpaths CHIW2 on higher ground to the west of The Lane, and CHIW19 and CHIW3 to the east of The Lane. Views of the Site from Footpath CHIW12 which runs along the edge of the Conservation Area are obscured along the short section before the bend, except at one point where there is a gate in the tall hedge. The area beyond the bend lies outside the Conservation Area boundary.

7.8. Views into and out of the Conservation Area are discussed in more detail in the Landscape and Visual Impact Assessment. The Conservation Area Statement Key Views are identified in Figure 2.3 of the Statement and equate to views 15, 19, 21 and 22 in the Landscape and Visual Impact Assessment.

8. LISTED BUILDINGS 8.1. There are 30 listed buildings within 1.5km of the application site, fourteen of which are situated within the Allington Conservation Area, and four lie within 500m of the application site (LBs 24-27). One is listed Grade II* (LB15/16), the remainder are listed Grade II.

Ref. NHLE No NGR Address Grade Distance from Site (km)

LB14 1199309 ST 89246 75615 Dovecote SW of Bolehyde Manor II 1.2

LB15 1198976 ST 89263 75620 Bolehyde Manor II* 1.2

LB16 1283450 ST 89260 75621 Bolehyde Manor II* 1.2

LB17 1199312 ST 89288 75629 Coach house E of Bolehyde Manor+ II 1.2 gate piers

LB18 1022901 ST 89297 75623 Pair of summer houses E of Bolehyde II 1.2

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Manor

LB19 1022900 ST 89276 75596 Gate lodges, piers, gates & wall N of II 1.2 E lodge at Bolehyde Manor

LB20 1199290 ST 89036 75388 The Pitts II 1.2

LB21 1363562 ST 89301 75378 Allington House II 1

LB22 1363561 ST 89198 75154 Foxhill House II 1.1

LB23 1022899 ST 89411 75212 Ivy Cottage II 0.75

LB24 1022898 ST 89512 75124 Barn NW of Allington Manor II 0.5 Farmhouse

LB25 1199287 ST8954975166 Barn N of Allington Manor II 0.5 Farmhouse

LB26 1022897 ST8956175094 Allington Manor Farmhouse II 0.5

LB27 1199278 ST8965674962 The Cottage II 0.5

Table 1 Listed buildings and their distance from the proposed development site

BOLEHYDE MANOR (LB14-LB19) 8.2. Bolehyde Manor is Listed Grade II* and lies at the north end of Allington Lane at a distance of c.1.2km from the Site. The property was formerly in the adjacent parish of Kington St Michael and historically was not part of Allington, until the early 1970s when the parish boundary was moved. As a result of this boundary change, the property appears twice in the National Heritage List, relating to its change of parish. It was originally listed as Bulidge House in Kington St Michael (NHLE 1198976), although the name Bolehyde can be found as early as 1606 in documentary sources.

8.3. The house is described in the listing (NHLE 1283450) as being mid-17th century date with earlier origins. The main elevation of the house faces away from the Site and overlooks the road and ha-ha (of relatively modern date) towards the Pitts Cottages on the opposite side of a shallow valley.

8.4. Several structures within the manor complex are Listed Grade II for their group value. These include a pair of gate lodges, piers, gates and wall (NHLE 1022900) situated close to the road, to the south of the Manor House. The mid C17 dovecote (NHLE 1199309) is situated south of the house close to the road and there are ancillary outbuildings buildings to the north and east of the house.

8.5. The gardens lie to the south-east of the house and gate lodges, and are enclosed by trees and hedges. Two summer houses within the garden are also listed (NHLE 1022901). A swimming pool, surrounded by mature trees obscures views from the house towards the Site.

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Pl. 1 Bolehyde Manor looking north-west from footpath CHIW3 through tree-lined hedgerow

8.6. Views are further obscured by trees along a hedgeline noted in the Conservation Area Statement and depicted on Fig. 2 2 of that document (significant trees and foliage).

8.7. To the north of the older outbuildings are at least four modern barns and outbuildings of breezeblock and corrugated iron construction.

Pl. 2 Modern barns and outbuildings to the north of Bolehyde Manor, looking south-east from footpath CHW19

8.8. There are views of the proposed development site in the distance from the public footpath north of Bolehyde Manor CWI19.

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Pl. 3 View south-east from footpath CHWI9 to the east of Bolehyde Manor looking towards the proposed development site

ALLINGTON HOUSE (LB21) 8.9. Allington House sits on the west side of a bend in The Lane, below Bolehyde Manor and approximately the same distance north of Allington Manor Farm. The property is described in the listing as a being a mid C18 and early C19, ashlar and rubble stone building two storeys in height, with stone-tiled roofs.

8.10. It overlooks the lower valley to the east of The Lane, looking directly towards the proposed development. However, the view is obscured by a large tree at the entrance to the property and a thick hedge.

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Pl. 4 Entrance to Allington House from The Lane, looking NW, showing trees which obscure the view from the house over the valley to the south-east

8.11. While there is an uninterrupted view from the driveway which is aligned with a gate into the field on the opposite side of the road, views from the house itself are obstructed by the mature trees along the street boundary.

THE PITTS (LB20) 8.12. Immediately adjacent to the Allington House driveway is the private driveway that leads up the slope to The Pitts. The house is situated north-west of the main cluster of houses along Main Street and its main elevation faces south-west. The 2-storey C17 house, built in rubble stone, is much altered; the front elevation is rendered and the windows are all 20th century replacements.

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Pl. 5 The Pitts. Front elevation facing south-west.

Pl. 6 View of The Pitts from bridleway CWI2 showing the south-east gable that overlooks the Site from a single small ground-floor window.

8.13. The south-east gable is the only part of the house that faces towards the proposed development site. There are views along the driveway, through the gap in the hedge, overlooking the site in the far distance, from the single small window at ground floor level. The associated gardens to the north-east of the house are enclosed with high hedges and the site is not visible from the rear of the house.

8.14. Public bridleway (CHIW2) crosses the driveway close to the entrance to the Pitts Cottage and there are the same uninterrupted views of the Site from the bridleway at this point on its route, as from Pitts Cottage. Views from the bridleway in front of the property would, however, be transient.

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Pl. 7 View from bridleway CHIW2 in front of The Pitts looking south through the gap in the hedgerow

8.15. Views from the high point to the east of Pitts Cottages overlooking Allington are not exclusively rural with the townscape of Chippenham in the middle distance including the Cepen Park North housing development, as well as Bumpers Farm Industrial estate. Long distance views show the hills to the south of Chippenham, which according to the Conservation Area Statement includes the White Horse (some 11 miles away as the crow flies). This might be possible on a clear day but the proposed development lies south-east of this point and would not interfere with this long-distance vista.

FOXHILL HOUSE (LB22) 8.16. Foxhill House (formerly listed as Shipways Farm) lies below bridleway CHIW2 and north-west of The Lane. It is described in the listing as a later C17 and C18 rubble stone farmhouse, with imitation stone-tile roofs. It has 2 storeys and attic, is L-plan with C17 original range and earlier C18 cross wing. The house was heavily restored c1980 with C20 imitation stone openings to the entire entrance front. There are outbuildings to its east, which partially mask its views in that direction towards the proposed development site.

8.17. There are trees to the immediate south of the house which partially obscure the view, although when not in leaf there is greater visibility. Views from this property are similar to those from Pitts Cottage higher up the slope but the main aspect of the building faces the town and Bumper Farm Industrial Estate.

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Pl. 8 Foxhill House from CHIW2 looking south over the rear elevation. Trees beyond partially obscure the roofs of Chippenham and Bumpers Farm Industrial Estate (middle horizon, right)

Pl. 9 View from bridleway CHIW2 looking SE towards Cepen Park North and Chippenham, and the Site. Note steeple of St Paul’s church adjacent to an electricity pylon.

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IVY COTTAGE (LB23) 8.18. Close to the bottom of the hill on the east side of The Lane, Ivy Cottage is situated north of Manor House Farm and is c.0.75km from the Site boundary. It is a rubble stone C18 house 1/1/2 storeys in height. The front elevation of the property faces the street.

8.19. The rear garden is enclosed by a low boundary wall and views across the field towards the proposed development site are only partially screened by outbuildings and the garden wall.

Pl. 10 Ivy Cottage from footpath CHIW3, looking south

Pl. 11 View from Ivy Cottage looking south-east towards the Golf Club and the Site from footpath CHIW3, to the east of Ivy Cottage

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ALLINGTON MANOR HOUSE AND BARNS (LBS 24-26) 8.20. Allington Manor House is south of Ivy Cottage. It is set back from The Lane, with a lawned area and wall in front of the house, facing south-west. This is a mid C18 farmhouse incorporating fragments from the C17 manor. It is a two- storey building with attic and faces The Lane. The rear of the house overlooks an enclosed walled garden although views from the windows in the south-east gable overlook the proposed development site. There are intervening hedges that serve to obscure the view.

8.21. Two listed barns that form part of the farmyard to the north and north-east of the manor house. More modern barns and outbuildings lie to the north and north-east of the C18 barns.

8.22. The only part of the house that directly overlooks the Site is the south gable first floor window. The listed barns to the north of the house are also buffered by the trees in the gardens, as well as the house itself.

Pl. 12 View north-west towards Allington Manor house from footpath CHIW12 showing partial screening of property by walls and trees and the first-floor window of the southwest gable

THE COTTAGE (LB27) 8.23. The Cottage at the south end of The Lane is the closest Listed Building to the Site. It is parallel to The White Cottage which is not listed and the north-east gable ends of both properties face the Site. This mid C18 two-storey house, is built parallel to the track that is footpath CHIW12. The front elevation overlooks the garden and the back wall of the adjacent house (which is built parallel to the Cottage but is not a listed building).

8.24. One gable end faces The Lane and the other overlooks the proposed development site. The gable which overlooks the proposed development site is blind, with no windows. The gardens to the rear of the two properties afford a buffer between the houses and the open field to the east. These are

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enclosed by a hedge and several outbuildings, which partially screen the view towards the proposed development site.

Pl. 13 The Cottage gable end looking west from footpath CHIW12

Pl. 14 Eastern curtilage boundary of The Cottage and adjacent property The White Cottage, looking north-west.

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9. ASSESSMENT 9.1. Paragraphs 133 and 134 of NPPF describe the requirement to consider the impact of a proposed development on the significance of a designated heritage asset. Its significance derives not only from its physical presence, but also from its setting. Furthermore, significance can be harmed or lost not only through alteration or destruction of the heritage asset but by development within its setting. NPPF defines the setting of an asset 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.’

SIGNIFICANCE OF HERITAGE ASSETS 9.2. The NPPF defines the ‘significance’ of heritage assets as being: “the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting” (NPPF 2012, Annex 2).

9.3. The principal guidance for understanding heritage values is set out in ‘Conservation Principles’ (English Heritage 2008) (paras 30 to 60). Heritage significance is divided into four categories or ‘values’: evidential, historical, aesthetic, and communal.

9.4. Evidential value “derives from the potential of a place to yield evidence about past human activity” (para 35). This refers to the role of a heritage asset in providing a unique material record of the past, particularly where written or visual records are lacking. None of the built heritage assets would be directly affected by the proposed development and no further consideration of their evidential value is provided here.

9.5. The recently scheduled Roman settlement site would be directly impacted upon by the proposed development. Evaluation of this monument has established the presence of a multi-phased Roman settlement dating from the 2nd – 4th centuries AD. The settlement remains include elements of a high status farmhouse with at least one room containing a hypocaust system and evidence for associated timber-built buildings of unknown function. Although stone foundations were recorded, they were severely truncated and in places survived to only one-course depth. The absence of large quantities of stone in the fields suggests these buildings were of timber construction on stone footings. No in situ floor surfaces or walls were found to survive; no pre- or post-Roman activity was identified; and no associated field systems were present. The palaeoenvironmental assessment has concluded that there is no evidence for industrial activities taking place and a single hearth-type feature is believed to be a domestic oven. The site has already been severely truncated by ploughing and unless a management agreement can be reached to return the entire scheduled area to pasture, it is expected that ploughing will continue to erode the Roman settlement.

9.6. The hedgerows to be removed by the proposed development are components of past and present human activity in the landscape. The main boundary to be removed is the hedge that bisects the Roman site. Map regression has established that it is later that 1847 but rearrangement of land boundaries took place before 1885 (Field 2014, figs 8-10). The most ancient boundary affected by the proposed development follows the Hardenhuish Brook and defines the parish boundary between Hardenhuish and Chippenham.

9.7. Historical value “derives from the ways in which past people, events and aspects of life can be connected through a place to the present” (para 39). Historical value is subdivided into ‘associative’, which refers to connections with notable persons or events in history, and ‘illustrative’, which

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though closely related to evidential, in providing evidence of the past, depends more on the immediate experience or perception of a heritage asset as a link with the past.

9.8. In an ‘illustrative’ sense the Listed Buildings within Allington Conservation Area, have an historical value and character as examples of particular historic building types, mainly associated with farming.

9.9. The field patterns, hedgerows and trees, and their management as part of the agricultural process, are the product of private enclosure which took place at some point prior to the third quarter of the 18th century. The agricultural land around the Conservation Area has strongly contributed to its illustrative historical value. However, this landscape has been modified since the 18th century, especially in the period after World War II, with shifting and removal of boundaries, as well as a rapid change from pastoral to arable husbandry. The fields of Allington are no more significant than any other fields in the area and therefore their historical value is low.

9.10. The Roman site is a typical example of a high status Roman settlement of which there are numerous examples in Wiltshire and beyond. There is no evidence for continuity of settlement from the Roman to modern periods and the historical value of the settlement identified within the site is low within the parameters of the definition of historical value given in the English Heritage guidance (EH 2008).

9.11. Aesthetic value “derives from the ways in which people draw sensory and intellectual stimulation from a place” (para 46). This is subdivided into ‘design value’ where the aesthetic value results from the conscious design of a landscape or structure, and ‘fortuitous value’ where the way in which a place has evolved over time or fabric has aged, resulting in an attractive appearance.

9.12. The listed buildings represent the vernacular traditions of 17th and 18th century Wiltshire. While there has been conscious design in the layout of individual buildings, especially in the case of Bolehyde Manor and also Allington Manor Farmhouse the appearance of these buildings will not be altered as a result of the proposed development

9.13. The aesthetic value of the Conservation Area and its setting is fortuitous in that the organic form of the rural landscape has not been designed. Both the Conservation Area and its setting have continuously evolved through time, with 20th and 21st century developments in many locations. The aesthetic value of the Conservation Area has been largely maintained despite modern development. The aesthetic value of the setting of the Conservation Area is lower with many modern developments and intrusions present in the nearby urban centre, including Cepen Park North and Bumper Farm Industrial Estate, as well electricity pylons in the immediate vicinity.

9.14. Communal value “derives from the meanings of a place for the people who relate to it, or for whom it figures in the collective experience or memory” (para 53). These include commemorative, symbolic, social and spiritual values, and can be closely related to historical values. This is not considered further as cohesion of the settlement is not going to be disturbed.

CONTRIBUTION OF SETTING TO SIGNIFICANCE OF HERITAGE ASSETS 9.15. ‘The Setting of Heritage Assets’ (English Heritage 2011); provides detailed guidance on how to understand and assess the setting of heritage assets, and forms the basis for the methodology of the evaluation below. The guidance states that “Setting is not a heritage asset, nor a heritage designation” (p 7) and that the significance of the setting to a designated heritage asset needs to be

19 The Range, Land off A350, Chippenham Addendum to Heritage Assessment First Industrial Developments

considered before any assessment of impact can be made. A staged approach is recommended for assessing the implications of development proposals on the significance of heritage assets:

STEP 1: IDENTIFYING THE HERITAGE ASSETS AND THEIR SETTINGS; 9.16. The Heritage Assessment prepared by Prospect Archaeology has identified designated heritage assets comprising the listed buildings and Allington Conservation Area. The listed buildings and Allington Conservation Area are experienced within both the context of their immediate curtilage, and within the wider landscape as described above, which in this instance is predominantly an open rural landscape on the fringes of an urban landscape.

STEP 2: ASSESSING WHETHER, HOW AND TO WHAT DEGREE THESE SETTINGS MAKE A CONTRIBUTION TO THE SIGNIFICANCE OF THE HERITAGE ASSET(S); 9.17. The listed buildings within the search area are not reliant on their settings for their designations. The majority of these properties look inwards to The Lane and that forms the focus of the Conservation Area and community. The exceptions to this are Foxhill House and The Pitts cottages which are outliers to the west of The Lane. Whilst they do have views towards the proposed development site, these views do not contribute to the significance of their settings and the proposed development would not significantly alter the nature of the views from these properties towards the urban centre of Chippenham.

9.18. A key characteristic of Allington Conservation Area identified in the Conservation Area Statement published in 2002 is claimed to be its location within an open rural setting, and the dispersed nature of the farmsteads that form the settlement. However, there are a number of urban and semi-urban developments within view of the Conservation Area, as well as high voltage powerlines and pylons, so its setting cannot be considered to be entirely rural and would not have been so even in 2002.

9.19. Since 2002, the character of the setting has been altered, and trees within the setting have matured. The valley and the slightly undulating land allow intermittent views in the summer and more open views in winter, from the public footpaths that cross the Conservation Area as shown on Figure 10.7 of Appendix 10 of the Environmental Statement. The majority of views of the proposed development site along the public rights of way lie outside the Conservation Area itself.

9.20. The Conservation Area Landscape Analysis (North Wiltshire District Council 2002, fig 2.3) shows extensive areas of pasture both within and beyond the limits of the Conservation Area; this has now almost entirely been transformed to arable agriculture. The following views which could be relevant with regard to the proposed development are identified for protection (ibid. p32 and 34):

a) The view looking east towards Chippenham and beyond from the lane outside the entrance to Allington House and the entrance to the track leading to Pitts Cottages

b) The same easterly view from higher ground on the track to Pitts Cottages

c) The view from the gardens at Bolehyde Manor looking south-easterly across the open countryside towards Chippenham and the White Horse at Cherhill

d) The view from Cepen Park North towards the Conservation Area and its rural setting.

9.21. Each of these views has been considered in the Landscape Visual Impact Assessment (LVIA) and are equivalent to views 19, 21 and 22 of that report (FPCR 2015, fig 10.7). In all cases trees and hedgerows have matured since 2002 and provide greater screening of views both into and out of the Conservation Area.

20 The Range, Land off A350, Chippenham Addendum to Heritage Assessment First Industrial Developments

9.22. View a) above is comparable with viewpoint 21 in the LVIA. The proposed development site is visible in the distance from this viewpoint with dense hedgerows and mature trees to left and right. Cepen Park North and other elements of the urban form are currently visible from this direction. The application site does not form a significant element of the setting of the Conservation Area from this viewpoint.

9.23. View b) listed above is comparable with viewpoint 22 in the LVIA. The distant landscape is screened by mature hedgerows and trees. Occasional glimpses of farmland are possible but not substantial in the views. The glimpsed views of farmland are secondary to the presence of mature planting in the medium distance and the longer distance views to the hills beyond.

9.24. View c) above is the view from the gardens of Bolehyde Manor. There is no public access to this particular view but it is believed there are extremely limited views to or from these gardens due to the heavy mature planting around the garden. Viewpoint 19 in the LVIA is located above Bolehyde on the public footpath. The large trees along the footpath and general topography mean that views into the application site are limited. This view is considered significant to the setting of the Conservation Area.

9.25. View d) Cepen Park North is comparable with viewpoints 1 and 2 in the LVIA. This view is from a modern housing development and cannot be considered as contributing to the significance of the Conservation Area itself. While views of the Conservation Area from some of the private houses in Cepen Park North will be obscured this is not the case for the whole of the Cepen Park North development. Only in the immediate vicinity of the building that there would be any significant interruption of the view . This point is addressed in detail in the response to Wiltshire Council’s landscape officer by FPCR dated March 2015.

STEP 3: ASSESSING THE EFFECT OF THE PROPOSED DEVELOPMENT ON THE SIGNIFICANCE OF THE HERITAGE ASSET(S) 9.26. Evidential Value: There would be no physical intervention to the listed buildings or Conservation Area and hence no loss of their evidential value.

9.27. The scheduled Roman settlement is of evidential value and will suffer a significant impact as a result of development. However, it is also recognised that a similarly significant impact would be suffered by its remaining under arable cultivation. A programme of excavation would allow all elements of the Roman settlement to be archaeologically recorded, analysed and reported upon, providing a better understanding of the role it played in the local Roman economy and settlement pattern, adding to our understanding of the period.

9.28. The loss of hedgerows does not affect a designated heritage asset and is therefore outside the scope of the assessment of harm required by the NPPF paragraph 134. Loss of hedgerows would require consideration under the terms of the Hedgerows Act 1997 and it is understood this will be covered in the ecology report.

9.29. Historical Illustrative Value: The open green space, views towards the heritage asset, and the surrounding landscape character all play an important role in the setting of Allington Conservation Area. This aspect of its setting has substantially altered in last 50 years with construction of the A350 bypass and extension of the urban footprint of Chippenham. The proposed development would not substantially alter the current setting of Allington Conservation Area as the urban form of Chippenham is already evident in the middle distance.

21 The Range, Land off A350, Chippenham Addendum to Heritage Assessment First Industrial Developments

9.30. Aesthetic Value: There are few distant views of Allington Conservation Area because it is enclosed within its own small valley. Views from the Cepen Park North housing estate and from the golf course have been identified (LVIA views 1, 2 and 13). As the proposed development lies adjacent to the A350 the aesthetic value of Allington Conservation Area would not be compromised and its rural setting would remain unaltered.

9.31. The Conservation Area is not a focal point in the surrounding landscape and is not easily identified from surrounding viewpoints

STEP 4: MITIGATION EXPLORING HOW TO MAXIMISE ENHANCEMENT AND AVOID OR MINIMISE HARM; 9.32. There is no impact on the listed buildings and no mitigation is proposed

9.33. The application site is an extension of the rural setting of the Conservation Area but is not an essential part of that setting; Allington will retain a rural setting regardless of development within the application site. The application site does not therefore contribute to the significance of the setting of the Conservation Area, albeit development will incur a visual change. However, additional screening proposed as part of the development will limit the impact of visual changes to some degree.

9.34. The potential harm to the Scheduled Monument is the same regardless of whether the site is developed or not, the only difference being the speed at which the Roman remains will be lost. The depth of topsoil recorded in January 2015 over the features inside the ditched enclosure was in some places only 0.12m deep. No subsoil horizon survived. This accords with the observation in the 1987 report (Wilcox 1987, p.6) which states that “The bulk of the damage from agricultural practices has already been done, so that the soil stratification down to the level of the natural rock is destroyed.”

9.35. The land is intensively farmed and it is highly likely what little archaeology remains in situ will be completely destroyed within the next 20 years. There is a positive benefit in recording now by means of a condition under a planning approval for development.

STEP 5: MAKE AND DOCUMENT THE DECISION AND MONITOR OUTCOMES. 9.36. This forms a later stage in the process, during and after implementation of the development and is not discussed further in this document.

10. CONCLUSIONS 10.1. With the exception of the scheduled monument, there will be no direct impacts on designated heritage assets. Contrary to the views expressed by the Wiltshire Council Conservation Officer and English Heritage, our assessment of the contribution made by the setting in respect of this application site, concludes that it does not contribute to the significance of the listed buildings of Conservation Area and there is therefore no evidence for harm. There will be visual change to the Conservation Area and this can be mitigated through additional planting as part of the development.

10.2. Allington has historically been inextricably tied to, and dependent upon, the market town of Chippenham. In the past its farms no doubt supplied agricultural produce to both its own inhabitants as well as to the local markets. However, the dramatic changes in agricultural practices since 1945 have resulted in radical changes in land use, the use of buildings within that landscape, and a vast reduction in the number of people employed in agriculture.

22 The Range, Land off A350, Chippenham Addendum to Heritage Assessment First Industrial Developments

10.3. Although the south-eastern edge of the Conservation Area lies only 250m west of the proposed development, the integrity of the Conservation Area and its component parts would not be affected or harmed. While the settlement may still be described as sitting ‘in relative isolation’ (Conservation Area Statement 2002), since its designation in 1998 and the review of 2002 there have been changes to the Conservation Area and its setting. Much of the pasture has been taken into arable cultivation, so it is no longer possible to describe the setting as pastoral. Although the houses in Allington may originally have been associated with farming, many properties are now solely residential in use.

10.4. Changes have also taken place outside the Conservation Area as views out from within the Conservation Area demonstrate. Contrary to the description in the Conservation Area Statement, views are not wholly rural (or ‘pastoral’). There is a mix of urban and industrial elements to the south of the village with the artificial landscape of the golf course to the east. Permission has been granted immediately to the north of the Conservation Area for a solar farm. The farm shop and café, on the A420, immediately south of the Conservation Area, is yet another example of the diversification taking place in the vicinity of Allington. In short, the suggestion that the setting of Allington is entirely rural is a falsehood.

10.5. These elements reflect the changing needs of the community that populates this landscape and the proposed construction of the distribution centre and retail outlet is arguably just another element in this process of change. Furthermore, while the proposed development would represent a visual change it does not follow that it represents an impact on the significance of the setting on the Conservation Area.

10.6. In summary, The English Heritage Guidance on the Setting of Heritage Assets clearly requires the contribution made by the setting of a heritage asset to the significance of that asset to be considered, and it is the impact on the contribution made by the asset’s setting to the asset’s significance which needs consideration, not an assessment of the potential impact on the setting regardless of the contribution it makes (pages 7, 8 and 32 and endnote 8, p. 29).

10.7. This is confirmed by the Javelin Park Appeal (2015) where “the ability to see the proposed development either from the heritage asset itself or from within its setting should not be equated with harm to the significance of the asset” and “to what extent, the proposed development would affect the contribution that setting makes to the significance of the heritage asset” (para. 285). The significance of setting on the designation of the Conservation Area is recognised but the proposed development will not affect this significance which will remain primarily rural with middle and long- distance views of the urban and commercial activity reflecting the village’s position as associated with but ancillary to Chippenham. The proposed development would therefore result in No Adverse Change to the significance of the setting of the listed buildings or the Allington Conservation Area. In accordance with the NPPF paragraph 134 no harm to a designated heritage asset needs consideration in determining this application.

10.8. The impacts on the scheduled monument would be major even if the site remains undeveloped. This is because the land is intensively farmed and it is highly likely what little archaeology remains in situ will be completely destroyed within the next 20-30 years. There is a positive benefit in recording now by means of a condition under a planning approval for development. This would allow recording, analysis and dissemination of the results to the benefit of the local, regional and national archaeological communities.

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11. REFERENCES Barnwell 2014 A four-turbine wind farm on land north of Catshead Woods, Sudborough, Northamptonshire. application ref: CO/4231/2012. Decision date February 18th 2014. Dept for Communities and Local Govt

English Heritage 2011 The Setting of Heritage Assets: English Heritage Guidance. English Heritage, London (http://www.english-heritage.org.uk/publications/setting-heritage-assets/setting-heritage- assets.pdf)

Field, N. 2014 The Range, Land off A350, Chippenham, Wilts. Environmental Statement APPENDIX 11.1: Heritage Assessment

Forge Field 2014 Affordable housing at Forge Field, Penshurst, Kent Application ref: CO/735/2013 & CO/16932/2013. Decision date June 14th 2014. Dept for Communities and Local Govt

Javelin Park 2015 Land at Javelin Park, near Haresfield, Gloucestershire application ref: 12/0008/STMAJW. Decision date January 15th 2015. Dept for Communities and Local Govt (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/392620/15 -01- 06_DL_IR_Javelin_Park_2200210.pdf)

NPPF 2012 The National Planning Policy Framework Department for Communities and Local Government, London (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/ 2116 950.pdf)

Wiltshire Council 2015 Wiltshire Core Strategy

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