EAST MIDLANDS OFFICE Ms Andrea Needham Direct Dial

Ms Andrea Needham Direct Dial: 01604 735460 Peak District National Park Authority Aldern House Our ref: P00978798 Baslow Road Bakewell Derbyshire DE45 1AE 14 November 2018

Dear Ms Needham

T&CP (Development Management Procedure) (England) Order 2015 & Planning (Listed Buildings & Conservation Areas) Regulations 1990

CAVENDISH CLUB, CHATSWORTH ESTATE OFFICE, UNNAMED SECTION OF B6012 FROM DUNSA LANE TO CHATSWORTH HOUSE, EDENSOR , DERBYSHIRE Application No. NP/DDD/1018/0911

Thank you for your letter of 17 October 2018 regarding the above application for planning permission. On the basis of the information available to date, we offer the following advice to assist your authority in determining the application.

Historic England Advice

Chatsworth is a landscape of the highest importance reflected in the Grade I Park registration and the Listings of the principal buildings at grade I alongside associated structures at grades II*and II and through Scheduled Monument status.

The improvement of parking and visitor / vehicle flow are desirable but these works come with a degree of harm from loss of grass, trees and archaeological remains as set out in the subm,itted documents. Whilst this harm to the designated assets is less than substantial, as the National planning Policy Framework sets out all harm requires clear and convincing justification and must be weighed against public benefits (with great weight

2nd Floor, WINDSOR HOUSE, CLIFTONVILLE, NORTHAMPTON, NN1 5BE Telephone 01604 735460 HistoricEngland.org.uk

Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation. to the conservation of the assets significance alongside the special regard to the desirability of preserving their features of interst and setting required by law). We are satisfied that the physical works prposed reflect our preapplication advice positively and the direct mitigation of those works is deliverable as discussed in the submission through archaeological work. We are not however satisfied with regard to the sustainability of the submitted proposals for overflow parking which form an integral element in the scheme before your authority subjec to the same considerations in respec t of the NPPF and Stature as the physical works.

As expressed in our pre-application advice Chatsworth Park needs as a basis for its sustainable future management and conservation an holistic plan for parking that takes in the hard parking, the issue of overflow on grass and the parking load at events. Chatsworth has a dense programme of large events that transform the character of the park whilst they are in place (and during the set-up and take-down periods) these cause considerable attrition to the fabric of the parkland and exclude the appreciation of the house and asociated features in it's polite designed setting. It is not sustainable to simple set aside this significant volume of events when developing a parking strategy and as such we cannot concur with the submitted approach.

The proposed approach to overflow parking starts from a justification based upon present loading where up to 350 places are parked below the Bastion Wall, in table 6.03 this is set against the uplift in parking provided by the proposed hard surface scheme of around 220 spaces giving a nominal shortfall below current (harmful) capacity of 130 spaces were the Bastion Wall spaces to be deleted (they are the most harmful in setting terms to the significance of the House since they sit square in the main view of the west elevation).

The submitted document then proposes a phased approach to adding grass parking capacity (additional to the hard car park) on normal operating days that would fill through 'The Helipad' a previously reinforced area (Zone 1), then moving into an area of archaeological earthworks north of the hard parking (Zone 2) and then finally the Cricket Field by the River Derwent (Zone 3). Combined these areas would produce an overall capacity of 1145 + 250 + 280 + 350 = 2025 spaces. The document then moves on to state that on busy days (in addition to major events) the estate wishes, notwithstanding its acknowledged harmful impact, to still park the area below the Bastion Wall on up to 28 days (350 cars). At no point is it explained on what basis 2025 - 2375 cars parked in the registered park might be regarded as sustainable in terms of the conservation of the parkland or the setting of the House and buildings. The new access to the roundabout wil deliver a much easier route to send excess cars back offsite, this alongside signing at junction when the site is full would allow a conctrolled closure to additional cars wjhen capacity was reached. In addition options for staff parking for instance within the walled former Paxton gardens (partially used for caravans) facilitated through a staff shuttle mini- bus should be considered.

The argument is made that when the ground is wet the Cricket Field may be unavailable and hence the other overflow areas would be essential yet in such conditions it would be damaging to park on unprotected grassland elsewhere on site, whilst reference is made to the use of ground protection, this is costly and requires advance planning and does not we believe offer a suitable solution outside of main events. The use of Zone 2 for parking appears to represent a high risk of damage to archaeological earthworks contributing to the significance of the park (through the illustration of its development from a farmed and EAST MIDLANDS OFFICE settled landscape). The significance of these features which fall out of use in the eighteenth century but have earlier origins, and the contribution they make to the significance of the Grade I registered park would also be eroded simply by the concealment of the features below parked cars and ground protection even were such measures practically implemented.

In conclusion we find that the scheme would through physical works cause a degree of less than substantial harm to the significance of the suite of designated heritage assets of the highest national (and international)importance. The applicants have engaged positively with our pre-application advice on the physical works and these might when balanced against the benefits of the scheme to visitor experience and the responsible management of the site be found acceptable were it not for the proposed overflow parking strategy which is harmful and unjustified. As set out in the NPPF your authority should seek to address conflict between any aspect of the scheme and the conservation of heritage assets and the overflow strategy is just such a matter.

Recommendation Historic England has concerns on heritage grounds, we consider that the issues and safeguards outlined in our advice need to be addressed in order for the application to meet the requirements of paragraphs 193, 194, 196, 197 of the NPPF. If these issues are not addresed through the submission of a satisfactory revised approach to overflow parking please treat this as a letter of objection.

In determining this application you should bear in mind the statutory duty of section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to the desirability of preserving listed buildings or their setting or any features of special architectural or historic interest which they possess and section 38(6) of the Planning and Compulsory Purchase Act 2004 to determine planning applications in accordance with the development plan unless material considerations indicate otherwise.

Your authority should take these representations into account and seek amendments, safeguards or further information as set out in our advice. If, however, you propose to determine the application in its current form, please treat this as a letter of objection,

2nd Floor, WINDSOR HOUSE, CLIFTONVILLE, NORTHAMPTON, NN1 5BE Telephone 01604 735460 HistoricEngland.org.uk

Please contact me if we can be of further assistance.

Yours sincerely

Tim Allen Inspector of Ancient Monuments E-mail: [email protected]