Dear Ms Howe I Write Further to Your Letter Dated 14 December 2011

By email: Date: 17 January 2012 [email protected] Our Ref: FIDP/001640-11 Enquiries to: Planning Policy Team Telephone: 01454 863469 Email [email protected]

Dear Ms Howe

I write further to your letter dated 14 December 2011 regarding your request for information held by the Council (ref FIDP/001640-11). Officers have considered your letter as a request for information under the Environmental Information Regulations 2004. Please find below responses to each of the two requests specified in your letter and where appropriate supporting explanation. Please note that personal information such as names and addresses has been redacted from all documents. The documents are being provided to you in four separate emails due to the number and size of attachments.

Request 1

Please supply all internal correspondence between the Spatial Planning officers and the Council’s historic environment, landscape, transport, ecology and flood/drainage teams relating to the proposed allocation of Park Farm, Thornbury for residential development in the draft Core Strategy between 1 December 2008 and 12 May 2010.

Please find the following information attached in relation to request 1:

• Ecology o 1 Core Strategy work for Thornbury o 1a clockface areas map o 2 Ecology comments covering email 31 March 09 o 2a Eco constraints thornbury 31 March 09 o 3 RE Thornbury community engagement exhibition Oct 09

• Flood/drainage o 1 Flooding – Thornbury 3rd Feb 2009 o 2 RE Thornbury meeting 10 Feb 2009 o 2a Meeting with drainage 10 Feb 09 o 3 Thornbury extension – March to June 09 o 4 emails

• Landscape o 1a Thornbury possible growth options Steve Evans Director of Environment and Community Services South Gloucestershire Council, Spatial Planning Team, PO Box 2081, South Gloucestershire, BS35 9BP Telephone: 01454 863469 Email: [email protected]

o 8th Dec 09 email o 30 March 2009 email

• Transport o Thornbury extension o Transport meeting

• Historic Environment o 1b Thornbury possible growth options o 1c Thornbury possible growth options o Correspondence January 2010 o Emails o Meeting arrangements o Park Farm Heritage Assets o Assessment of the cultural heritage issues relating to potential growth areas around Thornbury

Supporting explanation

In order to avoid any further misunderstanding and to ensure that the information provided is not inadvertently taken out of context, further explanation is provided here in relation to the document provided entitled ‘Assessment of the cultural heritage issues relating to potential growth areas around Thornbury’ (the Assessment document). The purpose of this is to provide you with the context for why this document was produced and how it has been used in relation to the assessment of the broad locations for new housing in Thornbury and the choice of Park Farm. We have also included heritage and landscape maps produced for the same purpose, which are attached to the end of this letter.

As you are aware, the Issues and Options consultation by the Council elicited a number of requests from the local community, (including the Town Council), for more housing in Thornbury. The Council set out six broad locations for development in Thornbury, publicised in October and November 2009, with a view to establishing the community’s views as to which area was preferred for an appropriate amount of new housing development. The Spatial Planning Team also began internal consultations with officers about the same areas.

The Assessment document was emailed to Spatial Planning officers in January 2010. To date the document has been used for the following purposes:

1: Broad location studies – background information

The Assessment document identifies all the heritage assets around Thornbury. The maps attached at the end of this letter show the locations of the assets. Clearly, all areas of land surrounding Thornbury either have or are proximate to heritage assets to varying degrees and the report acknowledges that, in terms of heritage impacts, areas 4, 5, and 6 are the most sensitive. The report also draws attention to the

Steve Evans Director of Environment and Community Services South Gloucestershire Council, PO Box 2081, South Gloucestershire, BS35 9BP Telephone: 01454 863469 Email: [email protected]

significance of the Grade 1 assets of the Castle and St Mary’s church as a group and draws attention to the need for particular attention to be given to the context of the Castle and its potential deer park, the potential loss of open landscape and views to heritage assets. However, heritage is only one subject to be considered in taking a balanced view of all the issues in planning. All advantages and disadvantages of the areas identified in the Thornbury Options for growth consultation were discussed at the community stakeholder workshop in October 2009.

2: Core Strategy production

The decision to include Park Farm as the proposed area for housing was taken as a result of balancing all planning matters (including ecology, landscape, transport, education and the local economy). This area performs the best in terms of place- making and providing a sustainable location for development.

In light of the comments in the Assessment document, Policy CS33 of the Draft Core Strategy specifically requires a Historic Environment Character Assessment before the capacity of the site is confirmed, to inform the layout and scale of development and to mitigate impact of development on heritage values and assets. This wording, together with other policies in the Core Strategy (for example Policy CS9 - Managing the Environment and Heritage and CS32 - Thornbury) clearly demonstrates the Council’s intention to consider the impact of development on heritage assets at Park Farm. Matters raised in the assessment document have therefore been taken into consideration in Policy CS33, the requirements of which ensure that assessment of the significance of the historic environment forms a central pillar by which the capacity, design and layout of the site will be judged.

3. Ongoing technical work post January 2010

In respect of the master planning work for Park Farm undertaken in preparation for the submitted outline planning application, significant technical work on heritage matters is being required of the developer. The Council requires the developer to provide a heritage appraisal and justification for any proposals that might affect any heritage assets, including the historical landscape and the settings of assets. This includes any relevant Listed Buildings, Conservation Areas, Scheduled Ancient Monuments and Registered Parks and Gardens.

The heritage assessment document formed the basis of the brief provided by the Council to the developers of the Park Farm site. This brief was provided to the developers in June 2010 and was also provided to you by email on 23 February 2011 in response to a previous Freedom of Information Request.

PPS5 does not preclude development taking place in the historic environment or adjacent to heritage assets. In this case the Housing Opportunity Area is adjacent to a number of heritage assets but none lie within it. The area does not lie within the Conservation Area and is well screened from it by mature vegetation. Thornbury’s most important landscape setting of its historic core, with views into and from the Conservation Area and the Castle, lies to the west of the town, away from Park

Steve Evans Director of Environment and Community Services South Gloucestershire Council, PO Box 2081, South Gloucestershire, BS35 9BP Telephone: 01454 863469 Email: [email protected]

Farm. The Deer Park was identified as a potential asset at the same time as the fishponds. A request for the historic Deer Park to be scheduled was refused by English Heritage in August 2011. It should be noted that development at Parkland Way has already taken place within the Deer Park.

PPS5 states that the historic environment can provide a stimulus to inspire new development of imaginative and high quality design that reflects a sense of place and local distinctiveness. The Council remains of the view that the further technical work required by Policy CS33, together with continued discussion with English Heritage, will secure high quality design of the development inspired by and sensitive to those heritage assets, and will ensure that their significance is not harmed.

We would also like to make the following points on the proportionality of the evidence required in plan making, compared to that needed to support a planning application. PPS12 requires a robust evidence base to support DPDs. Policy HE2 (evidence base for plan making) of PPS5 states that in preparing DPDs, Planning Authorities should use publicly documented evidence to ensure they have evidence about the historic environment and heritage assets. Policy HE2 goes on to state that the level of detail of evidence should be proportionate and sufficient to inform the plan-making process.

PPS5 and its accompanying guidance note require the core of evidence regarding the historic environment to be based on information contained in the Historic Environment Record (HER). The existence and location of the heritage assets at Park Farm Thornbury were identified by the Council from the HER and this evidence was used to inform both the preparation of the Core Strategy and the Sustainability Appraisal for the Core Strategy (which is also required to be proportionate to the level of plan being prepared). The proximity of heritage assets to Option 6 was identified in the Sustainability Appraisal, which informed the drafting of Policy CS33.

The information contained in the HER for the district includes information on (inter alia) Conservation Areas, Listed Buildings and Scheduled Ancient Monuments. It should be noted that the decision by the Secretary of State to Schedule the Mediaeval Fishponds at Park Farm in August 2011 was the result of the Council’s own request for recognition of these assets and was the subject of assessment by English Heritage. The scheduling was taken into account in the decision by Full Council to again confirm the identification of Park Farm as a housing opportunity area in December 2011.

Request 2

Please supply all correspondence between Spatial Planning and Development Control officers and the historic environment, landscape, transport, ecology and flood/drainage teams relating to the ‘broad locations’ for residential development identified in South Gloucestershire Council’s consultation documents for Thornbury between 1 January 2007 and 1 December 2008.

Steve Evans Director of Environment and Community Services South Gloucestershire Council, PO Box 2081, South Gloucestershire, BS35 9BP Telephone: 01454 863469 Email: [email protected]

The Council holds no information relevant to this request further to that disclosed under Request 1 above.

I trust that you are satisfied with this response to your request. However, if you need to clarify this response please contact me by writing to the address at the bottom of the letter or via e-mail to [email protected].

If you remain dissatisfied after contacting me, you can then write directly to Brian Glasson, Head of the Strategic Planning Division, using the same address or e-mail requesting a review of your request. After you have received a response from Mr Glasson, you may apply to the Information Commissioner, whose contact details are available at www.ico.gov.uk.

Yours sincerely

Donna Whinham Strategic Major Sites Manager

Steve Evans Director of Environment and Community Services South Gloucestershire Council, PO Box 2081, South Gloucestershire, BS35 9BP Telephone: 01454 863469 Email: [email protected]

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©Copyright South Gloucestershire Council {2009]. All rights reserved. ancient This map is reproduced from Ordnance Survey material with the permission of Ordnance Survev on h P h;::~lf nf thP r.nntrnllPr,.,.,.,.,. monume~.t Assessment of the cultural heritage issues relating to potential growth areas around Thornbury.

28th January 2010

Contents

Page

I.0 Introduction: Purpose of the report 2

2.0 Brief history of Thornbury 3

3.0 Policy background 3

4.0 Analysis of Area 1 4

5.0 Analysis of Area 2 5

6.0 Analysis of Area 3 5

7.0 Analysis of Area 4 6

8.0 Analysis of Area 5 7

9.0 Analysis of Area 6 7-9

10.0 Conclusion and recommendations 10

Appendices

Map 1 Map showing growth options area

Map 2 Map identifying extent of Thornbury Conservation Area

Map 3 Map identifying Area 1

Map 4 Map identifying Area 2

Map 5 Map identifying Area 3

Map 6 Map identifying Area 4

Map 7 Map identifying Area 5

Map 8 Map identifying Area 6

Map 9 Map identifying further potential growth area

1 1.0 Introduction: Purpose of the report

1.1 The Council is currently developing it’s Core Strategy and as part of this process the development potential of Thornbury is being considered. Several sites have been proposed as suitable for potential growth and six of these have been put forward for further scrutiny. The purpose of this document is to assess the potential impacts of development within these locations upon the historic environment of Thornbury and its setting. During this assessment it became clear that whilst development on a number of these sites would potentially have a significant adverse impact upon the cultural heritage of Thornbury, others would have a less significant impact and that mitigation strategies would be likely to overcome potentially adverse impacts. It also became clear that there were other locations, which appear to have not previously been considered, that would potentially have a far smaller adverse impact on the historic environment than many of the options presented.

1.2 The six sites are identified in the attached map (map1) and are as follows:

Area 1: Land adjacent to Morton Way and Gloucester Road (north east of the town)

Area 2: Land adjacent to Morton Way (eastern edge of the town)

Area 3: Land adjacent to Morton Way and (south east of the town)

Area 4: Land to the south of the allotments (south west of the town)

Area 5: Land adjacent to Kington Lane (west of the town)

Area 6: Land at Park Farm (north of the town)

1.3 The proposed sites as shown on the growth options map are non-specific, and do not show precise boundaries. Issues such as layout, densities and planting have not been addressed at this stage and it is therefore not possible to comment specifically on the full impacts of development of these areas. This assessment therefore considers the potential impacts upon heritage assets which could be affected.

1.4 Development in any of the six areas would impact on the character of Thornbury and its historic landscape context to a different degree, the purpose of this assessment is to identify those areas (if any) where development could take place without adverse impact on the cultural heritage of Thornbury. The modern landscape of Thornbury also contributes significantly to the historic character of the town and its setting and some landscape issues will be touched upon in this assessment even though the wider landscape issues are being assessed separately by a landscape officer. This report concentrates on potential impacts of development on cultural heritage assets, specifically listed buildings, scheduled monuments, registered parks and gardens and the conservation area.

2 2.0 Brief history of Thornbury

2.1 Thornbury is a former medieval market town, situated at the edge of the Severn Vale some 3 miles east of the River Severn. The original settlement of Thornbury was probably on the lower ground around the Church of St Mary. This was extended southward by Robert de Clare, Earl of Gloucester, who laid out the new town between 1243 and 1262. It was granted a Borough Charter in 1252 and the current street plan reflects this period of development with the three streets of Castle Street, High Street and The Plain converging to a large market place, all enclosed by a town wall. Outside the town wall are the closes, paddocks, meadows, orchards and market gardens to enable the borough to operate independently of the manorial castle.

2.2 Although the closes to the east have been largely lost to modern development, those surviving to the west and north are important both historically and for their contribution to the overall setting and context of the town.

2.3 Thornbury Castle, dating from the sixteenth century, and the Church of St Mary, of twelfth century origins, are important landmarks of national significance.

2.4 The population of the town has grown over the last 40 years from a population of 3,000 to 13,000. This planned expansion has taken place largely to the east of the historic town away from the historic centre. The medieval walled core of Thornbury sits on a low ridge with St Mary’s Church situated on slightly raised land at its northern edge providing an important landmark visible from many areas around the town. The area of recent development sits in a ‘saucer’ with higher land to the south, east and north. The historic core is designated as a conservation area (see map 2). There are a significant number of statutory listed buildings within the conservation area, and further outside its boundaries, within the surrounding landscape.

3.0 Policy background

3.1 In considering sites for development, the following statutory legislation, government guidance and local plan policy relating to cultural heritage will need to be considered:

Planning (Listed Buildings and Conservation Areas) Act 1990 Ancient Monuments and Archaeological Areas Act 1979

National guidance set out at: Planning Policy Guidance 15: Planning and the Historic Environment (PPG15) Planning Policy Guidance 16: Planning and Archaeology (PPG16)

South Gloucestershire Adopted Local Plan Policies: L10 – Historic Parks and Gardens L11 – Archaeology L12 – Conservation Areas L13 – Listed Buildings

3 4.0 Analysis of Area 1: Land adjacent to Morton Way and Gloucester Road (north east of the town)

4.1 This area of land lies to the north eastern side of Morton Way. Gloucester Road extends from Morton Way to the north, and bounds the site in part. The site is a significant distance from the historic core of the town and would have no impact visually on the historic centre or conservation area.

4.2 There are three listed buildings to the north of the site, Manor Farm (grade II), The Old Malthouse (grade II) and Morton Grange (Grade II*). Morton Grange, at approximately 250m away from Morton Way, is closest to the town. These buildings are identified on map 3.

4.3 Morton Way currently contains the modern development and allows these listed buildings to be read in a relatively rural context. The land rises upwards approximately 10m from Morton Way to the area around Morton Grange and Old Malthouse, with the modern development contained within the ‘saucer’ of lower land, and therefore although the urban edge of the modern housing can be viewed in the far distance from these buildings, it is relatively inconspicuous. This important group of historic buildings are therefore seen in rural context, and are visually far removed from the urban core of the town.

4.4 The development of site 1 would remove this ‘green buffer’, and result in modern development extending far nearer to these listed buildings. Views from Manor Farm to the site would be shielded to a significant degree by Old Malthouse. It is considered that the most significant and harmful impact of developing this site would be to the setting of Morton Grange, which is a grade II* listed building. The extent of development is not clear although the indicative development area would appear to extend directly up to Morton Grange. Views from and to Morton Grange will be significantly altered and it is considered that the loss of the existing rural context would harm the setting of the listed building.

4.5 The indicative map identifies this site as potentially very large, and accommodating up to 400 houses. It is considered that if the site area were reduced significantly in size, and brought further from Morton Grange, the site may have some development potential, subject to site layout and planting, which may help mitigate any adverse impacts on the setting of the listed building.

4 5.0 Analysis of Area 2: Land adjacent to Morton Way (eastern edge of town)

5.1 As with site 1, this area of land would breach Morton Way which currently physically contains the area of modern expansion. The site lies to the east of Morton Way between Crossways Lane and Hacket Lane. There are a number of historic buildings along both of these lanes, and they possess a strong rural character despite their proximity to the urban core of the town. There are two listed buildings which are located within approximately 100-200m of this site, depending on the extent of its boundaries. These are Woodbine Farm (grade II) and Crossways House (grade II) and are identified on map 4.

5.2 Although the urban edge of Thornbury is currently visible in the distance from both of these properties, their setting is primarily rural, and the field network to the east of Morton Way contributes positively to the setting and character of these buildings. The development of the site would detract from the sense of ‘remoteness’ from the urban core of the town, which both buildings currently possess.

5.3 Crossways House is located on land some 10-15m higher than Morton Way. The encroachment of development is likely to have an impact on the setting of the listed building, although it is probable that planting and careful layout of open spaces, would help mitigate any adverse impact. Woodbine Farm fronts on to Hacket Lane and is read in context with the linear development of buildings which front on to the lane. The buildings and hedgerows lining the lane provide a high level of enclosure and therefore views to the surrounding countryside are limited. The impact of development of site 2 on the setting of the Woodbine Farm may be limited, depending on the site layout and planting. The site area, and number of houses identified on the options map are both quite modest, and therefore this site is considered to have some development potential if appropriate mitigation was put in place to protect the setting of the listed buildings.

6.0 Area 3: Land adjacent to Morton Way and (south east of the town)

6.1.1 From a cultural heritage perspective, of the six sites put forward, this site is considered the most appropriate for development as it is likely to have the least impact on heritage assets. The site is shown on map 5.

6.1.2 Woodbine Farm (Grade II) is located approximately 200m to the north of the site, although the buildings and planting on Hacket Lane offers a significant degree of enclosure, and therefore views from Woodbine Farm to the south are limited. From Hacket House (grade II) it is possible to see the rooftops of the modern housing along Morton Way over the fields in the distance. The setting of Hacket House (grade II) is therefore likely to be affected by development of this site, however this would very much depend on the extent and precise location of the development. Planting or site layout could be sensitively handled to mitigate against any potentially damaging impact on the setting of Hacket House.

5 7.0 Area 4: Land to the south of the allotments (south west of the town)

7.1 This site, shown on map 6, is within the Thornbury Conservation Area, situated just to the south of the town’s allotments. The character of this site differs markedly to the three previously discussed sites. The three locations to the east of Thornbury are all of a similar landscape quality, with gently rolling fields of medium size and of regular shape, and generally sloping from east to west. The land is predominantly good quality pasture, with some arable. This landscape is clearly in sharp contrast to the hard urban edge contained by Morton Way. Site 4 has a more varied character. The site lies to the west of Bristol Road, which is a heavily used access in to the town. Other than the relatively slope away from the road to the east, the site is a relatively level area. To the south west of the site the land rises steeply to a hill, which forms part of the Severn Ridges. Part of the hill is now in use as a golf course, and therefore this part of the landscape is very different in character to the low lying site. There is a stream running through the site although generally the land appears to be quite poorly drained. It is largely scrubland, with a fairly dense network of trees and planting following the line of the stream. To the north of the site are the allotments. To the east of the site, on the opposite side of the road is a belt of development.

7.2 The route to Thornbury from the A38, via Alveston, emerges at this southern end of the town. The route descends steeply, via a wooded and tightly enclosed road. At the foot of the hill the visitor emerges to a more open landscape, with long distance views over land to the west (including site area 4), towards the Severn Estuary, and north towards the historic High Street. Rosemount House (grade II listed building) forms an important entrance gateway at this approach to the town and the preservation of its setting and views need to be carefully considered. This open area of landscape, including the site, is an important reminder of the rural setting of Thornbury, and it’s historic and landscape context. The site is identified in the Adopted Thornbury Conservation Area SPD as part of the original open closes around the town. The closes would have been areas used as paddocks, meadows, orchards and market gardens to enable the borough to operate independently of the manor.

7.3 The modern development has engulfed the historic town entirely to the east, thereby significantly altering the sense of its agricultural origins and context. The southern entrance to the town is therefore considered highly important and sensitive, allowing views towards the Severn Estuary, and providing a rural backdrop to the southern end of the town. It is considered that development on this site would dramatically alter the character of this part of the conservation area, to its detriment, and detract from the wider landscape and historic context of Thornbury.

6 8.0 Area 5: Land adjacent to Kington Lane (west of the town)

8.1 As with area 4, this site is within the Thornbury Conservation Area and was historically part of the open closes surrounding the medieval town. The area has an extremely tranquil, picturesque and rural quality, and one which is clearly distinct from the developed High Street. To the rear of the buildings on the High Street are the historic stone boundary walls of the town. Beyond these the landscape is open and of a rural character, with primarily only isolated and dispersed houses. The landscape of the site is undulating, with a stream running along the bottom of the sloping hills. The Community Centre is a large modern building in close proximity to the site, however as it is located behind the high stone boundary wall on Kington Lane, it does not appear to infringe in to the open countryside.

8.2 The site is rural in character and the historic stone walls provide a strong and prominent containment to development. The open fields offer views to St Mary’s Church, and provide an extremely important and sensitive landscape context to Thornbury. It is considered that the development of housing on this site, and the loss of this area as open fields, would have a damaging impact on the historic and landscape context of Thornbury, and harm the unique character and appearance of this part of the conservation area.

9.0 Area 6: Land at Park Farm (north of the town)

9.1 This potential site is identified as an extensive area of land to the north of Thornbury, to the rear of the Thornbury School site. The site is not within the conservation area boundary but is shown to be directly adjacent to its north eastern boundary. To the north of the town centre is Thornbury Castle, which dates from 1510. Thornbury Castle, which is now in use as a hotel, comprises the Inner Court; the Outer Court and wall of the Kitchen Court; and the walls enclosing the Privy Garden, all listed grade I. The garden, which includes the remains of the original elaborate enclosed Tudor garden, is included on the Register of Parks and Gardens. St Mary’s Church, also grade I, is located just to the south of Thornbury Castle. The Castle and Church are both buildings of national significance and by virtue of their grade are offered the highest level of protection.

9.2 To the north and north east of the castle (including the location of site area 6) were three large deer parks. There are further listed buildings in close proximity to area 6 which would be affected by development on this site. These are all shown on map 8 and include Park Farm (grade II), barn at Park Farm (grade II), Shieling Park School (grade II) and Morton House (grade II).

9.3 Approaching Thornbury from the levels along Oldbury Lane, views to the town edge are gained across the site, at a distance of between 0.6km and 1km. The west and north western edge of the town is generally well integrated in the landscape as a result of the strong vegetation network that exists within the conservation area, around the historic core of the town, and from other vegetation along this edge, which provides a high degree of visual containment to the town. The site is beyond this strong vegetation network and clear views towards the site can be gained from Oldbury Lane as well as the network of public footpaths. In views from the north west, the Park Farm complex and St Mary’s are clearly legible, and appear as attractive features in

7 the landscape. The developed areas of the town are largely well screened from these views, allowing for a rural and remote feeling. The settlement edge to the north east of Park Farm is partially visible, although not dominant.

9.4 The exception to this strong vegetation screen is land directly to the north west of Thornbury School. There is very limited screening between the school playing fields and the open countryside beyond, and therefore views towards the town from the north-west reveal the modern development. Planting along this boundary would enhance the landscape character at this edge of Thornbury. Site area 6 does not appear to include the playing fields, only the open landscape beyond, however in assessing this area it is considered that there may be potential for development on the site of the school playing fields, subject to appropriate planting to continue the vegetation screen that occurs along the rest of the north western edge of Thornbury. It is considered that development on the playing field site, subject to appropriate boundary planting, would not have an unduly adverse impact on the setting of the conservation area or the listed buildings.

9.5 It is considered that the fields beyond the playing field and included in site area 6 provide an essential and important setting to the historic town, and Thornbury Castle. The development of this area of land would result in further encroachment of modern development in to the landscape to the north, which would have a damaging impact on the setting of the Castle and the wider conservation area via the curtailment of views of the historic buildings within their landscape context, and the loss of openness. This further infringement on the historic curtilage of the Castle would reduce its sense of grandeur and hierarchical importance within the town.

9.6 The northern end of the historic part of the town is very distinct from the High Street and Castle Street, in atmosphere and appearance. The urban grain is much less tight, with large open spaces between the buildings, such as Glebe Field around the Church, and has a much more rural, tranquil character. The gradual transition from the urban to rural areas is an essential character of the historic town. The Castle parkland is thought to have originally extended up to Oldbury Lane. Although the landscape has been altered via the existing agricultural use and field subdivision and the modern development to the north east of the castle, the openness and remoteness to the north west is strongly apparent and is extremely important.

9.7 Views between the Castle and the site are in some places limited due to the existing planting, however the affect of potential development should not be considered based on individual view points. The importance of the setting of Thornbury Castle and its surrounding gardens and landscape is understood through an overarching contextual awareness and sense of place as opposed to particular viewpoints. As much as its architecture and archaeology, the special interest of the Castle relates to its setting and surroundings, achieved via the sense of remoteness and openness to the north and the transitional nature of the route northwards from the town centre to the open countryside beyond. The development of this site would close off the important visual gap between the conservation area to the west and the area of new development to the east. The merging of one of the most historic parts of the town, with new development would be unwelcome. It is unlikely that mitigation strategies such as planting or layout could overcome the harm caused by developing this area of open landscape, as it is the principle of loss of open landscape which is of concern.

9.8 Development of this site would impact on Park Farm and Shieling School in a similar way, as these buildings currently benefit from a predominantly open, rural setting, which would be significantly diminished via development. Park Farm retains its significant agricultural character through both its architecture and setting. Currently views looking southwards from Oldbury Lane and eastwards from public footpaths show Park Farm within open countryside, and are an important reminder of Thornbury’s agricultural origins. If this site were developed the setting and views of Park Farm would be greatly diminished. The same is true of Moreton House in that views towards and from the building would be harmed, although this is largely dependant on the precise area of development and the scope for mitigation.

9.9 To the south of Park Farm are the original fishponds which formed part of the deer park attached to Thornbury Castle. This area of the site is of significant archaeological potential, and is very important in historic and landscape terms. The relationship between Thornbury Castle and the fishponds is significant, and the retention of this area as open landscape is considered essential.

9.10 It is considered that development on this site would have an extremely harmful impact on the setting of several listed buildings, including the grade I listed Castle, to the character and appearance of the Thornbury conservation area, and to the wider landscape and historic context of the town.

9.11 Archaeology There are a number of surviving archaeological remains known within or immediately adjacent to the site. These are as follows:

The site lies within a historic park belonging to the Third Duke of Buckingham in the 16th century, although no traces of this appear to survive within the proposal site. The field of pasture within the proposal site do however contain feint earthwork remains of ridge and furrow ploughing which is likely to pre- date the 19th century enclosures, and therefore may be protected as a result.

The stream running westwards from the fishponds across the proposal site is believed to have formed part of a 16th century system of watercourses feeding a canal linking Thornbury Castle to the Severn. It appears to have diverted water from the small stream which still flows NW from the fishponds across the site.

The group of fishponds immediately adjacent to the site, within a wooded area, has been assessed as being of national importance and is currently being considered for scheduling as an Ancient Monument under the 1979 Act. The impact of any development on the site and its setting will need to be assessed as part of any proposal whether the site is scheduled or not. A public footpath runs along side the site.

Other archaeological remains associated with the park and fishponds may survive within this site area and an archaeological evaluation should be undertaken to assess the nature and extent of any surviving remains would be required prior to submission of an application/EIA.

9 10.0 Conclusions & Recommendations:

10.1 Having assessed each of the six areas highlighted as potential areas of growth, I would conclude that from a cultural heritage perspective three of the sites are unlikely to be appropriate for development as there historic significance is too sensitive. These are areas 4, 5 and 6. Development of Site 6 would have a harmful impact on heritage assets of national importance although some additional development of the Castle school site may be feasible if it were undertaken in a sensitive manner. Sites 4 and 5 are areas of significant landscape and historic importance to Thornbury and their development would be damaging to the town’s historic character.

10.2 Development of area 1 on the scale indicated would also be potentially harmful to the setting of listed buildings, particularly Morton Grange, however if the site area were reduced there may be some development potential.

10.3 Development of area 2 is likely to result in an adverse impact on the setting of listed buildings although would be less damaging, and mitigation via planting and site layout could overcome potentially adverse impacts.

10.4 Area 3 is the preferred option as it is considered that this would have very little impact on heritage assets.

10.5 Whilst undertaking this assessment it became clear that there were other possible locations where development would be more appropriate in terms of the potential impact on the historic environment of Thornbury. Whilst these have not been fully assessed nor other constraints considered these sites appear to provide potential for further investigation.

a. Land to the north east of Butt Lane and to the west of Gloucester Road. Map 9 shows the general area. Development of this site would impact on the setting of Morton House depending on the site layout and area, although it is considered that development could probably be accommodated with sensitive treatment of the setting of the listed building.

b. Land at Castle School As discussed in paragraph 9.4 it is considered that from a cultural heritage perspective, a certain level of development could be accommodated on land at Castle School, if contained within the extent of the existing playing fields, and subject to appropriate planting, to continue the strong vegetation screen that occurs elsewhere along the north west boundary of the town, but which is lacking at this site.

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10 Designing our Communities THORNBURY OPTIONS FOR GROWTH

AREA 6. Potential Growth 500—600 houses AREA 1. Potential Growth 350—400 houses.

Advantages : Advantages: Reasonable access to the High Street (10 minute walking distance). Not in Green Belt - no revision to Green Belt boundary necessary. Excellent access to Castle secondary school and Manor Brook and St Less harm to important landscapes. Mary’s primary schools. Less impact on historic character. Not in Green Belt, so no revision to Green Belt boundary necessary. Subways already installed under Morton Way to enable pedestrian Development may help to realise aspirations of the Castle School. access. Good access to primary school and Primrose Drive newsagent/ Disadvantages: convenience store Potential Flooding/drainage issues need to be investigated. Potential impact on nearby Conservation Area and historic character of Disadvantages: Thornbury Castle and listed buildings. No existing services within five minute walking distance (except children’s play equipment). AREA 5.Potential Growth 40—50 houses Town centre not within convenient walking distance (20 minutes minimum walking time). Advantages: Close proximity of A38 may encourage car use. Excellent access to the High Street shops and services. Breaches Morton Way ‘boundary’. Relatively little ecological interest compared to other areas. No statutory biodiversity designations, however national priority species are present in parts of the area. Disadvantages: In Green Belt. Potential impact on landscape and historic character. Potential Flooding/drainage issues need to be investigated. Area currently used by walkers and as a route to the Mundy AREA 2. Potential Growth 90—110 playing fields houses

Advantages: Not in Green Belt, so no revision to Green Belt boundary necessary. Less harm to important landscapes. Less impact on historic character. Basic local centre/convenience store at Primrose Drive within walking distance, however this is the only facility within that distance. Good access to Crossways primary school

Disadvantages: Poor access to High Street (20 minutes minimum walking time). Breaches Morton Way ‘boundary’. No facilities within a five minute walk. Close proximity of A38 may encourage car use.

AREA 3. Potential growth 750—900 houses

Advantages: Not in Green Belt, so no revision to Green Belt boundary necessary. Less harm to important landscapes. Less impact on historic character. AREA 4. Potential Growth 90—100 houses Primrose Drive convenience store within 15-20 minute walking distance, however this is the only facility within that distance. Advantages: Excellent access to the Town centre shops, services and facilities. Disadvantages: Excellent access to Midland Way employment. Poor access to High Street (20 minutes minimum walking time). Excellent access to leisure centre. Breaches Morton Way ‘boundary’. Area contains two Sites of Nature Conservation Interest (SNCI), ponds Disadvantages: and hedgerows of interest to wildlife. In Green Belt. No facilities within a five minute walk. Potential Flooding/drainage issues need to be investigated. Poor access to Castle School and health centre. Ecological habitats of interest; mitigation would be required. Close proximity of A38 may encourage car use Potential impact on landscape and historic character. Thornbury Community Engagement Workshop. 20th October 2009 MAP 2 - Conservation Area boundary

South Gloucestershire Council Castle Street Scale 1/10526 Date 28/1/2010 Thornbury South Gloucestershire BS35 1HF © Copyright South Gloucestershire Council 2010. All rights reserved. © Crown Copyright. All rights reserved. 100023410, 2010 Telephone: 01454 868009 Website: www.southglos.gov.uk MAP 3 - Area 1

South Gloucestershire Council Castle Street Scale 1/5263 Date 28/1/2010 Thornbury South Gloucestershire BS35 1HF © Copyright South Gloucestershire Council 2010. All rights reserved. © Crown Copyright. All rights reserved. 100023410, 2010 Telephone: 01454 868009 Website: www.southglos.gov.uk MAP 4 - Area 2

South Gloucestershire Council Castle Street Scale 1/2807 Date 28/1/2010 Thornbury South Gloucestershire BS35 1HF © Copyright South Gloucestershire Council 2010. All rights reserved. © Crown Copyright. All rights reserved. 100023410, 2010 Telephone: 01454 868009 Website: www.southglos.gov.uk