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.