Conservation Casework Log Notes October-December 2014
CONSERVATION CASEWORK LOG NOTES OCTOBER-DECEMBER 2014
The GHS conservation team received 417 new cases in England and 11 new cases in Wales between October and December (inclusive), in addition to ongoing work on previously logged cases. Written responses were submitted by GHS and/or CGTs for the following cases. In addition to the responses below, 21 ‘No Comment’ responses were lodged by GCTs in response to planning applications included in the weekly lists.
Please note that the dates given may reflect the date the response was added to the Casework Log rather than the date submitted to a Council
Site / County / GHS ref / Reg grade / Proposal / Written ResponseAshton Court / Avon / E14/0888 / II* / PRE-APPLICATION Proposed redevelopment of the Bower Ashton Depot, including conversion of existing buildings and construction of new buildings, to create either (i) residential development of up to 20 dwellings (Use Class C3); or (ii) educational facilities to allow the expansion of UWE Bower Ashton Campus (Use Class D1). (Headline views to be provided only). Bower Ashton Depot (inc. Wood Yard, Training Centre & 1 Park Farm) Kennel Lodge Road Bristol BS3 2JT. / CGT WRITTEN RESPONSE 23.11.2014
Summary: The Avon Gardens Trust supports the conversion and extension of these buildings and land as ‘enabling development’ for the restoration of the Ashton Court Mansion
Thank you for sending the Avon Gardens Trust the Pre-Application Enquiry Statement and plans for the Ashton Court Estate Buildings, and for explaining the proposal over the phone.
One of the roles of the Avon Gardens Trust, established in 1987, is to help safeguard the heritage of historic designed landscapes within the former County of Avon by advising local planning authorities on statutory and non-statutory parks, gardens and designed landscapes of importance. We now work closely with the Garden History Society, the statutory consultee for properties on English Heritage’s Register of Parks and Gardens of Special Historic Interest. The GHS notified us of this pre-application, but the Trust appreciates being directly notified about proposals affecting designed landscapes in Bristol.
The Council proposes to sell the estate buildings to fill the £4m funding gap for the restoration of the Ashton Court Mansion which is on English Heritage’s Heritage at Risk Register. One proposal is to convert the buildings to residential use and extend them with “mini-terraces of mews-type dwellings” (presumably single-storey) to provide 13 and 6 dwellings respectively. The alternative proposal is to convert the buildings to teaching space and provide new buildings for use by the adjoining College.
In terms of the issues :
1) whether any buildings would be considered to be curtilage-listed buildings
We consider that, due to their physical layout, past and present ownerships and previous and current uses, they should be regarded as curtilage-listed buildings to the Grade II listed Park Farm (now 1 and 2 Park Farm).
2) which of the two proposals are preferable.
Without fully-detailed plans drawn up for both options, this is difficult to assess. However, the residential option would appear to be preferable. The reasons for this are because it has been calculated that this would be the better way of raising the necessary finance, educational needs may dictate less-sympathetic designs for the new buildings and the conversion work, and the inclusion of the buildings and land into the College campus would be likely to involve new boundaries, surfaces, signage etc detracting from the simple agricultural character of the collection of the buildings.
3) whether the two proposals would be considered to be ‘enabling development’ to fill the funding gap of £4m for the restoration of the Ashton Court Mansion.
English Heritage’s ‘Enabling Development And The Conservation Of Significant Places of Interest’ June 2012 sets out their detailed policy about this, with a summary on page 5. Six criteria must be met for a proposal to be regarded as ‘enabling development’.
We consider that a good case has been made in the Statement for the conversion and extension of the estate buildings as shown on the draft proposed layout plan to be ‘enabling development’. Whilst no detailed plans have been submitted, the Statement says that the development would be carried out in a manner which respects the character and setting of the buildings, and we are concerned that this will be the case.
It is also important that the Council retains legal control over the details and implementation of the scheme (rather than the site being sold off to a developer). English Heritage refers on page 5 to four matters concerning this that need to addressed before planning permission is granted.
We hope that this letter is of help to you.
Yours sincerely
Ros Delany (Dr)
Avon Gardens Trust
Ashton Court / Avon / E14/1144 / II* / PLANNING APPLICATION Change of use to an all weather pitch with 8 x 12m floodlights, fencing and replacement of tennis courts with hardstanding for provision of extension to car parking area. Cathedral Choir School Playing Fields, Off Beggar Bush Lane, Long Ashton. SPORT/LEISURE / CGT WRITTEN RESPONSE 09.01.2015
Formed in 1987, the Avon Gardens Trust is one of the earliest county gardens trusts to have been established. One of its roles is to help safeguard the heritage of historic designed landscapes within the former County of Avon by advising local planning authorities on statutory and non-statutory parks, gardens and designed landscapes of importance.
This significantly reduced scheme within Ashton Court Estate, will have minimal impact on the registered Park and Garden providing all of the conditions with respect to lighting and fencing are followed.
The Gardens Trust now works closely with the Garden History Society [ the statutory consultee on Registered Parks & Gardens] to comment on planning applications affecting gardens and landscapes that are listed heritage assets.
Our comments on applications are forwarded to, and kept by, the Garden History Society.
We would be grateful to be advised of your decision.
Yours sincerely
Ros Delany (Dr)
Chair, Avon Gardens Trust
Upper Lansdown Mews / Avon / E14/0910 / N / PLANNING APPLICATION Erection of 1no four bed dwelling. Rear of Dixon Gardens, Upper Lansdown Mews, Lansdown, Bath. RESIDENTIAL / CGT WRITTEN RESPONSE 18.10.2014
Summary: The Avon Gardens Trust objects to this application.
Formed in 1987, the Avon Gardens Trust is one of the earliest county gardens trusts to have been established. One of its roles is to help safeguard the heritage of historic designed landscapes within the former County of Avon by advising local planning authorities on statutory and non-statutory parks, gardens and designed landscapes of importance. The Gardens Trust now works closely with the Garden History Society in commenting on planning applications affecting them.
We are grateful for the opportunity to comment on application 14/04025 which seeks permission for residential development to an area currently forming part of the gardens to the residence known as “Beckford Gate”, Lansdown Road,
Lansdown, Bath.
1 Origin of Site – design history; designation
1.1 We deduce, from looking at the street layout and the application site, that when
the cul-de-sac Dixons Gardens was being proposed on the gardens once
owned by Beckford the application site was deliberately excluded because of
the heritage value of the two terraces, the listed revetment walls that supported
them and the paths, including the one from Lansdown Mews.
1.2 We imagine this would have been a planning requirement rather than the wish of the owner who, we suggest, would have preferred the application site to be used for garden land to the then proposed houses. We do not have the resources to investigate speedily the planning history of Dixons Gardens but suggest that such an investigation would reveal such a requirement and purpose.
1.3 A photograph of the Dixons Gardens development about to start in 1977 (Bath in Time - Bath Central Library Collection) shows, we think, (to the right) the wall to Beckford's Ride to the Gate. The photograph also shows the Gate and the walls to the terraces, the full description in the listing for which is
"The walls flanking Beckford's Ride are approx 2m high and 140m long, of varying height and construction. The revetment walls to the north, approx 70m long, are of squared rubblestone with later buttresses. Laid out by Beckford as part of his landscaping project. Along the north side the walls are plain and form revetments to raised terraces, at the western end are stone steps to the upper terrace and walk. On the eastern side the wall is huge and impressive with round-headed arches, now blocked up, and vaults behind. HISTORY: These walls formerly enclosed the mile-long ride to Lansdown Hill, along which Beckford would ride almost daily, enjoying the seclusion of his private domain. Beckford had been influenced by the lengthy private grounds laid out by his great uncle Charles Hamilton north of the Royal Crescent. The walled ride extended from Beckford's stables in the mews to the embattled gateway (qv Beckford's Gate).”
1.4 The listing description of the 10m Beckford's Gate states
“HISTORY: The gate originally gave access to Beckford's Ride leaving his gardens above Lansdown Crescent into open land on the way up towards his tower (qv) a mile and a half away. It thus forms a literal gateway to a remarkable private domain, and is a remarkable garden structure designed in a characteristically singular idiom.”
1.5 Both the Gate and the walls were listed in 1972, presumably before the Dixons Gardens proposal was approved, and so for the reasons suggested at paragraph 1.2 above we presume that the listing of the revetment walls and Gate were instrumental in the application site remaining without modern built development.
If we are correct in our suggestion at paragraph 1.2 above, nothing has changed since, so that the current application for the house should be refused because of the heritage value of the site.
2 Significance of Site
The significance of the application site is that, whilst not having merited being an outlier to Lansdown Cemetery and Beckford’s Tower (Grade II registered, in terms of historic garden designations; Grade II and Grade I listed respectively) the application site has the following features:
2.1 forms part of an area known as “Beckford’s Ride”
2.2 forms part of the curtilage or setting of the Grade II listed Beckford’s Gate
2.3 includes the Grade II listed wall supporting the upper terrace running right through the site
2.4 a Grade II listed wall forming/abutting the northern boundary of the site with the main garden of the “Beckford Gate” residence
2.5 the northeast corner of the application site abutting the Grade II listed Beckford Gate itself.
3 Relevant Planning Policies
3.1 The National Planning Policy Framework - (extracts considered relevant)
Core Principle 10 states that planning should “conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations.”
Paragraph 128 states that local planning authorities should require an applicant to describe the significance of any heritage assets affected including any contribution made by their setting.”
Paragraph 129 states that local planning authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) and should take this assessment into account when considering the impact of a proposal on a heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal”.…
Paragraph 131 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 putting them to viable uses consistent with their conservation; ………………..”
Paragraph 132 states that “When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. …………………. Substantial harm to or loss of designated heritage assets of the highest significance, notably………..……., grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.”
Paragraph 133 states that “ Where a proposed development will lead to substantial harm to or total loss of a designated heritage asset, local planning authorities should refuse consent , unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or …………….”
Paragraph 134 states that “where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.”
3.2 Local Plan - Saved Policies
The proposed development must also be considered against saved policy BH2 (development affecting listed buildings or their settings: – buildings or their features of special architectural or historic interest; - adverse effect on building’s contribution to local scene) and saved policy BH6 (development within/affecting a conservation area).
4 The Design and Access Statement
4.1 We would disagree with some of the assertions in the following extracts from the Design and Access Statement:
"6.14 Heritage statement: The proposal falls within a site devoid of any listed buildings with the closest listing being afforded to Beckford’s walk, a small section of which borders the site to the east. The proposed development would be set within the lower of two terraced areas to the north of Dixon Gardens. Dixon Gardens itself is believed to occupy a former market garden which it is understood previously fell within the estate of William Beckford. Beckford’s walk / ride to the east links the former stables (Springfield) at Upper Lansdown Mews to Lansdown Road. This allowed a link for Beckford to access his Tower from his home at Lansdown Crescent.
6.15 Little is known about the history of the application site although as yet, unsubstantiated assumptions have been made suggesting that it may have formed a viewing platform, providing views south towards the rear of Lansdown Crescent and beyond."
4.2 The assertion that "The proposal falls within a site devoid of any listed buildings..." seems to ignore that the listed wall supporting the upper terrace runs right through the site. Furthermore, if not “within [the] site” there are immediately adjacent (1) the listed wall which forms the northern boundary of the application site with the “Beckford Gate” house main garden and (2) the north-east corner of the application site abutting the listed Beckford Gate itself.
4.3 We note also the statement concerning pre-application consultation with B and NES as local planning authority referred to at paragraphs 5.1 and 5.2 of the Design and Access Statement accompanying the application, and mentioned in the application form. These seem not (or not expressly) to deal with the heritage assets within or adjacent to the application site. We would hope that, on further consideration of the historic interest of the site, the planning officer would now reconsider the favourable view referred to in the application form.
5 The Proposed Development
5.1 The proposed development is
- of land associated with the Grade II Listed Beckford’s Gate , and
- land associated with (and including part of) the Grade II Listed Walls enclosing nursery gardens (N and E sides) and Ride to Beckford’s Gate, and
- situated on land near to the Grade I Listed Beckford’s Tower.
- sited also within the City of Bath Conservation Area and within the setting of the City of Bath World Heritage Site.
5.2 We would ask that the following points should be taken into consideration when a decision is made:
- The Heritage Statement does not sufficiently address the heritage assets and their settings within and adjacent (or near) to the application site to enable an informed decision to be made in the context of such matters;
The proposal affects the significance of heritage assets and impacts
adversely on the designed landscape in that it would harm the setting
of the listed historic garden buildings of Beckford’s Gate and the
integrity of the walled terraces, all part of Beckford’s design for his
estate.
As the Avon Gardens Trust works closely with the Garden History Society, our comments on applications are forwarded to, and kept by, the Garden History Society.
We would be grateful to be advised of your decision.
Yours faithfully
Ros Delany (Dr)
Chairman, Avon Gardens Trust
Parkfield Farm / Avon / E14/0933 / N / PLANNING APPLICATION Removal of Conditions 1,7 and 9 attached to planning permission PK14/1701/F. Parkfield Farm, Lower Hamswell, South Gloucestershire BA1 9DE. MISCELLANEOUS / CGT WRITTEN RESPONSE 15.10.2014