Please forgive me for having to bring this matter to your attention, but as this application concerns a strategic housing site, I thought it merited your personal attention.
As you may be aware, this Society and others previously supported the allocation of this site in preference to some others through the LDF / Core Strategy consultation, as we believe that it offers the potential to have a positive regenerating effect on the Bretch Hill area. It was always a sensitive site owing to its proximity to the Grade II* Wroxton Abbey Registered Park and the Grade II* Drayton Arch, a skyline eye-catcher on the edge of the Registered land. We nevertheless believed that, subject to two- and two-and-a-half storey development similar to that on Bretch Hill, local screening and locally positioning development well back from the scarp, impacts on key designed views within the Registered area could be avoided.
Regarding grading criteria for Parks and Gardens, the English Heritage website notes:
The grading criteria are as follows:
Grade I sites are of exceptional interest
Grade II* sites are particularly important, of more than special interest
Grade II sites are of special interest, warranting every effort to preserve them
The majority of the sites identified on the Register are awarded a Grade II status. Around 27% of the 1,600 sites are awarded a Grade II* status, and a further 9% are classified as Grade I.
We are unfortunately profoundly disappointed by the application for outline consent submitted by Bloor Homes. Whilst we recognise that this is in Outline only, there is very little about the application that is in any way smart about how it responds to the site's environmental constraints. This is particularly the case with regard to the Wroxton Abbey Registered Park and the Grade II* Drayton Arch. Consent to develop up to four storeys in height is sought within the parameters. The parameters also seek for this to be set back uniformly from the western site boundary, without reference to local screening, the location of the scarp edge or historic and extant designed views within the Registered area. There is not even any attempt to ascertain where the designed views are, or what the effects on them are. Instead the applicant has simply chosen a historic environment noted for their, shall we say, strong client focus. They have chosen to simply justify the development by rubbishing the folly and the park:
3.2.31. The setting of the RPG partially lies in its historic origins, where it would be experienced as part of the grounds of Wroxton House. However, this has largely been destroyed through the implementation of agriculture across much of the land. Physical elements such as thickets of trees, ponds and follies remain, but these are not seen in their original context.
3.2.32. Essentially, the RPG does not exist as a parkland in any form, and the designation largely demarcates an area historically used as a pleasure park, but essentially only forms a curtilage boundary on largely agricultural land indicating the extent of the pleasure park. It is not experienced as a pleasure park, but as a series of crop fields and small thickets of trees.
3.2.33. It is thus not considered that the development of the Site can physically, visually or aesthetically impact on what is essentially an ephemeral designation of a boundary.Wroxton Park
3.5.26. Essentially, the RPG does not exist as parkland in any form, and the designation largely demarcates an area historically used as a pleasure park, but essentially only forms a curtilage boundary on largely agricultural land indicating the extent of the pleasure park. It is not experienced as a pleasure park, but as a series of crop fields and small thickets of trees.
3.5.27. It is thus not considered that the development of the Site can physically, visually or aesthetically impact on what is essentially an ephemeral designation of a boundary. Furthermore, there is negligible potential for impact on the remaining features of the Registered Park and Garden, as no development is proposed within the boundaries of the designated heritage asset, and thus these elements such as thickets and ponds will not be affected.
This hardly seems consistent with English Heritage's assessment of a site that is 'particularly important, of more than special interest'.
The effect on the folly is dismissed because the arch is viewed as having no surviving setting of any significance.
It hardly goes without saying that English Heritage were not consulted in the preparation of the heritage assessment.
Not only is the attempt to denigrate the park as being unworthy of its designation insulting to the professionalism of English Heritage who judged all of the registered area to meet the very strict criteria for designation at Grade II* when they added the Park to the Register, it is insulting to Fairleigh Dickinson University who own its idyllic core, and it is insulting to the to the wider community, who have spent significant sums on the restoration of the park and its monuments since the park was added to the Register.
The assessment fails to understand that the park includes, and has always included, a belt farmland around its inner core. It fails to understand that the Obelisk and the Drayton Arch have always been located in this farmland belt, acting as distant eye-catchers to be seen framed in designed views from within the inner park and from the historic approaches to the house. The failure of the assessment to even pay lip service to such very basic aspects of English historic landscape design unfortunately throws all the assessment's other conclusions regarding other heritage assets into doubt. That this is the case with the heritage assessment, throws into doubt the other studies submitted in support of the application.
Given this doubt, we would expect that this application cannot be determined on the basis of the height and location parameters sought, pending a full and independent assessment of effects on heritage, including a detailed assessment of all designed views and effects on each of them. We would expect the Fairlieigh Dickinson University and English Heritage to be consulted in the course of this assessment. When such an appraisal is carried out, perhaps it may be discovered that the site is not quite capable of accommodating all of the 'up to 400 homes' initially hoped for.
We still support the allocation of this site for residential use in principle. Due to the deficiencies in the heritage appraisal, we cannot support this application in its present state however.
I'd be most grateful if you could please forward this to the officer(s) dealing with this application.
(Rob Kinchin-Smith, Acting Chairman, Banbury Civic Society)