Object

Representation ID: 70000

Received: 21/04/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The southern approach to Warwick, including the Gallows Hill site, contributes to the significance of the town (designated Conservation Area), the Castle (Grade 1 Listed Building and Scheduled Monument), and Castle Park, Grade 1 Registered Park and Garden). The site is also 'in itself' a (non-designated) historic landscape and abuts the Grade II Listed Toll House. National policy expects 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. There is also an expectation that local planning authorities set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment , recognising that heritage assets are an irreplaceable resource. To ensure the Local Plan's soundness it is important to satisfy these national planning policies.
Additionally, special regard must be given to desirability of preserving the setting of a listed building; and to the desirability of preserving or enhancing the character or appearance of conservation areas.
At the recent Asps appeal, the Council, the local community, HE and others presented a clear and robust case. The Inspector and SoS acknowledged the likely harm to the significance of affected heritage assets. However the SoS placed great importance on the lack of an adequate housing supply and so granted permission. That decision does not alter the case that Gallows Hill contributes to the significance of a number of very important heritage assets and that development would cause harm to that significance contrary to national policy.
Further development to the south of Warwick on the Gallows Hill site will exacerbate the impact of intrusive development within the landscape and that the cumulative impact of development to the south of the town reinforces the importance of Gallows Hill.
HE has no reason to disagree with the conclusion of the Councils own evidence - The Setting of Heritage Assets Gallows Hill, Warwick (2014) - that the harm to highly graded heritage assets could not be adequately mitigated or justified and therefore should not take place. It is therefore a surprise to note the Council intends to include Gallows Hill as a development site in the Proposed Modification to the Local Plan.
Only where harm is unavoidable should mitigation be considered. Any harm and mitigation proposals need to be fully justified and evidenced to ensure they will be successful in reducing harm. It is not apparent whether such a case has been made by the Council to justify the allocation of Gallows Hill, or shown how harm might be mitigated.
Modifications to the Local Plan enable the Council to identify suitable sites within the District, and beyond if necessary, to accommodate future growth and the delivery of sustainable development in accordance with the NPPF, a core principle being the protection and enhancement of the historic environment. Published Modifications demonstrate the potential availability of more suitable alternatives to Gallows Hill. HE encourage consideration of an alternative spatial strategy (in respect of the Gallows Hill site), and in doing so demonstrate a positively prepared plan, that is technically sound and in accordance with national planning policy.