Comments on Developer’s Heritage Assessment – Land Opposite Adel Parish Church

ADDENDUM TO ADEL NEIGHBOURHOOD FORUM SUBMISSIONS

 Comments on Pegasus Heritage Assessment

The Adel Neighbourhood Forum (ANF) has the following observations on the developer’s additional heritage assessment submitted in support of this application. We would expect our comments to be given equal prominence in any report to the Plans Panel report to those in the developer’s assessments .

The developers of this site submitted a number of commentaries produced on their behalf by their sub-contractors which are referred to in the “sources” section. Those reports were far from objective, as one would expect, given the companies’ relationships as paid suppliers to the developer. Their comments were in stark contrast to the views expressed by the independent and authoritative experts of English Heritage and Historic England.

Having reviewed the comments made, we would urge that they are considered in close comparison with the contemporaneous advice given by English Heritage and Historic England as well as the critique of them contained in objections to the application for outline planning consent. For instance, we would point out that whilst the authors of those reports may claim an element of expertise they make  sweeping statements unsubstantiated by any evidence. It seems somewhat unlikely that they have even visited the site – for instance, one report made observations about a listed monument in Adel Churchyard which had in fact been stolen some years previously. We would therefore argue that they are partial as well as lacking in expertise, particularly when contrasted with the commentary provided by acknowledged experts English Heritage and Heritage England

 

 

Adel Neighbourhood Forum has the following observations on the latest report, which has been prepared for the developer’s purposes, by Pegasus Group. Our analysis of it shows that like its predecessors, it lacks objectivity and its conclusions unsubstantiated by any actual evidence:

PEGASUS STATEMENT:

“Summary 

“ This Heritage Assessment has been prepared in support of the reserve matters application for residential development at land to the east of Otley Road, Adel.”

“This Assessment has shown that the layout has been prepared in accordance with recommendations and consultation responses prepared for and received during the application for outline planning consent on the site. The proposed pumping station and grasscrete access track are the only elements of the proposed layout which are to be placed east of the beck. The provision for this is set out in condition 20 placed upon the planning permission of the outline application 16/06222/OT for residential development for up to 100 dwellings and land reserved for a primary school. This condition states: “there shall be no buildings except those required with any drainage proposal on the eastern side of the existing Beck”. Therefore, due to the sensitive design of the proposed layout and lack of development to the east of the beck, barring the pumping station which was allowable via planning condition 20 of permission 16/06222/OT, it is considered that this reserve matters application would not cause any harm to the significance of the Adel St. John’s Conservation Area and the grade I Church of St. John the Baptist.”

ANF comment

It is noted that the author concedes that the pumping station will cause harm to the significance of Adel St John’s Conservation Area and the Grade 1 Church of St John the Baptist.

The only justification given for the pumping station is that it can be constructed under the wording of the relevant planning consent.

Our understanding is that the planning condition quoted was inserted by a Council Officer, and we note that it was done without the authority of the Plans Panel, and without any public consultation. We therefore consider that that agreement is  unlawful; it is the subject of a formal complaint by an Adel resident.

 

 

PEGASUS STATEMENT: 1. Introduction

“Pegasus Planning Group have been commissioned by Barratt Homes and David Wilson Homes West Yorkshire to carry out a heritage assessment of the proposed pumping station and access road at Otley Road, Adel as shown on the Site Location Plan provided at Figure 1. This assessment is prepared as an addendum to the Heritage Appraisal undertaken by Montagu Evans1 on behalf of Hallam Land prepared to support the outline planning application on land to the east of Otley Road, Adel (16-06222/OT). This addendum has been prepared to support the reserved matters application including supporting the proposed location of the pumping station and access road. It is noted here that condition 20 placed on the planning permission states: “There shall be no buildings except those required with any drainage proposal on the eastern side of the existing Beck. In the interests of visual amenity.” Although located on the eastern side of the beck, the pumping station is a structure associated and required for drainage purposes and therefore falls within the purview of this condition. It is thus considered that the location of the pumping station to the east of the beck is acceptable.”

ANF comment

Again, the authors have made no attempt to address the heritage implications of the pumping station and associated culverting of the beck and concrete road.

 

 

PEGASUS STATEMENT: “2. Methodology 3.Planning Policy Framework”

ANF comment

The author provides 15 pages of their opinion on how heritage assessment should be carried out and on planning law. There is no specific reference to the site in question, so whilst not necessarily accepting the author’s opinions, ANF has no comment.

 

PEGASUS STATEMENT: 4. The Historic Environment

“……….There is relatively scant evidence for prehistoric activity within proximity to the site, with evidence limited to findspots of flint artefacts. There is evidence for Roman activity in the wider surrounding area with the route of the Roman road between the forts at Ilkley and York running 1km to the north of the site………”

ANF comment

This report fails to make any reference to the probability of a Roman Road as shown by crop marks which extends north to south for the full length of the site west of the beck. It is therefore inaccurate and incomplete.

 

 

 

PEGASUS STATEMENT: 5. Setting Assessment

“5.4 The Adel St. John’s Conservation area is located to the east of the proposed development, the western boundary of the asset formed by the line of Church Lane. The Adel St. John’s Conservation Area Appraisal of 2009 identifies that the special interest of the Conservation Area is from its long historical associations and the survival of a number of historic buildings which display the local architectural traditions. The rural character of the surroundings of the Conservation Area also contribute to its special interest, as it acts as a gateway between the suburban areas of Leeds and the open countryside beyond. A number of key views have been identified in the Appraisal document, though in the accompanying text it states that “there are many interesting views. The most prominent building is St. John’s Church. Much of the rest of the architecture is set back P18-0944 │ LCG │ July 2018 Otley Road, Adel 20 from the road or shielded. This means there are no focal point buildings, rather the buildings make up scenes and have a cumulative impact on the streetscape.” It is therefore noted that if there are a number of interesting views, the selection of a key view is perhaps more arbitrary.”

 

ANF comment

There is nothing arbitrary about the statement of key views into and out of the conservation area; the appraisal document was thoroughly and expertly prepared. This is merely an attempt by Pegasus to denigrate the important  provisions of the conservation area appraisal without any foundation in fact.

 

PEGASUS STATEMENT: “ A view across towards the site from Church Lane is noted as an important long-distance view. It is acknowledged that there are views available from this point across and along the valley floor which add to the sense of rural surroundings, however the development will not remove or impact upon these views.

 

ANF comment

The development as currently proposed will impact on these views by substituting a view of jam-packed bog standard BDWH houses for the current view of open farmland against a woodland background .The Pegasus statement is plainly untrue.

ANF have consistently asked the developer to design something of better quality for this special site so that the alteration to the views will be less offensive. English Heritage advised: “ The design and materials used for the new buildings will affect the extent and nature of the visual impact of the development when viewed from the church. Therefore, ensuring the design and materials reflect the local built character will be a critical part of the reserved matters stage. High quality traditional, local materials should be used taking reference from the existing character of the settlement.” The views of ANF and of English Heritage have been completely ignored.

 

PEGASUS STATEMENT: “The landscaping proposals and retention of a significant buffer of open land means that the sense of the rural surroundings will be maintained and the long views across the valley and along the valley floor will not be reduced or compromised. “

ANF comment

We totally disagree. Of course the long views will be compromised. See above.

 

PEGASUS STATEMENT: “The Church of St. John the Baptist is a grade I Listed Building constructed in the 12th century with a number of later additions and alterations. It is located on higher ground to the east of the site within a churchyard east of Church Lane. As described in the topography section above, the site slopes down towards the beck at the centre of the site before rising up again, but on a shallower slope towards the western boundary of the site. Therefore, although there is the potential for the pumping station to be visible from the church, or within the churchyard, the topography and low height of the building means that views will be glimpsed, and given its scale, will read as an isolated building, possibly agricultural in nature rather than as an outlier to a larger development scheme.”

ANF comment

The assertion that a pumping station (and associated concrete road) might be confused with an agricultural building is risible. It is precisely the sort of built development which the condition agreed by the Plans Panel was designed to avoid. 

Historic England has consistently opposed any built development east of the beck.

 

PEGASUS STATEMENT: “ 5.7 The setting of the church of St. John the Baptist is primarily provided by its surrounding churchyard with its stone boundary wall and strong vegetation and tree planting around the edge. This churchyard provides an enclosed feeling around the church, which matches with the churches more intimate scale, with a lack of tower or strong visual presence in views towards the asset. There are glimpses to the surrounding rural landscape through the vegetation around the churchyard which provide a sense of the rural and agricultural surroundings of the asset and which contribute a minor amount to the significance of the asset, but is not the primary setting of the asset in terms of contribution to significance.”

ANF comment

The rural surroundings of the churchyard contribute much more than “ a minor amount to the significance of the [church]”.   English Heritage’s expert assessment is completely contrary to this assertion  by Pegasus and points to a completely different approach to understanding an asset in its setting to that put forward by the developer’s report-writer. English Heritage stated “ … the way in which we experience an [historic] asset in its setting is also influenced by….spatial associations…The setting of the Church of St John is a perfect example of this ; the appreciation and understanding of the building as a twelfth century rural church is enhanced by experiencing the peaceful nature of its setting and spatial qualities of the open fields as well as the visual impact of long-distance views incorporating green fields and vegetation”.

 

PEGASUS STATEMENT There are few views towards the church from vantage points within the site. Whilst traversing the public footpath which crosses the site there are hardly any views of the church. Even when foliage is at its least dense in winter, the position of the church, set back from its boundary and the lack of a tall tower or spire means that it is not a prominent presence within the landscape.”

ANF agrees with English Heritage’s assessment of the importance of the church, churchyard and their wider setting, including the views from the ancient footpath. The Pegasus statement shows a complete failure to appreciate the quality of the view of the church and churchyard when approached from the ancient footpath.

 

PEGASUS STATEMENT: “The significance of this church lies primarily in its architectural and historic interest. It provides historic evidence of the early origins of Adel as a settlement and with the grave slabs within the churchyard provides information on the society and occupants of Adel throughout the centuries. Its early origins provide architectural evidence for changes in fashion in ecclesiastical architecture as well as information on the local materials and styles. “

ANF comment

This is a further attempt to ignore the importance of the rural setting of the church and churchyard. Of course the architectural and historic interest is important; but its open and rural context as noted by English Heritage is a unique survival giving it a special quality ; it must not be eroded by any development east of the beck.

 

PEGASUS STATEMENT: “5.10 It was noted in consultation responses received from Historic England24 that the setting of the church of St. John retains a strong rural character which contributes to its significance by enabling an appreciation of its early origins and isolated position as well as an appreciation of its FORMER [my capitals] rural surroundings. It was also stated that the development would harm the character and appearance of the Conservation Area due to the loss of a portion of the open fields that contribute to the rural character of the assets; setting to the north and west. It is considered that these considerations have been addressed with the reserve matters layout.”

ANF comment 

This is a misrepresentation of what Historic England wrote on 12 April 2017, not least insofar as Historic England was writing about the CURRENT rural surrounding of the church. Nowhere in the letter is there any reference to “former” rural surroundings. In complete contrast to the suggestion put forward by Pegasus, Historic England are reinforcing the point that the ancient rural surroundings of the church have survived-and must not be destroyed. The letter from Historic England should be re-read in full to put this Pegasus report in proper context.

Historic England wrote “ We have consistently advised that no development should take place to the east of the beck”. Pegasus have put forward no argument or evidence at all to back up their suggestion that this consideration has been addressed.

 

PEGASUS STATEMENT: “ The principal of the proposed development has been discussed in a number of heritage appraisals and assessments produced for the outline planning application.

ANF comment

This references only those appraisals commissioned by the developer

 

PEGASUS STATEMENT: “The proposed layout which forms part of the reserve matters application has been undertaken with the consultation comments received from Historic England and the Leeds City Conservation Officer in mind”.

ANF comment

Pegasus has made no attempt to demonstrate how it has taken account of any of these comments. Our analysis shows that in fact, these comments have been completely ignored.

 

PEGASUS STATEMENT: “5.14 Therefore, the level of impact to the significance of assets resulting from changes in setting was established and accepted by the grant of permission of the outline planning application. The addition of the pumping station to the east of the beck does conflict with advice and comments given on the outline planning application, however as stated above, planning condition 20 allows for such a structure and the design and location of the building is such that it is at a low-level, adjacent to the beck and will not be a prominent feature within views from the church or the Conservation Area across. The location of a single building in this area gives the impression of an isolated farm or agricultural building, constructed in the local vernacular and not out of keeping within the view. Therefore, the pumping station to the east of the beck will cause no harm to the significance of the grade I listed church or to the Adel St. John’s Conservation Area. It is also considered that the masterplan as a whole will not cause harm to the significance of the grade I listed church or to the Adel St. John’s Conservation Area through changes to its setting.”

 

ANF comment

Pegasus accept that the building a pumping station east of the beck flies in the face of advice, but their client intend to build it anyway because they have planning consent.

Clearly Pegasus’s brief is to downplay the damage that this building will inevitably do. Although our understanding is that no plans of this structure have been made available (as stated in Leeds City Council’s own conservation team’s statement), Pegasus have attempted to fob off concerns by talking about it as “low level” and “not prominent” and that it is now taking on the form of an “isolated farm or agricultural building constructed in the local vernacular”? We consider that this statement is completely ridiculous. If Historic England had considered it was possible to mitigate the damage to the setting in this way, then it was open to them to say so: they did not, they were clear that there should be no building at all to the east of the beck. The suggestion that this building could be built in the “local vernacular” also raises the issue of why if BDWH have the ability to build in the local vernacular, they are refusing to do so for the whole development.

PEGASUS STATEMENT:

  1. Conclusions

“This Heritage Assessment has been prepared in support of the reserve matters application for residential development at land east of Otley Road, Adel. The outline planning application considered matters of heritage including the impact of the outline scheme upon the significance of identified heritage assets through changes to setting and found this to be acceptable. The reserve matters application for the details of the layout and other matters has followed advice given in the consultation responses to the outline application….”

“The proposed layout has been prepared in cognisance of the consultation responses for the outline planning application from historic England and the Leeds City Conservation Officer. In accordance with their statements, and in accordance with the conclusions of the various heritage appraisals carried out in support of the outline planning application, no residential buildings have been located to the east of the beck, the height of the proposed houses has been restricted to two-storeys and a large buffer of open land both within the red-line boundary of the development and beyond to Church Lane has been retained. Boundary treatments on areas facing towards the Conservation Area and the grade I listed Church of St. John the Baptist are proposed as 1.8m high stone walls, referencing local forms surrounding boundary treatments, with other boundaries formed by 1.8m high timber fencing. Therefore, due to the sensitive design of the proposed layout and lack of development to the east of the beck, barring the pumping station which was allowable via planning condition 20 of permission 16/06222/OT, it is considered that this reserve matters application would not cause any harm to the significance of the Adel St. John’s Conservation Area and the grade I Church of St. John the Baptist.

 

ANF comment

Contrary to the wording carefully selected by Pegasus, the outline planning application was quite specific that there should not be any buildings (residential or otherwise). The Pegasus report insinuates that Historic England advised against any residential building east of the beck; they did not-they advised against any built development whatsoever.r

 Once again Pegasus clearly acknowledges that the pumping station WILL cause harm,and would only be permitted if the wording discussed with a Leeds City Planning Officer is permitted to stand.

No evidence or arguments have been presented to explain the “sensitivity” of design, nor how high in the landscape any development will sit. This is a major failing of a document that purports to address these issues.

Whilst “in cognisance of” demonstrates that the developer  has seen the material generated by others, our conclusion is the developer  has the proceeded to ignore it.

 

 

Adel Neighbourhood Forum Comments on the report from Leeds City Council Conservation Team.

 

The report is weak and incomplete.

It simply makes unsubstantiated statements about the impact of the development, and offers no evidence for such judgements. These assertions are in direct contradiction to the many statements by English Heritage and Historic England, who have had much to say about the impact of development of this site on the setting of and important views from the Grade 1 listed church and conservation area.

The report asserts that the impact on the Grade 1 Church of a pumping station east of the beck is likely to be minimal but goes on to admit that the author does not know what the pumping station machinery will look like. This assertion can therefore carry no weight. Further, the developer’s own commissioned report on heritage makes clear several times that the proposed pumping station will have a negative impact but simply goes on to claim that it has planning consent.

The report also contains errors. For instance, it comments on an 1800mm fence around the pumping station. The only such fence shown in the site layout is to the north of the pumping station and does not enclose it.  ANF objects to any such fencing in this location or anywhere east of the beck.

Out of the numerous conservation issues relevant to the site, the report only addresses the proposed pumping station. For some reason that is not explained in the report, it does not cover any other relevant issues.

Clearly others in Leeds City Council were anticipating a rather fuller and quite different response from Conservation, as they state in their response:

  1. Bio- diversity is being dealt with by my Nature Conservation colleague but the change from a pond offering multiple benefits including public amenity, public access and recreation is a significant loss to the quality of this scheme. This is being replaced by an underground tank with above ground apparatus all of which will sterilise the area. The original plan for the area should be restored and this will undoubtedly be supported by the Land drainage team.

We would also have expected that the Council Conservation Team would have covered a range of key issues. For instance, English Heritage advised  : “ The design and materials used for the new buildings will affect the extent and nature of the visual impact of the development when viewed from the church. Therefore, ensuring the design and materials reflect the local built character will be a critical part of the reserved matters stage. High quality traditional, local materials should be used taking reference from the existing character of the settlement”

Yet the LCC Conservation Team report is completely silent about design, materials, density, greenspace or any of the other factors relevant to the visual impact from the church and conservation area. It just states – erroneously – that the previously raised conservation concerns relating to this site have been limited to development to the east of the beck.

 

 

Adel Neighbourhood Forum Comments on revised Community Engagement Statement

The developers are well aware that because of its impact on the church and conservation area, this development impacts on all residents of Adel, not just those whose homes adjoin the site. The limited distribution of leaflets was inadequate.

The meeting on 11 May 2018 with councillors and ANF representatives was not for the purpose of consultation on these proposals. BDWH had not previously disclosed its proposals so any comment made on them when plans were tabled at the start of the meeting were very much ad hoc. The purpose of the meeting was to try to persuade BDWH to have some meaningful consultation with Adel residents before any reserved matters application following a complete absence of consultation at the outline stage.

The circulation of the event at Adel Stables in June 2018 to 2000 households arose from the initiative of our local councillors. BDWH made no effort to publicise the event.

It is not accepted that the Community Engagement Statement presents a fair representation of resident’s comments. We are aware that a number of residents objected to a pumping station and service road being placed east of the beck, yet this is not mentioned. We are sceptical that anyone asked for “ the pumping station to be positioned sensitively in relation to the church to ensure it is not visible”.

Cconsultation should be a two-way exercise with BDWH responding to comments made by local residents and changing their plans to take account of reasonable points raised. There is no evidence of BDWH making or having any intention to make any changes to their proposals to take account of points made to them. The leafleting and public display of their proposals was no more than a box-ticking exercise.

 

 

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