Exploring the Hidden History of the Vale of Glamorgan

August 29, 2022

Lower Cosmeston Farm Development Objection-Heritage

 

This article is a critical assessment of the Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage of the Welsh Assembly Government's planning application for Lower Cosmeston Farm, as well as comprising a small part of our overall objection to this scheme. 

Introduction

The intrinsic loss of valuable ‘greenfield agricultural farmland’ which is currently designated as being within the LDP’s defined ‘settlement boundary’ of Penarth, 1.28 ha of which is currently designated as a ‘Green Wedge’ encompassing Lower Cosmeston farmhouse, is the chief concern amongst critics of this scheme (Land at Upper Cosmeston Farm, Lavernock Road, Penarth Green Wedge Review, 3.1. p4.).

There is an acknowledgement within the Landscape Visual Impact Assessment that

The proposed development on Upper Cosmeston Farm will have some significant adverse effects, even at 15 Years of operation, as the proposal is a large scale mixed use development on what is now ‘greenfield’ agricultural land (Environmental Statement-Addendum. Volume 2, Chapter 7; Landscape and Visual.7.133).


(Painting by artist Alfred Sisley (1896) showing the beauty of the Vale coastal footpath and in the distance a part of the land at Lower Cosmeston Farm which is set to be built upon)

There are also other concerns such as increasing traffic, pollution, the destruction of natural habitat which is home to a wide range of animal, insect and plant life, the impact the development will have upon heritage assets, namely the recently Grade II listed Lower Cosmeston farmhouse and its associated farm buildings, archaeological remains, as well as the general effect that constructing a mass of new houses will have upon a parcel of land that is both comprised of and surrounded by lush countryside.

In short, this development plan constitutes a direct, and in our opinion an unnecessary and avoidable assault upon the natural environment.

Impetus for Development. Allocation within the LDP

Lower Cosmeston Farm’s inclusion within the revised LDP is viewed by proponents as an assumption in favour of development and by some a legislative duty. The Planning Statement (Addendum) 2022 states that

The Principle of Development 7.2 In accordance with the LDP the majority of the site is located within the settlement boundary and is allocated for housing with infrastructure including education and community facilities. As such the principle of developing the site for residential use with supporting educational and community facilities is considered to be accepted’ (by the Welsh Assembly Government) (Planning Statement (Addendum), Land at Upper Cosmeston Farm, 2022. pp27).

The inclusion of ‘Upper Cosmeston Farm’ within the revised LDP means that it is free from the constrains of Policy MD1 of Section 7,‘Managing Development in the Vale of Glamorgan’, Location of New Development, which states

New development on unallocated land should have no unacceptable impact upon the countryside’ and ‘have no unacceptable impact upon the best and most versatile agricultural land’ (LDP, Written Statement 2017, pp 99).

The word ‘unacceptable’ is of course subjective and open to varying interpretations based upon different perspectives, however according to policy within the planning policy framework for Wales, and also to many ordinary people, most housing developments built upon open farmland, within or contiguous to the green wedge and on most greenfield sites, would generally be regarded as unacceptable with brownfield sites being considered preferable. This is reflected in PPW ‘previously Developed Land’ (3.55) (Planning Policy Wales, Edition 11. February 2021.pp3).

The statement of intent, or an assumption in favour of development, that Lower Cosmeston Farm’s inclusion within the revised LDP seemingly gives the applicant however does not mean that this application is free from the constrains of protocol found within the planning policy framework for Wales.

There exist a number of policies that both give credence to and go against this application and it must therefore be judged upon its merits and its detriments rather than utilising simplistic platitudes such as ‘we need houses’ ad lapidem which we often hear from advocates of such house-building schemes, and/or using apriori reasoning such as the belief that because Lower Cosmeston Farm is ‘allocated’ within the LDP, that overrides all material considerations.

There exist a number of important material considerations that this planning application must satisfy in order to gain planning permission. Having read through and critically-assessed the reports addressing the most pertinent material considerations, namely Quality of Land, the impact upon the Green Wedge, issues surrounding heritage assets and the overall visual effect that this development will have upon the surrounding landscape, it has become clear that the benefits that new housing developments can bring are significantly outweighed by the harm that this development plan, if allowed to proceed, would cause at Lower Cosmeston Farm,

Heritage

 The Farmhouse at Lower Cosmeston Farm is a building of considerable local importance. CADW describe the building as

Multi-period house, nucleus of a single-unit house built C17 or C16’.

CADW’s reasons for designation are

Included for its special architectural and historic interest as a rare surviving pre-1700 farmhouse with its form and layout largely legible, retaining clear evidence of its early origins (with surviving features) and its development in the 17C


(The farmhouse at Lower Cosmeston Farm)

The Conservation Officer’s Report, states that Lower Cosmeston Farm is ‘an historic farmstead of some significance’, Peter Thomas, Senior Planner (Conservation and Design) (Conservation Officer comments. p5).

In a meeting with the applicants Peter Thomas stated

It was agreed that the implementation of the proposed Development brings forward opportunities for the enhancement of the farm buildings in the short term because it can secure conservation and restoration of their historic fabric as they are converted to sustainable new uses’ (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.27).

However

At the same time, it was agreed that, in the longer term, the implementation of the proposed Development is likely to have more negative effects arising from the changes within the setting of the farm buildings. It is a question of balancing the long term impact on the buildings’ setting against the benefits arising from the delivery of physical improvements to the farm buildings’ (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.28).

Methodology Employed by Applicant

Lower Cosmeston farmhouse, and by association its barns, are now Grade II listed structures. The Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage paper sets out to identify and

Assess the potentially significant effects of the Proposed Development in respect of cultural heritage resources, in accordance with Chapter 6 of Planning Policy Wales (PPW) Edition Eleven (Welsh Government, 2021a)’ (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage.12.2).

The Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage paper

Employs the methodology detailed in Cadw’s publication Heritage Impact Assessment in Wales (Cadw, 2017a) (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.19).

The identification and assessment of ‘significance’ for the various historic assets draws on the four ‘heritage values’ defined by Cadw in Conservation Principles (Cadw, 2011). These values consist of:

• The asset’s evidential value, which is defined as those elements of the historic asset that can provide evidence about past human activity, including its physical remains or historic fabric.

• The asset’s historical value, which is defined as those elements of an asset which might illustrate a particular aspect of past life or might be associated with a notable family, person, event or movement.

• The asset’s aesthetic value, which is defined as deriving from the way in which people draw sensory and intellectual stimulation from the historic asset.

• The asset’s communal value, which is defined as deriving from the meanings that a historic asset has for the people who relate to it, or for whom it figures in their collective experience or memory (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.21).

Applicant’s proposal

The applicant has proposed a ‘medium’ sensitivity categorisation (rather than high due to the loss of some of its historic fabric) for the designated historic asset, or Farmhouse at Lower Cosmeston Farm (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.61).

The applicant plans to retain and restore the fabric of the farmhouse and three associated barns contained within its curtilage which would be

Converted into Community, Commercial and Co-working facilities alongside the development of the new school on the land adjacent to the south-east’ (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.168).

I would agree with the applicant that the renovation of these buildings would help to stabilize the historic fabric and provide greater public access. However, the restoration of these buildings would come at a great cost to their integrity as historic monuments as their setting would be significantly altered from a rural environment to an urban one. The field to the north would become the site of a housing estate, and the land to the south-east is mooted to provide space for a primary school, car parking and ancillary structures as well as a new vehicular route directly adjacent to the southern side of Lower Cosmeston Farm (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage v ).

Negative Effects of Development   

The setting of an historical building is essential to its integrity, this is reflected in CADW’s ‘aesthetic value’, as well as a number of laws governing the treatment of historic buildings in Wales such as The Planning (Listed Buildings and Conservation Areas) Act 1990.

Planning Policy Wales Edition Eleven (2021) also contains pertinent information.

Paragraph 6.17 states

 It is important that the planning system looks to protect, conserve and enhance the significance of historic assets. This will include consideration of the setting of an historic asset which might extend beyond its curtilage. Any change that impacts on an historic asset or its setting should be managed in a sensitive and sustainable way (Planning Policy Wales, Edition 11. February 2021.pp 126).

Paragraph 6.1.10 states

There should be a general presumption in favour of the preservation of a listed building and its setting, which might extend beyond its curtilage (Planning Policy Wales, Edition 11. February 2021. pp 126).

Setting and Character of Lower Cosmeston Farm

Surrounding landscape

It is acknowledged within the Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage that

The development of the site would sever the interrelationships between the historic farm buildings and the agricultural landscape that historically supported them, and which was managed from the farmstead. This element of the farm buildings’ wider setting would be entirely lost if proposals for the site’s development come forward to implementation; being replaced with a variety of built form to the north, north east and south east and with it also being anticipated that the field to the south will be developed for a new school for special educational needs in due course’ (Environmental Statement-Addendum, Volume 2. Chapter 12 12.195).


(Field to the northern extent of the WAG's 'defined settlement boundary' of Lower Cosmeston Farm)

That this setting would be entirely lost is unacceptable and it is challenging to think of how this change would accord with PPW paragraph 6.17, wherein it states that ‘any change that impacts on an historic asset or its setting should be managed in a sensitive and sustainable way. The total annihilation of the surrounding landscape can hardly be considered sensitive or sustainable.

Historic road

The old road, which lies adjacent to the modern Lavernock Road and which now serves as a lane which gives access to Lower Cosmeston Farm, would be completely destroyed upon completion of this development and thus deprive Lower Cosmeston Farm of a significant amount of historical character.

Victorian period farmhouse

The Victorian period farmhouse which lies adjacent to the lane would also be destroyed. The applicants argue that this house is of ‘negligible significance’ as it is not considered to be a part of the curtilage of Lower Cosmeston farmhouse. This house however was built in 1896 as a direct replacement to the earlier building by noted architect EWM Corbett who was the Marquis of Bute’s estate architect. Corbett was responsible for designing a number of architecturally important buildings within Cardiff such as the Royal Hamadryad Hospital for Seamen (1905) and the Former County Club (1895), which is now a listed building. Thus, Mr EWM Corbett is an architect of note. This should be given consideration.

The Victorian farmhouse however

Is considered to make a contribution to the significance of the other buildings to the south because it serves to illustrate and highlight an important developmental shift in the arrangement and administration of Lower Cosmeston Farm’ (Environmental Statement-Addendum, Volume 2. Chapter 12 12.144).

Applicant’s opinion regarding aesthetics

The aesthetic value, notably the setting, of Lower Cosmeston Farm is believed by the applicants to constitute only a ‘small portion of their significance’ (Environmental Statement-Addendum, Volume 2. Chapter 12 12.198). On the contrary, PPW Paragraph 6.17, PPW paragraph 6.1.10, and CADW’S ‘aesthetic value’, from its conservation  principles all seem to contradict this belief. The Conservation Officer has also expressed concerns in regards to

Whether the proposed development preserves the listed building, its setting or any features of architectural or historic significance it possesses’ (Conservation Officer Comments, p1).

It is clear from the Heritage Report that this development proposal does not in any way, shape or form preserve the setting of Lower Cosmeston Farm. The applicant has not even thought to include a protective green buffer-zone.

Mitigation Measures

In view of the aesthetic damage that would be caused by this development proposal the applicant has proposed a number of mitigation measures which they believe would offset the visual damage the development would render to the farm buildings at Lower Cosmeston Farm.

One mitigation measure proposed by the applicant is to retain a small section of land on the

straightened alignment of Lavernock Road, in order to maintain visual relationships between the statutorily and curtilage listed buildings and the medieval settlement of Cosmeston on the opposite (south-west) side of the B4267’ (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12,189).

The intention to leave the land to the south and west ‘largely undeveloped’ is a pragmatic idea to help maintain the rural feel or ‘experience’ of Lower Cosmeston Farm (Environmental Statement-Addendum, Volume 2. Chapter 12: Heritage 12.192). This idea however would in the long run prove to be ineffective as the mass of houses mooted for development in the large field immediately to the north of Lower Cosmeston Farm would ultimately serve to provide an incongruous urban intrusion and thus negate the ‘rural feel’ that the small chunk of land to the south and west would seemingly provide.

Looking at the master plan it is also evident as mentioned above that there is no green ‘buffer zone’ in place within the field to the north to help provide softening between the new houses and the historic farm buildings. This is something that if included would help to provide an effective mitigation against modern urban encroachment as we have seen with other local historic assets such as St Brynach’s Church Darren Farm Cowbridge, and the recent development near Old Cogan Farm Cogan. The author of this objection would realistically expect to see a similar measure in place at Lower Cosmeston Farm as it is challenging to think of a similar Grade II listed structure from a similar rural environment that does not have a protective green buffer-zone in place.

Overall the effect of change that this new development would bring to Lower Cosmeston Farm’s aesthetic relationship with the reconstructed medieval village of Cosmeston and surrounding landscape is regarded as being significant. The applicant views the majority of these changes as being ‘positive’.

Conclusion

The applicant essentially argues that in regard to Lower Cosmeston Farm, its evidential value, historic value and communal value are more significant combined than its lone detractor-the buildings aesthetic value- hence, the development plans if brought forward, would go some way towards fulfilling these three values to the detriment of the one-lower Cosmeston Farm’s aesthetic value.

In view of the changes proposed however the alteration to Lower Cosmeston Farm’s setting or ‘aesthetic value’ from a rural one to an urban one would be by far the most significant. The development plan and the mitigation measures proposed certainly do not accord with Paragraph 6.17 of PPW viz the setting of a designated asset which should

‘Be managed in a sensitive and sustainable way (Planning Policy Wales, Edition 11. February 2021. Pp 126).

The almost complete loss of the landscape as well as the modern and incongruous form and layout of the new buildings are anything but ‘sensitive’ and would serve to eclipse the other three heritage value considerations which are all rather modest in terms of the ‘sustainable’ enhancements involved. Whilst the idea of restoration is appealing it is not imperative at this moment in time and in view of the destruction of the most important factor in this discussion, namely the setting of Lower Cosmeston Farm, it would be best if renovation was left for a future date and that a ‘presumption in favour of the preservation of a listed building and its setting, which might extend beyond its curtilage is enforced (Planning Policy Wales, Edition 11. February 2021. pp 126).

 

 

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