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).
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
‘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 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).
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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