APPENDIX 3
HERITAGE COMENTS
LAND AT MANOR FARM, CRANMER, SCULTHORPE, NORFOLK NR21 9HZ
APPLICATION NO. PF/14/0680
INTRODUCTION
This application proposes the erection of a single wind turbine at land associated with Manor Farm,
Sculthorpe, with access road. The height to the hub of the turbine will be 49m and 78m to the tip of
the blades.
Beacon Planning has been asked to assist North Norfolk District Council by providing heritage advice
on the proposal and visited the site and heritage ‘receptors’ on 10 November and 5 December 2014.
We have seen the documentation relating to this application, and the comments and objections
received. We have however formed our own, independent view of the proposals.
For completeness, we have looked at all the sites which we feel could potentially be affected by the
development rather than just concentrating on those identified by, for example, English Heritage.
We have however concentrated on designated heritage assets (specifically scheduled monuments,
listed buildings, registered parks and gardens and conservation areas) rather than seeking to identify
any non-designated heritage assets. This is with the exception of the locally designated park and
garden within which the application site is located.
It is noted that although the applicant has acknowledged the local designation of the Cranmer Hall
Parkland, it has failed to adequately assess the impact of the proposed development on the
significance of this Parkland as a non-designated heritage asset in its own right – it is not included in
Appendix C of the Heritage Statement which lists those heritage assets assessed. This is particularly
important as this non-designated heritage asset essentially forms the setting to the highly
designated Cranmer Hall. The Parkland has its own local designation description which provides
information about its significance and which does not appear to have been referenced in the
analysis of the setting of Cranmer Hall. The applicants are therefore incorrect when they state in
para 6.2 of the Heritage Statement and 4.39 of the Design and Access Statement that ‘the proposed
turbine would have no direct impact on any heritage asset’ – there will be no direct impact on any
designated heritage asset, but there will be a direct impact on the non-designated heritage asset of
Cranmer Park.
In considering the potential impact on the setting of the designated heritage assets identified,
paragraph 132 of the NPPF is clear that harm to heritage significance can occur through
development within an asset’s setting and it advises that ‘the more important the asset, the greater
the weight’ which should be given to its conservation. This reflects the statutory duty imposed on
those making decisions about listed buildings and conservation areas by Sections 66 and 72 of the
Planning (Listed Buildings and Conservation Areas) Act 1990. The former (in the case of planning
applications affecting Listed Buildings) states that:
‘...the local planning authority …shall have special regard to the desirability of preserving the
building or its setting or any features of special architectural or historic interest which it
possesses’.
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The application site is located within the boundary of a locally designated park and garden, and will
therefore have direct physical impacts on this non-designated heritage asset. Paragraph 135 of the
NPPF is clear that the effects on such assets should be a consideration in the determination of
planning applications.
THE APPLICANT’S METHODOLOGY
The methodology states that by virtue of their reduced settings, scheduled monuments have only
been assessed within a two mile radius by virtue of their more restricted settings. We do not agree
that it is correct to generalise the settings of this asset type in this way. In addition to which, the
National Planning Policy Framework in paragraph 132 is clear that scheduled monuments are of the
highest significance. It is not unreasonable to expect that the assessment should have been
undertaken within a five kilometre radius.
In addition to which, it is noted that not all assets within the 5km radius have been assessed as
described in the methodology. Omissions include the conservation areas at East Barsham and
Houghton St Giles. Although it is not considered that non-designated heritage assets needed to be
assessed in the wider area, given the fact that the application site is within the locally designated
Cranmer Park, it seems perverse not to assess the impact of the proposed development on the
significance of this heritage asset (see above).
It is also noted that there is no reference in the methodology to English Heritage’s best practice
guidance on setting.
HERITAGE ASSETS POTENTIALLY AFFECTED BY THE DEVELOPMENT
Church of St Mary and All Saints, Sculthorpe (Grade II*)
This church dates back to the C14, with a series of later additions and alterations including a north
aisle added in the C15, and C19 chancel and south aisle. The list description notes that is decorated
with C19 stained glass, including windows by William Morris and Burne-Jones. As a Grade II* listed
building, clearly the church is an asset of the highest significance, as stated in paragraph 132 of the
NPPF.
The church is located at the northern end of the village at the junction with Moor Lane and Creake
Road. The settlement of Sculthorpe broadly comprises ribbon development along these two roads,
with further development along The Street which is a conservation area, also a designated heritage
asset. To the west of the church is the Grade II Manor Farm complex, with the application site
located approximately 735 metres to the north west.
The church tower can be glimpsed from the B1355 in views south towards Sculthorpe. However,
these views are limited by virtue of a tree screen and the tower is not a prominent feature. As
identified in the Applicant’s Heritage Statement, key views are instead from the south, from Moor
Lane and Creake Road, and in particular from where these roads intersect to the front of the green.
The church stands as part of a group with Manor Farm (Grade II), somewhat removed from the
remainder of the village and particularly the historic core to the south (designated as a conservation
area).
The church stands in a rural location, with an open setting to the south but with trees along its
northern boundary and a well treed boundary to Manor Farm, and the church is viewed against this
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backcloth. Nevertheless, views to the open countryside beyond are visible through breaks in this
screen. The experience is one of quiet and tranquillity, a characteristic of Norfolk’s rural churches.
The Heritage Statement is clear that the turbine would be visible in these key views from the south.
It goes on to state that the impacts on closer views would be mitigated by the mature trees as
demonstrated by photomontage viewpoints 2 and 3. Whilst it is acknowledged that the turbine
would not be visible in these particular views, we agree with English Heritage’s conclusion that as
one moves around the building and churchyard as these spaces are intended to be experienced, it is
likely that the turbine will come into view through breaks in the trees.
Viewpoint 5 is taken from Moor Lane and gives a clear impression of the nature of the impacts. This
shows the turbine hub clear above the hedge line, along with a significant proportion of the turbine
blades juxtaposed against the church tower and roof which are prominent in the view. In scale, the
hub is broadly comparable with the height of the tower parapet, with the blade tips rising above.
The Heritage Statement suggests that due to the comparable scale of the turbine set against the
church tower, this would ensure that it would not appear ‘overly oppressive’. Whilst this might be
true, the turbine could not be considered subservient, and would distract from and compete with
the tower in views from this direction. This would be even more so given the rotation of the blades,
creating a distracting flicker motion. The Heritage Statement acknowledges this impact: ‘there
would be some harm to this setting with the rotating blades drawing the eye in the same context as
this locally important approach.’
The Heritage Statement concludes in Section 6 that, although the turbine would be visible in the
broader setting, it would not be seen in or detract from the most significant vistas of the heritage
assets. In the case of this church, whilst the turbine is not visible in the selected viewpoints from the
green to the front, as one moves around the green and churchyard itself, it is likely to come in to
view. The approach from the south along Moor Lane is an important one, comprising one of two
historic roads linking the church to the core of the village to the south. Viewpoint 5 gives an
indication of the level of impact on this view.
The Applicant has acknowledged that harm will be caused to the setting of the church, which is a
conclusion that both English Heritage and we share. The Heritage Statement concludes that these
impacts cannot be avoided within the 500kw turbine range, but that its height and location has
striven to reduce its impacts. Nevertheless, the impacts remain significant, and would harm the
heritage significance of this Grade II* listed building.
Cranmer Hall, Barns and parkland (Grade II*, Grade II, and locally designated park and garden)
Cranmer Hall comprises a much altered Georgian country house of c.1721. It was originally of three
storeys, now reduced to two, and reduced in plan sometime after 1905. It was extended in the late
C19 with a two storey three bay wing attributed to Phillip Webb. Webb was also responsible for the
Grade II* listed stables to the rear, and possibly the Grade II gates, piers and railings at the entrance
from the B1355. The hall sits within a locally designated park and garden identified on Faden’s map
of Norfolk published in 1797. The park description notes the designed views to the south east,
including the remnants of an avenue of trees that would have drawn the eye towards the plantation
towards the edge of the park known as ‘The View’. The application site is located within the
boundary of the designated parkland, positioned within a field to the northeast of this clump. A
historic track connecting the hall to the Church of St Mary and All Saints travels through the gap
between The View and Foxhill Plantation.
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The parkland was purposely designed to create key vistas and views to and from the hall. As such,
their significance is closely integrated. English Heritage state in their comments on the proposals
that: ‘part of the significance of the buildings lie in the landscape setting, both of the immediate
gardens and with wider park and farmland.’
As identified in the Heritage Statement, the main approach is from the B1355 to the north as
marked by the listed gates, piers and railings, and also the lodge. This driveway travels in a straight,
south-westerly direction and delivers the visitor to the front façade which accordingly faces
northeast. The Heritage Statement concludes that there would be no impact on this approach.
To the contrary, viewpoint 9 is taken from Old Wells Road, with the formal approach to the hall in
the middle ground of the photomontage. The turbine is clearly visible in this view, rising above
historic plantations. It is highly likely therefore that the turbine would also be visible from the main
approach road. Although it will not be seen in direct conjunction with the front elevation of the
main house, the open nature of the driveway permits views outwards to the parkland and farmland
and this is an important part of how the house is experienced on both arrival and exit. Although
much of the former parkland is now farmed, there is little evidence of built development within
these views. The turbine, rising above the historic tree planting, would comprise a particularly alien
feature within this historic landscape that would distract and detract from the landscape design
intentions. As an integral part of how the hall is experienced, harm to the parkland would cause
harm to the setting of the listed building.
The construction of the turbine and access road within the boundary of the historic park and garden
will itself cause harm to this portion. Although it is acknowledged that this is historic farmland
rather than parkland, it nonetheless is within the locally designated area and has a close historic
relationship with Cranmer Hall. As noted above, although the Heritage Statement notes the impacts
on the historic farmland at paragraph 5.4 and in the conclusions, it is incorrect in stating that there
are no direct physical impacts to heritage assets in 4.2. The Statement would seem to disregard
entirely the status of the locally designated park and garden as a non-designated heritage asset, and
consequently fails to assess satisfactorily its significance and the impacts on this asset.
Views from the stables and from the southern elevations of the hall are screened by mature trees
and hedges such that any impact would be less, and similarly it is unlikely that views from the main
elevation from the hall and principal rooms would be harmed. There is also considered to be
minimal impact, if any, on the listed gate piers at the entrance.
Manor Farm (Grade II)
Manor Farm forms part of a historic group, with the Grade II* listed Cranmer Hall and barns to the
northwest, Grade II* listed church to the immediate east, and the locally designated parkland that
stretches to the immediate west of the farmhouse. Historically, a path connected the church to the
hall across the parkland, travelling to the north of Manor Farm. Clearly, these assets share a close
historic relationship. The Heritage Statement notes that the historical interest of Manor Farm is in
part derived from its association with the farmed parkland to the north, and that the farmed
parkland to the north and northwest forms part of its setting.
The house has a dense tree screen on its northern boundary which will filter views to the turbine
when looking towards the front elevation, however it will be visible from within the farmland
associated with the asset which forms part of its setting. Furthermore, the construction of the
turbine itself will erode part of the historic farmland currently connected with this asset. The
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proposals are therefore considered to cause harm to positive elements of its setting and therefore
the significance of this heritage asset.
Church of All Saints, East Barsham (Grade II*)
This church sits on a high point within the village at the crossroads with the road to West Barsham.
The topography drops away in the direction of the road, but rises towards the application site. The
church is screened with a dense tree screen on its western boundary such that it does not have a
commanding presence over the landscape to the west. No verified views have been produced to
confirm or disprove the presence of the turbine in views to and from the church. If the turbine can
be glimpsed, the topography and tree screen around the church will limit any impacts such that any
harm is considered to be minimal.
Grade II Listed Buildings in Sculthorpe & Sculthorpe Conservation Area
Sculthorpe village contains a number of Grade II listed buildings and the southern portion is
designated as a conservation area. The Heritage Statement notes that generally the listed buildings
have a village setting and that the turbine would have minimal impact, and we concur with this view.
With respect to the conservation area, the analysis concludes that views to the turbine would be
limited, and that the turbine would not represent a significant intrusion within its setting. This is a
logical conclusion. Any harm to these assets is therefore considered to be limited.
Other assets
There are a large number of other heritage assets within the 2km and 5km radii of the application
site, and from which the turbine will be visible. These include the Fakenham Conservation Area and
Church of St Peter and Paul, the Manor and Gatehouse at East Barsham, Egmere Medieval Village
and the Church of St Edmund, Bloodgate Hillfort, and Church of St Peter at Dunton. The impacts on
their heritage significance have been assessed, and are considered to be minor. This is by virtue of
the limited visibility and/or lack of contribution that the application site makes to their heritage
significance.
CONCLUSIONS
The Heritage Statement concludes that the main assets affected comprise the listed buildings of
Cranmer Hall, Manor Farm and the Church of St Mary and All Saints. To this list we would also add
the locally designated park and garden associated with the Hall. The impacts on these designated
and non-designated heritage assets are of greatest concern.
There are other designated assets also affected, although to a lesser degree. However, they form
part of the collective impact and should be taken into account as part of the balancing exercise.
It is acknowledged that the turbine is not a permanent structure and its impacts are therefore
reversible. It is also noted that attempts have been made to reduce its impacts by avoiding both the
loss of trees and the requirement for a standalone substation.
Development Control Policy EN 8 requires that development proposals should preserve or enhance
the character and appearance of designated assets, and other historic buildings, structures,
monuments and landscapes and their settings. Development that would have an adverse impact will
not be supported. The proposals fail to preserve the setting of a number of designated heritage
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assets (including two Grade II* listed buildings) and directly harm a non-designated asset. The
proposals are therefore contrary to the Development Plan.
Section 66 of the Act 1990 is clear that in exercising its planning functions, the local planning
authority must pay special regard to the desirability of preserving listed buildings and their settings.
The weight to be given to this special regard has recently been tested in the High Courts (Barnwell
Manor Wind Energy Ltd v. East Northants DC and others [2014] EWCA Civ 137) and it is clear that
considerable weight must be afforded to the protection of listed buildings and their settings in
balancing harm to their heritage significance against other interests.
There is no legislative test for preserving the setting of scheduled monuments or non-designated
heritage assets. With respect to conservation areas, Section 72 does not specifically mention the
setting of conservation areas but does require special attention to be paid to the desirability of
preserving their character and appearance.
The harm in this instance falls within the less than substantial bracket and, in planning policy terms,
is subject to the tests of paragraph 134 of the NPPF. In our view, in the light of the clear and strong
legislative test that must be met, the Council will need to be satisfied that there are demonstrable
wider public benefits that will outweigh the presumption in favour of preserving the setting of these
designated heritage assets. The locally designated park and garden is not of the same heritage
significance, but national policy nevertheless directs that this harm is considered as per paragraph
135 of the NPPF. The applicant is clear that there are no identifiable heritage benefits that might
deliver enhancement – the potential for other public benefits will need to be considered in the
planning balance.
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Landscape Officer Comments:
Summary:
The application is not supported and should be refused as is it
considered that the proposed turbine would have a significantly adverse impact on
the local landscape character and the nearby heritage assets of Cranmer Hall and its
locally designated Park and Garden.
Landscape and Visual Impact:
The application has been supported by a
Landscape and Visual Impact Assessment (LVIA) prepared by AAH Planning
Consultants dated June 2013. The LVIA has been prepared by suitably qualified
professionals in accordance with recognised guidelines (The Landscape Institute:
Guidelines for Landscape and Visual Impact Assessment, Third Edition, 2013). The
LVIA draws upon published landscape character assessments at a national and local
level to establish the baseline landscape character and to assess the degree of
impact of the proposed wind turbine on that character.
The LVIA concludes that the overall effect of the wind turbine on the local landscape
character (Rolling Open Farmland) would be slight/moderate adverse, and
although this effect is long term it would ultimately be reversible due to the life cycle
of the turbine (approximately 25 years). A ‘moderate’ effect is described as being
one where “the proposed scheme would cause a noticeable difference to the
landscape and would affect several receptors”. A ‘moderate’ effect on landscape
character is not considered significant under the EIA Regulations.
The process of LVIA is based on established methodology and principles however it
is not a quantitative process. It is generally recognised that the correlation of the
sensitivity of the landscape to accommodate change and the magnitude of the effect
is ultimately based on professional judgement and experience.
Many elements of the submitted LVIA, such as the assessment and judgement of the
capacity and the sensitivity of the landscape to receive the proposed wind turbine,
are considered acceptable and a fair reflection of the proposed development and
landscape impacts. However, it is considered that certain significant landscape
features in the baseline assessment have been undervalued and the magnitude of
impact underestimated. For example, it is considered that the weight given in the
LVIA to the sensitivity of the open character, uninterrupted skyline and Cranmer Hall
Historic Park and Garden elements of the landscape have been undervalued; and
the magnitude of the impact the proposed development will have on these features
underestimated. This is important when considering the relative importance of each
of the individual landscape elements affected and the value attributed to them both
as contributing factors in the landscape character and by the local community and
thus the overall perception of the landscape and resultant change.
As recognised in the LVIA the Rolling Open Farmland character type is defined by
two main factors: its topography, large expansive, open, gently rolling or undulating
land and associated uninterrupted skyline views; and its historical land ownership,
large land holdings since the mid eighteenth century, of which Cranmer Hall plays a
significant part.
It is considered that insufficient weight has been given to the impact of the
development on these two defining elements in the assessment of the impacts. In
the LVIA in Appendix D – Landscape Impact Assessment Table, topography and
scale have been attributed a ‘medium’ sensitivity whereas the North Norfolk
Landscape Character Assessment Supplementary Planning Document (June, 2009)
(NNLCA) suggests that these particular landscape features have a ‘moderate to high’
sensitivity. Similarly ‘culture and heritage’ has been attributed as having a ‘medium’
sensitivity in the LVIA whereas it could be argued that the sensitivity of this particular
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feature is higher given its significance with the Rolling Open Farmland landscape. If
a ‘medium’ magnitude of effect, i.e. “one where there is partial loss or alteration to
one or more key elements of the baseline”, is then accredited on that feature (which
has a ‘moderate to high’ sensitivity) the resulting significance is moderate/major
which has a greater degree of significance of impact on the defining features of the
overall landscape character type.
In addition, the NNLCA repeatedly states that the erection of wind turbines in certain
areas of the Rolling Open Farmland Character Type can have very severe effects,
and whilst the submitted LVIA acknowledges this to a certain degree in its
assessment, it could be argued that insufficient weight has been given in the
assessment because of the type of change being affected on the landscape by the
wind turbine development.
The proposed development is located specifically within the Egmere, Barsham,
Tatterford Landscape Character Area of the Rolling Open Farmland Type. The
NNLCA states that “this landscape Area is more open and has less built
development (settlement or otherwise) than its neighbouring Areas and most other
Types.” The NNCLA goes on further to state that the area is consequently more
sensitive to increases in built development such as large vertical structures i.e. wind
turbines and telecom masts.
The comparison is then made between the
neighbouring area to the south which has been subject to gradual increases in
development that have eroded the character of the landscape and provides an
insight to the potential results of allowing such development in the area to the north.
There is therefore a concern that the relatively intact landscape Area of Egmere,
Barsham, Tatterford, which is typical of the landscape character, will be eroded by
the proposed wind turbine by such a degree that it has alters the overall condition of
the landscape from ‘good’ to ‘fair’. The damaging effects of the development are
intensified as the existing intact landscape typifies the Type.
The LVIA has also considered the cumulative impacts of the development on the
landscape, in respect of the permitted commercial wind energy schemes at Jack’s
Lane (6 turbines at 126m to blade tip) and Chiplow (5 turbines at 100m to blade tip)
which are located 7.6km and 9.4km, respectively, to the east of the Cranmer turbine
in the Borough of Kings Lynn and West Norfolk. Other smaller micro-scale wind
turbines are located within the vicinity of proposed Cranmer turbine and have also
been taken into consideration in the assessment.
The LVIA concludes that the cumulative effects of the development are limited or
occasional due to the rolling topography, distance between the developments and
the intervening vegetation. This has been considered in terms of simultaneous or ‘in
combination’ visual effects, i.e. as when viewed from a fixed viewpoint or viewpoints,
and also as sequential effects such as when travelling through the landscape along
major highways. The overall significance of effect is considered as no more than
slight adverse, which is concurred with.
Policy EN2 of the Core Strategy states development that does not respect or
enhance the landscape character of the area should not be permitted. The LVIA
acknowledges that the proposed development will cause a noticeable difference to
the character of the landscape, however it is contended that the effect is more
adverse for certain defining elements of the landscape and therefore has greater
significance. Given that the development will result in adverse impacts to the
landscape character contrary to Policy EN2, the benefits of the turbine with respect
to renewable energy policies must be carefully examined and questioned particularly
in view of the importance of the landscape to the local community.
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In terms of the visual impact of the proposed wind turbine, the LVIA has provided a
Zone of Theoretical Visibility Map (ZTV) for both hub height and blade tip and a
number of photomontages for prescribed viewpoints based on a baseline
assessment of visual sensitivity and a range visual receptors. The LVIA suggests
that although the ZTV illustrates that the turbine would theoretically be visible at
distances of up to 15km, the likely impact of such views would be negligible. The
effects of the proposed development are considered to only be of sufficient impact for
assessment within 5 to 10km distance of the turbine. For an individual turbine of a
medium scale, this assessment methodology is considered acceptable.
The visual impact assessment describes a ‘negligible’ magnitude of impact to the
‘nearest heritage asset’ to the proposed turbine, Church of St Marys and All Saints.
This is on the basis that the two principle viewpoints of the church and its setting
(photomontages 2 & 3) indicate that the turbine will be obscured by either the
building itself or vegetation. Notwithstanding the fact that the nearest heritage asset
to the turbine is actually the locally designated Cranmer Hall Park and Garden (in
which the turbine is located), it is evident by walking within the vicinity of the church
and its grounds that views of the turbine, and at a relatively close distance, can be
gained. This therefore questions the assessment of effects on this particular
receptor and heritage asset.
Within Appendix E – Visual Impact Assessment Table, the significance of the effect
for nearby visual receptors such as Manor Farm, residential properties and road
users within the village of Sculthorpe have been classified as ‘moderate’. It is
suggested that the significance should be upgraded to ‘major’ if the methodology as
prescribed in Appendix C is adhered to, due to the sensitivity of the receptor being
judged as ‘high’ and the magnitude of impact judged as ‘medium’ resulting in a
significance of moderate/major. The downgrading of the significance from ‘major’ to
‘moderate’ may be attributed to the definition of the terms, as ‘major’ is defined as
“the proposed scheme would completely change the character and/or appearance of
the landscape for a long period of time or permanently. It would affect many
receptors”. It is acknowledged that not all residential receptors or road users within
Sculthorpe will experience the same visual effects or magnitude of impact of the
turbine as this will be dependent on the orientation of the dwelling and any
intervening vegetation or other built forms. However, it should be recognised that for
some residential receptors a significant visual effect is possible.
As mentioned previously the turbine is located within the locally designated Cranmer
Hall Park and Garden. This parkland, illustrated on Fadens Map of Norfolk (1797),
associated with the hall can be dated back to 1740. Although the landholdings of the
hall and associated parkland have been split up, the parkland and its defining
features and elements remain relatively intact and can be read in conjunction with
the setting of the Grade II* listed hall. Vantage point 9 seeks to illustrate the impact
that the proposal will have on the heritage asset of Cranmer Hall and the unregistered historic park and garden and illustrates a view from the Old Wells Road in
a south-easterly direction across the parkland but without taking in a view of the hall
to the south. This vantage point almost mimics a designed view within the parkland,
whereby the link between the hall and Manor Farm and the parish church of St Marys
and All Saints has been afforded special emphasis. By channelling views through
the woodland planting blocks of Foxhills Plantation and ‘The View’, views across
open parkland are completely unobstructed towards the church and the village of
Sculthorpe.
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The turbine, as demonstrated in Viewpoint 9, will clearly be visible within this setting
and diminish the experience of the hall and historic park and garden by introducing a
discordant and distracting visual intrusion. This will clearly have an impact on the
setting of the hall and the locally designated park and garden and should be
attributed sufficient weight in consideration of national heritage policies and Policy
EN8 of the Core Strategy.
Although the development will not directly affect the fabric of the historic landscape,
i.e. Cranmer Hall and its avenue, and the parcels of land and woodland blocks that
make up the historic park and garden; it is considered that the introduction of the
turbine within the associated parkland will effect the receptors experience of the
historic landscape, which itself is part of the overall landscape character, thereby
contributing to the erosion of that landscape further.
Ecology:
The application was supported by an Extended Phase 1 Habitat
Survey, prepared by Peak Ecology Limited dated June 2013. The report highlights
that there are no statutory or non-statutory designated sites for conservation with
2km of the survey area. The survey identified that the land affected by the proposed
development is predominantly arable with hedgerow field boundaries and some
scrub, woodland and ruderal vegetation nearby. The survey did not reveal the
presence of any protected species on site; however the habitats present were
suitable for breeding birds and foraging/commuting badgers and/or bats.
The report has been prepared in accordance with recognised standards and
procedures by suitably qualified ecologists and is accepted as being fit for purpose.
The report provides a comprehensive impact analysis of the proposed wind turbine in
respect of its size and location and potential impacts on habitats and species and
does not highlight any specific concerns. The conclusions of the report are
concurred with and it is not considered that the proposed turbine would have any
significant adverse effect on protected species (such as bats, badgers and breeding
birds) or the interest features of the North Norfolk Coast Special Protection Area
(SPA) that is located approximately 12km to the north of the site.
Some mitigation has been proposed to reduce the potential for minor impacts and
based on a precautionary approach. It is considered that if these mitigation
measures are secured via a condition of planning, the impact of the proposed turbine
on biodiversity would be minimal and consistent with the aims and objectives of
Policy EN9 of the Core Strategy and NPPF.
Conclusion: With respect to the impact on ecology, no objections are raised. With
respect to the impact on landscape character, it is considered that the proposed
turbine will have a moderate/major adverse impact on a landscape that is currently
intact and in good condition. The proposed turbine would erode the character of the
landscape reducing the overall condition of the landscape to ‘fair’. Furthermore, it is
considered that the turbine would introduce a visually discordant element within the
Historic Park and Garden of Cranmer Hall affecting the setting of the hall and the
locally designated park and garden. The proposal contradicts Policies EN2 and EN8
of the Core Strategy and is not supported. It is recommended that the application is
refused due to the adverse impact on the local landscape and heritage assets.
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NORTH NORFOLK D.C. ,
a
·c
- 1 SEP 2014
POSTAL SERVICES
J
f
Direct Dial: 01223 582738
Direct Fax: 01223 582701
Our ref: P00429242
29 August 2014
Dear Mr Lyon
Notifications under Circ
/2001~ cfrCular 08/2009 &
T&CP (Development Management Procedure) Order 2010
LAND AT MANOR FARM, CRANMER, SCULTHORPE, NORFOLK NR21 9HZ
Application No PF/14/0680
Thank you for your letter of-31 July 2014 notifying English Heritage of the above
application.
,, , "
Summary
,.
The application proposes the erection of a wind turbine with a blade tip height of 78
metres on land at Manor Farm. The development has the potential to affect the setting
and significance of a number of designated heritage assets within the vicinity. We
have visit the area to consider the impacts of the proposal. The applicant's Heritage
Statement takes a limited view of the potential impacts and the viewpoints do not
appear to have been chosen to help consider the impact on the historic environment.
However, on the basis of our visit and the submitted information, we consider the
turbine would cause harm to the setting of the Church of St. Mary and All Saints at
Sculthorpe, grade II*; the bui,ldings and landscape of Cranmer Hall, grade II*, grade II
and locally designated and the Church of St. Peter and Paul at Fakenham, grade I and
within the town conservation area. There is potential for there to be harmful impacts
on the Church of St. Peter at Dunton, grade II* and we also have reservations about
th.e impact on the church anq manor at East Barsham, the Slipper Chapel at
Walsingham and the scheduled monument and church at Egmere and at Bloodgate
·Hill. In line with the National Pl~nning Policy Framework the public benefits of the
proposal should be weighed against the harm to the significance of the assets. Unless
you are satisfied that the ha.rm is outweighed, we recommend the application should
be refused.
·.
English Heritage Advice
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org. uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
Development Committee
133
23 April 2015
a
The site lies to the north·of Manor Farm and to the west of the 81355. The Design
and Access Statement notes the surrounding landscape has an open character with
long uninterrupted views, the topography is generally rolling with large domed plateau
giving a feeling of height (paragraph 2.2). The land is largely agricultural with some
small and scattered blocks of woodland.
·
The methodology of assessment within the Heritage Statement explains that grade 11
buildings and scheduled ancient monuments have been identified within 2km of the
application site whereas other4esignations have been looked at within a 5km radius
(paragraph 4.8). It notes that grade II listed buildings have a lower sensitivity to grade
. I and II* buildings. Our advice focuses on the impact of the development on grade I
and II* buildings in line with the statutory requirements for consultation. However, the
sensitivity of any listed building to impacts on its setting and significance will depend
upon the contribution that setting makes to significance and the nature of the proposed
development. The grading of a building is not necessarily an indication of this. We
would also challenge the statement that 'given the nature of scheduled ancient
monuments, it is considered that' a more constrained search area is reasonable as
these assets would also typically have reduced settings.' Again the sensitivity will
depend on the contribution that setting makes to significance and is not reflected in the
type of designation.
The nearest heritage asset is the Church of St. Mary and All Saints at Sculthorpe
which lies c.713 metres to the south of the site (Heritage Statement, paragraph 2.4).
The church dates largeiy from tpe fourteenth and nineteenth centuries and is listed
grade II*. It lies to the north ·of the village in a group with Manor Farm. There are key
views of the church from Moor Lane and Creake Road which connect the village with
·the church. It is also.clearly visible in views from the A148. The tower is seen in views
from the B1355 above the tree line.
The Heritage Statement concludes the views to the church from the south would be
the most affected and we concur with this. Viewpoint 2 is taken from the lane in front
of the church and the turbine app,ears obscured by trees however as visitors move
around the building and churchyard it is likely to come into view. Viewpoint 3 is taken
from the junction of Moor Lane and Creake Road and the turbine is obscured by the
church, again it is likely to come in to view from parts of the churchyard. Viewpoint 5
shows the view from Moor Lane where the turbine appears to the west of the church
and at a comparable height to the church tower. Viewpoint 16 taken from the A 148
shows the church to the eas~ with the tower set just below the horizon. The tall turbine
rising above the tree line contrasts with the smaller scale of the traditional buildings
and open, flat character of th~ IC!'ndscape. The church tower is the existing dominant
feature and its historic landm'.~rk status would be eroded by the taller presence of the
turbine. This would result in harm ~o the significance of the listed building.
I
,
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
.
Telephone 01223 582 700 Facsimile 01223 582 701
'
www.english-heritage.org. uk
English Heritage is subject to the Freedom'of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
Development Committee
134
23 April 2015
a
-c
To the north west of the sit~ is Cranmer Hall and associated stables which are both
separately listed grade 11*. The gates and gate piers are listed grade 11. This is an
early Georgian ·country house with later work by the Victorian architect, Philip Webb
who also designed the stables and possibly the entrance gates. Your Council has
designated the land around Cranmer Hall and Manor Farm, including the development
site, as historic park and farmland. We were not able to obtain access to this site to
make a detailed assessment, however as a country house in a historic landscape, part
of the significance of th~ puildings lies in the landscape setting, both of the immediate
gardens and the wider par~ and farmland. This illustrates how the house functioned
historically and provides an ~ttractive rural setting to the building.
The Heritage Statement notes toe.turbine would not have an adverse impact on the
main approach as the front elevation faces north east. However, it does consider 'the
turbine would be evident in,the broader setting' (paragraph 5.5). Viewpoint 9 is taken
from Old Wells Road looking across Cranmer Hall and Park and shows how the
turbine is visible in these open views rising above the trees. The analysis in Table 2
also notes the turbine is likely to pe visible from the south east elevation of the Webb
wing together with the coach house, stables and walled cottage garden. The presence
of a tall turbine with rotating blades would erode the rural landscape character of the
setting of the Hall and cause harm to its significance.
The town of Fakenham .lies to t~e south east of the proposed turbine. The historic
core of the town is designated
as conservation area and it contains a number of
/
highly graded listed buildings_ including the parish church. The medieval church is
listed grade I and the t~ll Perpendicular tower rises above the town and is visible as
landmark from the surrounding countryside and in particular in views from the south
and west (although from the west it is also seen in conjunction with the large water
'
tower).
a
The Heritage Statement_ discusses the church in Table 1 in relation to the conservation
area. It notes the 'the town:s parish church is particularly prominent and picturesque
when viewed from the sout~ west, which is a particularly dramatic view and whilst the
turbine would theoreticall"y be visible from this direction for example along the 81146 it
would be seen as a distant feature set within the landscape to the rear of the town.' It
goes on to note 'any advers~ impact is therefore considered to be confined to the
distant views of Fakenham from the south and south west where some distant
glimpses of the turbine may be achievable in the background.' There are no
photomontages to illustrate this and to enable it to be independently assessed.
However, the presence of a new, vertical structure within the landscape could erode
the landmark status of the church tower which has been the dominant feature in these
views for centuries. We recommend a photomontage is produced to illustrate this
.
I
24°'BR09KLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org. uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
.
the FOIA or EIR applies.
,.,
Development Committee
135
23 April 2015
a
-o
view. The cumulative impa~t ofthe turbine and the water tower should also be
considered when determining the application.
The medieval church of St.. Peter at Dunton, grade II*, lies to the south of the
development site on the other side of the A148. We concur with the assessment that
the church does not have a strong visual presence in the landscape due to its modest
scale. However from the land to the east of the church there are views out across
farmland. There are no photomontages to illustrate the visibility of the turbine in these
views. The visibility of a turbine would erode the landscape character of the setting
within which the church is seen.
1
To the east of the development site is the village of East Barsham. The Church of All
Saints is listed grade II*. and is modest building framed by trees to the west. Despite
this the Heritage Statemenfnotes that the photomontages indicate the turbine would
be visible. These images dqnot appear to form part of the submission. Your authority
should consider how vie"!'s of tti~· church in conjunction with the turbine would impact
of the landscape character .,of the setting of the listed building. The Manor House lies
to the north of the church and is·: listed grade I. The analysis notes this is 2.5 km from
the turbine and that the house appears to be orientated towards the turbine. We were
not able to obtain acces~ bµt are not convinced by the conclusion the turbine would be
'outside the setting of the manor house and would not result in any impact.' We
recommend a photomontage is provided to illustrate the turbine in these views.
a
The Slipper Chapel on the pilgrimage route to Walsingham and is listed grade I. The
analysis notes the turbine would be visible on the approach from the 81105 and would
impact on the wider appreciation of the landscape when travelling to the chapel. This
could be described as. how the turbine is experienced, in other words its setting. The
rural landscape can be said to contribute to the seclusion and, although it has clearly
evolved over time, the landscape character reflects the historic setting of the building
and contributes to its sign.ifican~~-. The erosion of this would result in harm.
There are a number of scheduled monuments which have not been considered
because they are more thari 2k111 from the turbine but fall within an approximate 5km
radius. Of these we have some· concerns about the potential impact of the turbine on
the broader landscape setting of the Egmere Medieval Settlement and the Ruins of
Church of St Edmund, listed grade II*, which is prominently sited on high ground
enabling broad views to the south in the direction of the proposed turbine. We also
note that Bloodgate Hill Fort is noted as having views eastwards, in other words in the
direction of the proposed turt;>ine the south east.
to
As the application affects a listed building, the statutory requirement to have special
regard to the desirability of preserving the building, its setting and any features of
24 BROdKLANDS AVENUE, CAMBRIDGE, CB2 8BU
. Telephone 01223 582 700 Facsimile 01223 582 701
.www.english-heritage.org. uk
English Heritage is subject to the Fi-eedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation wilf,be accessible in response to an information request, unless one of the exemptions in
,,. ,
the FOIA or EIR applies.
Development Committee
136
23 April 2015
a
special interest (ss.16, 92, 1990 Act) must be taken into account by your authority
when making its decision. It ~l~o has implications for the Fakenham Conservation
Area and the statutory requ,jf,~ment to pay special attention to the desirability of
preserving or enhancing the ·chara,cter or appearance of the conservation area (s. 72,
1990 Act) must be taken into account by your authority when making its decision.
Your authority should aim ~o achieve sustainable development, seeking economic,
social and environmental g,ains jointly and simultaneously through the planning system
as required by the NPPF, P,aragraph 8. Pursuing sustainable development involves
seeking positive improvements in the quality of the built, natural and historic
environment, paragraph 9.
Under the NPPF it is a core planning principle to conserve heritage assets in a manner
appropriate to their significance, so that they can be enjoyed for their contribution to
the quality of life of this and future 'generations, paragraph 17. When considering the
impact of a proposed d~velopment on the significance of a designated heritage asset,
great weight should be given to the asset's conservation. No other planning concern is
given a greater sense 6f importance in the NPPF. The more important the asset, the
greater the weight should oe.- Significance can be harmed or lost through alteration or
destruction of the heritage asset or development within its setting. As heritage assets
are irreplaceable, any harm br loss should require clear and convincing justification,
paragraph132. The onus is. therefore on you to rigorously test the necessity of any
harmful works.
·
Planning authorities should; look for opportunities for new development within
conservation areas and within the setting of heritage assets to enhance or better
reveal their significance. Proposals that preserve those elements of the setting that
make a positive contribution to or better reveal the significance of the asset should be
·
treated favourably, paragraph 13?.
If a proposal cannot be amepded to avoid all harm, then if the proposal would lead to
less than substantial harm tO the significance of a designated heritage asset, this harm
should be weighed against tne public benefits of the proposal, including securing its
optimum viable use, paragr~ph134.
·1'
In conclusion, the turbine wquld 'cause harm to the setting of the Church of St. Mary
and All Saints.at Sculthorpe,_grade II*, the buildings and landscape of Cranmer Hall,
grade II*, grade II and locally designated, the Church of St. Peter and Paul at
Fakenham, grade I and within the town conservation area. There is potential for there
to be harmful impacts on the Church of St. Peter at Dunton, grade II*, and we also
have reservations about the impact on the church and manor at East Barsham, the
Slipper Chapel at Walsingham and the scheduled monument and church at Egmere
24 BROOKLANDS AVENUE, CAMB~IDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org. uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
· the FOIA or EIR applies.
Development Committee
137
23 April 2015
a
and at Bloodgate Hill. We consider the level of harm is under estimated in the
applicant's Heritage Statement and that there are insufficient photomontages to
assess the impact on the historic environment. In line with the National Planning
Policy Framework the publi~ benefits of the proposal should be weighed against the
harm to the significance of tpe assets. If your authority is minded to grant consent, we
recommend additional photomontages are requested to enable the full impacts on the
historic environment to be independently assessed.
Recommendation
The application would cause harm to the significance of a number of highly designated
heritage assets including the grade II* church at Sculthorpe and the grade I church in
Fakenham which is also a landm.ark feature of the conservation area, and the grade II*
Cranmer Hall and its grade I.I* stables and locally designated landscape. We have
concerns that there is insufficient information to assess the impacts on other sites
discussed above, the significance of which may also be harmed by the proposed
development. If your authority is .minded to grant consent, we recommend additional
photomontages are req~ested to enable the full impacts on the historic environment to
be independently assessed. In ·line with the National Planning Policy Framework the
public benefits of the proposal should be weighed against the harm to the significance
of the assets. Unless Y,OU are satisfied that the harm is outweighed, we recommend
the application should be, re,fdse9.
~
' ~
Yours sincerely
l
'
Clare Campbell
Principal Inspector of Historic Buildings and Areas
E-mail: clare.campbell@english-heritage.org.uk
-_,,,
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org. uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
Development Committee
138
23 April 2015
Development Committee
139
23 April 2015
Development Committee
140
23 April 2015
Geoff Lyon
From:
Sent:
To:
Subject:
Sally Nicholson
26 August 2014 11:54
Planning Consultation
WK/140010396 - Land at Manor Farm, Cranmer pf/14/0680
M3PPRef:
M3PPUnique:
WK/140010396
00000000E456CD835F153A49A81823D17E5B73BA070092119D6D64675943A0646F
FDDCED746400000005B01800006DB201DB0FDF7B48A6FE7C5AD8FDB0630000000
1A0590000
Dear Geoff
I have reviewed the noise reports that accompany this planning application. As the closest non
connected property is 640 metres from the turbine, this falls out of the study area, as defined in
both ETSU 97 and The Good Practice Guide to the application of ETSU-97 for the assessment
and rating of wind turbine noise produced by the IOA May 2013.
This defines the “Study Area” as:
2.2.1 The ‘study area’ for background noise surveys (and noise assessment) should, as a
minimum, be the area within which noise levels from the proposed, consented and existing wind
turbine(s) may exceed 35 dB LA90 at up to 10 m/s wind speed. (Note: unless stated, in this
document the wind speed reference for noise data is the 10 metre standardised wind speed,
derived from the wind speed at turbine hub height as explained in Section 2.6). It should be borne
in mind that at the survey scoping stage the definition of the 35 dB LA90 contour is often
preliminary, because (for example) the precise positions and type of wind turbines are not
finalised. In specific cases it may be necessary to incorporate the ETSU-R-97 tonal penalty into
these predicted noise levels. SB2:The study area should cover at least the area predicted to
exceed 35 dB LA90 at up to 10 m/s wind speed from all existing and proposed turbines.
Therefore, following this guidance a full noise assessment is not required in this instance.
However, due to the quiet rural background area; I feel it would be wise to add the following
planning condition:
In the event that the Local Planning Authority receives a noise complaint which appears to
be of substance, and once the wind turbine operator has been notified of the complaint in
writing by the Local Planning Authority, the wind turbine operator shall, at its expense,
employ a suitably qualified noise consultant approved by the Local Planning Authority, to
undertake an appropriate noise assessment of the noise emissions from the wind turbine
at the complainant’s property following procedures first agreed by the Local Planning
Authority. A report of the assessment shall be provided in writing to the Local Planning
Authority within 60 days of the request under this condition unless this period is extended
by the Local Planning Authority in writing. If the findings of this report identify that the
wind turbine is causing noise levels considered to be of detriment to the amenity of the
nearby residential properties, a scheme shall be included in the report detailing remedial
works reasonably necessary to address the noise complaint, and these works shall be
implemented in full in accordance with an agreed timescale.
Regards
Development Committee
1
141
23 April 2015
Sally Nicholson
Environmental Protection Officer
ep@north-norfolk.gov.uk
01263 516181
Development Committee
2
142
23 April 2015