Appendix 6
EAST OF ENGLAND OFFICE
Mr G Lyon
North Norfolk District Council
Planning Service, Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
Direct Dial: 01223 582710
Direct Fax: 01223 582701
Our ref: P00110159
5 July 2012
Dear Mr Lyon
POND FARM, BODHAM, HOLT, NORFOLK, NR25 6PP
Application No. PF/11/0983
Further to our letter of 19th June 2012 in relation to the application for a Wind turbine
at Pond Farm, Bodham (PF/11/0983) and our subsequent discussion. As discussed
we do not wish to debate matters of opinion in relation to individual assets; however
we welcome the opportunity provided by the letter from Philip Grover to clarify our
advice. For the avoidance of doubt, we confirm that our recommendation to the
planning authority is to refuse the application.
In our view the harm is less than substantial and therefore the application should be
assessed in accordance with paragraph 134 of the NPPF.
‘Where a development proposal will lead to less than substantial harm to the
significance of a designated heritage asset, this harm should be weighed against the
public benefits of the proposal…’
In light of the significance of the heritage assets concerned we do not consider that a
turbine such as this would be capable of delivering sufficient public benefits to
outweigh the harm caused. We fully accept that it is for the Local planning Authority to
weigh the harm against the public benefit, but our recommendation to the LPA is, as
previously stated, that given the quality and significance of the assets involved we do
not believe the public benefits arising from the proposal will be sufficient to outweigh
the harm. The application should therefore be refused. In arriving at this
recommendation we have reviewed the findings of recent appeal decisions to inform
our balancing of the harm against public benefit (including the Bicton wind farm
decision).
The appeal we referred to in our letter is included because it relates to a ‘setting’ issue
involving highly graded heritage assets. In that appeal the inspector assessed that the
development would be sustainable but for the fact that the harm to the heritage asset
was not outweighed by the public benefit, therefore, the development was contrary to
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.
6.1
EAST OF ENGLAND OFFICE
the NPPF and as such was not sustainable development. In this instance, if the harm
is not outweighed by public benefit then the proposal would similarly not be
sustainable development.
I would want to thank Mr Grover for pointing out the typographical error in our letter of
the 19th June 2012 (see page 2, para. 2, line 4). The words "does not" should be
deleted and the phrase should now read ‘…we feel that the harm to a range of
heritage assets outweighs the public benefit…’
We would also want to clarify that English Heritage were not aware of the Repton
images until quite late in the consultation process and were therefore unable to
request the specific view along the main drive was produced as a photomontage
image until our formal advice to the Council. The impact from this view should be
carefully considered.
The turbine is, of course, not visible in views along the axis of the avenue and our
reference to the turbine's visibility in ''views along the avenue'' does not refer to this.
We are in fact referring to the possibly of seeing the turbine while moving along the
avenue, where the turbine would be visible to the north. Regarding views through the
preserved north doorway of Barningham Winter church, an image submitted with the
application shows the turbine as directly visible and it is to this image that we are
referring. In relation to Baconsthorpe Castle, I was not aware of the ‘town planning’
usage for the term ‘overlooked’, and it is clearly not appropriate in this context. The
meaning of the sentence was designed to illustrate our view that the elevated position
of the turbine increases the impact on views to the east.
We trust that this provides clarification of the points made in our previous advice.
Yours sincerely
Will Fletcher
Ancient Monuments Inspector
E-mail: will.fletcher@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.
6.2
EAST OF ENGLAND OFFICE
Mr G Lyon
North Norfolk District Council
Planning Service, Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
Direct Dial: 01223 582710
Direct Fax: 01223 582701
Our ref: P00110159
19 June 2012
Dear Mr Lyon
POND FARM, BODHAM, HOLT, NORFOLK, NR25 6PP
Notifications under Circular 01/2001 & GDPO 1995
POND FARM, BODHAM, HOLT, NORFOLK, NR25 6PP
Application No PF/11/0983
Many thanks for the consultation on the above application. English Heritage supports
sustainable development but recognises that applications of this nature can be
challenging for the historic environment. We have looked at both this and the previous
proposal for a turbine at this location and have discussed the impact widely in light of
the new National Planning Policy Framework and our own guidance on the setting of
heritage assets. Please find our advice below.
English Heritage advice
The National Planning and Policy Framework (NPPF) states in Paragraph 132 that,
‘When considering the impact of a proposed development on the significance of a
designated heritage asset, great weight should be given to the asset’s conservation.
The more important the asset, the greater the weight should be. Significance can be
harmed or lost through alteration or destruction of the heritage asset or development
within its setting…’
In this case we feel that this development is likely to have an unfavourable impact
upon the setting of the scheduled monument at Baconsthorpe Castle (also Grade I
listed) and the Grade I listed Barningham Hall and its registered parkland. It also would
affect the medieval churches of All Saints' Church, Bodham (Grade II*), St Mary’s,
Baconsthorpe (Grade II*) and St. Mary's Church, Barningham Winter (Grade II*).
In addition, it should be noted that the NPPF sets out a presumption in favour of
sustainable development, and wind turbines are considered to be a sustainable
development. However (and as noted by the Planning Inspector in appeal reference
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.
6.3
EAST OF ENGLAND OFFICE
APP/V5570/A/11/2162902) ‘one of the core planning principles in the Framework is 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’. In
that appeal, which involved harm to the setting of a large number of highly graded
heritage assets, though not from a wind farm, the inspector concluded that the harm
was not outweighed by the public benefit and therefore the proposal ‘would not
constitute sustainable development and it would not comply with the aims of the
Framework.’
We consider that the impact of this development is sufficient to cause harm to the
historic environment, and would therefore recommend that the application is refused.
We would also like the local authority to take into consideration in determining the
application that we feel that the harm to a range of heritage assets does not outweigh
the public benefit, and that ‘great weight’ should be given to the conservation of the
heritage assets at this location. In the event that the Local Planning Authority
determines that in this case the harm to heritage assets is outweighed by the public
benefits of the application then English Heritage would wish to see a condition
requiring the removal of the new turbine and the reinstatement of the site after 25
years or whenever the turbine becomes redundant (whichever is the sooner).
In terms of mitigation, although we recognise that the height of the turbine has been
reduced since the scheme was first proposed, it is worth noting that a further reduction
in hub height, or moving the turbine may reduce the harm to the historic environment.
Please also find below specific comments in relation to the heritage assets noted in
the letter.
Barningham Hall and Barningham Winter Church
Images submitted in support of the application suggest that the proposed turbine will
be visible on the skyline in views from and around the grade I listed Barningham Hall.
The Hall's parkland setting is the product of multiple phases of development, but it is
perhaps the landscape design of Humphry and John Adey Repton that has left the
strongest mark on the immediate surroundings of the building. Repton's own
illustrations indicate how the main southern approach to the building was adapted to
create the current experience of approaching the building. The west front of
Barningham Hall is a powerful architectural composition and although the formal
gardens that may have been planted on the 17th century have been removed, the
Reptons' avenue of trees leading to the west entrance brings focus and formality. The
grand entrance porch on the west facade also commands views over the avenue and
to some degree in the direction of the application site to the north.
It would have been valuable if the images submitted with the application included
views from the Repton illustration vantage point, but they do give an impression of the
likely scale and location of the proposed turbine. They also show the impact it will have
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.
6.4
EAST OF ENGLAND OFFICE
in views along the avenue and from open ground to the north west of the Hall. The
turbine will visible on the horizon and although mediated by the trees of the avenue,
from some positions it will be clearly seen. While not of sufficient scale to dominate
these views, the motion of the turbine blades will make it more noticeable than a static
structure of a similar size. It will therefore be an alien and distracting feature in the
landscape resulting in harm to the wider setting of the Hall.
The proposed turbine will also be visible from the partially ruined church of St Mary,
Barningham Winter. This medieval building was largely disused by the 18th century,
but formed part of the Reptons consideration of the Barningham landscape design and
was partly rebuilt shortly after the period of their activity at the site. Submitted images
suggest that the proposed turbine will be visible on the horizon to the north of the
church. In some views of the building the structure itself will obscure the turbine, but in
others it will be flanked by it. The scale of the turbine is not sufficient to dominate the
building, but the motion of the blades will make it more noticeable than a static
structure of a similar size. The fact that the turbine will be visible through the preserved
north door of the former nave is particularly unfortunate. This church, preserved as a
partial ruin, was a conscious addition to the landscape and the doorway appears to
have been retained to create a view terminating at the horizon. The presence of the
turbine in that view will significantly change this view.
Bodham and Baconsthorpe Parish Churches
The applicant has submitted further images to illustrate the visual impact of the
churches on the parish church at Bodham. It is perhaps more challenging to illustrate
the impact on parish churches as unlike designed landscapes or some 'polite'
architecture they are not commonly designed to be seen in formal, considered views.
Their presence in the landscape should be considered in the round and both from
close and distant viewpoints. I am therefore unsure that the information provided really
does allow a full appreciation of the turbine's visual impact on the significance of the
setting. However, the images do give an indication of the likely scale of the turbine in
relation to the church and particularly to the presence of the tower in the landscape. It
seems unlikely that the turbine will dominate the building and wholly supplant it as a
prominent landscape feature, but it will appear as being close to the tower in views
across open countryside. It should be noted that other images provided indicate there
will be general change to the landscape settings of other historic parish churches in
the area, particularly North Barningham and Bessingham.
In the case of Bodham and Baconsthorpe churches earlier images also suggest how
the turbine will be visible from the churchyards. This will have a disturbing effect on
these peaceful historic places. In both general landscape views and views from the
churches, the images suggest there will be a harmful impact on the qualities of the
setting that contribute to the churches' significance.
Baconsthorpe Castle
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.
6.5
EAST OF ENGLAND OFFICE
This site is a Scheduled Monument and in the Guardianship of English Heritage. It’s is
a highly significance archaeological site and ruined manor house site within a setting
that is quiet and rural in character. It is also an important guardianship site, which is
popular with visitors and noted for its peaceful and tranquil setting. In particular the
NPPF Glossary (see Annex 2) suggests that the Setting of a heritage asset can be
defined as ‘The surroundings in which a heritage asset is experienced…’ The rural
location of the site and its landscape context must therefore be considered as a factor
in the sites significance and therefore an important part of the sites setting.
The addition of a turbine overlooking the castle from the east, and in particular the
kinetic circular motion will bring considerable change to the setting of this asset. In
addition it will be clearly visible in both summer and winter views as visitors approach
the site, from the entrance and visitor car park and in views from within the site
including views from across the mere and remains of the pleasure gardens, which are
a key part of the designated asset. The trees on this side of the asset mask some
views of the turbine, these are however mainly summer views and this should be
discounted. Trees are subject to change and are unlikely to continue to mask impacts
of the development over its lifetime. The turbine will therefore be visible from a number
of locations within the site and in particular from a number of key views which can be
appreciated by visitors on their journey around the site. This in our view constitutes
harm to the setting of this asset.
English Heritage’s National Collections department who mange the asset, have also
expressed concern about the impact of the development on the site, which may in turn
affect the value of the experience for the visitor.
Yours sincerely
Dr. Will Fletcher
Ancient Monuments Inspector
E-mail: will.fletcher@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.
6.6
EAST OF ENGLAND REGION
Mr G Lyon
North Norfolk District Council
Planning Service, Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
Direct Dial: 01223 582710
Direct Fax: 01223 582701
Our ref: P00110159
30 September 2011
Dear Mr Lyon
Notifications under Circular 01/2001 & GDPO 1995
POND FARM, BODHAM, HOLT, NORFOLK, NR25 6PP
Application No PF/11/0983
Thank you for your letter of 11 August 2011 notifying English Heritage of the above
application.
Summary
Many thanks for the consultation with regards to the above application. English
Heritage has a responsibility, as the Government’s adviser on the historic
environment, for the protection and management of England’s historic assets. In
planning terms, this role includes providing advice to ensure that statute and national
policy, in particular Planning Policy Statement 5, Planning for the historic environment,
are reflected in the planning process.
Although English Heritage does not object in principle to renewable energy schemes,
we recognise that these types of development can be challenging to the historic
environment. We have identified that this application is at present incomplete and does
not provide sufficient information by which to adequately judge the impact on a number
of heritage assets including the grade I Listed Barningham Hall and Baconsthorpe
Castle. This application does not in my view meet the requirements of PPS5 Policy HE
6.1 and should not be determined until this information has been provided and fully
assessed
Further more detailed advice on this application is given below.
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. All information held by the organisation will be accessible in
response to a Freedom of Information request, unless one of the exemptions in the Act applies.
6.7
EAST OF ENGLAND REGION
English Heritage Advice
We have previously been consulted at the pre-application stage on this and earlier
iterations of the proposal by the developer. We have also been asked to provide
advice to the applicant on the submission prior to the application being submitted. We
recognise however that this is a complex case which has the potential to impact on a
number of heritage assets. Subsequent to our pre-application advice, new information
and issues have continued to emerge with regard to the development as the
application has been subject to public consultation.
For example, Barningham Hall and its park are at some distance from the application
site, but due to the designed nature of the landscape they have a particular
relationship with the wider setting. In a recent conversation between English Heritage
Officers and with the Council's Conservation Officer it was noted that the impact on the
hall and park had not been fully assessed in the documentation submitted with the
application. Visualisations from the appropriate positions near the hall and in the park
could illustrate this and we would support the Conservation Officers suggestion that
this is required before the application is determined.
English Heritage therefore recommends that the applicant is asked to provide the
following additional information:
o An assessment of the impact of the wind turbines on the setting of Barnigham
Hall including additional photomontages to help in the assessment of impact on
the setting of heritage assets. Note the fact that an asset may not have public
access is not a reason for not preparing photomontages. Paragraph 117 of the
Historic Environment Planning Practice Guide which was published alongside
PPS 5 states ‘the contribution that setting makes to the significance does not
depend on there being public rights or an ability to access or experience that
setting. This will vary over time and according to circumstances.’
Although English Heritage would not normally comment on the Grade II Registered
Park and Garden it is important to ensure that the application has adequately covered
these aspects to ensure that the local Authority has all the relevant information by
which to judge the impact of this development.
We have also previously raised concerns about the methodology for assessing the
impact of the development on heritage assets and on the historic landscape. In
particular the assessment matrices system used in the application (see Appendix 4
pp4), and its application to the assets in question.
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. All information held by the organisation will be accessible in
response to a Freedom of Information request, unless one of the exemptions in the Act applies.
6.8
EAST OF ENGLAND REGION
It is our view that the assessment of impacts although a subjective process has not
been adequately considered and that the degree of change and harm to the historic
environment is more substantial than the applicants have stated. In relation to
Baconsthorpe Castle for example it is our view that the magnitude of change is higher,
which would in our view mean the impact on the setting of the asset is higher than
stated. The applicant has not provided a heritage specialist to undertake the
assessment. We feel therefore that this may contribute to an underestimation of the
harm to the setting of heritage assets associated with this development. The
assessment process for determining the relative significances of heritage assets is in
our view one that should require specialist input.
In addition we have recently noted that the site of Baconsthorpe Castle has been
incorrectly identified as a Grade I listed building, although it is indeed Grade I listed it
is also a Scheduled Monument and in this case this designation takes precedence.
The scheduling covers the standing remains of the castle and gatehouse, and includes
the archaeological remains of the moated enclosure, a mere and remains of the formal
gardens situated on the eastern side of the castle.
Recommendation
As discussed above, we recommend that the applicant be asked to provide additional
material to support the application as directed by Policy HE 6.1 of PPS 5. In the event
that the applicant is unwilling to undertake this assessment, then English Heritage
recommend that the application is refused.
Yours sincerely
Will Fletcher
Ancient Monuments Inspector
E-mail: will.fletcher@english-heritage.org.uk
Cc: James Albone, Norfolk Landscape Archaeology
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. All information held by the organisation will be accessible in
response to a Freedom of Information request, unless one of the exemptions in the Act applies.
6.9