Objecting to January 2022 revision of planning application 20/01033/EIA for housing in the setting of Old Oswestry hillfort
‘Reconsultation due to amendment to application 20/01033/EIA – Land To The North Of Whittington Road. Proposed residential development of 83 No. dwellings with associated access, public open space, electricity sub-station, drainage and landscaping.’
ADVISED DEADLINE: 9th February 2022 – but comments after this are still accepted*
As we reach almost 10 years since major development by Old Oswestry was proposed in Shropshire’s Local Plan (SAMDev), we need your support once again to oppose the latest bid to build houses in the hillfort’s near landscape.
This 4th version, which sees the planning application revised to 83 houses, remains at a physical scale, proximity and density that constitutes substantial harm to the significance and experience of this outstanding Iron Age hillfort and its setting.
Please note, the amendments have been published for ‘reconsultation’ by Shropshire Council with a 21-day period for public comments, so you must object again. We need to lodge objections in similar numbers to before, to show that public opposition is as strong as ever. Since fundamentally little has been changed by the amendments, then resubmitting your previous objections, but now for an 83-dwelling scheme, will still hold good. You can also refer to our guide below. Public objections advised deadline: Wed 9th February 2022* *However, comments will be accepted after this date; in addition, Highways England has stipulated no planning permission should be decided until at least 23 March 2022 due to outstanding information they require from the applicant.
Ten years on, let’s rally again and protect this archaeological jewel from housebuilding for which Oswestry has more than sufficient land elsewhere, including brownfield.
FOLLOW THESE STEPS TO OBJECT:
- Inspect the application on the Shropshire Planning Portal: https://tinyurl.com/44m38rna When objecting, you may find it helpful to refer to our ‘Guide Points’ below. Objections should be based on ‘material considerations’ – advice on this is available here: https://www.planningportal.co.uk/services/help/faq/planning/about-the-planning-system/what-are-material-considerations
- If it helps, you can cut and paste the below guide points into a standard letter form. Don’t forget to include the planning reference 20/01033/EIA, as well as the date, your name and address, and sign it. Your opening sentence should read “I strongly object to the amended proposal for housing development for the following reasons”. You can email your letter in Word or PDF format to: email@example.com or upload it to the planning portal https://tinyurl.com/44m38rna
- IMPORTANT. Please remember to register your objections if possible by the deadline – midnight on Wednesday 9th February 2022.
Thank you so much for your support and for sticking with this campaign to save a local valued landscape, an archaeological icon, and ensure local people are heard in local planning.
HOOOH – Hands Off Old Oswestry Hillfort
GUIDE POINTS TO OBJECTING
Non-compliant with NPPF
- The application fails to provide ‘clear and convincing justification’ for loss of significance to a designated heritage asset (as per NPPF para 200) and to conserve a heritage asset of the highest significance. This is due to the harm the proposal would cause to the heritage significance of the scheduled monument Old Oswestry hillfort through urban encroachment and destruction of a key part of its historical and landscape setting.
- The proposal conflicts with NPPF paras 199-200 because development would cause substantial harm to the significance of a designated heritage asset through development within (and therefore destruction of) its setting. The LPA should refuse consent, because it cannot be demonstrated that the harm/loss is necessary when houses can be built elsewhere, as more than sufficient housing land has been identified for Oswestry’s future growth, including east of the bypass.
- The proposal would devastate the existing views of the hillfort afforded along the B4580 Whittington Road, which allows the monument to be appreciated and experienced in its landscape. This conflicts with NPPF para 206 which states: ‘Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, 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 the asset (or which better reveal its significance) should be treated favourably.’
- The application would adversely affect a valued landscape (as per NPPF para 174) which is historically charged, providing a vital visual link between the scheduled monuments at Old Oswestry and Wat’s Dyke, with Oldport, Park Hall, and Whittington, and the ancient road connecting them. The existing rural landscape allows these connections to be made, but permission to build houses would change this valued landscape to an urban suburb, devoid of historical resonance and preventing future appreciation of it as a critical part of the setting for the hillfort. The Gillespies’ Shropshire Landscape & Visual Sensitivity Assessment (Oswestry [050SW] p.7) undertaken for Shropshire Council in 2018 identified this landscape east and south-east of Old Oswestry as valued, stating: ‘Therefore, views experienced are of high sensitivity to change arising from new housing and very-high sensitivity to change arising from employment.’
Non-compliant with SAMDev policy Oswestry S14.1a
- The application fails to comply with Shropshire Council’s SAMDev policy Oswestry S14.1a in which they signed a Statement of Common Ground (SoCG) with Historic England. This agreement states: ‘The layout of the development needs to respect its situation within the wider setting of the Hillfort to minimise impacts…. carefully prevent block development which could create an over dominance of built form ….The layout should ensure that new development does not protrude to the north of the existing built development, to the west of the allocation.’ The masterplan and layout ignore these conditions, with a substantial element of housing located north of the industrial units and block development being very evident.
- Although housing numbers have seen a slight reduction, from 91 to 83, the latest amendment still constitutes ‘major development’ within the near setting of a scheduled monument. In fact, an even greater proportion of the total number of dwellings would exceed, either wholly or partly, the northern limit for new buildings that was agreed between Shropshire Council and Historic England as a condition of the site’s allocation for housing.
- The large scale of the development, including 83 houses, drives, roads, substation and pumping station, constitutes a substantial change to the setting of a scheduled monument of high order significance. This conflicts with the S14.1a policy requirement that: ‘Development should demonstrate appropriate regard to the significance and setting of the Old Oswestry Hill Fort.’
- A requirement of the S14.1a policy is for ‘pedestrian and cyclepath links to the former railway and a new footpath link between Whittington Road (B4580) and Gobowen Road (B5069) to improve access towards the Hill Fort’. A change in ownership rights affecting access across the railway line prevents compliance with these conditions, upon which allocation in the SAMDev was predicated. Therefore, the proposal fails to deliver a key requirement of the S14.1a policy and fails to provide a major public benefit that gave weight to the case for the OSW004 allocation.
- In its Statement of Significance for Old Oswestry (within the SoCG), English Heritage (now Historic England) stated: ‘The setting of the Hillfort is essentially rural with prominent views to the east, west and north which are not appreciably affected by modern development. Maintaining this rural setting is important in allowing the significance of the site to be better understood.’ The master planning, housing grid, design and density remain wholly inappropriate; they do not enable the rural setting to be maintained nor the significance of the site to be better understood. The protection of setting to a site of such national archaeological importance should be afforded the greatest weight. Old Oswestry is regarded as a unique type site for the understanding of the Iron Age, equating to the same significance that Stonehenge and its landscape have for the Neolithic period. This high status is evidenced by reference to it among archaeology academics as ‘The Stonehenge of the Iron Age’.
Conflicts with other planning policy and updated assessments
- Fields shared with OSW004 and others located across the hillfort’s west/east landscape have been excluded from allocation for housing development in the SAMDev local plan until at least 2036 (a commitment made by Shropshire Council in March 2019), due to their heritage importance as part of the hillfort’s setting. OSW004 would also meet these criteria if it had not been allocated back in 2015. The site is now gravely at odds with updated strategic planning and landscape assessments that are ushering development away from the hillfort and to the east of the A5 bypass.
- The application fails to comply with Oswestry’s 2020 plan, since it does not provide an ‘attractive gateway’ to the town along Whittington Road. Instead, first impressions will be dominated by a modern housing estate, like many other towns, rather than open views to the unique spectacle of one of Britain’s finest hillforts and the town’s most distinctive asset and outstanding landmark.
Overwhelming public opposition to loss of a valued landscape
- Since 2012, there has been considerable and longstanding opposition from the public and key stakeholders/consultees to development on OSW004. This is compelling evidence that the greater public benefit comes from the conservation of what is a landscape of high value to the community, and not from housing that damages the hillfort’s setting and significance and can be accommodated elsewhere.
- Old Oswestry hillfort and its landscape are much loved and appreciated as an asset of high community and cultural value. This is because of its national heritage and archaeological importance, recreational amenity, environmental beauty, and sense of escape enhanced by 360 degrees views and rural context. A notable aspect of Old Oswestry’s cultural and community value is the intrinsic role which the earthwork and its eastern landscape played during WW1, housing practice trenches and serving as the extended training ground for troops based at the adjacent Park Hall camp. This poignant association was marked when the hillfort was chosen for the staging of the WW1 Centenary Beacon Lighting on 11 November 2018 for Oswestry and nearby communities. The experience of all these cultural and heritage values relies on preserving the hillfort’s fragile separation from the town, with no further urban encroachment into its setting.
Unsustainable location due to changes in housing targets and alternative housing land availability, transport issues, and loss of high value agricultural land
- OSW004 was originally allocated because the public benefits to meet housing target needs at the time were judged to outweigh the detrimental impacts on one of Britain’s archaeological jewels. However, housing targets have been revised down in the SAMDev review to the year 2038. More than sufficient land has been identified elsewhere to accommodate long-term housing growth in Oswestry, and Shropshire Council is now pursuing town growth east of the A5 bypass. The Council has also relaxed the delivery schedule from the Oswestry Eastern Sustainable Urban Extension (SUE) so that it goes beyond the current plan period of 2026 – another signal that the town’s annual housing delivery targets have been unrealistic and are being watered down in the current review.
The viability and sustainability of development at OSW004 are dependent on the delivery of major highways infrastructure changes at regional level to the A5 bypass, for which there are no start dates and may be years away.
- Development would use high quality Grade 2 & Grade 3a soils (as per Agricultural Land Classification England) which are regarded as ‘best and most versatile’ agricultural land and soils. This is not sustainable under government policy promoting local and national food supply security, and when alternative housing land is available elsewhere.
· Planning consent for housing at Whittington Road Sawmills not far from OSW004 was refused (Nov 2021) due to added traffic congestion and safety issues at the junction with Gobowen Road. An estate of 83 houses would make these traffic problems considerably worse. Clearly, housing on OSW004 does not align with Oswestry’s sustainable development due to the disconnect with schools and shops, the additional traffic congestion, and the inappropriate use of land of high heritage and agricultural value.