Guidance to Objecting/Deadline 19th Nov 2019

Objecting to the reconsultation on Phase 1 & 2 housing development in setting of Old Oswestry hillfort   

* Deadline Extended to Tuesday, 19th November 2019 *

This is the final push to save one of Britain’s most important hillforts and Iron Age landscapes from shortsighted development that has been consistently opposed by the public and key stakeholders for over 7 years.

Revised/new documents are out for consultation concerning the proposed housing estate in the near setting of Old Oswestry. Please join the fight to stop this ruinous and unwanted scheme by objecting – deadline extended to Tuesday, 19th November.

Please spare just a few minutes in our efforts to save 3000+ years of irreplaceable heritage landscape.

To object, follow our simple guidance here:

STEPS TO OBJECTING:

  1. Inspect the two planning applications and supporting documents here:

Ref 19/02685/EIA (Phase 1). Proposed residential development of 52 No dwellings…. Land to the North of Whittington Road, Oswestry. Weblink is: https://tinyurl.com/y5umezyv

Ref 19/02686/EIA (Phase 2). Proposed residential development of 48 dwellings…Land to the North Of Whittington Road, Oswestry. Weblink is: https://tinyurl.com/yxp3y98n

  • If you objected first time round (back in July), it is vital that you do so again to ensure your objections are considered. We recommend you resubmit your original objections, as little has changed in the new documents. You can also consider the ‘Guide Points’ below.
  • If you are objecting for the first time, start with a statement expressing how you value and feel about Old Oswestry hillfort and its landscape setting. We have also provided some ‘Guide Points’ below. 

Alternatively, you can register your objections online, making sure you submit them to both applications via these links: https://tinyurl.com/y5umezyv & https://tinyurl.com/yxp3y98n. Tip: If you are objecting online, draft and save your response separately before you complete the online form, just in case you encounter a technical hitch.

IMPORTANT. Please remember to register your objections against both applications and by the new, extended deadline – midnight on Tuesday, 19th November 2019.

Thank you so much for your support.

GUIDE POINTS TO OBJECTING

  • In the ‘Statement of Common Ground’ (SoCG) agreed between English Heritage (now Historic England) and Shropshire Council in 2014, a condition of any potential scheme would be to ‘ensure that new development does not protrude to the north of the existing built development, to the west of the allocation’. The proposed housing significantly exceeds this limit.
  • The proposed development extends outside the town boundary and into land (OSW058) that Shropshire Council has ruled out for potential development through to at least the end of 2036.
  • The masterplan has not complied with SAMDev Policy S14.1 because the layout leaves no views of the hillfort from Whittington Road.
  • The design fails to meet Oswestry’s 2020 plan as it does not provide an attractive gateway to the town along Whittington Road. Instead, first impressions will be dominated by indistinct modern housing, similar to many other towns, rather than preserving open views to the unique spectacle of one of Britain’s finest hillforts.
  • Oswestry Town Council and Selattyn & Gobowen Parish Council, important consultees, have consistently opposed and continue to oppose development on OSW004.
  • Old Oswestry hillfort and its landscape is much loved and appreciated as an asset of high community value for its national heritage importance and natural beauty preserved by its existing surroundings, without any further incursive development.
  • Significant and longstanding public opposition to development on OSW004 is evidence that the greater public benefit comes from its conservation, not housing that damages the hillfort’s setting and significance and can be accommodated elsewhere.
  • The Heritage Impact Assessment (HIA) provided within the Environmental Impact Assessment (EIA) states that setting is not relevant to communal value but without providing any supporting evidence, contrary to Historic England’s Conservation Principles which require an assessment of communal value.
  • The EIA/HIA does not fairly assess and therefore underestimates the degree of harm from the OSW004 development within the setting of Old Oswestry (and of two adjacent scheduled sections of Wat’s Dyke) given its national significance as a designated heritage asset. It assesses that only ‘some’ harm will be caused, including harming 11% of views to/from the hillfort – this is ‘substantial’ given the hillfort’s national significance, and represents only part of the harm/impacts.
  • The EIA/HIA does not meet the following requirement within the S14.1 Oswestry policy/Statement of Common Ground: ‘To inform the layout of the site, full archaeological assessment will be required to enhance the understanding and interpretation of the significance of the Hillfort and its wider setting.’ A full archaeological assessment has not been delivered because an insufficient area (less than 2%) of the site has been investigated with trenching. In addition, there is no reference to the PAS (Portable Antiquities Scheme), nor to Shropshire’s HER (Historic Environment Record), and no metal detecting survey has been undertaken. The omission of references to the PAS and HER also makes the EIA/HIA non-compliant with Shropshire Councils’ EIA Screening Opinion which requires consideration of the ‘many designated and non-designated heritage assets around this site’.
  • The EIA/HIA fundamentally underestimates the heritage significance of Old Oswestry and therefore the heritage impacts on this significance from development in its setting. This is contrary to the NPPF, where harm to a nationally important monument through damage to its setting is predicated on the principle that the greater the significance of the monument, the greater the impacts of development in its setting.
  • Since the EIA/HIA fundamentally underestimates the significance of Old Oswestry, while misinterpreting the contribution and principle of setting, the masterplan and proposed development, contrary to the S14.1 Oswestry policy, does not secure ‘appropriate integration of development within the sensitive historic landscape’.
  • In its Statement of Significance for Old Oswestry (given 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.’ In light of this, the masterplanning, housing grid, design and density are wholly inappropriate; they do not enable the rural setting to be maintained or the significance of the site to be better understood.
  • The housing arrangement adopts a block plan, contrary to the requirements of English Heritage (now Historic England) in the SoCG.
  • The proposed development does not comply with the NPPF paragraph 192 which states the desirability of enhancing the significance of heritage assets.
  • The proposed development does not comply with NPPF paragraphs 193–94. The development clearly causes substantial harm to the significance of a designated heritage asset through development within (and therefore destruction of) its setting. As such, in accordance with the NPPF, the LPA should refuse consent, because it cannot be demonstrated that the harm/loss is necessary when houses can be built elsewhere.
  • The proposed development does not comply with NPPF paragraph 193 which states: ‘..great weight should be given to the asset’s conservation … irrespective of whether any potential harm amounts to substantial harm, total loss, or less than substantial harm to its significance’.
  • The EIA/HIA fails to comply with NPPF 194 as it does not make ‘clear and convincing justification for the harm to, and loss in significance of, the significance of a designated heritage asset’.
  • By underestimating both the harm to the setting and the magnitude of this harm to the  hillfort’s significance, the EIA/HIA fails to comply with the requirement in Shropshire Councils’ EIA Screening Opinion, as follows: ‘The Oswestry Hill Fort is a unique historic setting and landscape landmark that will require detailed consideration in relation to impacts on its setting and consideration to any mitigation in the form of landscaping (if considered necessary).’
  • Shropshire Councils’ EIA Screening Opinion requires that ‘the environmental sensitivity of geographical areas likely to be affected by development must be considered’, with regard to, among other things, ‘(viii) landscapes and sites of historical, cultural or archaeological significance’ also stating: ‘The Oswestry Hill Fort is a unique historic setting and landscape landmark’. The scale of the masterplanning represents unacceptable damage to the setting and significance of the hillfort and Wat’s Dyke and to a heritage-rich landscape, with numerous PAS and HER features, of high cultural value to the local community.
  • Shropshire Council’s updated landscape and visual sensitivity assessment for northern Oswestry attaches high value to the area including the hillfort and its surroundings, saying: ‘Any development within this landscape would be highly noticeable within the view and could result in the degradation of the setting of heritage assets…’ and ‘overall the sensitivity of the landscape to change as a result of development for housing is high…’ As an updated planning document for strategic development, these assessments render development on OSW004 and any proposed masterplan as undeliverable.
  • The large scale of the built development (including houses, drives, roads, substation, pumping station) of the masterplan, entailing substantial harm to the setting and the significance of the scheduled monument, does not meet the S14.1 Oswestry policy requirement that: ‘Development should demonstrate appropriate regard to the significance and setting of the Old Oswestry Hill Fort.’  
  • The S14.1 Oswestry policy requirement is undeliverable, creating significant safety risks in asking for ‘pedestrian and cyclepath links to the former railway and a new footpath link between Whittington Road and Gobowen Road to improve access towards the Hill Fort’. The proposed point of access emerges on a dangerous bend with no pavement onto the B5069 Gobowen road that has seen several RTI fatalities. People will gain no additional opportunities to view the hillfort along the road nor new access to the hillfort, as there is no public access via the hillfort’s eastern entrance nor would this be supported by Historic England, as indicated in their response to previous masterplans on Oldport Farm attempting to offer this. In addition, the railway line, a heritage asset, is privately owned and not a corridor for walking or cycling as it is to be returned to service as a railway link.
  • In providing public access to the B5069 Gobowen road, disabled access will be extremely difficult to achieve over the raised embankment of the Cambrian Railway line, and impossible when a live railway track is installed as part of local plans to restore the connection to Gobowen.
  • The S14.1 Oswestry policy requires that: ‘The opportunity should be taken to consider measures to improve the access, interpretation and enjoyment of the Hillfort and the wider historic landscape.’ A substantial housing estate with intermittent green planting and a handful of information boards does not fulfil this, especially when the access improvement to the hillfort leads people into road safety risks and Historic England has no plans to develop access via the eastern entrance.
  • The proposed development does not comply with the S14.1 Oswestry policy that masterplanning should ensure that ‘long distance views to and from the Hillfort within its wider setting are conserved’. The built form will screen a large percentage of views of the hillfort currently available from Whittington Road (B4580).
  • The viability and sustainability of development at OSW004 is dependent in part 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.

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