Guidance for objecting to the new planning application (20/01033/EIA) for development in the setting of Old Oswestry hillfort
‘PLANNING APPLICATION REFERENCE: 20/01033/EIA, Land To The North Of Whittington Road, Oswestry, Shropshire. Proposed residential development of 91 No. dwellings with associated access, public open space, electricity sub-station, drainage and landscaping.’
DEADLINE: Monday 20th April 2020
Exactly 8 years since major development by Old Oswestry was first proposed, we are asking for your support once more in opposing the latest bid to build houses in the hillfort’s near landscape.
This third attempt with a planning application, for 91 houses, is still as large and as damaging to the significance and experience of this outstanding Iron Age hillfort and its setting as previous ones.
Be warned: this is likely to be our final chance to stop this widely opposed and unnecessary development. It will have very tangible, negative and irreversible impacts on a nationally important heritage landscape – entirely senseless when Oswestry has alternative sites for housing.
We need to reach a similar if not greater number of objections as before – that’s 130+ to show that public opposition is as strong as ever. Please note, this is a new planning application, so objections you may have made to previous applications are null and void – you must object afresh.
You can refer to our guide below to help you object by the deadline: Monday 20th April 2020.
Don’t let this unwanted development sneak through during a time of crisis
We know these are hugely challenging times; we are all very rightly prioritising the protection of our families and livelihoods through this devastating COVID-19 pandemic. As we cope with the current threat to public health and unprecedented social upheaval, the questionable timing of this new planning application for this most controversial of developments should not gain an advantage from our understandable distraction. As you stay safe and maximise time at home, we hope you will find a few minutes to stay with this fight in protecting this fascinating hillfort and special landscape, ‘The Stonehenge of the Iron Age’. These places of calm, escape and connection with our ancestors and nature will be all the more valuable to us when we come through this awful crisis. While we are striving to safeguard family and friends in our community from this dangerous virus, let’s make sure that ruinous planning under cover of a national crisis does not usher through development that we have passionately opposed for almost a decade.
FOLLOW THESE STEPS TO OBJECT:
- Inspect the application on the Shropshire Planning Portal here: https://tinyurl.com/ql2y9gj
- In submitting an objection, you might 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/faqs/faq/4/what_are_material_considerations
- For those campaigners who are busy with family life during these challenging times, simply cut and paste the 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 this proposed 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/ql2y9gj
- Please remember to register your objections by the deadline – midnight on Monday 20th April 2020.
Thank you so much for your support.
HOOOH – Hands Off Old Oswestry Hillfort
GUIDE POINTS TO OBJECTING
- The application is not compliant with the NPPF (revised February 2019). It fails to provide ‘clear and convincing justification’ for loss of significance to a designated heritage asset (as required by NPPF paragraph 194) and to conserve a heritage asset of the highest significance. This is due to the harm this 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 NPPF glossary states: ‘Setting of a heritage asset: The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral.’
- The application would destroy the existing views of the hillfort afforded along the B4580 Whittington Road, which allows the monument to be appreciated and experienced in its landscape. Shropshire Council planners and planning committee members are reminded of their duty under NPPF paragraph 200: ‘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 (NPPF paragraph 170) 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 and ‘Therefore, views experienced are of high sensitivity to change arising from new housing and very-high sensitivity to change arising from employment.’
- 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. Specifically, in Appendix 3 (page 48) the 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.’ However, the application masterplan and design concept show that these constraints have been widely ignored, by housing located north of the industrial units and block development being very evident.
- The large scale of the development, including 91 houses, drives, roads, substation and pumping station, constitutes a substantial change to the setting of a scheduled monument of high order significance. It therefore does not meet 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’. The applicants concede in the Planning Statement that there are significant material issues, raised in a previous objection by the Cambrian Heritage Railways, in providing access to Gobowen Road across the railway line. 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.
- The development still faces significant material issues due to its proximity to the Cambrian line; the proposal continues to refer to the railway as ‘disused’ and does not consider the potential noise, vibration, safety and other hazards and problems of being sited next to an operating railway. The landscape and access routes leading towards the north and north-west of the site are designed around the principle of gaining access over the railway, presenting potential dangers to those expecting or attempting to cut across to Gobowen Road towards the hillfort (which is not accessible to the public from the east, in any case).
- The proposal provides for an ‘Observation point equipped with benches and interpretation boards at the end of the tree-lined pedestrian avenue, to enable greater appreciation of the Hillfort.’ This observation point occupies one of the lowest points of the site, so would compound the barrier to views from existing trees and the Oldport farm buildings alongside Gobowen Road. It would also create the risk of extra traffic entering the site, with attendant parking and safety problems, due to visitors accessing it for views of the hillfort. There is also the added concern they may expect to access the hillfort from the estate, leading to potential trespass and safety issues if they should attempt to cross a ‘live’ railway line and reach the hazardous Gobowen Road.
- Fields shared with OSW004 and others located across the hillfort’s west/east landscape have been excluded from allocation for housing development by Shropshire Council until at least 2036 in the local plan review, 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 bypass.
- The design 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.
- Since 2012, there has been considerable and longstanding opposition from the public and key stakeholders/consultees to development on OSW004. This 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.
- 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 surrounding communities. The experience of all these cultural and heritage values rely on preserving the hillfort’s current fragile separation from the town, with no further urban encroachment within its setting.
- 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 masterplanning, 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’.
- 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 applicant claims that housing on OSW004 must be delivered to meet housing targets. However, we know from the current local plan review to 2036 that the town’s housing targets have been heavily reduced – hence the proposal for 229 dwellings including just 2 new site allocations to make up housing need as far as 2036, even though many new sites came forward for consideration 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.
- Over the past 18-24 months, there has been a healthy number of housing completions as well as new planning applications/approvals for dwellings in Oswestry, including progress with the application for 150 homes on the SUE. Housing data cited by the applicant does not account for all this activity. It is very possible that the current and prospective level of builds will meet Oswestry’s housing targets, without developing OSW004, through to the adoption of the revised local plan during the next 2 years when SAMDev becomes obsolete.
- 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.
- OSW004 constitutes the loss of high-quality Grade 2 and Grade 3a soils (as per the Post 1988 Agricultural Land Classification England) which would be regarded as ‘best and most versatile’ agricultural land and soils according to government policy driving for local and national food supply security.