Conservation casework log notes august 2017


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The GT conservation team received 147 new cases in England and three cases in Wales during August in addition to ongoing work on previously logged cases. Written responses were submitted by the GT and/or CGTs for the following cases. In addition to the responses below, 49 ‘No Comment’ responses were lodged by the GT and 13 by the CGTs in response to planning applications included in the weekly lists.



GHS ref

Reg Grade


Written Response


Page Park




PLANNING APPLICATION Erection of single storey rear and side extension to form additional living accommodation. 1 Park Road, Staple Hill, Bristol, South Gloucestershire BS16 5LB. BUILDING ALTERATION


Summary: The Avon Gardens Trust has no objection to this proposal.
We are grateful for the opportunity to comment on this proposal. Page Park is a non-designated heritage asset as identified by South Gloucestershire Council. It is a locally registered garden in the gazetteer of Historic Parks and Gardens in Avon. Within the curtilage of the Park itself there are a number of locally listed structures and one nationally listed.
We made a site visit to Page Park and noted that the proposed works are in keeping with alterations already carried out to adjacent houses. The South and East boundary of the application site are adjacent to the Park. 
Views of the extension from the Park would be quite limited by trees and other vegetation in the Park. However the planned extension would be very close to the southern boundary wall of the Park (75mm) and would need protective measures to prevent possible damage to the wall during construction of the extension.
Similarly, before any construction work takes place, consideration of how to protect the roots of existing trees within this area of the Park ( in particular that labelled T2 ) should be demonstrated
As previously notified to you, The Gardens Trust, which is the statutory consultee on matters concerning registered parks and gardens is now working closely with County Gardens Trusts, and the responsibility for commenting on planning applications in this context has now passed to Avon Gardens Trust.
We would be grateful to be advised of your decision, or if further information is submitted.
Yours sincerely
Ros Delany (Dr)
Chairman, Avon Gardens Trust

Kedleston Hall




PLANNING APPLICATION and Listed Building Consent Conversion of existing barns to 4 No. residential units, removal of modern agricultural sheds and erection of 2 No. new build 'barn' style dwellings. Hall Farm, Flagshaw Lane, Kirk Langley, Ashbourne, Derbyshire DE6 4NW. RESDIENTIAL, BUILDING ALTERATION

Thank you for consulting The Gardens Trust (GT), formerly the Garden History Society, in its role as Statutory Consultee with regard to proposed development affecting a site included by Historic England (HE) on their Register of Parks & Gardens (RPG), as per the above application. The GT has studied the deposited documents online. Based on these, the GT would be grateful if those involved in the decision making process would take into consideration our comments below.
The Gardens Trust objects to the proposal in its current form, for the following reasons:
1. The proposed development area includes the Grade II Listed Hall Farmhouse and lies within the Defined Setting for Kedleston Park, which is a Grade I Registered Park and Garden. It is similarly close to and may impact adversely upon the Settings of the nearby Grade II Listed Langley Hall and the Grade II Listed Garden Walls at Barn Croft, both of which lie c.150m to the south and Lodge Farmhouse (Grade II) which is around 600m to the east.
The National Planning Policy Framework (NPPF) requires that where a development is proposed, the applicant should ‘…describe the significance of any heritage assets affected, including any contribution made by their setting…’ (para.128). The applicant’s ‘Planning and Heritage Statement’, while it lists some of the designated heritage assets nearby, including Kedleston Hall RPAG, fails adequately to describe their settings and how these may be impacted upon by the proposed development. 

In the case of Hall Farmhouse itself, the Statement merely states that the farmhouse will benefit from ‘…the removal of the unattractive modern sheds, and their replacement with smaller, more traditionally designed buildings…’ (para.5.16). 

Overall, the applicant’s heritage impact assessment is limited to the rather bland statement that ‘…it is considered that the proposed scheme will enhance the setting of the Listed Building and Curtilage Listed Buildings, the character and appearance of the Conservation Area, and restore the appearance of a valued traditional landscape within the designated setting of Kedleston Hall Park and garden...’ (para.5.16), but without in any way attempting to describe the settings referred to, or to quantify the changes which are likely to occur as a result of the proposed developments, or to say why it is considered that these settings will be ‘enhanced’.
2. The proposed development lies within the Kirk Langley Conservation Area (which does in fact include some adjacent farmland) and as such is subject to a number of controls, including Amber Valley’s Supplementary Planning Document Listed Buildings and Buildings in Conservation Areas (April 2007). Among other objectives, this provides advice to owners and occupiers of listed buildings to:
• ensure that any new buildings within the curtilage of a listed building or its setting are designed and sited to respect the character and appearance of the building (p.3).
A Grade II listed building is described as of ‘…special interest which warrants every effort to preserve them.’ (p.5).
With reference to new buildings within the curtilage of a listed building, the SPD guide states that planning permission ‘…is required for all new buildings within the curtilage of a listed building which are 10 cubic metres or more. Such buildings will only be acceptable where they do not adversely affect the setting of the listed building and complement the principal building. Good quality materials will also be required’ (p.8).

The following elements of the proposed development would seem in our view to run counter to the above guidance and would in consequence tend to have a negative impact on the setting of the heritage assets described above, as well as the overall appearance of the development within its agricultural landscape setting: 

• The replacement of the existing agricultural shed, adjacent to the east side of Hall Farm itself, with a new garage block of 3 double and one single garages. The applicant states that this ‘…would take the place of a large 20th Century shed which somewhat detracts from the character and appearance of the Listed Buildings…(para.5.3). However, the proposed garage footprint in fact extends some way beyond the northern side of the existing buildings footprint (and its historical predecessor) and would in our view negatively impact upon the Hall Farm listed building;
• The erection of 3 new-build properties beyond the historical farmyard complex boundary, including a separate new-build garage in the north of the site;
• The layout of the new-build properties in particular, which do not appear on plan to relate in any way to the surviving historic buildings, and which would in our view tend in consequence to appear more as an urban residential development, rather than as a traditional farming complex from this area;
• The proposed use of ‘zinc sheet with standing seams’ as a roofing material, which is more usually seen in urban office and other developments, in two locations within the site.
We accept that the conversion to other uses of redundant agricultural buildings in a farming landscape may contribute to their future preservation. We are concerned however that in proposing this development, the applicants have not sufficiently considered the impact of their proposals on the surrounding countryside, or on the setting of the designated heritage assets described above. We would have hoped to see something more sympathetic to the site.
Yours sincerely,
Margie Hoffnung
Conservation Officer

Kedleston Hall




PLANNING APPLICATION Single Storey Bungalow with Garage and Car Port (This is a Departure from the Amber Valley Borough Local Plan 2006). Woodlands, 12 Ashbourne Road, Kirk Langley, Ashbourne, Derbyshire DE6 4NS. RESIDENTIAL

Thank you for consulting The Gardens Trust (GT) in its role as Statutory Consultee with regard to proposed development affecting a site included by Historic England on their Register of Parks & Gardens, as per the above application. 
The application site above is just to the north of Ashbourne Road at about 1.5 miles as the crow flies from Kedleston Hall itself, bringing it well within the Defined Setting for Kedleston (Policy EN33). As such Para 6.108 requires any planning applications within this zone be accompanied by an historic landscape appraisal, which this application lacks. The proposed bungalow lies within an existing development of approximately half a dozen other buildings, all larger than the proposed new structure. The proposed house is of one story, and as such the GT is satisfied that its impact is likely to be minimal. However, should Amber Valley grant permission (despite this being a departure from the Local Plan 2006) the GT would ask that this site is monitored by the planners on the GT’s behalf, to ensure that no future application(s) attempt to vary the permission to allow a first floor to be added as this would have a far more negative impact.
We would be grateful if you would keep us informed as to the outcome of this application.
Yours sincerely,
Margie Hoffnung
Conservation Officer

New Hall, Boreham




PLANNING APPLICATION Erection of 3m high open-mesh security fencing around school perimeter - approx. 2500 li.m. New Hall School, The Avenue, Boreham, Chelmsford, Essex CM3 3HS. BOUNDARY

New Hall is a grade I Tudor mansion set in a grade II registered landscape with many layers of history, from the Middle Ages to the 17th century. The setting of the house and its landscape is under pressure from both new housing in the vicinity and the further development of the school which occupies the premises. This is yet another totally inadequate application for development at the school. It claims ignorance as to the listing grade of the building, lacks a heritage statement or design and access statement, or any supporting justification for what it is proposed to do. This application would see the registered landscape enclosed by utilitarian weldmesh fencing on all but its north side, with consequential damage to its setting. Were this, or elements of it, to be considered acceptable, it should be justified, alternatives in different areas at least contemplated, and mitigation offered in the form of planting to soften it. I would refer the applicants to Essex County Council's School Boundaries Guidance document.

David Andrews

Little Grove

Greater London




PLANNING APPLICATION Demolition of existing dwelling and erection of 7no two-storey dwellings, including 3no detached dwelling house and 4no semi-detached dwelling houses. Associated access road, car parking and landscaping. 48 Chestnut Grove, Barnet EN4 8PU. RESIDENTIAL

PLANNING APPLICATION Demolition of existing dwelling and erection of 8 no two-storey buildings, comprising of 1no detached dwelling house, 6no semi-detached dwelling houses and 1no two-storey building with rooms in roofspace to provide 3no self-contained units. Associated access road, garaging, car parking and landscaping (AMENDED DESCRIPTION). NOTE: This application Ref: 17/4364/FUL is running concurrently with application Ref: 17/3949/FUL for 7 two-storey dwellings. When comments are made please quote applicable reference numbers. 48 Chestnut Grove, Barnet EN4 8PU. RESIDENTIAL


The two applications above have been brought to our attention by a local resident, via the London Parks & Gardens Trust. The Gardens Trust (GT) is the Statutory Consultee with regard to proposed development affecting a site included by Historic England on their Register of Parks & Gardens. Whilst the above site is not listed, what is not made apparent from the documentation on-line, is that the area marked for development is a small remaining part of a mostly lost Capability Brown landscape. Payments are recorded in Brown’s account book from between September 1768 to July 1770 totaling £700 for the work he carried out for the Hon Edward Willes at Little Grove, East Barnet. Given that he was paid such a substantial sum for the work here, the GT would expect this to include a kitchen garden as well as some good planting. 2016 was the tercentenary of Capability Brown. As part of this a great deal of research was carried out and it appears that whilst the site itself is not listed, almost certainly the walls within the garden attached to 48 Chestnut Grove, and perhaps the large pond itself, are part of Capability Brown's work. Joan Pateman wrote an article about the garden in the London Landscape 42, Spring 2016, pp.10-11, which I am attaching for your information. She says that the site was inspected in 1991 by Edward Chaney, then at English Heritage, who described the walls : ”as two and a half sides of a walled kitchen garden. …. It is notable that the kitchen garden is not shown in either Dury’s map of 1766 or John Rocque’s 1754 map of Middlesex but it does appear in the Enclosure map of 1817, and subsequent maps and plans, and is included in the 1817 sale particulars. This argues for the wall to have been built between 1766 and 1816. Indeed it could have been put up between 1768 and 1770, given the sums disbursed by Mr Brown.” The large kitchen garden, fishponds and specimen trees in the garden and park are all familiar elements of a Brownian landscape.

The pond itself appears on the OS 1st edition as a roughly rectangular pond without an island to the west of the walled garden, in exactly the same place as in the 1817 enclosure map. It is therefore at least 200 years old and as such an historic landscape feature in its own right with wildlife and amenity value.
The GT would therefore ask that an accurate examination of the complete site is undertaken and a detailed Heritage Impact Statement produced. The GT would like to be able to review this document to ensure that it is sufficiently thorough, before submitting their final comments. Given the known history of the site, without such a rigorous report it is not possible to make any meaningful comments about the impact of the application. The GT feels that without a Heritage Impact Statement, the application does not fulfill NPPF’s sustainability criteria and until these are satisfied, any decision on the applications should be put on hold. 
We would urge Barnet Council to request further research so that these applications can be properly assessed.
Yours sincerely,
Margie Hoffnung
Conservation Officer

Woodhall Park




PLANNING APPLICATION Application for the proposed realignment of Ware Road between a point west of the access road to Heath Mount School, to the existing southern-most Stony Hill junction; with realignments at all junctions within this section; including associated changes to verges, lighting, drainage, landscaping and engineering operations at A602, West of entrance to Heath Mount School, to existing Stony Hills junction in the south-east. ROAD


Thank you for consulting the Hertfordshire Gardens Trust
We are familiar with the landscape of Woodhall Park (Grade II* on the HE Register) and its history. As this application affects the setting and therefore significance of a Registered heritage asset, we have studied the application documents in this light..
We are satisfied that the mitigation measures proposed, as well as the partial re-alignment further from the park wall, will not damage the setting of the park and, together with the additional tree planting and other measures carried out in the parkland by the owner, may well enhance it.
We therefore raise no objection to this application
Yours sincerely
Kate Harwood
Conservation & Planning
Hertfordshire Gardens Trust





PLANNING APPLICATION Removal of existing damaged tarmacadam path and replace with stone paving. Haileybury And Imperial Service College, College Road. Hertford Heath, Hertfordshire SG13 7NU. FOOTPATH/CYCLEWAY

HGT are familiar with this Locally Important landscape designed by Humphry Repton, and his only college landscape.

We support the replacement of inappropriate tarmacadam with a more sympathetic paving material. We are aware that historically Wilkins used stone to highlight the important status of the building but that this was in limited amounts for reasons of economy. We have no information about the original paving material in this location although the terrace and gardens had gravel paths.

Kate Harwood

Tewin Water




PLANNING APPLICATION The construction of a new farmyard including 3 new agricultural buildings, associated yard area, cattle handling pens and silage storage area, landscaping and drainage. Tewin Water Farm, Churchfield Road, Tewin, Hertfordshire AL6 0BW. AGRICULTURE

HGT, as a member of the Gardens Trust, OBJECTS to this proposal. Despite assertions in the accompanying documents that there is scope for 'restoration' of Repton elements, Repton's design intent for this part of the park would be destroyed. 
Repton deliberately opened up views from the house towards his new lake just to the south of the application site and specified that it should be all parkland, i.e. not ploughed fields or evidence of farming. Views up the valley sides and down to the lake were important, incorporating ancient landscape within his design, and they would be destroyed. Repton praised the 'extent of parkland without mixture of alien property' and this Grade II landscape is a good, almost intact survival of his work and ideas. He considered it as one of his jewels along the Mimram, together with Panshanger and Digswell, now both severely compromised as designed landscapes. The new development would destroy the Tewin Water concept just before we celebrate nationally his bicentenary in 2018.
This application would be contrary to the NPPF concept of conserving and enhancing heritage assets an the utilitarian farm buildings and layout contrary to the principles of sympathetic design 

We urge you to Refuse this application.  

Kate Harwood
Conservation & Planning
Hertfordshire Gardens Trust





PLANNING APPLICATION Demolition of existing dwelling and erection of 2no. detached dwellings amended application. 24 Pishiobury Drive, Sawbridgeworth, Hertfordshire CM21 0AE. RESIDENTIAL

HGT, a member of The Gardens Trust, considers that this development, although not causing substantial harm to the Registered Pishiobury Park, does lie within the former parkland at a position where a walled and wooded enclosure is depicted on early OS maps. An archaeological watching brief for any groundworks would be advisable, as footings and floors for former structures have previously been uncovered elsewhere in the park.
Kate Harwood
Conservation & Planning
Hertfordshire Gardens Trust

St Albans Brownfield Register (BLR) & Strategic Housing Land Availability Assessment (SHLAA)




LOCAL PLAN St Albans City and District Council Draft Brownfield Register (BLR) and Strategic Housing Land Availability Assessment (SHLAA) Call for Sites.


Hertfordshire Gardens Trust, a member of The Gardens Trust, statutory consultee for historic parks and gardens, have the following comments on 3 sites

1. SHLAA-GB-SA-405 Land Northwest of Batchwood Drive St Albans: This is part of the designed landscape for Batchwood House, home of Baron Grimsthrope which has key views across this landscape towards the Abbey, which he was instrumental in restoring
2.SHLAA-GB-H-247 Aldwickbury Golf Course. This is the substantial remnants of a 19th c gentry estate then know as High Firs and contains relics of the plantings as well as key views across the Lea Valley
3.SHLAA-GB-LC- 239 All Saints Pastoral Centre. This is an early pilgrimage landscape, relics of which are extant. t was also an 18 and 19th century designed landscape, relics, such as the hollies collection and other trees, still remain.
All these sites, as well as being Green Belt are historic designed landscapes on HGT's Local List and any future revision of the list should take this into account. We welcome the fact the the Aldwickbury and Batchwood Drive sites have been rejected and trust that All Saints will have a heritage impact study as part of any future consideration for development.
Kate Harwood
Conservation & Planning
Hertfordshire Gardens Trust

Node Park




PLANNING APPLICATION Demolition of partially constructed dwelling and associated garage and erection of 2 dwellings with associated access, parking, gardens and partial rebuilding of existing garden wall. Node Park, Hitchin Road, Codicote. RESIDENTIAL


Herts Gardens Trust has been considering this application - and has been involved with the planning process for this site for many years.

We do have a number of reservations about this plan. Whilst we feel that the demolition of the round house and re-instatement of the garden wall are to be welcomed, we are concerned that the inclusion of part of the historic orchard ground to the east of the wall as garden ground for the replacement house tucked behind the wall (Plot 5). If this is inappropriately fenced or hedged and cultivated as garden, it will detract from the orchard ground and the Listed Peach House.
We suggest that the re-instatement of the wall should be in period-appropriate materials and in matching bricks and bond. We note that several windows will be inserted though, as that document does not open (on the NHDC wesbite) we are unable to judge how intrusive they may be
The other house (Plot 4) is sited in a very prominent part of its plot and will thus detract not only from the historic landscape and the Peach House, but from the small scale farm or stockyard to its southwest. and the line of house, wall and double garage doors would cause an unacceptable degree of ham to the significance of these. We would suggest that the house is sited further back on its plot and the garage resited so the doors are not in such a prominent position.

We note that the Beacon Report mentions that the apple store is derelict and not used . It was used to store apples from the orchard until very recently and it is only neglect that has caused this deterioration. We would suggest restoration of this facility and also the replanting of some historic fruit species in the orchard to replace those which have been recently felled. This would restore context to the Walled Garden and the Peach House (listed glasshouse). You may be aware that the Hertfordshire Orchards Initiative is being re-launched on September 8, as part of the HLF Orchard East project. The Node is one of the historic orchards included.

If planning permission is granted we would urge that, as noted in the application (section 6.06), the same condition of removing permitted development rights is applied . Two houses, gardens and garages cause far more harm to the significance of the landscape than one, regardless of size of house. We are also concerned about the rest of the walled garden, and indeed, the whole estate, which has much new development on it, not all of the standard we would have expected. We would urge that the fact that this is a historic designed landscape (on HGT's local list) and within the Green Belt protects this from either more housing or the extension of garden ground by any of the current householders.
We note that policies SP1 and SP13 in the NHDC Draft Local Plan support the conservation and enhancement of heritage assets which would include their settings.
Yours sincerely
Kate Harwood
Conservation & Planning
Hertfordshire Gardens Trust

Caythorpe Court




PLANNING APPLICATION Construction of 4 no. accommodation blocks, trapeze and vertical challenge course, quad bike track, raft building platforms, rifle range and target shooting and giant swing and zip wire towers. Caythorpe Court, Caythorpe Heath Lane, Caythorpe NG32 3ER. VISITOR ATTRACTION


Lincolnshire Gardens Trust (LGT) welcomes this opportunity to comment re this planning proposal. As a member of The Gardens Trust (TGT) LGT works closely with the TGT (formerly the Garden History Society), the statutory consultee for all planning and development proposals affecting all sites on the Historic England Register of Parks and Gardens. Thanks to local knowledge, LGT advises the TGT and, on occasion, comments on their behalf. 

Caythorpe Court, Grade II*, has a 4-hectare park, Grade II, containing an early 20th-century formal garden with mid-20th-century development. Caythorpe Court was designed by Sir Reginald Blomfield in 1899 as a hunting lodge and built in 1901-3. The site is now used as an outdoor pursuits centre. 
LGT cannot agree that the “open nature of the activities” in this proposal will have a negligible impact on this listed building and its designed setting. LGT have the following major concerns: 
Firstly, the Aeroball Area would be inappropriate to the sense of place and ‘arrival theatre’ of the original site entrance (no longer the main site entrance) a 70-metres approach drive leading from ornamented wrought-iron gates sit between partially rusticated gate piers and are flanked by high stone walls, Grade II to the contrasting walled forecourt. Such a feature would be detrimental and impact on the significant elegant ambiance/sense of place of the Edwardian Grade II* house, Caythorpe Court. 
Secondly, LGT considers the proposed Rifle Range is inappropriate within close range of the Edwardian Grade II* house, Grade II gatehouse and Grade II garden setting. Such an activity would completely disturb the ambiance and the noise would disturb the peaceful views from the garden terraces let alone the wild-life of the woodland, including the birdlife. LGT queries the need for this second rifle range. What is wrong with the existing rifle range that another site is needed? 
Thirdly, a second zip wire tower in the woods would detract from the setting of the listed building, and might degrade the views particularly in the winter months. 

Lastly, it seems that the Arboricultural Survey and Plan is incomplete in recording only those trees in the main activities area, that is, the site for accommodation and administration buildings of the outdoor pursuits centre. There seems to be no reference to the trees in the listed area of the designed setting of Caythorpe Court gardens and enclosing woodland to northwest and southwest, at the heart of the PGL site. LGT have concerns re possible removal of significant mature trees in all these areas to enable proposed activities in the Aeroball Area, the Proposed Rifle Range and in the area of the second Zip-wire tower. 

There are few surviving gardens of historic and design significance from this Edwardian period in Lincolnshire. Lincolnshire Gardens Trust has concerns that historic designed gardens by Sir Reginald Theodore Blomfield RA (1856 –1942) an internationally renowned and prolific British architect, garden designer and author, with further works by award-winning garden designer, winner of RHS Chelsea gold medals, and horticultural writer Percy Cane (1881 – 1976) will be both affected and degraded by unsuitable proposals for an Aeroball Area, a Rifle Range, and second Zip-wire tower. The impact of this proposal would be to reduce the historic park sense of place considerably along the original drive and would affect the peaceful ambiance of the garden terraces and woodland. Caythorpe Court’s gardens are becoming increasingly in danger of being neglected and at best marooned, surrounded by an outdoor activities theme park. For this perceived harm to the Heritage Asset LGT object to this planning proposal. 
Yours sincerely, 
Steffie Shields 
Vice-Chairman Lincolnshire Gardens Trust 

Badger Dingle




PLANNING APPLICATION Erection of residential annex following demolition of garage/storage building. Stableford Lodge, Stableford, Bridgnorth, Shropshire WV15 5LS. BUILDING ALTERATION


We have been forwarded notice of the above planning application through the offices of The Gardens Trust (formerly The Garden History Society). The Gardens Trust is a Statutory Consultee in planning matters relating to historic parks and gardens which are included on the Historic England Register of Parks & Gardens of Special Historic Interest in England and we are acting on its behalf in this matter. 

We understand that permission has previously been granted for a residential building in a similar location to the current application, although we do not recall having been consulted at that time. Nonetheless, we note that the current application is for a smaller building which will have less visual impact than the earlier design. 
The application site is at the northern entrance to the former Badger Dingle, which is included at Grade II* on the Historic England Register of Parks and Gardens. At least one, if not two of the extant buildings on the site appear to relate to the former lodge buildings at this entrance and the site boundary straddles the line of the former approach from this point. This notwithstanding, a new entry and approach from the road has now been constructed, so the inclusion of the proposed new building should not interfere with access to this approach to Badger Dingle. We request however that no additional expansion of the northern boundary shown on the Amended Block Plan (drawing No.3096421.pdf) should take place and that the development should not cause or bring about any obstruction to the existing access route. 
Yours sincerely, 
Christopher Gallagher for Shropshire Parks & Gardens Trust & The Gardens Trust

Hatch Court




PLANNING APPLICATION Construction of Ha-Ha, reconfiguration of driveway and repositioning of fencing at Hatch Court, Frost Street, Hatch Beauchamp. BOUNDARY, ACCESS/GATES


Further to your email of 27th July I have re-examined the documentation relating to the above application. As you requested, I have paid particular attention to the letter sent to your authority by Ms Wendy Tomlinson of Historic England (HE), dated 6th July 2017 and spoken to Kim Auston in the absence of Ms Tomlinson who is on leave. The Gardens Trust (GT) would like to confirm that we maintain our original OBJECTION to this application for the reasons set out at length in greater detail below.

As you will be aware from the leaflet I sent you with my original letter (The Planning System in England and the Protection of Historic Parks and Gardens – Guidance for Local Planning Authorities), LPAs should consult the GT for all grades of sites, but HE only in relation to Grades I and II* registered sites. Therefore in this instance, as a Grade II registered landscape, the GT is the appropriate statutory consultee. 
From the correspondence it would appear that Historic England has had discussions with the applicant. Had appropriate pre-application discussion taken place with the GT it is possible that a scheme could have been devised which would not have resulted in a formal objection on our part. 
While we have no particular objection to the proposed minor realignment of the west drive, we would point out that the statement in paragraph 2.2 that “The present [west] drive is of 20th Century construction” is potentially misleading. While the present surface is undoubtedly of twentieth century construction, the line of the drive has remained unchanged since at least 1820 when it was recorded on the Estate plan. This point notwithstanding, we do not object to the proposed change because we conclude that it does not conflict with the prevailing early nineteenth century character of the designed landscape.

The HE letter begins with an extract from the Register of Parks & Gardens description which includes a reference to the C19 ornamental railings which enclosed an area forming “a semi-ellipse on plan” to the south of the house, and these railings are clearly delineated in pictorial form on the 1820 Estate plan (Somerset RO:DD/TN9). The English Heritage Register Inspector clearly considered these to be significant features of the historic landscape design. Drawing 105/4 submitted with this application shows the semi-elliptical enclosure removed and a straight boundary comprising “Estate Railings” separating the park from the pleasure grounds substituted south of the house. We consider this to be a significant and detrimental change to the designed landscape. We also believe, from the admittedly limited vantage point of the adjacent public footpath and highway, that the distinctive and highly ornamental early nineteenth century railings have already been removed, although no consent appears to have been granted for this operation in the setting and curtilage of the Grade I Listed Building. We have already requested your clarification of this point and await your response.

We also believe that the historic and aesthetic analysis of the historic designed landscape is problematic for several reasons :
• There is no evidence of any consideration of the historic or aesthetic significance of the early nineteenth century railings to be removed south of the house;
• A comparison of the early nineteenth century plans with the later nineteenth and early twentieth century OS, and with the situation on the ground today, shows that the early nineteenth century phase of landscape development remains substantially intact today, and determines the prevailing character of the designated designed landscape and the setting of the Grade I Listed Building. Whilst a ha-ha may be an “authentic landscape device to keep the deer within their sphere”, there is no evidence of any consideration of whether (a) a ha-ha is appropriate to this particular designed landscape; or (b) whether the design of ha-ha proposed is appropriate to the historic and aesthetic character of this particular designed landscape. 
• There is no attempt to analyse the intrinsic or relative significance of the various phases of historic landscape development at Hatch Court. The earliest map evidence for the approach to the house, including Day and Masters’ map (1782), the Ordnance Survey Drawing (1802) and the 1” OS (1809) show an approach from the south; while the Estate map of 1820 (Somerset RO: DD/TN9) and a related, slightly earlier plan, and the Tithe map (1840-41) reflect the early nineteenth century development of the designed landscape around the house, which coincides with the addition of the curved wings to the original 1755 villa. 
For the reasons set out above, we consider that the ha-ha as proposed would be detrimental to the historic and aesthetic character and integrity of this designed landscape.

The Design Statement and Justification Statement attached to the application is over-simplified and given the impact of the proposed changes on the designated historic designed landscape, a more detailed analysis should be required from the applicant. For these reasons, the GT considers that the application does not meet the requirements of the NPPF with regard to the conservation of the historic environment.

The Design and Justification statement complains of the impact of an “inappropriate 2m high wire fence” in the vicinity of the house. We note from the Register description and various photographic sources that as recently as 2007, the deer fence forming the western boundary of the deer park was located immediately east of the semi-mature trees on the east side of the south drive, where, due to its proximity to the trees, it had a minimal visual impact. The fence which is now considered inappropriate, intrusive and costly to maintain, must therefore have been constructed in its present location within the past decade. Indeed, it does not appear to be shown in the position marked on Drawing 105/3 on Google Earth images dated August 2016. We find it surprising, therefore, that the adverse visual impact of a fence apparently so recently constructed is now used to justify the proposed ha-ha.
It is suggested that “if a ha-ha existed, it was lost during these alterations and later Victorian landscaping” (2.2). As a point of fact, no ha-ha is recorded on the 1820 Estate plan or the related slightly earlier drawing; demonstrating beyond doubt that any putative ha-ha was removed as part of the programme of landscape changes and improvement co-incident with the remodelling of the house in the early years of the nineteenth century.

It is stated that “archaeological evidence” exists for a ha-ha on the east side of the pleasure grounds at Hatch Court. However, this evidence is not produced in support of the application, and neither is it clear from the applicant’s documentation that, if implemented, this proposal would not have a damaging impact on any putative below-ground archaeology. We consider that your authority should be taking a close interest in this aspect of the proposals. If, as appears to be suggested by the applicant, archaeological evidence exists on site for the ha-ha and formal terraces shown by Thomas Prowse on his original architect’s proposal for the house (1755), this would be highly significant in itself, and would require appropriate safeguarding during any development. There is no evidence in the documentation that these features, allegedly the remains of a mid-eighteenth century ha-ha, are well-understood, or would escape damage if the proposed ha-ha was to be implemented.

Summary and Conclusion
The GT maintains its OBJECTION to this application. While the proposals relating to the west drive are in our view acceptable in heritage terms, those relating to the proposed ha-ha east of the house are unacceptable in heritage terms by reason of their detrimental impact on the special historic and aesthetic interest and significance of the designed landscape.
We believe that lack of rigorous historic and aesthetic analysis has resulted in the present unsympathetic and inappropriate proposals which, if implemented, would have a significantly adverse impact on the designated designed landscape and the consciously designed setting of the Grade I Listed house (as extended and altered in the early nineteenth century).
Conservation best practice indicates that proposals of the kind contained in this application should be informed by a conservation management plan (CMP). No such document exists for the designed landscape at Hatch Court, and in view of the present proposals we consider that one is essential in order to safeguard this nationally significant mid and late eighteenth and early nineteenth century designed landscape. Such a document would provide a firm evidential base from which to develop future development proposals, and against which such proposals could be judged by all interested parties.

Based on our understanding of the designed landscape at Hatch Court, we consider that it is likely that any CMP would conclude that the 1820 Estate plan (which shows the landscape as developed at the time of the alteration of the mid-eighteenth century villa, and which accords very closely to the late nineteenth and early twentieth century OS maps) provides the best record of that designed landscape, and the point of reference against which any development proposal should be judged. We stand by our assertion that the proposed ha-ha is entirely inconsistent with the aesthetic character of the landscape recorded on that plan and which, in all its essential elements, survives on the ground today and which accords with the character of the Grade I house as extended and altered in the early nineteenth century.

Should your authority be minded to grant consent for this application we would further advise:
• If implemented, the proposed ha-ha would represent the greatest change to the designed landscape at Hatch Court since the remodelling of that landscape in the early nineteenth century. The changes involved in the construction of the ha-ha and the removal of the curved ornamental railings south of the house implicit in the application, would entail the obliteration of a major part of the early nineteenth century designed landscape phase of development at Hatch Court, which was consciously developed as an aesthetically appropriate setting to the addition of the curved wings east and west of the mid-eighteenth century villa. 
• The loss of a substantial part (and arguably the key components) of the early nineteenth century landscape design would substantially diminish the historic significance of this designed landscape.
We understand that your authority is concerned about the possibility of an appeal by the applicant should you refuse consent for this application. In view of:
• The failure of the planning authority properly to consult the Gardens Trust as Statutory Consultee as part of the planning process;
• The inadequacy of the supporting documentation submitted with the application;
the GT suggest that the most appropriate course of action at this stage would be for the applicant to withdraw the application for further reflection and discussion both with ourselves and other relevant parties. At the same time, we suggest that such a course would allow time for a CMP to be developed which would inform future, more sympathetic proposals for the development and management of the deer park and deer herd, the continuity of which we agree to be a desirable outcome.
We look forward to being notified of your decision on this application.
Yours sincerely,
Margie Hoffnung
Conservation Officer

Brympton d’Evercy





1) FULL APPLICATION for formation of new road access, erection of 2,040sqm gross Class B1 offices and light industrial/Class B8 storage and distribution unit and erection of 8,443sqm gross Class A1 foodstore, petrol filling station, car parks and related infrastructure and landscaping.

2) OUTLINE APPLICATION for formation of remainder of a 56,051sqm gross business park including erection of Class B1 office and light industrial and Class B8 storage and distribution uses, secondary road access off Bunford Hollow, other related infrastructure and landscaping and all other matters reserved for future consideration.

3) EIA development.

Hybrid mixed-use planning application on 21.6 hectares of land known as Bunford Park. MAJOR HYBRID

Thank you for consulting The Gardens Trust in its role as Statutory Consultee with regard to proposed development affecting a site included by Historic England on their Register of Parks & Gardens, as per the above application. It is regrettable that this land was previously zoned for Business use in the South Somerset Local Plan and that the previous application (07/05341/OUT) was permitted as this application will be extremely detrimental to the RPG at Brympton D’Evercy. 

Having said that, the Gardens Trust is pleased to note that our comments relating to that application (as the Garden History Society) have been taken into account with regard to the currently proposed screening planting on the western side of the site. We felt that a 10m screening strip was woefully inadequate and are glad to see that this application shows a further belt of trees beyond the 10m strip to the west. I was not able find any documentation on line specifying which species of trees are proposed, but would suggest a mix which includes evergreen species as well as broadleaved. The landscape document on-line illustrates trees/plants which the Gardens Trust surmises are for planting within the site as they are unsuitable for exterior screening belt planting. Currently drawing 3558-Pl-001 rev N shows a band of planting to the west of Area D. The Gardens Trust would suggest that this strip was extended if possible to the north and west of the pond directly above (to the west of Area A). Additional planting below the 15m buffer planting zone below areas D & B to the south of the development would also be welcomed.
We would be glad if you would keep us informed as to the outcome of this application.
Yours sincerely,
Margie Hoffnung
Conservation Officer


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