Schedule of Sites Consultation Document (February 2015)
Representation ID: 1789
Respondent: Derbyshire County Council
S&H1901 has been subject to substantial opencast extraction and archaeology may be scoped out of the planning process.
Thank you for consulting on this Initial Draft Local Plan (Part 1), including a schedule of possible housing allocation sites. I offer the following comments in relation to archaeology and the historic environment resource:
Local Plan Part 1 initial draft
Policy LP28: the Protection of the Historic Environment.
Part e reads "Consulting the Historic Environment Record to identify and, where appropriate, seek protection and preservation in situ or recording of non-designated heritage assets in terms of previously unknown important archaeological remains, if they are likely to be adversely affected by development. All recording shall be undertaken by a suitably qualified professional prior to the development commencing and the records made publicly available."
I support the aim of this policy, which is to enable the conservation, management and recording of undesignated archaeological remains, including previously unknown remains identified as part of the planning process. However, the wording of the policy at present is a little confusing, and seem to only refer to previously unknown remains and not known archaeological sites (e.g. those with an HER record). The policy as worded also seems to imply that it is the local planning authority who will be responsible for consulting the HER, rather than the planning applicant (see NPPF para 128); it would also be useful to refer to archaeological desk-based assessment and field evaluation, which applicants may be required to carry out where appropriate to identify and characterise archaeological remains (also NPPF para 128). Finally, the use of the word 'important' introduces an unnecessary degree of uncertainty (because the policy doesn't define what 'important' means and it isn't a term used in historic environment planning policy): it may be more appropriate to refer to 'significance' in line with NPPF chapter 12.
I therefore recommend that the policy wording at LP28e is rewritten in the light of the above comments. A suggested revised wording might be as follows:
"Consulting, and requiring planning applicants where appropriate to consult, the Historic Environment Record, in order to identify undesignated archaeological remains, including known sites and previously unknown remains, and using archaeological desk-based assessment and/or field evaluation as appropriate. The local planning authority will seek to promote the conservation of such heritage assets. Where loss of or harm to undesignated heritage assets is considered to be justified in terms of the benefits of a development, the local planning authority will require archaeological recording to be undertaken by a suitably qualified professional prior to the development commencing and the records made publicly available."
Schedule of sites - general comments
Due to the large number of sites and the preliminary nature of the consultation it is not proposed to give detailed comments on every site. The comments below should be seen as an initial screen to identify known archaeological issues, and also to identify those sites where archaeology can be scoped out at an early stage due (e.g.) to large scale opencast coal extraction. Potential for previously unknown archaeological remains has in general not been assessed. Comments on individual sites are grouped under the settlement headings below, and should be read in combination with the following general comments:
Undesignated archaeological remains (known sites)
These sites have been identified by records on the Derbyshire HER and where previous archaeological fieldwork (geophysics and/or evaluation) has taken place.
Identified archaeology may weigh to a greater or lesser extent against the allocation of a site for housing, depending on the significance of the archaeological remains. The following sites fall into this category: CX/1607 (north-west part close to Egstow Hall); ECK/901 (the western part, corresponding to a medieval/post-medieval mill site); GRA/1608 (1) and (2): medieval settlement and cultivation earthworks; GRA/702: post-medieval ridge and furrow; WW/1609 (eastern end): 17th century forge site.
Some archaeological sites previously identified through the planning process have attracted recommendations for archaeological excavation and recording using planning conditions in line with NPPF para 141. The following sites fall into this category: ASH/2001: possible prehistoric remains; ECK/703: Late Iron Age settlement (evaluation); ScD/2103: later prehistoric or Romano-British activity (geophysics); WW/704: probable prehistoric activity (geophysics). Potential developers for these sites should be aware of the likely time and cost implications of substantial archaeological works.
The following sites are identified in the Derbyshire HER as having a built heritage significance which may act as a constraint on housing allocation or subsequent development: CX/1604: former Clay Cross Community School; DRO/603: Grade II Listed Vale House; NW/1605: former infants' school. Conservation of these assets through re-use/conversion should be explored in the first instance, in line with the policies at NPPF chapter 12.
The following sites may have setting impacts to designated heritage assets (Conservation Areas and listed buildings), and this may weigh against allocation of the sites (or parts thereof) for housing development. The local planning authority may wish to seek more detailed conservation advice on these sites: CX/1607 (north-western part): setting of Egstow Hall; DRO/602: Dronfield Conservation Area and setting of Vale House; ECK/702, 702, 2016: setting of Renishaw Park and Hall; all Heath sites: Heath Village Conservation Area and listed buildings within the village; S&H/803: setting of Hallfield Gate Conservation Area; TUP/801 and 1604: setting of Ankerbold House.
Potential for previously unknown archaeological remains
Within the constraints of the current consultation it has not proved possible to undertake the detailed site appraisal necessary to advise on the potential for previously unknown remains on these sites, beyond noting below where individual sites are close to known archaeological remains or lie within or adjacent to historic settlement cores. Detailed site appraisal would include study of aerial photography, historic mapping, geology, topography and regional/sub-regional settlement patterns as evidenced by known sites. It is proposed to undertake this level of appraisal when the number of sites has been whittled down.
Previously unknown remains would not weigh against allocation of a site for housing development. In general, however, large greenfield sites with no opencast extraction have a meaningful potential for previously undiscovered archaeological remains, with particular relation to the prehistoric and Romano-British periods. On coal measures geology (most of North-East Derbyshire), most substantial development sites evaluated through geophysics or trial trenching have produced significant archaeological results - a remarkably high hit rate.
Following detailed appraisal it is therefore likely that large greenfield sites with no history of opencasting will require some level of archaeological evaluation (typically geophysical survey validated by trial trenching as appropriate) to be submitted as part of a planning application. Smaller sites closer to historic settlement cores may also need archaeological assessment through the planning process. Many sites not individually discussed under the settlement headings below will therefore be considered to have archaeological potential and will require archaeological work as part of the planning process. In these cases potential developers are advised to seek pre-application guidance in order to promote positive outcomes for historic environment assets.
Schedule of sites - grouped by settlement
Identified sites are small in size but close to the historic settlement core. Geophysical survey in the context of a larger housing proposal on the ASH/2001 site has identified probable archaeological remains which would need to be evaluated and recorded as part of any development. The remaining sites would need archaeological assessment because they are close to the historic core, but this could be managed through the planning process and would not preclude allocation.
BRAC/1401 is in the medieval core of the settlement and would need archaeological assessment as part of the planning process.
CAL/1602 has undergone significant opencast extraction, so archaeology could be scoped out of the planning process.
CAL/1601 has been considered in the context of previous planning applications and found on balance to have very low archaeological potential.
CX/1607 has undergone substantial opencast extraction, though the northern extent close to Old Tupton may be undisturbed, and runs close to the Ryknield Street Roman road (HER 4213/99016) and the site of Egstow Hall (HER 14402 and 14403) and Grade II Listed and associated medieval village remains. Development right up to this north-western boundary may be inappropriate due to the setting of the listed building, and the local planning authority may wish to consider setting any allocation boundary further back to conserve the setting of this designated asset.
CX/1608 and 1604 include HER 4211, the course of the former Stretton and Ashover Light Railway. CX/1604 has a surviving embankment for this feature on its eastern boundary.
CX/601 is within a former colliery tip, so archaeology could be scoped out of the planning process.
CX/1901 is a former sewage works, so archaeology could be scoped out.
The following sites have undergone substantial opencast extraction, so archaeology could be scoped out: CX/704, 1605, 1606, 1609, 1701, 1801, 2101 and the eastern part of CX/1506.
CX/1604 includes the locally significant buildings of the former Clay Cross Community School, dating from 1854/5 (HER 4235); these should be retained as part of any redevelopment.
CX/703, 1702, 2105 are adjacent to the course of the Ryknield Street Roman road (HER 4213/99016).
DRO/901 is close to the historic core of Coal Aston and would need archaeological assessment through the planning process.
DRO/602 contains the 17th century Vale House (HER 4778 and Grade II Listed); allocation may not be appropriate if housing development is considered harmful to the setting of the Listed Building (or the Dronfield Conservation Area).
DRO/1603 is a former works site considered to have no remaining archaeological potential.
ECK/901 contains HER 4953, the site of a medieval and post-medieval mill. This undesignated heritage asset would weigh against allocation, and would require archaeological desk-based assessment and possibly field evaluation in advance of a planning application for the site.
ECK/703 has a known archaeological site, a Late Iron Age enclosure with ironworking remains. ECK/702 is immediately adjacent and would require some archaeological investigation through the planning process (though I note it is developed for allotment gardens).
ECK/2016 is a very large greenfield site, immediately adjacent to the known Iron Age evidence at ECK/703, and containing HER records for post-medieval collieries and tramways. The western end of the site has however been substantially opencast. The site would need pre-application field evaluation, apart from the opencast area.
These sites south of Eckington may have impacts upon the setting of Renishaw Park, and may therefore be considered inappropriate for allocation, subject to conservation advice.
GRA/1608(1) and (2) contain HER 7208 and 7210, records of earthwork house platforms, banks and ridge and furrow likely to represent archaeological remains of medieval occupation. This undesignated heritage asset would weigh heavily against allocation, and would require archaeological field evaluation in advance of a planning application for the sites.
GRA/1605: the vast majority of this site has been subject to opencast extraction, although it may encroach on the medieval interest at GRA/1608(2) at its north-western boundary.
GRA/702 contains HER 7209, a record of earthwork ridge and furrow; this undesignated heritage asset would weigh against allocation.
GRA/1604 contains part of HER 7213, a record of probable early mining remains visible as parch marks and cropmarks.
GRA/1601, 1901 and 2102 have been substantially opencast and archaeology could be scoped out of the planning process.
Identified sites are all within the Heath Village Conservation Area and housing allocation may therefore be considered inappropriate because of significant harms to this locally designated heritage asset, and to the setting of listed buildings within the village. The area west of the village appears to have been subject to substantial opencast coal extraction and therefore may retain no archaeological potential. The area east/north of the village is close to the medieval core and should be subject to archaeological field evaluation as part of any planning application.
S&H/1801 has been subject to substantial opencast extraction and archaeology may be scoped out of the planning process.
HOLM/2013 is partly within the Cartledge Conservation Area and within the setting of Listed Buildings at Cartledge Hall and Cartledge Grange.
NW/702 and 706 have subject to substantial opencast extraction and archaeology may be scoped out of the planning process.
H&H/1603 has been subject to archaeological evaluation and found to be of very low potential.
KIL/605 and 1701 adjoin the line of the Chesterfield Canal (HER 3998), and any planning application would require an archaeological/heritage assessment of any direct or setting impacts to the canal and associated archaeology.
ScD/1602 has been subject to substantial opencast extraction and archaeology may be scoped out of the planning process.
ScD/2103 has been subject to geophysical survey as part of a recent planning application, revealing late prehistoric and/or Romano-British archaeology including field systems, enclosures and probable settlement areas. It has been accepted that this archaeological interest could be addressed through planning conditions requiring extensive archaeological excavation and recording (NPPF para 141); any potential developer should be aware of the potential resource implications of this in terms of time and costs.
Lower Pilsley and Pilsley
PIL/1602 and 1901 are close to the historic settlement core at Upper Pilsley and should therefore be subject to archaeological assessment through the planning process.
S&H1901 has been subject to substantial opencast extraction and archaeology may be scoped out of the planning process.
NW/1605 includes HER 10811, the Infants' School of 1910, designed by George Henry Widdows (although considered unworthy of listing because of later additions and alterations). This undesignated heritage asset would be a constraint to housing development of the site, and should be considered for re-use/conversion in the first instance.
The following sites have been subject to substantial opencast extraction and archaeology could be scoped out of the planning process: NW/704, 1701
S&H/802 and 1602 have been subject to substantial opencast extraction and archaeology may be scoped out of the planning process.
S&H/1802 has been considered of very low archaeological potential in the context of a previous pre-planning consultation.
S&H/803 may have harmful setting impacts to Hallfield Gate Conservation Area, and may therefore be considered inappropriate for allocation.
TN/1602, 1604, 1605 have been subject to substantial opencast extraction and archaeology may be scoped out of the planning process
TN/701 is in close proximity to the medieval settlement core and should be subject to archaeological field evaluation as part of any planning application.
The following site has been subject to substantial opencast extraction and archaeology may be scoped out of the planning process: TUP/2102
TUP/1604 and TUP/801 are within the immediate setting of the Grade II Listed Ankerbold House (HER 14411) and may therefore be inappropriate for allocation, subject to conservation advice.
TUP/701 contains the course of the Ryknield Street Roman road (HER 14406/99016). The site has also been subject to episodes of opencast coal extraction so should be subject to a desk-based assessment process to establish the extent of opencasting, followed by evaluation of any likely surviving lengths of the Roman road.
The identified sites appear to be of low archaeological potential and WES/1601 and 2101 have been identified as such in previous pre-planning and planning consultations.
WW/702 and 1610(1) and (2) are within the zone of disturbance of the former Avenue Works. Although crossed by the probable line of Ryknield Street previous archaeological observation suggest that the site has experienced massive disturbance and therefore archaeology can be scoped out of the planning process.
WW/1605 has been subject to opencast coal extraction; although the course of Ryknield Street runs through the site no surviving remains were identified during archaeological evaluation.
WW/704: geophysical survey in the context of a recent planning application shows probable prehistoric archaeology within the site. It is accepted that this could be addressed through planning conditions requiring archaeological excavation and recording (NPPF para 141); any potential developer should be aware of the potential resource implications of this in terms of time and costs.
WW/1609 includes part of HER 15310, a 17th century forge site, at its eastern end. It may be appropriate to locate the allocation boundary further back to avoid impacts to the HER site.