Ruperra Conservation Trust's Objections to the Planning Application
Application Ref: P/02/0773
Proposed Development at Ruperra Castle, Rudry
The Trust objects to this application for the following reasons:
Summary of contents
i) The principle of residential conversion of Ruperra Castle has not been justified as no alternatives to secure the future of the Castle have been considered,
ii) The residential development around the Castle can only be justified if the residential conversion of the Castle is considered necessary,
iii) Even if a residential scheme is considered necessary and appropriate, the scheme as proposed is damaging and undesirable in historic building and environmental terms.
The Principle of Residential Conversion & Residential Enabling Development
The Trust remains strongly of the view that this site should be preserved, and the historic buildings it contains conserved, for the benefit of the public. This option has not been considered by the developer. No information (such as a financial viability study) has been submitted to demonstrate that the residential scheme proposed is the only feasible option available to secure the future of the Castle. There may be other options involving far less intervention, such as stabilising the structure of the Castle and leaving it as a romantic ruin for the public to enjoy.
The developer has only submitted a marketing appraisal and financial appraisal to demonstrate that the residential scheme proposed is viable. It is noted that the viability of the scheme appears to rely in part on grant funding. It is entirely unclear where such grant funding would come from or what conditions will be attached to any grant. If the grant is not forthcoming the development may not be able to proceed. It is worth noting that most grant giving bodies do not offer funding to profit making companies. Further, a grant of £1,000,000, as sought by the developer, could be enough to stabilise the Castle structure without the need for any residential development on the site.
Justification of the Residential Development.
The Conservation Statement submitted in support of the scheme is entirely inadequate. Although it deals with the issue of conservation of historic fabric it fails to deal with:
i) why the principle of an enabling development is appropriate in the case of Ruperra Castle,
ii) why this particular form of enabling development is appropriate (i.e. residential conversion and residential development within the historic garden setting, and,
iii) how the impact of the proposed development minimises the detrimental impact on the setting of the castle and the historic garden.
Until it can be adequately demonstrated that a residential enabling development is the only option available to secure the long term future of the Castle, planning permission should be refused because of the detrimental visual and environmental impact of the development.
Respect for the Natural and Historic Environment.
The Trust would strongly argue that if the principle of residential enabling development around the perimeter of the Castle is accepted, the scheme needs to be fundamentally reconsidered to ensure that the form of the development pays respect to the historic landscape. A starting point would be for the developer to commission a landscape management plan which would include a survey of the landscape assets. This would enable the soft areas where development would be least detrimental to be identified.
The current proposed layout still locates car parking and access roads adjacent to the Castle. A significant amount of open space around the Castle should be preserved. If the site access was reorientated to the perimeter of the site parking areas, associated services could be located further from the Castle, thereby ensuring the parkland setting of the Castle would be better preserved. Further, the scheme remains unclear regarding which trees on the site are to be preserved and indeed whether these are the most important.
The Trust is of the opinion that a scheme involving far less intervention to the historic fabric and far less detrimental enabling development in the setting of the historic castle could be developed. However, the developer has made no attempt to explore such an option. Until it can be demonstrated that such an option is unfeasible it is our view that it would be inappropriate to grant planning permission for this scheme.
Prematurity
It is understood that no formal application for scheduled monument consent has been submitted to Cadw to date. Without this consent any development cannot go ahead. However, the issues which need to be considered for both the planning permission and the scheduled monument consent are mutually dependent. The Trust strongly argues that until the scheduled monument consent has been submitted and properly considered (including seeking the views of all the relevant statutory consultees) it would be premature to positively determine the planning application. Of particular importance to considering the planning application must be the view of Cadw (on behalf of the Assembly). If Cadw is of the view that scheduled monument consent would be unlikely to be granted (as it indicated when the scheme was originally submitted in 2002 - letter dated October 2002) then it would seem entirely inappropriate for Caerphilly to proceed to grant planning permission.
Other Information Still Required
i) Given that the basis of this application is (presumably) to secure the future of the Castle (rather than just turn a profit for the developer) the Trust argues that further information needs to be submitted by the developer to demonstrate how this will be achieved.
ii) The Trust has always argued that any development of this important site should secure public access to the Castle and historic gardens. The location of the site next to land owned by the Trust, where there is full public access already, makes such an arrangement not only desirable but highly practical. No information has been provided by the developer as to what public access will be provided (if any).
iii) What mechanism is proposed to ensure that the developer provides all the benefits of the scheme prior to disposing of the valuable residential units?
iv) Also of concern is the future of the site after development takes place. What provisions are to be made for future upkeep of the buildings and landscaping not forming part of the residential units? There is a real risk that unless funding for their upkeep is secured at this stage their future will be uncertain. Assuming public access is proposed for part of the site it would seem unrealistic to expect future residents to entirely fund upkeep of the whole estate.
v) Finally, the Trust finds it surprising that no Environmental Impact Assessment is considered necessary in this instance, given the sensitivity of the location in both historic and ecology terms.
Conclusion
It is the view of the Trust that the revised proposals do not overcome the in principle objections set out in our letter dated June 2002 (copy attached). We do not therefore seek to set out again Council policies to which the development appears to be contrary. The revisions and new information submitted in support of the application do address some of the issues raised in the Trust's letter (e.g. the provision of a bat roost, deletion of the lodge, retention of the glasshouses). However, the fundamental issue of the principle of residential development of this important historic site remains unresolved. Finally, given the significance of the issues raised by the application the Trust considers that there are strong arguments for referral of the application to the Assembly for determination, in line with paragraph 4.12.2 of Planning Policy Wales.
The Trust again asks that the application be refused on the grounds of the detrimental impact of the proposal on the Castle and associated historic buildings and landscape. Given the considerable period of time the applicant has been allowed to develop his scheme since the original submission in 2002 the Trust asks that a decision be made now to refuse the scheme. The applicant should not now be allowed any further time to amend or justify this scheme.
Proposed Development at Ruperra Castle, Rudry
The Trust objects to this application for the following reasons:
Summary of contents
i) The principle of residential conversion of Ruperra Castle has not been justified as no alternatives to secure the future of the Castle have been considered,
ii) The residential development around the Castle can only be justified if the residential conversion of the Castle is considered necessary,
iii) Even if a residential scheme is considered necessary and appropriate, the scheme as proposed is damaging and undesirable in historic building and environmental terms.
The Principle of Residential Conversion & Residential Enabling Development
The Trust remains strongly of the view that this site should be preserved, and the historic buildings it contains conserved, for the benefit of the public. This option has not been considered by the developer. No information (such as a financial viability study) has been submitted to demonstrate that the residential scheme proposed is the only feasible option available to secure the future of the Castle. There may be other options involving far less intervention, such as stabilising the structure of the Castle and leaving it as a romantic ruin for the public to enjoy.
The developer has only submitted a marketing appraisal and financial appraisal to demonstrate that the residential scheme proposed is viable. It is noted that the viability of the scheme appears to rely in part on grant funding. It is entirely unclear where such grant funding would come from or what conditions will be attached to any grant. If the grant is not forthcoming the development may not be able to proceed. It is worth noting that most grant giving bodies do not offer funding to profit making companies. Further, a grant of £1,000,000, as sought by the developer, could be enough to stabilise the Castle structure without the need for any residential development on the site.
Justification of the Residential Development.
The Conservation Statement submitted in support of the scheme is entirely inadequate. Although it deals with the issue of conservation of historic fabric it fails to deal with:
i) why the principle of an enabling development is appropriate in the case of Ruperra Castle,
ii) why this particular form of enabling development is appropriate (i.e. residential conversion and residential development within the historic garden setting, and,
iii) how the impact of the proposed development minimises the detrimental impact on the setting of the castle and the historic garden.
Until it can be adequately demonstrated that a residential enabling development is the only option available to secure the long term future of the Castle, planning permission should be refused because of the detrimental visual and environmental impact of the development.
Respect for the Natural and Historic Environment.
The Trust would strongly argue that if the principle of residential enabling development around the perimeter of the Castle is accepted, the scheme needs to be fundamentally reconsidered to ensure that the form of the development pays respect to the historic landscape. A starting point would be for the developer to commission a landscape management plan which would include a survey of the landscape assets. This would enable the soft areas where development would be least detrimental to be identified.
The current proposed layout still locates car parking and access roads adjacent to the Castle. A significant amount of open space around the Castle should be preserved. If the site access was reorientated to the perimeter of the site parking areas, associated services could be located further from the Castle, thereby ensuring the parkland setting of the Castle would be better preserved. Further, the scheme remains unclear regarding which trees on the site are to be preserved and indeed whether these are the most important.
The Trust is of the opinion that a scheme involving far less intervention to the historic fabric and far less detrimental enabling development in the setting of the historic castle could be developed. However, the developer has made no attempt to explore such an option. Until it can be demonstrated that such an option is unfeasible it is our view that it would be inappropriate to grant planning permission for this scheme.
Prematurity
It is understood that no formal application for scheduled monument consent has been submitted to Cadw to date. Without this consent any development cannot go ahead. However, the issues which need to be considered for both the planning permission and the scheduled monument consent are mutually dependent. The Trust strongly argues that until the scheduled monument consent has been submitted and properly considered (including seeking the views of all the relevant statutory consultees) it would be premature to positively determine the planning application. Of particular importance to considering the planning application must be the view of Cadw (on behalf of the Assembly). If Cadw is of the view that scheduled monument consent would be unlikely to be granted (as it indicated when the scheme was originally submitted in 2002 - letter dated October 2002) then it would seem entirely inappropriate for Caerphilly to proceed to grant planning permission.
Other Information Still Required
i) Given that the basis of this application is (presumably) to secure the future of the Castle (rather than just turn a profit for the developer) the Trust argues that further information needs to be submitted by the developer to demonstrate how this will be achieved.
ii) The Trust has always argued that any development of this important site should secure public access to the Castle and historic gardens. The location of the site next to land owned by the Trust, where there is full public access already, makes such an arrangement not only desirable but highly practical. No information has been provided by the developer as to what public access will be provided (if any).
iii) What mechanism is proposed to ensure that the developer provides all the benefits of the scheme prior to disposing of the valuable residential units?
iv) Also of concern is the future of the site after development takes place. What provisions are to be made for future upkeep of the buildings and landscaping not forming part of the residential units? There is a real risk that unless funding for their upkeep is secured at this stage their future will be uncertain. Assuming public access is proposed for part of the site it would seem unrealistic to expect future residents to entirely fund upkeep of the whole estate.
v) Finally, the Trust finds it surprising that no Environmental Impact Assessment is considered necessary in this instance, given the sensitivity of the location in both historic and ecology terms.
Conclusion
It is the view of the Trust that the revised proposals do not overcome the in principle objections set out in our letter dated June 2002 (copy attached). We do not therefore seek to set out again Council policies to which the development appears to be contrary. The revisions and new information submitted in support of the application do address some of the issues raised in the Trust's letter (e.g. the provision of a bat roost, deletion of the lodge, retention of the glasshouses). However, the fundamental issue of the principle of residential development of this important historic site remains unresolved. Finally, given the significance of the issues raised by the application the Trust considers that there are strong arguments for referral of the application to the Assembly for determination, in line with paragraph 4.12.2 of Planning Policy Wales.
The Trust again asks that the application be refused on the grounds of the detrimental impact of the proposal on the Castle and associated historic buildings and landscape. Given the considerable period of time the applicant has been allowed to develop his scheme since the original submission in 2002 the Trust asks that a decision be made now to refuse the scheme. The applicant should not now be allowed any further time to amend or justify this scheme.
posted by Save Ruperra Castle | 12:26 PM
<< Home