NAA LEEDS LDF SITE ALLOCATIONS PLAN PRE-SUBMISSION CHANGES (FEBRUARY 2017) HERITAGE REPRESENTATIONS Northern Archaeological Associates Ltd. Marwood House Harmire Enterprise Park Barnard Castle Co. Durham DL12 8BN t: 01833 690800 f: 01833 690801 e: hmf@naaheritage.com w: www.naaheritage.com SITE REF: HG2-22 CHURCH STREET, BOSTON SPA prepared for Catholic Care Project No.: 1361 Text: Illustrations: Edited by: Mary Fraser Kate Chapman & Dawn Knowles Andy Crowson NAA 17/42 March 2017
NAA Document Authorisation Project name St Mary s, Boston Spa, Leeds Project number Report title Report No. 17/42 Leeds LDF Site Allocations Plan Pre-Submission Changes (February 2017) Site Ref: HG2-22, Church Street, Boston Spa - Heritage Representations. Revision Date Filename NAA_1361_Rpt_17-142_LDF-SAP-Heritage-Reps.pdf 1 26/03/17 Description Heritage Representations submitted in relation to the Pre-Submission Changes to Site ref: HG2-22, Church Street, Boston Spa. Prepared by Edited by Approved by 1361 Name Mary Fraser Andy Crowson Carol Hill, Catholic Care This document has been approved for release by:..
1.0 INTRODUCTION 1.1 This is a representation on the Leeds City Council LDF Draft Site Allocations Plan (SAP), Outer North East, Pre-Submission Changes published in February 2017. 1.2 This submission relates to Pre-Submission Change No. 441, SAP site reference HG2-22, Church Street, Boston Spa and deals only with heritage representations. It has been prepared by Northern Archaeological Associates Ltd (NAA) and is being submitted, the landowners of the southern field included in this allocation and also owner of the adjacent St Mary s Children s Home (Fig. 1 Area A). Although this submission is confined to heritage considerations on behalf of Catholic Care, our client and its representatives have been liaising with Bradley Stankler Planning in respect of the representations they made which affect the former site allocations HG2-22 1 and HG2-23 2, and are in agreement as to the case for the two sites to be allocated separately (please refer to paragraphs 1.4 and 1.5 below). 1.3 The site lies within the southern part of the Boston Spa Conservation Area, to the south of the High Street and to the east of Church Street. It is an area of former medieval/post-medieval enclosure field system, elements of which are still legible in the landscape. The former St Mary s Children s Home is situated to the west of the site boundary, and is identified as a positive building in the conservation area 3 (Fig. 1). 1.4 Within the first SAP Publication Draft (September 2015), this land had been divided into two separate allocations HG2-23, the southern field owned by NAA s client (Fig. 1 Area A), and HG2-22, the northern field, known as Hollydene Nurseries (Fig. 1 Area B), which is in separate ownership. Both sites were identified as Phase 3 housing allocations. Following representations by Historic England about potential impact that development might have on the character and appearance of the Boston Spa Conservation Area, a heritage impact assessment was undertaken by Leeds City Council Conservation Officer 4. 1 Bradley Stankler Planning (October 2015) Written Submission in response to Leeds LDF Publication Draft Site Allocations Plan Site Ref: HG2-22 Church Street (land to the east of) Boston Spa 2 Bradley Stankler Planning (October 2016) Written Submission in response to Leeds LDF Publication Draft Site Allocations Plan Site Ref: HG2-23 Church Street (St Mary s) Boston Spa 3 Leeds City Council Boston Spa Conservation Area Appraisal and Management Plan (2009) 4 Leeds City Council LDF Site Allocations Plan Revised Publication Draft: Heritage Background Paper Outer North east (September 2016) 1
1.5 As a consequence of this assessment, the SAP Revised Publication Draft Section 3: Outer North East (September 2016) proposed that the two separate site allocations were conjoined and changed to a single allocation, HG2-22. The Pre-Submission Changes to the SAP has reaffirmed these proposed changes and under Pre-Submission Change No. 441 set out the details of the change. 1.6 Following representations from West Yorkshire Archaeology Advisory Service (WYAAS), the Pre-Submission Changes proposes a further amendment to the site requirements for this allocation, and states that an archaeological evaluation of the site needs to be undertaken prior to the development of the site. 1.7 Our client recognises the sensitivity of the site in terms of its heritage value and has commissioned NAA to provide heritage advice with respect to the contribution that the land specifically within their ownership makes to the significance of the conservation area, and also to advise whether the changes proposed in the Pre- Submission Changes documentation are justified. 1.8 In this submission, the south field of the current HG2-22 allocation is referred to either as Area A or as the former site allocation HG2-23On behalf of Catholic Care, this representation summarises the objections or queries to the heritage justifications which underpin the proposal to merge the sites and preserve the southern part of the south field as undeveloped open space. It also sets out the heritage reasons for why our client considers that: 1) Built development can be justified within the southern part of the former site allocation HG2-23, an area of identified higher sensitivity (Plate 2); 2) Combining the two sites is unnecessary in terms of heritage and that there are good heritage reasons why the south field (former site allocation HG2-23) can be developed independently of the north field (former site allocation HG2-22), in a manner that would preserve the character and appearance of the conservation area and be consistent with national policy; and 3) Archaeological evaluation of the site prior to development isn t justified with respect to development within the south field. 2
2.0 SAP CONTEXT 2.1 Figures 1 and 3 of this submission show the location of the various SAP sites referred to below in relation to - each other, the conservation area boundary, listed buildings, positive buildings in the conservation area and other heritage assets. 2.2 Within the SAP Publication Draft (September 2015) the land was divided into two separate allocations: HG2-23 (southern field) and HG2-22 (northern field and former Hollydene Nurseries) (Plate 1). Both were identified as Phase 3 housing allocations and suitable for older persons housing/independent living. The Site Capacity for HG2-22 (1.14 ha) was proposed as 19 units, HG2-23 (0.55 ha) was 17 units. Plate 1: SAP Publication Draft (September 2015) HG2-22 and HG2-23 3
2.3 Representations by Historic England during Public Consultationn (letters dated 21 October 2015) stated that, in order to meet the requirements of the SEA Directive, these two allocations required a more detailed heritage impact assessment due to the potential impact that development might have on the Boston Spa Conservation Area. This assessment was prepared by Leeds City Council Conservation Officers and the results presented in the SAP Heritage Background Paper (September 2016). 2.4 The outcome of this impact assessment was that both areas were considered positive spaces within the conservation area, but that the southern part of HG2-23 (as shown on Plate 2) was considered to be an area of higher sensitivity. Plate 2: Pink shaded area identified as being of higher sensitivity (Heritage Background Paper, p. 10). 2.5 In order to provide more flexibility within the allocation to respond to the heritage issues identified, it was therefore recommended that the allocations HG2-22 and HG2-23 should be combined into a single site allocation. 2.6 With respect specifically to HG2-23 (our client s landholding), the justifications for this merger were that: HG2-23 is a positive space within the conservation area which h marks the entrance or gateway into Boston Spa Conservation Area and the village of Boston Spa and 4
provides an important rural break and clear division between the historic village and the newer development to the south; The sensitivity of the site is increased through its location adjacent to St Mary s Children s Home, a positive building within the Conservation Area; The openness, together with the gardens of St Mary s Children s Home and the open land on the western side of Church Street, provides for a strong sense of arrival into Boston Spa. 2.7 It was concluded that the development of the majority of land at HG2-23 would therefore have a more significant impact on the conservation area, than development of the HG2-22 land, and that the loss of this site as an area of open space, would cause moderate to substantial harm. 2.8 Built development on the southern part of HG2-23 was also not considered appropriate, as it would impede the role this land has as a gateway into the historic village. However, it was considered that it could be utilised to meet the requirement for green space associated with development of HG2-22 and the less visible, less sensitive, land to the east of St Mary s Children s Home. 2.9 By combining the two allocations, and maintaining the area of higher sensitivity within the southern part of HG2-22 as open space, it was considered that this would reduce the level of harm to the conservation area, enable the net developable area of the combined area to be maximised, and so make the most efficient use of these sites overall. 2.10 It was further recommended that the preferred access should be through the adjacent St. Vincent s School (SAP site HG1-39 Phase 1 allocation; Fig. 1), as this would ensure that the role of the southern part of the site as a gateway into the Conservation Area is maintained (Heritage Background Paper, p. 11). 2.11 The Pre-Submission Changes to the SAP has reaffirmed these proposed changes and details of the pre submission change for the amended HG2-22 site allocation (Pre- Submission Change No. 441) state that: Any development should preserve or enhance the character or appearance of the Conservation Area; 5
The openness of the southern part of the site has an important role in contributing to the significance of the Conservation Area, and so no built development should take place on this part of the site; Development should also seek to preserve historic field boundaries, and An archaeological evaluation of the site needs to be undertaken prior to the development of the site. 2.12 While our client is fully supportive of the identification of the area defined as Site HG2-22 for housing, the two former site allocations, HG2-22 and HG2-23, are in separate ownership. It is our client s view that there is no heritage reason why the two sites cannot be developed independently or why some level of development cannot be accommodated within the southern part of the site between Londsdale Meadows and St Mary s, despite its higher heritage sensitivity. 3.0 FORMER SITE REF. HG2-23 23 CONTRIBUTION TO SIGNIFICANCE IFICANCE OF THE BOSTON ON SPA CONSERVATION AREA Significance as gateway into Boston Spa settlement and rural divide 3.1 According to the Heritage Background Paper, the justifications for the merger of the two site allocations and for the requirement that the southern part of the former site allocation HG2-23 should remain as undeveloped open space, is that, whilst both the former sites HG2-22 and HG2-23 are both positive spaces within the conservation area, the perception of HG2-22 is very limited. HG2-23, however, lies adjacent to St Mary s Children s Home, a positive building within the conservation area, and is considered to: Mark the entrance or gateway into the Conservation Area and the village of Boston Spa. In terms of this sense of arrival, this site it particularly important as it provides a rural break between the 1980s suburban ban housing of Lonsdale Meadows and Clifton itself, and the distinctive forms that contribute to the significance of the conservation area (Leeds City Council Heritage Background Paper, 2015, p. 10) 3.2 Whilst the southern field may mark the entrance into Boston Spa Conservation Area, and Boston Spa civil parish, for reasons set out below, we would question whether its 6
significance as a gateway into the historic village of Boston Spa and as an area which provides a sense of arrival due to its importance as a meaningful rural break, is fully justified. 3.3 Boston Spa settlement originated in the mid-18th century and was not established as a separate civil parish until 1896. Prior to this date, from 1866 it had formed part of Clifford-cum-Boston Civil Parish, and prior to 1866, had formed part of Clifford Township, in the large ancient parish of Bramham. The 1896 civil parish boundary between Boston Spa and Clifford follows Primrose Lane, Church Street and Lonsdale Meadows, adjacent to the western and southern boundaries of the south field (Figs. 1 and 6). 3.4 Whilst the site marks the location of a relatively recent administrative gateway into Boston Spa, analysis of historic mapping indicates that it is not an historic gateway and that development had already occurred south of this area by the second half of the 19th century, prior to the establishment of the civil parish boundary. This development is first shown on the 1891 2nd Edition Ordnance Survey plan and comprised St John s Institute, built prior to 1875, and three large detached family villa residences set back from the road in their own grounds Borlocco House (now St Mary s Children s Home) construction date unknown but pre-1891 and Belvedere and Claremont, which are said date from about 1864 (Figs. 2 and 5). 3.5 These buildings form a distinctive contemporary grouping on the outskirts of the village, and whilst very distinctly different in character to the earlier, smaller-scale, vernacular style buildings further to the north along Church Street, and infilling plots to the rear of High Street, they nonetheless form an integral part of Boston Spa s historic development. 3.6 We would contend that, although outside the conservation area boundary and civil parish boundary, St John s Institute, with its imposing end gables and elevations, provides a more meaningful historic gateway marking the arrival at Boston Spa, than the open space to the south of St Mary s Children s Home in the southern part of Site HG2-22. 3.7 It is also clear from historic mapping that, whilst also outside the civil parish boundary, the inter-war development around the junction of Boston Road/St John s Road and along Clifford Road (Figs. 2, 3 and 7), also formed part of Boston Spa 7
settlement envelope in terms of its spatial relationship, rather than Clifford village. This lends further justification to querying whether too much importance is being placed on the significance of the open space as marking the entrance to the historic village. 3.8 Although St John s Institute, Claremont and Belvedere lay outside the Boston Spa Conservation Area and civil parish, they form part of the setting and historic context of the conservation area and provide a more meaningful visual and physical entrance into Boston Spa settlement. We would therefore contend that, despite technically being within Clifford parish, the gateway into Boston Spa is represented by the arrival at the junction between Boston Road and St John s Road, with St John s Institute to the west and inter-war detached houses to the east. We also consider that the open fields to the south of St John s Institute and St John s Road represent a much more meaningful historic rural divide between the Boston Spa village and Clifford village, than the open space of the southern part of SAP Site HG2-22. The significance of historic field boundaries 3.9 The area now occupied by the Boston Spa settlement historically formed part of the Clifford township field systems. As stated within the Heritage Background Paper (p.10), the site formerly identified in 2015 as HG2-22, is an area of space that respects the former medieval strip field system boundaries associated with Clifford Township, prior to the establishment of Boston Spa. 3.10 The significance of the division between the former allocations HG2-22 and HG2-23 is visible on the 1842 Tithe Map for the Township of Clifford-cum-Boston (Tracks in Time, The Leeds Tithe Map Project) and on the 1846 First Edition Ordnance Survey map (Fig. 4). At this date, the former HG2-22 site allocation clearly forms part of the township s former medieval strip field system, whereas the former HG2-23 site allocation, appears to form part of the larger, post-medieval enclosure field system. 3.11 The field boundary between the two former site allocations is therefore of some historic interest, as it appears to mark the transition between these two field systems. The hedgerow which defines this boundary, also meets the important criteria in terms of archaeology and history under Criteria 5a of the Hedgerows Regulations 1997, in that it forms an integral part of a field system recorded on a plan dated pre-1845. Similarly, the eastern hedgerow boundary of HG2-22/HG2-23 and the western hedgerow boundary of the northern field, are also important in terms of archaeology and history under the Regulations. 8
3.12 We would contend that the boundary that runs east from Church Street, demarcating the grounds of St Mary s Children s Home and the divide between the two former site allocations, has some significance as a historic division within the conservation area. It potentially marks the southern limit of the medieval strip field system, and also marks the change in historic building character from the small-scale vernacular style buildings alongside Church Street, and to the rear of High Street, to the group of large, detached, later-19th century buildings on the outskirts of the settlement alongside Church Street and Boston Road. 3.13 Both building forms contribute to the character and appearance of the conservation area and its setting and it will be important to ensure that new development respects the relevant character of the area within which it is located. Significance as an open space 3.14 Together with St Mary s Children s Home and grounds, we support the identification of the south field as a significant green open space within the conservation area. 3.15 The mature trees along the western boundary of both St Mary s Children s Home and the field to the south contribute significantly to the value of the streetscape and to the sense of green space within the conservation area. They are prominent in views north and south along Church Street, and continue the line of mature trees along the western side of Boston Road from St John s Institute to Belvedere villa. There is some limited visibility of the greenfield character and openness of the south field through the boundary along Church Street (Plates 3 and 4). 3.16 The most open views across the former HG2-23 site allocation and into the conservation area are from Lonsdale Meadows (Plates 5 and 6). The significance of this view is that it enables an appreciation of the sense of enclosure of the grounds around the St Mary s building, but at the same time, the sense of its setting within a once rural context on the outskirts of Boston Spa. 9
Plate 3: View along Boston Road from near Belvedere villa, looking north towards Site HG2-22 and St Mary s Children s Home Plate 4: Site HG2-22 - view of western boundary and south-west corner, from Boston Road at the junction between Church Street and Lonsdale Meadows 10
Plate 5: HG2-22 south boundary demonstrating minimal screening between the south field and Lonsdale Meadows Plate 6: Area B view north-west into the site from Lonsdale Meadows showing post and rail fence, open aspect and St Mary s Children s Home visible in background 3.17 We consider that one of the primary roles of the higher sensitivity area of green space is to preserve the essence of the character and setting of the suburban country villas built on the outskirts of Boston Spa and to serve as a meaningful linking space between St Mary s Children s Home (former Borlocco House) and the contemporary group of later 19 th -century buildings on the west side of Boston Road Belvedere, 11
Claremont and St John s Institute, which form part of the setting of the conservation area and St Mary s Children s Home. 3.18 Our client supports the importance of protecting the southern part the former HG2-23 site allocation from inappropriate modern development, and loss of trees. The southern field clearly has a role in maintaining the sense of a rural setting for St Mary s Children s Home, and the villas to the south, and maintaining an open aspect is important in this respect. 3.19 Our client, however, objects to the reasoning that development within this area would cause moderate to substantial harm to the conservation area (Historic Background Paper, p.21). 3.20 Our client considers that with sensitive design and more detailed consideration of site capacity, there is potential for development within the south field which is sympathetic in character to the adjacent 19th century villas, which will retain the sense of openness and green space around these buildings and which would avoid harm to the significance of the conservation area. 4.0 WHY BUILT DEVELOPMENT CAN BE JUSTIFIED WITHIN THE SOUTHERN PART OF THE FORMER SITE ALLOCATION HG2-23 23 4.1 In the landowner s view, the SAP site requirements that no built development should take place within the area of higher sensitivity (Plate 2) cannot be justified on heritage grounds. 4.2 The site is green field open space within the conservation area, which makes a contribution to its character and appearance and to the setting of St Mary s Children s Home, a positive building within the conservation area. 4.3 Whilst a significant open space, the site is embedded within, and surrounded by, development of various dates, and, as discussed previously, there are good reasons to argue that the area does not represent a meaningful rural divide between the historic village and modern development, and does not represent a meaningful point of arrival into Boston Spa. 12
4.4 The site comprises the remains of a post-medieval enclosure field, which was subdivided in the later 19th-century so that its north-western sector could be developed as a large family villa style residence Borlocco House (now St Mary s Children s Home). Immediately outside the boundaries of the conservation area, similar subdivision of enclosure fields for development as large detached villas within areas adjacent to Boston Road, was occurring at around the same time on the west side of Boston Road and then continued during the interwar period with developments along Boston Road and St John s Road, and with further infill post-1950, between Belvedere and Claremont, and on the east side of Boston Road (Fig. 2). 4.5 Our client considers that, in addition to development within the less sensitive area to the east of St Mary s Children s Home, the site could also accommodate development within the western half of the southern area, providing it reflected the style and design of the adjacent, detached villa residence(s). Such development would need to be set back from the road within its own grounds and be on a scale and design similar to the two Victorian villas Belvedere and Claremont to the south on Boston Road. Like these villas, the building could be concealed from view by perimeter planting, which would also contribute to streetscape and preserving the sense of green space characteristic of this area. 4.6 If appropriately designed, this scale and design of development will respect the character and settlement form of this part of the conservation area, and enable open space to be maintained around the dwelling and within the south-east part of the field, thus protecting the setting of St Mary s Children s Home. 5.0 WHY THE SOUTH FIELD SHOULD BE DEVELOPED INDEPENDENTLY OF THE NORTH FIELD 5.1 The two sites are in separate ownership. Our client is the landowner of the south field and considers that there is no heritage reason why the sites should be combined and why development of the two sites should be jointly considered. 5.2 The field boundary between the north and south field potentially marks the southern limit of the medieval strip field system. It also marks the change in historic building character from the small-scale vernacular style back land and infill developments, characteristic of Church Street and the rear High Street, to the much larger, later 19th- 13
century detached suburban country villa-style residences set within their own grounds. 5.3 A presumption of development of the two sites as one may risk obscuring the distinction between these two distinctly different historic character areas, and may result in the loss of an important historic division within the conservation area; preserving historic field boundaries is one of the key site requirements of the Pre- Submission Changes. 5.4 The historic division between the north and south field contributes to the evidential, historic and aesthetic significance of the conservation area. The inclusion of these two fields as separate housing allocations within the SAP would help maintain this historic division and enable a positive bespoke design response to each area. 5.5 As set out above, it is considered that low density, sympathetic development, respecting the historic grain and historic character of the conservation area and its setting, is achievable within the southern part of the site. Given that development within the area to the east of St Mary s Children s Home may also need to be quite different in character to development within the field to the north, our client considers that there are very strong heritage grounds for maintaining separation between the two areas and for the SAP to revert back to including the fields as separate site allocations, but with a revised site capacity for the south field. 5.6 If this area continues to be allocated as a combined site within the SAP, then as set out in the current site requirements, the historic division between the two areas should be maintained through retention of all, or part, of the field boundary. The change in built form between the two areas should also be reflected through differences in the density and layout of new development within the two fields and also through a difference in the character and design of new build. 6.0 ARCHAEOLOGY 6.1 Pre-Submission Change No. 441 HG2-22 states that Areas of potential archaeological sensitivity are also present within the site. An archaeological evaluation of the site needs to be undertaken prior to the development of the site. 14
6.2 WYAAS has confirmed that the archaeological interest lies in the potential for unrecorded prehistoric or Roman remains. Aerial photographic evidence indicates that there are extensive areas of Late Iron Age-Romano-British cropmarks in the Boston Spa area (ditched enclosures, field systems, trackways, etc.). WYAAS is also concerned that unattributable linear cropmarks, identified in the field immediately to the west (Fig. 1 PRN6697), could extend into part of the application area and may be archaeologically sensitive. 6.3 It is WYAAS view that in accordance with the National Planning Policy Framework, the site would warrant pre-determination archaeological evaluation (geophysical survey and trial trenching). 6.4 In view of the small size of the south field (0.55ha), it may be difficult to obtain meaningful geophysical survey results, or a meaningful trial trenching strategy. Given these issues, and the limited archaeological potential of the site, our client considers that the requirement for pre-determination evaluation of this area is unreasonable and requests that this site requirement be amended to provide for the protection of archaeological interests through planning conditions. 15