Heritage Report

The proposed Solar Park will have a huge impact on our heritage and we therefore engaged with a heritage expert.

The proposed Solar megafarms would be of such size and scale that the impact on landscape and rich historical heritage outweighs its energy benefits, especially taking into consideration the area has many brownfield sites and vast expanses of rooves of the numerous industrial buildings close by that using valuable farmland would be a poor choice in which to site the solar panels.

The open field site selected whist not being a formally designated landscape does nonetheless form part of an attractive undulating river valley landscape that exhibits demonstrable physical attributes that makes it a much-valued landscape to the urban area of Alfreton and surrounding settlements. As virtually the last remaining green lung for the district the open fields, footpaths, bridleways and landscape vistas highlight just how beneficial and essential this amenity is for the Alfreton urban area and surrounding settlements.

This is particularly significant at this moment in time in relation to the need for local people to be able to access such beautiful landscapes during the Covid-19 pandemic without the necessity for getting into a car to travel to areas of corresponding amenity.

Government advice and indeed, law, has been to stay local and access the footpaths, bridleways and landscapes on your own doorstep. Something the imposition of a vast solar megafarm would have a serious negative impact on.

The heritage report prepared on behalf of Kronos is flawed and includes many inaccuracies which serve to underestimate the cultural, visual and historic heritage amenity of the area. The report concedes that due to Covid restrictions the assessment had to be ‘desk based’ only and admits to not being able to use aerial photography in order to give a more considered report.

We instructed JB Heritage Consulting Ltd to review the heritage reports that have been submitted with this application. Below is a summary of their review. To read the full report, search for the planning application AVA/2020/1224 on the Amber Valley website, click on 'Documents', and insert the reference 1092012 in the search field.

Click here to read the Full Report

Methodology

The study area of the HEA (Historic Environment Assessment) comprises land up to 1km radius around the application area. The site itself is over 1km on both its north-south and east-west axis. No justification of the appropriateness of this study area has been provided.

The ZTV (Zone of Theoretical Visibility) provided as part of the LVIA (Landscape and Visual Impact Assessment) is helpful in providing an indication of the visibility of the site within the surrounding area. There are numerous designated heritage assets beyond the 1km boundary from which the site is visible. Wingfield Manor is located to the south west of the site. This is a Grade I listed building placing it within the top 2.5% of nationally significant buildings. It is also a scheduled monument and is looked after by English Heritage. As such it is one of the most significant heritage assets within the country. Castle Hill camp is a scheduled monument occupying a site on higher ground east of Wingfield Manor. The ZTV suggest that the development would be visible from both these highly graded assets, but no assessment has been provided as to any potential impact.

No reference to the ZTV is made and it’s not clear how the visibility of the site from the surrounding areas beyond the 1km boundary has been taken into account. Given the size of the site at over 100ha, the size of the study area is questioned, and Amber Valley Borough Council should be satisfied that it’s sufficient to understand the full nature of the potential historic environment impacts.

Heritage Environment Assessment

The following observations are made below with regards to the impact assessment provided in the HEA.

Amber Hill and Toad Hole Conservation Area

The nature of the setting, appears to be misunderstood, describing the setting of the conservation area to be ‘largely internal, comprising the settlement, the assets within it and their functional and former relationships with each other’. As stated in the glossary of the NPPF (National Planning Policy Framework 2019) the definition of setting is ‘The surroundings in which a heritage asset is experienced.’ Therefore, the setting of the conservation area can only relate to land outside of the asset boundary.

The setting analysis states the ‘topography and mature vegetation (trees and hedges) are not conducive to long views through the settlement’. However, the ZTV suggests that the development would be visible from a significant proportion of the Conservation Area. It’s not clear how this has been taken into account.

In summary, the setting assessment appears to be flawed and makes no reference to the ZTV which demonstrates clear intervisibility. This puts into question the accuracy of the conclusion which identifies no impact.

South Wingfield Conservation Area and Associated Assets

A brief description and significance of the South Wingfield Conservation Area is provided, however the HEA doesn’t set out any assessment of the contribution made by their setting. Consequently, there is no analysis to support the conclusion that proposals would have no impact on the setting of the Conservation Area or the assets within its boundary.

The five-stage approach as outlined in Historic England’s ‘The Setting of Heritage Assets: Historic Environment Good Practice Advice in Planning Note 3 (Section Edition 2017)’ is referenced in the HEA. Step 2 of this stage is to assess the degree to which the setting contributes to the significance of the asset or allows the significance to be appreciated. However, this analysis is not provided in the HEA so it’s not clear how the conclusions have been drawn regarding the potential impact.

Alfreton Conservation Area and Associated Assets

The assessment of the setting of Alfreton Conservation Area appears to make the same error as that identified for Amber Mill and Toad Hole Conservation Area. It makes reference to the setting being ‘largely internal, comprising the street pattern, the assets within it and their functional and former relationships with each other’. The assessment of the views appears to concentrate on views through the asset, rather than how it's experienced in conjunction with and from its surroundings. The strength of the conclusions is therefore questioned.

Alfreton Hall, Alfreton Park and Associated Assets

Both assets are considered together in the HEA with the acknowledgement that Alfreton Park is a ‘fundamental part of Alfreton Hall’s grounds and setting and lies partly within the application area’. Alfreton Park is a large area bounded by the A61 to the east and Wingfield Road to the south. A significant portion of this area is included within the boundary of the application site and would be directly impacted by the proposed development.

An overview of the significance of Alfreton Hall and its setting is provided, identifying that the setting of the Hall includes its grounds and park and the analysis of Alfreton Park makes clear the historic functional and economic relationship that the wider park shared with the Hall.

However, it’s not understood how it has been determined that the proposal wouldn’t have any impact on the significance of the Hall, given the changes that would occur to the landscape of a large proportion of Alfreton Park and the acknowledgement that it is a ‘fundamental part’ of the setting of Alfreton Hall.

The HEA concludes that the proposed solar park could have little effect on the setting of Alfreton Hall but could not affect the elements from which it mainly derives its significance and therefore could have no effect on its significance. The HEA has identified a degree of harm to the significance of Alfreton Park. As a ‘fundamental’ part of the setting of Alfreton Hall, it’s considered that this would have an adverse impact on the listed building.

The construction of a solar park would deeply change the landscape character, eroding setting attributes identified in the HEA that would harm the significance of Alfreton Hall as a designated heritage asset.

The assessment of impact on Alfreton Park doesn’t appear to consider what the change in character to the landscape would have on the ability to appreciate the historic relationship between the park and hall. Furthermore, it doesn’t appear to consider what impact the development on land immediately west of the park would have on its setting.

Other designated heritage assets within the study area

The visibility and effect of the proposal within the wider setting is demonstrated in Viewpoint 11 of the Photomontages and suggest the potential for adverse impact on the Grade II listed The Peacock Hotel.

Also identified are Shirland Lodge Farmhouse and Shirland Park Farmhouse, both listed at Grade II. There is no assessment of the contribution made by the setting to their significance. It’s not clear what consideration has been given to the contribution that the sites make as part of a wider rural setting to the significance of farmhouses and what impact erosion of this character might have. As Shirland Lodge Farm is situated in between the two sides, located approx. 500m to the east and west respectively, it deserves a more comprehensive analysis.

Conclusions

Elements of the assessments are problematic, and, as a result, the soundness of the conclusions and degree to which they offer a full account of the likely historic environment impacts is questioned.

There may be further impacts on designated and non-designated heritage assets not fully identified or reported that would be material to the determination of these applications. In some instances, the full scale of potential impact has not been identified, particularly with regards to the potential for an adverse impact on Alfreton Hall and Alfreton.

In our professional opinion we find that the proposals would most likely give rise to a considerable adverse impact on Alfreton Hall – a grade II listed building protected by the provisions of the Planning (Listed Buildings and Conservation Areas) Act 1990 – due to the erosion of the landscape character of Alfreton Park. We do not agree with the conclusion of the HEA which finds no impact.

Full Report

To read the full report, search for the planning application AVA/2020/1224 on the Amber Valley website, click on 'Documents', and insert the reference 1092012 in the search field.

Read the Full Report