Testun llawn:
HG1 KS1 North West Barry (Weycock Cross)
Objection Topic: KS1: Heritage
I object to the inclusion of land at North West Barry (HG1 KS1) within the RLDP on the basis
that the Heritage Assessment commissioned by Persimmon Homes (June 2025) is
inadequate, methodologically unsound, and non-compliant with national policy
requirements. As such, it cannot be relied upon as evidence to justify allocation of this land
for development.
1. Non-Compliance with Planning Policy Wales (PPW) Edi on 12 (2024)
1.1 Failure to Assess Significance of Assets
PPW Edi on 12 requires planning authorities to protect, conserve, and enhance the historic
environment as part of creating “Distinctive and Natural Places”. Heritage assets—
designated or non-designated—must be assessed in terms of their significance and the
impact of proposed development on that significance.
The developer’s assessment fails to meet these requirements. It:
relies almost exclusively on distance and visibility, rather than the holistic
considerations mandated by PPW
does not identify the significance of each potentially affected heritage asset
does not explain how the proposed development would affect that significance
This approach is materially below the standard required for plan-making.
1.2 Absence of Cumulative or Incremental Impact Assessment
PPW requires a long-term, sustainable approach to placemaking, including the prevention of
gradual landscape erosion. The assessment:
ignores previous encroachment on the rural se ng of Barry
fails to consider whether further development contributes to incremental loss of
historic landscape
uses past erosion as justification for further erosion, in stark contradiction to
placemaking principles in PPW
This omission is a significant policy failure.
2. Non-Compliance with Cadw’s “Se ng of Historic Assets in Wales” Guidance
2.1 Failure to Apply the Required Four-Stage Methodology
Cadw requires a structured four-stage methodology:
1. Identify the asset
2. Define and analyse its se ng
3. Assess the impact of change
4. Consider mi ga on
The developer’s assessment does not follow this methodology. There is:
no se ng analysis
no asset-specific impact evaluation
no discussion of mi ga on
no documented methodology
2.2 Incorrect and Narrow Definition of Setting
Cadw defines se ng as the surroundings in which an asset is understood, experienced, and
appreciated. This includes tranquillity, remoteness, historic relationships, topography, and
other experiential qualities—not merely intervisibility.
The assessment is inconsistent with this definition. It:
treats “no intervisibility” as equivalent to “no impact”
disregards experiential qualities such as rural tranquillity and historic context
fails to acknowledge that se ng can be harmed even without direct views
3. Lack of Asset-Specific Evaluation
There are listed buildings within approximately 350–420 metres (e.g., Cwm Ciddy Farm) and
several other designated heritage assets within 1–2 km, including Registered Historic Parks,
Scheduled Monuments, Gardens and Conservation Areas.
However, the assessment:
merely lists these assets without analysing their se ng or sensitivity
provides no evaluation of how suburban expansion may alter their rural historic
context
fails to recognise the role of surrounding fields in forming the historic approach to
Barry and Porthkerry
Cadw requires each asset’s se ng to be analysed individually, supported by evidence. This
has not been undertaken.
4. Unsubstantiated Dismissal of Historic Landscape Value
LANDMAP identifies the area as part of a Historic Landscape Aspect Area of “Moderate”
value, with surviving regular fieldscapes. The assessment dismisses this without evidence,
claiming the field pa ern is “already altered”.
However:
PPW requires recognition of distinctive historic character, whether designated or not
Cadw confirms that se ng impacts apply to all historic assets
The assessment provides no justification for disregarding this historic character.
5. Insufficient Evidence for LDP Allocation
Cadw states that developers must provide “sufficient, but proportionate information” to
allow authorities to assess impacts. The assessment fails this test. It contains:
no photomontages
no se ng diagrams
no significance analysis
conclusions unsupported by evidence
This is inadequate for LDP allocation and fails PPW’s requirement for a robust evidence base.
6. Risk of Partiality
While it is standard practice for developers to commission their own heritage assessments,
PPW and Cadw expect such assessments to be balanced, transparent, and methodologically
sound. Given the clear departures from national guidance, the LPA must exercise caution in
relying on an assessment commissioned by a party with a vested interest in minimising
constraints.
Conclusion
The heritage assessment:
does not comply with PPW Edi on 12
does not comply with Cadw’s Setting of Historic Assets in Wales
does not provide adequate evidence to assess impacts
overlooks cumulative and experiential impacts
fails to evaluate individual assets or their significance
presents conclusions unsupported by analysis
On this basis, the assessment does not meet the tests of soundness and cannot justify
removal of this land from the Green Wedge or its allocation for development within the
RLDP.
