Further to your client's current planning application and our recent discussions concerning this proposal at Bagpath, I write to record our observations.

I am aware that your clients have inspected the files related to the proposal that are held at these offices. I assume, therefore, that they are familiar with the volume and content of the many individual letters of support and objection that I have received during the consultation period. The purpose of this correspondence is to draw your attention to internal consultation responses with which you will be unfamiliar. Officers of the Council have visited the site on more than one occasion and the proposal has been the subject of a site visit by the Architects' Panel, a group of independent architects drawn from the local community. The remainder of this letter addresses each of the main considerations in the determination of this application under appropriate headings. It also refers to various procedural matters.

Design and detailing

Officers consider that this is a well presented and researched proposal. We see that the proposal is based on early eighteenth century square form buildings of around 1700 -1715 in date, on the cusp of Palladianism. The rise of the Burlingtonian School (1720s) and the emergence of Palladian classicism promoted the strict adherence to harmonic proportion and mathematic progression through the internal spaces and we see that these influences are reflected in the proposal. The proposed buildings are faced in natural materials indigenous to the Cotswolds and the use of ashlar as a facing material for the main block denotes the building as being of high status and facilitates the use of fine crisp detailing.

We find the design is at first glance a pleasing, yet unchallenging Queen Anne/George I country house. The central block is a cube with typical hipped roof and top lit stair. The elevations are more horizontal in emphasis than many earlier Carolean prototypes and lack the decorative excesses of the English Baroque. The submission is intelligent in its subtle use of Palladian proportion and Mannerist detailing. This is a combination that is not generally encountered in Historicist schemes. The proposal employs a sensitive blend of the Cotswold vernacular, palladianism and Mannerism. The apparent simplicity of the scheme is overlain by a sophistication not encountered in smaller period country houses which may generally be termed "country cousin classicism". The proposal may be seen as an informed development of this tradition.

The confident handling of the internal spaces and fine detailing is an outstanding example of classicism in a building which is a modern house. The house lacks the extensive service accommodation which typified country houses in the past. Instead, the proposal displays an efficient internal plan which successfully achieves an interior with principal rooms of sufficient architectural presence to distance the building from other contemporary houses. The proposal achieves a marriage between the contemporary and larger classically derived period country houses. We feel the building displays a consistently high design quality both internally and externally. This also differentiates the proposal from the majority of historicist schemes. It is difficult to identify any current proposal as outstanding without the benefit of several years, to place the proposal in context, but in terms of its own genre it is possible to state that we consider the proposal to be an outstanding example of its type.

In our view, it is acceptable within the terms of paragraph 3.21 of PPG7 to use a traditional (vernacular or classical) as opposed to a modem or contemporary approach. The key test must be whether the proposal is outstanding. PPG7 is not prescriptive regarding architectural style. In this sensitive landscape of the Cotswolds Area of Outstanding Natural Beauty an historicist scheme is less likely to appear as an intrusion into the landscape than a strictly modern proposal, but this issue is discussed separately below.

The central block is elegantly articulated with the attached service wings which flank the rear courtyard. The proposed courtyard fountain set into the rear retaining wall is well handled and would add to the immediate setting of the house in our opinion.

Notwithstanding these comments, we have some criticisms of the design and detailing of the proposal. The driveway approach to the house is uninspired and lacks the tension associated with the "sublime" serpentine line and the Palladian cube. The rather direct approach to the house fails to exploit the best views of the house via a traditionally sinuous carriageway. It is unfortunate that the principal elevation is not seen on the approach. The proposed lodge is also well designed but in an illogical location. They are intended to announce and defend the gateway to a substantial property. It would be better sited at the access from the public highway or even preferable to omit it entirely.

Impact on the setting of a listed building

Some objectors have indicated that they believe the proposal would affect the setting of Boxwell Court, a Grade II* listed building on the opposite side of Ozleworth Bottom. We intend to advertise the proposal as affecting the setting of this building. Key details related to the development were sent to English Heritage on 22nd July 2002 but no response has been received to date.

Landscape impact

Officers have considered the effect of the appearance of the proposals on the character and appearance of the Cotswolds Area of Outstanding Natural Beauty (a landscape of national importance) and the landscape merits of the proposals in the context of paragraph 3.21 of PPG7.

The site lies within the "Incised Landscape" Character Area as described in the Countryside Commission's landscape assessment of the Cotswolds AONB (1990). The landscape character of the site coincides with the general description contained therein.

The site and its setting can be clearly viewed from the Monarch's Way footpath to the south of the site across the Ozleworth Valley. What is most striking in this panoramic view is the virtual absence of discernible dwellings. Glimpsed views are available of Lasborough, Boxwell Court and Ozleworth but Newark Park is not obvious, despite being at the highest elevation of all of these. It is clear to us that the characteristic location of these country houses is discrete, tucked into the landscape. Associated landscaping is informal, underplayed but quite extensive.

In contrast, the site proposed for the development is exposed to view. Its location is described as "a commanding position" in paragraph 4.4 of the landscape assessment with the application and officers agree with that description.

We consider that a property of the size and design proposed would be intrusive in the view and would dominate its setting in a quite uncharacteristic way compared to other nearby country houses. The landscaping proposed to mitigate this view consists of a number of trees scattered on the slope below the house.

In our opinion, the siting, scale and massing of the house and its ancillary accommodation (including the Lodge) would be free standing, dominant, permanent additions adversely intrusive to both their immediate setting and the intrinsically important wider landscape attributes of the locality.

Unless, therefore, the proposal meets the criteria of paragraph 3.21 of PPG7 it should not be permitted because of its underlying material harm to the character and appearance of the Cotswolds Area of Outstanding Natural Beauty.

In applying the criteria of paragraph 3.21 we have the following comments:

is the proposal of the highest quality? The landscape proposals have been based upon landscape assessment and historical research in accordance with best practice. We believe that the presentation of the landscape proposals is exemplary;

is the landscape design "outstanding"? Given the existing outstanding landscape quality of the site and its surroundings, a very low key approach has been taken to the design landscape. This has taken the form of introducing groves, clumps and individual trees to recreate the parkland indicated to have existed on the site from about 1865 to 1934, albeit in an earlier Reptonian style. The higher plateau area to the north of the house is generally left clear. These woods will be managed and replanted as necessary. The drystone walls will be repaired. The route of the drive has been designed to provide a "surprise" view of the house. It is clear that the whole landscape design has been handled most skilfully. However, the location and orientation.of the house itself(as I have said above) appears strange. From the front rooms, as far as one can tell, views to the south would be dominated by the high trees of Mill Wood, above which are the bleak downs above Boxwell. The proposal does not command views either up or down the valley, which would be expected with this style of property. Also, only limited use seems to have been made of the topography of the site to open these longer views by tree removal. All ground modelling is proposed to create new vistas or features. An oval wailed garden is discretely located some distance from the house. As stated above, we feel the lodge is rather incongruously located some distance from the entrance gates and appears to have no private garden for domestic use.
Thus, although the landscape design is appropriate for the overall design philosophy of the development itself, we are not convinced that there has been enough confidence to produce a scheme which provides a siting and orientation of the house which makes best use of its setting, or that is of such impact as to be literally and figuratively "outstanding" in the context of the landscape it is placed within;

does the proposal significantly enhance its immediate setting? I have described the subtle and low key approach to landscape design that has been proposed. It is difficult for us to see how the relatively simple landscaping proposed, essentially planting a number of clumps, groves and individual parkland trees, in a site which essentially still has a parkland character "significantly enhances" the immediate setting. The proposed repairs to walls, woodland management and reversion of arable land to pasture are all encouraged to grant aid under the Environmentally Sensitive Areas scheme and are therefore not dependant on this application for implementation; and

will the proposals "significantly enhance the wider surroundings? As noted above, apart from Newark Park, country houses in the Ozleworth Valley do not "occupy a commanding position" as is proposed here, but at discretely located so as not to dominate the landscape or their neighbours. It is our opinion that the development of a large house together with its lodge will, because of this visual dominance sought by your clients, be harmful to the wider landscape. We believe that the point about this proposal completing a "ribbon" of parkland along the valley is overplayed. By your own admission the site retains a parkland feel and in views from the Monarch's Way one is not aware of any abrupt changes in landscape character and appearance between Ozleworth and Boxwell Court of such magnitude that this proposal will "repair" the damage caused by the site declining from use as designed parkland.

We do not consider, therefore, that the proposal meets satisfactorily all the tests outlined in paragraph 3.21 of PPG7 and we are not able to support it on these grounds alone. For your information, I have attached a copy of the Architects' Panel comments made on 27th June and 19th July, 2002. You will see their recommendations on the second page, which appear to me to reflect the views of internal consultees.

Highways and access

You are aware that the County Highways Officer objects to the proposal on two grounds. The first of these is related to the remoteness of the development from amenities and the second refers to the sub-standard and unsuitable nature of the roads that serve the site. I understand that you have met Mr Power at the site and he maintains this position but I would be pleased to receive your considered views on his comments.

Archaeology

You are aware that the County Archaeology Officer has recommended that a field evaluation be carried out prior to determination and I understand that this has been done. I look forward to seeing the results.

Conservation

I have not yet received any formal comments from English Nature or the Gloucestershire Wildlife Trust but I understand that the former raise no objections to the proposal. I note the copy of the letter from Dr. Studholme at Annex E of the Supporting Statement.

Foul and surface water disposal

I am not yet in receipt of any comments from the Environment Agency or the Severn Trent Water Authority. You will have seen the comments of our own Engineer who recommends that the observations of the Environment Agency should be received prior to determination.

Right of Way

I am aware that an application has been made to Gloucestershire County Council for the adoption of a path across the site as a public fight of way. I will have ongoing discussions with them about this matter but I do not propose to delay consideration of the proposal pending the outcome.

Other Matters

There are a few procedural points that I would like to record, as discussed at out meeting on 2nd August 2002.

The proposal was presented to the Planning (Regulatory) Committee on 24th July 2002 with a recommendation that Members visit the site prior to making a decision. They did not debate the proposal but resolved to make an advanced site inspection on 18th September 2002. All Members of the Committee together with the three substitutes were invited to attend. I understand that you will despatch 20 copies of the planning supporting statement to them (excluding the Ward Member, who has already received a full set of the accompanying information). You have been supplied with names and addresses. I have also asked you to produce a photomontage of the proposal when viewed from the Monarch's Way and erect some sort of framework for the Members when they visit the site. It is my intention to present a full report to the Committee on 16th October 2002, when I hope they will determine the application.

Some objectors have referred to the question of departure from the Development Plan. As we discussed, the proposal is not in conformity with policies within the Cotswold District Local Plan and the Gloucestershire Structure Plan Second Review which seek to limit residential development in isolated locations to those essential to the needs of agriculture or forestry. With this in mind, if Members are minded to permit the proposal, it will first have to be advertised as a departure. Any comments arising therefrom will have to be taken into account.

On a related issue, I am aware that the Government Office for the South West has been invited to call-in the application for their own determination but, as yet, I have received no formal communication from them. If I am so advised I will make sure you are made aware of this.

Finally, I note the Deed of Undertaking at Annex F of the Supporting Statement. I hope to be able to get you some feedback on this prior to determination.

I appreciate that you will want to spend time considering these views and I hope that you will be able to provide a full response by early in September. I will not be available now until 3rd September but please feel free to discuss the relevant component parts of this letter with the relevant officers in the intervening period (subject to annual leave). I look forward to your response.


Yours sincerely

M A Kitchen

Principal Planner (South)

c.c. Simon Cairns, CDC

Malcolm Watt, CDC

Mark Power, GCC

Nick Hayward, Chapman Warren, Fairwater House, Wroughton, Swindon, Wilts.

Cllr Mrs. C Nicolle, Didmarton

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