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SOUTH WEST Mr T Warne Cornwall Council Planning, Transport, Estates County Hall Truro TR1 3AY Dear Mr Warne

re: Proposed wind farm at Davidstow Woods, 16 x 130m to tip Thank you for consulting us over the plans for the above site. English Heritage is the Governments adviser on the historic environment. Central to our role is the advice we give to local planning authorities and government departments on development proposals affecting historic buildings, sites and areas, archaeology on land and underwater, designed landscapes and historic aspects of landscapes as a whole. The designations for which English Heritage has a statutory responsibility are: grade I and II* listed buildings; scheduled monuments; registered parks and gardens; and registered battlefields. English Heritage welcomes the Governments commitment to reduce carbon emissions. We support measures to reduce fuel consumption, increase energy efficiency and exploit renewable energy sources. Nevertheless, we also recognise that some renewable energy project proposals have the potential to cause serious damage to heritage assets which are themselves an integral part of the wider environmental and sustainability agenda. With this in mind English Heritage has drawn up guidelines for planners and developers, Wind Energy and the Historic Environment (October 2005), The Setting of Heritage Assets (2011) and Seeing History in the View (2011). These, our current, guidelines are designed to be used alongside other current standard methodologies associated with the development of such proposals. On the basis of the information about the proposals, received by us on 28/8/13, I offer the following advice. Summary English Heritage has concerns about the cumulative impact of terrestrial wind energy schemes on the historic landscape, particularly where applications are in a rural context and they replace heritage assets as the dominant man-made landscape feature. However, we recognise the vital role terrestrial wind farms play in meeting Government targets for the production of energy from renewable sources, and, as such, English Heritage is minded to support applications which do not directly impinge upon historic assets, but which may have a minor but reversible impact on the wider historic landscape. It is important to ensure applications for wind farm Our ref: Your ref: Telephone: Email: Date: P261630 PA/03743 0117 975 0671 Mon 01271 831386 Tue to Fri 07771 811353 mob nick.russell@english-heritage.org.uk 17th September 2013

development are properly supported by an appropriate assessment (as outlined below) to allow a full consideration of the likely impact upon historic sites and landscapes. Under the NPPF it is a core planning principle to conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations (para.17 NPPF). When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the assets conservation. No other planning concern is given a greater sense of importance in the NPPF. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification (para.132 NPPF). The onus is therefore on you to rigorously test the necessity of any harmful works. NPPF .128, requires 'an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary.' The proposal does not meet the requirements of NPPF and English Heritage object to the current proposals as submitted. We would advise that the application should be refused as a result of impact on the setting of the designated archaeological landscapes (Scheduled Monuments), of the North Bodmin Moor area, in particular the Rough Tor, Garrow Tor and Brown Will occupation sites. English Heritage Advice The application does not differ from previous applications other than a reduction in numbers of turbines from 20 to 16 and a raise in tip height from 126.5m to 130m and we do not intend to comment in detail other than to confirm our previous comments and refer to our previous advice in respect of the impact of the proposals on the high grade, nationally important designated heritage assets of Bodmin Moor (copies attached). With reference to the Cultural Heritage section of the Environmental Statement we would refer to the following extract (original attached). despite initial concerns, i.e. reliance on matrice approach, omission of SMs from 8.4.2, reference to old methodologies agreed in 2010, prior to NPPF and The Setting of Heritage Assets (EH 2011), its setting section isnt bad. I would probably comment that I would have expected more consideration of the significant elements of monuments, in relation to Heritage Values and less reliance on matrix to eliminate sites (see end of para), however, it has been done if only briefly. Generally ok but could do with more detail. Likewise the elimination process is not adequately described (elimination of assets to assess). To summarise the actual settings section, its good but light. I did, however, note that there seemed to be little reference to wider views, even in the initial assessment area with most concern focussed on nearby sites. It wasnt clear how

this related to the ZTV. Fox Tor, for instance is claimed as negligible, while impact is imperceptible (limited distant) visibility from parts of site. At only 8.2km, if there are parts visible then they are unlikely to be imperceptible. i.e., we believe that the significance of the assets as described in The Setting of Hertage Assets (EH 2011), has not been fully understood or discussed and that there is no clear auditable data upon which to confirm the suitability of certain assets from full assessment. Previous advice recommended Visualisation Standards for Wind Energy Developments (Highland Council 2013), should be used for visualisations relating to designated assets and that viewpoints should be considered carefully and, where included should address specific heritage issues identified during assessment. We were unable to identify any dedicated heritage visualisations and were only able to find fig 14 on the planning website, which was based on a 50mm photographic base and not 80mm as recommended by the above guidance. Recommendation The proposal does not meet the requirements of NPPF and should be refused. English Heritage object to the current proposals as submitted. We will ask the Local Planning Authority to ensure that wind farm proposals comply with Local Plan policies and the draft Spatial Strategy for the South-West and to ensure that any planning conditions relating to Scheduled Ancient Monuments and other archaeology are agreed by English Heritage/County Archaeologist as appropriate. The local authority archaeologist for Cornwall should be consulted for their advice on the impact on historic environment in general and direct impacts in particular. Yours sincerely

Nick Russell Assistant Inspector of Ancient Monuments cc. P Coplestone CC

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