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M4 Corridor around Newport
PUBLIC INQUIRY DOCUMENT
REFERENCE NO. : ID/166a revised
RAISED BY: Matthew Jones DATE: 13/12/17
RESPONDED BY: DATE:
SUBJECT: Proposed Demolition of Woodland House
Please find attached an update on the current Welsh Government position, including recent correspondence with Monmouthshire County Council on 13th December 2017. This document has been issued to Monmouthshire County Council, Natural Resources Wales (NRW), Cllr Frances Taylor, Mr Mike Smith, Mr Lawrence Lowe and Mrs Ann Picton. UPDATE: Now also includes Monmouthshire County Council’s response to this
Welsh Government Update.
Proposed Demolition of Woodland House – Welsh Government Update
Position ‐ 13 December 2017
Background
An Inquiry into the called‐in application for Listed Building Consent was held by the Planning
Inspectorate on 20 June 2017 (Ref. APP/E6840/V/17/3166811).
Four Proofs of Evidence were submitted by the Welsh Government, including:
1. Matthew Jones (Chief Witness);
2. John Davies (Planning and Sustainable Development);
3. Mick Rawlings (Cultural Heritage); and
4. Richard Green (Bats).
At the Inquiry, the Welsh Government explained that given its location and the physical constraints
of a suitable highway route around Magor, demolition of Woodland House is required and justified
to facilitate the M4 Corridor around Newport Scheme, in accordance with its proposed alignment.
Update
During the hearing of this case the Welsh Government committed to continue investigating the
potential for re‐location of Woodland House but did not consider that listed building consent should
be conditional on re‐location since the grant of planning permission for re‐erection would be outside
the control of the Welsh Government and the feasibility of re‐location required further investigation.
To proceed with re‐location, Welsh Government would need to justify any deficit of costs to be a
justifiable use of public funds. Contractor quotes for relocation have been obtained and discussions
are ongoing with Monmouthshire County Council on the scope of the existing buildings to be re‐
located, plus availability and land transfer options for an identified potential relocation site.
Whilst both Welsh Government and Monmouthshire County Council remain actively pursuing re‐
location of the property, Welsh Government is unable to guarantee that it will be re‐located and
suggest to the inspector that the Inquiry into its demolition be closed on this basis rather than await
any further progress.
The Welsh Government remains of the view that listed building consent should not be conditional
on re‐location since the grant of planning permission for re‐erection would be outside the control of
the Welsh Government and the feasibility of re‐location requires further investigation. That is also a
view now shared by Monmouthshire County Council, as reflected in the additional information on
commitments and conditions provided in the Statement of Common Ground submitted after the
inquiry (ID102). ID102 also deals with matters raised by Natural Resources Wales, provides further
information on mitigation opportunities for bats and sets out the commitments to meet their
concerns. ID102 is enclosed at Annex A.
Working collaboratively with Monmouthshire County Council officials, a possible Council‐owned site
at Knollbury has been identified as having the potential for the proposed relocation of Woodland
House. The location was included as a plan in Public Inquiry Document ID 102.
The Welsh Government purchased Woodland House in Magor at a cost of £1.1m in 2007. That cost
has been recorded as a Scheme cost because the property would have to be demolished should the
scheme proceed. The current Scheme budget did not include for the costs of relocating Woodland
House. To ascertain the potential estimated resale value of locating Woodland House at the
Knollbury location, the WG instructed the District Valuer (DV). The DV has advised WG of a resale
value of £800,000. The estimated costs of relocating Woodland House to the Knollbury location not
including land are £1,107,000. Current estimates from the District Valuer indicate there would be a
loss of approximately £307,000 to relocate the Grade 2 listed Woodland House, which is not
considered to be a good use of public money.
As such, Martin Bates (Welsh Government) wrote to Mark Hand on 5 December 2017 to ask what
assistance if any the Council can give to contributing to assisting with reducing the costs of
relocation. A copy is provided at Annex B.
If costs could be saved so to not incur a significant loss, the Welsh Ministers may then decide to
progress with relocation plans. The Welsh Government will continue to engage with Monmouthshire
County Council to determine whether that is feasible or not.
However, if the loss of Woodland House cannot be avoided through relocation, then whilst
Woodland House is a good example of a mid‐19th century purpose‐built vicarage in a
Tudor/Jacobean Revival style, it is not considered to be of a level of significance that would justify
the expense of rebuilding at a new location out of public funds and/or its loss is justified by the
benefits of the scheme.
As explained in the Proofs of Evidence submitted by the Welsh Government, should the draft Orders
be confirmed and the Scheme go ahead, the Welsh Government would liaise with the Royal
Commission on the Ancient and Historical Monuments of Wales (RCAHMW) and would ensure that a
detailed record of the buildings is made prior to demolition. In addition, it would liaise with the
Brooking National Collection to offer the fixtures and fittings from Woodland House and its curtilage
listed structures (as per the Register of Environmental Commitments (Appendix SR18.1 of the
December 2016 ES Supplement, Ref. No. 111).
Annex A: ID102
M4 Corridor around Newport
PUBLIC INQUIRY DOCUMENT
REFERENCE NO. : ID102
RAISED BY: PINS DATE: 24/05/17
RESPONDED BY: Allan Pitt DATE: 07/08/17
SUBJECT: Response to request for information RE: 3166811 - Woodland House, Newport Road, Magor.
Please find attached:
A signed Statement of Common Ground between Monmouthshire County Council and Welsh Government
A note on additional environmental commitments
A plan of the possible re-location site at Knollbury
A document showing the possible mitigation opportunities for Bats (which was requested in NRW’s letter of 19 June 2017)
This document has been issued to Monmouthshire County Council, Natural Resources Wales (NRW), Cllr Frances Taylor, Mr Mike Smith, Mr Lawrence Lowe and Mrs Ann Picton
Statement of Common Ground
1 May 2017
STATEMENT OF COMMON GROUND
INSPECTORATE REFERENCE APP/E6840/V/17/3166811 PLANNING REFERENCE DC/2016/01033
DATE OF INQUIRY 20th June 2017 at 10.00
The Lysaght Institute, Orb Drive, Corporation Rd, Newport, NP19 0RA
SITE ADDRESS AND DESCRIPTION OF THE DEVELOPMENT
Woodland House, Magor Vicarage and Curtilage Buildings at Newport Road, Magor, Monmouthshire, NP26 3BZ
Demolition of Woodland House (Grade II Listed Building) to accommodate
the alignment of the M4 Corridor around Newport.
APPLICANT Welsh Government
LOCAL PLANNING AUTHORITY Monmouthshire County Council
This statement addresses the following areas of common ground: 1. The site is Woodland House, also known locally as Magor Vicarage and
is a Grade II Listed Building. Included on the list in 31/05/1995 ref 16068.
2. The application is for total demolition of the building and the structures within the curtilage.
3. The justification for the proposed demolition relates only to the purposed alignment of the M4 Corridor around Newport. Therefore, listed building consent for demolition should only be granted if the M4 Corridor around Newport Scheme is approved and demolition should only be implemented if the M4 scheme proceeds to construction.
2 May 2017
4. The application is assessed under the requirements of the Planning (Listed Buildings and Conservation Areas) Act 1990, Welsh Office Circular 61/96 and Planning Policy Wales (PPW) Chapter 6. In respect of protected species, PPW Chapter 5 and Technical Advice Note 5 and the duties under the Natural Environment and Rural Communities Act 2006 and the Environment (Wales) Act 2016 have been taken into account.
5. There is no objection from Monmouthshire County Council regarding ecological surveys in relation to Bats, following additional information being agreed between Natural Resources Wales and the Welsh Government.
6. Monmouthshire County Council is working with the Welsh Government in actively investigating the re-erection of Woodland House on another site following demolition, although a site has yet to be identified and the feasibility of re-erection remains unproven.
7. Notwithstanding Monmouthshire County Council’s suggested planning conditions as presented in its Statement of Case, the following planning conditions would be appropriate only:
i. The works to which this consent relates must be commenced
no later than the expiration of 5 years beginning with the date on which this consent is granted. REASON: To comply with the requirements of Section 18 of the Planning (Listed Buildings and Conservation Areas) Act 1990.
ii. No works to which this consent relates shall commence until an appropriate programme of historic building recording and analysis has been secured and implemented in accordance with a written scheme of investigation which has been submitted to and approved in writing by the local planning authority. REASON: To ensure that adequate records are made of the building prior to its demolition.
iii. The listed building subject of this application shall not be demolished until the Schemes and Orders under the Highways Acts necessary for the construction of the proposed Scheme have been confirmed and a contract for the carrying out of works to the M4 scheme has been made. REASON- The only justification for the demolition of this Listed Building would be the overriding regional and national importance of the M4 relief road. Should that road scheme not be approved or not proceed, demolition of the Listed Building would be unjustified and unacceptable.
3 May 2017
iv. The works of demolition shall not be carried out before details of the method of demolition, including the storage of the resulting building material, have been submitted to and approved in writing by the local planning authority. The demolition of the building shall be carried out in accordance with the approved details. REASON- To enable the building to be demolished in a way that ensures the fixtures and fittings are preserved, if necessary and appropriate.
v. No works involving the demolition of the listed building the subject of this application shall be carried out before details of mitigation/compensation measures in respect of the impact of demolition on bats have been submitted to and approved in writing by the local planning authority. The approved details shall be implemented prior to the demolition of the listed building. REASON- To address the impact of the loss of day roost sites for bats, a European Protected Species, which would result from the demolition of the listed building.
Signed on behalf of Applicant
Matthew Jones
Signed on behalf of Local
Planning Authority Amy Longford
Date 24/05/17 Date 24/05/17
Position: Welsh Government Project
Engineer Position: Heritage Manager
Note on additional environmental commitments
Called-in Application by the Welsh Government for Listed Building Consent for
the Demolition of Woodland House, Magor
Public Inquiry: 20 June 2017
Note on Future Management of Bat Mitigation Measures
1. At the inquiry on 20 June the letter from Natural Resources Wales (NRW) dated
19 June 2017 was discussed. This letter requested that if listed building consent
were to be granted, it should be subject to appropriate planning obligation(s)
and/or conditions to deliver:
appropriate and sufficient mitigation/ compensation for the loss of bat
roosts, secured and delivered in advance of the loss of the existing roost
sites. NRW advised a structure to the south of the existing and proposed
M4 (on the same side of the M4 as Woodland House);
long term management, maintenance and monitoring of the structure(s)
built to compensate for the loss of the roost site for lesser horseshoe bats
and any associated planting.
2. The first point has been addressed by the revision of the Statement of Common
Ground to include an appropriate condition, as discussed at the inquiry. The
second point is dealt with in this note, which sets out the options for meeting
NRW’s request.
3. A condition requiring the approved mitigation measures for a period of 5 years,
similar to that used for landscaping and planting, would not be sufficient to meet
NRW’s long term requirement. The usual method for providing for maintenance
and management beyond 5 years would be by the provision of a commuted sum
using a planning obligation or other agreement.
4. Previous Government guidance stated that a condition could not require the
applicant to enter into a planning agreement and that a condition could not
require the payment of money or other consideration. Current Welsh Government
advice in Circular 016/2014: The Use of Planning Conditions for Development
Management is silent on this issue. However, the National Planning Practice
Guidance issued by the Department for Communities and Local Government now
directly addresses the issue. It states1 that in exceptional circumstances a
negatively worded condition requiring a planning obligation or other agreement to
be entered into before certain development can commence may be appropriate in
the case of more complex and strategically important development where there is
clear evidence that the delivery of the development would otherwise be at serious
risk. It adds that the six tests2 applied to determine the validity of conditions must
be met.
1 https://www.gov.uk/guidance/use-of-planning-conditions 2 See WGC 016/2014, para 3.1
5. It would therefore be possible to attach a negatively worded condition in this case
to provide for long-term management of mitigation measures since the same
legal principles apply in England and Wales. The condition would require the
Welsh Government to submit a planning obligation to the local planning authority
that would make provision for the necessary management and maintenance. The
following condition and reason are suggested:
No works involving the demolition of the listed building the subject of this
application shall be carried out before a planning obligation to secure the long-
term management and maintenance of the approved mitigation/compensation
measures in respect of the impact of the demolition works on bats has been
submitted to and approved in writing by the local planning authority.
REASON- To ensure provision is made in the long term to address the impact of
the loss of day roost sites for bats, which would result from the demolition of the
listed building.
6. At the inquiry an alternative means of ensuring long term maintenance was
proposed by the Welsh Government, involving additions to the Register of
Commitments. The following commitments are put forward for consideration:
Welsh Government will provide appropriate and sufficient mitigation (to be agreed with NRW) for the loss of the lesser horseshoe and pipistrelle bat roosts at Woodland House. Such mitigation will be secured and delivered in advance of the loss of the existing roost sites. Any replacement roost(s) should be located to the south of the existing and proposed M4, on the same side of the M4 as Woodland House.
A long-term management plan, including maintenance and monitoring requirements, for the replacement roost(s) for Woodland House will be prepared, agreed with NRW and implemented accordingly. Long term includes post installation, post construction (5 year aftercare period), and longer term (post aftercare period). Such a long term management plan will be incorporated into the Scheme’s Operation and Maintenance Manual (OMM) and/or other relevant documentation.
7. It is appreciated that the first of these commitments duplicates the condition
regarding mitigation measures discussed at the inquiry and added to a revised
Statement of Common Ground (condition v). However, the Welsh Government
considers it appropriate that this also reflected in the Register of Commitments.
The second commitment provides the necessary surety in the event that the
Inspector considers the condition suggested above fails the tests of validity.
Plan of the possible re-location site at Knollbury
A3
Scale
Drawing Title
Project TitleDrawing Status
DO N
OT S
CA
LE
Client Original Size
Suitability
Drawing Number Revision
Millim
etres
100
10
0
Location Type Role Number
Project Originator Volume
Date Date Date Date
Designed / Drawn Checked Approved Authorised
Rev. Date Description By Chk'd App'd
Project Team
Trwydded yr Arolwg Ordnans 100021874.
© Hawlfraint a hawliau cronfa ddata'r Goron 2015. Rhif
Survey 100021874. Welsh Government.
© Crown Copyright and database right 2015. Ordnance
40.2m
Horseshoe Cottage
42.4m
Knollbury Cottage
48.5m
Daffodil Lodge
Knollbury
Well
Cottage
Rose
Cottage
Old
2
Ty Knoll
LB
TCB
---
S2
M4 CORRIDOR AROUND NEWPORT
---GRDTLEAEJ
Z5_GEN - SK - CH - 0241
M4CaN - DJV - HGN -GRDTLEAEJ
1:1000
WOODLAND HOUSE
PROPOSED RELOCATION SITE FOR
LEGEND: NOTES:
ACCESS AND VISIBILITY.
GEN-SK-CH-0242 FOR DETAILS OF DOMESTIC
1. REFER TO SKETCH M4CaN-DJV-HGN-Z5
WOODLAND HOUSE
OUTBUILDING
25/07/17 GRDTLEAEJP01 First Issue
REVISED TO AVOID OVERHEAD CABLESP02
26/07/1726/07/1726/07/17
FOR INFORMATION
P0226/07/17TEMPORARY CONSTRUCTION LAND
PUBLIC FOOTPATH TO BE PROVIDED
UP
PUBLIC FOOTPATH TO BE STOPPED
PUBLIC FOOTPATH
TO BE ACQUIRED PERMANENTLY
PROPOSED RELOCATION SITE - LAND
INFORMATION
SAFETY, HEALTH AND ENVIRONMENTAL
(Reference shall also be made to the design hazard log).
detailed on this drawing, note the following significant residual risks
In addition to the hazards/risks normally associated with the types of work
Construction
building. It also crosses above proposed driveway.
Overhead 11kV electricity line located along south side of proposed
Maintenance / Cleaning
(Enter "None" if applicable)
Use
(Enter "None" if applicable)
Decommissioning / Demolition
(Enter "None" if applicable)
Possible mitigation opportunities for Bats
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 1
Adran yr Economi a’r Seilwaith Department for Economy and Infrastructure
Planning (Listed Buildings and Conservation Areas) Act 1990 – Section 12 Application by: The Welsh Ministers Site: Woodland House (known locally as the Magor
Vicarage) Newport Road, Magor, Monmouthshire, NP26 3BZ
Woodland House Bat Roost Compensation Options Richard Green BSc (Hons) CEnv MCIEEM Welsh Government, Bats Document Reference: WG 1.20.5
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
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Page 2
Contents 1. Introduction ...................................................................................................................... 3
2. Lesser horseshoe bat roosting ecology (adapted from Mitchell-Jones, 2004) ......... 3
3. Common pipistrelle bat roosting ecology (adapted from Mitchell-Jones, 2004) ...... 3
4. Proposed bat mitigation .................................................................................................. 4
5. Natural Resources Wales view ....................................................................................... 4
6. Consideration of additional mitigation .......................................................................... 5
7. Option 2 – Provision of building at proposed reed beds 11b, either side of St
Brides Road. ..................................................................................................................... 6
8. Option 3 – Provision of building in land close to Woodland House .......................... 7
9. References ........................................................................................................................ 7
10. Figures .............................................................................................................................. 8
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
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Page 3
1. Introduction
1.1 As part of the M4 Corridor around Newport scheme, it is proposed to
demolish Woodland House (also known as Magor Vicarage) and two
outbuildings, consisting of a coach house and a recently constructed
double garage. Woodland House is located at NGR ST 4205 8765.
1.2 Bat surveys undertaken in 2017 confirmed that Woodland House is used
as a day roost by a small number of common pipistrelle bats; and the
coach house is used regularly as day and night roost by one or a small
number of lesser horseshoe bats.
2. Lesser horseshoe bat roosting ecology (adapted from Mitchell-Jones, 2004)
2.1 Lesser horseshoe bats require large roost areas with flight access into
them, where they hang free. It is essential that a sufficiently large space,
unobstructed by constructional timbers, is available for bats to fly in.
Based on a sample of known roosts, it is unlikely that a void height (floor
to ridge board) of less than 2 m will provide sufficient volume or that an
apex length or width of less than 4 m will provide sufficient area. An ideal
roof void would have an apex height in excess of 2.8 m and a length and
width of 5 m or more. This species is generally found in older roofs of
traditional construction giving a large uncluttered void, so typical trussed
rafter construction must not be used. Suitable construction methods are
purlin and rafter (‘cut and pitch’) with ceiling ties. They prefer roosts with
associated sheltered light-sampling areas connected to woodland and
groups/lines of trees.
3. Common pipistrelle bat roosting ecology (adapted from Mitchell-Jones, 2004)
3.1 Common pipistrelle bats generally roost in crevices and do not normally
require light-sampling areas. Roosts are ideally at least 4 metres above
ground level but can be found lower. Connection to tree-lines is
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 4
desirable. Bat boxes are considered to provide an appropriate form of
mitigation/compensation for roosts of low conservation significance.
4. Proposed bat mitigation
4.1 A bat house, suitable for use by lesser horseshoe and pipistrelle bats will
be provided to the north of the existing M4 as part of the M4CaN
scheme. This is connected to the south side of the M4 by the St Brides
Brook and Mill Reen Underpass, which has been shown to be used by
lesser horseshoe and pipistrelle bats.
4.2 Bat boxes, suitable for common pipistrelle bats, are proposed along
Bareland Street (refer to Figure 6j of the Draft Bat Mitigation Strategy
update (May 2017) [PID-56 (revised)].
5. Natural Resources Wales view
5.1 Natural Resources Wales (in their letter to The Planning Inspectorate on
19 June 2017) considers that:
a) The level of survey effort is adequate to enable an assessment of
the demolition of Woodland House and its outbuildings on bats
b) Provided appropriate mitigation/ compensation proposals are
secured proportionate to the impact, we would have no objection to
the demolition of Woodland House and its outbuildings
and they recommend that:
c) Should it be minded to grant permission to enable demolition of
Woodland House and outbuildings, that demolition should only be
granted subject to the application of appropriate planning
obligation(s) and/or conditions to deliver:
i. Appropriate and sufficient mitigation/ compensation for the loss
of these roosts, secured and delivered in advance of the loss of
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 5
the existing roost sites. We would advise a structure to the south
of the existing and proposed M4 (ie on the same side of the M4
as Woodland House)
ii. Long-term management, maintenance and monitoring of the
structure(s) built to compensate for the loss of the roost site for
lesser horseshoe bats and any associated planting.
6. Consideration of additional mitigation
6.1 In response to NRWs request for a structure to the south of the existing
and proposed M4, three options for the location of the structure were
initially considered and discussed with NRW. Figures 1 - 3 show where
each of these options would be located. Figure 3e of the Statement to
Inform Appropriate Assessment shows where the majority of lesser
horseshoe bat activity was recorded around Magor.
6.2 With regards to Option 1 – Provision of building at replacement
allotment land, this has been discounted as this area is being provided
as exchange land for allotments under a Section 19 Application. This
area would therefore be under the control of Monmouthshire County
Council (MCC) rather than the Welsh Government and the use of the
allotments would be supervised by the Magor and Undy Community
Council.
6.3 Previous discussions with the Community Council in regard to the re-
provision of the allotments have identified that there have been problems
with vandalism and damage to tools and equipment on the existing
allotment sites. In view of the potential security risk, it is also considered
unlikely that the Community Council would be likely to support the
location of this type of building on the new allotment site.
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 6
7. Option 2 – Provision of building at proposed reed beds 11b, either side of St Brides Road.
Advantages
7.1 Location is south of M4 and in an area shown to be used by lesser
horseshoe bats.
7.2 Building could be positioned by mature trees to south of reedbeds.
7.3 No public access/reduced risk of vandalism but close to St Brides Road.
Disadvantages
7.4 There are programming issues with providing a building in advance of
demolition of Woodland House, as the reedbeds would have to be
constructed first. They are currently proposed to be constructed later in
the programme.
7.5 Whilst the building could be provided by existing trees, proposed
landscaping in that area comprises reed bed, open grassland and
shrubs with intermittent trees. Whilst lesser horseshoe bats will forage in
these habitats, woodland is considered to be much better habitat.
Viability/recommendation
7.6 Viable but causes programming issues likely to result in additional costs.
Proposed habitats around the building are not optimal. Not
recommended.
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 7
8. Option 3 – Provision of building in land close to Woodland House
Advantages
8.1 Location is south of M4 and in an area shown to be used by lesser
horseshoe bats.
8.2 Building could be positioned by mature trees to north of housing estate
that connect to wider landscape.
8.3 No public access and looked over by houses. Therefore, reduced risk of
vandalism.
8.4 Closest site to existing roost at Woodland House.
8.5 Building could be constructed early and before demolition, with no
programming constraints, as location not required for any engineering
work.
8.6 Proposed landscaping around the roost is deciduous woodland, i.e.,
lesser horseshoe bat favoured habitat, and planting could be undertaken
early in programme.
Disadvantages
8.7 There are no disadvantages.
Viability/recommendation
8.8 Viable and preferred option.
9. References
Mitchell-Jones, A.J. (2004). Bat Mitigation Guidelines. English Nature.
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 8
10. Figures
Figure 1. Alternative locations for bat roost building
Option 1
Option 3 Option 2 Woodland
House
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 9
Figure 2. Alternative locations for bat roost building - close-up (Option 1)
Option 1
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
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Figure 3. Alternative locations for bat roost building - close-up (Options 2 and 3)
Option 3
Option 2
Woodland House
Welsh Government M4 Corridor around Newport Woodland House Bat Roost Compensation Options
– Bats
August 2017
Page 11
Figure 3a of SIAA showing location of lesser horseshoe bat activity around Llandevenny and Magor
Annex B: Letter from Martin Bates to Mark Hand dated 5 December 2017
Adran yr Economi a’r Seilwaith Department for Economy and Infrastructure
Parc Cathays
Cathays Park
Caerdydd Cardiff
CF10 3NQ
Ffôn Tel 02920 826360
Gwefan website: www.gov.wales/m4newport
Mark Hand Head of Planning Department Monmouthshire County Council PO Box 106 Caldicot NP26 9AN
By Email Only
5th December 2017
Dear Mark
M4 Corridor around Newport Proposed relocation of Woodland House, Magor
As you are aware, the Welsh Government (WG) has proposed the demolition of Woodland House (Grade II Listed Building) to accommodate the alignment of the M4 Corridor around Newport at Magor. An Inquiry into the called-in application for listed building consent was held by the Planning Inspectorate on 20 June 20171 .
Both the WG and Monmouthshire County Council (MCC) each provided to the Inspectorate their Statement of Case, as required.
The Council’s Statement of Case dated 20 February 2017 set out that:
“The building should be relocated and not lost completely.”
The WG set out in their Statement of Case dated 1 March 2017 that:
“Whilst preservation in-situ is always preferred, relocation of listed buildings does occasionally occur, but is rare. It is problematic per se, less so for small, timber framed structures, but more so for sizeable, stone/brick-built, multi-storey buildings such as the application property. It is considered that partial recovery of historic fabric for museum or re-use and full recording prior to demolition are feasible mitigation options in this case.”
Subsequently, ongoing engagement between the WG and MCC resulted in an agreed Statement of Common Ground dated 24 May 2017, which has been submitted to the Inquiry (Public Inquiry Document ID 102, a copy of which is attached). Point 6 of the Statement of Common Ground states that:
1 INSPECTORATE REF. APP/E6840/V/17/3166811 / PLANNING REF. DC/2016/01033
Parc Cathays
Cathays Park
Caerdydd
Cardiff
CF10 3NQ
Ffôn Tel 02920826360
Gwefan website:
www.gov.wales/m4newport
“Monmouthshire County Council is working with the Welsh Government in actively investigating the re-erection of Woodland House on another site following demolition, although a site has yet to be identified and the feasibility of re-erection remains unproven.”
Working collaboratively with MCC officials, a possible Council-owned site at Knollbury has been identified as having the potential for the proposed relocation of Woodland House. The location was included as a plan in Public Inquiry Document ID 102. A separate copy of the plan is attached for ease of reference.
To ascertain the potential estimated resale value of locating Woodland House at the Knollbury location, the WG instructed the District Valuer (DV) The DV has advised WG of a resale value of £800,000.
The estimated costs of relocating Woodland House to the Knollbury location not including land are set out below.
Description of Cost Estimated Costs (excl. VAT)
Cost of rebuilding House £810,000
Cost of rebuilding Outbuilding £205,000
Provision of Services £50,000
Seeking planning permission £8,500
Construction Methodology Statement £1,000
Cost of marketing and selling the property £12,500
Part 1 claim £20,000
Total Costs for rebuild & marketing property £1,107,000
Less DV’s estimated resale value £800,000
Net Cost to WG for rebuild not including land (£307,000)
For your information the Welsh Government purchased Woodland House in Magor at a cost of £1.1m in 2007. That cost has been recorded as a Scheme cost because the property would have to be demolished should the scheme proceed.
As you may have anticipated the current Scheme budget did not include for the costs of relocating Woodland House. Therefore I have had work carried out to determine the estimated relocation and re-erection costs should the Knollbury location be suitable to MCC. As explained in the Statement of Case, Woodland House is a good example of a mid-19th century purpose-built vicarage in a Tudor/Jacobean Revival style but it is not of a level of significance that would justify the expense of rebuilding at a new location out of public funds. The table above shows that WG would incur a further estimated loss of approximately £307,000 to relocate the Grade 2 listed Woodland House which I do not consider to be a good use of public money.
Parc Cathays
Cathays Park
Caerdydd
Cardiff
CF10 3NQ
Ffôn Tel 02920826360
Gwefan website:
www.gov.wales/m4newport
To assist my further deliberations I would ask what assistance if any the Council can give to contributing to assisting with reducing these costs. In particular, I welcome your views on the following:
1. Your acceptability of the Welsh Government only relocating and rebuilding the House, excluding its Outbuilding (this would remove an estimated £205,000)
2. Whether the cost of land could be waived as an exceptional circumstance (not included in the above and so would increase costs); and
3. Whether the cost of the necessary planning application could be waived given it would be addressing a request from the Council (this would save £8,500).
I would be thankful for a prompt reply given the inspectors at the ongoing Public Inquiry into the proposals for the M4 Corridor around Newport require an update on the above matters.
If you wish to discuss please do not hesitate to contact me on 07870 906553
Yours sincerely
Martin W Bates Project Director Infrastructure Delivery Transport
Enc
1. M4 Corridor Around Newport Public Inquiry Document ID102 2. Proposed Relocation site for Woodland House (Drg No M4CaN – DJV – HGN
– Z5_GEN – SK – CH – 0241 Revision P02
Annex C: Updated Position Statement by Monmouthshire County Council dated 13th December
2017
Woodlands House, Magor
Updated Position Statement by Monmouthshire County Council
for Public Inquiry 13th December 2017
1. Monmouthshire County Council does not appear to have received advanced notification of
this Public Inquiry update session and regrettably is unable to send a representative at short
notice. However, the Council understands that the purpose of the session is simply for the
Inspector to receive a progress update on the proposals to relocate Woodlands House. On
that basis, the Council has no objection to the session continuing in its absence, but would
respectfully request that the content of this note be considered.
2. The Council was contacted by Mr Martin Bates on 5th December 2017. This letter, a copy of
which is provided at Annex B of Welsh Government document ID166, highlights the Welsh
Government’s concerns regarding the financial viability of relocating Woodlands House and
asks the Council for assistance in three regards:
i. Agreement to relocate Woodlands House only, without its outbuilding, to
reduce costs by approximately £205,000;
ii. To waive the cost of purchasing the Council-owned land on which the house
would be rebuilt;
iii. To waive the planning application fee of £8,500
3. These requests are considered in turn below:
Relocation of Woodlands House without its outbuilding
4. The Council has not yet concluded its consideration of this suggestion. The outbuilding is
not a Listed Building in its own right, but it is listed as a curtilage structure and as such it
contributes towards the importance of this heritage asset.
5. Additional time is required to properly consider this request.
6. Without prejudice to its position, the Council would question the sale value of the resultant
relocated dwelling, which may be lower if marketed without an outbuilding.
Waiving of the land purchase costs
7. In addition to the widely reported financial difficulties facing Local Government,
Monmouthshire County Council receives the lowest per capita funding from the Welsh
Government of all Welsh Councils. It must therefore make the best possible use of its
assets, including its landholdings, in order to keep delivering essential public services.
Disposing of this land for free is not an acceptable proposition.
8. Notwithstanding the above, the Council must comply with S.123 of the Local Government
Act.
9. This request to waive land purchase costs is therefore declined. The Council will require fair
market value for the land, and would expect such a value to be provided impartially by the
District Valuation Service.
Waiving of the planning application fee
10. The planning application fee is a statutory requirement to make a planning application valid.
The request to waive the application fee is therefore declined. However, the Council can
advise that the application fee is £380, not £8,500 as stated in Mr Bates’ letter.
Other matters
11. Notwithstanding the point made in paragraph 6 above, evidence suggests that house values
and speed of sales have both increased significantly over recent months, since the
announcement that the Severn Bridge tolls will be abolished. It is suggested that the
£800,000 sales value of the relocated dwelling should be reviewed by the DVS.
12. Mr Bates suggests that a net cost to the public purse of relocating Woodlands House would
not represent a good use of public funds. The Council would respectfully disagree with that
opinion, noting that, as a Listed Building, Woodlands House is by definition of national
significance. Moreover, culture, of which our built heritage is an important part, is a key
component of the Wellbeing of Future Generations Act and should be given appropriate
status in decision-making alongside the environmental, economic and social considerations.
