The Caerleon Civic Society welcomes the consultation draft of the Caerleon Conservation Area Appraisal and appreciates the willingness of the City Council to brief us at an early stage about its contents and to have arranged an exhibition for the wider public. We feel that this approach to consultation brings mutual benefits and lays a good foundation for future collaborative work.

We have the following comments:-

Section 1.
We agree with the headline description of the Caerleon Conservation Area as having a ‘ unique character and strong archaeological presence’.
Although this description is very likely to remain relevant for years to come, we also recognise that there are very strong pressures for change, expressed through diverse factors such as land and property values and the needs of a car and lorry users, which may fundamentally alter the ‘look and feel' of our Conservation Area.
Because of the relentless nature of these pressures we do consider that the Conservation Area should be reappraised on a more regular basis - say, every 5 years, so that an updated Management Plan can reflect the inevitable pace of change. This review cycle should be linked to the 15 year time period of the Local Development Plan.

Section 2.
We consider that the Report should draw attention to the apparent vacuum in national planning guidance, and related technical advice, regarding the complex relationship between air quality and area conservation. The very high levels of air pollution being experienced in some streets within the Conservation Area are not, in our view, compatible with healthy living environments or the principles of building and area conservation. This relationship requires explicit policy guidance in terms of the Local Planning Authority dealing with individual planning applications, as the evidence of the recent Campus development proposal has shown.

Section 3.
We acknowledge the significance given in the Report to the importance of views within the Conservation Area, and to views from the Area and into it from the surrounding adjacent environment.We support the suggestion that particular views into the surrounding environment, and of the Conservation Area from that environment, should be explicitly identified and taken into account in any proposals for larger scale development in areas adjacent to the Conservation Area.
We are particularly concerned that continued effort should be directed towards the maintenance and enhancement of public spaces and the public realm within the Conservation Area. We acknowledge that resources are limited but a more comprehensive plan of the street scene within the Conservation Area would enable available resources to be prioritised and directed more effectively. We also consider that such a plan would guide the use of any additional resources that might become available, such as Heritage Lottery Funding as mentioned in the Thurley Report, which is with Welsh Government Ministers.
We are willing to contribute our ideas, in detail, towards this end and welcome the identification of the opportunities in section 4.3.14, onwards, of the Report. We particularly endorse the relevant section of the proposed Management Plan at section 5.3.15.

Section 4.
We endorse your statement of special interest and welcome your identification of positive indicators. We consider that this important section of the Appraisal can form the basis of future detailed work with property owners and developers.
Paragraphs on condition and detracting features are more contentious. Issues will often relate to the financial resources available to individual property owners. We feel that progress in this area should not just rely on reacting to planning applications but on proactive work, perhaps with a small group of property owners, on a street-by-street basis, to discuss a more collaborative and collective approach and to receive pooled advice and guidance.
We particularly support the suggestion in Paragraph 4.3.17 that a high quality interpretation and way finding scheme is developed and we would wish to be involved in such a project.

Section 5.
We are not convinced that the open field area between the amphitheatre and the river should be removed from the Conservation Area by amending the boundary.
We consider that there is a distinct lack of evidence in the Report to justify this proposal, and, in particular,a lack of specific examples of sites where Scheduling, alone, has provided sufficient protection against inappropriate development.
Our main objections to removal of this open area are:-
* there is an overriding need to protect the views of the Conservation Area from the south. This area is integral to the principles laid out in the Report’s statement of special interest. The ‘unique character’ of Caerleon is a combination of the developed part of the Conservation Area and the historic value of the open area to the south beyond the amphitheatre and barracks.
* there are buildings and land uses within the area suggested for removal that could be the subject of large-scale development proposals and all available legislative means will be needed to ensure that such proposals are assessed properly and fully for their effect on the built part of the Conservation Area to the north.
* reliance on protection under Scheduled Monument legislation may remove that all important local, democratic, dimension to decisions about future use that comes with Conservation Area designation, within the context of the Local Development Plan and its supplementary guidance.

We have no comments on the minor amendments to the Conservation Area boundary.
We fully support the City Council in bringing forward shopfront design guidance.
We support the aims and objectives set out in paragraph 5.4. We recognise, however,that a degree of incentive will be needed for both the community and individual property owners to support progress towards objectives 5,7,9 and 10. - vegetation growth, exposure of external brickwork, colour of external paint and render, new public realm features.

Please advise us about the timing and content of the proposed Final Report to Cabinet.


Chris Thomas
Chair,
on behalf of Caerleon Civic Society.