Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2?
QD5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? Yes, the heritage assessment is very important. I am not certain the Heritage assessment to date for Henley is sufficient to show that large scale development in the area would be highly detrimental to historic heritage and environmental heritage and feel of the Henley area. It is important that Local communities are able to work with the SWLP to meet their local needs and for the SWLP to accept that local residents will often understand their local area more comprehensively than the SWLP or developers, to that end NDPs should be respected.
Issue D2: Design Codes and design guides: Any design codes created in support of this plan would hugely benefit from adopting what could be described as its Golden Threads: Environmental growth and nature recovery. Environmental growth and nature recovery should go beyond the protection of a small proportion of our most important landscapes, biodiversity and protected sites. It should actively increase our environmental assets and make better use of nature for drainage, food growing and creating great places to be. All new development should help nature to recover, achieve biodiversity net gain and ensure that residents have access to good quality green and natural spaces and support integration. 1. Health and wellbeing: The environment should support achievement of better quality lifestyles through the places where we live, meet and play. With nature at their heart, the design of new layouts and communities should include active, connected and healthy places to live with opportunities to grow our own food and to walk or cycle to work and local facilities. 2. Inclusivity: All communities should benefit equally. New buildings and places must work for everyone, meaning that all ages and physical abilities are able to call Sth Warwickshire home and to be included in society. Developments that are comfortable, nature engaging and safe places for children will also be great places for adults. Equally, additional measures to help meet needs of those with limited movement, cognitive or sensory issues and our older community members will also help to make life easier for all residents. 3. Resilience to climate change: Our future living environment will be impacted and influenced by climate change. The natural and built environment are resilient to change and help to reduce our carbon footprint, both in terms of the operation of the building (including heating, lighting and ventilation) as well as the fabric of the building (considering low carbon materials, construction and transportation) and the way that we access buildings and places. We would encourage you to review the Cornwall County Council’s new Design Guide which takes a holistic approach and joins all these component options together. Cornwall Design Guide https://www.cornwall.gov.uk/media/vzkd4iaj/cornwall_design_guide_v2-0.pdf. Issue D5: Protecting and enhancing heritage assets: Protected landscapes: Natural England would like to see the character of protected landscapes conserved and enhanced (both direct and indirect pressures can impact on character). We want to ensure that proposed developments close to the boundaries of protected landscapes (within their settings) take proper account of their impacts on the Area of Outstanding Natural Beauty (AONB). The plan should encourage the enhancement of the Cotswold Area of Outstanding Natural Beauty, making reference to its Management Plan objectives. We recommend approaching the AONB’s planning lead to discuss how the plans can fit together. The plan should provide protected landscapes with the highest levels of policy protection for landscape and scenic beauty (including acknowledgement of wider purposes-landscape, natural beauty, understanding and enjoyment and cultural heritage) whilst having regard for their economic and social well-being. It should include appropriate policies to manage the nature, scale and location of development in the protected landscape, or, where appropriate, its setting. The plan should encourage the highest standards of design for such development.
Q-D2: Please select all options which are appropriate for South Warwickshire Option D2a: Develop a South Warwickshire Design Guide Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an 'area' in the case of a new settlement) where the spatial strategy identifies significant change Option D2c: Develop design guides/codes for strategic development sites/locations In principle, the introduction of design codes and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. L&Q Estates therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site specific design code/guide that goes beyond the detailed guidance in the National Design Code. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies.
Issue D1: Strategic design principles Q-D1.1 Yes, the components listed (comprehensive development; attractiveness; sensitive to context; distinctiveness; connectedness; safety; environmental sustainability and adapting to climate change and; mix and amount of development – are considered to be an appropriate range of topics for a strategic design policy. The proposed content aligns with chapter 12 – achieving well-designed places of the NPPF as is currently worded. Proposed amendments to the NPPF currently under consultation strengthen the importance of good design. Issue D2: Design Codes and design guides Q-D2. We consider that the high level principles of good design could be contained within a suitably worded policy within Part 1 of the Plan which could relate to the whole of the South Warwickshire geographical area – there may be limited merit in doing so however, as expectations are already set out within the National Design Guide and National Model Design Code – for part 1, generally then, it may be sufficient to refer to the Framework and the National Design Guide requiring applicants to demonstrate compliance with. To ensure that design guides/design codes respond to local characteristics, it is essential in our view that these are prepared on an area (if a group of settlements share common features) or individual settlement basis. The design codes/guides should ideally be formulated over time, with input from all key stakeholders including local residents and business owners as well as technical and environmental personnel from both the private and public sector to ensure that these guides will be robust in their assessment of the character and what would be acceptable in terms of visual and environmental (to capture effects of climate change and so on) and deliverable from a developer point of view. Due to the nature of the above; being a collaborative exercise, which will take time, it is considered that the finer detail required to produce such codes, should be required at a later stage of the local plan – either within Part 2, and specific to new allocations proposed, or following adoption, when new sites are confirmed, where a site specific design code/guide could be required. The use of site wide design codes for new allocations is supported, provided there is proper consultation with relevant council departments at both District and County to avoid problems post adoption. We have experience with a site in Warwick (The Asps) which has an adopted site wide design code (which was prepared following a series of workshops with key stakeholders and relevant officers from both the District and County, submitted and approved via a discharge of condition attached to the outline consent). It was very prescriptive in terms of layout, design, materials, car parking spaces, public open space, connectivity and so on, even down to the widths of roads and pavements which would be expected for the main spine road, primary, secondary and tertiary roads. Whilst this code enabled the applicants to prepare reserved matters applications to a set of agreed principles, which the District (planning officer) confirmed they were supportive of; we were significantly delayed by the repeated objections from the County Highways officer who maintained concerns over highway safety and general layout of tertiary roads. This was despite apparently having provided comments on the proposed design code before it was approved. This situation left the District in a difficult position - the Code has been approved and therefore has considerable status in planning terms – to satisfy highways, tertiary roads were re-designed – to appear more engineered and to have footways on both sides – which is contrary to the design code – the engineered appearance significantly detracts from the intended character of these streets. Despite many discussions to try to persuade Highways and to remind them that they were involved with the production of the Code – it was easier to amend the proposals than to continue to argue. In addition to this, tertiary roads have been approved (as per the Design Code) with block paving. We have now received objection to use of block paving and a particular kerb height (again specified within the code) from the Technical Team. We are categorically being told that these materials will NOT receive technical approval. Initial discussions with the District (to try and resolve) have not progressed as the technical team have suggested the use of black tarmac and high kerbs is the only solution – this would fundamentally change the nature of the tertiary roads and character areas in which they are located. This would be across the whole development consisting of 900 dwellings. The planning officer is not keen to support as cumulatively, this change would adversely impact on the appearance of the whole of the development – contrary to the adopted Site Wide Design Code. For any design code to be acceptable therefore, it is critical that the correct officers, statutory and non-statutory consultees and other key stakeholders are consulted on and their views properly taken into account before adoption to avoid similar problems again. Whilst laudable, if any document is adopted without concerns or objections being addressed, it can cause a significant delay to the granting of permission for schemes which will ultimately affect their deliverability. Issue D3: Designing adaptable, diverse and flexible places Q-D3a. We consider that option a – to include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire is the most appropriate option. This would allow a greater flexibility to be considered for individual sites as they come forward for development. There will be a need to take into account the character of the surroundings and density is just one element of this. Issue D4: Safe and attractive streets and public spaces Q-D4.1 Yes. We agree that the range of topics listed is appropriate for a policy on the design of safe and attractive streets. Issue D5: Protecting and enhancing heritage assets Q-D5: Should we continue with the approach to include a high-level strategic policy within Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detail policies to Part 2? Yes. The NPPF advises that plans should set out a positive strategy for the conservation and enjoyment of the historic environment.
Issue D1: Strategic design principles Q-D1.1 Yes, the components listed (comprehensive development; attractiveness; sensitive to context; distinctiveness; connectedness; safety; environmental sustainability and adapting to climate change and; mix and amount of development – are considered to be an appropriate range of topics for a strategic design policy. The proposed content aligns with chapter 12 – achieving well-designed places of the NPPF as is currently worded. Proposed amendments to the NPPF currently under consultation strengthen the importance of good design. Issue D2: Design Codes and design guides Q-D2. We consider that the high level principles of good design could be contained within a suitably worded policy within Part 1 of the Plan which could relate to the whole of the South Warwickshire geographical area – there may be limited merit in doing so however, as expectations are already set out within the National Design Guide and National Model Design Code – for part 1, generally then, it may be sufficient to refer to the Framework and the National Design Guide requiring applicants to demonstrate compliance with. To ensure that design guides/design codes respond to local characteristics, it is essential in our view that these are prepared on an area (if a group of settlements share common features) or individual settlement basis. The design codes/guides should ideally be formulated over time, with input from all key stakeholders including local residents and business owners as well as technical and environmental personnel from both the private and public sector to ensure that these guides will be robust in their assessment of the character and what would be acceptable in terms of visual and environmental (to capture effects of climate change and so on) and deliverable from a developer point of view. Due to the nature of the above; being a collaborative exercise, which will take time, it is considered that the finer detail required to produce such codes, should be required at a later stage of the local plan – either within Part 2, and specific to new allocations proposed, or following adoption, when new sites are confirmed, where a site specific design code/guide could be required. The use of site wide design codes for new allocations is supported, provided there is proper consultation with relevant council departments at both District and County to avoid problems post adoption. We have experience with a site in Warwick (The Asps) which has an adopted site wide design code (which was prepared following a series of workshops with key stakeholders and relevant officers from both the District and County, submitted and approved via a discharge of condition attached to the outline consent). It was very prescriptive in terms of layout, design, materials, car parking spaces, public open space, connectivity and so on, even down to the widths of roads and pavements which would be expected for the main spine road, primary, secondary and tertiary roads. Whilst this code enabled the applicants to prepare reserved matters applications to a set of agreed principles, which the District (planning officer) confirmed they were supportive of; we were significantly delayed by the repeated objections from the County Highways officer who maintained concerns over highway safety and general layout of tertiary roads. This was despite apparently having provided comments on the proposed design code before it was approved. This situation left the District in a difficult position - the Code has been approved and therefore has considerable status in planning terms – to satisfy highways, tertiary roads were re-designed – to appear more engineered and to have footways on both sides – which is contrary to the design code – the engineered appearance significantly detracts from the intended character of these streets. Despite many discussions to try to persuade Highways and to remind them that they were involved with the production of the Code – it was easier to amend the proposals than to continue to argue. In addition to this, tertiary roads have been approved (as per the Design Code) with block paving. We have now received objection to use of block paving and a particular kerb height (again specified within the code) from the Technical Team. We are categorically being told that these materials will NOT receive technical approval. Initial discussions with the District (to try and resolve) have not progressed as the technical team have suggested the use of black tarmac and high kerbs is the only solution – this would fundamentally change the nature of the tertiary roads and character areas in which they are located. This would be across the whole development consisting of 900 dwellings. The planning officer is not keen to support as cumulatively, this change would adversely impact on the appearance of the whole of the development – contrary to the adopted Site Wide Design Code. For any design code to be acceptable therefore, it is critical that the correct officers, statutory and non-statutory consultees and other key stakeholders are consulted on and their views properly taken into account before adoption to avoid similar problems again. Whilst laudable, if any document is adopted without concerns or objections being addressed, it can cause a significant delay to the granting of permission for schemes which will ultimately affect their deliverability. Issue D3: Designing adaptable, diverse and flexible places Q-D3a. We consider that option a – to include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire is the most appropriate option. This would allow a greater flexibility to be considered for individual sites as they come forward for development. There will be a need to take into account the character of the surroundings and density is just one element of this. Issue D4: Safe and attractive streets and public spaces Q-D4.1 Yes. We agree that the range of topics listed is appropriate for a policy on the design of safe and attractive streets. Issue D5: Protecting and enhancing heritage assets Q-D5: Should we continue with the approach to include a high-level strategic policy within Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detail policies to Part 2? Yes. The NPPF advises that plans should set out a positive strategy for the conservation and enjoyment of the historic environment.
ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would likely jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different.
General Comments Firstly, Historic England is pleased to see that the historic environment is much more positively focused within the document than was the case at the Scoping stage of the SWLP. For example, we welcome that the Vision now includes a new overarching principle regarding design and beauty which encompasses heritage; that there is a specific Strategic Objective on heritage and cultural assets; that the technical evidence includes a Heritage and Settlement Sensitivity Assessment and that the Part 1 Plan proposes to include a high-level strategic policy that seeks to protect and enhance existing heritage assets. The NPPF is clear that Plans should set out a positive strategy for the conservation and enjoyment of the historic environment (para. 190), to ensure that growth options and site allocations avoid harming the significance of both designated and nondesignated heritage assets, including effects on their setting. There may also be opportunities to enhance or better reveal the significance of heritage assets (NPPF para. 206), or opportunities to tackle heritage at risk through sensitive development. To ensure that plans are positively prepared Historic England advises undertaking the process of the ‘Site Selection Methodology’ as set out in Historic England’s Advice Note 3 The Historic Environment and Site Allocations in Local Plans, 2015 (HEAN3): https://historicengland.org.uk/images-books/publications/historic-environment-andsite-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/ We note the assessment of the potential impacts of various directions of growth around certain settlements within the South Warwickshire area, as set out in the Heritage and Settlement Sensitivity Assessment and we would also recommend that detailed Heritage Impact Assessments (HIAs) are prepared as the Plan progresses towards preferred options and site allocations, either by or on behalf of the Local Authority, with reference to Historic England’s Advice Note 3 The Historic Environment & Site Allocations in Local Plans, 2015 (HEAN3) and Good Practice Advice Note 3 (Second Edition): The Setting of Heritage Assets (2017) (GPAN3) ): https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritageassets/ With specific reference to non-designated heritage assets, these can make a positive contribution to the character of our settlements and enrich our sense of place. We recommend that the views of your chosen specialist archaeological adviser are sought before any one growth option is selected. This should enable confirmation that the evidence base is sufficiently robust to ensure that any proposed allocation / growth option is deliverable in accordance with local and national planning policies. Your adviser will inform you on whether further assessment work is required through field assessment prior to allocation to ensure the extent, character and significance has been adequately understood to inform the allocation of a site.
Issue D1: Strategic Design Principles The NPPF is clear that a strategic design policy should be grounded in an understanding and evaluation of each area’s defining characteristics (paragraph 127). Historic England therefore considers that the range of topics for strategic design policy should also encompass reference to ‘local character and history, including the surrounding built environment and landscape setting’ as well as reference to establishing or maintaining a strong sense of place, as advised by the NPPF at paragraph 130. Issue D2: Design Codes and Design Guides Historic England supports the use of Design Codes and Design Guides to inform development and ensure that it is responsive to its setting. Information on good practice for design and on Historic England’s role in encouraging and facilitating new development which is based on an understanding of each site’s unique history, character and context, can be found at: https://historicengland.org.uk/advice/planning/design-in-the-historic-environment/ Issue D3: Designing adaptable, diverse and flexible places Historic England advises that any density policy for the SWLP should ensure that it supports the delivery of development that takes account of the desirability of maintaining the prevailing character and setting of an area. Issue D4: Safe and attractive streets and public spaces In relation to the appropriate range of topics for a policy on the design of safe and attractive streets, Historic England suggests that the contribution made by the historic environment to the character of a street or pubic space should be included, in line with paragraph 190 of the NPPF. Issue D5: Protecting and enhancing Heritage assets Historic England welcomes the recognition of heritage as an important consideration at the strategic level for the South Warwickshire Local Plan and we therefore support the proposed approach to include a high-level strategic policy within the Part 1 Plan. We are also pleased to see that the evidence base in relation to the historic environment will be developed as the Plan is progressed and that it will be utilised in determining the future growth strategy for the area.
Q-D2: Please select all options which are appropriate for South Warwickshire A set out in paragraph 128 of the NPPF, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences in order to provide maximum clarity about design expectations at an early stage. Such design guides / codes should be high level document and should not be overly prescriptive, thus enabling the design of each site to be considered based on its own merits and the context of the specific site. Detailed design of a site should take into account the specific technical considerations of that location which will not be fully investigated at design guide / code stage. Q-D3: Please select all options which are appropriate for South Warwickshire Crest Nicholson supports Option D3a, which proposes inclusion of a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. It is considered that this would enable a more locally tailored approach to density, which seeks to make the most efficient use of land, taking into account the specific context each site. This approach would not prevent specific design guides, codes or masterplans from guiding appropriate density ranges in areas of change, as advocated by Paragraph 125 of the NPPF. This approach could also be adapted to align with the general requirement set out within paragraph 125 of the NPPF for Local Plans to include the use of minimum density standards for city and town centres and other locations that are well served by public transport.
Q-D2 Producing a district wide Design Guide would be the preferred option to provide clear indication on the thought process and design ideologies to be implemented. This document should steer clear of providing specific details which should be brought out as part of any development rather than being dictated.
Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? 7.1 The IO document highlights that a heritage evidence base is being prepared to support the SWLP, titled ‘Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan (SWLP)‘ dated September 2022 (‘HSSA’). This is one of a number of technical documents that will help inform the choice of a single spatial option (or ‘preferred option’) to be consulted on at the next stage. 7.2 The IO document states that the HSSA has been prepared to determine the impact development may have on the heritage assets within various settlements, and will be used when determining the growth strategy (for the draft plan). Section 3 of the HSSA also states that the assessment will inform strategic site allocations and broad locations for growth within the development strategy for the Local Plan, but initially supporting the Issues and Options stage.
Issue D3: Designing adaptable, diverse and flexible spaces 6.1 We do not consider that there is any justification for seeking to define minimum densities which must be achieved across the plan area, this this will not fully reflect the specific characteristics and opportunities alongside constraints which will vary from site to site.
Q-D2: Please select all options which are appropriate for South Warwickshire (Design Codes and Design Guides) Bellway supports Option D2c: Develop design guides/codes for strategic development sites/locations. This is the preferred approach, however, Bellway consider that design guides / codes should be a high level / indicative document and should not be overly prescriptive, thus enabling the design of each site to be considered based on its own merits and in context of the specific site. Detailed design of a site should take into account the specific technical considerations of that location which will not be fully investigated at design guide / code stage. Q-D3: Please select all options which are appropriate for South Warwickshire (Designing adaptable, diverse and flexible places) Bellway supports Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire and Option D3e: None of these. Proposed densities should be agreed on a site by site basis and reflective of market requirements at the time of an application and local context. A policy could encourage higher densities within urban areas but not all urban sites will be conducive to high densities so it should be flexibly worded. Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? In support of this response, Bellway has instructed RP Heritage to review the Heritage and Settlement Sensitivity Assessment (HSSA) (September 2022) that has been published with the SWLP. Bellway strongly objects to the findings of the HSSA which recommends that development of the land to the south of Long Itchington should be avoided and development should be restricted to the north and eastern side of the settlement. A ‘Heritage Assessment of Long.09, Long.18 and Long.21’ (February 2023) has been submitted with this representation which responds to the HSSA in regards to its assessment of Bellway’s land (SHLAA references Long.09, Long.18 and Long.21) to the south of Long Itchington. As identified by RP Heritage, the HSSA’s RAG assessment of Bellway’s land shows inconsistencies and land to the north and east of Long Itchington has been assessed as having more significant impacts on heritage assets then Bellway’s land which have primarily been score as ‘green’. RP Heritage has concluded that the three proposed development options within Bellway’s Vision Document would have limited heritage harm that could be mitigated through the Masterplanning process at planning application stage. In contrast to the findings of the HSSA, which found that development of land to the south of Long Itchington should be avoided, RP Heritage has shown that there are no heritage related reasons why land to the south of Long Itchington could not be a focus for future housing growth. We request that the HSSA is reviewed and updated.
Q-D1.1 – Do you agree that this is an appropriate range of topics for the strategic design policy? Yes, the range of topics identified is appropriate for a strategic design policy. South Warwickshire has a large plan area, comprising large towns, a variety of villages of different size, hamlets and significant areas of countryside. It is, therefore, imperative that a design policy is flexible to recognise the different environments across the plan area, delivering high quality schemes. Q-D2 – Please select a design code option which is appropriate for South Warwickshire It is our view that a single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. It is our view that the most appropriate approach would be to include policy guidance within the site specific allocation policies where appropriate making it clear how the allocations are expected to respond to their surroundings. If necessary, design codes could also be produced for specific settlements and locations that have a particular design issue that need addressing. Q-D3 – Please select a density policy option which is appropriate for South Warwickshire We support a policy that confirms the relevance and importance of density, but it is not appropriate to identify a minimum density or range of densities within the policy. The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitate schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area. In addition, the SWLP will need to recognise the impact of the inclusion NDSS, open space and green infrastructure policies will have a density. NDSS compliance schemes result in larger property types, reducing the density of developments. Incorporating a significant amount of green space on schemes and biodiversity net gain measures is also likely to reduce net developable areas beyond those previously achieved. The proposed allocations need to be of a sufficient size to accommodate green and blue infrastructure whilst having realistic density assumptions.
Issue D2: Design Codes and design guides Q-D2: please select all options which are appropriate for South Warwickshire Option D2a – Develop a South Warwickshire Design Guide Option D2b – Develop design guides and/or design codes for specific places (eg existing settlements or groups of settlements, or an area in the case of a new settlement) where the spatial strategy identifies significant change Option D2c – Develop design guides/codes for strategic development sites/locations Option D2d – None of these 6.3 Catesby Estates considers Option D2c most appropriate and notes that these are likely to be the larger and more strategic sites, such as any new settlements. It is not appropriate to have a Design Guide across South Warwickshire as the area is too vast, and has a range of characteristics, therefore would not be representative or achieve suitable design across a variety of landscapes. Therefore, each Site should be assessed on its’ own merits. Issue D3: Designing adaptable, diverse and flexible places Q-D3: Please select all options which are appropriate for South Warwickshire Option D3a – Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. Option D3b – Include a policy which specifies a minimum density requirement across South Warwickshire, whilst emphasising that the minimum may be exceeded. This minimum could for example be set at a similar level to the existing policy in Warwick District. Option D3c – Identify appropriate density ranges for different locations/areas across South Warwickshire are specify these ranges in policy. These ranges could be based upon the prevailing characteristics of existing places. Option D3d – Identify appropriate density ranges for different locations/areas across South Warwickshire based upon accessibility and potential accessibility of these places. Options D3e – None of these. 6.4 Catesby Estates supports Option D3b where policy should specify a minimum density requirement across South Warwickshire. However, the Policy needs to be fully tested and evidence to understand the minimum housing density and requires caveats to enable different densities to be achieved, such as where housing need requires a greater number of one bedroom flats, or 4 bedroom houses which would impact upon density. 6.5 Furthermore, potential site constraints may also impact upon density, consequently, policy needs to be worded identifying the minimum density to be achieved, unless an alternative can otherwise be demonstrated as suitable. 6.6 However, in the current evidence base, it is difficult to fully establish and understand the housing need in relation to house types4 without further sufficient evidence, therefore it is difficult to decipher a suitable housing density. 6.7 It is crucial however that developers continue to maximise their densities across land, without having a negative detrimental visual impact, however should focus on the efficient use of land, in order to contribute towards achieving and delivering the much needed housing numbers. 6.8 One point of clarification is in relation to the density suggestion, as Option D3b states that an example could be set at a similar level to that of the existing policy at Warwick, being 30dph, whereas the Sustainability Appraisal, produced as part of the evidence base has based upon the assessment upon 35dph, thus an inconsistency between the two approaches. 4 PPG: Paragraph 005 Reference ID: 66-005-20190722 (How can density be measured for planning purposes?)
Q-D3: 2.43 A flexible approach to density in new development, which is consistent with national policy which states that Council’s should avoid unnecessary prescription or detail, and should set out their own approach to housing density to reflect local circumstances (paragraphs 123 of the NPPF).
Q-D1.1 – Do you agree that this is an appropriate range of topics for the strategic design policy? Yes, the range of topics identified is appropriate for a strategic design policy. South Warwickshire has a large plan area, comprising large towns, a variety of villages of different size, hamlets and significant areas of countryside. It is, therefore, imperative that a design policy is flexible to recognise the different environments across the plan area, delivering high quality schemes. Q-D2 – Please select a design code option which is appropriate for South Warwickshire It is our view that a single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. It is our view that the most appropriate approach would be to include policy guidance within the site specific allocation policies where appropriate making it clear how the allocations are expected to respond to their surroundings. If necessary, design codes could also be produced for specific settlements and locations that have a particular design issue that need addressing. Q-D3 – Please select a density policy option which is appropriate for South Warwickshire We support a policy that confirms the relevance and importance of density, but it is not appropriate to identify a minimum density or range of densities within the policy. The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitate schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area. In addition, the SWLP will need to recognise the impact of the inclusion NDSS, open space and green infrastructure policies will have a density. NDSS compliance schemes result in larger property types, reducing the density of developments. Incorporating a significant amount of green space on schemes and biodiversity net gain measures is also likely to reduce net developable areas beyond those previously achieved. The proposed allocations need to be of a sufficient size to accommodate green and blue infrastructure whilst having realistic density assumptions.
Q-D2 – Please select a design code option which is appropriate for South Warwickshire It is our view that a single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. It is our view that the most appropriate approach would be to include policy guidance within the site specific allocation policies where appropriate making it clear how the allocations are expected to respond to their surroundings. If necessary, design codes could also be produced for specific settlements and locations that have a particular design issues that need addressing.
Q-D2: Please select all options which are appropriate for South Warwickshire Option D2d: None of these 2.74. While Design Guides can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable in a local authority area, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design perspective since they can give rise to homogeny. 2.75. The Respondent would also caution against the preparation of design guides for numerous different areas, which would seem an overly complex approach. 2.76. If the Councils decide to proceed with the preparation of design guides or codes for specific places, then it is considered imperative that these are publicly consulted on. 2.77. If intended to be used as policy rather than flexible guides, then Design Guides must be brought forward as Development Plan Documents (DPD) and independently examined given the implications that they could have on the viability and delivery of development. Q-D3: Please select all options which are appropriate for South Warwickshire Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. 2.78. The Respondent is not convinced that a policy that prescribes densities is entirely necessary and considers Options D3c and D3d to be unduly complex. However, it is acknowledged that density does need to be optimised in accordance with Paragraph 141 of the NPPF if Green Belt release is to be justified. Considering the options therefore, the Respondent would suggest the inclusion of a policy that is in line with Option D3a but which is perhaps supplemented with explanatory supporting text with regards to the sort of density ranges that developments should be aiming for depending on their location, accessibility and context.
Q-D2: As per earlier comments Paragraph 124 of the NPPF sets out that planning policies should support development that makes efficient use of land. Moreover Paragraph 127 states that area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate; however we would caution against an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-D3: As above, the NPPF states that area based character assessments, design guides and codes and masterplans can be used to help achieve well-designed places which make efficient use of land. We would suggest that density ranges can be suitable in signalling what type of development the Council would expect to see in certain areas however we would caution against not providing any flexibility in the ranges to allow for specific circumstances. The aim should be to optimise sites.
Question D3: Please select all options which are appropriate for South Warwickshire • Option D3d: Identify appropriate density ranges for different locations/areas across South Warwickshire based upon accessibility and potential accessibility of these places. Specifically, NPPF para 125 is clear that it is “especially important that planning policies and decisions avoid homes being built at low densities”. It also states the following: “a) plans should contain policies to optimise the use of land in their area and meet as much of the identified need for housing as possible. This will be tested robustly at examination, and should include the use of minimum density standards for city and town centres and other locations that are well served by public transport. These standards should seek a significant uplift in the average density of residential development within these areas, unless it can be shown that there are strong reasons why this would be inappropriate; b) the use of minimum density standards should also be considered for other parts of the plan area. It may be appropriate to set out a range of densities that reflect the accessibility and potential of different areas, rather than one broad density range; and” For example, land off Rumbush Lane is highly accessible given its location adjacent to Earlswood railway station. The proposals also include a mixed use village centre to enhance the sustainability of the site. Furthermore, NPPF para 154 relating to climate change adaptation and mitigation (a key overarching principle of the SWLP) sets out new development should reduce greenhouse gas emissions via its location. This can be made possible by increasing densities around Earlswood railway station which is an efficient, safe and accessible means of transport with a low impact on the environment.
Q-D.2 - Please select all options which are appropriate for South Warwickshire: 1) Option D2a: Develop a South Warwickshire Design Guide 2) Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an ‘area’ in the case of a new settlement) where the spatial strategy identifies significant change. 3) Option D2c: Develop design guides/codes for strategic development sites/locations. It would be onerous to produce design guides or design codes for specific places or strategic development sites through the Local Plan process. In line with the anticipated Levelling Up and Regeneration Bill and the requirement for Local Authorities to produce whole area design codes, it would be prudent for the Council to produce a South Warwickshire Design Guide. It need not cover every aspect of design or every type of development. There is then the option for site specific design codes to be produced for large scale strategic sites through the application process. Option D2a would therefore be preferred. Q-D3 - Please select all options which are appropriate for South Warwickshire: 1) Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. 2) Option D3b: Include a policy which specifies a minimum density requirement across South Warwickshire, whilst emphasising that the minimum may be exceeded. This minimum could for example be set at a similar level to the existing policy in Warwick District - i.e. minimum 30d.p.h. 3) Option D3c: Identify appropriate density ranges for different locations /areas across South Warwickshire and specify these ranges in policy. These ranges could be based upon the prevailing characteristics of existing places. 4) Option D3d: Identify appropriate density ranges for different locations/areas across South Warwickshire based upon accessibility and potential accessibility of these places. 5) Option D3e: None of these Option D3a is the best option here. Any policy on density will need to be flexible enough to be able to adapt to the different needs of each site and location. It is too onerous to specify density ranges on a location or area basis, therefore in policy terms it is enough for policy to highlight the relevance and importance of density and acknowledge that it may change on a site-by-site basis. Q-D5 - Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? Heritage is obviously an important consideration when looking at the growth strategy and deciding on draft allocations, however it is important to remember that other factors such as sustainability and the level of public benefit brought by a site can outweigh any heritage harm, particularly where such harm can be mitigated through design principles. It is too straight forward to base plan allocations heavily on heritage impact. The Part 1 Plan should continue with high-level strategic policies but should include draft allocations for strategic site such as Clopton Quarter. This would be informed by the further evidence base to be prepared including the Green Belt review. On a site-specific basis, Clopton Quarter is located on a key entrance to the historic town. As shown on the masterplan and within the vision document, and by our award-winning developments elsewhere (see Houlton and Leicester Forest East), Davidsons are committed to creating exemplary frontages which respect and enhance the immediate location.
As a member of the Stratford Society which aims to protect the heritage of our historic market town, and to support development which maintains its health and prosperity for the benefit of those in South Warwickshire who live in and around it. I believe that Stratford’s economic wellbeing depends on a combination of respect for the past and appropriate development to meet the needs of the future. It is the very nature of Stratford-upon-Avon, in terms of its Heritage assets and open spaces, that encourage people to want to live there or come to the town as visitors. Contrary to the implication in the Consultation document, this appeal is not confined to Shakespeare’s Birthplace and the RSC. I suspect that is a minority draw to the town. Rather it is the historic appeal of the many old buildings along the Historic Spine between the Birthplace and Holy Trinity Church, and the delightful aspect of its riverside setting, offering peace and tranquillity. This is beneficial to the physical and mental health of residents and visitors alike. At all costs, this must be safeguarded, while not forgetting that it also brings economic benefits to the town’s hotels, restaurants and shops. The service sector may exist because of the Shakespeare connection but thrives on those drawn to the town as a destination in its own right
Q-D2: As per earlier comments Paragraph 124 of the NPPF sets out that planning policies should support development that makes efficient use of land. Moreover Parag raph 127 states that area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate; however we would caution agains t an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-D3: As above, the NPPF states that area based character assessments, design guides and codes and masterplans can be used to help achieve well-designed places which make efficient use of land. We would suggest that density ranges can be suitable in signalling what type of development the Council would expect to see in certain areas however we would caution against not providing any flexibility in the ranges to allow for specific circumstances. The aim should be to optimise sites.
Issue D1: Strategic design principles Q-D1.1 Yes, the components listed (comprehensive development; attractiveness; sensitive to context; distinctiveness; connectedness; safety; environmental sustainability and adapting to climate change and; mix and amount of development) are considered to be an appropriate range of topics for a strategic design policy. The proposed content aligns with chapter 12 – achieving well-designed places of the NPPF as is currently worded. Proposed amendments to the NPPF currently under consultation strengthen the importance of good design. Issue D2: Design Codes and design guides Q-D2. We consider that the high level principles of good design could be contained within a suitably worded policy within Part 1 of the Plan which could relate to the whole of the South Warwickshire geographical area – there may be limited merit in doing so however, as expectations are already set out within the National Design Guide and National Model Design Code – for part 1, generally then, it may be sufficient to refer to the Framework and the National Design Guide requiring applicants to demonstrate compliance with. To ensure that design guides/design codes respond to local characteristics, it is essential in our view that these are prepared on an area (if a group of settlements share common features) or individual settlement basis. The design codes/guides should ideally be formulated over time, with input from all key stakeholders including local residents and business owners as well as technical and environmental personnel from both the private and public sector to ensure that these guides will be robust in their assessment of the character and what would be acceptable in terms of visual and environmental (to capture effects of climate change and so on) and deliverable from a developer point of view. Due to the nature of the above; being a collaborative exercise, which will take time, it is considered that the finer detail required to produce such codes, should be required at a later stage of the local plan – either within Part 2, and specific to new allocations proposed, or following adoption, when new sites are confirmed, where a site specific design code/guide could be required. The use of site wide design codes for new allocations is supported, provided there is proper consultation with relevant council departments at both District and County to avoid problems post adoption. Cerda has experience with a site in Warwick which has an adopted site wide design code (which was prepared following a series of workshops with key stakeholders and relevant officers from both the District and County, submitted and approved via a discharge of condition attached to the outline consent). It was very prescriptive in terms of layout, design, materials, car parking spaces, public open space, connectivity and so on, even down to the widths of roads and pavements which would be expected for the main spine road, primary, secondary and tertiary roads. Whilst this code enabled the applicants to prepare reserved matters applications to a set of agreed principles, which the District (planning officer) confirmed they were supportive of; we were significantly delayed by the repeated objections from the County Highways officer who maintained concerns over highway safety and general layout of tertiary roads. This was despite apparently having provided comments on the proposed design code before it was approved. This situation left the District in a difficult position - the Code has been approved and therefore has considerable status in planning terms – to satisfy highways, tertiary roads were re-designed – to appear more engineered and to have footways on both sides – which is contrary to the design code – the engineered appearance significantly detracts from the intended character of these streets. Despite many discussions to try to persuade Highways and to remind them that they were involved with the production of the Code – it was easier to amend the proposals than to continue to argue. In addition to this, tertiary roads have been approved (as per the Design Code) with block paving. We have now received objection to use of block paving and a particular kerb height (again specified within the code) from the Technical Team. We are categorically being told that these materials will NOT receive technical approval. Initial discussions with the District (to try and resolve) have not progressed as the technical team have suggested the use of black tarmac and high kerbs is the only solution – this would fundamentally change the nature of the tertiary roads and character areas in which they are located. This would be across the whole development consisting of 900 dwellings. The planning officer is not keen to support as cumulatively, this change would adversely impact on the appearance of the whole of the development – contrary to the adopted Site Wide Design Code. For any design code to be acceptable therefore, it is critical that the correct officers, statutory and non-statutory consultees and other key stakeholders are consulted on and their views properly taken into account before adoption to avoid similar problems again. Whilst laudable, if any document is adopted without concerns or objections being addressed, it can cause a significant delay to the granting of permission for schemes, which will ultimately affect their deliverability. Issue D3: Designing adaptable, diverse and flexible places Q-D3a. We consider that option a – to include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire is the most appropriate option. This would allow a greater flexibility to be considered for individual sites as they come forward for development. There will be a need to take into account the character of the surroundings and density is just one element of this. Issue D4: Safe and attractive streets and public spaces Q-D4.1 Yes. We agree that the range of topics listed is appropriate for a policy on the design of safe and attractive streets. Issue D5: Protecting and enhancing heritage assets Q-D5: Should we continue with the approach to include a high-level strategic policy within Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detail policies to Part 2? Yes. The NPPF advises that plans should set out a positive strategy for the conservation and enjoyment of the historic environment
Q-D2: Please select all options which are appropriate for South Warwickshire L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the Land at Warwick Road, Kenilworth development during the preparation of the outline planning application, following the adoption of the South Warwickshire Local Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129. Therefore, L&Q Estates are supportive of Option D2c: Develop design guides/codes for strategic development sites/locations, particularly as the planned public engagement will ensure the design of spaces and buildings will be appropriate and will respond to local context and identified needs in terms of size, type and tenure. The Vision Document demonstrates that much work has already been undertaken into achieving a well-designed neighbourhood. Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? L&Q Estates agree that a high-level strategic policy that seeks to protect and enhance existing heritage assets should be included within the Part 1 plan, in accordance with Paragraph 190 of the Framework. Detailed heritage policies should be deferred to Part 2. An initial appraisal of the extent and nature of known heritage assets within the Site and the surrounding area has been undertaken and summarised within the Vision Document accompanying these written representations. The Site contains the Grade II Listed Wootton Grange Farmhouse, which is located to the south west of the site. It is also considered that the site is within the setting of the Leek Wootton Conservation Area to the south. The initial assessment of heritage impact considers that the mid-to-late nineteenthcentury agricultural structure of Wootton Grange Farmhouse is of low heritage significance and, subject to appropriate mitigation, is not considered a constraint to development. Indeed, it is proposed to retain the large arable field to the south of the Site (within which the Farmhouse is located) and to provide a large landscape buffer between the field and built development in the northern half of the site. Accordingly, it is considered that the proposed development at land at Warwick Road, Kenilworth will not impact harmfully on the ability to experience the Grade II Listed Wootton Grange Farmhouse or to understand or appreciate its significance, as the development will have very limited impact upon the ‘openness’ of the area and the view through to the Farmhouse and to the Conservation Area further to the south.
Q-D3: Please select all options which are appropriate for South Warwickshire 56. Spitfire would welcome a flexible approach to density in new development, which is consistent with national policy which states that Council’s should avoid unnecessary prescription or detail, and should set out their own approach to housing density to reflect local circumstances (paragraphs 123 of the NPPF).
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Persimmon therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
ISSUE D1: STRATEGIC DESIGN PRINCIPLES ISSUE D2: DESIGN CODES AND DESIGN GUIDES Q-D2: Please select all options which are appropriate for South Warwickshire 2.47 District Design Codes can be helpful in setting out guidance on the different character areas within the District, from the urban to the rural and include basic good urban design principles. District wide Design Guides can be by nature generic and in some instances stifle design innovation. 2.48 A more practical and informative approach to design would be through design codes for specific strategic sites and locations. Ellis Machinery would support Option D2c. ISSUE D3: DESIGNING ADAPTABLE, DIVERS AND FLEXIBLE PLACES Q-D3: Please select all options which are appropriate for South Warwickshire 2.49 The density of development has to reflect location. Higher density development would be more appropriate in built up areas, with lower densities in more rural areas. However, density of development has to be specific to the capacity of the site as well as the location to ensure that the land is most effective used. As such, Ellis Machinery would support Option D3a. ISSUE D5: PROTECTING AND ENHANCING HERITAGE ASSETS Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? 2.50 Yes, Ellis Machinery support this approach. The information that previously accompanied both the South Warwickshire and the Stratford-on-Avon Call for Site submissions has been updated to include a Heritage Note that assessed the capacity for the Site to accommodate residential development. 2.51 The Heritage Note concluded that the heritage issues related to the development of the Site for housing are extremely limited, with development likely to result in no harm to any heritage assets.