RLS3 - Conservation Areas

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Support

Royal Leamington Spa Neighbourhood Development Plan

Representation ID: 71553

Received: 05/02/2020

Respondent: Mrs Sidney Syson

Representation Summary:

I fully support these aims, but in view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 I think a requirement for electric charging points should be added to the car parking requirements.

Full text:

I fully support these aims, but in view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 I think a requirement for electric charging points should be added to the car parking requirements.

Support

Royal Leamington Spa Neighbourhood Development Plan

Representation ID: 71569

Received: 10/02/2020

Respondent: Canal & River Trust

Representation Summary:

The canal network through Warwick District has recently been designated as a conservation area, affording an additional layer of protection to the canal through the Plan area as a heritage asset. Criteria f), n) and o) all specifically reference the importance of planning applications considering the canal and how its character and setting could be affected by new development proposals and we support the inclusion of these criteria which should help to reinforce the protection currently provided through the policies of the adopted Warwick District Local Plan and through the conservation area status of the canal.

Full text:

The canal network through Warwick District has recently been designated as a conservation area, affording an additional layer of protection to the canal through the Plan area as a heritage asset. Criteria f), n) and o) all specifically reference the importance of planning applications considering the canal and how its character and setting could be affected by new development proposals and we support the inclusion of these criteria which should help to reinforce the protection currently provided through the policies of the adopted Warwick District Local Plan and through the conservation area status of the canal.

Support

Royal Leamington Spa Neighbourhood Development Plan

Representation ID: 71672

Received: 14/02/2020

Respondent: WDC Conservation and Design

Representation Summary:

With reference to Paragraph 5.1.18, we note that there are in fact only two Conservation Areas in Leamington Spa - Leamington Spa CA and the Canal CA; Lillington Road North and Lillington Village are in fact character areas 34 and 35 respectively of the Leamington Spa Conservation Area. Although these areas are physically separated from the main designated area and different in character, we understand the areas were approved via an amendment and expansion to the existing Leamington CA boundary. We also note that the Canal Conservation Area is incorrectly referred to as the ‘Canalside’ Conservation Area.

Full text:

We make the following comments on the draft policies contained within the Royal Leamington Spa Neighbourhood Development Plan (2019-2029) on behalf of the Conservation and Design team.

Policy RLS20 – Royal Leamington Spa Town Centre Shopfronts

The draft policy explains: ‘one area that has benefitted from a less controlled approach, an approach which should be fostered further is the High Street/Clemens Street area of Old Town. This area has a more varied selection of shopfronts and colours that go to help create this area’s own distinctive environment. This variety will continue to be supported’. The policy adds that ‘The RLSNDP supports the use of more creative, colourful and active frontages and signage on these shopfronts to develop a more distinct vibrant feel and image for Old Town.’

We would comment that this may encourage advertisements that are harmful character and appearance of the Conservation Area and we are concerned that this policy contrasts with our SPG: Shopfronts and Advertisements for Leamington Spa. This guidance explains specifically for the High St, Clements St and Bath St area that the Council wishes to retain the local character and identity of this area and ‘expects new or replacement shopfronts to be designed to reinforce those particular features and characteristics… they should be of scale appropriate to the building’. Importantly, this guidance is clear in that it states provisions for advertisements here should be similar to the approach applied in Warwick St/Regent St, with illumination and signage at fascia level not permitted.

The wording of this policy may also give rise to inappropriate signage that has a detrimental effect on the scale, proportions and character of historic buildings in these locations, whilst inadvertently giving the impression that premises with existing, unauthorised signage is acceptable.

Policy RLS3 – Conservation Areas

With reference to Paragraph 5.1.18, we note that there are in fact only two Conservation Areas in Leamington Spa - Leamington Spa CA and the Canal CA; Lillington Road North and Lillington Village are in fact character areas 34 and 35 respectively of the Leamington Spa Conservation Area. Although these areas are physically separated from the main designated area and different in character, we understand the areas were approved via an amendment and expansion to the existing Leamington CA boundary. We also note that the Canal Conservation Area is incorrectly referred to as the ‘Canalside’ Conservation Area.

Support

Royal Leamington Spa Neighbourhood Development Plan

Representation ID: 71677

Received: 17/02/2020

Respondent: Spitfire Bespoke Homes Ltd

Agent: Pegasus Group

Representation Summary:

As per Spitfire’s previous representations, the intent of Policy RLS3 as drafted is not contested but the wording of the policy departs from Framework and statutory guidance on the treatment of heritage assets in the way it is worded. It is still suggested that the policy should be reworded to be consistent with Framework guidance in this respect.
Specifically, in addition to referencing the need to assess impact of a development on the significance of the heritage asset, it also indicates that there should be an assessment of the impact on the significance of the asset’s setting. This is not the correct approach.
‘Setting’ is not a heritage asset. Its value is in the contribution it makes to the significance of the asset itself, and the policy should be amended to reflect this. The policy should be clear that the assessment criteria listed within the policy, should be applied in terms of any assessment of the asset’s significance, and are not required to be applied to an assessment of the setting of the asset.
With regard to the criteria of the policy the following detailed matters are raised;
a) ‘…creates a sense of unity…’; it is unclear the sense in which this would be applied. The implication is that only development which mirrors or provides a pastiche of the existing architectural styles of the conservation would be acceptable. However, well designed modern buildings, constructed using materials of appropriate quality, may also have a role within the Conservation Area. Sometimes, buildings which are of their time, and clearly separate out the temporal development of an area, can be appropriate and the policy should recognise this.
e) ‘…retention of existing gardens…’; the policy refers to the retention of existing gardens, yet policy RLS1 recognises that the loss of gardens is acceptable, if made within the context of strategic Local Plan Policy H1. That policy states that garden loss will be acceptable, where it ‘reinforces, or harmonises with, the established character of the street and/or locality…’ Criteria e) should be amended to reflect Policy PSL1 and strategic Local Plan policy H1, both of which accept the loss of residential gardens subject to demonstration of design criteria. If the reference to ‘gardens’ is to the more formal public gardens of Leamington, as protected through draft Policy RLS8, then the policy should make this explicit.
f) Criteria f combines in a single policy tests for treatment of both designated and non-designated heritage assets, whereas statute and Framework guidance treat them both separately and subject to different assessment criteria. It is suggested that the policy be split into two, and that the tests proposed to the different assets be consistent with that contained in the Framework.
g) As with criteria e) the policy should be clearer as to the type of gardens it is seeking to retain. If the policy is simply replicating the protection afforded by draft Policies RLS8 and RLS9, then it is unnecessary and should be deleted.
j) The cross-reference to Policy RLS21 should be corrected to refer to RLS20.
m) ‘Proper evaluation…’; the terminology of the Framework para 189 is ‘appropriate’ assessment, and this should be the terminology followed here.
n) The policy would benefit from clarification of the phrase ‘key views’. Is it the intent of the policy that any development proposal should be accompanied by a site specific assessment of whether such views exist, or are there existing ‘key views’ of principle buildings and assets which specifically are looking to be protected? The policy should be re-worded to provide greater clarity as to what is desired.

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