Issue and Options 2023

Yes

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.

Nothing chosen

Issue V1: Vision for the Local Plan Historic England is pleased to see that the proposed Vision now encompasses heritage within a new overarching principle on design and beauty. Issue V3: Strategic Objectives Historic England welcomes the addition of a specific objective relating to protecting and enhancing the heritage and cultural assets of the area. However, we suggest that the word ‘protecting’ is amended to ‘conserving’, to better reflect the wording of the NPPF.

In relation to the ‘Sustainability Appraisal of the South Warwickshire Local Plan -Main SA Report’ Historic England welcomes the inclusion of Objective 5: Cultural Heritage, which encompasses the protection, enhancement and management of sites, features and areas of archaeological, historical and cultural heritage importance. In terms of datasets included in the ‘Cultural Heritage Assessment Methodology’ at Table 2.6 of the SA Report, we suggest that the HER is also utilised. We note that the SA Report was prepared in advance of the Heritage and Settlement Sensitivity Assessment being available, and we would therefore suggest that this study, and any further heritage evidence, is fully utilised when the SA is revisited. Historic England understands that at the Issues and Options stage of a Local Plan detailed locational information is not available and that the ability to identify precise effects is challenging. However, we note that all of the growth options include settlements with historic assets and that the effects of new development on the historic environment will be dependent, in part, upon the specific location, layout and design of development, and also on any mitigation and enhancement, which is an unknown at this stage in the Plan process. We would therefore agree with the assessment of ‘Uncertain Impact’ (+/-) for Objective 5 Cultural Heritage in relation to Options 1-4, as presented in Table 7 of the Issues & Options document – ‘High level sustainability appraisal of Spatial Growth Options’. However, we also note that a ‘Minor Positive Impact’ has been assessed for Option 5 Dispersed. Given that many of the settlements included within Option 5 have not been assessed in relation to heritage impacts, we consider that this option should also be determined as having an ‘Uncertain Impact’ on Objective 5 at this current plan stage. In relation to the need for further heritage evidence to inform Option 5, further comments are provided below under ‘Issue S7: Refined spatial growth options.' To assist with your preparation of the SA in relation to the assessment of effect upon the historic environment we refer you to Historic England’s Advice Note 8: Sustainability Appraisal and Strategic Environmental Assessment, 2016 (HEAN8): Historic England Advice Note 8: Sustainability Appraisal and Strategic Environmental Assessment

Issue S1: Green & Blue Corridors Whilst Historic England is supportive of the identification of Green and Blue Corridors, we consider that the Local Plan should also recognise the value of the historic environment in contributing to the multi-functionality of these corridors via cultural heritage, recreation and tourism, through assets such as historic parks, gardens and canals. Issue S2: Intensification Historic England promotes positive and proactive approaches to heritage within design and planning frameworks and is therefore supportive of Design Codes to inform development and densities within particular areas. These can be useful tools to encourage heritage assets to be embraced within development to make contributions and enhancements to new environments. Issue S4: Growth of Existing Settlements As part of the evidence base to inform the spatial strategy Historic England is pleased to see that a ‘Heritage and Settlement Sensitivity Assessment’ has been undertaken for some settlements across South Warwickshire to assess the sensitivity to new development on the existing heritage and landscape character. Whilst this is a good starting point to assess the potential for growth of certain settlements, we consider that it should be used as an initial filtering, with those with potential for development being assessed further. Further assessment work should include consideration of historic settlement character and also of non-designated heritage assets that are not recorded on the HER that may contribute to historic character of settlement, which can be identified through the use of LiDAR. Therefore, we specifically suggest further consideration of: • Character of the historic core of settlements and how new development could sustain character and any significance it derives from its setting - Bearley is a good example, as to the north of Snitterfield Road an area of ridge and furrow contributes to the immediate setting of the historic core and we therefore suggest that the scope for new development should be located north or west of Grange Road. Sense of place is also important to inform how new development may sustain or enhance – Henley-in-Arden being a good example of this, as although a north-east extension has been ruled out, the prominence of castle views and linearity of settlement probably mean that extensions to the north-west and south-east would present significant heritage challenges too. • Capacity for a settlement to accommodate new development. Even 50 homes in a small settlement could have a big impact on character – Beausale is a good example of this, as it is a dispersed settlement and any concentration of development would impact that character and therefore Beausale would be better suited to individual piecemeal developments. • Unrecorded archaeology on LiDAR. For example, much ridge and furrow is unrecorded, but contributes greatly to the character of historic settlements and the landscape in this area. Therefore, development on areas of ridge and furrow should be avoided wherever possible. We also consider that further work on characterisation for Stratford-upon-Avon would be helpful, as the assessment describes at some length where the designated heritage assets are but makes no clear distinction between what has been built and the consents which are still being built out. In relation to the consideration of which direction the settlement should be allowed to expand, assessment of the impact of the recent and approved expansion of the town and how that affects the overall character of Stratford should be considered. Consideration should therefore be given to the overall impact of future development on the ‘experience’ of the place: the word used in the NPPF definition of setting of a heritage asset. We also suggest that the description of the development of the town could be further improved by including the key contribution of tourism since the 18th century to the town’s prosperity, so that the description reflects the essence of what that represents in terms of the experience. In relation to Kenilworth, we consider the assessment to be a little stronger on the overall setting of the place. However, although the assessment rules out expansion to the south-east, developing to the east would also need to consider Stoneleigh Park Registered Park and Garden and the Roman Scheduled Monument, whereas development to the south-west is likely to impact on the deer park of Kenilworth Castle (if located to the west of Rouncil Lane) and therefore impact on the significance of the Scheduled Monument and Registered Park. Additional general comments on the heritage assessment include that the keys to the maps use the correct labelling for listed buildings (Grades II, II* and I) whereas the text consistently refers to them using Arabic numerals and should be amended. Further comments on the ‘Heritage and Settlement Sensitivity Assessment’ in relation to specific growth options are set out below under ‘Issue S7: Refined spatial growth options’. Issue S5: The potential for new settlements We note that Table 6 – ‘Summary of potential locations for a new settlement’ includes Conservation Areas, but no other heritage designations such as Scheduled Monuments (SM), Listed Buildings or Registered Parks and Gardens (RPG). Historic England advises that heritage evidence will be required in relation to the selection of any of these locations for a new settlement and that this should include consideration of the impact on both designated and non-designated heritage. In relation to the potential locations for new settlements, we consider that location C1 Kingswood/Lapworth is especially sensitive, given that it lies between the Grade I Packwood House and Grade II* RPG to the west and the Grade I Baddesley Clinton House and Grade II RPG and SM to the east, both with many other Grade II listed buildings and structures also present. The area is also characterised by canal infrastructure and just to the south of the settlement of Kingswood is the junction of the Grand Union Canal and the Stratford-upon-Avon Canal, with a number of listed structures associated with the canals, such as locks, bridges and cottages. Historic England would therefore have concerns about the impact on the historic environment of a new settlement of around 6,000 dwellings in this location. Issue S7: Refined spatial growth options Historic England notes that some locations/settlements within certain growth options have not been assessed in relation to heritage or settlement sensitivity and some of the smaller settlements may indeed be ruled out for further development once a heritage assessment has been undertaken. For example, King’s Hill, South of Coventry, is included within Options 1, 2 and 4, but development here is likely to impact on the setting of a medieval settlement Scheduled Monument. In addition, Option 5, ‘Dispersed’, includes many smaller settlements, some of which have a considerable wealth of both designated and non-designated heritage assets. In relation to some of these smaller settlements change of the amount indicated is likely to have an effect on historical character and assets and we recommend that any significant growth at the following settlements is avoided: Great Walford, Lower Shuckburgh, Priors Hardwick, Sherbourne, Wappenbury and Wormleighton. Other settlements included in Option 5 were we have particular concerns regarding potential impacts on Scheduled Monuments and where integrating new development is likely to present challenges due to impact on the historic environment are as follows: Alcester, Aston Cantlow, Baginton, Beausale, Brailes, Bubbenhall, Butlers Marston, Farnborough, Halford. Hampton Lucy, Henley-in-Arden, Honington, Kenilworth, Long Itchington, Stoneleigh, Stretton-on-Fosse, Tiddington, Tredington, Wasperton and Whichford. For other settlements further detailed assessments to inform impacts on the historic environment are advised. These include Fenny Compton, where there is evidence of a medieval settlement that would be of regional significance; Harbury, Napton-onthe-Hill, Quinton and Tysoe, which all have surviving ridge and furrow. Therefore, if Option 5 is taken forward we would recommend that a heritage assessment exercise (to include consideration of HER & LiDAR data and historic settlement capacity/form) is undertaken and that the views of your chosen specialist archaeological adviser are sought at an early stage. Issue S9: Settlement Boundaries and infill development Historic England recommends that any consideration of the alteration of existing settlement boundaries should include assessment of the potential impact of the proposed alterations in respect of the historic environment. The Local Authority will need to be satisfied that it has fully considered the implications of proposed alterations to settlement boundaries in terms of the potential impact on designated and nondesignated heritage assets in its assessment work as the Plan progresses.

Issue S3: Using Brownfield Land for Development Historic England supports the sustainable re-use of land but would stress that the impact of brownfield development on the significance of heritage assets should be taken into account throughout the preparation of the local plan. We note that the Urban Capacity Study has defined character areas for a number of settlements utilising GIS data on historic buildings and conservation areas, amongst other data sets. With regard to the re-use of existing buildings we consider that the plan should recognise sustainability over the long-term. Historic buildings represent a significant investment of expended energy and demolishing and replacing them requires a major reinvestment of embodied energy and other resources. The local plan should therefore encourage and recognise the benefits of sympathetic restoration, retention, refurbishment and retrofitting of historic buildings.

Issue E6: Protecting South Warwickshire’s economic assets (incorrect title on page 85: Core Opportunity and Major Investment Sites) Historic England notes that a number of heritage assets are included within the list of ‘Unique economic assets in South Warwickshire’ and are therefore protected under heritage legislation and the guidance contained within the NPPF. Whilst we are aware that heritage can be utilised as a way of strengthening the economy, economic growth should be balanced against protecting and enhancing the historic environment in order to achieve sustainable development through the three interdependent overarching economic, social and environmental objectives set out in the NPPF (para.8). Issue E9: Supporting our Changing Town Centres Historic England recognises the important role of town centres in the economic, social and cultural well-being of an area. We therefore consider that Local Plans should promote their long-term vitality and viability through policies to encourage the restoration of disused and dilapidated historic buildings into new homes, shops, workplaces and community spaces, restoring local historic character and improving public realm. Issue E10: Tourism Historic England recognises the significant role that tourism plays in the economy of South Warwickshire and is supportive of the Local Plan helping to create the conditions for a thriving heritage and cultural sector. Given the importance of tourism in the area we consider that it plays a spatially strategic role and therefore should be addressed in Part 1 of the Local Plan and not left to be addressed in Part 2.

No

Historic England welcomes that the impact on historic assets and landscape are included as criteria against which schemes for solar and wind power should be considered. If the SWLP does choose to allocate land for these forms of renewable energy generation, then, in the same way as for housing or employment allocations, we advise 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), to ensure to ensure that the plan is positively prepared.

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Issue C5: Existing Buildings We welcome the acknowledgement of Historic England’s advice on the re-use of existing buildings and the links to our relevant webpage. In terms of Option C5b, whilst Historic England supports measures to tackle climate change, retrofitting of renewable technologies on historic buildings can be more challenging and we would recommend reference to our latest advice on this subject: https://historicengland.org.uk/advice/technical-advice/retrofit-and-energy-efficiencyin-historic-buildings Issue C6: Whole Life-Cycle Carbon Emission Assessments Historic England recommends the use of ‘Whole Life-Cycle Carbon Emissions Assessments’ as a means of reducing embodied emissions. Reference should also be made to the importance of regular building maintenance, as the benefits of caring for and re-using historic buildings can lead to energy savings and a reduction in carbon emissions.

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Historic England supports the use of ‘Climate Change Risk Assessments’ as a means of determining how a development is likely to be affected by climate change. This in turn will inform which measures would be appropriate to mitigate and adapt to these effects and will be helpful in deciding on a specific course of action for historic buildings.