Testun llawn:
We are concerned that insufficient assessment has been undertaken of the impact that the development of these proposed sites could have upon the historic environment. These impacts could include direct impacts upon archaeological sites, impacts upon the historic landscape character of the proposed sites and their wider vicinity, and any impacts upon the settings of any heritage assets within the wider vicinity of the proposed sites.
Of particular concern is that two sources of information which would provide relevant data, the Warwickshire Historic Environment Record (HER) and the English Heritage funded Historic Landscape Characterisation (HLC) project, do not appear to have been consulted during the shortlisting of these proposed sites.
In addition, as noted in our previous responses to the earlier Options paper of July 2008, the 2009 Proposed Submission Core Strategy and the 2012 New Preferred Options consultation, there will also be archaeological sites as yet undiscovered which will not be recorded on the HER, and even in areas where no archaeology has been recorded, evaluation may be required to confirm the presence/absence of remains. Consultation on a site by site basis will remain the best means of identifying archaeologically sensitive areas on the basis of current knowledge, as well as areas where archaeological potential will need to be assessed through more detailed work. On the other hand, the programme of HLC just concluded means that we have now been able to develop a more consistent understanding of this particular aspect of the historic environment across the District. There is now a developing methodology for identifying Historic Environment Character Zones which integrates the data from HLC with the site-specific data on particular monuments recorded in the Historic Environment Record; other authorities have found this type of study a useful tool for spatial planning.
We recommend that further work be undertaken in order to identify any potential issues in respect of the historic environment.
This should assess any potential impacts upon both designated and undesignated heritage assets.
Whilst we are concerned in principle to the selection criteria, since they do not allow for a proper consideration of Historic Environment, we do not object in principle to the majority of sites selected providing that proper appraisal is undertaken and allowance made where necessary for preservation of sites of national Importance (in the sense of the 1979 Ancient Monuments and Archaeological Areas Act and the National Planning Policy Framework).
We would be very happy to meet your strategic planning team in person to discuss our comments and recommendations whilst the Local Plan is prepared, and to contribute to any supplementary planning documents in respect of historic environment.