Regulation 19 - Proposed Draft Local Plan Submission

Further assessment work should be undertaken in respect of the aspirations of Policies DS02 and SA01 specifically in relation of Policy OA1: Policy SA02 to inform what ‘buffer’ may need to be considered in respect of the significance of the Stretton Magna SM and any potential harm from the proposed development.

Appendix 6 requirements for Policy SA02 should also include a requirement for archaeological investigations at the site due to proximity to the Roman Road and SM.

We have made a separate representation to Inset Plan 72 for the site seeking a redrawing of the boundary to exclude the SM site as a minimum, and potentially any ‘buffer’ zone that may be explored in due course and ahead of the EIP.

The site allocation for Land South of Gartree Road includes the Scheduled Monument (SM) known as Stretton Magna deserted village, two fishponds and moated site: https://historicengland.org.uk/listing/the-list/list-entry/1010201?section=official-list-entry

Whilst deserted medieval villages are a common and long-lived monument type in most parts of England, the village site at Stretton Magna is one of the best surviving examples of its type in Leicestershire.

It comprises a variety of features including extensive earthworks of the deserted village, a moated manorial site, two fishponds and part of the associated field system around the medieval St Giles Church.

The village community would have been engaged primarily with agricultural activity, a significant component of the rural landscape in most areas of medieval England, much as it is today. Whilst this fine example of a deserted village occupies two large modern fields, the surrounding open rural landscape contributes much to its significance and our understanding and appreciation of the monument today.

The proposed site allocation includes the SM site and would have the potential to cause substantial or a high level of less than substantial, harm to the nationally important designated heritage asset contrary to the provisions of the Ancient Monuments and Archaeological Areas Act 1979, the provisions of the NPPF and the Council's own extant and proposed Local Plan policies for the historic environment.

We note the information set out in the 'Heritage Analysis' document which forms part of the draft Plan's evidence base. However, the information is largely factual information rather than an assessment of potential impacts (whether harmful, neutral or beneficial) so whilst a Heritage Impact Assessment is required as part of Policy SA02 it is unclear what this may mean for the site allocation aspirations set out in Policies DS02 and SA01 (OA1) and SA02. The Sustainability Appraisal does not assist with this matter.

The site specific policy, SA02, sets out that: 'No development can take place within the Stretton Magna Deserted Medieval Village and an appropriate buffer for the enhancement and protection of this site must be provided; the area of this buffer should be informed through the Heritage Impact Assessment'.

Without any consideration of this requirement as part of the Plan process, it is not clear how any 'buffer' in respect of setting impacts has been considered as part of the Plan process. As such, the site allocation boundary may in fact need to be set further back from the SM boundaries in order meet the requirements of the NPPF, the 1979 Act and the Council's own extant and proposed heritage related Local Plan policies, in respect of considering harm to assets and any opportunities to enhance.

As such, it is not clear how the proposed development would be developable or deliverable to the quantum anticipated by the Council without harm to heritage assets. The site allocation may not meet the requirements of the NPPF in respect of plan making (para 203) or the provisions of the Ancient Monuments and Archaeological Areas Act 1979. This is of concern at this stage of the draft Plan and we would welcome opportunity to discuss with you further in due course. We have made separate representation in respect of Inset Map 72 for the allocation site as it is our view that there is no reason for the SM site to be site allocation boundary based on the requirements of proposed Policy SA02.

Further assessment work should be undertaken in respect of the aspirations of Policies DS02 and SA01 specifically in relation of Policy OA1: Policy SA02 to inform what ‘buffer’ may need to be considered in respect of the significance of the Stretton Magna SM and any potential harm from the proposed development.

Appendix 6 requirements for Policy SA02 should also include a requirement for archaeological investigations at the site due to proximity to the Roman Road and SM.

We have made a separate representation to Inset Plan 72 for the site seeking a redrawing of the boundary to exclude the SM site as a minimum, and potentially any ‘buffer’ zone that may be explored in due course and ahead of the EIP

The site allocation for Land South of Gartree Road includes the Scheduled Monument (SM) known as Stretton Magna deserted village, two fishponds and moated site: https://historicengland.org.uk/listing/the-list/list-entry/1010201?section=official-list-entry

Whilst deserted medieval villages are a common and long-lived monument type in most parts of England, the village site at Stretton Magna is one of the best surviving examples of its type in Leicestershire.

It comprises a variety of features including extensive earthworks of the deserted village, a moated manorial site, two fishponds and part of the associated field system around the medieval St Giles Church.

The village community would have been engaged primarily with agricultural activity, a significant component of the rural landscape in most areas of medieval England, much as it is today. Whilst this fine example of a deserted village occupies two large modern fields, the surrounding open rural landscape contributes much to its significance and our understanding and appreciation of the monument today.

The proposed site allocation includes the SM site and would have the potential to cause substantial or a high level of less than substantial, harm to the nationally important designated heritage asset contrary to the provisions of the Ancient Monuments and Archaeological Areas Act 1979, the provisions of the NPPF and the Council's own extant and proposed Local Plan policies for the historic environment.

We note the information set out in the 'Heritage Analysis' document which forms part of the draft Plan's evidence base. However, the information is largely factual information rather than an assessment of potential impacts (whether harmful, neutral or beneficial) so whilst a Heritage Impact Assessment is required as part of Policy SA02 it is unclear what this may mean for the site allocation aspirations set out in Policies DS02 and SA01 (OA1) and SA02. The Sustainability Appraisal does not assist with this matter.

The site specific policy, SA02, sets out that: 'No development can take place within the Stretton Magna Deserted Medieval Village and an appropriate buffer for the enhancement and protection of this site must be provided; the area of this buffer should be informed through the Heritage Impact Assessment'.

Without any consideration of this requirement as part of the Plan process, it is not clear how any 'buffer' in respect of setting impacts has been considered as part of the Plan process. As such, the site allocation boundary may in fact need to be set further back from the SM boundaries in order meet the requirements of the NPPF, the 1979 Act and the Council's own extant and proposed heritage related Local Plan policies, in respect of considering harm to assets and any opportunities to enhance.

As such, it is not clear how the proposed development would be developable or deliverable to the quantum anticipated by the Council without harm to heritage assets. The site allocation may not meet the requirements of the NPPF in respect of plan making (para 203) or the provisions of the Ancient Monuments and Archaeological Areas Act 1979. This is of concern at this stage of the draft Plan and we would welcome opportunity to discuss with you further in due course. We have made separate representation in respect of Inset Map 72 for the allocation site as it is our view that there is no reason for the SM site to be site allocation boundary based on the requirements of proposed Policy SA02.

Further assessment work should be undertaken in respect of the aspirations of Policies DS02 and SA01 specifically in relation of Policy OA1: Policy SA02 to inform what ‘buffer’ may need to be considered in respect of the significance of the Stretton Magna SM and any potential harm from the proposed development.

Appendix 6 requirements for Policy SA02 should also include a requirement for archaeological investigations at the site due to proximity to the Roman Road and SM.

We have made a separate representation to Inset Plan 72 for the site seeking a redrawing of the boundary to exclude the SM site as a minimum, and potentially any ‘buffer’ zone that may be explored in due course and ahead of the EIP.

The site allocation for Land South of Gartree Road includes the Scheduled Monument (SM) known as Stretton Magna deserted village, two fishponds and moated site: https://historicengland.org.uk/listing/the-list/list-entry/1010201?section=official-list-entry

Whilst deserted medieval villages are a common and long-lived monument type in most parts of England, the village site at Stretton Magna is one of the best surviving examples of its type in Leicestershire.

It comprises a variety of features including extensive earthworks of the deserted village, a moated manorial site, two fishponds and part of the associated field system around the medieval St Giles Church.

The village community would have been engaged primarily with agricultural activity, a significant component of the rural landscape in most areas of medieval England, much as it is today. Whilst this fine example of a deserted village occupies two large modern fields, the surrounding open rural landscape contributes much to its significance and our understanding and appreciation of the monument today.

The proposed site allocation includes the SM site and would have the potential to cause substantial or a high level of less than substantial, harm to the nationally important designated heritage asset contrary to the provisions of the Ancient Monuments and Archaeological Areas Act 1979, the provisions of the NPPF and the Council's own extant and proposed Local Plan policies for the historic environment.

We note the information set out in the 'Heritage Analysis' document which forms part of the draft Plan's evidence base. However, the information is largely factual information rather than an assessment of potential impacts (whether harmful, neutral or beneficial) so whilst a Heritage Impact Assessment is required as part of Policy SA02 it is unclear what this may mean for the site allocation aspirations set out in Policies DS02 and SA01 (OA1) and SA02. The Sustainability Appraisal does not assist with this matter.

The site specific policy, SA02, sets out that: 'No development can take place within the Stretton Magna Deserted Medieval Village and an appropriate buffer for the enhancement and protection of this site must be provided; the area of this buffer should be informed through the Heritage Impact Assessment'.

Without any consideration of this requirement as part of the Plan process, it is not clear how any 'buffer' in respect of setting impacts has been considered as part of the Plan process. As such, the site allocation boundary may in fact need to be set further back from the SM boundaries in order meet the requirements of the NPPF, the 1979 Act and the Council's own extant and proposed heritage related Local Plan policies, in respect of considering harm to assets and any opportunities to enhance.

As such, it is not clear how the proposed development would be developable or deliverable to the quantum anticipated by the Council without harm to heritage assets. The site allocation may not meet the requirements of the NPPF in respect of plan making (para 203) or the provisions of the Ancient Monuments and Archaeological Areas Act 1979. This is of concern at this stage of the draft Plan and we would welcome opportunity to discuss with you further in due course. We have made separate representation in respect of Inset Map 72 for the allocation site as it is our view that there is no reason for the SM site to be site allocation boundary based on the requirements of proposed Policy SA02.

Further assessment work should be undertaken in respect of the site allocation OA1/SA02 to inform what ‘buffer’ may need to be considered in respect of the significance of the SM and the site allocation boundary redrawn accordingly. As a minimum it should exclude the SM.

In addition, the Inset Map should include the location of the SM on the map legend.

Inset Map 72 includes the Scheduled Monument (SM) known as Stretton Magna deserted village, two fishponds and moated site: https://historicengland.org.uk/listing/the-list/list- entry/1010201?section=official-list-entry

The relating site specific policy, SA02, sets out that: 'No development can take place within the Stretton Magna Deserted Medieval Village and an appropriate buffer for the enhancement and protection of this site must be provided; the area of this buffer should be informed through the Heritage Impact Assessment'. As such, it is our view that there is no reason for the SM site to be included in the site allocation boundary. It is also noted that the SM is not shown on Inset Map 72.

Furthermore, the Plan has not provided any evidence base information to demonstrate how any 'buffer' in respect of setting impacts has been considered as part of the Plan process. As such, the site allocation boundary may in fact need to be set further back from the SM boundaries in order to meet the requirements of the NPPF, and the Council's own extant and proposed heritage related Local Plan policies, in respect of considering harm to assets and any opportunities to enhance.

We have made separate representations in respect of Policies OA1, SA02 and DM03.

Historic England recommends the policy title and wording is revisited to avoid repetition of the NPPF, and to clarify the intentions of the Policy, and make provision for all aspects of the historic environment, including Heritage at Risk.

Due to cross-boundary work with other Local Authorities, and conjoined work on the Land south of Gartree Road Strategic Development Area in particular, the Council may wish to consider wording proposed by Oadby and Wigston Borough Council in its Pre-Submission draft Local Plan of January 2025.

Parts 2 and 3 of the proposed policy essentially repeat NPPF requirements and we would suggest they are superfluous bearing in mind the provisions for NPPF requirements set out in Part 1 of the policy.

It is unclear what the 'design standard' element of the policy refers to. Part 4 of the draft policy makes provisions for the assessment of harm to heritage rather than design, SO it is considered the inclusion of 'design standards' is confusing. Design elements for site allocations appear to be set out in Appendix 6 of the draft Plan.

Harborough's administrative area includes a number of assets which are considered 'at risk' but there is no provision for Heritage at Risk in the policy.