We broadly welcome this policy and the recognition given to buildings of townscape interest as part of a local list approach.

It is not clear whether the density targets set out in this policy have been reviewed since the adoption of the Core Strategy to establish whether they remain appropriate. High densities may be acceptable in some locations, including in the town centre, but care needs to be taken to avoid harm to heritage assets through overly dense development. The Sustainability Appraisal notes uncertainties with regards to the impact of this policy on historic environment objective ET9. The policy helpfully sets out exceptions to the general approach, and specific site allocations should provide clarity with regards to detailed design issues.

The indicators and targets for Objective 8 should be improved with regards to the historic environment. Reference to buildings at risk is welcomed, but the national register now covers all designated heritage assets on a Heritage at Risk (HAR) Register (www.english-heritage.org.uk/risk). There should be a related target to this indicator stating that the number of assets on the HAR Register should be reduced (there are currently two listed buildings and one conservation area on the HAR Register). Other indicators/targets could include the number of up-to-date conservation area appraisals and management plans, and/or the number of planning decisions made in accordance with officer / English Heritage advice (along the lines of the Sustainability Appraisal indicators).

As currently drafted, we consider the plan is unsound as it is not effective in terms of ability to adequately monitor historic environment impacts.