Cultural Heritage

Introduction

This chapter describes the methodology followed and the potential impacts identified for cultural heritage when assessing the A75 Springholm and Crocketford Improvements (hereafter referred to as “the proposed scheme”). The assessment has been untaken in line with the Design Manual for Roads and Bridges (DMRB) LA 106 - Cultural heritage assessment (revision 1) (hereafter referred to as “DMRB LA 106”) and other relevant standards and guidance set out within this chapter.

Legislative and Policy Framework

This section provides a summary of the legislation and national policy that are relevant to this cultural heritage assessment.

Legislation

The following legislation is considered in this cultural heritage assessment.

Historic Environment Scotland Act 2014

The Historic Environment Scotland Act 2014 amends three pieces of primary legislation: The Historic Buildings and Ancient Monuments Act 1953; The Ancient Monuments and Archaeological Areas Act 1979; and, The Planning (Listed Buildings and Conversation Areas) (Scotland) Act 1997. It provides increased protection and improved management for Scheduled Monuments and Listed Buildings and sets out Historic Environment Scotland’s (HES) role as national statutory consultee for EIA projects.

Planning Advice Note (PAN) 2/2011 Planning and Archaeology

Planning Advice Note 2/2011 advises that planning authorities should take the relative importance of archaeological sites into account when determining planning applications. It also notes that the preference should be to preserve archaeological sites in situ to protect and enhance the historic environment. Where this is not possible then sites should be excavated, recorded and the results published.

Historic Environment Policy for Scotland

Historic Environment Policy for Scotland sets out a series of principles and policies for the recognition, care and sustainable management of the historic environment. It is aimed at promoting an informed and consistent approach to decision making.

The National Planning Framework 4 (NPF4), Policy 7: Historic assets and places

NPF4 Policy 7 establishes: the need for an assessment to be carried out of projects with potential to have a significant impact on cultural heritage; the need for exceptional circumstances for demolition of listed buildings, and the need to retain the character and special architectural or historic interest or setting; the need to preserve or enhance the setting of conservation areas; the need to avoid impacts on scheduled monuments; and the need to understand and retain non-designated heritage assets.

Local Policy and Plans

The following local plans and policies are relevant to this cultural heritage assessment.

Dumfries and Galloway Local Development Plan 2 (LDP2)

Dumfries and Galloway LDP2 includes policies that are directly relevant to the proposed scheme:

  • Policy HE2 sets out Dumfries and Galloway Council’s position on development affecting conservation areas. Of relevance to the proposed scheme is the requirement to maintain the quality of views from and into conservation areas.
  • Policy HE3 sets out Dumfries and Galloway Council’s position on development affecting designated and non-designated heritage assets. This includes a preference for the preservation of assets in situ, and a requirement to evaluate archaeological remains where there is uncertainty about their location, extent or significance.

In addition to LDP2, work is underway on the Dumfries and Galloway Council Local Development Plan 3 (LDP3). An Evidence Report was reviewed by the Scottish Government in December 2024, with feedback returned in April 2025. The proposed LDP3 is expected to be submitted in 2027 and adopted later that year.

Assessment Methodology

The assessment of cultural heritage assets has been undertaken in line with the DMRB LA 106.

The assigning of value has been completed in accordance with the DMRB LA 104 - Environmental assessment and monitoring (revision 1) (hereafter referred to as “DMRB LA 104”).

Assessment of potential impacts is based on Table 3.4N Magnitude of impact and typical descriptions of DMRB LA 104.

Data Sources

Data on designated heritage assets was sourced from Historic Environment Scotland Designations Map Search including Listed Buildings, Scheduled Monuments, Gardens and Designed Landscapes, Battlefields, Historic Marine Protection Areas, Conservation Areas and World Heritage Sites.

Data on non-designated heritage assets was taken from the Historic Environment Records (HER) made available on the Spatial Hub (hereafter referred to as “Spatial Hub website”) using information from Dumfries and Galloway Council.

Assumptions and Limitations

This Environmental Appraisal Report (EAR) has been compiled through desktop review, utilising a variety of sources, including secondary information derived from the HER made available on the Spatial Hub website using information from Dumfries and Galloway Council. As is proportionate for DMRB Stage 1, site visits have not been undertaken to verify the accuracy of the data.

The data held by the HER made available on the Spatial Hub website using information from Dumfries and Galloway Council, is limited to geospatial information on non-designated heritage assets, their name and type. It does not contain any specific detail of the asset.

The potential for impacts on below-ground archaeology is likely to require further assessment as the physical extent of the improvement strategies are developed at further DMRB stages. Additionally, the assessments may be refined further through a programme of investigative survey and fieldwork for the preferred route at DMRB Stage 3.

Study Area

All designated heritage assets within 1km of the improvement strategies were assessed, with additional designated assets considered on a case-by-case basis, based on professional judgement. This includes Listed Buildings, Scheduled Monuments, Gardens and Designed Landscapes, Battlefields, Historic Marine Protection Areas, Conservation Areas and World Heritage Sites.

All non-designated heritage assets within 500m of the improvement strategies were assessed, with additional non-designated heritage assets considered on a case-by-case basis, based on professional judgement. This includes archaeological remains, historic buildings and data.

The 1km and 500m study areas have been informed by DMRB LA 104 and DMRB LA 106 and are shown in Figure 6-1 and Figure 6-2 respectively.

Baseline Conditions

The locations of designated cultural heritage assets relative to the proposed scheme are shown on Figure 6.1, and non-designated cultural heritage assets are shown on Figure 6.2.

There are no designated Battlefields, Historic Gardens and Designed Landscapes, Historic Marine Protection Areas, Properties in Care or World Heritage Sites within the 1km study area.

Conservation Areas

There is one Conservation Area within the 1km study area, Kirkpatrick Durham, which is located 200m to the west of Improvement Strategy 1 and 300m west of Improvement Strategy 2.

Listed Buildings

As designated heritage assets, the Category A Listed Buildings have been assigned as high value and Category B and C Listed Buildings assigned medium value in accordance with Table 3.2N Environmental value (sensitivity) and descriptions from DMRB LA 104.

Eighty-six Listed Buildings are present within the designated assets study area. The Listed Buildings are mainly centred within Kirkpatrick Durham Conservation Area, Haugh of Urr village and Castle Douglas town. The majority of these would remain unaffected by the proposed scheme both in terms of physical impacts and also as a result of any change to their setting. High value assets located within the study area and medium value assets located within the improvement strategies are discussed below.

The following Category A Listed Buildings are present within the designated assets study area or included in the baseline based on professional judgement:

  • Haugh Bridge (LB16807) located in the Haugh of Urr, approximately 350m north-west of Improvement Strategy 6.
  • Watermill, Old Bridge of Urr (LB10191) located in the Old Bridge of Urr, approximately 220m west of Improvement Strategy 1.
  • Greenlaw House (LB3708) located north-west of the town of Castle Douglas, approximately 1.7km west of Improvement Strategy 1.
  • Cattle Market, New Market Street, Castle Douglas (LB22976) located in the town of Castle Douglas, approximately 1.7km south of Improvement Strategies 1 and 6.

The following Category B Listed Buildings are located within Improvement Strategies 1, 3, 4 and 6,

  • Brooklands, Ornamental Walling opposite Brooklands Lodge (LB9666) located within Improvement Strategies 1 and 2.
  • Brooklands Lodge (LB9665) located within Improvement Strategies 1 and 2.
  • Drummore Farmhouse, Retaining Wall and Gatepiers (LB9714) located within Improvement Strategies1 and 6.
  • The Galloway Arms Hotel, Castle Douglas Road, Crocketford (LB16805) located within Improvement Strategy 3.
  • The Galloway Arms Hotel Annex, Castle Douglas Road, Crocketford (LB16812) located within Improvement Strategy 3.
  • The Toll Cottage, Castle Douglas Road, Crocketford (LB9669) located within Improvement Strategy 3.
  • Millhouse, Newbank Mill (LB16815) located within Improvement Strategies 3 and 4.
  • Weaving Sheds, Newbank Mill (LB16815) located within Improvement Strategies 3 and 4.
  • Spinning Mill, Newbank Mill (LB16815) located within Improvement Strategies 3 and 4.
  • Weaver’s Cottages, Newbank Mill (LB16815) located within Improvement Strategies 3 and 4.

There are no Category C listed buildings within the Improvement Strategies.

Scheduled Monuments

Scheduled Monuments have been assigned a high value in accordance with Table 3.2N Environmental value (sensitivity) and descriptions from DMRB LA 104.

There are six Scheduled Monuments within or close to the 1km study area:

  • Ernespie, two standing stones which form the remains of stone circle 200m east of Erne Hill, Castle Douglas (SM1011) located 1km south of Improvement Strategies 1 and 6.
  • Mote of Urr, a hilltop fortified site (SM1134) located 1km south-east of Improvement Strategy 6.
  • Doon Hill, Mote of Doon, Doon of Urr, a hilltop fortified site (SM1128) located 1km north-west of Improvement Strategy 1.
  • Meikle Cairn, a prehistoric funerary monument, Upper Minnydow (SM1036) located 400m North-west of Improvement Strategy 1.
  • Green Island fort, an earthwork fort on a promontory by Milton Loch (SM1074) located 210m south of Improvement Strategy 5.
  • East Hill Farmhouse stone circle (SM1022) located 1.7km south-east of Improvement Strategies 1 and 6.

Non-Designated Historic Buildings

There are 127 non-designated historic buildings within the 500m study area surrounding the DMRB Stage 1 Assessment Corridor. Forty of the assets are ‘buildings’, this includes 23 farmsteads and farmhouses which is expected considering the rural location of the proposed improvement strategies. The assets have been assigned a value of low in accordance with DMRB LA 104.

Non-Designated Archaeological Remains

There are 66 non-designated archaeological remains within the 500m study area including crannogs, burnt mounds, a military road, cairns and enclosures. The assets have been assigned a low or negligible value in accordance with DMRB LA 104.

Archaeological Potential

The available evidence indicates potential for previously unknown archaeological remains within the vicinity of the proposed scheme in areas that have not been subject to previous impact from development. Improvement Strategies 1 and 6 would likely have the greatest impact on previously unknown archaeological remains as they cover the greatest total area. As noted above, a further and more detailed assessment and investigation would be required in later stages of the proposed scheme to fully define the level of risk in relation to this matter.

Potential Impacts

Conservation Areas

There would be no physical impact on Kirkpatrick Durham Conservation Area, which is located 200m and 300m west of Improvement Strategies 1 and 2 respectively.

There would potentially be some intervisibility between Kirkpatrick Durham Conservation Area and Improvement Strategies 1 and 2, resulting in potential for visual and noise effects in its setting, during construction and operation of these improvement strategies.

Listed Buildings

A total of 10 Category B Listed Buildings are located within Improvement Strategies 1, 3, 4 and 6, and have potential to be physically impacted during construction, in the form of full or partial removal.

There would be no potential direct impacts on the Category A or C Listed Buildings. All improvement strategies have potential to result in indirect impacts on Listed Buildings within the 1km study area.

Indirect physical impacts on historic buildings during construction may include changes to groundwater levels or vibrations caused by engineering activities associated with the proposed scheme. There may be alteration to the setting of historic buildings through the removal of vegetation or associated above-ground elements during construction. Finally, temporary noise, dust, and/or visual intrusion may occur within the setting of historic buildings during construction activities such as groundworks, placement of site compounds, and from increased construction traffic.

During operation of the road there may be indirect adverse and/or beneficial impacts to historic buildings through changes in air quality from pollutants which have the potential to damage historic building materials. There may be visual and/or noise intrusion on the setting of historic buildings where new infrastructure is present in key views from, towards, through and across an asset, especially where the proposed scheme creates changes to the skyline. There may also be beneficial impacts on the setting of historic buildings through improved traffic flow.

Scheduled Monuments

There would be no physical impact on any of the six Scheduled Monuments within the 1km study area from any of the six improvement strategies.

Whilst there would potentially be some intervisibility between the improvement strategies and the six Scheduled Monuments, five of these designated assets (Ernespie, Mote of Urr, Doon Hill, Meikle cairn and East Hill Farmhouse stone circle) would retain their prominent positions within the landscape. Green Island fort would retain its defensive waterside position. The visual intrusion of a modern road encroaching more closely than the existing A75 into the visual setting of the prehistoric assets may have an adverse impact, most noticeably for Improvement Strategy 5 which would be approximately 210m north of Green Island fort.

Non-Designated Historic Buildings

Seventeen non-designated historic buildings are located within Improvement Strategies 1, 3, 4, 5 and 6, and would potentially be physically impacted during construction, in the form of full or partial removal.

There may be indirect physical impacts on historic buildings during construction, these may include changes to groundwater levels or vibrations caused by engineering activities associated with the proposed scheme. There may be alteration to the setting of historic buildings through the removal of vegetation or associated above-ground elements during construction. Finally, temporary noise, dust, and/or visual intrusion may occur within the setting of historic buildings during construction activities such as groundworks, placement of site compounds, and from increased construction traffic.

During operation of the road there may be indirect adverse and/or beneficial impacts to historic buildings through changes in air quality from pollutants which have the potential to damage historic building materials. There may be visual and/or noise intrusion on the setting of historic buildings where new infrastructure is present in key views from, towards, through and across an asset, especially where the proposed scheme creates changes to the skyline. There may also be beneficial impacts on the setting of historic buildings through improved traffic flow.

Archaeological Remains

Fifteen non-designated archaeological remains are located within the improvement strategies. With the exception of the findspots, which have usually been removed from their original location, physical impacts as a result of the proposed scheme are anticipated. Potential impacts from construction on archaeological remains are as follows:

  • Partial or complete removal of archaeological remains within the footprint of the proposed scheme, in areas of new land take through groundworks associated with construction activities. This includes, but is not limited to, activities such as widening of the existing road boundary, or the creation of new offline sections in addition to any service trenches and drainage features, topsoil stripping for compounds, the excavation of attenuation ponds and landscaping features.
  • Damage to archaeological remains within the footprint of the proposed scheme through their compression during construction, through the movement of machinery or within site compound or spoil storage areas.
  • Damage to archaeological remains through changes to groundwater levels caused by engineering activities associated with the proposed scheme. The alteration to the setting of archaeological remains through the removal of vegetation or associated above-ground elements during construction.
  • Temporary noise, dust, and/or visual intrusion on the setting of archaeological remains during construction activities such as groundworks, placement of site compounds, and from increased construction traffic.

The potential impacts of the operation of the road on archaeological remains are as follows:

  • Indirect adverse and/or beneficial impacts to archaeological remains through changes in air quality from pollutants which have the potential to damage archaeological materials.
  • Visual and/or noise intrusion within the setting of archaeological remains where new infrastructure is present in key views from, towards, through and across an asset, especially where the proposed scheme creates changes to the skyline.
  • Beneficial impacts on the setting of archaeological remains through improved traffic flow.

Design, Mitigation and Enhancement Measures

Should the proposed scheme be considered likely to have a direct or indirect significant adverse effect on a heritage asset of medium, high or very high importance, options for the avoidance of impact(s) would be proposed in the first instance. Avoidance may not be possible due to specific design elements being integral to the delivery of the proposed scheme, and/or where the design is avoiding significant effects identified in other topics. Instances where impact(s) cannot be designed out of the proposed scheme or reduced in magnitude would then be mitigated through additional measures.

Measures and changes integrated into the design of the proposed scheme could include:

  • Amendments to the proposed scheme where reasonably practicable during both initial and detailed designed phases.
  • Preservation in situ of heritage assets using engineering solutions to avoid physical impacts to historic building fabric and/or archaeological remains.
  • Consideration of the elements of a heritage asset that contribute to its cultural significance (value), and the wider historic environment.

Measures for the mitigation of impact(s) could include:

  • Erecting temporary screening and other barriers during construction to protect heritage assets from possible damage and to potentially reduce adverse change(s) to setting.
  • Ensuring that the creation of dust is controlled through dampening down construction areas.
  • Monitoring of heritage assets with a high importance located close to construction areas to ensure vibration or settlement from construction-related activities do not exceed levels which would result in damage to the heritage asset.
  • Archaeological excavation, informed by previous desktop review, field survey and/or archaeological monitoring or archaeological evaluation, to enable the preservation by record of recorded and unrecorded in situ archaeological remains.
  • Accurate recording of heritage assets where relevant such as historic buildings or structures prior to their demolition or alteration to enable preservation by record of their original form.

Any mitigation or reduction of impacts proposed would not outweigh the impact to an asset but would potentially reduce it.

It should be noted that some of these measures themselves may impact the historic environment and therefore good practice measures designed to limit common construction impacts must also be embedded within the design and any proposed mitigation. This could be achieved through the implementation of a Code of Construction Practice (COCP).

Opportunities for enhancement of the historic environment would be investigated as the design of the proposed scheme develops.

Assessment of Likely Significant Effects

Significant effects are those with a residual significance of effect which has been assessed in line with DMRB LA 104 to be moderate or greater.

Construction Phase

Conservation Areas

Because of the distance of Kirkpatrick Durham Conservation Area from the improvement strategies there would be no physical impacts on the Conservation Area and as such no significant effects are predicted.

Listed Buildings

In accordance with Table 3.8.1 Significance Matrix from DMRB LA 104 the value of Category A Listed Buildings have been assessed to be high, and the value of Category B and C Listed Buildings have been assessed to be medium.

The Category B Listed Buildings are at greater risk of change as they are located within the improvement strategies, therefore they will be discussed in greater detail. The potential magnitude of impact on them would be moderate resulting in moderate adverse significance of effect. As shown in Table 6-1.

Table 6-1: Assessment of Potential Construction Effects on Listed Buildings Within the Improvement Strategies
HES Unique Identifier Name Category Improvement Strategy Value Magnitude of Impact Significance of Effect

LB9666

Brooklands, Ornamental walling opposite Brooklands Lodge

B

1, 2

Medium

Moderate

Moderate Adverse

LB9665

Brooklands Lodge

B

1, 2

Medium

Moderate

Moderate Adverse

LB9714

Drummore Farmhouse, Retaining Wall and Gatepiers

B

1 and 6

Medium

Moderate

Moderate Adverse

LB16805

The Galloway Arms Hotel, Castle Douglas Road, Crocketford

B

3

Medium

Moderate

Moderate Adverse

LB16812

The Galloway Arms Annex, Castle Douglas Road, Crocketford

B

3

Medium

Moderate

Moderate Adverse

LB9669

The Toll Cottage, Castle Douglas Road, Crocketford

B

3

Medium

Moderate

Moderate Adverse

LB16815

Millhouse, Newbank Mill

B

3 and 4

Medium

Moderate

Moderate Adverse

LB16815

Weavings Sheds, Newbank Mill

B

3 and 4

Medium

Moderate

Moderate Adverse

LB16815

Spinning Mill, Newbank Mill

B

3 and 4

Medium

Moderate

Moderate Adverse

LB16815

Weavers Cottage, Newbank Mill

B

3 and 4

Medium

Moderate

Moderate Adverse

Scheduled Monuments

In accordance with Table 3.8.1 Significance Matrix from DMRB LA 104 the Scheduled Monuments have a high value, and the potential magnitude of impact on them would be negligible, resulting in a slight adverse significance of effect. This effect is not deemed to be significant.

Non-Designated Historic Buildings

In accordance with Table 3.8.1 Significance Matrix from DMRB LA 104 the value of the non-designated Historic Buildings is assessed as low. Most of the buildings would potentially be subject to a major magnitude of impact, resulting in a moderate adverse significance of effect. These effects are deemed to be significant as they would result in partial or full removal of the buildings.

For a few of the buildings, the improvement strategies run through the driveway to the buildings and would only impact their historic settings. As such the magnitude of impact on these building would potentially be negligible, resulting in slight adverse significance of effect. These effects are not deemed to be significant as they would not harm the fabric of the buildings.

Table 6-2 presents the non-designated Historic Buildings of moderate adverse significance.

Table 6-2: Assessment of Potential Significant Construction Effects on Non-Designated Historic Buildings within the Improvement Strategies
HER Unique Identifier Name Description Improvement Strategy Value Magnitude of Impact Significance of Effect

MDG16606

Bogrie Bridge

Bridge

1

Low

Major

Moderate Adverse

MDG23695

Moolance House, West Gate Lodge

Gate Lodge

1

Low

Major

Moderate Adverse

MDG18240

Crocketford, Ashmount

Building

3

Low

Major

Moderate Adverse

MDG22161

Crocketford, Castle Douglas Road, Anvil House

Blacksmiths Workshop

3

Low

Major

Moderate Adverse

MDG18239

Crocketford, Anvil House (Former Smithy)

Building

3

Low

Major

Moderate Adverse

MDG21588

Crocketford Village

Village

3

Low

Major

Moderate Adverse

MDG17282

Springholm, New Village Hall

Village Hall

3

Low

Major

Moderate Adverse

MDG17283

War Memorial, New Village Hall, Springholm

War Memorial

3

Low

Major

Moderate Adverse

MDG21617

Springholm Village

Village

3

Low

Major

Moderate Adverse

MDG9794

Newbank Mill / Springholm Mill

Watermill

3 and 4

Low

Major

Moderate Adverse

MDG27087

Bettyknowes Farmstead

Farmstead

5

Low

Major

Moderate Adverse

MDG8656

Ramhill Bridge

Road Bridge

5

Low

Major

Moderate Adverse

MDG16601

Whinnyhill Farmstead

Farmstead

6

Low

Major

Moderate Adverse

MDG16194

Forge Tree, Hopehead

Named Tree

6

Low

Major

Moderate adverse

Non-Designated Archaeological Remains

Significant effects on non-designated archaeological remains would result from the removal of the majority of the archaeological remains that form each asset. Whilst this effect has been assessed as part of the construction phase of the proposed scheme, once removed archaeological remains cannot be reinstated or replaced, making the change permanent.

Potential significant effects on seven non-designated archaeological remains from the construction of one or more improvement strategies have been assessed and are presented in Table 6-3 below.

Table 6-3: Assessment of Potential Construction Effects on Non-Designated Archaeological Remains within the Improvement Strategies
HER Unique Identifier Name Description Improvement Strategy Value Magnitude of Impact Significance of Effect

MDG5477

Crocketford Hill

Settlement

1, 2

Low

Major Adverse

Moderate Adverse

MDG4147

Moat Hill / Marlmount

Possible Motte; Moat

2

Low

Major Adverse

Moderate Adverse

MDG4743

Chapelton

Pit; Ditch; Findspot; Findspot; Site

2, 5

Low

Major Adverse

Moderate Adverse

MDG4150

Chapelton 2

Chapel

2

Low

Major Adverse

Moderate Adverse

MDG13038

South Park, Springholm

Burnt Mound

4

Low

Major Adverse

Moderate Adverse

MDG16614

Barfil

Field

5

Low

Major Adverse

Moderate Adverse

MDG4518

Milton Park, Urr Water

Enclosure

6

Low

Major Adverse

Moderate Adverse

The impact of the construction of additional laydown, compound, welfare or storage areas has not been assessed as the size, type and location of these areas has not yet been determined.

Operation Phase

It has been assumed that no significant physical impacts would occur on historic assets during operation of the proposed scheme. Any groundworks undertaken for maintenance are assumed to be within the road boundary where, if archaeological remains had been present, they would have previously been removed during construction.

The potential for indirect physical impacts on heritage assets, such as through vibration or through changes to air quality, would be addressed at DMRB Stage 2 when further information is available. However, it has been assumed that good practice mitigation would limit the potential for these impacts and no significant effects would result.

Proposed Scope of Future Assessment

Future cultural heritage assessment of the proposed scheme should include a more detailed heritage assessment using updated HER data direct from Dumfries and Galloway Council and Historic Land use data, available from HES.

Once more design information is available, the potential impact of any storage areas, welfare sites, compounds or haul roads should be assessed. Even if these areas are to be used temporarily, there is the potential that topsoil stripping could remove or truncate known or unknown archaeological remains.

Summary

Table 6-4 shows the heritage assets that have potential to experience likely significant effects during construction of the proposed scheme. The table also shows a comparison of the numbers of heritage assets within each improvement strategy. At DMRB Stage 2, the location of these heritage assets will be taken into consideration during design development with the aim of avoiding or reducing impacts.

Table 6-4: Number of Cultural Heritage Assets Potentially Experiencing Likely Significant Effects during Construction for each Improvement Strategy

Likely Significant Adverse Effects

Improvement Strategy 1

Improvement Strategy 2

Improvement Strategy 3

Improvement Strategy 4

Improvement Strategy 5

Improvement Strategy 6

Number of Category B Listed Buildings potentially impacted

3

2

7

4

0

1

Number of non-designated Historic Buildings potentially impacted

2

0

9

1

4

2

Number of non-designated Archaeological Sites potentially impacted

1

6

2

2

3

3

At this stage no significant impacts are anticipated during construction or operation to the Conservation Area or Scheduled Monuments.

Cultural Heritage assets are considered to be an irreplaceable resource and as stated in DMRB LA 106, the ‘need for development’ should be balanced against the requirement to ‘protect and enhance our national cultural heritage resource’ in line with national and local legislation, policy and good practice guidance.