Policy NB8: Protection and enhancement of the historic environment and heritage assets

Comment

Representation ID: 3994

Received: 23/11/2022

Respondent: Inland Waterways Association (IWA)

The Key Evidence list includes Conservation Area Appraisals and Management Plans 2010, but these are not included in the Evidence Base in Appendix A or on the website.

Object

Representation ID: 4194

Received: 21/12/2022

Respondent: Mr John Marsh

Legally compliant? No

Sound? No

Duty to co-operate? No

See attachment

Comment

Representation ID: 4399

Received: 22/12/2022

Respondent: Historic England

First paragraph - replace 'preserve' with 'conserve'. Text should read 'development propsals should demonstrate how they conserve and enhance the significance of heritage assets, including their setting'. Details such as how and relating to 'character, appearance and function' could then follow.

Second paragraph should be amended to read that development proposals should seek to avoid, and minimise, harm in the first instance. Only when this can't be achieved should the clause in the second paragraph be relevant. Consider additional detail is required on when a Heritage Statement is required and what it should contain. Clause relating to archaeology should include text requiring this to be undertaken by a suitably qualified professional. Where loss of heritage assets is unavoidable this information should be recorded on the HER as a minimum. Request the inclusion of the term 'appropriate reuse' in the sentence relating to heritage at risk.

Object

Representation ID: 5063

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Having considered the evidence, we have concerns that The Council is taking forward an unsound Policy (Policy NB8) given that many of the Conservation Area Character Appraisals (CACA) background technical evidence base documents which support the designation of Conservation Areas are now heavily out-of-date. For example: Chillington Estate, Weston-under-Lizard, Enville Village, Shropshire Union Canal, Wombourne and Lower Penn.
The HESA reports provide evidence that is too vague and unclear, and which forms insufficiently robust guidance and should not therefore be being used solely to inform critically important spatial planning policy considerations for the future spatial distribution of major new housing development, within areas of historically sensitive countryside. The position is very clear, there is an incomplete and insufficiently robust up-to-date historic environment evidence base.
Nearly all of the Conservation Areas are being underpinned by an evidence base which is at least 12 years old, and therefore heavily out-of-date evidence. And as stated, alarmingly some of the district’s Conservation Area’s have not been surveyed for the last 51 years. We have concerns about this level of incompetence.
By taking forward insufficiently robust and unsound policies which are based on heavily out-of-date and highly questionable evidence, the Plan is clearly unsound and fails the proportionate evidence tests of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indent b) of the Revised NPPF (2021). The approach taken towards Local Plan preparation is also in direct conflict with paragraphs 31 and 192 of the Revised NPPF (2021).

Support

Representation ID: 5318

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy