Comment

Representation ID: 2025

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We are concerned that there is insufficient evidence in relation to the historic environment to support some of the site allocations.
Whilst the HEELA methodology and site assessments are a helpful starting point, we are looking for more detail, particularly in relation to the amber sites.
Unfortunately, the assessments do not follow the five-step methodology for site allocations set out in our Advice note 3 on site allocations. They do not properly consider significance of heritage assets, the contribution of setting to that significance, impact of development upon significance of those assets and do not consider potential mitigation and enhancement.
Therefore, Heritage Impact Assessments should be prepared for a number of sites; this is imperative to ensure a robust evidence base for the Local Plan. These should be prepared in advance of the next draft of the Plan to inform whether some sites are suitable, but for majority of sites to inform potential mitigation and policy wording. This is a matter of priority, given the timetable for the Plan.
HIAs should consider the issue of the capacity of the sites including issues in relation to height and impact on historic environment. They should consider significance of assets, impact of development upon significance of those assets, and make recommendations about potential mitigation.
Should a HIA conclude that a particular site could be allocated, the findings of the HIA should inform the policy wording.
Paragraph 32 of NPPF makes it clear that significant adverse impacts should be avoided wherever possible and alternative options pursued. Only where these impacts are unavoidable should suitable mitigation measures be proposed.