Comment

Representation ID: 2027

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
General comments on allocations
It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal.
The policy wording should mention the specific designated heritage assets both on site and nearby.
The policy and supporting text should also refer to specific appropriate mitigation measures e.g. landscaping or careful design or maintaining key views or buffer/set back/breathing space etc.
Typical wording for the policy criterion might be:
Development should conserve or where appropriate enhance the significance of heritage assets including [list heritage assets on site and nearby – these should include designated and non-designated heritage assets] including any contribution made to their significance by their settings. Appropriate mitigation measures [as identified through the Heritage Impact Assessment] including … will be required.’
Therefore, please revisit the site allocations and ensure that policy wording/supporting text is consistent with the advice above.
By making these changes to policy wording the Plan will have greater clarity, provide greater protection to the historic environment and the policies will be more robust.
Given the inclusion of reference to significance and setting we suggest that these terms (which are quite technical) are included in a glossary.