Comment

Representation ID: 2065

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We are concerned at the over-reliance of GIS distance-based analysis for the Sustainability Appraisal (paras 5.1.1 – 5.13). The report itself comments on the limitations of this and states that it is not technically an appraisal. And little of no potential for reach conclusions on significant effects. The report uses the example of biodiversity features. The same issue applies for heritage assets.
A purely distance based approach is not appropriate. The impact of proposals on the significance of heritage assets should be taken into consideration at an early stage. In terms of sites, this should be based on more than just measuring the proximity of a potential allocation to heritage assets.
Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. The application of a standard proximity test (e.g. is the site within a set distance of a heritage asset) should not be used as it can lead to misleading results.
A simple matrices approach is not considered sufficient. We would want to see a narrative-based approach that properly considers more nuanced issues in relation to setting and significance of both designated and non-designated heritage assets.
The analysis at section 9.8 again seems to overly focus on proximity.
We welcome the reference at 9.8.6 for the need to ensure policy in place to mitigate for historic environment impacts. We have identified a number of sites where we consider further heritage assessment is needed. These assessments should make recommendations regarding appropriate mitigation and this should then be incorporated into individual site policy wording.
In future SA reports, please ensure the correct notation is used for listed buildings eg grade1 should be grade I, grade 2 should be grade II.
The findings of the Analysis on pages 48-52, and Table A further highlights our concern that the analysis has been overly focused on distance.
We note that Scheduled monuments do not appear in Table A.
The appraisals from p76 following do give a slightly fuller discussion of the historic environment; however, the analysis is still somewhat superficial.
This again points to the need for HIAs of particular sites.