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Publication
24
Representation ID: 23955
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
You will be aware that we have raised some concerns regarding the fact that you are not proposing to update the Development Management policies at this stage during the Reg 18 consultation and in subsequent meetings.
Whilst paragraph 20 of the Reg 18 Plan left open the possibility for some limited amendment to such policies, and we had also previously been told at Reg 18 that the DM policies would be reviewed in advance of the Reg 19 Plan, this now no longer seems to be the case.
Indeed the new text in paragraph 24 makes it clear that the GNLP will be used in conjunction with the existing adopted Development Management Policies.
Whilst we accept that this is a perfectly acceptable approach to Plan review, and indeed many of the policies set out in the existing adopted Development Management Plans and the City Centre Conservation Area Appraisal are good and valuable, Historic England continues to have concerns that this still leaves some policy areas lacking.
In particular we are concerned that there is a lack of strategic policy framework for taller buildings and the skyline, the detailed approach to designated and non-designated heritage assets and heritage at risk.
Please review these policy areas and ensure the Plan provides sufficient
Object
Publication
Table 3 - Numbers of Conservation Areas, Listed Buildings, Scheduled Monuments and Registered Parks and Gardens
Representation ID: 23956
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Paras 104-107 and Table 3
We welcome the changes made in these paragraphs to better reflect NPPF terminology (scheduled monuments, heritage assets and Registered Parks and Gardens) as well as the additional sentence referencing the city centre’s current street pattern reflecting historic influences.
We continue to suggest reference to what heritage is at risk and historic landscape characterisation.
Object
Publication
125
Representation ID: 23957
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We continue to suggest that you change historic assets to historic environment. The historic environment is considered the most appropriate term to use as a topic heading as it encompasses all aspects of heritage, for example the tangible heritage assets and less tangible
cultural heritage.
Object
Publication
147
Representation ID: 23958
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We welcome the reference to the protection and enhancement of distinctive local characteristics of our city, towns and villages and their separate identities. This is a really important aspect of ensuring a positive strategy for the historic environment in your Plan in line with para 185 of the NPPF. We also welcome the reference to high quality, well designed and beautiful new development picking up on the Building Better Building Beautiful report.
However, this paragraph should also refer to landscape.
Object
Publication
Climate Change Statement
Representation ID: 23959
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
There is currently no reference to the question of climate change and the historic environment. It might be appropriate to include some reference to this in this section of the Plan.
Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture.
In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://historicengland.org.uk/images- books/publications/energy-efficiency-historic-buildings-ptl/ to be helpful in understanding these special considerations.
Object
Publication
Policy 2 Sustainable Communities
Representation ID: 23960
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We welcome the new reference to the historic environment in Policy 2 and Table 8. These are helpful additions to the policy.
Policy 2 would be further improved with specific reference to conservation area appraisals in criterion 5 to read
…taking account of landscape or historic character assessments including conservation area appraisals, design guides and codes
Object
Publication
202
Representation ID: 23961
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The NPPF requires Plans to include a positive strategy for the historic environment (para 185). We continue to suggest that you include more here about the distinctive, unique heritage of the area – what makes this special and different from elsewhere? Think about building materials, building styles, local vernacular, settlement form and pattern and so on and try to describe that here. We need to know what it is that we need to
protect and enhance
Object
Publication
203
Representation ID: 23962
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The NPPF requires Plans to include a positive strategy for the historic environment (para 185). We continue to suggest that you include more here about the distinctive, unique heritage of the area – what makes this special and different from elsewhere? Think about building materials, building styles, local vernacular, settlement form and pattern and so on and try to describe that here. We need to know what it is that we need to
protect and enhance.
Object
Publication
203
Representation ID: 23963
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Replace historic assets with heritage assets in line with the terminology used in the NPPF.
Object
Publication
205
Representation ID: 23964
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Replace historic assets with heritage assets in line with the terminology used in the NPPF.