Re: Rochford District Council New Local Plan: Spatial Options Consultation Paper 2021

Thank you for consulting Historic England on the Council’s New Local Plan: Spatial Options Consultation Paper 2021. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

We welcome the production of this consultation paper, but do not currently have capacity to provide detailed comments, and instead provide the following high-level comments which we hope you will find helpful.

Please note that the absence of a comment on an option or question in this letter does not affect our obligation to provide further advice and comment on specific proposals in the future, particularly where we consider that these would have an adverse effect upon the historic environment.

POTENTIAL SITE ALLOCATIONS

The Plan includes details of all sites that have been promoted for development as part of the new Local Plan. We understand that these sites will undergo further assessment before the Council identifies those sites which it deems suitable for inclusion in the Plan. To assist with this the Council has commissioned a high level heritage assessment of the Call for Sites submissions (Place Services, October 2020) which will ensure that heritage is considered consistently across all sites and heritage assets, and which we commend.

Further assessment of sites

Our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans sets out a suggested approach to assessing sites and their impact on heritage assets. It advocates a number of steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This could be applied to the assessment and selecting of sites within a plan.

In essence, it is important that you:

1. Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale;

2. Assess the contribution of the site to the significance of heritage assets on or within its vicinity;

3. Identify the potential impacts of development upon the significance of heritage asset including impacts resulting from a changing in setting;

4. Consider how any harm might be removed or reduced, including reasonable alternatives sites;

5. Consider how any enhancements could be achieved and maximised; and

6. Consider and set out the public benefits where harm cannot be removed or reduced

Looking at the above, it can be seen that the Council’s existing heritage assessment only really deals with the first 2/3 steps of the 5-step process and does not comprise a full heritage impact assessment of each of the sites (which the heritage assessments acknowledges). In order to help refine which sites to take forward, we would therefore suggest that Heritage Impact Assessments (HIAs) are undertaken for those which are considered to be contenders, but for which heritage issues have been identified. This should be proportionate (both to the scale of the site and the assets affected). Again, we would refer you to our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans.

As the Council begins the next stage of assessing sites it will be important to identify those which are inappropriate for development and also to assess the potential capacity of each in the light of any historic environment (and other) factors. It is worth stressing here that mitigation required to make a site acceptable from a historic environment perspective may mean that either, a site cannot actually be developed or the anticipated quantum of development is undeliverable. This is particularly an issue for smaller sites which may find it difficult adapt to the necessary mitigation measures, and this could have consequences for the suitability and achievability of these sites in terms of the Councils’ supply.

Site specific policy criteria informed by further heritage assessment

Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal with the Planning Practice Guidance stating “where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interests about the nature and scale of development (addressing the ‘what, where, when and how’ questions)” (Paragraph: 002 Reference ID: 61-002-20190315 Revision date: 15 03 2019). Conservation of the historic environment is a part of the key overarching environment objective (Paragraph 8c) and Local Plans should set out a positive strategy in this respect (Paragraph 190). To this end, if a site is allocated then the findings of the HIA should inform the site-specific policy including any specific development criteria required. We would also expect to see reference in the policy and supporting text to the need to conserve and seek opportunities to enhance the significance of on-site or nearby heritage assets (noting that significance can be harmed by development within the setting of an asset), the need for high quality design and any other factors relevant to the historic environment and the site in question.

FURTHER GUIDANCE

We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review the following as part of your plan preparation process:

The Historic Environment in Local Plan - Good Practice Advice in Planning 1
<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/>

The Setting of Heritage Assets 2nd ed. - Good Practice Advice in Planning 3
<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

The Historic Environment and Site Allocations and Local Plans - Advice Note 3
<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

CONCLUSION

We look forward to engaging with you as these proposals progress over the coming months. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise (either as a result of this consultation or in later versions of the plan/guidance) where we consider that these would have an adverse impact upon the historic environment.

If you have any queries about any of the matters raised above or would like to discuss anything further, please do not hesitate to contact me. I would be grateful if you could confirm receipt of this email.