Heritage Statement (including Historical, archaeological features and Scheduled Ancient Monuments)

Thank you for your letter of 19 February 2008 and for consulting us on your draft local checklist for the validation of planning applications which we welcome.

In order to offer detailed advice on any application we require a full understanding of the impact of the proposed works on the historic environment. We also need to understand why the changes contained in an application are proposed. Our publication, 'A Charter for English Heritage Advisory Services' contains a guide to the range of information required for consultations with English Heritage. This guide is reproduced at Appendix A of this letter.

We believe that the items set out in Appendix A are required by local authorities to determine applications. These items are what we require if there is to be a 'genuine invitation to give advice' as set out in ODPM Circular 08/2005.

The glossary and guidance that your authority gives to applicants to ensure that the required documents are clear and unambiguous should therefore reflect the content of our Charter. The Government's guidance on the Validation of Planning Applications published on 7th December 2007 included many of these items. We would like to offer the following general comments on the local checklist and the glossary of terms:

* Planning statements, Listed Buildings Appraisals, Conservation Area Appraisals or Heritage Statements (as described in the CLG guidance) should take account of the 'impact on' and the 'setting of' the historic environment, which includes individual historic assets. For example, applications for planning permission for development may affect the setting of a listed building, scheduled monument, battlefield, conservation area, registered park or archaeological remains. They may also have an impact on the surrounding environs and these issues need to be addressed in any appraisal. Within these requirements we would look to find a statement of the significance of the historical and archaeological interest of a site as well as a state of justification for the works. This information could help inform the decisions your authority has to make and we strongly advise your authority to request the same categories of information as indicated in our charter.

* Design and Access Statement requirements as set out in DCLG Circular 01/2006 must be fully reflected in checklists. When a planning application is submitted in parallel with an application for listed building consent for example, a single combined statement should address the requirements of both. We would also suggest that reference to the CABE guidance "Design and access statements - How to write, read and use them' may assist the applicant."

Where English Heritage is a statutory consultee on an application, using our Charter will help to ensure we receive genuine invitations to give advice in order to offer meaningful advice.


APPENDIX A

GUIDE TO THE RANGE OF INFORMATION REQUIRED FOR CONSULTATIONS WITH ENGLISH HERITAGE ON PROPOSALS AFFECTING NATIONALLY IMPORTANT HISTORIC ASSETS

The type and amount of information needed may vary according to the kind of development proposed. The following items may be necessary to assess the impact of changes to the historic environment:

* A plan showing the site, its location, extent and context
* Photographs, dated, numbered and cross-referenced to a plan, showing the site and its context in general and the area of proposed change in detail
* A statement of significance which demonstrates an understanding of the historical, archaeological and architectural interest of the site

Measured drawings as existing and as proposed to show, where appropriate:

* All floor plans
* Any external and internal elevations affected by the works
* Sections through floor, roof and wall structures, where these are affected by the works
* Perspectives or photomontages, models or computer visualisations, to show the impact of new works on the heritage asset and its setting
* Landscape works, to include contours and planting schemes
* Other material necessary to provide a full understanding of the impact of the works on the significance of the historic asset and its setting

Drawings should be at a scale appropriate to show the impact of the proposals on the historic asset and its setting, usually 1:50. Plans, elevations and sections as existing should indicate elements proposed for demolition.

A written explanation of the proposed works to include:

* An assessment of the impact of the works on the significance of the asset
* A statement of justification explaining why the works are desirable or necessary (this should include development appraisal where appropriate)
* An archaeological assessment or field evaluation and a mitigation strategy, where important archaeological remains may exist
* A structural report by an engineer familiar with historic assets, which identifies defects and proposes remedies, when works include significant elements of demolition or rebuilding

When proposed works include the total or substantial demolition of a listed building, or any significant part of it, the statement of justification should be based on the following criteria, as set out in detail at 3.19, PPG15:

* The condition of the building, the cost of repairing and maintaining it in relation to its importance and to the value derived from continued use
* The adequacy of efforts made to retain the building in use, including evidence that the building has been offered on the open market at a realistic price
* The merits of alternative proposals for the site

Specialist Archaeological Advice

RE: VALIDATION DOCUMENT

Following our discussions yesterday please find our comments below. I apologise for not responding during the consultation period. It is pleasing to see that Heritage has been included, however the present wording relating to archaeological deposits in the explanatory notes largely copies that which is in the national document and there is a clear problem regarding the sites identified in the local plan. Neither the local Plan or the new LDF have areas of archaeological potential thus making part of the statement meaningless. As an alternative, below is a suggested wording which brings in all aspects of the historic environment, it also provides more detail and locally applicable information and gives a link to the Historic Environment Record web site.


Heritage Statement

Required where there is a reasonable probability of archaeological remains, whether below or above ground, being present on the site. The need for a Heritage Statement will depend on the scale of the development, as well as the nature of the archaeology. Domestic extensions and alterations will not require such an assessment, except in the case of historic buildings or conservation areas. Where significant ground disturbance occurs, especially in areas which have recorded historic environment assets on the Historic Environment Record (see http://unlockingessex.essex.gov.uk), then a field evaluation including trial trenching may be necessary as part of the Heritage Statement.

Heritage Statements must be produced by an appropriately qualified individual. National policy advice is provided in Planning Policy Guidance Note 15 - Planning and the Historic Environment and Planning Policy Guidance Note 16 - Archaeology and Planning. The Historic Environment Branch of Essex County Council can provide further information on the requirements. Please contact heritage.conservation@essexcc.gov.uk

It would also be useful giving our office as a contact to discuss archaeological implications. It is already recommended that the applicants discuss the heritage implications with a planner or the conservation officer, however, it would be very useful if we could get involved in discussions at an early stage.

On the check lists would it be possible to add Heritage Statements to the Hedgerow removal notice as applicants are required to check the historic environment implications of their removal.

Please let me know if you would like any further information, clarification or would like to discuss this further.