Issues and Options Document

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. 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 as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

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 or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or 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. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. 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 site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on 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
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), 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)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
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 where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.