Issues and Options Document

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Comment

Issues and Options Document

Homes Businesses

Representation ID: 37096

Received: 07/03/2018

Respondent: Historic England

Representation Summary:

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.

Comment

Issues and Options Document

Delivering Homes and Jobs

Representation ID: 37097

Received: 07/03/2018

Respondent: Historic England

Representation Summary:

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.

Comment

Issues and Options Document

Protecting and Enhancing Heritage and Culture

Representation ID: 37098

Received: 07/03/2018

Respondent: Historic England

Representation Summary:

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.

Comment

Issues and Options Document

How have you assessed the sustainability impacts?

Representation ID: 37099

Received: 07/03/2018

Respondent: Historic England

Representation Summary:

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.

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