Object

Representation ID: 22528

Received: 16/03/2020

Respondent: Historic England

We note that you are not proposing to update the Development Management policies at the present time. This approach is of concern to us. It would be helpful if the Plan could be read as a consistent whole, both for decision makers, developers and the public.

Paragraph 20 of the draft GNLP states that development management policies will not be amended except in very specific circumstances.

It is unclear what the statutory relationship between these documents will be. If the GNLP contains strategic level policies it is not clear how existing development management policies will be able to deliver these strategic objectives and vision given that the development management policies already exist. This raises fundamental question regarding the ability of the overall plan to provide a sound, evidence based positive strategy for the conservation and enhancement of the historic environment given that the strategic part of the plan will be retrospectively formulated in isolation of the development management parts of the plan. The approach taken means that there will be a period where the development management policies will not synchronise with the new strategic policies. There is concern that this fundamentally undermines a truly integrated plan-led approach to long term development.

We are concerned that the approach taken will result in any plan being unsound as it will in effect be incomplete and the component parts will not reflect each other. It is for these reasons that even in the event the GNLP is sound itself; it is very unlikely that we will be able to confirm that the entire plan is sound. At this stage we must again advise that the development management policies are reviewed to ensure that they align and can deliver the strategic policies of the GNLP.

Suggested Change: Please update Development Management policies too.