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Representation ID: 22551

Received: 16/03/2020

Respondent: Historic England

General comment on site assessment booklets for site allocations:
Whilst we have not had the capacity to review every site assessment in the Site Assessments booklet, we have looked at a number of the assessments.
We are concerned that there is currently insufficient evidence in relation to the historic environment in terms of site allocations. To that end, we suggest that you review the site assessments to ensure that there is sufficient and robust in its consideration of the historic environment.
We refer you to our advice on the Historic Environment and Local Plans and Sites Allocations which is set out in the following documents:
HE Good Practice Advice in Planning 1 – the historic environment in local plans: https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/
HE Advice Note 3 – site allocations in local plans: https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/
Our advice note 3 on site allocations in local plans sets out a suggested approach to assessing sites and their impact on heritage assets (a Heritage Impact Assessment or HIA). It advocates 5 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 should 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. This should be more than a distance based criteria 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.
We suggest that a brief Heritage Impact Assessment (HIA) is undertaken for ALL sites in the Plan following the 5 step methodology, with more detailed HIA being undertaken for selected sites where the heritage issues are greater. It is important that the evidence base is proportionate and so the level of detail will vary depending on the site – its size and the number and significance of heritage assets affected. We have identified a number of sites in this table and the covering letter where a more detailed assessment would be required. This is not an exhaustive list and it may be that in preparing the brief HIAs you identify other sites which also warrant a fuller assessment.
The findings of the assessments should then be incorporated into the relevant site allocations policies (e.g. site capacity, potential mitigation and enhancements etc.)
The assessments could be included either in the Site Assessments or into the Historic Environment Topic Paper. Either way, it is important that they form part of the evidence base for the Local Plan.