Interim Sustainability Appraisal

Comments on Interim Sustainability Appraisal
The historic environment should be considered as part of the sustainability appraisal process. We recommend that these comments should be read alongside our Advice Note 8, available here: https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/
Key Sustainability Issues
We would suggest that the starting point for considering Key Sustainability Issues for the Historic Environment should include:
 Conserving and enhancing designated and non-designated heritage assets and the contribution made by their settings
 Heritage assets at risk from neglect, decay, or development pressures;
 Areas where there is likely to be further significant loss or erosion of landscape/seascape/townscape character or quality, or where development has had or is likely to have significant impact (direct and or indirect) upon the historic environment and/or people's enjoyment of it
 Traffic congestion, air quality, noise pollution and other problems affecting the historic environment
We would expect to see consideration of opportunities. It is considered that the historic environment can make a significant contribution to the success of development and there may be opportunities for the enhancement of the historic environment which comes from sustainable development proposals. It is considered that the Sustainability Appraisal should highlight these opportunities. Examples of the sorts of opportunities that can be used can be found in our guidance notes in the links above.
We request that the sustainability issues table at the start of section 3 is amended to replace the term built heritage with the historic environment. The issues set out in this table are appropriate and we are pleased to see reference to the effects of more intangible elements such as pollution, traffic, etc. on the historic environment. We recommend however that heritage at risk is also listed as an issue here.
As outlined earlier in this letter we do not agree with the GNLP objectives which are replicated in section 4 of the Interim SA as they do not contain any reference to the need for the conservation and enhancement of the historic environment as required by the NPPF. Given that these objectives have been used to evaluate the SA objectives we necessarily have fundamental concerns with the SA findings which consider the objective to have a generally positive impact.
We are however pleased to see the inclusion of SA Objective SA13, this objective is appropriate and has been used to assess the potential effects of policies within the GNLP. SA13 makes appropriate reference to setting and the wider historic environment.
We note that a number of the policies would result in significant negative impacts upon the SA13 baseline. We therefore expect to see the inclusion of criterion which address the negative effects of the options to be taken forward.
Method for Generation of Alternatives
The historic environment should be a factor when considering a method for the generation of alternative proposals. The impact of proposals on the significance of heritage assets should be taken into consideration at an early stage. In terms of sites, this should be based on more than just measuring the proximity of a potential allocation to heritage assets. Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base.
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.
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.