CS4: Protecting our Assets
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5207
Received: 05/03/2015
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy CS4 does not meet the NPPF requirement for a positive strategy to the historic environment or constitute a strategic policy approach. There is a need for a more explicit strategic policy approach.
The supporting paragraphs also need amendments.
Our response to the 2013 consultation expressed the need for a more explicit and holistic approach to the historic environment in the Core Strategy (and Site Allocations DPD) in order to address the requirements of the NPPF (particularly paragraphs 126, 156 and 157). The previous version of Policy CS4 made a general reference to" historical assets" in the first sentence and referred to conservation areas in the second sentence, but the supporting paragraphs stated that the Council would rely on national legislation and policy for listed buildings (8.46) and scheduled monuments (8.53)
We note the amendments to Policy CS4 and the supporting paragraphs in relating to the historic environment, but our concerns remains. The new third sentence in Policy CS4 is limited and effectively delegates the conservation and enhancement of heritage assets to the development management policies. This does not meet the NPPF requirement for a positive strategy to the historic environment (paragraph 126) or constitute a strategic policy approach (paragraph 156). The development management policies are important, but there is a need for a more explicit strategic policy approach. There is a strategic approach to biodiversity in the policy, and we consider that a similar approach should exist for the historic environment.
Paragraphs 8.46 and 8.53 still state that the Council will rely on national legislation, policy and guidance for listed buildings and scheduled monuments, while paragraph 8.55 underplays the status of registered parks and gardens as just a material consideration in planning applications (when they are designated heritage assets in the NPPF, potentially of the highest significance).
As currently drafted, Policy CS4 and the supporting paragraphs (8.46, 8.53 and 8.55) are unsound as they are not consistent with national policy in respect of the NPPF.
In order to achieve soundness, the third sentence of Policy CS4 should avoid merely delegating to the development management policies and should set out a strategic approach similar to what is set out for biodiversity. It could read as follows:
"The Council will conserve and enhance heritage assets within the Borough in a manner appropriate to their significance. This will include the use of planning obligations to secure the enhancement of the significance of any heritage asset, the maintenance of a list of buildings and other heritage assets of local importance, and steps to reduce the number of heritage assets "at risk" and improve historic shopfronts and public realm.
Paragraph 8.46 should be amended to set out the Council's local and strategic approach to listed buildings (not just relying on national legislation and policy). The second sentence of Paragraph 8.53 should be deleted. The second sentence of Paragraph 8.55 should read "Whilst registration offers no additional statutory protection, they are designated heritage assets of considerable significance and an important material consideration in development management"
As a minor change to ensure accuracy with the NPPF, the first sentence of Policy CS4 should be amended to read "heritage" rather than "historical", as heritage assets is a nationally defined policy term.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5411
Received: 05/03/2015
Respondent: Mr Arwel Owen
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Paragraph 113 of the NPPF requires [policy] to be criteria-led, but Policy CS4 is not. We also consider that the balancing measures set out in paragraph 118 of the NPPF should be reflected in the Policy. We consider that the last paragraph of the Policy should form part of Policy CS1.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5645
Received: 20/01/2015
Respondent: Marine Management Organisation
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Policy CS4 - this policy would benefit from making reference to the East Offshore and East Inshore Marine Plans, specifically policy MPA1. Within this policy RAMSAR and SPA sites do cross into the South East marine plan area.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 24071
Received: 05/03/2015
Respondent: River Action Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
It is not known whether the removal of trees, hedgerows, habitats and farmland is acceptable or whether the plan will deliver the Country Park in a timely manner.
See attached