PROPOSED SUBMISSION LOCAL PLAN 2006-2028 - Aug 12

Comment ID 2121
Document Section Proposed Submission Local Plan 2006-2028 Environmental Quality Historic Environment Policy EQ3: Historic Environment View all on this section
Respondent English Heritage (C Power) View all by this respondent
Response Date 10 Aug 2012
Do you consider the DPD is Legally Compliant?
Do you consider the DPD is Sound?
If you have responded that the DPD is unsound, Do you consider the DPD is unsound because it is:
Comment
  • At present the Plan fails to positively address South Somerset's heritage assets at risk. There are 8 schedule monuments; 10 grade I and II* buildings; 3 historic parks and gardens, 1 battlefield and 4 conservation areas (this data may not be up to date) on the national heritage at risk registe?. There is no indication of an intention to continue to carry out at risk surveys in future to ensure there is an understanding of what is "at risk" nor a clear strategy in response to those assets at risk. Perhaps a role for the additional heritage SPD referred to at 12.40.
  • Reference to registered battlefields is not included

NPPF Section 12 - Conserving and Enhancing the HE Paragraph 126.

To conserve the HE one has to appreciate the condition of the areas assets. These key facts should be included.

NPPF paragraph 169.

Has it been demonstrated that up to date evidence to assess the significance of heritage assets has been applied?

Only CA Appraisals are referred to. What does the evidence tell us about the threats and opportunities?

NPPF - Plan making Paragraph 156.

Is there a strategic policy for the protection and enhancement of the HE, including landscape?

NPPF - Plan making Paragraph 152.

Has the Plan set out clear policies on what will or will not be permitted and where?

NPPF - Plan making Paragraph 156.

Does the plan contain a clear strategy for enhancing the HE?

NPPF paragraph 7 - Achieving Sustainable Development

Does the Plan contribute to the protection and enhancement of the HE?

NPPF paragraph 9 - Achieving Sustainable Development

Does the plan seek positive improvements in the quality of the HE?

NPPF Section 12 - Conserving and Enhancing the HE Paragraph 126.

Does the plan set out a positive strategy for the conservation and enjoyment of the HE?

NPPF Section 12 - Conserving and Enhancing the HE Paragraph 126.

NPPF paragraph 169.

Is there a maintained and accessible HE record?

NPPF Section 12 - Conserving and Enhancing the HE Paragraph 126.

Does the Plan set out a positive strategy for the conservation heritage assets most at risk through neglect, decay or other threats?

NPPF Section 12 - Conserving and Enhancing the HF.

Does the Plan take into account the desirability of new development making a positive contribution to local character and distinctiveness?

The policy does not refer to the heritage protection strategy that is mentioned in 12.40 and 12.41. This needs to be robustly set out in the Policy to ensure that it is delivered. The following suggested policy would suffice.

Delivery and Monitoring

Support but consider that the current Indicator and Target are too limiting.

What changes do you suggest to make the DPD legally compliant or sound? Indicators; To ensure a clear and effective strategy, additional policy targets are recommended and might include:
- The completion of historic environment guidance (Heritage SPD).
- Up to date heritage at risk surveys and conservation area appraisals/management plans.
- Contributions secured to maintain and improve heritage assets (Policy EQ3- See Table for suggested amendments).
- The reduction in the number of heritage assets on the national at risk register.

Additional historic environment guidance
English Heritage welcome the commitment to prepare additional guidance (heritage SPD) to aid the application of Policy EQ3 but it is important to indicate more clearly its scope, purpose and when it might be prepared. Otherwise this potentially important component of a positive and proactive strategy for the conservation of the historic environment is merely aspirational and may not actually come to fruition therefore affecting the effectiveness of the Plan, and as a consequence its soundness.
To be Sound the Core Strategy and SA will need to state very clearly the evidence that has gathered and applied; demonstrating the particular significance, condition and sensitivity of South Somerset's heritage assets and their setting has been understood and addressed. There will need to be a specific and comprehensive heritage policy and strategy for its conservation and enjoyment.

In accordance with the NPPF we would recommend a more thorough policy that addresses this matter:

Valuing our Historic Environment.
Heritage assets will be conserved and where appropriate enhanced for their historic significance and important contribution to local distinctiveness, character and sense of place. Their potential to contribute towards the
economy, tourism, education and local identity will be exploited.

This will be promoted by producing a positive management strategy for the historic environment that will ensure:
- proposals and initiatives are supported that protect and, where appropriate, enhance the heritage significance and setting of heritage assets, especially those elements that contribute to the distinct identity of South Somerset.
- the sensitive expansion, growth and land use change in and around towns and villages, safeguarding elements of the historic character and value within their built up areas, including surrounding historic landscape character and setting of individual settlements
- working with County highways, Town and Parish Council's to provide highway improvements and street furniture that are appropriate to the historic context of those places
- the sensitive re-use and adaptation of historic buildings
- a maintained, and publicly accessible HE Record and its use to inform development proposals
- a maintained local list of heritage assets that identifies key buildings and structures which, although not of sufficient quality to meet national listing criteria, have valuable architectural or historic merit and make a positive contribution to local character.
- rural design guides are prepared and applied
- How the historic environment can help to deliver wider economic, social and environmental objectives for the plan area
- The interrelationship between conservation of heritage assets and green infrastructure, landscape, regeneration, economic development, transport works, infrastructure planning, tourism, town centres and climate change mitigation or adaptation.
- How conservation areas may be sustainably managed, including through the use of Management Plans and Article 4 Directions where appropriate.
- How CIL and/or S106 agreements could contribute towards the enhancement of individual assets or specific historic places such as "At risk" assets.

Delivery and Monitoring
- The completion of historic environment guidance (Heritage SPD).
- Up to date heritage at risk surveys and conservation area appraisals1 management plans.
- Contributions secured to maintain and improve heritage assets.
- The reduction in the number of heritage assets on the national at risk register.
If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination?
If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:
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