Draft Regulation 18 Sandwell Local Plan

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Comment

Draft Regulation 18 Sandwell Local Plan

Green and Blue Infrastructure

Representation ID: 1133

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

Section on Green and Blue Infrastructure from page 74 onwards - We would welcome a reference to the historic environment as a component of green and blue infrastructure and the role heritage plays in this area. If you have any questions we are happy to answer.

Attachments:

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SDS7 - Green and Blue Infrastructure in Sandwell

Representation ID: 1134

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

We would request a clause to be included in this policy regarding the historic environment and its function within Green/ Blue Infrastructure.

Attachments:

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SNE4 - Geodiversity and the Black Country UNESCO Global Geopark

Representation ID: 1135

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

We welcome a policy on the UNESCO Geopark and recognition of the important cultural heritage of the area and the contribution it has made in historical terms. Clause 1) consider re-phrasing to ensure that the significance of the asset and its integrity is fully protected and conserved for future generations.

Attachments:

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SNE5 - The Rowley Hills

Representation ID: 1136

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

This policy would benefit from strengthening the reference to the historic environment context of the area, including non designated heritage assets and heritage features as well as the heritage components of landscape.

Attachments:

Support

Draft Regulation 18 Sandwell Local Plan

Policy SNE6 – Canals

Representation ID: 1137

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

We support the recognition of the historic nature of canals as heritage assets/ role within the wider cultural heritage agenda and welcome reference within the policy and justification text in this area.

Attachments:

Support

Draft Regulation 18 Sandwell Local Plan

Listed Buildings and Conservation Areas

Representation ID: 1138

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

We welcome a specific section on the historic environment and specific policies for the historic environment. We welcome the introductory paragraphs to the interesting, rich and varied history of the Black Country and the need to protect this and the value placed on heritage led regeneration.

Attachments:

Comment

Draft Regulation 18 Sandwell Local Plan

Listed Buildings and Conservation Areas

Representation ID: 1139

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

Para 4.114 - Consider the wording in this paragraph and also needs reference to the setting of heritage assets as well as an understanding of the context in which they are in and any relationships they may have with other heritage assets within the area/ heritage landscapes etc.

When considering a suite of policies for the historic environment, it is important to ensure that all the policies are consistent and that all assets are fully supported.

Attachments:

Support

Draft Regulation 18 Sandwell Local Plan

Policy SHE1 – Listed Buildings and Conservation Areas

Representation ID: 1140

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

We welcome the inclusion of this policy. We would request that there are some amendments to the wording to ensure it is compliant with the National Planning Policy Framework (NPPF), paragraphs 199 to 205 particularly. Heritage assets are an ‘irreplaceable resource’ and efforts should be made to ensure that the significance of heritage assets, including their setting are protected. The policy wording in clause 1 and 2 can be strengthened to reflect this. The wording in clause 3 is welcome and we are supportive of the need for Heritage Impact Assessment. The assessment should also set out the level of harm, how harm can be avoided or mitigated against and any opportunities for enhancement. Clause 4, setting in itself is not a heritage asset but it should be included within the section on significance and can still be a reason for refusal where the setting contributes to the significance of an asset, but will be affected by proposed development. Recording the loss of any heritage asset/ features on the Historic Environment Record (HER) would also be beneficial to include within this policy. Consider the wording for clause 5 to ensure the protection of a Conservation Area. We would recommend deleting clause 6. Paragraph 4.121 relates to this paragraph also.

Attachments:

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHE2 – Development in the Historic Environment

Representation ID: 1141

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

Similar to comments above, ensure that the policy is NPPF compliant and that it seeks to protect and conserve the historic environment and sets out where applications will be refused. As referenced the historic environment is an ‘irreplaceable resource’ and the NPPF sets out clearly how to deal with harm and how if necessary to apply the tests of harm. Clause 1 for example requests that heritage informs proposals and is considered; there should be a clause that states that harm to heritage will be refused unless xx. Again, clause 2 refers to the need to inform proposals which is beneficial, yet there needs to be wording inserted to prevent harm to the historic environment and conserve their significance, including setting.

Where ‘historic assets’ are referenced this should be amended to state ‘heritage assets’.

Clause 3, heritage assets should be protected as set out in the NPPF and relevant legislation.

Clause 5, delete ‘aim’. The policy wording should be strengthened to ensure that heritage assets are protected and conserved in Sandwell. The examples used are useful and provide a context for the type of heritage within the Borough; it would be beneficial to ensure that this describes some examples only and reference the relevant heritage evidence base that prospective developers will need to consider in full.

It would be beneficial to have a clause that relates to the need for appropriate qualified individuals undertaking assessment work, that the Historic Environment Record should be considered as a minimum, that views analysis is a useful tool to consider in the wider process etc. for all proposals which could affect heritage.

Para 4.123 - Delete ‘ancient’.

It would be useful to provide some additional information about what a heritage impact assessment could include.

Attachments:

Support

Draft Regulation 18 Sandwell Local Plan

Policy SHE3 – Locally Listed Buildings

Representation ID: 1142

Received: 18/12/2023

Respondent: Historic England

Representation Summary:

Consider referring to significance generally in this clause. It would be useful to have a link to the Sandwell Local List. We are supportive of a Local List and welcome this.

Attachments:

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