Draft Regulation 18 Sandwell Local Plan
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Draft Regulation 18 Sandwell Local Plan
Policy SNE3 – Provision, Retention and Protection of Trees, Woodlands and Hedgerows
Representation ID: 668
Received: 11/12/2023
Respondent: Dr Michael Hodder
This policy should also state that replacement trees should not be planted where they would impact on sites identified / designated as archaeologically important
This policy should also state that replacement trees should not be planted where they would impact on sites identified / designated as archaeologically important
Support
Draft Regulation 18 Sandwell Local Plan
The Historic Environment
Representation ID: 669
Received: 11/12/2023
Respondent: Dr Michael Hodder
I welcome the statements made under the heading "The Historic Environment"
I welcome the statements made under the heading "The Historic Environment"
Comment
Draft Regulation 18 Sandwell Local Plan
Policy SHE1 – Listed Buildings and Conservation Areas
Representation ID: 670
Received: 11/12/2023
Respondent: Dr Michael Hodder
This policy is titled Listed Buildings and Conservation Areas but parts 1, 2 and 3 of the policy then talks abouit heritage assets and their settings- heritage assets, as defined in the NPPF, include locally listed buildings and sites of archaeological interest. The wording of parts 1,2 and 3 is welcomed, but perhaps the policy was intended to specifically relate to listed buildings and conservation areas (which are designated heritage assets, along with scheduled monuments and registered parks and gardens)
This policy is titled Listed Buildings and Conservation Areas but parts 1, 2 and 3 of the policy then talks abouit heritage assets and their settings- heritage assets, as defined in the NPPF, include locally listed buildings and sites of archaeological interest. The wording of parts 1,2 and 3 is welcomed, but perhaps the policy was intended to specifically relate to listed buildings and conservation areas (which are designated heritage assets, along with scheduled monuments and registered parks and gardens)
Support
Draft Regulation 18 Sandwell Local Plan
Policy SHE2 – Development in the Historic Environment
Representation ID: 671
Received: 11/12/2023
Respondent: Dr Michael Hodder
No additional comments
No additional comments
Comment
Draft Regulation 18 Sandwell Local Plan
Policy SHE2 – Development in the Historic Environment
Representation ID: 672
Received: 11/12/2023
Respondent: Dr Michael Hodder
It would be useful to define the Historic Environment Record here or elsewhere in the Plan.
It would be useful to define the Historic Environment Record here or elsewhere in the Plan.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SHE3 – Locally Listed Buildings
Representation ID: 673
Received: 11/12/2023
Respondent: Dr Michael Hodder
No further comments
No further comments
Comment
Draft Regulation 18 Sandwell Local Plan
Justification
Representation ID: 674
Received: 11/12/2023
Respondent: Dr Michael Hodder
4.131 Should be reworded to say that "Scheduled monuments in Sandwell currently consist of:"
4.131 Should be reworded to say that "Scheduled monuments in Sandwell currently consist of:"
Comment
Draft Regulation 18 Sandwell Local Plan
Policy SHE4 - Archaeology
Representation ID: 675
Received: 11/12/2023
Respondent: Dr Michael Hodder
4. lines 3-5 should read "....conditions of planning permissions for archaeological excavation to be undertaken prior to impact on or loss of the asset, in accordance with a written scheme of investigation to be approved by the Council, followed by analysis and publication of the results. [evaluation is the wrong term here because it refers to assessment undertaken prior to determination of a planning application]
5. This should begin "For sites with known or likely archaeological potential..." [the use of the term evaluation in this sentence is correct].
The Council must consult Historic England about the wording of this policy
4. lines 3-5 should read "....conditions of planning permissions for archaeological excavation to be undertaken prior to impact on or loss of the asset, in accordance with a written scheme of investigation to be approved by the Council, followed by analysis and publication of the results. [evaluation is the wrong term here because it refers to assessment undertaken prior to determination of a planning application]
5. This should begin "For sites with known or likely archaeological potential..." [the use of the term evaluation in this sentence is correct].
The Council must consult Historic England about the wording of this policy
Comment
Draft Regulation 18 Sandwell Local Plan
Justification
Representation ID: 676
Received: 11/12/2023
Respondent: Dr Michael Hodder
4.134 this section needs rewording. It should read:
" Desk-based assessment should include the results of a search of the HER, information taken from the Heritage List for England, and any other relevant sources. It should determine the nature, extent and significance i of archaeological remains and identify the need for, and scope of, any further evaluation that might be necessary prior to consideration of development proposals".
There should be a reference in the text to Historic England Guidance and the Chartered Institute for Archaeologists' standards and guidance, which define different types of archaeological work,
4.134 this section needs rewording. It should read:
" Desk-based assessment should include the results of a search of the HER, information taken from the Heritage List for England, and any other relevant sources. It should determine the nature, extent and significance i of archaeological remains and identify the need for, and scope of, any further evaluation that might be necessary prior to consideration of development proposals".
There should be a reference in the text to Historic England Guidance and the Chartered Institute for Archaeologists' standards and guidance, which define different types of archaeological work,
