Comment
Draft Black Country Plan
Representation ID: 23264
Received: 11/10/2021
Respondent: Historic England
Policy ENV5 clause 1 we would recommend amending ‘sustain’ with ‘protect’. It may be useful if at the beginning of the policy the first clause sets out the need to protect and enhance the significance of heritage assets, including their setting. Clause 2 we would recommend amending ‘preserve’ with ‘protect’. We are very supportive of the references to the historic environment of the Black Country and its local distinctiveness. We support the references in the policy to Historic Landscape Characterisation Studies and other up to date assessments. We are supportive of clause 6 and welcome the local elements included within this policy. It may be necessary to have some additional guidance for prospective applicants and development management planners to follow, in order to ensure that this is upheld during the development management process. Clause 8 would benefit from additional detail on what type of assessment would be appropriate including the level of detail and ensuring that the impacts to significance if fully evaluated. Clause 9 and 10 would benefit from the inclusion of a reference to suitable qualified and appropriate persons undertaking relevant assessments. We welcome the detailed consideration of the historic environment within the Black Country and the desire to protect it for future generations.