Draft Black Country Plan

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Comment

Draft Black Country Plan

Policy CSP1 - Development Strategy

Representation ID: 23182

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

Development Strategy policy – CSP1 – 1 a) to deliver 47, 837 homes and 1b) 355ha employment land. Clause f) Protecting the Black Country’s character and environmental assets including heritage assets, natural habitats and open spaces – we would recommend that there is a specific clause that refers to the need to protect, and where possible, enhance the significance of heritage assets including their setting.

Comment

Draft Black Country Plan

Policy CSP2 – The Strategic Centres and Core Regeneration Areas

Representation ID: 23183

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

Limited reference currently to the themes of the historic environment and the policy would benefit from a specific reference to heritage.

Comment

Draft Black Country Plan

Duty to Co-operate

Representation ID: 23184

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

3.21 shortfall of 28,239 homes that are not being planned for in the plan period within Black Country; will this unmet need be provided elsewhere in the region?

Comment

Draft Black Country Plan

Table 1 – Black Country Plan - Objectives and Strategic Priorities

Representation ID: 23185

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

Page 23, Strategic Policy 12 – on built and historic environment – suggest amend ‘sustain’ with ‘protect’. We encourage looking at protecting the significance of heritage assets and assessing cultural heritage. Ensuring not just built assets but also landscape and features etc

Support

Draft Black Country Plan

Policy CSP4 - Achieving well-designed places

Representation ID: 23186

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

CSP4 – Achieving well designed places – includes some useful text for the historic environment and the benefit of responding to local heritage and cultural context which we support.
Clause 3 relates to heritage and would benefit from the addition of a line about protecting the significance of heritage as well as responding to historic character.
Clause 7 looks at protecting and enhancing the historic canal network which we support.

Support

Draft Black Country Plan

Policy CSP5 - Cultural Facilities and the Visitor Economy

Representation ID: 23187

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

We support the policy, lots of detail and recognition of the value of culture economically and socially. We consider that the references to heritage tourism could be more explicit and there are opportunities for enhancement of this type of use.

Comment

Draft Black Country Plan

Policy GB1 – The Black Country Green Belt

Representation ID: 23188

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

we would want to ensure that any amendments to the Green Belt are assessed both in terms of their Green Belt functions for historic towns, if appropriate, and on the impact to the significance of heritage assets including their setting.

Comment

Draft Black Country Plan

Policy GB2 – Extensions and Replacement Buildings in the Green Belt

Representation ID: 23189

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

Paragraph 3.8.1 sets out that large swathes of the Green Belt are also areas of significant historic landscape character. How is the plan providing a positive strategy for the historic environment and protecting areas of significant historic landscape character?

Comment

Draft Black Country Plan

Transport and Access to Residential Services

Representation ID: 23190

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

Paragraph 4.11 we would be supportive of heritage being included within this list and seeking opportunities to better reveal the significance of heritage assets and enhancement opportunities/addressing heritage at risk.

Comment

Draft Black Country Plan

Justification

Representation ID: 23191

Received: 11/10/2021

Respondent: Historic England

Representation Summary:

We are supportive of paragraph 4.3.1 and consider that it is essential that appropriate development is located in the right location and complements existing uses. We are keen to understand what assessment has been undertaken with regards to the historic environment and the proposed allocation sites.

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