Draft Black Country Plan

Comment

Representation ID: 23192

Received: 11/10/2021

Respondent: Historic England

Policy DEL 3, page 65, clause 5 we would suggest the text is amended as follows, or similar: ‘Proposals should not have an adverse impact on […] heritage assets or conservation areas…’ to ‘Proposals should protect and where possible, enhance […] the significance of heritage assets including their setting’. Conservation areas are listed within the NPPF definition of heritage assets and as such do not require their own reference.

Comment

Representation ID: 23251

Received: 11/10/2021

Respondent: Historic England

We recognise that Table 3 on page 90 sets out a significant housing requirement for the Black Country and seeks to find land to accommodate over 47,000 new homes in the plan period. Historic England is concerned about the location of this proposed development and is keen to ensure that the Plan has a positive strategy for the historic environment, seeks to protect and where possible, enhance the significance of heritage assets including their setting and has suitable and up to date evidence to justify the inclusion of proposed allocations and any potential harm/ avoidance and mitigation measures.

See comments elsewhere on proposed allocations and within the body of the letter attached to this response.

Comment

Representation ID: 23252

Received: 11/10/2021

Respondent: Historic England

Section 7 This section sets out a hierarchy of employment centres and the need to safeguard employment areas for future development.
It remains unclear as to what the implications may be for the historic environment and what assessment has been undertaken at this stage. We require further detail in order to make an assessment.

Comment

Representation ID: 23253

Received: 11/10/2021

Respondent: Historic England

Policy Trans 1 we welcome reference to the Council’s transport strategy for the Black Country Area. We are keen to understand what stage the proposals listed within the policy are at, and what assessment has been undertaken to date to understand the impacts for the significance of heritage assets including their setting.

Comment

Representation ID: 23254

Received: 11/10/2021

Respondent: Historic England

Policy TRAN2 what assessment has been undertaken with regards to safeguarded land needed for future transport development and the impact on the historic environment? Same comment for TRAN4 where specific sites are referenced.

Comment

Representation ID: 23255

Received: 11/10/2021

Respondent: Historic England

Same comment for TRAN4 where specific sites are referenced. Policy TRAN2 what assessment has been undertaken with regards to safeguarded land needed for future transport development and the impact on the historic environment? Same comment for TRAN4 where specific sites are referenced.

Comment

Representation ID: 23256

Received: 11/10/2021

Respondent: Historic England

Policy TRAN5 We support Policy TRAN5 and would welcome the canal network being more accessible. We also welcome public realm improvements and consider that there could be opportunities to enhance the historic environment through signage, interpretation, creation of new links and accessibility etc. and would be keen to see this referenced in the policy as a potential aim.

Comment

Representation ID: 23257

Received: 11/10/2021

Respondent: Historic England

Policy TRAN6 is there any information available on where the sites for new park and rides are likely to be?

Support

Representation ID: 23262

Received: 11/10/2021

Respondent: Historic England

Policy ENV4 we are supportive of a policy that seeks to retain and enhance tree cover within the wider Black Country area. We do request that there is reference within the policy to heritage assets and the historic landscape to ensure that appropriate design and species are chosen to complement/ enhance the historic environment and that consideration is given to ensure there is no harm for the historic environment or heritage landscapes. The insertion of a clause into the policy could safeguard this issue. We support clause 25) and the retention of hedgerows.

Comment

Representation ID: 23263

Received: 11/10/2021

Respondent: Historic England

Paragraph 10.78 states that where ‘physical evidence of local character persists, it should be conserved’. Can the Plan clarify what is meant by this and how this can be achieved? We are supportive of the aim.