Draft Black Country Plan

Comment

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.

Support

Representation ID: 23266

Received: 11/10/2021

Respondent: Historic England

Paragraph 10.82 - We are supportive of this paragraph and we recognise the risk that significant new development can pose for the area and how it is essential that this is well located and appropriately and sensitively designed.

Comment

Representation ID: 23267

Received: 11/10/2021

Respondent: Historic England

Under the ‘delivery’ tab it would be useful to understand which specific documents are available, for example, what are the relevant SPDs?

Comment

Representation ID: 23268

Received: 11/10/2021

Respondent: Historic England

Paragraph 10.86 We welcome the references to the UNESCO Geopark designation.
Paragraph 10.88 We welcome the references to the opportunities that this designation brings for the area.


Consider deleting ‘where possible’ in clause 1.

Support

Representation ID: 23269

Received: 11/10/2021

Respondent: Historic England

We are supportive of a policy for canals and canal structures. We would request that, in clause 1, undesignated is replaced with non designated and historic assets is replaced with heritage assets, to reflect NPPF terminology. Clause 2c would benefit from the inclusion of text to protect the significance of heritage assets including their setting. Clause 2e we support the references. Has any assessment work been undertaken to understand what the key views may be? Clause 3c we suggest insert the wording to protect and enhance the significance of heritage assets within this clause and delete the term ‘preserve’.

Comment

Representation ID: 23270

Received: 11/10/2021

Respondent: Historic England

Clause 1 we are not clear on what assets this policy is aiming to protect. Where heritage is relevant, we recommend that the policy protects the significance of the heritage assets including their setting. How will this clause be considered through the development management process?

Comment

Representation ID: 23271

Received: 11/10/2021

Respondent: Historic England

We are supportive of this policy and have a few queries. What is meant by clause 1a? Are there views linked with clause 1b and how have these been defined? We suggest that a link to Policy ENV5 is also necessary in clause 1e. We support clause 4.

Comment

Representation ID: 23272

Received: 11/10/2021

Respondent: Historic England

Page 260 Monitoring Indicators - We would request additional indicators to objectively assess ENV5 such as % of assets on the at risk register, number of applications approved contrary to Historic England advice, % change in heritage assets. We would be willing to discuss in further detail to assist you.

Support

Representation ID: 23273

Received: 11/10/2021

Respondent: Historic England

We are supportive of a section on climate change and we recognise the important role this issue has to play. We also recognise that there are likely to be benefits for the historic environment as a result of addressing climate change and we welcome this. We are keen to ensure that the historic environment is fully considered in plans for climate change mitigation and adaptation to ensure appropriate and sensitive measures are undertaken.

Comment

Representation ID: 23274

Received: 11/10/2021

Respondent: Historic England

We support the references in clause h. Every care should be taken to ensure that appropriate and sensitive measures are undertaken.