8.89
Object
Pre- Submission Draft Waste Local Plan
Representation ID: 1039
Received: 11/10/2023
Respondent: Historic England (Midlands)
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Many of the paragraphs in the justification we support and consider that these should be better integrated into the policy wording to ensure it is National Planning Policy Framework (NPPF) compliant. We do not however consider that large sections of Section 16 NPPF are necessary to be included within the text. The justification should focus on how the policy clauses can be fully understood with links to appropriate documents and explanation. Paragraph 8.89 and 8.90 for example, there should be a clause within the policy setting out these details.
Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.
We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.
If you have any questions, please contact us.
(Please see attached for table and full representation).