Minerals Local Plan Sustainability Appraisal Scoping Report

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Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

1. Introduction - What is Sustainability Appraisal?

Representation ID: 30561

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q1 response - Historic England is of the view that the information sets out the requirement for, and purpose of, SEA and SA adequately. However, para.1.7 'Other Appraisals' should include reference to the potential need for Heritage Impact Assessments for site allocations in the Plan. These are currently omitted from the scope of the assessment and should be included to ensure the Plan can demonstrate a positive approach to the historic environment in line with NPPF requirements.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

2. Methodology

Representation ID: 30562

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q2 response - Historic England is of the view that the methodology has been adequately explained. Historic England's Advice Note 8: Sustainability Appraisals and Strategic Environmental Assessment may be of use to NCC in respect of the historic environment:

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 1: Key messages from the document review

Representation ID: 30563

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q3 Response- Additional relevant information in respect of the historic environment should be included (Appendix 1).

Implications for the plan section doesn't include Roman settlement near Mansfield or the Neanderthal Creswell Crags (Palaeolithic site).

Q4 Response- It is recommended that Historic and cultural heritage key messages be revisited to extend the scope and address wording/content issues.

In current form, the key messages do not adequately reflect NPPF requirements for heritage assets and their setting nor impact on significance or harm.

Q5 Response- The current wording is insufficient to assist the Plan to move forward on a robust and sound base.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Key Characteristics of Nottinghamshire

Representation ID: 30565

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q6 Response- Heritage data refers solely to heritage at risk and relates to one paragraph (4.14). Does the HLC or HER offer any additional baseline information that could assist the SA and Plan moving forward?

Q7 Response- There are no apparent inaccuracies in heritage at risk data which is monitored annually.

Q8 Response- There are omissions in the characteristics section for Historic and Cultural heritage. Creswell Crags should be included, para 4.12 should include reference to waterside settlements where the River Trent is mentioned due to potential for palaeolithic remains. Non-designated heritage assets should be referred to possibly in para.4.14.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

5. Sustianbility issues

Representation ID: 30566

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q9 response- Due to the narrow approach earlier on in scoping, the sustainability issue identified is skewed towards listed buildings at risk and potential Trent Valley archaeology when, due to the nature of mineral extraction it is likely that Scheduled Monuments, Registered Parks and Gardens, Conservation Areas and non-designated heritage assets in the County are likely to be mostly affected by the Plan, in particular Creswell Crags in respect of possible dolomite extraction.

Q10 response- Historic England agrees that the Historic Environment and Cultural Heritage has a moderate/high significance to the Plan. The word 'affect' should be replaced with 'harm'.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 2: Sustainability issues

Representation ID: 30567

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q11 response - In relation to the Historic Environment and Cultural Heritage section of Table 2 and how the Plan can influence the sustainability issue we recommend that 'adverse impacts' be replaced with 'harm' in line with NPPF terminology and that reference to the setting of heritage assets is included in line with NPPF requirements. Whilst the text brings other elements together that are mentioned elsewhere in the scoping report, it is recommended that the text be adjusted to reflect any other changes that are made to the scope of the report as it progresses to the next stage.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 3: Proposed sustainability appraisal objectives

Representation ID: 30568

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q12 response- SA Objectives 4 and 5 in respect of the historic environment/cultural heritage and landscape respectively are welcomed.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 4: Proposed SA Objectives, decision making criteria and proposed indicators

Representation ID: 30569

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q13 response- Objective 4 decision making criteria 'have an adverse impact upon' wording should be replaced with 'cause harm to' and add a separate sentence 'Can any such harm be mitigated against?' 'SAM' should be amended to 'SM' in line with current terminology. It is not clear why Conservation Areas are included in the indicators for Objective 5 Townscape and landscape since they are heritage assets of national importance. If suggestions earlier in this response are taken on board it would be worth reviewing whether the CA's issue would fit better in the Objective 4 section.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 7: Relationship between SEA topics and SA objectives

Representation ID: 30570

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Agent: Historic England (East Midlands)

Representation Summary:

Q14 response- Table 7 sets out a limited approach to links for Cultural heritage. Cultural Heritage has synergy with SA objectives 2, 3, 7, 13 and 14 which would provide a wider scope for the SA. SAO2 in respect of green infrastructure areas sometimes coinciding with heritage assets; SAO3 in respect of traffic impact on a place; SAO7 impacts on climate change can impact on buried remains through watering and dewatering similar to flooding; SAO13 there is synergy with economic development in relation to heritage related tourism; and, SAO14 personal engagement with the historic environment can add to wellbeing.

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