Waste Issues and Options

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,

NOTTINGHAMSHIRE AND NOTTINGHAM WASTE LOCAL PLAN - ISSUES AND OPTIONS DOCUMENT AND SUSTAINABILITY APPRAISAL (SA) SCOPING DOCUMENT

Thank you for the opportunity to engage with the above consultation. As the Government’s adviser on the historic environment Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account at all stages and levels of the development plan document.

Please find below our comments on the Issues and Options document and the SA Scoping document.

Issues and Options Document

We have set out responses to questions which are relevant to our remit below.

Q2: Overview of Plan and implications for the management of waste

The historic environment is not mentioned in paragraphs 3.2 - 3.12 and it is recommended that it is represented as an issue within the Plan. Nottingham City and the District and Borough Councils in Nottinghamshire include a rich variety of heritage assets and any impact on these assets would need to be considered by the Plan as it progresses.

Q4: Managing waste streams; and,
Q7: CDE Scenarios

Historic England’s 2019 Heritage Counts report focuses on reuse and recycling buildings to reduce carbon and highlights alternative opportunities to demolition of existing fabric and new build which produces C, D and E waste. This information may be of use as evidence base information for the PPP section of the Sustainability Appraisal associated with the Plan in respect of the above questions. In addition the 2019 report includes reference to the work undertaken by Poyntons, commissioned by Nottingham City Council, in respect of new homes over commercial uses in existing built fabric. This may be of relevance to CDE waste scenarios and any economic outcomes from the current pandemic situation. Links to relevant web pages and information are as follows:

<https://historicengland.org.uk/whats-new/news/recycle-buildings-tackle-climate-change/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

Q10: Energy recovery options

It is recommended that any new sites identified for potential energy recovery facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q11: Additional disposal capacity

It is recommended that any new sites identified for potential additional disposal facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q12: Draft vision

The inclusion of heritage protection within the draft vision is welcomed.

Q13: Plan Objectives

Objective 3 relates to the environment and refers to built and natural heritage. It is recommended that this be revised to read ‘built, historic and natural environments’ or a similar alternative. At present, ‘built heritage’ refers only to buildings in respect of the historic environment and any buried archaeological remains would not be included in the Plan objectives contrary to the requirements of the NPPF.

Q14: Broad locations for future waste management facilities

It is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q15: Future provision - general criteria or specific site allocation

Whichever approach/approaches is/are used in the Plan for future provision, the Plan will need to demonstrate a positive approach to the historic environment and that its future provision requirements are achievable and deliverable in respect of the historic environment. As with previous question responses it is recommended that any new sites identified for potential future waste management facilities are assessed by using the five step site allocation assessment methodology set out in Historic England’s Advice Note 3: The Historic Environment and Site Allocations in Local Plans:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

Q16: Scope of Development Management policies

The inclusion of a heritage policy in respect of decision making is welcomed.

Sustainability Appraisal Scoping Report

We have set out responses to questions which are relevant to our remit below.

Q1: SEA and SA requirement explanation

It is noted that para 1.3 refers to our natural, built and historic environment and the inclusion of both ‘built’ and ‘historic’ environments are welcomed.

Q2: Methodology

The proposed methodology is noted and we would welcome opportunity to engage with you further in due course, as the Plan and SA develop, in respect of any assessment criteria for the historic environment.

Q3: Appendix 1 relevant documents

In respect of the Historic (environment?) and cultural heritage section it is recommended that the following Historic England documents are referred to:

<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/>

<https://historicengland.org.uk/research/heritage-counts/2019-carbon-in-built-environment/>

It is noted that Historic Landscape Characterisation is referred to in the Landscape section and this is welcomed.

Q4: Key messages

In respect of the Historic (environment?) and cultural heritage section the key messages do not sit well with NPPF requirements in respect of the differentiation of substantial and less than substantial harm. If this is not reconciled in the SA it may have implications for the Plan in respect of soundness at a later stage. We would be happy to discuss this with you further in due course.

Q5: Implications for SA Framework

In respect of the Historic (environment?) and cultural heritage section the last part of the SA Framework implication does not sit well with NPPF para.199 which states that ‘the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’. This could perhaps be addressed by amended wording in line with that contained in the key messages section Bullet Point 6 (BP6).

Q6: Baseline data

It is recommended that Grade II listed buildings are included in the baseline information in addition to non-designated heritage assets and setting including any locally listed assets. It is also noted that there is no reference made to Cresswell Crags which is on the tentative list for World Heritage Sites.

Q7: no response

Q8: Key characteristics

It is recommended that the Historic Environment and Cultural Heritage section refers more fully to its archaeological past and include reference to Cresswell Crags.

Q9: Sustainability issues; and,
Q10: Significance

The issues for the historic environment and cultural heritage are noted and the moderate/high significance to the Plan is accepted.

Q11: Plan influence on issue

The influence set out for the historic environment and cultural heritage is noted. It is recommended that ‘preservation’ be replaced with ‘conservation’ since all heritage assets are covered by the issue and would be in line with NPPF terminology.

Q12: SA Objective

The SA objective in respect of the historic environment and cultural heritage is welcomed in respect of the Waste Plan.

Q13: Decision making criteria and proposed indicators

In respect of the historic environment the decision making criteria are noted. It is recommended that an additional indicator relating to opportunities for enhancement and better revealing of assets is included and that non-designated assets are referred to in a separate indicator.

Q14: Other comments on Scoping Report

We are not convinced that the Internal compatibility of the SA objectives set out in Table 6 is an accurate reflection of the synergy the Historic Environment SA objective has with other SA objectives. At present it is indicated as linking with SA objectives 1, 5, 6 and 9 as well as itself (4). However, it is an iterative process and we look forward to working with you on the Plan and its SA as it progresses.

Should you have any queries please do not hesitate to contact me.


Yours sincerely,