Pre- Submission Draft Waste Local Plan

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Object

Pre- Submission Draft Waste Local Plan

4.5

Representation ID: 1017

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This paragraph would benefit from reference to the heritage component of landscape and how heritage has shaped and evolved the local landscape.

Change suggested by respondent:

This paragraph would benefit from reference to the heritage component of landscape and how heritage has shaped and evolved the local landscape.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

4.6

Representation ID: 1018

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We welcome the reference to heritage within this paragraph; the first sentence may consider re-writing as it is long in its current form. Historic Parks should be referred to as Registered Parks and Gardens and Scheduled Ancient Monument should be referred to as Scheduled Monuments. It may be worth including a reference to the variety of non-designated heritage and the role of heritage landscapes. We welcome the reference to heritage at risk. Is there a positive strategy for this and any opportunities through the Plan to reduce this risk?

Change suggested by respondent:

the first sentence may consider re-writing as it is long in its current form. Historic Parks should be referred to as Registered Parks and Gardens and Scheduled Ancient Monument should be referred to as Scheduled Monuments. It may be worth including a reference to the variety of non-designated heritage and the role of heritage landscapes. We welcome the reference to heritage at risk. Is there a positive strategy for this and any opportunities through the Plan to reduce this risk?

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

6.1

Representation ID: 1019

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We welcome the inclusion of the term ‘heritage’ within the vision. We would welcome further consideration of how the heritage of the area will be protected and enhanced by 2038 and what the local plan will put in place to ensure that this occurs

Change suggested by respondent:

We would welcome further consideration of how the heritage of the area will be protected and enhanced by 2038 and what the local plan will put in place to ensure that this occurs

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

Objective 4: The environment

Representation ID: 1020

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

As previously raised, we recommend a specific indicator for heritage so that it is possible to fully consider what the effects are for the historic environment rather than a variety of environmental factors. For example, it is possible that a positive for biodiversity or water management may have a negative for the historic environment and this would not be identifiable in a joint indicator. Where it says ‘avoid harm to heritage’ we would recommend that this is amended to ‘protect and conserve the significance of the historic environment, heritage assets and their setting’ or similar.

Change suggested by respondent:

We recommend a specific indicator for heritage so that it is possible to fully consider what the effects are for the historic environment rather than a variety of environmental factors.

Where it says ‘avoid harm to heritage’ we would recommend that this is amended to ‘protect and conserve the significance of the historic environment, heritage assets and their setting’ or similar.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

Objective 7: High quality

Representation ID: 1021

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The highest possible standard should recognise the need to protect and conserve the significance of heritage assets, including their setting.

Change suggested by respondent:

The highest possible standard should recognise the need to protect and conserve the significance of heritage assets, including their setting.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

7.5

Representation ID: 1022

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We consider that the appropriate policies should be included within the Plan in the first instance to ensure that the Plan is sound and can respond to a variety of planning applications for waste development.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

SP2 - Future Waste Management Provision

Representation ID: 1023

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

How does this policy consider the potential impact of new waste facilities on the significance of the historic environment, heritage assets and their setting? There should be a reference that new facilities will be approved in line with other policies in the Plan.

Change suggested by respondent:

There should be a reference that new facilities will be approved in line with other policies in the Plan.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

SP3 – Broad Locations for Waste Treatment Facilities

Representation ID: 1024

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We raised this issue at the previous stage. See our comments from April 2022. How does this policy consider the implications for the historic environment? There may be appropriate sites located in sustainable locations as per this policy, however, the potential site may be inappropriate due to its harm on the historic environment. How is a positive strategy for the historic environment being pursued in the Plan? Clause 2, what is meant by ‘fit in with local character’? and how will this be assessed? There is very limited information for us to understand where these broad locations may be and as a result what heritage assets may be harmed through development, or indeed if there are any enhancement opportunities? There is no consideration of reasonable alternatives. We consider this wording unsound.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

SP4 – Managing Residual Waste

Representation ID: 1025

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Consideration should be given to the historic environment in the provision of any new facilities. Clause 3 we would recommend a reference to the need to protect the significance of heritage assets including their setting akin to other considerations which are included such as the natural environment.

Change suggested by respondent:

Clause 3 we would recommend a reference to the need to protect the significance of heritage assets including their setting akin to other considerations which are included such as the natural environment.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

Object

Pre- Submission Draft Waste Local Plan

7.30

Representation ID: 1026

Received: 11/10/2023

Respondent: Historic England (Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

All these issues should consider the impact on the significance of the historic environment, heritage assets including their setting. Additionally, any restoration principles should be appropriate in the context of the historic environment and consider the significance of heritage assets and their setting.

Full text:

Our specific comments are attached in Table 1, appended to this letter.
Many thanks for the opportunity to comment on this Regulation 19 Pre-Submission version of the Nottingham City and Nottinghamshire Waste Plan, October 2023. We would like to refer you back to the comments that Historic England raised during the Regulation 18 consultation in April 2022, as largely they remain relevant.
Unfortunately, we do not consider that the Waste Plan has set out a positive strategy for the historic environment, as required by paragraph 190 of the National Planning Policy Framework (NPPF).
There are a number of questions that we have raised in our consultation response about the potential impacts/harm for the significance of the historic environment, heritage assets and their setting.
Whilst we welcome the inclusion of a specific historic environment policy, and we consider this essential, we have raised a number of concerns about specific wording issues and policy areas that are absent from inclusion.
Further, there are a number of policy areas discussed within the Plan where there is the potential for harm to the historic environment and yet there is little or no detail on how this harm can be avoided or mitigated or what measures are required in order to assess the harm. As such we find that these policy areas are not legally compliant or effective.

We would be happy to discuss these issues with the Council and consider appropriate wording that could be included within the Plan to overcome these issues and are available to enter into a Statement of Common Ground if the Councils consider this is an appropriate way forward.

If you have any questions, please contact us.

(Please see attached for table and full representation).

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