Pre- Submission Draft Waste Local Plan
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Pre- Submission Draft Waste Local Plan
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Comments raised at previous stage. Please find a relevant document included within the link below. This is relevant generally to the Waste Local Plan and the need to consider the effects of waste planning on archaeology.
https://historicengland.org.uk/images-books/publications/land-contamination-and-archaeology
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).
Pre- Submission Draft Waste Local Plan
DM3 – Design of Waste Management Facilities
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Clause 1 b) this should also consider the impact on its surrounding location and ensure that any design features including security fencing are appropriate in the context of its location and the potential harmful effects for the historic environment.
Change suggested by respondent:
Clause 1 b) this should also consider the impact on its surrounding location and ensure that any design features including security fencing are appropriate in the context of its location and the potential harmful effects for the historic 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).
Pre- Submission Draft Waste Local Plan
DM4 – Landscape Protection
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
This policy would benefit from consideration of heritage as a component of landscape. Additionally, how is the historic environment being protected and conserved through this policy and ensuring a positive strategy for the historic environment?
Previous comments still stand.
We would request a reference to heritage landscapes within this policy and the recognition that design, landscaping, planting and restoration principles should be appropriate to the historic landscape that they are in and the setting of heritage assets, where appropriate. We are pleased to see reference to landscape character appraisal evidence that the Councils already have.
Change suggested by respondent:
We would request a reference to heritage landscapes within this policy and the recognition that design, landscaping, planting and restoration principles should be appropriate to the historic landscape that they are in and the setting of heritage assets, where appropriate.
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).
Pre- Submission Draft Waste Local Plan
Respondent: Historic England (Midlands)
Representation Summary:
We support the inclusion of this paragraph.
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).
Pre- Submission Draft Waste Local Plan
DM6 – Historic Environment
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Clause 2 is a useful starting point and should be clear that applications which cause harm to the significance of heritage assets will not be supported. Harm should be avoided/ mitigated and then the tests of public benefits apply. The wording needs amending to reflect this hierarchical approach.
Change suggested by respondent:
Clause 2 is a useful starting point and should be clear that applications which cause harm to the significance of heritage assets will not be supported. Harm should be avoided/ mitigated and then the tests of public benefits apply. The wording needs amending to reflect this hierarchical approach.
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).
Pre- Submission Draft Waste Local Plan
DM6 – Historic Environment
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Clause 3, first sentence, insert between affect and heritage asset – ‘the significance of’.
Change suggested by respondent:
Clause 3, first sentence, insert between affect and heritage asset – ‘the significance of’.
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).
Pre- Submission Draft Waste Local Plan
DM6 – Historic Environment
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
We support the need for a heritage statement to be supplied for any application where harm could occur. Clause 3 c) what is the contribution of the development parcel on the significance of the asset? What is their relationship and how will the significance of the heritage asset be affected as a result of the change? Is the harm necessary/ avoidable.
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).
Pre- Submission Draft Waste Local Plan
DM6 – Historic Environment
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Clause 3 d) should be clear that harm should be avoided as heritage assets are an ‘irreplaceable resource’.
Change suggested by respondent:
Clause 3 d) should be clear that harm should be avoided as heritage assets are an ‘irreplaceable resource’.
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).
Pre- Submission Draft Waste Local Plan
DM6 – Historic Environment
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Consider re-wording of clause 3 e) what is specifically meant here? Mitigation measures should be identified that can overcome the harm to the significance of the heritage asset, including its setting. These mitigation measures should be informed by assessment and then included as planning conditions on the application.
Change suggested by respondent:
Consider re-wording of clause 3 e)
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).
Pre- Submission Draft Waste Local Plan
DM6 – Historic Environment
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Additional points to include within the policy:
• There is no reference to the potential need for archaeological evaluation and assessment or how impacts for different types of heritage assets may be considered.
• We would also recommend design considerations being included to protect heritage assets.
• Where there is harm to heritage assets, resulting in the loss of heritage this should be recorded and as a minimum recorded on the Historic Environment Record.
• Any assessments should be undertaken by an appropriate and qualified professional.
• A clause setting out the potential for enhancement measures would be welcome.
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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