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:
We support paragraph 8.77 and consider this aim can be better reflected within the policy. Links to relevant heritage documents such as local lists and landscape and townscape character assessments would be positive.
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)
Duty to co-operate? Not specified
Representation Summary:
We note the reference to archaeology within paragraph 8.78 and consider that this should be reflected in the policy and referenced elsewhere under climate change/ water management issues.
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)
Duty to co-operate? Not specified
Representation Summary:
Many of the paragraphs in the justification we support and consider that these should be better integrated into the policy wording to ensure it is National Planning Policy Framework (NPPF) compliant. We do not however consider that large sections of Section 16 NPPF are necessary to be included within the text. The justification should focus on how the policy clauses can be fully understood with links to appropriate documents and explanation. Paragraph 8.89 and 8.90 for example, there should be a clause within the policy setting out these details.
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)
Duty to co-operate? Not specified
Representation Summary:
Many of the paragraphs in the justification we support and consider that these should be better integrated into the policy wording to ensure it is National Planning Policy Framework (NPPF) compliant. We do not however consider that large sections of Section 16 NPPF are necessary to be included within the text. The justification should focus on how the policy clauses can be fully understood with links to appropriate documents and explanation. Paragraph 8.89 and 8.90 for example, there should be a clause within the policy setting out these details.
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
DM7 - Flood Risk and Water Resources
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
We attach our previous comments as they remain relevant:
As referenced above within Policy SP5 we would welcome recognition of the potential for changes to the watercourse and treatment for flooding and water courses, also need to consider how they may impact upon the historic environment, with particular attention to below ground archaeology. A reference within the justification text is likely to be suitable.
Change suggested by respondent:
we would welcome recognition of the potential for changes to the watercourse and treatment for flooding and water courses, also need to consider how they may impact upon the historic environment, with particular attention to below ground archaeology. A reference within the justification text is likely to be suitable.
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
DM10 - The Cumulative Impact of Development
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
We are supportive of a policy that considers the cumulative impacts of more than one development in a close locality. We consider there needs to be additional detail within the policy for this to be effective.
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)
Duty to co-operate? Not specified
Representation Summary:
We welcome reference to the historic environment within this paragraph. As mentioned in our previous consultation response we do consider that additional detail is needed to understand what the ‘unacceptable cumulative impacts’ may be and how these can be avoided. There needs to be enough detail for a potential applicant to know what they need to provide and for a planning officer to be able to determine an application.
Change suggested by respondent:
Additional detail is needed to understand what the ‘unacceptable cumulative impacts’ may be and how these can be avoided. There needs to be enough detail for a potential applicant to know what they need to provide and for a planning officer to be able to determine an application.
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
DM12 - Highway Safety and Vehicle Movements/Routeing
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Clause 1b) what is meant by ‘an unacceptable impact on the environment’? We would welcome reference to the historic environment within this clause or within the justification text below as these issues can harm the significance of heritage assets and how they are appreciated within their setting.
Change suggested by respondent:
Reference to the historic environment in clause 1b) or within the justification text below.
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
DM12 - Highway Safety and Vehicle Movements/Routeing
Respondent: Historic England (Midlands)
Duty to co-operate? Not specified
Representation Summary:
Our previous comments remain relevant:
Please see comments to Policy DM10 as they also relate here. This should be considered in the whole and whether impacts to the highway through traffic movements etc. are an unacceptable harm for the historic environment and how any future planning applications for new waste facilities will consider the issue of harm to heritage assets resulting from highways and
vehicle movements.
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 c) we would welcome a specific clause that considers the impact on the historic environment and ensures that any development proposals protect and conserve the significance of heritage assets, including their setting, as well as the potential to seeks enhancements. As it stands the clause seeks only to ‘minimise impacts’ rather than ensuring that only appropriate locations are given planning permission and that harm is avoided and mitigated in the first instance. This policy wording needs amending to reflect the National Planning Policy Framework, Section 16.
Change suggested by respondent:
Clause 1 c) we would welcome a specific clause that considers the impact on the historic environment and ensures that any development proposals protect and conserve the significance of heritage assets, including their setting, as well as the potential to seeks enhancements. As it stands the clause seeks only to ‘minimise impacts’ rather than ensuring that only appropriate locations are given planning permission and that harm is avoided and mitigated in the first instance. This policy wording needs amending to reflect the National Planning Policy Framework, Section 16.
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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