Regulation 18 draft Local Plan

Object

Representation ID: 7571

Received: 08/01/2024

Respondent: Historic England

Paragraph 1 is welcomed, however, reference should
also be made to non-designated heritage assets and
archaeology.

Reference to non-designated
heritage assets and
archaeology should be
included in the first paragraph

Comments noted. Chapter 2 gives only a brief overview of the characteristics of Rutland. Reference to non-designated heritage assets and archaeology are better included in the Environment Chapter under Policy EN12.

Support

Representation ID: 7572

Received: 08/01/2024

Respondent: Historic England

Reference to heritage assets in the 6th bullet point is
welcomed. This should also include reference to settings.
Reference to the historic environment within the 11th
bullet point is welcomed.

Bullet point 6 could be amended to read:-
“protection and preservation of heritage assets and their
settings together with the natural environment.”

Add in and their settings to the bullet.

Support

Representation ID: 7573

Received: 08/01/2024

Respondent: Historic England

Reference to heritage assets and their settings is strongly
welcomed.

Support noted.

Object

Representation ID: 7574

Received: 08/01/2024

Respondent: Historic England

There is no reference to listed buildings and other
heritage assets.

Historic England would be very happy to assist with wording. Examples might include reference to a whole building approach in the retrofitting of traditional buildings, whereby applications will need to demonstrate how principles such as the following have been embedded in the design rationale – methodical assessment of the buildings heritage significance, harm to heritage significance, advice from heritage professionals.

Noted but Policy CC2 should not be read in isolation as set out in ‘How to use the Plan’ in the opening chapter. The accompanying text to CC2 makes reference to Policy SC3 and the Design Guidelines for Rutland SPD (2021) (which recognises the importance of the rich heritage that Rutland has when designing schemes). Local Plan policies EN12 and EN13 consider the protection of the historic environment.

Object

Representation ID: 7575

Received: 08/01/2024

Respondent: Historic England

There are significant concerns and objections regarding
the proposed “broad area suitable for Larger Scale Wind
Energy Turbines" as identified on the Policies Map, its
supporting evidence base and corresponding policy.

If a wind map is to be included it should be explicit about what it is a map of and in what sense areas are defined as suitable; specifically what material considerations in respect of future planning applications have not been adequately considered in the mapping but
which would need to give great weight to designated and
equivalent heritage assets, with particular reference to
setting impacts. The approach proposed does not reflect
this.
Consequently, it is considered that the approach of Policy
CC8, the Renewable Energy Study and the
corresponding ‘Wind Map for broad areas suitable for
Larger Scale wind Energy Turbines’ does not comply with
the NPPF:-
The plans showing wind areas cannot support a sound
Local Plan policy in relation to renewable energy, as they
are not based on a robust evidence base or methodology
nor do they adequately address the historic environment
as set out above. As such, the wind map with the areas
shown should not be included in its present form. The evidence base is not robust nor the wind map acceptable as set out above.

Comments noted. Agree further text required explaining which principal constraints have been used in the mapping of the potentially suitable areas in the Rutland Renewable Energy Study and what other site specific constraints would need to be applied in the assessment of a planning application for wind energy development. A similar approach is used in the text accompanying the Central Lincs renewable energy policy.

Object

Representation ID: 7576

Received: 08/01/2024

Respondent: Historic England

The Renewable Energy study does include reference to heritage, Grade II listed buildings and setting of heritage assets are not referenced nor are archaeology and non-designated heritage assets. Setting is of particular importance when assessing the impact of wind turbines.There is
strong concern regarding the methodology and
assessment of setting. Individual turbine locations are
shown on Figure 13, will a settings assessment be
undertaken? How was the 500 metre buffer considered for
RPAG’s? In particular, proximity should not be used as a
gauge of harm or impact when considering setting. The use of proximity does not comply with the NPPF; impact upon the setting of assets can occur from a great distance and not simply from sites ‘in close proximity’ to an asset,
dependant on the type of development.

The Renewable Energy Study Parts 1 and 2 (November 2023) forms part of the supporting evidence for Policy CC8. Historic constraints (Scheduled Monuments, Conservation Areas and Listed Buildings) are shown on the constraints figure. Impact on heritage assets and their setting is included in the criteria based policy CC8 on Renewable Energy. A similar criteria-based policy for renewable energy is in the adopted Central Lincolnshire Local Plan. In addition to Policy CC8, other Local Plan policies would be used to assess renewable energy schemes such as EN12 and EN13 which consider the historic environment and heritage assets, and their settings. Other guidance such as the NPPF/NPPG would also be used in the assessment of applications for renewable energy schemes. The NPPG recognises that the significance of a heritage asset derives not only from its physical presence but also from its setting, so careful consideration should be given to the impact of wind turbines on such assets.

Object

Representation ID: 7577

Received: 08/01/2024

Respondent: Historic England

The areas which have been identified in the Renewable Energy Study as being suitable for such developments may result in harm to a number of Rutland’s most important designated heritage assets and hence render policy CC8 incompatible with the NPPF’s overarching objectives of sustainable development and specifically paragraph 196.

Consequently, it is considered that the approach of Policy
CC8, the Renewable Energy Study and the corresponding ‘Wind Map for broad areas suitable for Larger Scale wind Energy Turbines’ does not comply with the NPPF.

Whilst criteria a) “heritage assets, their settings and the
historic landscape” is welcomed and a robust assessment
would be required and should be specified within policy
CC8, similar to the requirement for criteria c), as
proposed the policy is not sufficient and the evidence
base is not robust nor the wind map acceptable as set out
above.

Comments noted. Disagree as explanation in policy about compliance with part a) is via applicable policies in the Local Plan (including EN12)/any relevant Neighbourhood Plan and a future SPD.

Object

Representation ID: 7578

Received: 08/01/2024

Respondent: Historic England

Criteria d) does not provide sufficient detail regarding the
nationally important heritage assets at the site. Historic
England have had extensive informal pre-submission
engagement, please refer to our previous
correspondence. Historic England would be very happy to
discuss further. Why is this policy needed supporting text:-
The first bullet point within key issues is strongly
welcomed.

Criteria d) should be revised to:-
d) be accompanied and influenced by a Heritage Impact Assessment and identifying the potential impact of
development on heritage assets including their settings
and an evaluation of the known and potential archaeological significance of the area. The masterplan should demonstrate how important heritage assets, such as the Thor Missile site (grade II* listed building) will be
protected, identifying options for the adaptation and re-use of existing historic buildings where possible, and determining how the historic layout of the site will be
reflected in new development.

Noted. Add in additional criterion for SGB.

Object

Representation ID: 7580

Received: 08/01/2024

Respondent: Historic England

Criteria d should reference heritage assets and their
settings to reflect NPPF wording.

The following phrase could be added to end of criteria “including heritage assets and their settings”

Agree. Add to criteria d): ‘and heritage assets and their settings’.

Object

Representation ID: 7581

Received: 08/01/2024

Respondent: Historic England

Criteria c should reference heritage assets and their
settings to reflect NPPF wording.

The following phrase could be added to end of criteria c)
“including heritage assets and their settings”

Agree. Add to criteria c): ‘and heritage assets and their settings’.