Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
Chapter 2 – Spatial Portrait
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
Support
Regulation 18 draft Local Plan
Vision
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.”
Support
Regulation 18 draft Local Plan
Strategic Objective 8:
Representation ID: 7573
Received: 08/01/2024
Respondent: Historic England
Reference to heritage assets and their settings is strongly
welcomed.
Object
Regulation 18 draft Local Plan
Policy CC2 - Design Principles for Energy Efficient Buildings
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.
Object
Regulation 18 draft Local Plan
Policy CC8 - Renewable Energy
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.
Object
Regulation 18 draft Local Plan
Chapter 4 - Climate Change
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.
Object
Regulation 18 draft Local Plan
Policy CC8 - Renewable Energy
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.
Object
Regulation 18 draft Local Plan
Policy SS5 – St. George's Barracks Opportunity Area
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.
Object
Regulation 18 draft Local Plan
Policy SS5 – St. George's Barracks Opportunity Area
Representation ID: 7579
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.
Object
Regulation 18 draft Local Plan
Policy SS6 – Use of military bases and prisons for operational or other purposes
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”