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Publication Draft
Providing well-designed new developments that are in the right location and address climate change
Representation ID: 66063
Received: 27/06/2014
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
EH welcomes the principle of this sub objective however suggests a minor clarification to ensure consistency with national planning policy.
See attachment.
Support
Publication Draft
DS3 Supporting Sustainable Communities
Representation ID: 66064
Received: 27/06/2014
Respondent: Historic England
We welcome, support and endorse this policy.
See attachment.
Support
Publication Draft
CT7 Warwick Castle and Warwick Racecourse/St Mary's Lands
Representation ID: 66065
Received: 27/06/2014
Respondent: Historic England
EH welcomes the principle of the initiative. Due to the national importance of the Castle and the intended role of the masterplan in shaping the future of the site, English Heritage would welcome the opportunity be a partner in its preparation.
If the masterplan is to be a development plan should its preparation be subject to the same rigor and discipline of a local plan?
It should also be recognised that Warwick Castle is also a Scheduled Monument
See attachment.
Support
Publication Draft
H4 Securing a Mix of Housing
Representation ID: 66066
Received: 27/06/2014
Respondent: Historic England
We welcome, support and endorse this policy.
See attachment.
Support
Publication Draft
SC0 Sustainable Communities
Representation ID: 66067
Received: 27/06/2014
Respondent: Historic England
We welcome, support and endorse this policy.
See attachment.
Object
Publication Draft
CC2 Planning for Renewable Energy and Low Carbon Generation
Representation ID: 66068
Received: 27/06/2014
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
As drafted this criteria is inconsistent with the NPPF. Its core planning principles in para 17 mention both the Government's desire to encourage the use of renewable resources and the need to 'conserve heritage assets in a manner appropriate for their significance'.
See attachment.
Object
Publication Draft
Transport
Representation ID: 66070
Received: 27/06/2014
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Although we support this policy, it is not clear that the implications for the historic environment arising from major development to the south of Warwick have been fully addressed in accordance to such a commitment.
See attachment.
Object
Publication Draft
TR1 Access and Choice
Representation ID: 66071
Received: 27/06/2014
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Mindful of the commitment in paragraph 5.29 and 5.41 it is of concern there is no criteria in this policy to ensure transport infrastructure responds positively to the historic environment.
It is not clear whether such guidance has been applied to inform an understanding of the implications for the historic environment arising from major development to the south of Warwick.
See attachment.
Object
Publication Draft
TR2 Traffic Generation
Representation ID: 66072
Received: 27/06/2014
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy fails to address the appropriate response arising from development that results in increased traffic generation potentially harming the significance of the Districts historic environment.
Whilst a commitment to undertake such an assessment is welcomed it needs to take place at this stage, rather than when a planning application is submitted to inform the principle of the strategic allocations to the south of Warwick.
See attachment.
Object
Publication Draft
H06 East of Kenilworth (Thickthorn)
Representation ID: 66075
Received: 27/06/2014
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The development affects Thickthorn Manor and the Glasshouse Roman Settlement. There is no evidence to demonstrate a proper assessment has been undertaken to inform the principle of development, nor, without prejudice, the critical design response (mitigation).
It should be appreciated that due to the former Roman occupation of the site there also needs to be an assessment of the likelihood that currently unidentified archaeology, potentially of national importance, will be discovered (NPPF para 169).
Without such an assessment the local authority is unable to assert that the objectives for sustainable development have been met.
There appears to be a failure to demonstrate that great weight has been given to the conservation of the heritage assets (NPPF para 132) nor a recognition of the legislative expectation that special weight is paid to the desirability of preserving the setting of the affected Manor. The Ancient Monument and Archaeological Areas Act gives provision for the protection of the scheduled Roman Settlement.
The significance of a heritage asset derives not only from its physical presence but also from its setting - the surroundings in which it is experienced. Consequently English Heritage considers the Plan is inconsistent with the provisions of the NPPF and therefore unsound.
See attachment.