Object

Representation ID: 99224

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst we appreciate that you have made some changes to policy MW1 to include more references to the historic environment, which is welcome, it is still our view that there is currently insufficient policy provision for the historic environment in the Plan. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. We are particularly concerned about the lack of detail in relation to below ground archaeology. In order to make this policy consistent with the NPPF and effective in securing sustainable development, we suggest that the policy wording is amended.

Although our preference would be for a separate historic environment policy, we recognise that this policy is now much more detailed in relation to the historic environment which is welcomed.
We note that the policy has been expanded to include greater reference to the historic environment which is welcomed. This has included reference to the NPPF, balancing harm and public benefit and avoiding harm in the first.
The policy does reference cumulative effects and enhancement which is welcomed.
The policy now also includes reference to the need to conserve and where opportunities arise enhance the historic environment which is welcomed.
In the list of bullet points we suggest a minor rewording to read;
• the [delete: setting] significance of heritage assets [insert: '(including any contribution made to significance by setting)'] and protected landscapes,
Although this represents an improvement on the previous draft of the policy, we remain concerned that the policy does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. This policy remains unsound as it does not meet the requirements of paragraph 210(f) of the Framework.
In fact, Policy MW2 appears to be a similar list of areas to cover in paragraph 210 but provides limited historic environment criteria against which planning applications will be assessed so as to ensure that there are no unacceptable adverse impacts.
As this policy underpins all the other policies in the plan we are concerned that, as drafted, this policy undermines the plan.
We are also concerned about the lack of detail in relation to below ground archaeology in this policy. In relation to archaeology, we offer the following more detailed advice:
When considering the historic environment, it is necessary to consider the below ground archaeological remains which includes structures, artefacts, and deposits/features of palaeoenvironmental and geoarchaeological interest such as palaeochannels.
The potential for these sorts of remains to be present, both within the area of proposed works and in the adjacent areas needs to be investigated as part of the desk-based assessment and evaluation stages.
The impacts of the proposed extraction works also need to be considered in terms of the direct and indirect impacts that may occur. This includes the potential for the works to alter the groundwater levels within the areas of the proposed works and in adjacent areas, which may affect the movement of water through archaeological deposits, or the preservation conditions. If this occurs it can result in the damage or even loss of vulnerable archaeological remains, such as waterlogged wood, leather or palaeoenvironmental remains, or effect the preservation of archaeological materials (e.g. peat).
There is also the potential for the effects of mineral extraction to impact adjacent areas. For example, hydrological assessments were carried out before, during and after the extraction of materials at the Over quarry, Cambridgeshire, which demonstrated that ground water levels were lowered by between 2 to 5m up to 500m from the quarry face (French 2004, Environmental Archaeology vol 9).
We would therefore recommend that the following Historic England documents are referred to in terms of the materials that may be present and how the potential impacts could be investigated, such as changes to the groundwater levels or chemistry in the area:
Preservation of Archaeological Remains (2016):
https://historicengland.org.uk/images-books/publications/preserving-archaeological-remains/
Environmental Archaeology (2011):
https://historicengland.org.uk/images-books/publications/environmental-archaeology-2nd/
Geoarchaeology (2015):
https://historicengland.org.uk/images-books/publications/geoarchaeology-earth-sciences-to-understand-archaeological-record/