Object

Representation ID: 99233

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We have raised concerns about the wording in relation to harm to the historic environment in policy MP2.
In order to make this policy consistent with the NPPF and effective in securing sustainable development, we suggest that the policy wording is amended.

We welcome the addition of designated heritage assets as a bullet point in this policy. Conservation Areas should also be added to this list as they are designated heritage assets.
Substantial harm is a very high bar. Less than substantial harm is still harm and harm should be avoided in the first instance. We suggest that you reword this bullet point to delete the word substantial and add reference to significance and setting.
The bullet point would then read:
a designated heritage asset, including listed buildings, registered parks and gardens, [insert: 'conservation'] areas and scheduled monuments, or their settings if the proposed development would cause [delete: substantial] harm to [delete: or] the [delete: loss] [insert: 'significance'] of the heritage asset [insert: '(including any contribution to significance by setting)'].