Object

Representation ID: 99257

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We continue to have concerns regarding the potential impact of this allocation on heritage assets. We consider that there is insufficient historic environment evidence to justify its allocation.
Whilst we appreciate that an application is due shortly, we would still expect the preparation of a heritage impact assessment to inform the policy wording in the Local Plan, particularly, in respect of potential mitigation for the site.
Prepare a proportionate HIA now ahead of the application and EiP to consider the suitability or otherwise of the site and inform its extent and any potential heritage mitigation. The findings of the HIA would then need to inform the policy and supporting text.
In order to justify this allocation, ensure consistency with the NPPF and to make the policy wording effective, for these sites we recommend an HIA is prepared now in advance of the EiP. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate and need not necessarily be particularly onerous. For this site a fairly brief HIA will suffice. Our site allocations advice note https://historicengland.org.uk/imagesbooks/
publications/historic-environment-and-site-allocations-in-local-plans/ provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.

Whilst there are no designated heritage assets within the site boundaries, there are a number of grade I and grade II listed buildings in close proximity to the site. Of particular concern is the impact on the setting of the Grade I listed Church of St Mary, just 110m away and also the grade II listed White House Farm only 70 metres away. Whilst we note that indicative site buffers/screening are shown on the map, we are still very concerned at the potential impact of the proposed allocation on heritage assets.
We note that the plan states that users of the road would not have views of the mineral extraction when viewing the church, but that is not the same as not affecting the setting. Setting impacts can are not just visual but can include noise, dust, vibration etc.
Indeed, in relation to the previous application on this site we raised strong objections and we advised that ‘In considering the contribution to the historic significance of the church made by its setting, it is clear that some harm will result from the proposed quarry, both during its period of activity and from the permanent change to the landscape.’
Although we appreciate that unlike the previous application, the allocation is just to the north of the road. However, we continue to have concerns regarding the potential impact of the allocation on heritage assets.
To that end we recommended that a Heritage Impact Assessment is completed at this stage to assess the suitability or otherwise of the allocation and extent of the site and consider any mitigation that might be necessary should the site be found suitable from a heritage perspective. The findings of the HIA would then need to inform the policy and supporting text.
Whilst we appreciate that an application is due in late 2022, we would still expect the preparation of a heritage impact assessment to inform the policy wording in the Local Plan, particularly, in respect of potential mitigation for the site.
We do welcome criteria a, b, g and h. In addition, we welcome the screening to the around the edge of the site as shown on the map extract.