Site Characteristics

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Object

Minerals and Waste Local Plan: Pre-Submission Publication

Representation ID: 99247

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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 this site 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/images-books/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 boundary, there are a number of designated heritage assets quite close by including a cluster of grade II listed buildings at Grange Farm, a cluster at Spixworth Hall and Meadow Farmhouse, also grade II listed. The grade I Church of St Peter and Church of the Blessed Virgin and St Andrew and the grade I listed Priory, also scheduled, both lie within the Horsham St Faiths Conservation Area to the west of the site. Minerals extraction in this location therefore has the potential to affect the setting of a number of designated heritage assets.
We note the proposed mitigation buffer to the south east boundary (shown on the map) of the site which is broadly welcomed. We do welcome criteria a, c and d.
However, given our concerns regarding the impact on a number of nearby designated assets 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 the site is already allocated and that an application is due in 2023, we would still expect the preparation of a brief heritage impact assessment to inform the policy wording, particularly, in respect of potential mitigation for the site.

Change suggested by respondent:

We continue to recommend the preparation of a brief HIA prior to EiP to inform potential mitigation and enhancement measures which should then be incorporated into the policy wording.