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Representation 2651 on Preferred Options Local Plan by Historic England -East of England (Ms N Gates)

Support / Object: COMMENT
Document Link: Preferred Options Local Plan - Central Colchester: Town Centre, TC3: Town Centre Allocations
Representation: We welcome the requirements in respect of archaeological investigation and consideration of the conservation area and listed buildings for;

St Boltoph's
Britannia Car Park and Nunns Road Car Park (also refer to proximity to Conservation Area)

Vineyard Gate should make reference to the scheduled town wall, part of which forms part of the Vineyard Gate site, its setting, and archaeological potential.




We would note that some of the Local Economic Areas are within or adjoining the conservation area and any proposals relating to those sites should preserve or enhance the conservation area and its setting.

Original submission

Ref: Preferred Options Local Plan Consultation

Thank you for consulting Historic England on Colchester's Preferred Options local plan. Historic England has published a number of Good Practice Advice and Advice Notes which you may find useful in developing your local plan. In particular:

Good Practice Advice in Planning 1 - the historic environment in local plans: <https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/>

Good Practice Advice in Planning 3 - the setting of heritage assets: <https://content.historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/gpa3.pdf/>

Advice Note 1 - conservation area designation, appraisal and management: <https://historicengland.org.uk/images-books/publications/conservation-area-designation-appraisal-management-advice-note-1/>

Advice Note 3 - site allocations in local plans: <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>.

We have confined our comments to the Local Plan Draft. Unfortunately, owing to current staffing capacity we have been unable to review and comment on the Settlement Boundary Review, Traffic Modelling Report, Strategic Land Availability Assessment, Sustainability Appraisal and Strategic Environmental Assessment.

We recommend that you review our advice entitled Strategic Environmental Assessment, Sustainability Appraisal and the Historic Environment:<https://content.historicengland.org.uk/images-books/publications/strategic-environ-assessment-sustainability-appraisal-historic-environment/SA_SEA_final.pdf/>




We have also produced updated advice on the matter which is currently out for public consultation. This document, entitled Sustainability Appraisal and Strategic Environmental Assessment Historic England Advice Note 8 can be found at: <http://content.historicengland.org.uk/content/docs/guidance/sea-advice-note-consultation-draft-jul16.pdf>

Our specific comments on the preferred options local plan follow.

Chapter 2 - Shared Strategic Plan for North Essex

The Vision

We welcome the reference to protecting and enhancing the rich historic environment of North Essex in paragraph 3.28.

Strategic Objectives

These high level strategic objectives for the wider area of North Essex are quite generic and the National Planning Policy Framework's (NPPF) requirement for sustainable development, including the historic environment, could be reflected more specifically in the text, for example through requiring developments to respond to the distinctive character of North Essex as part of providing sufficient new homes and ensuring high quality outcomes in paragraph 3.29.

SP4 Infrastructure and Connectivity

We note the aspiration set out in paragraphs 3.58-3.60 and policy SP4 for dualling the A120 between Braintree and the A12. We have been invited to be part of the Highways England Environmental Forum. We would note that the A120 is a historic route through Essex and as such there is great archaeological potential, alongside the potential impacts on heritage assets, which may vary, depending on the options developed.

In respect of broadband we would expect to see reference, though not a hyperlink, in the supporting text (paragraphs 3.72 and 3.73) to the Cabinet Siting and Pole Siting Code of Practice:<https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/205744/Final_Cabinet_and_Pole_Siting_COP_Issue_1_2_.pdf>






SP5 Place Shaping Principles

We welcome the commitment to creating quality places set out in paragraphs 3.74, 3.75 and Policy SP5. We would suggest that the first bullet point of the policy is clarified to read: "...enhance the quality of existing places." We would refer you to our comments below relating to specific sites and proposals.

SP6 Spatial Strategy for North Essex

We welcome the commitment that future growth will be planned so that settlements maintain their distinctive character, role and to avoid coalescence. We also welcome the aspiration for a high quality of built and urban design. We would suggest that what this means for North Essex should be set out in the supporting text and the policy.

SP7 Development and Delivery of New Garden Communities in Essex

Whilst we welcome some of the detail contained within the policy, particularly criterion x, it is difficult to comment on the impact of the proposed settlement and potential harm to heritage assets without seeing the boundaries of what is proposed. In particular, it is difficult to assess what harm would be caused to the historic environment by the New Garden Community and whether what was proposed was appropriate, in terms of the historic environment. This also extends to providing advice on the policy as set out. Notwithstanding this point, we would additionally recommend a criterion setting out how the historic environment and heritage assets can form part of the development of successful schemes.

SP8 East Colchester / West Tendring New Garden Community

Whilst we welcome some of the detail contained within the policy, particularly identifying heritage assets and topography as being key for design, it is difficult to comment on the impact of the proposed settlement and potential harm to heritage assets without seeing the boundaries of what is proposed. In particular, it is difficult to assess what harm would be caused to the historic environment by the New Garden Community and whether what was proposed was appropriate, in terms of the historic environment. This also extends to providing advice on the policy as set out.

SP9 West of Colchester/East of Braintree New Garden Community

Whilst we welcome some of the detail contained within the policy, particularly identifying heritage assets and topography as being key for design, it is difficult to comment on the impact of the proposed settlement and potential harm to heritage assets without seeing the boundaries of what is proposed. In particular, it is difficult to assess what harm would be caused to the historic environment by the New Garden Community and whether what was proposed was appropriate, in terms of the historic environment. This also extends to providing advice on the policy as set out.

Chapter 3 Vision and Objectives

We welcome the reference to how Colchester's character reflects the rich history of the town in paragraph 3.4. We support the inclusion of the historic environment within the vision for Colchester as a strategy for the historic environment, as per paragraph 126 of the NPPF, will be embedded in the vision for an area. We support the text in paragraph 3.9 which sets out that surrounding settlements will remain 'distinctive and thriving villages' and that landscape will be protected and enhanced. We would recommend a similar vision for the historic environment, setting out how it will be protected and enhanced across the Borough.

We welcome the identification of protecting the environment, good quality design, and streetscapes as key objectives in paragraph 3.15. Whilst we welcome the references to sustaining Colchester's historic character through its buildings, townscape and archaeology; more explicit reference to the historic environment should be made in the previous bullet point relating to the whole Borough.

Chapter 5 Environmental Assets Policies

ENV1: Natural Environment

We recommend that the Natural Environment Policy section and Policy ENV1: Natural Environment are renamed given the inclusion of this historic environment within this section and policy. We suggest the Natural and Historic Environment Policy and Policy ENV1: Natural and Historic Environment Policy.

We welcome the description of Colchester's environment in paragraph 5.1 which encompasses landscape character, archaeology and cultural heritage. However, we would recommend a slight amendment to the wording so that is reads: "...in terms of its natural and historic environment including biodiversity, landscape character....."

In paragraph 5.9 we would suggest clarifying what is meant by: "....without harm to the built environment" in respect of the historic environment in its widest sense (buildings and structures, archaeology, townscape and landscape). We welcome the commitment in paragraph 5.10 to preventing coalescence and maintaining settlement identity.

We welcome paragraph 5.11 on the protection of the historic environment and the references to Townscape Character Assessment, Characterisation, and the Urban Archaeological Database.



ENV 2: Coastal Areas

We recommend the use of the term 'heritage asset' rather than 'historic environment asset' throughout this section and policy ENV2 for consistency with the terminology in the NPPF. We would suggest that the supporting text paragraph 5.13 should be redrafted as currently statutorily protected aspects such as habitats and heritage assets have been described as 'competing interests' with recreational activities and fishing. We suggest: "As a consequence there are a number of diverse planning considerations and land uses which all need to be managed in an integrated way within the Borough's coastal belt. These include internationally important habitats, land and water-based recreation, fishing, and heritage assets (including archaeological). Climate Change including sea level rise..."

ENV 4: Dedham Vale Area of Outstanding Natural Beauty

We welcome a specific policy within the plan for the AONB linked to its special qualities. We would recommend a small amendment to Policy ENV4: "Application s for major development within or in close proximity to the boundary of the Dedham Vale Area of Outstanding Natural Beauty will be refused unless in exceptional circumstances and where it can be demonstrated that the development is in the public interest and this outweighs other material considerations."

CC1: Climate Change

Paragraph 5.45 should be amended in respect of the types and groups of heritage assets and traditionally built buildings which are exempt and those where special considerations apply in respect of certain energy efficiency measures. The information can be found on pages 14 and 17 of Historic England's advice Energy Efficiency and Historic Buildings - Application of Part L of the Building Regulations to historic and traditionally constructed buildings <https://content.historicengland.org.uk/images-books/publications/energy-efficiency-historic-buildings-ptl/eehb-partl.pdf/> Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. Any policy encouraging energy efficiency should note that the application will be different in relation to these classes of buildings. In policy CC1, we recommend the addition of 'where appropriate' after "supporting energy efficiency improvements to existing buildings in the Borough where appropriate."


Chapter 6 Places

Please note that we are unable to comment at this time on the capacity of each suggested site allocation to accommodate the number of dwellings proposed. Any comments on allocations do not extend to agreement of the proposed dwelling numbers.

Colchester

TC1: Town Centre

We welcome the identification of the important historic character of the town centre within the policy and the commitment that it must be protected and enhanced by all development, with links through to the historic environment policy. We support the aspiration for attractive public spaces and streetscapes which will further enhance the character of historic Colchester.

TC3: Town Centre Allocations

We welcome the requirements for St Boltoph's in respect of archaeological investigation and consideration of the conservation area and listed buildings.

Vineyard Gate should make reference to the scheduled town wall, part of which forms part of the Vineyard Gate site, its setting, and archaeological potential.

We welcome the reference in the Britannia Car Park proposed allocation to the setting of the scheduled monument, the Priory, and archaeological potential. However, the proximity to the conservation area, therefore consideration of how its setting could be enhanced should also be included.

We welcome the archaeological provision for Nunns Road Car Park but it also should reference its location within the conservation area and require development to preserve and enhance the character of the conservation area. In addition, any impact on the listed buildings in proximity to the site should be considered.

We would note that some of the Local Economic Areas are within or adjoining the conservation area and any proposals relating to those sites should preserve or enhance the conservation area and its setting.

EC1: Knowledge Gateway

We are surprised that reference is not made through the policy and supporting text to the numerous heritage assets that form part of the area. Grade II* Wivenhoe House set within grade II Wivenhoe registered park and garden and with a number of ancillary grade II buildings. We recommend that consideration of these assets and their setting is incorporated into the policy.

EC2: East Colchester - The Hythe Special Policy Area

Hythe has been a conservation area at risk for a number of years. We note that the policy sets out how improvements for the natural environment will be made, but measures to address the at risk status for the designated heritage asset have not been explicitly made. We would suggest consideration in the supporting text, linked to an objective within the policy on how this will be addressed.

EC3: East Colchester

We welcome the information in the supporting text for the East Bay Mill site, although note that there are a number of heritage assets within this proposed allocation which will require consideration.

The Magdelen Street proposed allocation supporting text would benefit from references to the designated heritage assets within the area, including the conservation area. This also should be reflected in the policy wording.

WC1: Stanway Strategic Economic Area

We would note that whilst Stanway has an established economic role and has seen much new development, there remain a number of listed buildings in the area whose setting and use should be considered as the area is identified for growth.

WC3: Colchester Zoo

We welcome the reference to the scheduled monument in the supporting text but would recommend its inclusion within the policy wording.

WC4: West Colchester

We welcome the policy wording for the Land at Gosbecks in respect of the scheduled monument and archaeological potential. We welcome the policy reference to the Essex County Hospital Development brief.


Garden Communities

We would refer you to our comments made above in Chapter 2 and our previous comments made in our letter dated 27 February 2015.


Sustainable Settlements

SS1: Abberton and Langenhoe

We welcome the identification of the proximity of grade II Pete Tye Hill to the proposed allocation. We welcome reference in the policy to archaeological considerations as well as design and landscaping in respect of Pete Tye Hill.

SS2: Birch

Consideration should be given to the setting to the rear of the grade II buildings of the Hare and Hounds Public House, Heath House and The Manse in respect of the proposed allocation. We also note that Birch is on the Conservation Areas at Risk Register.

SS3: Boxted

As noted in the Boxted Neighbourhood Plan, grade II Hill House and a separately listed grade II wall are immediately north of this allocation and any proposals for this site should take account of the setting of these heritage assets.

SS4: Chappel & Wakes Colne

We welcome the identification of the proximity of grade II Hill House, Martyn's Croft and Brook Hall to the proposed allocation. We welcome reference in the policy to good design and landscaping.

SS5: Copford & Copford Green

We welcome the identification of grade II Brewers Cottage, but note that grade II Old Mill House and grade II Shrub House appear to share boundary with the propose allocation at land to the east of Queensbury Road and consideration should be made to their setting. We welcome that design and landscaping in respect of heritage assets appears in the policy in relation to both proposed allocations and the requirement for archaeological consideration.

SS6: Dedham and Dedham Heath

We welcome the identification of grade II Old Church House next to the proposed allocation at land north of Long Road East. We welcome reference in the policy to archaeological considerations as well as design and landscaping in respect of Old Church House.


SS7: Eight Ash Green

We would note that the broad direction of growth for Eight Ash Green, to be determined by a Neighbourhood Plan, potentially impacts on the setting of grade II listed building. As the Neighbourhood Plan and the site allocations are developed consideration of this heritage assets and its setting is required in order to determine appropriate locations and densities for growth.

SS8: Fordham

We welcome the identification of the proximity of a listed building to this proposed allocation. We welcome reference in the policy to archaeological considerations as well as design and landscaping.

SS9: Great Horksley

We welcome the identification of heritage assets in respect of both proposed allocations in Great Horkesley. We welcome reference in the policy to good design and landscaping.

SS10: Great Tey

We welcome the identification of grade II Rectory Cottage but would note that the proposed site allocation abuts the conservation area boundary, which is not mentioned in the supporting text or policy. This should be amended. We welcome reference in the policy to archaeological considerations as well as design and landscaping.

SS11: Langham

We welcome the identification of listed buildings in respect of the School Road sites, but would highlight the potential impact of the Wick Road proposed allocation on the setting of grade II Mantons. We welcome reference in the policy to archaeological considerations as well as design and landscaping.

SS13: Marks Tey

Given the substantial proposals relating to Marks Tey, we are surprised that the supporting text does not reference the significant number of grade II listed buildings in Marks Tey, the scheduled brick kilns and the grade I Church of St Andrew. At this stage it is difficult to comment as which heritage assets will be affected is unknown. However, we note that the broad areas of growth indicated on the maps, to be brought forward through the Marks Tey Neighbourhood Plan may affect designated heritage assets. As the Neighbourhood Plan and the site allocations are developed consideration of these heritage assets and their setting is required in order to determine appropriate locations and densities for growth.

SS15: Tiptree

We note that the broad areas of growth indicated on the maps, to be brought forward through the Tiptree Neighbourhood Plan may affect designated heritage assets. As the Neighbourhood Plan and the site allocations are developed consideration of these heritage assets and their setting is required in order to determine appropriate locations and densities for growth.

SS17a: West Mersea

We welcome the identification of the proximity of grade II Brierley Hall to the proposed allocation at Brierley Paddocks. We welcome reference in the policy to archaeological considerations at Dawes Lane as well as design and landscaping at Brierley Paddocks.

SS17b: Coast Road

We recommend under criterion ii 'historic environment assets' is replaced with 'heritage assets'.

SS18: Wivenhoe

We note that one of the proposed site allocations borders grade II 14, 15 and 16 Colchester Road. As the Neighbourhood Plan is developed consideration of these heritage assets and their setting is required.

OV1: Other villages

We welcome the commitment to high quality design which is distinctive to the character of the village.

Chapter 7 Development Management Policies

DM5: Tourism, Leisure, Culture and Heritage

We welcome the recognition that Colchester's rich heritage is a benefit and attraction to people who live, work and visit the Borough. We would suggest that in paragraph 7.22 "..rich historic heritage.." be amended to either "...rich historic environment..." or "...rich heritage.." We welcome that new development should not detract from the aspects that make the Borough attractive and distinctive. Whilst the policy covers a wide range of different development types and locations, we would suggest that the policy could not only require development to "...minimise their impact on neighbouring areas..." but also ensure that consideration is given to how such developments could make a positive contribution.


DM6: Economic Development in Rural Areas and the Countryside

We welcome the consideration of re-use of existing buildings and the link in the supporting text, paragraph 7.31, to policy DM16 for historic rural buildings. In paragraph 7.30 it may be better to use the NPPF term 'heritage asset' rather than 'heritage building' as the term is not defined in the glossary. In respect of (c) in the policy itself, it should be clarified that there is a presumption that heritage assets in a poor state of repair will be retained rather than replaced, otherwise heritage assets which have not suffered deliberate neglect or damage as per paragraph 130 of the NPPF may fall within the scope of replacement.

DM7: Agricultural Development and Diversification

We welcome the link in the supporting text, paragraph 7.39, to policies DM6 and DM16. We welcome the inclusion within the policy of the requirement that re-use of historic farm buildings should maintain and enhance the historic environment.

DM9: Housing Density

We welcome the requirement in the policy that density should respond to the character of a site and its surroundings. Appropriate density will vary significantly across the Borough owing to the variety and location of sites coming forward. However, density on a site could also be affected by consideration of the setting of heritage assets and this should be reflected in the policy and supporting text.

DM13: Domestic development - residential alterations, extensions and outbuildings

Whilst we welcome the commitment to design for replacement dwellings in the countryside, we also recommend that the presumption to retain buildings which are heritage assets should be referenced. As it is drafted, the policy also would allow the replacement of a building which makes a positive contribution to a rural conservation area. This should be clarified.

DM15: Design and Amenity

We welcome a policy on design and in particular the reference to the Essex Design Guide and supporting text paragraph 7.83.

DM16: Historic Environment

We welcome a local policy on the historic environment. We particularly welcome the commitment to a local list which can help local authorities and local communities define aspects of the historic environment that are locally significant. As such, we would recommend that the list cover character areas, parks and gardens, structures etc. as well as buildings. More information can be found in Historic England Advice Note 7 - Local Listing: <https://www.historicengland.org.uk/images-books/publications/local-heritage-listing-advice-note-7/>.

We would recommend that heritage at risk forms part of any policy on the historic environment, particularly with a number of long-standing assets on the Heritage at Risk Register, including Hythe and Distillery Pond Conservation Areas.

DM25: Renewable Energy, Water, Waste and Recycling

Please see our comments above on Policy CC1.

Chapter 9 Monitoring

We support the Council's aspiration to promote high quality design and sustain Colchester's historic character. We welcome a specific and measurable target relating to the historic environment. We would be happy to discuss further with you data and options for monitoring progress.

Conclusion

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We hope that the above comments of assistance. Please let me know of you have any queries. We look forward to further engagement on the Local Plan review.


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