Support

Representation ID: 12

Received: 23/11/2023

Respondent: Mr Roy Burgess

14: Historic Landscape- SUPPORT

Object

Representation ID: 565

Received: 15/12/2023

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy DLP55 – Historic Character

8.1. The emerging Plan confirms that in the Council’s view, the character and quality of the historic environment is one of the borough’s greatest assets. As such, Draft Policy DLP55 requires development proposals to sustain and enhance the distinctive character of the area to help maintain Dudley’s cultural identity and strong sense of place. New development is accordingly required to be designed to make a positive contribution to local character and distinctiveness and demonstrate steps taken to achieve a locally responsive design. The policy identifies that in addition to designated heritage assets, attention should be paid to non-designated assets including: Areas of High Historic Townscape Value; Areas of High Historic Landscape Value; Designed Landscapes of High Historic Value; and Archaeology Priority Areas; Locally Listed Buildings; Non-designated Heritage Assets.

8.2. It is considered that the proposed policy seeks to secure protection for non-designated heritage assets that could comprise a wide range of landscapes or townscapes in addition to buildings and structures, in a highly restrictive manner that is not consistent with national policy set out in the Framework. The Framework at Paragraph 203, in respect of non-designated assets, requires that a ‘balanced judgement’ be made, having regard to the scale of any harm or loss and the significance of the heritage asset.

8.3. It is also noted that the policy seeks to secure a level of protection for ‘physical assets, whether man-made or natural’ that contribute positively to local character and distinctiveness. Contribution to local character and distinctiveness is considered to be a subjective matter, and so the policy as currently drafted could be used by decision-makers to object to development that the applicants’ view would not conflict with this policy. As such, it is not considered that this would accord with the Framework’s requirements for policies to be unambiguous and this part of the policy should be deleted.

8.4. Draft Policy DLP55 should accordingly be modified to reflect this, as well as reduce the level of protection sought for non-designated assets to ensure consistency with national policy as required by Paragraph 35 of the Framework.

Object

Representation ID: 581

Received: 21/12/2023

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

8.1.
The emerging Plan confirms that in the Council’s view, the character and quality of the historic environment is one of the borough’s greatest assets. As such, Draft Policy DLP55 requires development proposals to sustain and enhance the distinctive character of the area to help maintain Dudley’s cultural identity and strong sense of place. New development is accordingly required to be designed to make a positive contribution to local character and distinctiveness and demonstrate steps taken to achieve a locally responsive design. The policy identifies that in
addition to designated heritage assets, attention should be paid to non-designated assets including: Areas of High Historic Townscape Value; Areas of High Historic Landscape Value; Designed Landscapes of High Historic Value; and Archaeology Priority Areas; Locally Listed Buildings; Non-designated Heritage Assets.
8.2.
It is considered that the proposed policy seeks to secure protection for non-designated heritage assets that could comprise a wide range of landscapes or townscapes in addition to buildings and structures, in a highly restrictive manner that is not consistent with national policy set out in the Framework. The Framework at Paragraph 203, in respect of non-designated assets, requires that a ‘balanced judgement’ be made, having regard to the scale of any harm or loss and the significance of the heritage asset.
8.3.
It is also noted that the policy seeks to secure a level of protection for ‘physical assets, whether man-made or natural’ that contribute positively to local character and distinctiveness. Contribution to local character and distinctiveness is considered to be a subjective matter, and so the policy as currently drafted could be used by decision-makers to object to development that the applicants’ view would not conflict with this policy. As such, it is not considered that this would accord with the Framework’s requirements for policies to be unambiguous and this part of the policy should be deleted.
8.4.
Draft Policy DLP55 should accordingly be modified to reflect this, as well as reduce the level of protection sought for non-designated assets to ensure consistency with national policy as required by Paragraph 35 of the Framework.

Comment

Representation ID: 755

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust welcomes mention of the canal network within section 6h of Policy DLP55 Historic Character and Local Distinctiveness of Dudley, and cross-reference to canals policy DLP36. We also welcome the applicability of this policy to designated and non-designated assets alike. The depth and breadth of this Policy wording is also noted and the Trust queries whether separating the policy out and addressing Archaeology matters within a separate policy would assist in providing clarity. (ACTION REQUEST)

Request cross reference to DLP36 in justification.

Support

Representation ID: 813

Received: 30/01/2024

Respondent: Historic England

Historic Environment Section 14. We welcome the inclusion of a specific section on the historic environment. We are very supportive of the justification paragraphs which set out the evidence and additional detail that supplements the Plan and will be of use to prospective applicants when preparing planning applications.

Comment

Representation ID: 814

Received: 30/01/2024

Respondent: Historic England

DLP55. We support this policy and welcome its inclusion. It is beneficial to see a policy which contains so much of the specific information about your unique local history and provides detail about what and how it should be conserved and protected.
Within the opening sections it would be useful to state that development will be supported where it protects and conserves the significance of heritage assets, including their setting or that development will be resisted if this is not the case. We would recommend ensuring that non designated heritage assets are suitably protected and consider the re-wording of clause 8 to be clear on what assessment is required, when it is needed and what it needs to contain. Clause 9 and 10 would also benefit from additional clarification on what is required and when.