Part One: Spatial Strategy and Policies (Regulation 18)
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Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP45 Flood Risk
Representation ID: 808
Received: 30/01/2024
Respondent: Historic England
DLP45. We would welcome a clause in this policy on the historic environment and the need for it to be a consideration when planning flood alleviation measures or plans that will affect the watercourse which could have impacts on issues such as waterlogged archaeology etc.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP46 Sustainable drainage and surface water management (SuDS)
Representation ID: 809
Received: 30/01/2024
Respondent: Historic England
DLP46. A reference within this policy to the potential affects for the historic environment would also be beneficial.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP47 Renewable and Low Carbon Energy and BREEAM Standards
Representation ID: 810
Received: 30/01/2024
Respondent: Historic England
DLP47. We consider it would be more suitable to have a specific clause for the historic environment that considered the issues that might arise and ensured the protection of the significance of heritage assets, including their setting.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP51 Dudley Borough's Green Infrastructure Network
Representation ID: 811
Received: 30/01/2024
Respondent: Historic England
DLP51. We consider it would be appropriate to include a clause on heritage as a component of green/blue infrastructure and the role it plays including issues such as heritage landscapes and features.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP53 Parks
Representation ID: 812
Received: 30/01/2024
Respondent: Historic England
DLP53. We welcome inclusion of the Leasowes RPG in this policy. Amend ‘English Heritage’ with ‘Historic England’. We would recommend re-phrasing the text to ensure that the heritage asset will be afforded the greatest protection in line with the National Planning Policy Framework (NPPF). Dudley Park should be referred to as a Registered Park and Garden, from Historic England and recognise that this is a heritage asset that requires the protection of Section 16 in the NPPF.
Support
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP55 Historic Character and Local Distinctiveness of Dudley
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
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP55 Historic Character and Local Distinctiveness of Dudley
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.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP56 Conservation Areas
Representation ID: 815
Received: 30/01/2024
Respondent: Historic England
DLP56. Any recording should be required to be added to the Historic Environment Record. Clause 1 consider amending the first sentence for clarification.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP57 Listed Buildings
Representation ID: 816
Received: 30/01/2024
Respondent: Historic England
DLP57. Consider breaking down the clauses in this policy so that each point has its own clause rather than combining them. This will make it clearer to understand what is required by the policy. The first point would be beneficial to reference that development which does not protect the significance of heritage assets, including their setting, will be resisted/ refused. Any loss/ recording should be added to the HER. Any assessments should be undertaken by appropriate and qualified professionals. It would be useful to set out detail of when a heritage impact assessment may be required and what detail it should include.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Policy DLP58 Buildings or Structures of Local Historic and/or Architectural Importance
Representation ID: 817
Received: 30/01/2024
Respondent: Historic England
DLP58. We welcome the inclusion of this policy. Some of our comments above apply such as breaking down the points in to individual clauses to make it clearer.