Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1543

Received: 29/11/2024

Respondent: Historic England

We consider that the policy approach the Council has taken to both Section 14 of Local Plan Part One and the additional area specific historic environment policies within Local Plan Part Two provide a positive strategy for the historic environment and respond both to the requirements for heritage assets but also to protecting and enhancing the unique, special character of Dudley. The policies are supported by an extensive evidence base and go into relevant detail that will ensure the policies are effective and a practical resource for prospective developers. We support the policy approach contained within the Regulation 19 consultation version.


When reading through the Plans, we could not locate any reference to the Heritage Impact Assessment (HIA) document prepared by the Council, either referenced specifically in relation to site allocation policy or listed as an evidence base that had informed a policy approach. We consider that the Local Plan should reference this document so that once the Plan is adopted, it can be utilised and aid in future planning applications.
We are unclear how the HIA has been utilised within the site allocations approach in the Plan. At times there is reference in the Local Plan to some of the mitigation measures highlighted within the HIA and at other times we could either not locate a HIA for a site, or there is a table approach listing allocations by name only. There is no connection with the HIA, or any assessment/ mitigation measures for these sites. We would welcome understanding how this approach has been taken and to assess if there are positive opportunities to refer to the mitigation measures listed for the sites to ensure the policies/ allocations are effective and justified.


We note Section 8 of the HIA and that it was considered that there were no amendments required to the Local Plan. However, we remain unclear on the approach for sites and ensuring that any harm will be fully mitigated, through the Local Plan, at the appropriate time. We are available for a discussion on this subject.

Support

Representation ID: 1544

Received: 29/11/2024

Respondent: Historic England

Profile of the Borough

We welcome the many references to the cultural heritage of the Borough and the role heritage plays within Dudley.

Comment

Representation ID: 1545

Received: 29/11/2024

Respondent: Historic England

Policy DLP10 Clause 3

Could reference the need to consider mitigation/enhancement measures from the Heritage Impact Assessment for housing allocation sites.

Comment

Representation ID: 1546

Received: 29/11/2024

Respondent: Historic England

Housing Section on Page 128

There is no reference under evidence base to the Heritage Impact Assessment that has been prepared to inform the site allocations.

Comment

Representation ID: 1547

Received: 29/11/2024

Respondent: Historic England

Policy DLP18 Page 165

Could reference the need to consider mitigation/enhancement measures from the Heritage Impact Assessment for employment allocation sites.

Comment

Representation ID: 1548

Received: 29/11/2024

Respondent: Historic England

Employment Section on Page 170

There is no reference under evidence base to the Heritage Impact Assessment that has been prepared to inform the site allocations.

Comment

Representation ID: 1549

Received: 29/11/2024

Respondent: Historic England

Policy DLP19

References could be incorporated to protecting the significance of heritage assets and their setting and linking to the evidence within the Heritage Impact Assessment.

Comment

Representation ID: 1550

Received: 29/11/2024

Respondent: Historic England

Policy DLP20

References could be incorporated to protecting the significance of heritage assets and their setting and linking to the evidence within the Heritage Impact Assessment.

Support

Representation ID: 1551

Received: 29/11/2024

Respondent: Historic England

Policy DLP30

We support clause 2 a.

Comment

Representation ID: 1552

Received: 29/11/2024

Respondent: Historic England

The policy could also refer to the retention of hedgerows on historic landscape considerations and where the hedgerow makes a contribution to the significance of heritage assets and the wider historic landscape they are experienced within.