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Representation ID: 9030

Received: 04/10/2021

Respondent: Historic England

Site Assessment
We are pleased to note that a considerable degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the Site
Assessment pro-formas as well as the historic environment Excel spreadsheet. We welcome the additional table. This helps to ensure the process is both robust and transparent. To date, the assessment of sites is fairly high level and brief but provides a useful
starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber and the table notes that further assessment in
terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed.
As we have discussed previously, further assessment will be needed of the sites. This further assessment, known as Heritage Impact Assessment (HIA) should
follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/imagesbooks/
publications/historic-environment-and-site-allocations-in-local-plans/.
HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment
impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid
merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.
Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at
risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.
Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available
evidence base. Cumulative effects of site options on the historic environment should be considered too.
The following broad steps might be of assistance in terms of assessing sites:
• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced
The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area
could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.