Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9725

Received: 26/07/2022

Respondent: Historic England

Representation Summary:

For some sites an HIA has been prepared but is incomplete. Some are still marked Draft. Others only complete 2 or 3 steps of the 5 step methodology for HIAs set out on page 5 of the HE Advice Note 3 – Site Allocations in Local Plans:
https://historicengland.org.uk/images-books/publications/historic-environment-andsite-
allocations-in-local-plans/ Some do not identify impact (step 3), others do not consider maximising enhancement, avoiding harm and mitigation (step 4), others do not determine whether the proposed site allocation is appropriate in light of the NPPFs test of soundness (step 5).
These include sites EMP6, EMP7 and EMP8.
In these cases, please ensure that the HIA is complete and that any recommendations have been used to inform the policy wording in the Plan.