BASE HEADER

No

ID sylw: 102043

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

This draft policy sets out requirements for development proposals that affect heritage assets. We strongly object to the wording of this draft policy owing to its inconsistency with the Framework.
The draft policy relating to significance of heritage assets and justification of harm is inconsistent with paragraphs 205 – 214 of the Framework which contain a much more nuanced approach, reflecting the magnitude of harm and setting out appropriate justification in each case. The inconsistency with the Framework not only renders the draft policy unsound but would, if adopted in its current form, present challenges for accurate and consistent decision making.
The Framework states that ‘Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use’. In so doing it recognises that harm can be outweighed.
The first bullet point of DPD27 however states that ‘a strategic historic environment policy will … preserve and enhance the historic environment (including its setting) for its inherent value, and for the enjoyment of residents and visitors’.‘Preserve and enhance’ is a binary test where any harm would be render the application proposals in conflict with the policy. The Framework, however, seeks to balance harm against public benefits, even in circumstances where substantial harm will occur. For this reason, the current wording of draft DPD27 is unsound and must be revised in line with national policy.