Chapter 20
185) Do you agree the government should implement the additional regard duties under Section 102 of the Levelling-Up and Regeneration Act? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons.
No further comment.
186) Do you have any evidence as to the impact of implementing the additional regard duties for development?
No further comment.
187) Do you agree with the approach to plan-making for the historic environment, including the specific requirements for World Heritage Sites and Conservation Areas, set out in policies H1 – H3? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI strongly welcomes the approach to plan-making for the historic environment. We particularly endorse the more positive framing of the language to encourage the sustainable redevelopment of heritage assets. We also support any proposals which make the Historic Environment Records more readily available through open access. We are unclear how SDSs will be usefully engaged in implementing such policies as drafted.
188) Do you agree with the approach to assessing the effects of development on heritage assets set out in policy H5? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
189) Do you agree with the approach to considering impacts on designated heritage assets in policy HE6, including the change from "great weight" to "substantial weight", and in particular the interactions between this and the statutory duties? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, particularly if you disagree.
Regarding HE7, we hold some concern about the weight attributed to non-designated heritage assets and to improve the proportionately of approach would recommend that HE7(2) be only engaged when a development proposal could lead to the total loss of the asset.
We also note some concerns around changes from ‘great weight’ to ‘substantial weight’, given the implications in respect of relevant statutory duties, reinforced and clarified through case law.
190) Do you agree with the new policies in relation to world heritage, conservation areas and archaeological assets in policies HE8 – HE10? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
191) Do you have any other comments on the revisions to the heritage chapter?
No further comment.
