Policy SDC9: Non-Designated Local Heritage Assets

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Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6950

Received: 23/03/2018

Respondent: Mrs Lisa Bell

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

OBJECT to policy ans supporting text as a Local List has yet to be produced in line with the NPPF and the Council has not 'committed' to produce one - just 'aiming'.

Change suggested by respondent:

Undertake, consult on and adopt a Local List of Heritage Assets in line with the NPPF.

Full text:

This policy is welcomed in the main, however, it is noted that the Council is still yet to produce, consult on and formally adopt a local list of non-designated heritage assets. Paragraph 8.41 of the Publication Draft states that the Council will 'aim' to identify and establish a local list. This statement does not provide any certainty/commitment that the Council will in fact produce and adopt a Local List of heritage assets which is contrary to paragraph 169 of the NPPF which states "Local planning authorities should have up-to-date evidence about the historic environment in their area and use it to assess the significance of heritage assets and the contribution they make to their environment."

The Council's response to my previous comments which include "Agree in part. Through the inclusion of policy SDC 9 in the Plan the Council has made commitment to prepare a local list of non-designated assets as a means to sustain and enhance their significance. In drawing up a new local heritage list for North East Derbyshire it is envisaged that the starting point will be the Historic England Advice Note 7 on Local Heritage Listing." We do not believe that the Council has made a 'commitment' as 'aiming' to provide is very different to committing to provide.

Without an up-to-date local list, this policy would not appear to be enforceable/useable and as such we maintain our objection to this section.