HTF comments - Planning Act 2008


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 Planning Act 2008: Nationally Significant Infrastructure Projects: Application form guidance - Consultation
Comments from Historic Towns Forum (HTF) 


Application Form Guidance
The Guidance provides for a box on the application form relating to the historic environment and this is most welcome. 

However, the Forum is concerned about Regulation 5(2)(m) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009, which sets out the information that should be referred to in Box 17.   This says:

"where applicable, a plan with accompanying information identifying any statutory or non statutory sites or features of the historic environment, including scheduled monuments, World Heritage sites, listed buildings and other historic structures, archaeological sites and registered battlefields, together with an assessment of any effects on such sites, features or structures likely to be caused by the proposed development;"

A lot depends on the word 'including'.  Is the list that follows it intended to be definitive or merely to cite examples?  The HTF fears that it might be interpreted to omit Conservation Areas, locally listed buildings and any other heritage assets not referred to specifically.  The guidance to completing Box 17 should be amended to clarify the position and encourage agencies to ensure that the entire historic environment is covered. 

Guidance on the pre-application process
We note that this deals mainly with community consultation but also refers to the requirements for EIA, in which historic ernvironment evidence would normally feature.  We also note that this would not be expected to be available at the pre-application stage, but that the EIA should address any issues raised in consultation.  The HTF is content with this.

Associated Development Guidance
Guidance on Associated Development has been amended to take account of the Localism Act amendments and clarify the existing guidance in a number of areas.  This appropriate.

However, as the Guidance sets out what is allowable (and not allowable) as associated development we urge that works to mitigate impacts on heritage assets be added to the list of examples.

Examinations Guidance
The Guidance does not appear to pose any specific historic environment issues and the HTF notes the changes.

Compulsory Acquisitions Guidance
The Guidance does not appear to pose any specific historic environment issues and the HTF notes the changes.

Fees Guidance
There are no issues related to fees that the Forum wishes to raise.

Historic Towns Forum
7th July 2012