City of London Supplementary Planning Documents Appendix 1 - Consultation Statement July 2017 1 The Introduction to the Historic Environment Strategy, the Archaeology Guidance SPD and the Churchyard Statements were published in draft for public consultation during a ten week period from 29th October 2015 to 8th January 2016. Prior to the public consultation the drafts were prepared by officers in the Department of the Built Environment in consultation with colleagues in that and other departments within the City of London Corporation and the text was approved by the Planning and Transportation Committee. Regulation 12 of the Town and Country Planning (Local Planning) (England) Regulations 2012 require the City Corporation to prepare a consultation statement setting out the persons consulted when preparing a supplementary planning document, a summary of the main issues raised by those persons and how these have been addressed in the SPD. The following measures were taken to consult the public on the SPDs and evidence bases during the consultation period: Website. The draft SPD and evidence base documents were made available on the City Corporation‟s website. Information and a link were provided on the home page of the City‟s website and on the landing page of the Planning section of the website to ensure maximum exposure. Information was provided in the City of London e-shot. Inspection copies. A copy of the SPD and the evidence base documents were made available at the Planning Information desk at the Guildhall and the Guildhall, Barbican, Artizan Street and Shoe Lane public libraries. Notifications. Letters and emails containing information about the draft SPD and other documents and inviting comments were sent to relevant specific and general consultation bodies. The City Corporation maintains a database of all those who have expressed an interest in planning policy, and letters or emails were also sent to all those on the list. Leaflets advertising the draft SPD and evidence base documents consultation and inviting comments were placed in the Guildhall, Barbican, Artizan Street and Shoe Lane public libraries. Meetings. Presentations on the Historic Environment Strategy were given to the Conservation Area Advisory Committee. The planned preparation of the draft SPDs was posted in the Local Plan Bulletin and on the Consultations page of the City of London website. Members of the public were invited to make comments to contribute to the preparation of the draft SPDs. No such comments were received. Responses to the consultation were received from the City of London Archaeological Trust (CoLAT), Natural England, Transport for London, Tideway, the Port of London Authority, Historic England and the City of London Conservation Area Advisory Committee. The table that follows summarises the comments and explains how they were addressed in finalising the SPDs. 2 Summary of comments and responses – minor amendments to deal with typos/errors in the comments will be made in the final documents Doc Comment Response City of London Archaeological Trust Archaeology and Development Guidance SPD All This is the latest edition of a set of procedures which have been developed by the City over the last three decades. As an example of procedures to manage how archaeology fits into the development process, it is a model for other cities in Europe and further afield. The City should be congratulated on the statement of these procedures. All the procedures concerning archaeology however need constant vigilance by the Corporation‟s officers if they are to be observed by developers (secular or religious). We perceive that the front end of archaeological projects, how the access to sites is managed and the excavations, together with immediate post-excavation work, is in general well done by archaeological contractors and regulated by the Corporation. We recommend that the Corporation puts equal effort into ensuring that developers do their duty in funding publication beyond the writing of the post-excavation assessment which is sometimes erroneously thought of as the final report; as required by this SPD on p.30 and national legislation. As this text is a version which has grown over the years, there are some out of date references which should be changed. Here are a few: 1. Photographic standards have been updated 1. p.25: surely the reference to 35mm film is now out of date. 2. ‘LAARC’ has been changed to the ‘Museum of 2. p.25: LAARC now has a new name, The Museum of London Archaeological London Archaeological Archive’ throughout the Archive (and see refernece on p.26). document 3. p.25: Museum of London Specialist Services disappeared several years ago. 3. ‘Museum of London Specialist Services’ has If you are to retain this sentence, put MOLA; but it may be inappropriate now to been altered to ‘Museum of London Archaeology’ say this. 3 CoLAT (continued) All City Churchyards Statements of Significance The suggested amendments have been These are excellent. incorporated into the text 1. General point: consideration should be given to laying out the outline for parts of parish churches which lie beneath their present churchyards. The extent to which all the churchyards you catalogue can do this could be ascertained. It would be only a few, but it would make the churchyards even more interesting and would constitute a form of memory which is very rare in the City today. 2. Points of historical accuracy: All Hallows by the Tower: in the archaeology paragraph, the 3rd century date is surely wrong and from something else, perhaps the nearby City wall. The church is 11th-century, as you state above. St Bartholomew the Great, archaeology: strictly speaking the excavation of 1987 was not in this area but on the north-east side of the church, where the parish building is now. Amend your sentence, but keep it in. St Benet Fink: the Wren church was decagonal, not octagonal. Perhaps add to the archaeological potential: „The remains of a Wren church of unique plan could be significant.‟ St Botolph Aldersgate: add to the archaeological potential that the Roman and medieval City wall borders the site on the south side, and fragments may survive (explaining your reference to the SAM). St Magnus the Martyr: was in existence by the 11th century, not the 12th. Instead of „(cartographical error?)‟, put „(from the 12th century to 1666, from excavations of the 1970s)‟. This is detailed in your Archaeology paragraph for the church. St Mary le Bow: please add to the Archaeology paragraph that the west end of a vaulted undercroft built shortly after 1276 was recorded immediately west of the tower in 1959 (Grimes). Transport for London All Thank you for consulting Transport for London (TfL) on the Historic Environment No response required Strategy and Enforcement Plan. TfL has no comments on these documents. 4 CgMs – (part of RPS Group) 1. The policy section on pages 5&6, identifies the Archa Please see below the comments to the consultation on Historic Environment national (NPPF), regional (London Plan) and local (Local eology Strategy from the archaeology team at CgMs (part of RPS Group). Plan) policy context for the assessment of significance of Guida designated heritage assets. Paragraphs from the NPPF nce The CgMS (Part of RPS) comments for CoL area as follows: on the assessment of undesignated heritage assets will be added. 1 It would be beneficial if there is guidance on how Roman developments A further document characterising the city‟s in the City are assessed for significance archaeological and historic past is in preparation, and will provide a greater degree of information regarding the 2 There is much emphasis on preservation in-situ, but is this a hangover Roman period. from PPG16, given that it is significance that is now paramount? 2. Where there is potential for archaeological remains of 3 The approach to outreach has no NPPF backing and might be significance, preservation in-situ is a consideration. considered an area of blurred lines Reference to preservation in-situ has been cited where it is considered relevant; however the assessment of 4 There should be a need to require CMIfA membership as RO# significance and archaeological potential of the site is considered in the policy context and impact assessment sections of the document. Several alterations to the text to further emphasise the assessment of significance have been added in response to this comment. 3. Paragraph 141 of the NPPF directs LPAs and developers to both gather and disseminate information about the Historic Environment. Policy DM 12.4 paragraph 3.12.21 of the City of London Local Plan concerns the interpretation and presentation to public of visible or buried remains. It says the „agreement will be sought, where appropriate, to achieved reasonable public access‟. This provides sufficient backing for the guidance outlines in the document. 4. The City of London follows current standards and guidelines for staffing and organisations, but is unable to make CIfa membership a requirement for organisations undertaking work in the City of London. 5 Natural England All No response required. Whilst we welcome this opportunity to give our views, the topic of the Supplementary Planning Document does not appear to relate to our interests to any significant extent. We therefore do not wish to comment. Historic England All Heritage Environment Strategy Historic England welcomes the production of a Heritage Environmental Strategy. In our view, the component elements identified for inclusion within the Strategy will contribute positively to a solid framework for the management of the historic environment through drawing together relevant guidance and advice. The introduction refers to a number of topics including Understanding the The Introduction will be revised to provide greater clarity Historic Environment, a Structure of the Historic Environment SPD, and as regards the content and structure of the Historic Managing Change and the Historic Environment.