Document Information Cover Sheet ASITE DOCUMENT REFERENCE: WSP-EV-SW-RP-0088 DOCUMENT TITLE: Environmental Statement Chapter 6 ‘Cultural Heritage’: Final version submitted for planning REVISION: F01 PUBLISHED BY: Jessamy Funnell – WSP on behalf of PMT PUBLISHED DATE: 03/10/2011 OUTLINE DESCRIPTION/COMMENTS ON CONTENT: Uploaded by WSP on behalf of PMT. Environmental Statement Chapter 6 ‘Cultural Heritage’ ES Chapter: Final version, submitted to BHCC on 23rd September as part of the planning application. This document supersedes: PMT-EV-SW-RP-0001 Chapter 6 ES - Cultural Heritage WSP-EV-SW-RP-0073 ES Chapter 6: Cultural Heritage - Appendices Chapter 6 BSUH September 2011 6 Cultural Heritage 6.A INTRODUCTION 6.1 This chapter assesses the impact of the Proposed Development on heritage assets within the Site itself together with five Conservation Areas (CA) nearby to the Site. 6.2 The assessment presented in this chapter is based on the Proposed Development as described in Chapter 3 of this ES, and shown in Figures 3.10 to 3.17. 6.3 This chapter (and its associated figures and appendices) is not intended to be read as a standalone assessment and reference should be made to the Front End of this ES (Chapters 1 – 4), as well as Chapter 21 ‘Cumulative Effects’. 6.B LEGISLATION, POLICY AND GUIDANCE Legislative Framework 6.4 This section provides a summary of the main planning policies on which the assessment of the likely effects of the Proposed Development on cultural heritage has been made, paying particular attention to policies on design, conservation, landscape and the historic environment. This includes national planning guidance in the form of Planning Policy Statements (PPS) and Guidance, particularly PPS 5. The adopted local policy, the Local Plan, supplemented by Supplementary Planning Guidance and Documents are also relevant. In addition, at a local level, the draft Core Strategy, which is not yet formally adopted, but which has been subject to extensive consultation, is considered a material consideration. In addition, non-statutory guidance has been used to inform this assessment. 6.5 The applicable legislative framework is summarised as follows: Planning (Listed Buildings and Conservation Areas) Act 1990 inclusive of (Amendment No. 2)(England) Regulations 2009 (HMSO, 1990); Planning Policy Statement (PPS) 5: Planning for the Historic Environment and Practice Guide (DCLG, 2010); Brighton and Hove City Council (BHCC, 2005) Local Plan (Saved Policies 2005), policies QD1, QD2, QD4, QD5, HE2, HE3, HE4, HE6, HE10 and HE11 BHCC Core Strategy Proposed Submission Draft (BHCC, February 2010), policies CP17, SO5, SO9, SO10, SO19 and DA5. Planning Policy National Planning Policy PPS5: Planning and the Historic Environment 6.6 PPS5 provides national guidance on the identification and protection of the historic environment. It replaced Planning Policy Guidance Notes 15 and 16 in March 2010 and provides an integrated approach to the historic environment. The guidance introduces the concept of ‘Heritage Assets’, which includes both designated (e.g. listed buildings, conservation areas, scheduled monuments) and non-designated assets such as locally listed buildings. These are structures of architectural or historic interest which does not qualify 6-1 Brighton 3Ts Chapter 6 BSUH September 2011 for inclusion in the statutory list, but which, in the opinion of the local authority, makes a valuable contribution to the character of an area. 6.7 PPS5 seeks consideration of heritage buildings, monuments and landscapes as assets to be utilised rather than a barrier to development, recognising the contribution the historic environment can make to achieving climate change and long-term sustainability objectives, and highlighting the design potential for built heritage to contribute to local place-shaping and act as a catalyst for change. 6.8 PPS5 identifies the need for early consultation in the planning process to determine the impact of construction schemes upon any buried archaeological strata and standing remains. It indicates that there is a presumption in favour of preservation in situ over excavation, where remains are of national importance. PPS5 places significant emphasis on determining precisely where impacts might occur as well as seeking to advance within the planning process how change in the built environment can have a positive impact upon archaeological and built heritage resources. 6.9 One of the aims of PPS5 is to introduce a ‘values’ approach to conservation where the significance of the heritage asset affected by the proposals is understood by all involved in the planning process. Significance is defined in PPS5 as the ‘value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic’ (PPS5 Annexe 2). Significance is therefore the total heritage interest of an asset covering all the statutory designations and also those assets considered important in heritage terms but without national designation, such as ‘locally listed’ buildings. 6.10 In the assessment of significances in Appendix 6.1 reference has been made to Policy HE6.1 within PPS5 which states: ‘Local planning authorities should require an applicant to provide the description of the significance of the heritage assets affected and the contribution of their setting to that significance. The level of detail should be proportionate to the importance of the heritage asset and no more than is sufficient to understand the potential impact of the proposal on the significance of the heritage assets.’ Draft National Planning Policy Framework (2011) 6.11 The draft National Planning Policy Framework (NPPF) is the first consultation draft of new national planning policy. It seeks to combine all the PPSs, PPGs and Guidance notes into a single document. It promotes sustainable development and opportunities for local communities to engage in plan making at a neighbourhood level. The draft document is in its initial consultation stage from 25th July to 17th October 2011. The core underpinning principle of the new framework is the presumption in favour of sustainable development, defined as: “Development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” (Paragraph 9). 6.12 The document is broken down into sections covering the previous PPS’s and PPG’s and will, when adopted, supersede them. Local Planning Policy Brighton and Hove City Council Local Plan (Saved Policies 2005) 6.13 The Secretary of State for Communities and Local Government sent BHCC a Direction in accordance with paragraph 1(3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004 stating that for the purposes of the policies specified in the Schedule (1) of the direction, paragraph 1(2)(a) of Schedule 8 to the Planning and Compulsory Purchase Act 2004 did not apply, attached to a list of Local Plan policies in Schedule 1 of the direction. In essence, this enacted to ‘save’ certain Local Plan policies until the LDF Core Strategy is formally adopted. 6-2 Brighton 3Ts Chapter 6 BSUH September 2011 6.14 The Local Plan aims to meet the overall vision of the Council for Brighton & Hove as “a cosmopolitan, successful city by the sea where people have a high quality of life in a decent environment”. The following policies are deemed relevant to the consideration of the Proposed Development: 6.15 The following saved BHCC Local Plan policies are of relevance to this assessment: QD1 Design – quality of development and design statements: seeks a high standard of design that makes a positive contribution to the visual quality of the environment, looking at the scale and height of development, architectural detailing, quality of materials, visual interest (particularly at street level) and appropriate levels and type of landscaping. QD2 Design – key principles for neighbourhoods: seeks developments which emphasise and enhance the positive qualities of the local neighbourhood, by taking into account the local characteristics, including: – height, scale, bulk and design of existing buildings; – topography and impact on skyline; – natural and developed background or framework against which the development will be set; – natural and built landmarks; – layout of streets and spaces; – linkages with surrounding areas, especially access to local amenities; – patterns of movement (permeability) within the neighbourhood with priority for all pedestrians and wheelchair users, cyclists and users of public transport; and – natural landscaping. QD4 Design – strategic impact: Seeks the preservation or enhancement of strategic views, important vistas, the skyline and the setting of landmark buildings through high quality design. Policy states that development “that has a detrimental impact on any of these factors and impairs a view, even briefly, due to its appearance, by wholly obscuring it or being out of context with it, will not be permitted”. Policy considers the following features and buildings to be of strategic importance: – views of the sea from a distance and from within the built up area; – views along the seafront and coastline; – views across, to and from the Downs; – views across valleys; – views into and from within conservation areas; – the setting of listed buildings and locally well known landmark buildings of townscape merit; – vistas along avenues, boulevards and steeply rising streets; and – initial views of Brighton & Hove from access points