Three Rivers District Local Plan Regulation 18 Preferred Policy Options and Sites for Potential Allocation Interim Sustainability Appraisal Report Appendices June 2021 Table of Contents Appendix A Consultation Responses A-1 Appendix B Environmental and Sustainability Planning Context B-1 Appendix C SA Framework C-1 Appendix D Alternatives considered D-1 Appendix E Assessment of Regulation 18 Local Plan Part 1 E-1 Appendix F Assessment of Regulation 18 Local Plan Part 2 F-1 Appendix G Sites not proposed for allocation G-1 Appendix A Consultation Responses This appendix provides details of the representations received during previous consultation exercises in relation to the Sustainability Appraisal. A.1 Scoping Report Consultation In Spring 2017 (from 12th May to 16th June) the SA Scoping Report was consulted upon. The following table summarises the consultation comments received and the action taken in response. Summary of Comments How comments taken on board Statutory Consultees Environment Agency Consultation on strategic environmental assessment (SEA) / Sustainability appraisal (SA) draft scoping report for new The list of policies, plans or local plan programmes in the Biodiversity and Thank you for consulting us on this draft scoping report and I apologise for the late response. I have answered the specific Water chapters have been updated to questions which we had comments for below. include those mentioned here. Are there any other policies, plans or programmes (PPPs) that contain environmental protection or sustainability objectives, or which identify issues, that are not covered by the PPPs listed in this Scoping Report? Potentially the Thames Water Authority Land Drainage Byelaws 1981. Is there any other baseline information which is relevant to the SA/SEA of the Local Plan that has not been included? Page 8, Biodiversity Para 2.2.1.1 Relevant plans, policies and programmes: We believe the following should be added: • Thames River Basin Management Plan 2015 – 2021, • Hertfordshire Green Infrastructure Plan (March 2011) Where do you see the main issues in the area and which topics do you want see addressed with priority within the SA/SEA? The SA framework includes objectives Flood risk is a problem in the area and the following topics should be addressed as a priority relating to flood risk and therefore • Sequential development, avoiding building in Flood Zone 3, assessing climate change increases in flood risk these issues will be taken into • Providing ecological and flood-risk betterment on the riparian corridor through the implementation of an 8m buffer zone adjacent to main rivers. A-1 RPN5025 Summary of Comments How comments taken on board consideration during the ongoing SA/SEA and plan making process. Do the SA/SEA objectives provide a reasonable framework through which the likely significant environmental and SA Framework has been amended to sustainability effects of the Local Plan can be assessed? reflect the changes suggested for SA Yes, although we recommend the following amendments: Objectives 1 and 3. Page 95 Table 3-1: SA Framework We welcome and support Objective 1, but we would wish to see a more explicit reference to ‘blue infrastructure’ and the water environment included in the relevant sub-objectives. Whilst we welcome and support Objective 3, we would suggest that the following sub-objective “To promote properly maintained sustainable drainage systems (SUDs) to reduce flood risk and surface water run off” is amended as follows: “To promote properly designed and maintained sustainable drainage systems (SUDs) to reduce flood risk, surface water runoff and contribute to improved water quality, green and blue infrastructure and function”. We would also propose a further sub objective – “To seek opportunities for Natural Flood Management where appropriate”. Do you believe that the significant effects of the Local Plan can be identified using the methodology outlined in the Scoping SA Framework has been amended to Report? include the additional site specific Yes, although we would suggest that under Table 3-1 Objective 3 (To reduce flood risk), a site specific question could be: question suggested for SA Objective 3. ‘would development of the site be at risk from flooding arising from climate change?’ Historic England Thank you for you notification of scoping consultation for your local plan. Unfortunately, Historic England cannot provide The list of policies, plans or detailed advice at this time. programmes in the Historic We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review Environment chapter has been the following as part of your local plan development: updated to include those mentioned The Historic Environment in Local Plan - Good Practice Advice in Planning 1 here. https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/ Managing Significance in Decision-Taking in the Historic Environment - Good Practice Advice in Planning 2 https://content.historicengland.org.uk/images-books/publications/gpa2-managing-significance-in-decision- taking/gpa2.pdf/ A-2 RPN5025 Summary of Comments How comments taken on board The Setting of Heritage Assets - Good Practice Advice in Planning 3 https://content.historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/gpa3.pdf/ Conservation Area Appraisal, Designation and Management - Advice Note 1 https://historicengland.org.uk/images-books/publications/conservation-area-designation-appraisal-management-advice- note-1/ Making Changes to Heritage Assets - Advice Note 2 https://historicengland.org.uk/images-books/publications/making-changes-heritage-assets-advice-note-2/ The Historic Environment and Site Allocations and Local Plans - Advice Note 3 https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/ Tall buildings – Advice Note 4 https://historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/ Local Heritage Listing - Advice Note 7 https://www.historicengland.org.uk/images-books/publications/local-heritage-listing-advice-note-7/ Sustainability Appraisal and Strategic Environmental Assessment – Advice Note 8 https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental- assessment-advice-note-8/ All Historic England advice should be read alongside our Conservation Principles, which underpin our work. Conservation Principles can be found here: https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/ Specific Advice on Common Themes Noted Some common themes are clear from the advice we give in the East of England. A summary of some relevant topics follow: Sustainability Appraisal Scoping The historic environment should be considered as part of the sustainability appraisal process. We recommend that these comments should be read alongside our Advice Note 8. Key Plans and Programmes These PPPs, where applicable, have When considering key plans and programmes, we recommend the inclusion and been included in the Historic consideration of the following: Environment chapter. International/European • UNESCO World Heritage Convention A-3 RPN5025 Summary of Comments How comments taken on board • European Landscape Convention • The Convention for the Protection of the Architectural Heritage of Europe • The European Convention on the Protection of Archaeological Heritage National • Planning (Listed Buildings & Conservation Areas) Act 1990 • Ancient Monuments & Archaeological Areas Act 1979 • Marine and Coastal Areas Access Act 2009 • Government’s statement on the Historic Environment • National Planning Policy Framework • National Planning Policy Guidance Local • Local Plans • Historic Environment Record • AONB Management Plans • Heritage/Conservation Strategies • Other Strategies (e.g. cultural or tourism) • Conservation Area Character Appraisals and Management Plans • Listed building Heritage Partnership Agreements Baseline Information Noted. To be considered during the All designated heritage assets (Conservation Areas, Listed Buildings, Scheduled Monuments, Registered Parks and Gardens, next phases of the SA. Registered Battlefields, and Protected Wrecks) within the area should be identified. Mapping these assets provides a greater indication of their distribution and highlights sensitive areas. We also would expect non-designated heritage assets to be identified. These include, but are not confined to, locally listed buildings. In addition to the above, we would expect reference to currently unknown heritage assets, particularly sites of historic and archaeological interest. The unidentified heritage assets of the City, Borough or District should be acknowledged and outlined in this section. Identification and mapping of designated and non-designated heritage assets at risk can provide an indication of clusters and themes. A-4 RPN5025 Summary of Comments How comments taken on board Historic England’s Good Practice Advice Note 1 contains advice on other relevant sources of evidence. These include Conservation Area Appraisals and Management Plans, Local Lists, Historic Characterisation assessments and any other in- house and local knowledge. We recommend that these other sources of evidence are considered as part of the SA process. Key Sustainability Issues The list of issues and opportunities We would suggest that the starting point for considering Key Sustainability Issues for the Historic