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Wednesday, 2 November 2016

Environmental Planning Advice: A Reply to Castle Point Borough Council from Our President

The Essex Society for Archaeology & History 

Mr. Steve Rogers, 
Head of Regeneration and Neighbourhoods, 
Castle Point Borough Council, 

29th October 2016 

Dear Mr. Rogers, 


Thank you for your letter of 24th October 2016, setting out Castle Point Borough Council's (CPB) approach to the historic environment and the planning process. 

You may care to note that the Essex Society for Archaeology and History has not hitherto commented on the content of Local Plans, and only comments on individual planning applications if they are very large and/or of particular historic environment sensitivity. 

It is welcome and reassuring to know how much CPB values and recognises the importance of the historic environment. In particular the efforts which CBT has put into ensuring that its new Local Plan will have appropriate coverage of the historic environment is very commendable and will clearly provide the basis for a `..positive strategy for the conservation and enjoyment of the historic environment..' (National Planning Policy Framework paragraph 126). 

However, the policies in the Local Plan can only be effective if they can be appropriately implemented. Whilst your letter notes that pre-determination requests for information and post-determination conditions are placed on applications as necessary, it is not clear how the cases where this is required are identified. The basis for such identification is the historic environment record (HER) which is of course the reason 'Local Authorities should either maintain or have access to a historic environment record.' (National Planning Policy Framework paragraph 169). Since CBT no longer obtains HER services from Essex County Council (ECC) what arrangements has it made to obtain them from another source? Since HER information has to be interpreted before it can be useful, which requires, specialist expertise, and even the mapped aspects of the HER do not operate as more usual planning constraint maps do, as CBT no longer obtains specialist historic environment advice from ECC how does it identify those applications which require pre-determination requests for information and/or post-determination conditions? 

Yours sincerely, 
Adrian Corder-Birch, 
Essex Society for Archaeology and History 

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