Response from Mr Jeremy Parsons, Cumbria County Council
1. Mr Jeremy Parsons, Cumbria County Council : 28 Nov 2016 15:59:00
Please make your comments in the box below and refer specifically to the number of each site / policy you are commenting on.
Policy AS08 – Historic Environment
The proactive tone of policy AS08, which not only seeks to protect but also seeks to enhance the AONB’s historic environment, is fully supported. However, the following amendments to the proposed wording of policy AS08 are suggested:
AS08 currently states: ‘Before works to historic buildings or assets take place, surveys should be undertaken to record their historical interest and build the heritage evidence of the AONB.’
The principle of this statement is supported, but it implies that in all instances where work takes place to assets a survey should be undertaken. This is too onerous, as minor work to assets often does not adversely impact on them and so require such a survey to be implemented. Instead, it is recommended that the principle outlined in section 12 of the NPPF is used, whereby harm to the significance of an asset is the trigger for an appropriate level of mitigation measures to be implemented. Furthermore, it is advised that the reference to ‘historic buildings or assets’ in this sentence is altered to heritage assets, so that it is in line with the term used in NPPF.
It is suggested that the sentence is re-worded along the following lines:
‘Before any work that harms the significance of heritage assets takes place, records should be undertaken to a level that is proportionate to the significance of the asset and the scale of the impact.’
AS08 also currently states: ‘Proposals within the setting of historic assets must be accompanied by an archaeological survey and any finds must be recorded and interpreted.’
This statement implies that in all instances where proposals are located within the setting of an asset an archaeological survey should be undertaken. Again, this is considered too onerous and is unnecessary for many proposals. Heritage assets take many forms within the AONB and it does not follow that the setting of an asset will contain archaeological remains and so require an archaeological survey. It is true that some assets lie in archaeological landscapes and proposals in these sites may require archaeological work. Many sites however, are discrete features and always have been. Undertaking archaeological surveys for these assets is needless because the potential to disturb archaeological remains is negligible.
It is suggested that this sentence is removed.
Proposed Site Allocations
AS18 – A6 Land off Queen’s Drive, Arnside
This proposal does not raise any archaeological issues.
AS19 – A8/A9 Land on Hollins Lane, Arnside
This proposal does not raise any archaeological issues.
AS20 – A11 Land at Briery Bank, Arnside
This proposal does not raise any archaeological issues.
AS21 – B108 Land at Church Street, Beetham
There is some potential for this site to contain currently unknown archaeological assets given the size of the proposed development and the close proximity to the medieval village centre and medieval church. The proposal in the mini-brief to undertake a programme of archaeological investigation of the site in advance of development to record any assets disturbed by the development, is therefore supported.
AS22 – B112 Land at Stanley Street, Beetham
This proposal does not raise any archaeological issues.
AS26 – A25/A26/A27 Station House and Yard, Arnside
The site contains one former late 19th century railway building, which is a local heritage asset. The proposal in the mini-brief to retain the existing buildings is therefore supported.
AS27 – B35/B38/B81/B125 Sandside Road & Quarry Lane, Sandside
These sites contain an impressive set of limekilns and a recently restored 18th century former warehouse, which are local heritage assets. The proposal in the mini-brief to retain these buildings is supported, although they lie in site B38 and not B35 as specified in the mini-brief.
