Wandsworth Council
IIA Scoping Report –
consultee responses
March 2017
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
Natural England
Pressure on the
We agree with the potential significant effects on
No action
Noted with regards to HRA
natural and built
Wimbledon Common Site of Special Scientific Interest
environment
(SSSI) and Special Area of Conservation (SAC) and
Richmond Park SSSI and SAC that you have identified.
Natural England
Pressure on the
IIA1: as well as avoiding the loss of designated sites,
Revise
Changed IIA1 to read 'IIA1:
natural and built
we advise to include conserving and enhancing
framework
Avoid loss of designated
environment
internationally and nationally designated nature
ecological sites, priority habitats
conservation sites. We also advise to include priority
and species.'
habitats (alongside priority species).
Natural England
Pressure on the
IIA2: we advise to include geodiversity.
No action
Geodiversity has not been
natural and built
identified as a key issue in
environment
Wandsworth through the
scoping exercise
Natural England
Pressure on the
We advise including baseline information on
No action
We are not aware that this
natural and built
designated sites with regards to air quality, water
data is available
environment
quality and water supply.
Natural England
Pressure on the
The proposed monitoring indicators, such as SSSI
No action
Proposed monitoring
natural and built
condition, appear to monitor wider changes, rather
indicators are not included in
environment
than the effects of the plan itself. We thus advise that
the Scoping Report and
the monitoring indicators proposed are not sufficient
these will be proposed in the
to meet the requirements of the Environmental
formal IIA Report later in the
Assessment of Plans and Programmes Regulations
plan making process.
2004 to include suitable monitoring indicators in the
Indicators are included
SA, Local Plan, or post adoption statement. Whilst this
within the baseline data
can be deferred
tables in Appendix 2 and
to the post adoption statement, we advise it would be
these have been used to
best to resolve such matters at an earlier stage (see
gather and update the
email for specific suggestions and examples).
baseline data. The baseline
1
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
data indicators provide
useful information which
presents the baseline
situation at present and in
the future. The suggested
monitoring indicators
provided by NE will be
reviewed later in the IIA
process
Natural England
Pressure on the
under the conservation objectives of Wimbledon
Revise
amended text as suggested
natural and built
Common SAC ‘The structure anfunction ‘ should read
scoping
environment
‘The structure and function’.
report
Natural England
Pressure on the
when progressing to the next stages of the IIA, we
No action
Noted
natural and built
advise including alternatives and measures to prevent,
environment
reduce and offset any significant adverse effects on
the environment of implementing the plan.
Natural England
Pressure on the
With regards to ‘Appendix 3: Baseline and scope of
No action
Noted
natural and built
the HRA’, Natural England concurs with the European
environment
designated sites that have been scoped into an HRA.
The only information included into the table on the
state of the designated sites is based on the SSSI
condition, but these are a moment in time and do not
necessarily reflect trends or the most up-to-date
situation. In addition, because SSSIs are designated for
national nature conservation interest (as opposed to
European), you will need to ensure that the notified
features you are comparing are identical. When
proceeding with the HRA, we advise to gather
2
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
additional evidence to correctly identify the baseline.
Enable Leisure &
Pressure on the
(Pg 13, para3): Whilst I recognised that access to
Revise
amended as suggested
Culture
natural and built
nature/ greenspace is reflected on page 21, I also feel
scoping
environment
a sentence on “areas of deficiency in access to nature” report
would sit well at the end of this para to offer balance
about the distribution of the open space you refer to.
Enable Leisure &
Waste reduction
(Pg 19, T4.1): I would recommend that “soil” is also
Revise
We had previously decided to
Culture
and sustainable
included as an SEA topic in relation to “pressure on
framework
scope out soil and then found
consumption of
the natural and built environment”. Soil is
some additional information
resources
fundamental element of some of the other SEA topics
about contamination in the
here listed and will have a direct effect on them if it is
borough. Contamination and
adversely impacted.
remediation is well controlled
through development
management policies, however,
and therefore a decision has
been made to scope out soil
from the assessment.
Enable Leisure &
Pressure on the
(Pg 19, T4.1): I would also suggest that “population” is
Revise
added 'population' alongside
Culture
natural and built
included as an SEA topic in relation to “pressure on
scoping
"pressure on the natural and
environment
the natural and built environment”. I am aware we
report
built environment" to table 4.1
lack firm data to underpin trends but anecdotally I
as suggested. Biodiversity data
increasingly believe that the quality and condition of
included as a data gap using
biodiversity, flora and fauna is decreasing as a direct
text provided by Valerie Selby.
result of increasing accessibility by a larger population.
Enable Leisure &
Pressure on the
(Pg 21, F4.1 & Para below): This would read better if it Revise
Rearranged as suggested.
Culture
natural and built
was move to sit between pages 22 and 23 – it refers
scoping
environment
to the built environment whereas the preceding
report
introductory paragraph and the following information
3
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
on page 22 refer to the natural environment and it
would make more sense for them to sit together.
Enable Leisure &
Pressure on the
(Pg 22, F4.2): Omission: you have failed to add SINCs
Revise
amended figure added to the
Culture
natural and built
to the map. It is important to reflect these here both
scoping
scoping report showing SINCs
environment
in and of themselves and to demonstrate existing
report
Green Infrastructure and connectivity.
Enable Leisure &
Pressure on the
(Pg22, Para1): It is unclear to the general reader
Revise
It is inclusive of SSSI and SAC
Culture
natural and built
whether your reference to Areas of Biodiversity
scoping
and this has been clarified
environment
Importance is inclusive of SSSI & SAC or not?
report
within the report.
Enable Leisure &
Pressure on the
(Pg22, Para1): Omission: you have omitted to refer to
Revise
included reference to Barn Elms
Culture
natural and built
Barn Elms Wetlands SSSI in the text – this is an
scoping
Wetlands SSSI which lies in the
environment
important site especially when we are considering
report
neighbouring Richmond upon
Green Infrastructure and connectivity and particularly
Thames borough
in relation to “dark sky” issues and European
Protected Species.
Enable Leisure &
Climate change
(Pg 24, Para3): I believe there are revised measures
Revise
Checked the source and there is
Culture
and air quality
for the AQAP published in 2016
scoping
no data in the document. It is
http://www.wandsworth.gov.uk/info/200485/air_qua
report
already in PPP review and
lity/1584/monitoring_and_assessment/7 Speak to
relevant objectives have been
David Kennett Environmental Protection Team
highlighted.
Manager at Wandsworth Council for more
information
Enable Leisure &
Business and
(Pg 26,Para2): Would it be more accurate if you
Revise
Revised as suggested
Culture
employment
changed the last sentence to read “69.7% of adult
scoping
residents hold a degree level education……”
report
Enable Leisure &
Transport and
(Pg 27, F4.6): This key is meaningless to the general
No action
The levels are clearly
reader – for example; is an accessibility level of 1 good
explained in the
4
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
Culture
access
or bad?
accompanying text
Enable Leisure &
Pressure on the
(Pg 29, 4.4 bullet 3): By including the word
Revise
Text relating to this data gap
Culture
natural and built
“published” you imply there may be unpublished
scoping
has been clarified.
environment
trend data on biodiversity – this is disingenuous. The
report
information on trends is being analysed specifically for
this project, it doesn’t already exist in any format
published or unpublished.
Enable Leisure &
Pressure on the
IIA1 (Pg 30, T5.1): what is the rationale for the
Revise
Changed IIA1 to read 'IIA1:
Culture
natural and built
“particular focus on nationally important habitats and
framework
Avoid loss of designated
environment
priority species”? I would strongly caution against this
ecological sites, priority habitats
narrow approach.
and species.'
Enable Leisure &
Pressure on the
IIA4 (Pg 30, T5.1): you merely refer to “enhancement”
Revise
Revised as suggested
Culture
natural and built
in relation to multi functional green infrastructure. I
framework
environment
would strongly advocate for the inclusion of the
“establishment / creation of and retention of” of GI in
additional to enhancement.
Enable Leisure &
Pressure on the
IIA17 (Pg 32, T5.1): access per se is not the issue –
Revise
Creation of new green space is
Culture
natural and built
adequate accessible space is the issue. What is
framework
now included in IIA4. IIA17 has
environment
required is more space not alterations to the access to
now been deleted.
existing space.
Enable Leisure &
Public health
(Pg 32, T5.1): Omission: you have omitted to refer to
No action
This will be addressed
Culture
play / adequate access to play facilities for children
through revised
and young people to ensure good public health for
objective"IIA11: Ensure
that age group
people have access to
essential community services
and facilities, including open
space". Information about
areas which are deficient in
5
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
play space is out of date
(2007) and known to be
inaccurate. Planning can
ensure that facilities are kept
open and maintained
through s106 agreements.
Enable Leisure &
Pressure on the
(Pg 37, TA.1): Omission: you have omitted to include
Revise
Many of the PPPs are cross -
Changed introductory text for
Culture
natural and built
the Water Framework Directive (200/60/EC) having
scoping
cutting but are only included Table A.1 to make this clear.
environment
instead included it under Water Quality, Flooding and
report
in one category to avoid the
Climate Change. It belongs in both categories.
summary becoming any
more unweildy.
Enable Leisure &
Pressure on the
(Pg 63, TA.1): Omission: you have made no reference
No action
There is no Play Strategy
Culture
natural and built
to a council Play Strategy to guide provision and
available online and there is
environment
identify need? Perhaps the “Wandsworth’s children
no target for play provision
and young people s plan 2011-2015” supersedes this?
in the Children & Young
People's Plan.
Enable Leisure &
Pressure on the
(Pg 106, App2): % of people living in open space
Revise
Up to date data is not available
Culture
natural and built
deficiency area: The data showing areas of deficiency
baseline /
and this has been added as a
environment
in access to open space is available to WBC under the
PPP review
data gap for now. There is
SLA agreement between GiGL and Enable and is
potential for it to be plotted on
updated annually. WBC would need to plot this
GIS in the future.
against updated population figures but more recent
figures than 2001 should be calculable.
Pressure on the
The “City of London BAP 2016- 2020” is still only draft
Revise
Reference to London BAP
natural and built
format and does not apply to the borough of
baseline /
removed
environment
Wandsworth.
PPP review
Enable Leisure &
Pressure on the
(Pg 109, App2): I am not aware of the “London
Revise
This is a legacy from the
natural and built
Biodiversity Audit” – what is this and who undertook
baseline /
previous SA. We are unable to
6
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
Culture
environment
it? I am curious as to why it only deals with “wet”
PPP review
clarify the source. Data
habitats ?
removed from baseline.
Enable Leisure &
Pressure on the
(Pg 109, App2): Omission: you have not made
Revise
Data has been added to the
Culture
natural and built
reference to the GiGL Habitat Suitability Assessment
baseline /
baseline.
environment
which identifies areas which would give the best
PPP review
benefit to biodiversity, if used to create nine BAP
priority habitats in London.
http://www.gigl.org.uk/our-data-holdings/habitat-
data/bap-habitat-suitabilitydata/
Enable Leisure &
Pressure on the
(Pg 115,App2): Omission: you have not mentioned the Revise
The Wandle Catchment
Culture
natural and built
Catchment Management Plans for Beverley Brook
baseline /
Management Plan has been
environment
(hosted by the Environment Agency) and River
PPP review
added to the PPPs review.
Wandle (hosted by Wandle Trust
However, there doesn't appear
http://www.wandletrust.org/about-us/community-
to be a separate PPP for
catchmentplan/)
Beverley Brook. The Thames
river basin management plan
has been added
Enable Leisure &
(Pg 118, App3): Conservation Objectives – para 3:
Revise
corrected text
Culture
typing error
scoping
report
RBKC
Waste reduction
(Section 3.2): ‘key messages from the review of PPP’:
Revise
amended text
and sustainable
the bullet point relating to enabling
scoping
consumption of
sufficient and timely provision of sustainable waste
report
resources
management facilities should make clear this
relates not only to Wandsworth’s waste arisings but
also waste arisings from other waste planning
authorities in the WRWA.
7
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
Environment
Population and
Growth and Infrastructure Act 2013
Revise
Added to PPPs
Agency
household
· The Act allows the modification or discharge of the
baseline /
growth and
affordable housing elements of section 106 planning
PPP review
housing demand
gain agreements in order to make developments more
and supply
viable.
· Contains measures to extend permitted
development rights to allow single-storey extensions
of up to eight metres.
· Introduces measures to allow developers to take
planning applications to the Planning Inspectorate
where a council has "consistently failed to meet
statutory requirements to consider applications on
time".
· Removes the need for the communities’ secretary to
approve local development orders (LDOs), which relax
planning rules in specific areas, after they have been
drawn up by local authorities.
· Includes measures to speed up the planning
application process.
· reduces the volume of extra paperwork required
with a planning application; removing over-lapping
development consent regimes that require multiple
extra permissions from different government agencies
Environment
Public health
Civil Contingencies Act 2004 (CCA) –
Revise
Added to PPPs
Agency
Legislation that aims to provide a single framework for baseline /
civil protection. The Act and accompanying non-
PPP review
legislative measures, delivers a single framework for
civil protection in the country.
Climate change
The National Flood and Coast Erosion Management
No action
Already included
Strategy (July 2011) require communities to prepare
8
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
and air quality
flood action plans and link with the Cabinet Office’s
initiative to develop wider community resilience to
threats and hazards.
Part 1 of the Act and supporting Regulations and
statutory guidance establish a clear set of roles and
responsibilities for those involved in emergency
preparation and response at the local level. They are
required to:
· assess the risk of emergencies occurring and use this
to inform contingency planning; put in place
emergency plans;
· put in place Business Continuity Management
arrangements;
· put in place arrangements to make information
available to the public about civil protection matters
and maintain arrangements to warn, inform and
advise the public in the event of an emergency;
· provide advice and assistance to businesses and
voluntary organisations about business continuity
management (Local Authorities only);
· share information with other local responders to
enhance co-ordination; and
· co-operate with other local responders to enhance
co-ordination and efficiency
Environment
Climate change
National Flood Emergency Framework
Revise
Added to PPPs
Agency
and air quality
In planning and preparing for a flooding emergency,
baseline /
the Government’s strategic objectives are to:
PPP review
· protect human life and alleviate suffering; and, as far
as possible, property and the environment;
· support the continuity of everyday activity and the
9
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
restoration of disrupted services at the earliest
opportunity; and
· uphold the rule of law and the democratic process.
The National Flood Emergency Framework is intended
to cover the development, maintenance, testing and,
when necessary, implementation of operational
response arrangements that are:
· able to respond promptly to any changes in alert
levels;
· developed on an integrated basis, combining local
flexibility with national consistency and equity;
· capable of implementation in a flexible, phased,
sustainable and proportionate way;
· based on the best available scientific evidence;
· based on existing services, systems and processes
wherever possible, augmenting, adapting and
complementing them as necessary to meet the unique
challenges of a flood emergency;
· understood by, and acceptable to, emergency
planners and responders;
· designed to promote the earliest possible return to
normality.
Environment
Climatic factors
Building regulations
Revise
Added to PPPs
Agency
and energy
The Department for Communities and Local
baseline /
Government is responsible for policy on Building
PPP review
Regulations. These exist to ensure the health, safety,
welfare and convenience of people in and around
buildings.
Part H of the Building Regulations specifically covers
drainage. It strongly recommends a more sustainable
10
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
approach to surface water management with a
hierarchy that suggests disposal to watercourses and
sewers is the last resort. There is no current advice
directly on flood risk in the Building Regulations, with
some references to the management of moisture and
contamination should there be flooding. Sir Michael
Pitt's review of the 2007 flooding suggested that Part
H of the Building Regulations should be amended to
include property level flood resilience and resistance
measures. A number of measures have been included
to help reduce flood risk:
· requirement of planning permission to pave over
front gardens with impermeable surfaces
· Flood and Water Management Act calls for new
developments to no longer connect directly to
sewerage systems for surface water runoff. Instead
sustainable drainage systems (SuDS) are encouraged.
Environment
Pressure on the
River Basin Management Plans (RBMP) The RBMP is
Revise
Thames river basin
Agency
natural and built
the over-arching source of information on the water
baseline /
management plan added to
environment
environment and the actions we and others are
PPP review
PPPs
undertaking. The NPPF states in para 165 that RBMPs
should be used as evidence on which to base planning
decisions. This promotes the use of “up-to-date
information about the natural environment” which
should be useful to inform the action needed to
manage water resources in Local Plans. All public
bodies, including local authorities are required to
“have regard to the River Basin Management Plan and
any supplementary plans in exercising their
functions”. More information on the Water
11
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
Framework Directive is available on GOV.UK at:
https://www.gov.uk/government/policies/improving-
water-quality/supporting-pages/planning-for-better-
water.
Environment
Climatic factors
Climate change allowances
Revise
Added to PPPs
Agency
and energy
Recent updates to climate change allowances may
baseline /
have an impact upon the development sites in terms
PPP review
of flood risk. The National Planning Practice Guidance
refers planners, developers and advisors to the
Environment Agency guidance on considering climate
change in Flood Risk Assessments (FRAs). This
guidance was updated in February 2016 and is
available on Gov.uk
The guidance can be used for planning applications,
local plans, neighbourhood plans and other projects. It
provides climate change allowances for peak river
flow, peak rainfall, sea level rise, wind speed and wave
height. The guidance provides a range of allowances
to assess fluvial flooding, rather than a single national
allowance. It advises on what allowances to use for
assessment based on vulnerability classification, flood
zone and development lifetime.
National planning policy and guidance states that site-
specific flood risk assessment should be carried out by
(or on behalf of) a developer to assess the flood risk to
and from a development site. The assessment should
demonstrate to the decision-maker how flood risk will
be managed now and over the development’s
lifetime, taking climate change into account, and with
regard to the vulnerability of its users.
12
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
Environment
Climatic factors
River flows
Revise
Added to PPPs
Agency
and energy
The guidance on Gov.uk provides central, higher
baseline /
central and upper end allowances for peak river flow
PPP review
over three different timeframes up to the year 2115.
Use the Environment Agency River Basin District maps
to determine the applicable river basin. The range of
allowances is based on the following percentiles:
Central –50th percentile
Higher central –70th percentile
Upper end –90th percentile.
See Appendix 1 for an explanation of the percentiles.
Environment
Climate change
Peak rainfall
Revise
Added to PPPs
Agency
and air quality
The guidance on Gov.uk shows anticipated changes in
baseline /
extreme rainfall intensity in small catchments (<5 sq.
PPP review
km) and urban catchments. Central and upper end
estimates are provided. The new allowances and
supporting advice in ‘Flood risk assessments: climate
change allowances’ are relevant when preparing
strategic flood risk assessments for development plan
documents and flood risk assessments for planning
applications falling within the Town and Country
Planning Act 1990 (as amended).
Environment
Various
Additional background information supplied with
No action
Noted
Agency
regard to the EA's role in water resources and quality;
waste management; flood risk; soil and contaminated
land; and biodiversity
Historic England
Pressure on the
Chapter 1 Introduction
No action
Noted
natural and built
It is worth noting that the Sustainability Appraisal/IIA
– in seeking to reconcile economic, social and
13
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
environment
environmental objectives - should aim to avoid, not
just mitigate, significant effects in considering
alternative options, and seek environmental
enhancement where possible (NPPF in paras 8, 126
and 152). Historic England would like to see this
positive approach incorporated within the IIA
ambitions (for instance, in section 1.2, opening
paragraph and, importantly, within the process.
Historic England
Pressure on the
Chapter 3 Review of Policies Plans and Programmes
Revise
Issues revised as suggested
natural and built
Section 3.2 Summary of key messages, p16
issues
environment
It is important that the cultural heritage dimension
within the SEA/IIA remains a distinct part of the
analysis, and is not subsumed within townscape
generally. A distinction is needed so that the impact of
new development (or new townscape) can, through
the SEA/IIA, be measured for its impact on the historic
environment, whether beneficial or harmful.
With respect to the categories on p16, it would
therefore be helpful to refer to ‘Landscape,
townscape and heritage’. The first bullet is welcome,
but would be more aligned with the terminology and
scope of the NPPF if it were amended to:
- ‘Conserve and enhance heritage assets and their
settings, and the wider historic environment’
Historic England
Pressure on the
With respect to the second bullet, it is unclear why
Revise
Issues revised as suggested
natural and built
pollution is selected as the key threat. We suggest this issues
environment
is amended to:
- ‘Protect the most vulnerable heritage assets from
harm and seek sensitive re-use and repair to sustain
14
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
assets into the future’
Historic England
Pressure on the
Chapter 4 Baseline data and key sustainability issues
Revise
revised as suggested
natural and built
Table 4.1 Coverage of IIA topics
framework
environment
We suggest the first topic refers to ‘Pressure on the
natural, built and historic environment’ to align with
the NPPF (paras 7 and 9).
Historic England
Pressure on the
We welcome figure 4.1 showing key heritage assets.
No action
We're not aware that these
natural and built
To provide a more comprehensive picture a map of
are available on GIS. We
environment
the borough’s Archaeological Priority Areas should be
could add them if WBC can
included as well as scheduled monuments.
provide them.
Historic England
Pressure on the
Historic England encourages boroughs to provide a
Action for
WBC to liaise with HE on
A gap with regards to heritage
natural and built
rounded picture in the baseline heritage information,
planning
this issue.
information has been added to
environment
both characterising the resource and identifying the
policy team
section 4.4.
key issues and trends that need to be addressed. In so
doing the process can engage with the heritage of the
borough in a positive, practical way and secure
sustainable outcomes. We comment below on the
information in the Appendices. At present, the
information relating to the historic environment is
insufficient.
At this stage it may be helpful to provide a heritage
topic paper for the partial review, targeting the
heritage of the industrial and employment land. This
could be built on for the full review of the local plan,
perhaps through a borough characterisation report.
We consider that the gap in heritage information
should be identified within section 4.4. Should you
wish to discuss this further, we would be pleased to
15
Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
do so.
Historic England
Pressure on the
Chapter 5 Proposed Assessment Framework
Revise
revised as suggested
natural and built
Table 5.1 Key – We recommend that the IIA objective
framework
environment
for the historic environment is amended to read:
‘Conserve and where appropriate enhance heritage
assets and their settings, and the wider historic
environment, including buildings, areas, structures,
landscapes, townscapes, important views and
archaeological remains’
Historic England
Pressure on the
We welcome the statement following table 5.1 that
No action
Noted
natural and built
emphasises the simultaneous achievement of all the
environment
IIA objectives, and that no one objective should be
achieved at the cost of others. This reflects paras 8
and 152 of the NPPF.
Historic England
Pressure on the
Appendix 1, Table A1 Review of Policies, Plans and
Revise
Issues revised as suggested.
natural and built
Programmes
issues
Cumulative effects will be
environment
We welcome the inclusion of Historic England’s Good
addressed for all topics in the
Practice Advice Notes 1-3 (p44). Points that could be
next stage of the IIA.
drawn out for the sustainability objectives column
from the GPAs:
- understanding the significance of heritage assets in
order to conserve and enhance
- avoiding, as well as minimising and mitigating
impacts on heritage assets
- including assessment of cumulative impacts
Historic England
Pressure on the
In terms of the ‘Local overarching documents’ (pp61)
Action for
WBC to liaise with HE
natural and built
and the Council’s own strategies for landscape and
planning
environment
townscape (p65) there appears to be a gap in relation
policy team
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Consultation
IIA Topic (where
Issues Raised
Required
Reason for rejecting
Summary of action taken
body
applicable)
Action
comments or
recommendations
to heritage – although the cultural strategy objective
to foster a sense of place is welcome. A heritage
strategy for the borough, or a borough-wide
characterisation study, would be of great assistance in
taking a strategic approach to the historic
environment. Many London boroughs have
characterisation studies in place and these provide
helpful baseline information. We would be interested
in discussing if such analysis could be brought
forward.
Historic England
Pressure on the
Appendix 2: Baseline data
No action
The suggested monitoring
natural and built
P105/6 Landscape and Townscape – It is useful to
indicators provided by
environment
have a number of heritage-related indicators. The
Historic England will be
listed buildings ‘at risk’ indicator could be re-worded
reviewed later in the IIA
to ‘Heritage Assets at Risk’ – as the national Heritage
process, when preparing
at Risk register covers conservation areas, listed
formal IIA report
buildings, historic parks and gardens and scheduled
monuments. Although the entries for Wandsworth are
currently listed buildings, this would future-proof the
indicator. Additionally, it would be helpful to include a
more qualitative indicator to measure the impact of
development on the borough’s heritage assets –
perhaps through monitoring harm identified in
development management decisions. Lastly, we note
that two indicators - the number of conservation
areas and the area of Historic Parks and Gardens - are
included. Although part of the ‘baseline’ factually,
these are not useful in terms of measuring change.
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