MM56

Schedule Ancient Monument reference throughout the plan should be updated to Scheduled Monument to ensure terminology is consistent with NPPF

RE: Main Modifications Consultation - Colchester Borough Local Plan 2017 - 2033 - Section 2 (October 2021)
Thank you for consulting Historic England on the Colchester Borough Local Plan 2017 - 2033 - Section 2 - Main Modifications (October 2021). As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.
General
On the whole we support the Council’s main modifications as set out in the Draft Schedule of Recommended Modifications to Section 2 Local Plan (October 2021), particularly those which require development proposals have regard and respond to their historic contexts. However, we would draw your attention to the various uses of the term ‘Scheduled Ancient Monument’ throughout the Plan - the correct term is ‘Scheduled Monument’. The Council should review the Plan again to ensure that terminology is consistent with that used in the NPPF.
Policy WC3: Colchester Zoo
Notwithstanding the above we still have concerns regarding the allocation of Policy WC3: Colchester Zoo. The site incorporates the Gosbecks Scheduled Monument as well as archaeological remains that are probably of equivalent significance. We would, therefore, expect to see significant public benefit for the historic environment in any proposed scheme, informed by an adequate Heritage Impact Assessment (HIA). In particular a large part of the Scheduled Monument is within the allocation boundary, and under intensive cultivation - we would be keen to see this taken out of cultivation and incorporated in the adjacent Gosbecks Archaeological Park (which is part of the same Scheduled Monument), and within an integrated conservation management plan that preserves, interprets, promotes and makes accessible this important site as a whole. We would expected to see this stipulated in Policy WC3.
Conclusions
Finally, we should like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.
If you have any questions with regards to the comments made, then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime, we look forward to continuing to work with you and your colleagues.