Page 104 - Ickford NP Consultation Report

104 VISION FOR ICKFORD : ICKFORD NEIGHBOURHOOD PLAN CONSULTATION REPORT

Table Three continued

Responder Comment INP Reference Comment Response Change
Number Number Page Policy Para Required

11 17 21 BEH1 The policy needs to more closely reflect the 2019 NPPF Agree, chapter needs to Changes
which refers to the significance of designated heritage be updated to reflect to
assets and conditions the refusal of consent under para NPPF which was wording
195 due to substantial harm to a designated heritage published in 2019 of chapter
asset “unless it can be demonstrated that the substantial and
harm is necessary…” (designated asset defined in Annex policies
2 includes conservation area). Similarly the setting of
designated and non-designated heritage assets should be
addressed by the policy, including where positive
contributions are made as per NPPF para 200 on the
setting of a designated heritage asset (which include
conservation areas) “Proposals that preserve those
elements of the setting that make a positive contribution
to the asset should be treated favourably”. There are also
similarities in the use of ‘retain’ and ‘conserve’ which
should be resolved either through the use of only
‘conserve’ or otherwise defining both terms and
ensuring they are used consistently.

11 18 22 7.10 – The text should have consistent terms between Agree, chapter has been Changes
7.13 ‘heritage assets’ and ‘historic environment’ and reworded to
clarify that the NP identifies additional assets & wording
aspects of the historic environment which do not of chapter
already have protection, the NPG may wish to and
consider other elements of the historic environment policies
beyond structures. Similarly greater consistency and
clarity should be made recognising ‘buildings of
local note’ as ‘non designated heritage assets’. 7.12
implies there are other non-designated assets which
are not identified for inclusion, this inconsistency
should be rectified.
11 19 22 BEH3 The Policy should specify that it identifies only Agree Change
non-designated assets and more closely reflect
NPPF para 197: “…a balanced judgement will be
required having regard to the scale of any harm or
loss and the significance of the heritage asset”.
11 20 23, 25, Comments The comments should not be included as part of Do not agree, it is important Format
27, 30, the Neighbourhood Plan document but is more for residents to see their change
34 appropriate for inclusion within the consultation comments in the NP.
statement required for submission. Formatting could be changed
to separate the comments
form the text of the NP

11 21 23, 24, Flooding This chapter needs to more accurately reflect and Comments have been None as a
and Drainage distinguish between the multiple sources of flood risk received from BCC and result of
which are present in the Parish. This is particularly Thames Water and this
important when using technical terms such as Flood changes made to the text general
Zone 3 which relates to river-flooding only. The chapter comment
should refer to the likely effects of climate change and
the latest guidance from the Environment Agency
regarding how flood risk should be considered for new
development as well as the sequential test set out in the
NPPF. Given the significance of this issue for the parish it
might be beneficial to secure input from the flood risk
specialists at Buckinghamshire County Council as Lead
Local Flood Authority. It would be beneficial to have
other sources (ground water, surface water) of flood risk
mapped and referred to within the Neighbourhood
Plan.

VISION FOR ICKFORD – NEIGHBOURHOOD DEVELOPMENT PLAN
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