Object
Publication
Representation ID: 23979
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Deal Ground includes a grade II listed bottle kiln and the southern portion of the site lies within the Trowse Millgate Conservation Area.
The Carrow Works site lies within the Bracondale Conservation Area. The site includes the Scheduled Monument, Carrow Priory and grade I listed Carrow Abbey, as well as several grade II listed buildings including Carrow House and several Carrow Works buildings. There are also a number of grade II buildings nearby on the opposite side of Bracondale.
Any development of these sites has the potential to affect these designated heritage assets and their settings.
We are very concerned about the very high number of dwellings (4000, rather than previously 2000 in Reg 18 Plan) anticipated from this area. Further comments on this are given at Appendix A of our comments. This is likely to give rise to very high density development on the sites, which may have a harmful impact on the historic environment.
We continue to strongly advise that the HIA should be prepared for the whole site ahead of the EiP to inform the allocation and in particular the capacity of the site. The HIA should inform the masterplan required under policy 7.1. Will the masterplan be adopted as SPD?
We are pleased to see that this policy now includes reference to heritage assets at criterion 6.
We suggest that the first sentence is moved to later in the criterion, perhaps as the penultimate sentence in this paragraph.
In the third sentence, the wording for the conservation areas should be amended to read ‘conserve or where opportunities arise enhance the character or appearance of the conservation areas’
We welcome criterion 12 in relation to archaeology. Deal Ground
We broadly welcome criterion 3 but suggest that the phrase ‘and reuse encouraged’ be replaced with ‘required together with a future maintenance scheme for the asset’.
Carrow Works
The reference to demolition of locally listed buildings in bullet point one would appear to be unhelpful and gives the wrong emphasis in relation to conservation and enhancement of heritage assets. We suggest that this second sentence is reframed in a more positive manner to more closely reflect the NPPF. There are a number of unlisted former Colman’s industrial buildings on site that are of some historic interest. The potential to retain and adapt these buildings should be identified at para 2.10 vii on page 8.
We are particularly concerned about this site, given the heritage assets within this site.
Utilities Site
We welcome bullet point one which acknowledges the heritage significance of the site.
ATB Lawrence Scott
It is not entirely clear where the ATB site is and there is no separate subheading for this area of the site. Is this a new site?
We continue to strongly advise that an HIA is prepared for the area now ahead of the EiP. This should also be used to inform the site capacity, the policy wording and the development of the masterplan for the Area.
Criterion 6
Reorder the sentences, moving the first sentence to the penultimate sentence.
Amend wording in third sentence to read ‘conserve or where opportunities arise enhance the character or appearance of the conservation areas’
Deal Ground
In criterion 3, replace ‘repair and reuse with be encouraged’ with ‘repair will be required together with a future maintenance scheme for the asset’.
Carrow Works
Re-frame second sentence of Carrow works bullet point 1 in a more positive manner to more closely
reflect the NPPF.
Add subheading for ATB site
Add ref at para 2.10 vii to unlisted Colman’s industrial buildings of historic interest and the potential retain and adapt these.
Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. 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 conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.
SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.
In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.