Support
Sites
Representation ID: 25322
Received: 22/11/2023
Respondent: Historic England
Historic England welcomes the proposed modifications to criterion 3 and 9 as they provide greater protection for the historic environment and ensure consistency with national policy.
Thank you for consulting Historic England about the Proposed Modifications to the Greater Norwich Local Plan. We have the following comments to make on the suggested changes to the Plan:
We welcome many of the proposed Main Modifications. Our detailed comments on the proposed Main Modifications to the Plan are set out in Appendix A.
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
The key outstanding issue relates to East Norwich. We remain particularly concerned about the location of development around the Abbey. We have suggested revised policy wording in Appendix A, reflecting our earlier advice in our hearing statement and at EiP. We have raised these concerns in relation to the emerging SPD too.
Other policies
There are a number of other more minor issues relating to wording for the following policies/sites:
MM8 Policy 2 Sustainable Communities
MM13 Policy 7.1The Norwich Urban Area including the Fringe - East Norwich
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
MM33 GNLP1061R Norwich Airport
MM43 CC8 King Street Stores
MM92 GNLP0596R Land at Norwich Road, Aylsham
MM100 Hethel2 Land south and south west of Lotus Cars, Hethel
Our concerns in relation to the above sites set out in Appendix A reflect the proposed wording set out in our SOCG with the Council.
Archaeology Criterion
In a number of policies in the Local Plan, there have been amendments made to a policy criterion relating to archaeology. The criterion previously read 'Historic Environment Record to be consulted to determine any need for archaeological surveys prior to development' and now reads, 'An archaeological assessment will be required prior to development'.
Whilst this is an improvement on the previous wording, we suggested that the policy would be even better is it read, 'Planning applications should be supported by a desk based archaeological assessment and, where necessary, the results of a field evaluation as advised by the LPAs archaeological advisors'. This is accordance with para 194 of NPPF.
Finally, we would like to stress that this opinion 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 where we consider that these would have an adverse effect upon the historic environment.
Object
Sites
Representation ID: 25518
Received: 11/12/2023
Respondent: Broads Authority
Objection – lack of consistency between policies.
There is a lack of consistency between some policies. I have used a table (see full submission) to illustrate this. You will see that all sites are located next to the River in Norwich but some mention the Broads in the supporting text or in the policy and others don’t. Indeed, some modifications are proposed to refer to the Broads (which are welcomed), but the reference to the Broads is not consistent between these policies and needs to be. It is not clear why some modifications have been made to some policies and not to others given that the context of all the sites in relation to the Broads is exactly the same. I have added colour coding where green is that no change is needed, orange is that the Broads is mentioned, but not correctly or consistently with other policies so needs changing and red where text is missing and needs adding in order to be consistent. Considering all the sites have exactly the same context, changes are required to make them all consistent and so ‘green’ across the board, like Policy CC4B.
Representations in relation to MM8, MM9 and various sites
See full submission attached for more details