MM133 - Policy GNLP0608R

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.

To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities (78, The Framework). Lenwade is the main service centre of the Great Witchingham, Lenwade, Weston Longville, Attlebridge, Little Witchingham and Morton-on-the-Hill village cluster.

Our comments reiterate our previous representations made at Regulation 19 stage. Currently, there is only one allocation for 20 new homes in Lenwade, which is not consistent with national policy where it states that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services (78, The Framework). The allocation of land at Weston Hall, Weston Longville (GNLP0553) (as shown on the masterplan) would promote sustainable development in Lenwade by locating housing where it will enhance the vitality of local services. In addition, identifying Lenwade as a village for growth will support the communities of other villages within the cluster. An allocation of up to 85 new homes is likely to unlock the local school's capacity issues.

A new allocation GNLP0553 for housing, consistent with the masterplan should be included in the plan within an extended settlement boundary.