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Policy 3 Environmental Protection and Enhancement
Representation ID: 24531
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
It is important that your plan is underpinned by appropriate evidence.
We would continue to recommend that you review the list of types of evidence that we outlined to you in our Reg 18 response. We advise you to carefully consider the list we sent through (see letter dated 16.3.20).
There would appear to be a lack of heritage evidence to date. It is important that your plan is built on a sound and robust evidence base.
Any evidence base should be proportionate.
In particular we would highlight the need for a historic environment topic paper, Heritage Impact Assessments of certain sites and also taller buildings evidence base.
We advocate the preparation of a topic paper in which you can catalogue the evidence you have gathered and to show how that has translated into the policy choices you have made. Do this from the start, as a working document, that you add to throughout the plan preparation process, not just before EiP.
Ensure sound evidence base for the
historic environment in advance of EiP
a) Prepare a topic paper for the historic environment
b) Prepare HIAs for selected sites
c) Prepare taller buildings study to inform strategy
d) Prepare capacity of sites evidence base document
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.
Object
Publication
333
Representation ID: 24532
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We recognise the opportunities provided in East Norwich for brownfield regeneration.
However, one of our key concerns in this area relates to Carrow Works (Abbey/Priory). We have set out in more detail our concerns in Appendix B in relation to this site but in summary, we question the capacity of the
site and suggest that a more detailed Heritage Impact Assessment be undertaken before the next draft of the Plan to inform the suitability or otherwise of the site, the likely impact of development upon the significance of heritage assets, the extent of the developable area and
hence capacity of the site, any necessary mitigation or enhancements that could be made and then any changes required to policy wording.
Undertake detailed HIA for Carrow Works site and wider East Norwich area
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.
Object
Publication
304
Representation ID: 24533
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We still consider that there is a need for a taller buildings policy to be included in the GNLP Plan. This should be based on a study/evidence base that looks not only at your existing policy framework but that also explores the issue of the wider city skyline. In our view, this is a key
policy area that needs to be addressed in the strategic Plan.
We appreciate that you have now included some reference to height at Policy 7.1 in relation to City Centre criterion 5 which is welcome. However, the issue relating to height is not exclusive to the City Centre area.
We understand from our meetings that you are not proposing to address this issue through the Greater Norwich Local Plan but instead Norwich City are considering doing a 3D modelling study of the City and update to the Conservation Area appraisal. We understand that this work is likely to feed into future Development Management Local Plan revisions, or a
plan under the proposed new system, rather than the current GNLP.
However, in our view this is insufficient, particularly given the current growth pressures in Norwich. We continue therefore to recommend that a tall buildings study is undertaken to provide the evidence base and
contribute towards the development of an appropriate tall(er) buildings policy for this Plan. Ideally this should also consider the question of massing.
The study should investigate the important key views of the city, the skyline as a whole and the contribution that makes to the Conservation Areas and the wider historic environment. It should establish if there is
scope for tall(er) buildings and if so where and where not.
Our advice note in relation to tall buildings provides further guidance in this respect
Tall buildings – Advice Note 4
https://historicengland.org.uk/images-books/publications/tall-buildingsadvice-note-4/
A revision of our advice note is was out for public consultation last year.
https://historicengland.org.uk/whats-new/news/tall-buildings-adviceconsultation/
The Plan should then include a policy for taller buildings and the skyline
Undertake evidence base study on tall(er) buildings, massing and the skyline.
Include policy for tall(er) buildings and the skyline in the Plan.
We would be happy to explore this matter with you further.
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.
Object
Publication
Norwich and Urban Fringe Assessment Booklets
Representation ID: 24534
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
In our comments we have raised concerns about the indicative capacity of a number of sites.
Whilst we consider that it will be possible to achieve high densities on brown field sites compared with the densities of many parts of the city, it would not be appropriate to seek the densities associated with very tall buildings in metropolitan areas.
We appreciate the emphasis in national policy on high density development in sustainable locations but highlight paragraph 11b and footnote 6 of the NPPF which states that there may be circumstances where the application of policies in the framework that protect areas or assets of particular importance (including
designated heritage assets) provides a strong reason for restricting the overall scale, type or distribution of development in the plan area.
Historic England consider that Norwich’s historic character is under pressure from recent developments and also the scale of growth envisaged by this Plan.
One of the first questions any Inspector will ask at EiP concerns the capacity of the sites to accommodate the level of development indicated in the Plan.
To that end we consider that it is essential evidence base document is prepared outlining the site capacities and the assumptions that have been made in reaching these figures, particularly for the sites in the City. The evidence should set out the indicative site capacity,site area, density (as dwellings per hectare dph), assumed
maximum height, surrounding heights of development, other on site and off site capacity considerations (e.g. heritage, natural environment etc.). This will provide a helpful starting point for us to be able to consider whether the indicative site capacities are justified, realistic and achievable in terms of their impact upon the
historic environment (and other factors).
Prepare an evidence document on site capacities in advance of the EiP
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.
Support
Publication
HAR5 Policy
Representation ID: 24535
Received: 18/03/2021
Respondent: Historic England
We welcome the changes to criterion 4 to reference the listed buildings
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.
