Publication
Search representations
Results for Historic England search
New searchObject
Publication
208
Representation ID: 23965
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Replace historic assets with heritage assets in line with the terminology used in the NPPF.
Replace historic assets with heritage assets
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
204
Representation ID: 23966
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We broadly welcome reference to guidance including landscape character assessments conservation area appraisals, listed building and scheduled monuments information and archaeological records.
We note reference to heritage impact assessments. We would comment that HIA at planning application stage does not negate the need for Heritage impact assessments for inform site allocations. More on this issue in relation to the site allocations section of the Plan (see Appendix B of our response).
Amend scheduled ancient monuments to scheduled monuments, the preferred NPPF term.
Amend scheduled ancient monuments to scheduled monuments, the preferred NPPF term
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
207
Representation ID: 23967
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
At the start of this paragraph, make the point that harm should be avoided in the first instance.
State that harm should be avoided in
the first instance.
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
208
Representation ID: 23968
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We welcome reference in this paragraph to Heritage at Risk. In this paragraph
Although this paragraph now references Heritage at Risk, there is still no
specific mention within the policy. We strongly suggest that Heritage at Risk is specifically mentioned in policy 3.
Add a sentence on Heritage at Risk to Policy 3.
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
222
Representation ID: 23969
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We welcome the addition of this paragraph which mentions the relationship between Green Infrastructure and the historic environment.
We suggest replacing Historic Environment assets with heritage assets, the preferred term and in line with the NPPF.
The paragraph could be strengthened by adding the following wording:
Green Infrastructure can have a role to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history.
Replace ‘historic environment assets’ with ‘heritage assets’.
Add text in relation to the role of green infrastructure in relation to the historic environment to read,
‘Green Infrastructure can have a role to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history.’
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
Policy 3 Environmental Protection and Enhancement
Representation ID: 23970
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
This policy is quite generic and could be a policy for anywhere in the country. We suggest that you make the policy more locally specific in order to make a positive contribution to local character and distinctiveness in the Greater Norwich Area .
Bullet point 1
Whilst we broadly welcome the requirement for heritage impact assessment to accompany proposals for development, more fundamentally, HIA is also needed to inform the Plan making process, the suitability of the site per se and any particular capacity issues/design criteria that should be included in the Plan. HIA to inform planning application is not a substitute for HIA at plan making stage.
Bullet point 2
The second bullet point requires amendment. Harm should be avoided in the first instance. Only where harm cannot be avoided should we move on to consider the tests and weighing exercise as set out in the NPPF.
And the tests are more subtle than is implied here which just talks about outweighing. Of course, we know that:
a)Substantial harm requires substantial public benefits that outweigh the harm
b) Whereas for less than substantial harm, public benefits are
weighed against.
c) And for non-designated heritage assets a balanced judgement is required.
You could add the phrase, ‘in accordance with the requirements of the NPPF’ to help clarify the position.
Bullet point 3
Expand this bullet point to make specific reference to the need to address Heritage at Risk.
Include a separate paragraph in the policy after ‘importance of the heritage asset.’ To read, ‘The Councils will maintain and update the Heritage at Risk Register and develop a strategy for addressing Heritage
at Risk.’
Make the policy more locally specific.
Suggest reordering bullet points, 2, 1,
3.
Bullet point 1 We re-iterate our advice that HIAs are required to inform site allocations and as part of the evidence base for the Local Plan. These need to be completed before the EiP.
Amend bullet point 2 to more properly reflect the tests in the NPPF. You could add the phrase, ‘in accordance with the requirements of the NPPF’.
Amend bullet point 3 to also specifically refer to heritage at risk.
Include a separate paragraph in the policy after ‘importance of the heritage asset.’ To read, ‘The
Councils will maintain and update the Heritage at Risk Register and develop a strategy for addressing Heritage at Risk.’
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
312
Representation ID: 23971
Received: 18/03/2021
Respondent: Historic England
We welcome the reference at bullet point two to conserving and enhancing the historic and natural environment.
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
316
Representation ID: 23972
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Historic England recognise that this area contains a number of key brownfield sites and understand the importance of regeneration in the area for the city as a whole.
We note the amendments made to the Anglia Square site allocation policy and also to policy 7.1 to reference some of the key principles for development in this area. However, we continue to have some significant concerns regarding the approach to development at Anglia Square and the lack of HIA evidence to inform the allocation. Further more detailed comments are provided in relation to policy 7.1 and site allocation policy GNLP0506.
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 Anglia Square site.
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
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 23973
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Historic England raised concerns regarding some of these housing figures at the Regulation 18 consultation. At the time, we specifically requested HIAs for a number of sites to test and inform the capacity of sites in the Local Plan. These HIAs have not been completed, calling into question the accuracy of the capacity of some of these sites.
It would be helpful to know which sites in addition to Anglia Square contribute to the 1558 commitment for the Northern City Centre Area, in order to properly assess whether this is realistic.
We note that the figures for East Norwich have doubled from 2,000 to 4,000 dwellings. In the absence of Heritage Impact Assessment, it is difficult to say whether this uplift in capacity is realistic.
To that end, we find the Plan unsound as it is not justified since it is not based on sufficient evidence in relation to the historic environment.
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. See separate comment on capacities of sites at Appendix B.
Prepare HIAs of key sites to inform site capacity and amend figures accordingly if necessary..
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
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 23974
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Title
We welcome the change to this title to specifically reference the historic environment.
First sentence
Again this is very generic – please make this more locationally specific to Norwich
Bullet point 2
We welcome the amplification of the second bullet point to include reference to scale mass, height, layout and materials as well as the reference to the character of the Conservation Area and the City Centre Conservation Area Appraisal. We suggest that wording of this criterion is amended and re-ordered to read, New development proposals will respect the character of the city centre conservation area and address the principles set out in the City Centre Conservation Area Appraisal (or any successor), Heritage Impact Assessments and the Taller Buildings and the Skyline Study in particular in relation to scale, mass, height, layout and design. New development will be sustainable and, where appropriate, innovative design.
We also welcome the deletion of the bullet point in relation to landmark buildings.
East Norwich Bullet Point 7:
We again register our concern regarding the doubling of the housing figure from 2000 – 4000 for this area. We question whether this is realistic, in light of historic environment considerations. Again we suggest an HIA is prepared to more properly inform the capacity of these sites and assess the potential impact on the historic environment.
We welcome 7th bullet point in relation to heritage assets. Whilst it is unfortunate that specific reference to certain key heritage assets has been deleted, we welcome the fact that the policy wording recognises the need to protect not only heritage assets at the sites but also the wider city’s heritage assets.
Elsewhere in the urban Area:
There is currently no reference to the need to conserve and enhance the historic environment within the list of bullet points for these areas.
Amend the Plan to include a bullet point in relation to the historic environment.
First sentence – make more locationally specific to Norwich
We suggest that wording of this criterion is amended and re-ordered
to read, ‘New development proposals will respect the character of the city centre conservation area and address the principles set out in the City Centre Conservation Area Appraisal (or any successor), Heritage Impact Assessments and the Taller Buildings and the Skyline Study in particular in relation to scale, mass, height, layout and design. New development will be sustainable and, where appropriate, innovative design.’
East Norwich Bullet point 7: Complete HIA in advance of EiP to inform capacity of area.
Elsewhere in the urban area: Amend the Plan to include a bullet point in relation to the historic environment.
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.
