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Policy 7.6 Preparing for New Settlements
Representation ID: 23975
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Evidence base for planning for new settlements
We note that the authorities are planning for new settlements in the next Plan cycle. We strongly advise that sufficient evidence in relation to the historic environment is prepared to inform the choice of new settlement.
We would expect a Heritage Impact Assessment to be undertaken for each of the proposed new settlements in order to assist in comparing the different options and selecting a preferred option..
We would then expect more detailed heritage impact assessment of the chosen site to inform the allocation itself e.g. capacity, extent of developable area, areas of open space, landscaping etc. required as heritage mitigation.
We note that reference is made to Garden City Principles in paragraph
398. Whilst Historic England broadly welcomes new settlements, it is important that these are carefully located and planned with respect to all three strands of sustainable development. One of the strands of sustainable development includes the protecting and enhancing the historic environment.
Landscape (including landscape character areas and historic landscape characterisation) and heritage assets should be considered from the outset when determining the location of a new settlement in order to ensure that development can be delivered whilst having regard to the these assets. It is expected that strategic new settlement policies makes reference to the historic environment and the need for its conservation or enhancement.
Many Local Plans state that new settlements should come forward as a new ‘Garden Village’ based on the Town and Country Planning Association’s principles for Garden Cities. It is important at this stage to highlight that whilst these principles are useful and do embody a number of modern town planning concepts, they do not address the historic environment. It is therefore unclear how the TCPA principles can be reconciled with the NPPF’s definition of sustainable development in terms of its environmental strand which requires the conservation and enhancement of the historic environment.
Whilst the TCPA Garden Cities Principles are silent on the historic environment, their 2017 publication “The Art of Building a Garden City” does provide a further level of detail, particularly with regards to the siting of new settlements. This publication states that,
“locations for new garden cities should not only avoid damaging areas that are protected for their ecological, landscape, historic or climate- resilience value but should actively be located in areas where there can be a positive impact on these assets. Underpinning the consideration of sites for new garden cities or towns should be the extent to which each one … will allow for positive impacts on assets of historic value”.
(Emphasis added, pg. 100)
In drafting your principles for the development of new garden communities, we would suggest that you ensure that reference is made to the need to conserve and enhance the historic environment.
In preparing for a new settlement we strongly advise that sufficient evidence in relation to the historic environment (including a Heritage Impact Assessment) is prepared to assist in the new settlement site selection process.
Policy 7.6 could make it clear what types of evidence will be needed, including heritage impact assessment.
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
Appendix 2 Glossary
Representation ID: 23976
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We continue to suggest that you add in definitions for Listed Building and Local List and Registered Park and Garden. Change Scheduled Ancient Monument to scheduled monument for the reasons set out above.
Add in definition for Listed Building and Local List and Registered Park and Garden. Change Scheduled Ancient Monument to scheduled
monument
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
• Introduction and Methodology
Representation ID: 23977
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
General comment on site assessment booklets for site allocations and lack of Heritage Impact Assessments Unsound At the regulation 18 consultation and in subsequent discussions with the Council, we have made it clear that we did not consider there to be sufficient evidence in relation to the historic environment to support the site allocations.
We understand that the HEELA and some site assessments have been revisited during the last year. Prepare HIAs for particular sites identified below prior to EiP. However, we have reviewed a number of the assessments, both in the HEELA and also the site assessment booklets. Whilst we see that some of the HEELA and site assessments have been revisited,
we still find the assessments lacking.
Unfortunately, the assessments do not follow the five step
methodology for site allocations set out in our Advice note 3 on site allocations. https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/ They do not properly consider the significance of the heritage assets, the impact of development upon the significance of those assets and do not consider mitigation and enhancement.
This is particularly concerning for the sites where we suggested that more detailed Heritage Impact Assessment (HIA) was required (and indeed, we had understood that it was the Council’s intention to
undertake this work when we met with them last year).
In our view, the key sites requiring HIA are: GNLP0409R, GNLP3053 GNLP3054, GNLP 0506, GNLP0125, GNLP2143, GNLP2019 and GNLP0133B and D.
The Plan now includes a number of new sites and we would also recommend an HIA for the following new sites GNLP0596R , GNLP 0253 and GNLP0581/2043.
We appreciate that there were various reasons why the Councils did not undertake this work prior to consultation on the Regulation 19 Plan.
However, we continue to advise that these HIAs should be prepared; this is imperative to ensure a robust evidence base for the Local Plan. These should be prepared in advance of the EiP. This is a matter of priority, given the timetable for the Plan.
The HIAs should assess the suitability (or otherwise) of each area for development and the impact on the historic environment. The HIA should consider the issue of the capacity of the site including issues in relation to height and the impact on the historic environment.
Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and ideally a strategy diagram which expresses the development criteria in diagrammatic form.
We would remind you that paragraph 32 of the NPPF makes it clear that significant adverse impacts should be avoided wherever possible and alternative options pursued. Only where these impactsare unavoidable should suitable mitigation measures be proposed.
Prepare HIAs for particular sites identified below prior to 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
2.8
Representation ID: 23978
Received: 18/03/2021
Respondent: Historic England
We welcome the references in the supporting text to heritage at paragraphs 2.8, 2.10(vii), 2.13, 2.18-2.21.
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
0360/3053/R10 Policy
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.
Object
Publication
Policy 0068
Representation ID: 23980
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We welcome the changes to policy and the addition of criterion 3 in relation to heritage assets. The policy would be further improved by including reference to the Area of Main Archaeological Interest into the policy.
Include reference to the Area of Main Archaeological Interest into the Policy
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 0133BR
Representation ID: 23981
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We very much welcome the wording at criterion 2 in relation to heritage.
We continue to suggest that a detailed HIA is prepared for the campus as a whole to inform future development and the impact on
the historic environment.
Continue to suggest HIA for campus as a whole now ahead 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.
Object
Publication
0133DR Policy
Representation ID: 23982
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Criterion 2 has been very much improved by reference to heritage assets. We suggest replacing respect with ‘conserve and enhance the heritage significance. We also suggest inserting a comma after Terraces.
We continue to suggest that a detailed HIA is prepared for the
campus as a whole to inform future development and the impact on the historic environment.
We suggest replacing respect with ‘conserve and enhance the heritage significance. We also suggest inserting a comma after Terraces.
Continue to suggest HIA for campus now ahead of 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
0282 Policy
Representation ID: 23983
Received: 18/03/2021
Respondent: Historic England
Policy GNLP0282 Land at Constitution Motors Sound Welcome bullet point 1 and reference to locally listed building.
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
Policy 0401
Representation ID: 23984
Received: 18/03/2021
Respondent: Historic England
We welcome the new wording in criterion 2 in relation to 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.
