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Object

Publication

Policy 0409AR

Representation ID: 23985

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We welcome the reference to the heritage assets in paragraphs 2.56 – 2.62.

We suggest that the first sentence of criterion 2 is moved to later in the criterion, perhaps as the penultimate sentence in this paragraph.

Criterion 3
Should read character or appearance in line with legislation

The policy would be further improved by including reference to the Area of Main Archaeological Interest into the policy.

Again we suggest a more detailed HIA is prepared for this site.

Change suggested by respondent:

Criterion 2
Reorder the sentences, moving the first sentence to the penultimate sentence

Criterion 3 Change to ‘character or appearance’

Include reference to the Area of Main Archaeological Interest into the policy

Prepare HIA for site now ahead of EiP

Full text:

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 0409BR

Representation ID: 23986

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Criterion 2 would be improved by using the phrase ‘conserve and enhance the significance of heritage assets (including any contribution made to that significance by setting)’

Again continue to suggest a more detailed HIA is prepared for this site.

Change suggested by respondent:

Amend criterion 2 to include ‘conserve and enhance the significance of heritage assets (including any contribution made to that significance by setting)’

Prepare HIA for site now ahead of EiP

Full text:

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

0451 Policy

Representation ID: 23987

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy GNLP04 51 Land adjoining Sentinel House (St Catherine’s Yard) Surrey Street Norwich Unsound We broadly welcome the revised wording in relation to heritage at criterion 1.

We suggest the addition of the words ‘the significance’ after ‘enhances’.

The policy would be further improved by including reference to the Area of Main Archaeological Interest into the policy. Criterion 1
add the words ‘the significance’ after ‘enhances’.

Include reference to the Area of Main Archaeological Interest into the policy.

Change suggested by respondent:

Criterion 1
add the words ‘the significance’ after ‘enhances’.

Include reference to the Area of Main Archaeological Interest into the policy.

Full text:

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

0506 Policy

Representation ID: 23988

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We continue to have significant concerns about this allocation – in particular the scale of the allocation and potential to cause harm to the historic environment.

Site capacity – dwellings
We note that the capacity of the site has been reduced to 800 dwellings in response to the Secretary of State’s decision in relation to this site.

We have previously commented that the capacity of the planning 2018 application site would be closer to 600 dwellings. This was, in part, based on the work undertaken by Ash Sakula https://www.ashsak.com/projects/anglia-square-norwich that put forward a worked illustration of how Anglia Square could be redeveloped so as to provide the facilities required, within a new community in a sustainable manner that conserves and enhances the historic environment and restores the former street pattern of the area.

We therefore continue to advise that in our view 600 dwellings should be the maximum for the site.

It is not clear form the policy wording what scale of other development can be accommodated on site.

A heritage impact assessment should be undertaken prior to EiP to inform the allocation and policy wording. This could in part draw on some of the work done by Ash Sakula, but needs to look more broadly at the impact of potential development as expressed in the allocation (rather than simply the previous application) upon the significance of heritage assets, consider the capacity of the site including issues of height. Without an HIA, the allocation is not sufficiently justified as the potential impact on the historic environment has not been sufficiently assessed.

Criterion 5 and 9
Car parking – owing to its central location, car parking should be kept to a minimum on the site. We welcome the reference to low car or car free residential development but remain concerned about the reference to decked parking for the retail element. In our view,
Amend site capacity to 600 dwellings as a maximum.

Criterion 5
Delete criterion 5 in relation to car parking for the district centre.

Criterion 6
Add the following sentence to the criterion: ‘Any landmark building should not achieve this status through height exceeding that of existing buildings that from the immediate context of the site.’

Criterion 7
Add the words ‘including those’ before ‘at Magdalen Street’.
Add sentence to read, ‘The density of development to reflect the wider character and grain of the area.’

Criterion 11
Add sentence to read ‘Reinstatement of historic street pattern.’

Include reference to the Area of Main Archaeological Interest into the policy.

Change suggested by respondent:

Prepare an HIA prior to EiP to inform the site capacity (residential and other uses), potential mitigation and
enhancement and policy wording.

Amend site capacity to 600 dwellings as a maximum.

Criterion 5
Delete criterion 5 in relation to car parking for the district centre.

Criterion 6
Add the following sentence to the criterion: ‘Any landmark building should not achieve this status through height exceeding that of existing buildings that from the immediate context of the site.’

Criterion 7
Add the words ‘including those’ before ‘at Magdalen Street’.
Add sentence to read, ‘The density of development to reflect the wider character and grain of the area.’

Criterion 11
Add sentence to read ‘Reinstatement of historic street pattern.’

Include reference to the Area of Main Archaeological Interest into the policy.

Full text:

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

1061R Policy

Representation ID: 23989

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This would appear to be a new site.

There are no heritage assets within the site boundary. However, to the north west of the site lies the Horsham St Faith Conservation Area and a number of associated listed buildings including the grade I listed Church of the Blessed Virgin and St Andrew and the grade I listed and scheduled Priory as well as numerous grade II listed buildings. Development on the airport site has the potential to impact upon these heritage assets.

To that end, we suggest that a criterion is added to the policy to conserve and enhance the significance of the Horsham St Faith Conservation Area, listed buildings including the Grade I listed Church of the Blessed Virgin and St Andrew and the grade I listed and scheduled Priory as well as numerous grade II listed buildings
(including any contribution made to tier significance by setting).

Change suggested by respondent:

GNLP10 61R Land known as Site 4, Norwich Airport Unsound This would appear to be a new site.

There are no heritage assets within the site boundary. However, to the north west of the site lies the Horsham St Faith Conservation Area and a number of associated listed buildings including the grade I listed Church of the Blessed Virgin and St Andrew and the grade I listed and scheduled Priory as well as numerous grade II listed buildings. Development on the airport site has the potential to
impact upon these heritage assets. Add criterion to the policy to conserve and enhance the significance of the Horsham St Faith Conservation Area, listed buildings including the Grade I listed Church of the Blessed Virgin and St Andrew and the grade I listed and scheduled
Priory as well as numerous grade II listed buildings (including any contribution made to tier significance by setting)

Full text:

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

2114 Policy

Representation ID: 23990

Received: 18/03/2021

Respondent: Historic England

Representation Summary:

We welcome the changes made to the policy wording to include specific reference to heritage assets.

Full text:

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

2163 Policy

Representation ID: 23991

Received: 18/03/2021

Respondent: Historic England

Representation Summary:

We welcome the changes made to the policy wording to include specific reference to heritage assets, grain and massing and archaeology on this site. Paragraph 2.85 also provides helpful supporting text in relation to heritage.

Full text:

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

2164 Policy

Representation ID: 23992

Received: 18/03/2021

Respondent: Historic England

Representation Summary:

GNLP 2164 Land west of Eastgate House, Thorpe Road Sound We welcome the reference to the Conservation Area in this policy.

Full text:

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

3054 Policy

Representation ID: 23993

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Again we suggest a more detailed HIA is prepared for this site.

The supporting text at paragraphs 2.93 - 2.98 provide helpful context in relation to heritage and the site.

We note that reference is made to a heritage statement and heritage impact assessment in paragraph 2.95. However, we continue to suggest that the HIA should be prepared ahead of the EiP to inform the allocation.

Criterion 1
Should read character or appearance in line with legislation

Criterion 2
We suggest that the first sentence of criterion 2 is moved to later in the criterion, perhaps as the penultimate sentence in this paragraph.

The final sentence of this is not quite right - significance can in part be derived from setting. The sentence would be better is it read ‘conserve and enhance significance of the designated and non- designated heritage assets both on-site and off-site (including any contribution made to that significance by setting).

We welcome criteria 3,4 and 6

Criterion 5
Character or appearance rather than and to reflect the legislation


The policy would be further improved by including reference to the Area of Main Archaeological Interest into the policy.

Change suggested by respondent:

GNLP30 54 St Marys Works and St Marys House (150 dwellings and hotel) Unsound Again we suggest a more detailed HIA is prepared for this site.

The supporting text at paragraphs 2.93 - 2.98 provide helpful context in relation to heritage and the site.

We note that reference is made to a heritage statement and heritage impact assessment in paragraph 2.95. However, we continue to suggest that the HIA should be prepared ahead of the EiP to inform the allocation.

Criterion 1
Should read character or appearance in line with legislation

Criterion 2
We suggest that the first sentence of criterion 2 is moved to later in the criterion, perhaps as the penultimate sentence in this paragraph. Prepare HIA for site now ahead of EiP

Criterion 1
Should read character or appearance in line with legislation.

Criterion 2
We suggest that the first sentence of criterion 2 is moved to later in the criterion, perhaps as the penultimate sentence in this paragraph.
The final sentence of this is not quite right – setting can be part of significance. The sentence would be
better is it read ‘conserve and enhance significance of the designated and non-designated heritage assets both on-site and off- site (including any contribution made to that significance by setting).

Criterion 5
Character or appearance rather than and

Include reference to the Area of Main Archaeological Interest into the policy.

Full text:

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 CC2

Representation ID: 23994

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We welcome criterion 2 that references the Conservation Area and listed buildings. It would be helpful to specifically identify some of the key listed buildings including the Grade I listed Church of St John de Sepulchre and other nearby grade II listed buildings.

The policy would be further improved by including reference to the Area of Main Archaeological Interest into the policy.

Change suggested by respondent:

Include reference to the Area of Main Archaeological Interest into the policy.

Full text:

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.

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