Comment

Representation ID: 22526

Received: 16/03/2020

Respondent: Historic England

Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:
a)Development Management Policies
We continue to have significant concerns that the Development Management Policies for the three local authorities have not been reviewed as part of this Local Plan (although we note that there is some mention that they may be prior to EIP) for the reasons set out in Appendix A. We recommend that the Development Management Policies are reviewed and incorporated into the Regulation 19 Plan as a matter of priority.

b)Historic Environment Policy
It is our view that there is insufficient policy detail for the historicenvironment. The strategic historic environment policy is currently combinedwith the natural environment policy (Policy 3). We would expect to see a more detailed policies for the historic environment - presumably in the development management policies section of the Plan. Such policies should cover designated heritage assets, non-designated heritage assets including Local lists, archaeology, a policy to address heritage at risk (including provision for a local heritage at risk list), historic shop fronts, historic landscape character etc.The strategic policy inevitably lacks that level of detail but without seeing the detailed policies it is hard to comment on the soundness of the Plan in the round. This further underlines the need to update the development management policies at the same time so the Plan can be read as a whole. It is difficult to see whether the historic environment will be adequately covered without seeing the updated Development Management Policies.

c) Key principles for development of City sites
Whilst we broadly welcome the principle of redevelopment of many brown field sites, it is clearly important that such development does not cause harm to the historic environment of City. To that end we suggest a number of key principles for development which could be incorporated into policy 7.1, section 5 namely:
·Development should be of a scale and massing in keeping with the surrounding area;
·Development should respect and reinterpret the historic grain, street layouts,burgage plots and morphology of the City;
·Development should avoid breaking the skyline or competing with historic landmark buildings across the City;
·Development should use materials in keeping with the historic fabric of the City.

d)Strategy for tall(er) buildings in Norwich
In addition to these key principles, we also consider that it would be helpful to undertake a tall buildings study to provide the evidence base and contribute towards the development of an appropriate tall(er) buildings policy for the Plan.This might also consider the question of massing. We would welcome the opportunity to discuss the development of a policy approach to taller buildings in more detail with you. By developing a strategy for height and mass, this will help to secure sustainable development of high quality that protects and enhances the historic environment, character and significance of the City.

e)Indicative Site Capacity
We are concerned that some of the indicative capacities for site allocations may not be realistic. To that end we consider that it would be useful for you to prepare an evidence base document outlining the site capacities and the assumptions that have been made in reaching these figures, particularly for the sites in the City. This will provide a means of demonstrating whether the indicative site capacities are justified, realistic and achievable in terms of their impact upon the historic environment (and other factors). Our concerns are set out in more detail in Appendix A and B.

f)Impact on historic environment for some site allocations
We are concerned that there is currently insufficient evidence in relation to the historic environment in terms of site allocations. Paragraph 31 and 187 of the NPPF requires a proportionate evidence base for Plans. To that end, we suggest that you review the site assessments to ensure that there is sufficient and robust in its consideration of the historic environment. We suggest that a brief Heritage Impact Assessment (HIA) is undertaken for ALL sites in the Plan following the 5 step methodology, with more detailed HIA being undertaken for selected sites where the heritage issues are greater. We suggest more detailed HIA for the following sites GNLP0409R, GNLP3053GNLP3054, GNLP0125, GNLP2143, GNLP379, GNLP0229, GNLP2019 and GNLP0133B and D. This is not an exhaustive list and it may be that in preparing the brief HIAs you identify other sites which also warrant a fuller assessment. 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 impacts are unavoidable should suitable mitigation measures be proposed. Further detail is given in the attached table.

g)Policy wording for some site allocations
As currently drafted there is either a lack of criteria or insufficient detail within the site specific policies for the conservation and enhancement of the historic environment. The NPPF (para 16d) makes it clear that Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals. Further advice on the content of policies is given in the PPG at paragraph Paragraph: 027 Reference ID: 61-027-20180913 Revision date: 13 09 2018 that states, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development’. The policies should be re-worded to include criteria for the protection and enhancement of the historic environment. This will provide greater protection for the historic environment and ensure clear and robust policies are in place that provide the decision maker and developers with a clear indication of expectations for the sites. Further details of our suggestions in this regard for each of the sites and a comment on site allocations in general are given in the attached table B.