Object

Representation ID: 22542

Received: 16/03/2020

Respondent: Historic England

Policy 7.1 Housing figures
Historic England has some concerns regarding the housing figures.
In particular the figures provided in the table for housing include those for both Anglia Square (awaiting the Inspector’s decision) but it is Historic England’s view that the capacity of that site is closer to 600 than 1200 dwellings) and the Carrow Works (where we have suggested caution regarding the capacity of the site and have requested that a more detailed HIA be undertaken to more carefully consider the likely impact of development upon heritage assets and thus the likely capacity of the site).
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 permitted without or against our advice (Pablo Fanque House, new student accommodation below St. Giles) and by proposals such as those for Anglia Square.
We are concerned at some of the indicative site capacity figures given in the site allocations (and contributing to this table).
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).
We refer you to our publication, ‘Increasing residential density in historic environments’ which can be found here. This study explores the factors that can contribute to successfully delivering developments which increase residential density in historic environments. It uses a combination of literature review and case studies to provide a series of recommendations to support decision making. In addition we commend the work by Ash Sakula in relation to Anglia Square and the demonstration of how that particular site could be developed at high density whilst respecting the historic environment.

Suggested Change: Amend housing figures if necessary following the Inspectors decision on Anglia Square and upon completion of an HIA for Carrow Works.
Prepare an evidence base document to consider indicative site capacities of allocations.