Object

Representation ID: 22563

Received: 16/03/2020

Respondent: Historic England

The site lies within the Norwich City Centre Conservation Area. To the east of the site lies the grade II listed 75 Magdalen Street, to the south lie numerous listed buildings, the nearest of which being Doubty's Hospital also listed at grade II. To the north west lies a collect of listed buildings including the grade I listed Church of St Augustine with a further group of listed buildings along Magdalen Street to the north east of the site.
Any development of the site has the potential to impact upon these heritage assets and their settings.
Historic England is broadly supportive of the principle of redevelopment of this site, providing it is of an appropriate scale and massing and conserves and enhances the heritage assets.
However, we object to the allocation as currently proposed.
It is our view that the scale of the proposed development would be inconsistent with the council’s development management policies, as well as with broad strategic objectives, because it would entail development which would cause severe harm to the character of the city centre conservation area and harm to a variety of other designated heritage assets of the highest significance. The adopted SPD for this site placed a wide range of requirements on the site which we consider would be difficult to achieve at an appropriate density that would conserve and enhance the historic environment
In particular, we consider that the indicative capacity of 1200 dwellings cannot be achieved without harm to the historic environment.
Instead we suggest that the allocation should be based on the reinstatement of the lost historic street pattern – as envisaged by the policies in the conservation area appraisal. It should rest on an understanding of how mid- to high density development can be accommodated in a manner appropriate to the wider character and grain of the city. Elements fundamentally incompatible with this – notably the provision of c. 600 car parking spaces – should be omitted. Finally the dwelling capacity should be reduced.
We commend Ash Sakula’s approach https://www.ashsak.com/projects/anglia-square-norwich
as 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.
More specifically in relation to the current wording of the allocation, there is currently no mention of the Conservation Area within the policy. We suggest this be amended.

Bullet point 6 refers to a landmark building or buildings to provide a focal point for the northern city centre. We have concerns regarding this bullet and in particularly the lack of clarity regarding an appropriate scale and massing of such development. We do however welcome the need for any such development to be sited to conserve and enhance heritage assets and their setting (although again we would recommend the inclusion of the word significance).
However, it is about more than just individual heritage assets and their settings but extends to the character and skyline of the city as a whole.
To that end we suggest that further work needs to be done to provide an appropriate evidence base for a tall buildings strategy for the city (see Appendix A comments on tall buildings)..
Clearly this site has been the subject of a recent Planning Inquiry in which Historic England objected to a scheme not dissimilar to that envisaged by the proposed allocation. The outcome of the Inquiry will clearly be crucial in determining an appropriate way forward for this site and we suggest that the wording of the allocation will need to be revisited in light of this.

Suggested Change:
Include reference to the City Centre Conservation Area and other heritage assets in the policy.
Amend policy to reduce indicative dwelling capacity, remove requirement for car parking, and ensure the reinstatement of the historic street pattern and a more appropriate density of development to reflect the grain of the area and to conserve and enhance heritage assets.
The policy will need to be reviewed following the outcome of the Planning Inquiry for this site.
Undertake a tall buildings study to inform an appropriate strategy for such development within the City – see comments in Appendix A.