Object
Publication
Representation ID: 23970
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
This policy is quite generic and could be a policy for anywhere in the country. We suggest that you make the policy more locally specific in order to make a positive contribution to local character and distinctiveness in the Greater Norwich Area .
Bullet point 1
Whilst we broadly welcome the requirement for heritage impact assessment to accompany proposals for development, more fundamentally, HIA is also needed to inform the Plan making process, the suitability of the site per se and any particular capacity issues/design criteria that should be included in the Plan. HIA to inform planning application is not a substitute for HIA at plan making stage.
Bullet point 2
The second bullet point requires amendment. Harm should be avoided in the first instance. Only where harm cannot be avoided should we move on to consider the tests and weighing exercise as set out in the NPPF.
And the tests are more subtle than is implied here which just talks about outweighing. Of course, we know that:
a)Substantial harm requires substantial public benefits that outweigh the harm
b) Whereas for less than substantial harm, public benefits are
weighed against.
c) And for non-designated heritage assets a balanced judgement is required.
You could add the phrase, ‘in accordance with the requirements of the NPPF’ to help clarify the position.
Bullet point 3
Expand this bullet point to make specific reference to the need to address Heritage at Risk.
Include a separate paragraph in the policy after ‘importance of the heritage asset.’ To read, ‘The Councils will maintain and update the Heritage at Risk Register and develop a strategy for addressing Heritage
at Risk.’
Make the policy more locally specific.
Suggest reordering bullet points, 2, 1,
3.
Bullet point 1 We re-iterate our advice that HIAs are required to inform site allocations and as part of the evidence base for the Local Plan. These need to be completed before the EiP.
Amend bullet point 2 to more properly reflect the tests in the NPPF. You could add the phrase, ‘in accordance with the requirements of the NPPF’.
Amend bullet point 3 to also specifically refer to heritage at risk.
Include a separate paragraph in the policy after ‘importance of the heritage asset.’ To read, ‘The
Councils will maintain and update the Heritage at Risk Register and develop a strategy for addressing Heritage at Risk.’
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.