Object
Publication
Representation ID: 23973
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Historic England raised concerns regarding some of these housing figures at the Regulation 18 consultation. At the time, we specifically requested HIAs for a number of sites to test and inform the capacity of sites in the Local Plan. These HIAs have not been completed, calling into question the accuracy of the capacity of some of these sites.
It would be helpful to know which sites in addition to Anglia Square contribute to the 1558 commitment for the Northern City Centre Area, in order to properly assess whether this is realistic.
We note that the figures for East Norwich have doubled from 2,000 to 4,000 dwellings. In the absence of Heritage Impact Assessment, it is difficult to say whether this uplift in capacity is realistic.
To that end, we find the Plan unsound as it is not justified since it is not based on sufficient evidence in relation to the historic environment.
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. See separate comment on capacities of sites at Appendix B.
Prepare HIAs of key sites to inform site capacity and amend figures accordingly if necessary..
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.