Object

Publication

Representation ID: 23974

Received: 18/03/2021

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Title
We welcome the change to this title to specifically reference the historic environment.

First sentence
Again this is very generic – please make this more locationally specific to Norwich

Bullet point 2
We welcome the amplification of the second bullet point to include reference to scale mass, height, layout and materials as well as the reference to the character of the Conservation Area and the City Centre Conservation Area Appraisal. We suggest that wording of this criterion is amended and re-ordered to read, New development proposals will respect the character of the city centre conservation area and address the principles set out in the City Centre Conservation Area Appraisal (or any successor), Heritage Impact Assessments and the Taller Buildings and the Skyline Study in particular in relation to scale, mass, height, layout and design. New development will be sustainable and, where appropriate, innovative design.

We also welcome the deletion of the bullet point in relation to landmark buildings.

East Norwich Bullet Point 7:
We again register our concern regarding the doubling of the housing figure from 2000 – 4000 for this area. We question whether this is realistic, in light of historic environment considerations. Again we suggest an HIA is prepared to more properly inform the capacity of these sites and assess the potential impact on the historic environment.

We welcome 7th bullet point in relation to heritage assets. Whilst it is unfortunate that specific reference to certain key heritage assets has been deleted, we welcome the fact that the policy wording recognises the need to protect not only heritage assets at the sites but also the wider city’s heritage assets.

Elsewhere in the urban Area:
There is currently no reference to the need to conserve and enhance the historic environment within the list of bullet points for these areas.
Amend the Plan to include a bullet point in relation to the historic environment.

Change suggested by respondent:

First sentence – make more locationally specific to Norwich

We suggest that wording of this criterion is amended and re-ordered
to read, ‘New development proposals will respect the character of the city centre conservation area and address the principles set out in the City Centre Conservation Area Appraisal (or any successor), Heritage Impact Assessments and the Taller Buildings and the Skyline Study in particular in relation to scale, mass, height, layout and design. New development will be sustainable and, where appropriate, innovative design.’

East Norwich Bullet point 7: Complete HIA in advance of EiP to inform capacity of area.

Elsewhere in the urban area: Amend the Plan to include a bullet point in relation to the historic environment.

Full text:

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.