Object
Publication
Representation ID: 23975
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Evidence base for planning for new settlements
We note that the authorities are planning for new settlements in the next Plan cycle. We strongly advise that sufficient evidence in relation to the historic environment is prepared to inform the choice of new settlement.
We would expect a Heritage Impact Assessment to be undertaken for each of the proposed new settlements in order to assist in comparing the different options and selecting a preferred option..
We would then expect more detailed heritage impact assessment of the chosen site to inform the allocation itself e.g. capacity, extent of developable area, areas of open space, landscaping etc. required as heritage mitigation.
We note that reference is made to Garden City Principles in paragraph
398. Whilst Historic England broadly welcomes new settlements, it is important that these are carefully located and planned with respect to all three strands of sustainable development. One of the strands of sustainable development includes the protecting and enhancing the historic environment.
Landscape (including landscape character areas and historic landscape characterisation) and heritage assets should be considered from the outset when determining the location of a new settlement in order to ensure that development can be delivered whilst having regard to the these assets. It is expected that strategic new settlement policies makes reference to the historic environment and the need for its conservation or enhancement.
Many Local Plans state that new settlements should come forward as a new ‘Garden Village’ based on the Town and Country Planning Association’s principles for Garden Cities. It is important at this stage to highlight that whilst these principles are useful and do embody a number of modern town planning concepts, they do not address the historic environment. It is therefore unclear how the TCPA principles can be reconciled with the NPPF’s definition of sustainable development in terms of its environmental strand which requires the conservation and enhancement of the historic environment.
Whilst the TCPA Garden Cities Principles are silent on the historic environment, their 2017 publication “The Art of Building a Garden City” does provide a further level of detail, particularly with regards to the siting of new settlements. This publication states that,
“locations for new garden cities should not only avoid damaging areas that are protected for their ecological, landscape, historic or climate- resilience value but should actively be located in areas where there can be a positive impact on these assets. Underpinning the consideration of sites for new garden cities or towns should be the extent to which each one … will allow for positive impacts on assets of historic value”.
(Emphasis added, pg. 100)
In drafting your principles for the development of new garden communities, we would suggest that you ensure that reference is made to the need to conserve and enhance the historic environment.
In preparing for a new settlement we strongly advise that sufficient evidence in relation to the historic environment (including a Heritage Impact Assessment) is prepared to assist in the new settlement site selection process.
Policy 7.6 could make it clear what types of evidence will be needed, including heritage impact assessment.
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.