Object
Publication
Representation ID: 24531
Received: 18/03/2021
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
It is important that your plan is underpinned by appropriate evidence.
We would continue to recommend that you review the list of types of evidence that we outlined to you in our Reg 18 response. We advise you to carefully consider the list we sent through (see letter dated 16.3.20).
There would appear to be a lack of heritage evidence to date. It is important that your plan is built on a sound and robust evidence base.
Any evidence base should be proportionate.
In particular we would highlight the need for a historic environment topic paper, Heritage Impact Assessments of certain sites and also taller buildings evidence base.
We advocate the preparation of a topic paper in which you can catalogue the evidence you have gathered and to show how that has translated into the policy choices you have made. Do this from the start, as a working document, that you add to throughout the plan preparation process, not just before EiP.
Ensure sound evidence base for the
historic environment in advance of EiP
a) Prepare a topic paper for the historic environment
b) Prepare HIAs for selected sites
c) Prepare taller buildings study to inform strategy
d) Prepare capacity of sites evidence base document
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.