Object
Publication
Representation ID: 24551
Received: 22/03/2021
Respondent: Fuel Properties Ltd
Agent: Iceni Projects Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy 3 – Environmental Protection and Enhancement
2.9 We support the aim of the policy to ensure development appropriately protects and has regard to both the historic and natural environment. The former Carrow Works site contains a number of heritage assets and is also within the setting of various other assets, and there is a significant opportunity to conserve and enhance these assets through an appropriately sympathetic redevelopment proposal.
2.10 In order to ensure the text of Policy 3 is compliant with national policy, we consider that the second bullet point under the historic environment section of the policy needs to be updated, to fully reflect the approach set out at paragraphs 193-197 of the NPPF. The current wording refers to all designated and non-designated heritage assets as a single group and indicates that harm should be avoided “unless there are overriding benefits”. We consider that this does not sufficiently reflect the approach advocated by the NPPF, which requires different levels of benefits and justification depending on the significance of the asset and the extent of harm generated. On the one hand, substantial harm or loss
of the most significant assets should be wholly exceptional, whilst at the other end of the scale paragraph 197 of the NPPF indicates that the effect of development on the significance of a nondesignated heritage asset should be “taken into account”, with a “balanced judgement” being made having regard to the scale of any harm or loss and the significance of the asset. We are concerned that the current policy wording suggests a need for “overriding benefits” regardless of the significance of an asset or the extent of harm, which would not be consistent with national policy. It is also unclear how “historic character” is defined and how this reference in the policy relates to terms used in the
NPPF.5
2.11 In a similar way, we also recommend that the wording of the policy in relation to the natural
environment is clarified. The reference to avoiding harm to all designated and non-designated natural assets unless there are “overriding benefits” conflicts with the indication later in the policy that regard will be given to the level of importance of the natural element. In order to ensure the policy is sound, we therefore recommend that this wording is clarified, with appropriate references to Chapter 15 of the NPPF.
2.12 In relation to the references to biodiversity net gain, it will be necessary to ensure that the final policy wording reflects the requirements set out in the Environment Act once this is enacted.
See attachment for full representation
See attachment for full representation
On behalf of our client, Fuel Properties (Norwich) Ltd, we provide our comments on the Greater Norwich Plan Pre-Submission Draft Strategy (Regulation 19 Publication Stage), published for consultation in February 2021.
Fuel Properties (Norwich) Ltd are the developers of the Carrow Works site in east Norwich, which is identified in the emerging Greater Norwich Local Plan as being within the East Norwich Strategic Regeneration Area. The wider Regeneration Area has the potential to deliver some 4,000 new homes and 6,000 jobs, and will act as a catalyst for longer term regeneration of the wider area. The Carrow Works site comprises an important and substantial part of the East Norwich Strategic Regeneration Area and provides a significant opportunity to deliver growth for Norwich City the Greater Norwich
area.
Our client welcomes the opportunity to provide comments on the emerging Greater Norwich Local Plan and to work collaboratively with the authority and key stakeholders as the plan progresses.
See attachment for full representation.