Question 20: Do you support, object or have any comments relating to approach to the built and historic environment?

Comment

Representation ID: 20059

Received: 23/02/2020

Respondent: Mr Norman Castleton

Development
There is far too much development proposed on green field and village sites. The services have not and will not keep pace with this and the environmental impact will eventually be catastrophic. The current housing developments on the edge of the city, towns and villages is pretty awful. Insensitive to landscape and area. Note the work of Taylor & Green for the Rural & Urban District councils in the 1960s which would be a good example to follow e.g. Hopkins homes are the same wherever built, in the city or in a field.

Comment

Representation ID: 20989

Received: 14/03/2020

Respondent: Mr Keith Benjafield

Our heritage is crucial in maintaining our identity and history Wymondham is a place in point. To much over unsympathetic development will kill the town It should enhance the town but all it does is create separate communities as the development does not link the town with improved infrastructures cycle ways footways bus routes etc.

Object

Representation ID: 21400

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Glavenhill Ltd contend that the GNGB's approach to the natural environment as set out in Policy 3 of the Regulation 18, Stage C Consultation Document, specifically the lack of any discernible or deliverable site for a new country park, is "unsound".

Comment

Representation ID: 21535

Received: 16/03/2020

Respondent: Hingham Town Council

Hingham Town Council support the policy of environmental protection and enhancement. A community should have total confidence that if forced to accept more development , that the development would be an asset to and enhance the environment.
Sites should not be allocated for development when they are so clearly contrary to the policies that should be applied.

Object

Representation ID: 21620

Received: 16/03/2020

Respondent: Aylsham TC

There is a lack of acknowledgement within the policy that the historic asset maybe underground rather than visible on the surface. This is also badly covered in the NPPF. This would be an opportunity to ensure discovery and then protection of unknown sites

Support

Representation ID: 21743

Received: 16/03/2020

Respondent: Brown & Co

We support the approach to the built and historic environment.
The proposed new settlement Honingham Thorpe would respect the built and historic environment of the local area, avoiding coalescence with the existing surrounding villages whilst providing opportunities for their enhancement. Technical surveys already carried out have concluded that the proposed development would not have a significant adverse impact upon the local built and heritage environment. Additional technical work will be undertaken, and future plans would seek to respect local features including Saint Peter’s Church at Easton and St Andrew’s Church to the north of the A47.

Support

Representation ID: 21945

Received: 13/03/2020

Respondent: UEA Estates & Buildings

Agent: Bidwells

The UEA are supportive of the strategy to ensure that development proposals conserve and enhance the built, historic and natural environment.
As outlined within the Representations for GNLP0133-B, GNLP0133-C, GNLP0133-D, and GNLP0133-E, Historic England consulted on the potential designation of the landscape surrounding the UEA as Historic Parkland (Case: 1466188). Notwithstanding this, regardless of whether the landscape is designated as Historic Parkland, development on each site will be designed in a manner to respect the visual setting of the UEA, whilst facilitating the growth and expansion of the UEA.

Support

Representation ID: 22037

Received: 13/03/2020

Respondent: East Suffolk Council

We support the approach to the built and historic environment as it is in accordance with the NPPF.

Comment

Representation ID: 22066

Received: 16/03/2020

Respondent: Norfolk Wildlife Trust

Policy 3 – Environmental Protection and Enhancement
We support the reference in paragraph 186 to the likely future requirement for mandatory biodiversity net gain as a result of the Environment Bill currently being considered by Parliament. In addition to biodiversity net gain, there is a requirement to develop Nature Recovery Networks (NRNs), which will likely require further amendments to the submission plan. We highlight and direct the Council to recently published guidance by Natural England on NRNs, the Nature Networks Evidence Handbook , which highlights the important role Local Plans can play in helping deliver them successfully.

We note with concern the reference to the 2017 Interim Habitats Regulation Assessment (HRA) in paragraph 187. It suggests the development mitigates impacts on sites protected by the Habitats Regulations. Whilst mitigation has a role in the HRA process and can be considered at the Appropriate Assessment stage, the overall target of the HRA process is to ensure that adverse effects on European Sites is avoided.

Whilst we recognise that significant changes may need to be made to the policy wording in response to the outcome of the Environment Bill, in order to ensure that the plan objectives to protect and enhance the natural environment can be delivered, we recommend the following changes are made to the text of Policy 3:

Policy 3, paragraph 5 ‘...development should deliver biodiversity net gain wherever possible proportional to the scale of the development, as set out in the DEFRA biodiversity net gain metric’. This is in order to ensure that the policy meets the plan objectives to secure net gains for wildlife and offers clear guidance to developers on the proportional contributions expected from all development, in line with the requirements of the NPPF.

Policy 3, paragraph 7 ‘All housing development is required to avoid mitigate impacts on sites protected under the Habitats Regulations Directive’. We presume this refers specifically to the indirect impacts of recreational pressure from new housing on European Sites, but this is unclear in the policy text and we recommend the wording is changed to clarify the wider legal requirement applying to development that may affect European Sites. The legal need is set out in the UK Habitat Regulations, originally derived from the European Habitat Directive.

In addition, the last sentence in the fourth paragraph is too ambiguous and risks misinterpretation of developers’ obligations regarding protection of the various difference wildlife designations. We strongly recommend that this wording is expanded to highlight the requirements regarding development and legally protected European Sites, Sites of Special Scientific Interest and Ramsar sites, as well as local designations including County Wildlife Sites, Local Nature Reserves, Roadside Nature Reserves and ancient woodland. Clear policy wording should be included to demonstrate how the plan will ensure that the natural environment will be protected and enhanced.

Comment

Representation ID: 22526

Received: 16/03/2020

Respondent: Historic England

Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:
a)Development Management Policies
We continue to have significant concerns that the Development Management Policies for the three local authorities have not been reviewed as part of this Local Plan (although we note that there is some mention that they may be prior to EIP) for the reasons set out in Appendix A. We recommend that the Development Management Policies are reviewed and incorporated into the Regulation 19 Plan as a matter of priority.

b)Historic Environment Policy
It is our view that there is insufficient policy detail for the historicenvironment. The strategic historic environment policy is currently combinedwith the natural environment policy (Policy 3). We would expect to see a more detailed policies for the historic environment - presumably in the development management policies section of the Plan. Such policies should cover designated heritage assets, non-designated heritage assets including Local lists, archaeology, a policy to address heritage at risk (including provision for a local heritage at risk list), historic shop fronts, historic landscape character etc.The strategic policy inevitably lacks that level of detail but without seeing the detailed policies it is hard to comment on the soundness of the Plan in the round. This further underlines the need to update the development management policies at the same time so the Plan can be read as a whole. It is difficult to see whether the historic environment will be adequately covered without seeing the updated Development Management Policies.

c) Key principles for development of City sites
Whilst we broadly welcome the principle of redevelopment of many brown field sites, it is clearly important that such development does not cause harm to the historic environment of City. To that end we suggest a number of key principles for development which could be incorporated into policy 7.1, section 5 namely:
·Development should be of a scale and massing in keeping with the surrounding area;
·Development should respect and reinterpret the historic grain, street layouts,burgage plots and morphology of the City;
·Development should avoid breaking the skyline or competing with historic landmark buildings across the City;
·Development should use materials in keeping with the historic fabric of the City.

d)Strategy for tall(er) buildings in Norwich
In addition to these key principles, we also consider that it would be helpful to undertake a tall buildings study to provide the evidence base and contribute towards the development of an appropriate tall(er) buildings policy for the Plan.This might also consider the question of massing. We would welcome the opportunity to discuss the development of a policy approach to taller buildings in more detail with you. By developing a strategy for height and mass, this will help to secure sustainable development of high quality that protects and enhances the historic environment, character and significance of the City.

e)Indicative Site Capacity
We are concerned that some of the indicative capacities for site allocations may not be realistic. To that end we consider that it would be useful for you to prepare an evidence base document outlining the site capacities and the assumptions that have been made in reaching these figures, particularly for the sites in the City. This will provide a means of demonstrating whether the indicative site capacities are justified, realistic and achievable in terms of their impact upon the historic environment (and other factors). Our concerns are set out in more detail in Appendix A and B.

f)Impact on historic environment for some site allocations
We are concerned that there is currently insufficient evidence in relation to the historic environment in terms of site allocations. Paragraph 31 and 187 of the NPPF requires a proportionate evidence base for Plans. To that end, we suggest that you review the site assessments to ensure that there is sufficient and robust in its consideration of the historic environment. We suggest that a brief Heritage Impact Assessment (HIA) is undertaken for ALL sites in the Plan following the 5 step methodology, with more detailed HIA being undertaken for selected sites where the heritage issues are greater. We suggest more detailed HIA for the following sites GNLP0409R, GNLP3053GNLP3054, GNLP0125, GNLP2143, GNLP379, GNLP0229, GNLP2019 and GNLP0133B and D. This is not an exhaustive list and it may be that in preparing the brief HIAs you identify other sites which also warrant a fuller assessment. We would remind you that paragraph 32 of the NPPF makes it clear that significant adverse impacts should be avoided wherever possible and alternative options pursued. Only where these impacts are unavoidable should suitable mitigation measures be proposed. Further detail is given in the attached table.

g)Policy wording for some site allocations
As currently drafted there is either a lack of criteria or insufficient detail within the site specific policies for the conservation and enhancement of the historic environment. The NPPF (para 16d) makes it clear that Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals. Further advice on the content of policies is given in the PPG at paragraph Paragraph: 027 Reference ID: 61-027-20180913 Revision date: 13 09 2018 that states, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development’. The policies should be re-worded to include criteria for the protection and enhancement of the historic environment. This will provide greater protection for the historic environment and ensure clear and robust policies are in place that provide the decision maker and developers with a clear indication of expectations for the sites. Further details of our suggestions in this regard for each of the sites and a comment on site allocations in general are given in the attached table B.

Support

Representation ID: 22532

Received: 16/03/2020

Respondent: Historic England

Para 176: We welcome this paragraph including brief mention of heritage at risk.

Object

Representation ID: 22533

Received: 16/03/2020

Respondent: Historic England

Para 177-179: We would like to see more here about the distinctive, unique heritage of the area – what makes this special and different from elsewhere? Think about building materials, building styles, local vernacular, settlement form and pattern and so on and try to describe that here. We need to know what we have that we need to protect and enhance.

Suggested change: Add more description about what is distinctive/unique etc. about the historic environment of the area.

Para 179 and 180: Replace historic assets with heritage assets for the reasons set out above

Para 182: Make the point that harm should be avoided in the first instance.
Be careful when talking about weighing against public benefits – there are different tests depending upon the grade of asset and the degree of harm. Suggest making reference here to the NPPF.
Suggested Change: State that harm should be avoided in the first instance.
Add the following to the end of the last sentence …in accordance with the various tests set out in the NPPF.

Natural Environment:
Make the link between green infrastructure and the natural environment. Landscape parks and open space often have heritage interest, and it would be helpful to highlight this. It is important not to consider ‘multi-functional’ spaces only in terms of the natural environment, health and recreation. It may be helpful to make reference in the text to the role GI can have to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history. Opportunities can be taken to link GI networks into already existing green spaces in town or existing historic spaces such as church yards to improve the setting of historic buildings or historic townscape. Maintenance of GI networks and spaces should also be considered so that they continue to serve as high quality places which remain beneficial in the long term.
Suggested Change: Add text to make the link between green infrastructure and the natural environment.

Policy 3:
We suggest adding the words, ‘in accordance with the requirements of the NPPF either after historic environment of after historic asset.
Again change historic asset to heritage asset, the preferred term.
Suggest separate policy for Natural Environment

Support

Representation ID: 22908

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The UEA are supportive of the strategy to ensure that development proposals conserve and enhance the built, historic and natural environment.

As outlined within the Representations for GNLP0133-B, GNLP0133-C, GNLP0133-D, and GNLP0133-E, Historic England consulted on the potential designation of the landscape surrounding the UEA as Historic Parkland (Case: 1466188). Notwithstanding this, regardless of whether the landscape is designated as Historic Parkland, development on each site will be designed in a manner to respect the visual setting of the UEA, whilst facilitating the growth
and expansion of the UEA.

Support

Representation ID: 22939

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The UEA are supportive of the strategy to ensure that development proposals conserve and enhance the built, historic and natural environment.
As outlined within the Representations for GNLP0133-B, GNLP0133-C, GNLP0133-D, and GNLP0133-E, Historic England consulted on the potential designation of the landscape surrounding the UEA as Historic Parkland (Case: 1466188). Notwithstanding this, regardless of whether the landscape is designated as Historic Parkland, development on each site will be designed in a manner to respect the visual setting of the UEA, whilst facilitating the growth and expansion of the UEA.

Support

Representation ID: 22959

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The UEA are supportive of the strategy to ensure that development proposals conserve and enhance the built, historic and natural environment.
As outlined within the Representations for GNLP0133-B, GNLP0133-C, GNLP0133-D, and GNLP0133-E, Historic England consulted on the potential designation of the landscape surrounding the UEA as Historic Parkland (Case: 1466188). Notwithstanding this, regardless of whether the landscape is designated as Historic Parkland, development on each site will be designed in a manner to respect the visual setting of the UEA, whilst facilitating the growth and expansion of the UEA.

Support

Representation ID: 22994

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
The UEA are supportive of the strategy to ensure that development proposals conserve and enhance the built, historic and natural environment.
As outlined within the Representations for GNLP0133-B, GNLP0133-C, GNLP0133-D, and GNLP0133-E, Historic England consulted on the potential designation of the landscape surrounding the UEA as Historic Parkland (Case: 1466188). Notwithstanding this, regardless of whether the landscape is designated as Historic Parkland, development on each site will be designed in a manner to respect the visual setting of the UEA, whilst facilitating the growth and expansion of the UEA.

Support

Representation ID: 23033

Received: 16/03/2020

Respondent: Hingham Town Council

Hingham Town Council support the policy of environmental protection and enhancement. A community should have total confidence that if forced to accept more development , that the development would be an asset to and enhance the environment.

Object

Representation ID: 23034

Received: 16/03/2020

Respondent: Hingham Town Council

Preferred option site for housing development GNLP0520 is contrary to this policy. It has been commented upon that the recent Hops development adjacent to GNLP0520 (built by the same developer ) has “ruined” the approach to Hingham and is an “eyesore”. Communities should not be subject to development that instils such vehement dislike and opposition.

Policy 3 states “ The development strategy of the plan and the sites proposed for development reflect the area's settlement structure of the city, towns and villages, retaining the separate identities of individual settlements.
Development proposals will be required to conserve and enhance the built and historic environment through:
being designed to create a distinct sense of place and enhance local character taking account of local design guidance and providing measures such as heritage interpretation to further the understanding of local heritage issues;”
With the allocation of GNLP0520 as a preferred site to be built by the same developer as the Hops, residents fear being left with a large area of development (covering both the Hops and GNLP0520) that will not be in keeping with the historic environment of the very nearby areas of Hingham. Having one development of a distinctive style already been built, it does not mean that it is right for the settlement to be further developed by adding more of the same. In particular if its style and design is likely to be opposed and resented by residents of the town.

Support

Representation ID: 23139

Received: 16/03/2020

Respondent: Hopkins Homes

Agent: Bidwells

Support. No additional comments suggested.