Draft Greater Norwich Local Plan – Part 1 The Strategy

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: 22527

Received: 16/03/2020

Respondent: Historic England

Welcome the reference to heritage and the historic environment.

Object

Representation ID: 22528

Received: 16/03/2020

Respondent: Historic England

We note that you are not proposing to update the Development Management policies at the present time. This approach is of concern to us. It would be helpful if the Plan could be read as a consistent whole, both for decision makers, developers and the public.

Paragraph 20 of the draft GNLP states that development management policies will not be amended except in very specific circumstances.

It is unclear what the statutory relationship between these documents will be. If the GNLP contains strategic level policies it is not clear how existing development management policies will be able to deliver these strategic objectives and vision given that the development management policies already exist. This raises fundamental question regarding the ability of the overall plan to provide a sound, evidence based positive strategy for the conservation and enhancement of the historic environment given that the strategic part of the plan will be retrospectively formulated in isolation of the development management parts of the plan. The approach taken means that there will be a period where the development management policies will not synchronise with the new strategic policies. There is concern that this fundamentally undermines a truly integrated plan-led approach to long term development.

We are concerned that the approach taken will result in any plan being unsound as it will in effect be incomplete and the component parts will not reflect each other. It is for these reasons that even in the event the GNLP is sound itself; it is very unlikely that we will be able to confirm that the entire plan is sound. At this stage we must again advise that the development management policies are reviewed to ensure that they align and can deliver the strategic policies of the GNLP.

Suggested Change: Please update Development Management policies too.

Object

Representation ID: 22529

Received: 16/03/2020

Respondent: Historic England

Comment & Suggested Change:
Paras 93-96: We suggest a little more descriptive detail about the heritage in the Local Plan area. What is unique and distinctive about this place? What needs to be protected, conserved and enhanced? What heritage is at risk? What about historic landscape characterisation?

Para 93: We suggest changing historic assets to heritage assets, in accordance with the terminology used in the NPPF.

Para 95: We suggest you use the term Registered Parks and Gardens.

Para 96: We suggest you use the term scheduled monuments rather than ancient monuments, in line with the NPPF. Modern convention is to refer to scheduled monuments rather than scheduled ancient monuments, given that a wide range and age of monuments are scheduled.

Table 3: As above – use the terms Scheduled Monuments and Registered Parks and Gardens.

Object

Representation ID: 22530

Received: 16/03/2020

Respondent: Historic England

Para 110: Change historic assets to historic environment. The historic environment is considered the most appropriate term to use as a topic heading as it encompasses all aspects of heritage, for example the tangible heritage assets and less tangible cultural heritage.

Environment: It would be helpful to separate out the natural and historic environment here?

Para 132: We welcome the reference to distinctive local characteristics of our city, towns and villages. However, also need to refer to landscape. Again would be helpful if you can describe in more detail what is unique and special about your area in terms of heritage.

Objectives: We broadly welcome the objective for the environment. Again it might be helpful to either separate out into Natural and historic environment or at least change the title to include specific reference to built, historic and natural environment.

Object

Representation ID: 22531

Received: 16/03/2020

Respondent: Historic England

There is no mention of the historic environment in this policy on sustainable communities. Paragraph 8 of the NPPF makes it clear that achieving sustainable development means that the planning system has three overarching objectives, the third of which is an environmental objective to contribute to protecting and enhancing our natural built and historic environment. To that end we would expect to see reference to the historic environment in the policy on page 61 and also in the key issues addressed by the policy as set out in Table 2.

Suggested change: Include reference to the historic environment in the policy as required by para 8 of the NPPF.

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

Object

Representation ID: 22535

Received: 16/03/2020

Respondent: Historic England

Omission – Heritage at Risk:
Add a policy and paragraph on heritage at risk. There are a high number of assets on the Heritage at Risk Register in this Local Plan Area. Summarise the type of assets at risk. State what you are planning to do to address this.

Omission – Historic Landscape Characterisation:
We suggest adding reference (policy and text) to Historic Landscape Characterisation and Landscape Character Assessments. Landscape character assessments, particularly those accommodating major developments, can be deficient in assessing the landscape value relating to scheduled monuments and their settings. The historic environment has an important role to play in understanding the landscape. Many tracks, green lanes, field boundaries and settlement patterns are remnants of past use and provide evidence of how the landscape has evolved over time. The objective of protecting and enhancing the landscape and recognition of its links to cultural heritage can help improve how the historic environment is experienced an enjoyed.

Object

Representation ID: 22536

Received: 16/03/2020

Respondent: Historic England

It is difficult to see whether the historic environment will be adequately covered without seeing the updated Development Management Policies. We would expect such policies to 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. This 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.

Suggested change: Update Development Management policies to create a complete Plan.