Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22537

Received: 16/03/2020

Respondent: Historic England

It is important that your plan is underpinned by appropriate evidence. We would recommend that the following evidence for the historic environment is used in the preparation of your Local Plan.
Any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base. Sources include:
 National Heritage List for England. www.historicengland.org.uk/the-list/
 Heritage Gateway. www.heritagegateway.org.uk
 Historic Environment Record.
 National and local heritage at risk registers. www.historicengland.org.uk/advice/heritage-at-risk
 Non-designated or locally listed heritage assets (buildings, monuments, parks and gardens, areas)
 Conservation area appraisals and management plans
 Historic characterisation assessments e.g. the Extensive Urban Surveys and Historic Landscape Characterisation Programme or more local documents. www.archaeologydataservice.ac.uk/archives/view/EUS/
 Environmental capacity studies for historic towns and cities or for historic areas e.g. the Craven Conservation Areas Assessment Project. www.cravendc.gov.uk/CHttpHandler.ashx?id=11207&p=0
 Detailed historic characterization work assessing impact of specific proposals.
 Heritage Impact Assessments looking into significance and setting especially for strategic sites or sites with specific heritage impacts
 Visual impact assessments.
 Archaeological assessments.
 Topic papers.

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.
We advise you to carefully consider the list above.
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.
It is also useful to include in this a brief heritage assessment of each site allocation, identifying any heritage issues, what you have done to address them and how this translates into the wording in your policy for that site allocation policy.

Support

Representation ID: 22538

Received: 16/03/2020

Respondent: Historic England

Para 271: This section recognises the unrivalled historic environment of the historic city centre which is welcomed.

Para 273: We welcome the reference to the need to make the best use of its distinctive assets.

Object

Representation ID: 22539

Received: 16/03/2020

Respondent: Historic England

Para 274: Bullet point 2 should be amended to read conserving and enhancing the historic and natural environment to more closely reflect the NPPF

Object

Representation ID: 22540

Received: 16/03/2020

Respondent: Historic England

The Northern City Centre
Historic England recognise that this area contains a number of key brownfield sites and understand the importance of regeneration in the area for the city as a whole.
The allocation proposes the redevelopment of Anglia Square at a density similar to that proposed in the planning application currently before the Secretary of State. We consider that any development of the scale envisaged would cause a high degree of harm to the character and appearance of the City Centre conservation area, as well as harm of varying degrees to many designated heritage assets, including some of the city’s most important.
Evidence prepared by Historic England for the Inquiry suggested that 600 dwellings, rather than 1200 would be a more appropriate scale. Historic England has also expressed fundamental concern regarding the proposed landmark building and in particular its height. The Norwich skyline is important to the character of the town as a whole and in particular the City Centre Conservation Area. For a number of years we have stated that development should not break the skyline in the City.
There are clearly differences of opinion in relation to this site in particular but a number of key principles can be drawn from this case and applied to other redevelopment sites in the City.
They are as follows:
 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.
It will be necessary to review the policy in the light of the Inspectors findings in relation to Anglia Square.

Suggested Change:
Include key principles for development within the Plan.
Review policy in light of Inspectors findings.

Object

Representation ID: 22541

Received: 16/03/2020

Respondent: Historic England

We recognise the opportunities provided in East Norwich for brownfield regeneration.
One of our key concerns in this area relates to Carrow Works (Abbey/Priory). We have set out in more detail our concerns in Appendix B in relation to this site but in summary, we question the capacity of the site and suggest that a more detailed Heritage Impact Assessment be undertaken before the next draft of the Plan to inform the suitability or otherwise of the site, the likely impact of development upon the significance of heritage assets, the extent of the developable area and hence capacity of the site, any necessary mitigation or enhancements that could be made and then any changes required to policy wording.

Suggested Change: Undertake detailed HIA for Carrow Works site.

Object

Representation ID: 22542

Received: 16/03/2020

Respondent: Historic England

Policy 7.1 Housing figures
Historic England has some concerns regarding the housing figures.
In particular the figures provided in the table for housing include those for both Anglia Square (awaiting the Inspector’s decision) but it is Historic England’s view that the capacity of that site is closer to 600 than 1200 dwellings) and the Carrow Works (where we have suggested caution regarding the capacity of the site and have requested that a more detailed HIA be undertaken to more carefully consider the likely impact of development upon heritage assets and thus the likely capacity of the site).
Whilst we consider that it will be possible to achieve high densities on brown field sites compared with the densities of many parts of the city, it would not be appropriate to seek the densities associated with very tall buildings in metropolitan areas.
We appreciate the emphasis in national policy on high density development in sustainable locations but highlight paragraph 11b and footnote 6 of the NPPF which states that there may be circumstances where the application of policies in the framework that protect areas or assets of particular importance (including designated heritage assets) provides a strong reason for restricting the overall scale, type or distribution of development in the plan area.
Historic England consider that Norwich’s historic character is under pressure from recent developments permitted without or against our advice (Pablo Fanque House, new student accommodation below St. Giles) and by proposals such as those for Anglia Square.
We are concerned at some of the indicative site capacity figures given in the site allocations (and contributing to this table).
One of the first questions any Inspector will ask at EiP concerns the capacity of the sites to accommodate the level of development indicated in the Plan.
To that end we consider that it is essential evidence base document is prepared outlining the site capacities and the assumptions that have been made in reaching these figures, particularly for the sites in the City. The evidence should set out the indicative site capacity, site area, density (as dwellings per hectare dph), assumed maximum height, surrounding heights of development, other on site and off site capacity considerations (e.g. heritage, natural environment etc.). This will provide a helpful starting point for us to be able to consider whether the indicative site capacities are justified, realistic and achievable in terms of their impact upon the historic environment (and other factors).
We refer you to our publication, ‘Increasing residential density in historic environments’ which can be found here. This study explores the factors that can contribute to successfully delivering developments which increase residential density in historic environments. It uses a combination of literature review and case studies to provide a series of recommendations to support decision making. In addition we commend the work by Ash Sakula in relation to Anglia Square and the demonstration of how that particular site could be developed at high density whilst respecting the historic environment.

Suggested Change: Amend housing figures if necessary following the Inspectors decision on Anglia Square and upon completion of an HIA for Carrow Works.
Prepare an evidence base document to consider indicative site capacities of allocations.

Support

Representation ID: 22543

Received: 16/03/2020

Respondent: Historic England

Historic England broadly supports redevelopment of brownfield sites both in the City Centre, (including the northern city centre), east Norwich and the wider urban area. However, all such development should conserve and enhance the historic environment and be of an appropriate scale and massing, reflecting the grain and historic street patterns of the City.

Object

Representation ID: 22544

Received: 16/03/2020

Respondent: Historic England

"5. The Natural and Built Environment"
We suggest that this section should also refer to the historic environment in the title to read, The built, natural and historic environment.
We suggest that the first word of the first sentence should be To rather than The.
We broadly welcome bullet points one and two.
We suggest the addition of the following bullet points as key principles of development:
 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.
We have concerns regarding bullet point 3 which encourages landmark buildings at the gateways to the city centre. While landmark buildings are not necessarily an issue per se, invariably such buildings are often tall and out of scale with the surrounding area. The particular skyline and historic setting of the city of Norwich as a whole means that the area is particularly sensitive to such development. Any such development must be of an appropriate scale and not harm the significance of heritage assets including for example the City Centre Conservation Area through development within its setting. To that end we recommend the deletion of bullet point 3.

Object

Representation ID: 22545

Received: 16/03/2020

Respondent: Historic England

P101 Bullet point 4
We welcome bullet point 4 in relation to heritage assets. We suggest the use of the word including before Carrow as there are other heritage assets besides those listed.

Object

Representation ID: 22546

Received: 16/03/2020

Respondent: Historic England

Policy 7.2: We recommend including something on the individual characters of the main settlements in this section.