Draft Local Plan-Part 2 Site Allocations

Comment

Representation ID: 22550

Received: 16/03/2020

Respondent: Historic England

General comment: We suggest that the bullet points in the site allocations are numbers to make it easier to reference policy and use the Plan

Object

Representation ID: 22551

Received: 16/03/2020

Respondent: Historic England

General comment on site assessment booklets for site allocations:
Whilst we have not had the capacity to review every site assessment in the Site Assessments booklet, we have looked at a number of the assessments.
We are concerned that there is currently insufficient evidence in relation to the historic environment in terms of site allocations. 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 refer you to our advice on the Historic Environment and Local Plans and Sites Allocations which is set out in the following documents:
HE Good Practice Advice in Planning 1 – the historic environment in local plans: https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/
HE Advice Note 3 – site allocations in local plans: https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/
Our advice note 3 on site allocations in local plans sets out a suggested approach to assessing sites and their impact on heritage assets (a Heritage Impact Assessment or HIA). It advocates 5 steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This should be applied to the assessment and selecting of sites within a plan.
In essence, it is important that you
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs tests of soundness
In assessing sites it is important to identify those sites which are inappropriate for development and also to assess the potential capacity of the site in the light of any historic environment (and other) factors. This should be more than a distance based criteria but rather a more holistic process which seeks to understand their significance and value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate.
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. It is important that the evidence base is proportionate and so the level of detail will vary depending on the site – its size and the number and significance of heritage assets affected. We have identified a number of sites in this table and the covering letter where a more detailed assessment would be required. 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.
The findings of the assessments should then be incorporated into the relevant site allocations policies (e.g. site capacity, potential mitigation and enhancements etc.)
The assessments could be included either in the Site Assessments or into the Historic Environment Topic Paper. Either way, it is important that they form part of the evidence base for the Local Plan.

Object

Representation ID: 22552

Received: 16/03/2020

Respondent: Historic England

General Comment on site allocations policy wording:
It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal.
Development should conserve or where appropriate enhance the significance of heritage assets including [list heritage assets on site and nearby] including any contribution made to their significance by their settings. Appropriate mitigation measure including … will be required.’
As previously advised the policy wording should mention the specific designated heritage assets both on site and nearby.
The policy and supporting text should also refer to specific appropriate mitigation measures e.g. landscaping or careful design or maintaining key views or buffer/set back/breathing space etc.
Therefore, please revisit the site allocations and ensure that policy wording/supporting text is consistent with the advice above.
By making these changes to policy wording the Plan will have greater clarity, provide greater protection to the historic environment and the policies will be more robust.
Given the inclusion of reference to significance and setting we suggest that these terms (which are quite technical) are included in a glossary.

Object

Representation ID: 22553

Received: 16/03/2020

Respondent: Historic England

This site is located within the Norwich City Centre Conservation Area. There are a number of listed buildings in the vicinity of the site including Blackfriars Bridge and 52 Colgate, both listed at grade II. Redevelopment of the site therefore has the potential to affect these heritage assets and their settings.
Historic England is broadly supportive of the principle of redevelopment of this site.
We welcome the commitment in the policy to an appropriate scale and form of development in bullet point 2.
However, there is no mention of the Conservation Area in the policy or supporting text and whilst bullet point 3 mentions the need to conserve and enhance adjoining heritage assets, the Conservation Area is not adjoining (the site lies within it) and other assets are not adjoining but nearby. Therefore, we suggest amending the policy wording to read Conserve and enhance the significance of the City Centre Conservation Area and nearby listed buildings (including any contribution made to their significance by setting).
We welcome the commitment to riverside access for walking and cycling in bullet point 5.
We note a desire to increase density at the site but emphasise that it is important that this must not cause a greater degree of harm on the historic environment.

Suggested Change:
Amend the policy wording to read Conserve and enhance the significance of the City Centre Conservation Area and nearby listed buildings (including any contribution made to their significance by setting).

Object

Representation ID: 22554

Received: 16/03/2020

Respondent: Historic England

Earlham Hall is listed at Grade II* with the garden walls and dovecote listed at grade II. The whole site lies within the Earlham Conservation Area. Any development of this site has the potential to impact upon the heritage assets and their settings.
We suggest that a more detailed HIA be prepared for the campus as a whole.
We note bullet point 2 relating to the need to protect and enhance the significance of heritage assets including Earlham Hall and Earlham Conservation Area. It would be helpful to state that Earlham Hall is listed at Grade II* and that there are other grade II listed buildings/structures.

Suggested Change:
Reword bullet point 2 to read Development should protect and enhance the significance of the grade II* Earlham Hall and associated Grade II listed buildings and the Earlham Conservation Area (including any contribution made to that significance by stetting), through careful design, massing and appropriate open space and landscaping.

Object

Representation ID: 22556

Received: 16/03/2020

Respondent: Historic England

There are no designated heritage assets within the site boundary but the Earlham Park Conservation lies to the north of the site and the campus includes a number of listed buildings including the grade II* Sainsbury Centre and Norfolk and Suffolk Terraces, together with a number of other grade II listed buildings. Any development of this site therefore has the potential to impact upon the settings of these designated heritage assets.
We suggest that a more detailed HIA be prepared for the campus as a whole.
We welcome bullet point 2 regarding the heritage significance and setting of buildings within the campus and also the sensitive location adjacent to the University Broad. Careful design will be needed of any development to ensure the protection and enhancement of nearby heritage assets.

Suggested Change:
Amend policy wording in accordance with the advice above.
Prepare a more detailed HIA for the campus as a whole.

Comment

Representation ID: 22557

Received: 16/03/2020

Respondent: Historic England

Welcome bullet point 1 in relation to heritage assets.

Support

Representation ID: 22558

Received: 16/03/2020

Respondent: Historic England

Welcome bullet point 1 and reference to locally listed building.

Object

Representation ID: 22559

Received: 16/03/2020

Respondent: Historic England

This large cross boundary site for 680 dwellings includes a grade II listed bottle kiln and the southern portion of the site lies within the Trowse Millgate Conservation Area. Any redevelopment of this site has the potential to affect these designated heritage assets and their settings.
Historic England is broadly supportive of the principle of redevelopment of this site.
There is currently no reference to these designated heritages assets within the policy or supporting text. To that end, we recommend that reference is made both in the policy and the supporting text to the need to Conserve and where appropriate enhance significance of the grade II listed bottle Kiln and Trowse Millgate Conservation Area (including any contribution made to that significance by setting).
While there maybe no designated heritage assets in northern most part of the site, any tall structures have the potential to impact on longer views (especially from higher ground) in towards the historic city core (including the castle and cathedral). Although there are no designated heritage assets along this stretch of river bank, this part of the site has a significant potential for archaeology. This should be referenced in the policy

Suggested Change:
Amend policy and supporting text to reference the designated heritage assets and the need to Conserve and where appropriate enhance significance of the grade II listed bottle Kiln and Towse Millgate Conservation Area (including any contribution made to that significance by setting).

Object

Representation ID: 22560

Received: 16/03/2020

Respondent: Historic England

This site is located within the Norwich City Centre Conservation Area. There are a number of listed buildings in the vicinity of the site including St Gregory Church and Strangers Hall Museum, both listed at grade I, 2 Charing Cross listed a grade II* as well as numerous buildings and structures listed at grade II. Redevelopment of the site therefore has the potential to affect these heritage assets and their settings.
This site benefits from Planning permission and so the principle of development has already been established on this site. Historic England is broadly supportive of the principle of redevelopment of this site and has provided advice over many years in relation to this site.
We welcome the commitment in the policy to an appropriate scale and form of development in bullet point 1
We welcome the reference to the conservation area in bullet point 1 but suggest that a separate bullet point is included in relation to the historic environment in relation to the need to Conserve and enhance the significance of heritage assets (including any contribution made to their significance by setting) including the City Centre Conservation Area, Grade I listed St Gregory’s Church and Strangers Hall Museum, grade II* listed Charing Cross and other buildings listed at grade II.
We welcome the commitment to riverside access for walk in bullet point 4.
We note a desire to increase density at t eh site but emphasise that it is important that this must not cause a greater degree of harm on the historic environment.

Suggested Change:
Suggest that a separate bullet point is included in relation to the historic environment in relation to the need to Conserve and enhance the significance of heritage assets (including any contribution made to their significance by setting) including the City Centre Conservation Area, Grade I listed St Gregory’s Church and Strangers Hall Museum, grade II* listed Charing Cross and other buildings listed at grade II.