Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

SUMMARY
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
1. Recommended changes to policy wording
We are pleased to see the site assessments and sustainability appraisal for the
allocations. Although these are not full heritage impact assessments, these
assessments do make some helpful recommendations for the sites.
However, these recommendations are not always reflected in the policy.
As currently drafted, there is sometimes 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 development proposals. Further advice on the content of
policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315
Revision date: 15 03 2019. It states that, ‘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’.
We have therefore suggested a number of relatively minor changes to the policies to
incorporate these recommendations and address some of our concerns.
2. Heritage Impact Assessment of Bawburgh Site
The Bawburgh Site is perhaps most sensitive in heritage terms. There are several
designated heritage assets nearby including the Conservation Area, listed buildings
and scheduled monuments. Indeed, the Site Assessment states that a Heritage
Impact Assessment (HIA) may be required. We concur with this.
Paragraph 31 and 192 of the NPPF requires a proportionate evidence base for Plans
and we consider that an HIA for this site would help to ensure a robust evidence
base for the Local Plan.
Therefore, we recommend that a proportionate Heritage Impact Assessment is
undertaken now to inform the suitability of the site per se, assess the impact, identify
any mitigation and enhancement required and inform any changes to policy wording.
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.
Where a potential impact is identified, wording should be included in the policy and
supporting text to this effect. We suggest the inclusion of additional bullet point in the
site allocation. Ideally, the bullet point should mention the specific asset(s), the policy
requirement (see wording in appendix) and any potential mitigation required.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes
suggested do not go to the heart of the Plan’s soundness, but instead are intended to
improve upon it. We believe that these comments can be addressed by changes to
wording in the plan.
In preparation of the local plan, we encourage you to draw on the knowledge of local
conservation officers, the county archaeologist and local heritage groups.
Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU
Telephone 01223 58 2749 HistoricEngland.org.uk
Please note that Historic England operates an access to information policy.
Correspondence or information which you send us may therefore become publicly available.
Please note that absence of a comment on a policy, allocation or document in this
letter does not mean that Historic England is content that the policy, allocation or
document is devoid of historic environment issues. We should like to stress that this
response is based on the information provided by the Council in its consultation. To
avoid any doubt, this does not affect our obligation to provide further advice and,
potentially, object to specific proposals, which may subsequently arise as a result of
this plan, where we consider that these would have an adverse effect upon the
historic environment.


GNLP5004
Land off Buxton Road, Eastgate, Cawston
The policy states that an archaeological assessment will be required prior to development which is broadly welcomed. The SA recommends that the policy should make it clear whether these should be desk based of field studies. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA also recommends that the landscaping should be species appropriate to the local area.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Amend policy to state that ‘landscaping should be species appropriate to the local area.’

GNLP5005
Strayground Lane, Wymondham Recycling Centre
No comments

GNLP5009 Hockering Lane, Bawburgh

Whilst there are no designated heritage assets within the site, the Bawburgh Conservation Area lies to the west of the site but is separated by a block of development. There are listed buildings and scheduled monuments to the north west of the site across the valley. The development has the potential to impact the significance of these heritage assets via a change in their settings.
The Site assessment suggests the preparation of a Heritage Impact Assessment. The Sustainability Appraisal identifies negative impact.
Given this is one of the more sensitive sites in heritage terms, an HIA should be prepared now to inform the suitability of the site per se and the policy wording.
The policy states that an archaeological assessment will be required prior to development. As with the Cawston site it would helpful for the policy to state if the assessment should be desk based or field based. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA recommends that the policy should protect or where possible enhance the trees and hedgerow surrounding the site, which would be likely to help conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened. This should be included in the policy.
We recommend an HIA is prepared now prior to inform the suitability of the site and policy wording.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Add criterion to read ‘Protect and enhance the trees and hedgerows surrounding the site to conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened’.

GNLP5014
A47 North Burlingham Junction
We welcome bullet point 3 in relation to landscaping to protect views of non-designated heritage assets nearby.

GNLP5019 Woodland Stable, Shortthorn Road, Stratton Strawless
No comments

GNLP5020 Romany Meadow, The Turnpike, Carleton Rode
Whilst there are no designated heritage assets within the site, there are several grade II listed buildings nearby including The Ashes to the east and a cluster of grade II properties to the northwest. However, the site is quite well contained and intervening landscaping should limit the impact on the historic environment.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5021 The Old Produce Shop, Holt Road, Horsford
No comments

GNLP5022 The Oaks, Foulsham
This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5023 Strayground Lane, Wymondham
The SA states that the policy could be further improved by detailed requirements to consider landscaping measures to reduce potential for adverse effects on the surrounding landscape character
Add policy criterion to read
‘Landscaping measures to reduce potential for adverse effects on the surrounding landscape character’

GNLP5024 Upgate Street, Carleton Rode
Whilst there are no designated heritage assets within the site, there are two grade II listed buildings to the north of the site and the New Buckenham Conservation Area to the west of the site. The site assessment states that Bunns Bank Linear Earthwork, which elsewhere in its course is scheduled, is adjacent to the site and should be taken into consideration. This requirement should be included in the policy wording of the Plan. We suggest an additional bullet point to the policy criteria.
However, overall the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage would be minimal.
Amend policy wording to add bullet point to read:
‘Protect the adjacent Bunns Bank Linear Earthwork.‘

Reasonable Alternative Site Policy GNLP5013 Ketteringham Depot land west of Station Lane, Ketteringham
Whilst there are no designated heritage assets within the site boundary, there are two round barrows (scheduled monuments) to the south of the site and several grade II listed buildings nearby. However, these are all over 500 metres from the site. Given the distance and intervening vegetation, we consider there would be little impact on designated heritage.

SUMMARY
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
1. Recommended changes to policy wording
We are pleased to see the site assessments and sustainability appraisal for the
allocations. Although these are not full heritage impact assessments, these
assessments do make some helpful recommendations for the sites.
However, these recommendations are not always reflected in the policy.
As currently drafted, there is sometimes 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 development proposals. Further advice on the content of
policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315
Revision date: 15 03 2019. It states that, ‘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’.
We have therefore suggested a number of relatively minor changes to the policies to
incorporate these recommendations and address some of our concerns.
2. Heritage Impact Assessment of Bawburgh Site
The Bawburgh Site is perhaps most sensitive in heritage terms. There are several
designated heritage assets nearby including the Conservation Area, listed buildings
and scheduled monuments. Indeed, the Site Assessment states that a Heritage
Impact Assessment (HIA) may be required. We concur with this.
Paragraph 31 and 192 of the NPPF requires a proportionate evidence base for Plans
and we consider that an HIA for this site would help to ensure a robust evidence
base for the Local Plan.
Therefore, we recommend that a proportionate Heritage Impact Assessment is
undertaken now to inform the suitability of the site per se, assess the impact, identify
any mitigation and enhancement required and inform any changes to policy wording.
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.
Where a potential impact is identified, wording should be included in the policy and
supporting text to this effect. We suggest the inclusion of additional bullet point in the
site allocation. Ideally, the bullet point should mention the specific asset(s), the policy
requirement (see wording in appendix) and any potential mitigation required.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes
suggested do not go to the heart of the Plan’s soundness, but instead are intended to
improve upon it. We believe that these comments can be addressed by changes to
wording in the plan.
In preparation of the local plan, we encourage you to draw on the knowledge of local
conservation officers, the county archaeologist and local heritage groups.
Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU
Telephone 01223 58 2749 HistoricEngland.org.uk
Please note that Historic England operates an access to information policy.
Correspondence or information which you send us may therefore become publicly available.
Please note that absence of a comment on a policy, allocation or document in this
letter does not mean that Historic England is content that the policy, allocation or
document is devoid of historic environment issues. We should like to stress that this
response is based on the information provided by the Council in its consultation. To
avoid any doubt, this does not affect our obligation to provide further advice and,
potentially, object to specific proposals, which may subsequently arise as a result of
this plan, where we consider that these would have an adverse effect upon the
historic environment.


GNLP5004
Land off Buxton Road, Eastgate, Cawston
The policy states that an archaeological assessment will be required prior to development which is broadly welcomed. The SA recommends that the policy should make it clear whether these should be desk based of field studies. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA also recommends that the landscaping should be species appropriate to the local area.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Amend policy to state that ‘landscaping should be species appropriate to the local area.’

GNLP5005
Strayground Lane, Wymondham Recycling Centre
No comments

GNLP5009 Hockering Lane, Bawburgh

Whilst there are no designated heritage assets within the site, the Bawburgh Conservation Area lies to the west of the site but is separated by a block of development. There are listed buildings and scheduled monuments to the north west of the site across the valley. The development has the potential to impact the significance of these heritage assets via a change in their settings.
The Site assessment suggests the preparation of a Heritage Impact Assessment. The Sustainability Appraisal identifies negative impact.
Given this is one of the more sensitive sites in heritage terms, an HIA should be prepared now to inform the suitability of the site per se and the policy wording.
The policy states that an archaeological assessment will be required prior to development. As with the Cawston site it would helpful for the policy to state if the assessment should be desk based or field based. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA recommends that the policy should protect or where possible enhance the trees and hedgerow surrounding the site, which would be likely to help conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened. This should be included in the policy.
We recommend an HIA is prepared now prior to inform the suitability of the site and policy wording.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Add criterion to read ‘Protect and enhance the trees and hedgerows surrounding the site to conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened’.

GNLP5014
A47 North Burlingham Junction
We welcome bullet point 3 in relation to landscaping to protect views of non-designated heritage assets nearby.

GNLP5019 Woodland Stable, Shortthorn Road, Stratton Strawless
No comments

GNLP5020 Romany Meadow, The Turnpike, Carleton Rode
Whilst there are no designated heritage assets within the site, there are several grade II listed buildings nearby including The Ashes to the east and a cluster of grade II properties to the northwest. However, the site is quite well contained and intervening landscaping should limit the impact on the historic environment.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5021 The Old Produce Shop, Holt Road, Horsford
No comments

GNLP5022 The Oaks, Foulsham
This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5023 Strayground Lane, Wymondham
The SA states that the policy could be further improved by detailed requirements to consider landscaping measures to reduce potential for adverse effects on the surrounding landscape character
Add policy criterion to read
‘Landscaping measures to reduce potential for adverse effects on the surrounding landscape character’

GNLP5024 Upgate Street, Carleton Rode
Whilst there are no designated heritage assets within the site, there are two grade II listed buildings to the north of the site and the New Buckenham Conservation Area to the west of the site. The site assessment states that Bunns Bank Linear Earthwork, which elsewhere in its course is scheduled, is adjacent to the site and should be taken into consideration. This requirement should be included in the policy wording of the Plan. We suggest an additional bullet point to the policy criteria.
However, overall the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage would be minimal.
Amend policy wording to add bullet point to read:
‘Protect the adjacent Bunns Bank Linear Earthwork.‘

Reasonable Alternative Site Policy GNLP5013 Ketteringham Depot land west of Station Lane, Ketteringham
Whilst there are no designated heritage assets within the site boundary, there are two round barrows (scheduled monuments) to the south of the site and several grade II listed buildings nearby. However, these are all over 500 metres from the site. Given the distance and intervening vegetation, we consider there would be little impact on designated heritage.

SUMMARY
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
1. Recommended changes to policy wording
We are pleased to see the site assessments and sustainability appraisal for the
allocations. Although these are not full heritage impact assessments, these
assessments do make some helpful recommendations for the sites.
However, these recommendations are not always reflected in the policy.
As currently drafted, there is sometimes 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 development proposals. Further advice on the content of
policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315
Revision date: 15 03 2019. It states that, ‘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’.
We have therefore suggested a number of relatively minor changes to the policies to
incorporate these recommendations and address some of our concerns.
2. Heritage Impact Assessment of Bawburgh Site
The Bawburgh Site is perhaps most sensitive in heritage terms. There are several
designated heritage assets nearby including the Conservation Area, listed buildings
and scheduled monuments. Indeed, the Site Assessment states that a Heritage
Impact Assessment (HIA) may be required. We concur with this.
Paragraph 31 and 192 of the NPPF requires a proportionate evidence base for Plans
and we consider that an HIA for this site would help to ensure a robust evidence
base for the Local Plan.
Therefore, we recommend that a proportionate Heritage Impact Assessment is
undertaken now to inform the suitability of the site per se, assess the impact, identify
any mitigation and enhancement required and inform any changes to policy wording.
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.
Where a potential impact is identified, wording should be included in the policy and
supporting text to this effect. We suggest the inclusion of additional bullet point in the
site allocation. Ideally, the bullet point should mention the specific asset(s), the policy
requirement (see wording in appendix) and any potential mitigation required.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes
suggested do not go to the heart of the Plan’s soundness, but instead are intended to
improve upon it. We believe that these comments can be addressed by changes to
wording in the plan.
In preparation of the local plan, we encourage you to draw on the knowledge of local
conservation officers, the county archaeologist and local heritage groups.
Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU
Telephone 01223 58 2749 HistoricEngland.org.uk
Please note that Historic England operates an access to information policy.
Correspondence or information which you send us may therefore become publicly available.
Please note that absence of a comment on a policy, allocation or document in this
letter does not mean that Historic England is content that the policy, allocation or
document is devoid of historic environment issues. We should like to stress that this
response is based on the information provided by the Council in its consultation. To
avoid any doubt, this does not affect our obligation to provide further advice and,
potentially, object to specific proposals, which may subsequently arise as a result of
this plan, where we consider that these would have an adverse effect upon the
historic environment.


GNLP5004
Land off Buxton Road, Eastgate, Cawston
The policy states that an archaeological assessment will be required prior to development which is broadly welcomed. The SA recommends that the policy should make it clear whether these should be desk based of field studies. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA also recommends that the landscaping should be species appropriate to the local area.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Amend policy to state that ‘landscaping should be species appropriate to the local area.’

GNLP5005
Strayground Lane, Wymondham Recycling Centre
No comments

GNLP5009 Hockering Lane, Bawburgh

Whilst there are no designated heritage assets within the site, the Bawburgh Conservation Area lies to the west of the site but is separated by a block of development. There are listed buildings and scheduled monuments to the north west of the site across the valley. The development has the potential to impact the significance of these heritage assets via a change in their settings.
The Site assessment suggests the preparation of a Heritage Impact Assessment. The Sustainability Appraisal identifies negative impact.
Given this is one of the more sensitive sites in heritage terms, an HIA should be prepared now to inform the suitability of the site per se and the policy wording.
The policy states that an archaeological assessment will be required prior to development. As with the Cawston site it would helpful for the policy to state if the assessment should be desk based or field based. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA recommends that the policy should protect or where possible enhance the trees and hedgerow surrounding the site, which would be likely to help conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened. This should be included in the policy.
We recommend an HIA is prepared now prior to inform the suitability of the site and policy wording.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Add criterion to read ‘Protect and enhance the trees and hedgerows surrounding the site to conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened’.

GNLP5014
A47 North Burlingham Junction
We welcome bullet point 3 in relation to landscaping to protect views of non-designated heritage assets nearby.

GNLP5019 Woodland Stable, Shortthorn Road, Stratton Strawless
No comments

GNLP5020 Romany Meadow, The Turnpike, Carleton Rode
Whilst there are no designated heritage assets within the site, there are several grade II listed buildings nearby including The Ashes to the east and a cluster of grade II properties to the northwest. However, the site is quite well contained and intervening landscaping should limit the impact on the historic environment.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5021 The Old Produce Shop, Holt Road, Horsford
No comments

GNLP5022 The Oaks, Foulsham
This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5023 Strayground Lane, Wymondham
The SA states that the policy could be further improved by detailed requirements to consider landscaping measures to reduce potential for adverse effects on the surrounding landscape character
Add policy criterion to read
‘Landscaping measures to reduce potential for adverse effects on the surrounding landscape character’

GNLP5024 Upgate Street, Carleton Rode
Whilst there are no designated heritage assets within the site, there are two grade II listed buildings to the north of the site and the New Buckenham Conservation Area to the west of the site. The site assessment states that Bunns Bank Linear Earthwork, which elsewhere in its course is scheduled, is adjacent to the site and should be taken into consideration. This requirement should be included in the policy wording of the Plan. We suggest an additional bullet point to the policy criteria.
However, overall the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage would be minimal.
Amend policy wording to add bullet point to read:
‘Protect the adjacent Bunns Bank Linear Earthwork.‘

Reasonable Alternative Site Policy GNLP5013 Ketteringham Depot land west of Station Lane, Ketteringham
Whilst there are no designated heritage assets within the site boundary, there are two round barrows (scheduled monuments) to the south of the site and several grade II listed buildings nearby. However, these are all over 500 metres from the site. Given the distance and intervening vegetation, we consider there would be little impact on designated heritage.