A.34. The Heritage Impact

Support

Representation ID: 2310

Received: 10/02/2023

Respondent: Norfolk Gardens Trust

The Norfolk Gardens Trust (NGT) works in partnership with the Gardens Trust (GT) to protect and conserve registered sites, and is authorised to respond on GT's behalf in respect of such consultations. We welcome the Council's use of heritage impact assessments to assess the potential impact of housing development on designated and non-designated heritage assets. It is particularly important that historic designed landscapes that are NOT registered but nevertheless have local heritage importance -- such as public green spaces, cemeteries and commercial green spaces -- are also protected and conserved, as these lack the statutory protection of registered sites.

Object

Representation ID: 3144

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We are delighted to see that Heritage Impact Assessments have been prepared for many sites. However, there are a few allocations where we recommend the preparation on an HIA now prior to EiP (e.g. VC BRO1 West, VC WOR1). The policy wording should then be amended accordingly. In the absence of an HIA we consider these sites are not sufficiently justified. There are also some settlement limit extensions where an HIA should also be prepared now ahead of EiP (e.g. SN0020SL, SN0588SL). Finally, there are some recommendations in HIAs that have not been incorporated into policy. The policies need to be amended to incorporate these HIA recommendations. This applies to a number of sites as set out in the attached table. Further details of all the relevant sites are given in Appendix A.

Object

Representation ID: 3146

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Many of the policies include an archaeology criterion which states that ‘The HER should be consulted to determine the need for any archaeological surveys prior to development’.
Whilst we welcome the inclusion of a criterion for archaeology, in our view some assessment is needed to inform any planning application (rather than waiting until
after permission is granted but before development). This is consistent with the policy set out in para 194 of the NPPF. We therefore advise that the archaeology criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ This applies to a number of sites in
the Plan.

Object

Representation ID: 3147

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We have raised a number of quite site-specific issues in relation to the Bressingham, Little Melton, Rockland St Mary and Tasburgh sites. See the attached table for
further details of our concerns.

Support

Representation ID: 3152

Received: 01/03/2023

Respondent: Historic England

We very much welcome the preparation of the Heritage Impact Assessments to inform the site selection process and site allocation policies.