South Norfolk Village Clusters Housing Allocations Plan (Reg. 18 Draft)

Comment

Representation ID: 2022

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We broadly support object 3 Protect the character of villages and their settings. However, we suggest that specific reference is made to the historic environment in this objective. Also, it is not just about protecting the character of villages and their settings but also the wider landscape
Include reference to the need to protect and enhance the historic environment in this objective.
Include reference to wider landscapes.

Comment

Representation ID: 2023

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We support the principle of a standard policy to avoid un-necessary repetition in policies.
However, there is currently no mention of the historic environment in this policy.
We suggest that there should be a criterion to reference the historic environment.
Include criterion for the historic environment to read
Development should conserve/sustain or where appropriate enhance the significance of designated and non-designated heritage assets both on-site and in the surrounding area. This includes any contribution made to its significance by its setting.

Comment

Representation ID: 2024

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We broadly support the criterion in this policy. However, specific reference should be made to local vernacular and materials. Reference should also be made to heritage assets and their settings.
Refer to local vernacular and materials.
Refer to heritage assets and their settings.

Comment

Representation ID: 2025

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We are concerned that there is insufficient evidence in relation to the historic environment to support some of the site allocations.
Whilst the HEELA methodology and site assessments are a helpful starting point, we are looking for more detail, particularly in relation to the amber sites.
Unfortunately, the assessments do not follow the five-step methodology for site allocations set out in our Advice note 3 on site allocations. They do not properly consider significance of heritage assets, the contribution of setting to that significance, impact of development upon significance of those assets and do not consider potential mitigation and enhancement.
Therefore, Heritage Impact Assessments should be prepared for a number of sites; this is imperative to ensure a robust evidence base for the Local Plan. These should be prepared in advance of the next draft of the Plan to inform whether some sites are suitable, but for majority of sites to inform potential mitigation and policy wording. This is a matter of priority, given the timetable for the Plan.
HIAs should consider the issue of the capacity of the sites including issues in relation to height and impact on historic environment. They should consider significance of assets, impact of development upon significance of those assets, and make recommendations about potential mitigation.
Should a HIA conclude that a particular site could be allocated, the findings of the HIA should inform the policy wording.
Paragraph 32 of 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.

Comment

Representation ID: 2026

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
Evidence Base:
We have set out our concerns in relation to insufficient historic environment evidence to support some site allocations and the need for HIAs.
It is important that your plan is underpinned by appropriate evidence.
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.
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 can also be 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.

Comment

Representation ID: 2027

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
General comments on allocations
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.
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.
Typical wording for the policy criterion might be:
Development should conserve or where appropriate enhance the significance of heritage assets including [list heritage assets on site and nearby – these should include designated and non-designated heritage assets] including any contribution made to their significance by their settings. Appropriate mitigation measures [as identified through the Heritage Impact Assessment] including … will be required.’
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.

Comment

Representation ID: 2028

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
Site SN0400 Church Meadow, Alpington
Although this site is located quite close to the grade, I listed St Mary’s Church, the site is tucked behind existing development and so the impact on the heritage asset and its setting would be minimal.

Comment

Representation ID: 2029

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
Site SN0412REV Former Concrete works, Church Road, Bergh Apton
There are no designated heritage assets on site. However, there is a cluster of grade II listed buildings to the east of the site. However, the redevelopment of the former cement works will enhance the setting of these assets rather than detract from them.
The policy for this site should reference the nearby heritage assets.
Add policy criterion to read,
Development should preserve and enhance the significance of the nearby listed buildings (including any contribution made to that significance by setting).

Comment

Representation ID: 2030

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
Site SN0459 - Land off Church Road, Aslacton
Whilst there are no designated heritage assets within the site boundary, there is a grade II listed Church Farmhouse to the south east of the site. However, given the distance and intervening development and vegetation, we consider that the development of the proposed allocation would have limited impact of the setting of the heritage asset.

Object

Representation ID: 2031

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
Site SN4053 Land to the east of Stocks Hill.
Whilst there are no designated heritage assets within this site, the site lies immediately to the south of the boundary of the Bawburgh Conservation Area. Any development of this site therefore has the potential to affect the Conservation area and its setting including views into and out of the Conservation area.
A heritage impact assessment of the site should be undertaken to assess the impact of the proposed development on the Conservation Area and determine if allocation of this site is appropriate, and if it is what mitigation may be required. The findings of the HIA should inform whether the site is allocated and if it is, the policy criterion including any mitigation and enhancement.
Complete an HIA to inform the allocation of the site including any mitigation, enhancement and policy wording.