Initial Consultation document

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Object

Initial Consultation document

1. Introduction

Representation ID: 92939

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

Page 8, 4th para
The M&WLPR does not include policies covering the historic environment with the exception of MP13 on areas of search for silica sand extraction.

Comment

Initial Consultation document

3. The process so far

Representation ID: 92940

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

Page 10 and 11
We note that the assessment of proposed sites includes landscape and historic environment considerations. We note that each site has the site characteristics set out in the plan. However, we are concerned that despite the clear identification of heritage assets, many of the minerals sites are close to and in one case include a designated heritage asset. Some of these concerns could be addressed through improved policy wording, introduction into policy of specific mitigation measures which have been identified in the Sustainability Appraisal, or the use of heritage impact assessments to define site boundaries at this stage. We also recommend further cumulative assessment, particularly for MIN 19, MIN 205, AOS E and SIL 02. We note that on some of the mapping some designated heritage assets appear to be missing.

Support

Initial Consultation document

5. Norfolk Spatial Portrait

Representation ID: 92941

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

page 17
We welcome the commitment that harm to the significance of heritage assets should be avoided in the design and location of new minerals or waste management development.

Support

Initial Consultation document

Question 1: Minerals and Waste Local Plan Vision

Representation ID: 92942

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

We welcome reference in the vision to minerals and waste development being located, designated and operated without adverse impacts on the natural, built and historic environment.

Support

Initial Consultation document

Question 2: 'Waste Management Strategic Objectives'

Representation ID: 92943

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

We welcome draft waste management strategic objective WS07 to ensure that the locations of waste facilities are sustainably designed, constructed and operated to reduce potential adverse effects on the natural, built and historic environment.

Support

Initial Consultation document

Question 3: 'Minerals Strategic Objectives'

Representation ID: 92944

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

We welcome the draft minerals strategic objectives MS06 and MS09. We welcome the requirements to positively contribute, to mitigate against adverse cumulative impacts, and to provide high quality progressive and expedient restoration.

Comment

Initial Consultation document

Question 4: Policy MW1 'Presumption in favour of sustainable development'

Representation ID: 92945

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

Whilst we welcome the strategic policy on sustainable development, paragraph 193 of the National Planning Policy Framework is clear that great weight should be given to the conservation of a heritage asset with the weight increasing with importance. This is irrespective of the potential level of harm to its significance. Given that paragraphs 193-195 set a stronger requirement for justifying harm than bullet point 1 in Policy MW1, we are assuming that bullet point two referring to other polices in the Framework applies, but it is not clear. As there is a lack of any policy on the historic environment, this is concerning.

Object

Initial Consultation document

Question 5: Policy MW2 'Development Management Criteria'

Representation ID: 92946

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

This policy remains unsound as it does not meet the requirements of paragraph 204(f) of the Framework. In fact, Policy MW2 appears to be a similar list of areas to cover in paragraph 204 (or former paragraph 143) but provides limited historic environment criteria against which planning applications will be assessed so as to ensure that there are no unacceptable adverse impacts. We note the inclusion of cumulative impacts within the definition and the requirement to enhance, where possible, the historic environment. This can be contrasted with MP13 which provides specific policy provisions for the historic environment in respect of areas of search but we would note that MP13 also relies upon the provisions in MW2.

As this policy underpins all the other policies in the plan we are concerned that, as drafted, this policy undermines the plan. An alternative approach would be to increase the historic environment specific criteria in every relevant policy, however, this would be a repetitive process given the plan should be read as a whole.

Comment

Initial Consultation document

Question 5: Policy MW2 'Development Management Criteria'

Representation ID: 92947

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

'Heritage assets' section, page 28
It would be clearer and more consistent if the section was entitled 'historic environment' rather than 'heritage assets'. We would note that under the existing policy hierarchy the National Planning Policy Framework covers designated and non-designated heritage assets although the statutory protection is focused on designated heritage assets.

page 31 'cumulative impacts'
The first paragraph should be reworded to read that the" ... natural, built and historic environment. .. " are considerations for cumulative impacts for consistency and accuracy.

Object

Initial Consultation document

Question 11: Policy WP2 'Spatial strategy for waste management facilities'

Representation ID: 92948

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

We are concerned that change from allocating sites for waste management to a criteria-based policy makes the impact on the historic environment hard to assess. Given the lack of historic environment policy to support this approach and a lack of evidence of the impact of this policy on the historic environment we currently cannot support this approach.

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