Preferred Options consultation document
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Preferred Options consultation document
MIN 6 - land off East Winch Road, Mill Drove, Middleton
Representation ID: 98812
Received: 30/10/2019
Respondent: Historic England
We have no objections to the allocation of this site, which would have limited impact on designated heritage assets. However, the site will be for the extraction of carstone, a material that can be used for building stone purposes. Carstone is probably the most important building stone within the county and can be seen in historic buildings and structures of western Norfolk. It is largely quarried today for construction rather than conservation purposes, but it is essential that some extraction takes place for building stone uses and that minimal crushing of good quality carstone takes place for construction purposes.
We note from the first paragraph that the carstone deposit in this site allocation is unsuitable for building stone use. We hope this has been based on a thorough investigation of the deposit within the site and it can be clearly demonstrated that the mineral is of insufficient quality for conservation purposes. If the evidence is lacking, then Policy MIN 6 should include reference to the need for further investigation to establish the quality of the carstone deposit before extraction takes place. This might prevent good quality stone from being needlessly wasted.
If it is indeed the case that this site is of insufficient quality for use as a building stone, we recommend that an alternative site for building stone be sought. It is important that such stone is available for historic conservation work and also for limited use in new build where using traditional building materials can be a helpful design tool in picking up on local vernacular, character and distinctiveness in sensitive design.
Suggested change: Consider if an alternative site for building quality Carstone is needed.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
MIN 40 - land east of Grandcourt Farm, East Winch
Representation ID: 98813
Received: 30/10/2019
Respondent: Historic England
We have previously raised concerns with this site in terms of the potential impact of on the significance and setting of the Grade II* listed church in East Winch, just 50 metres away. We welcome the inclusion of screening around the edge of the site allocation as shown on the Proposals Map, but there is no certainty that the impact on heritage assets will be properly considered.
To that end we recommend that a Heritage Impact Assessment is completed at this stage to assess the suitability or otherwise of the allocation and extent of the site and consider any mitigation that might be necessary should the site be found suitable from a heritage perspective. The findings of the HIA would then need to inform the policy and supporting text.
Suggested change: Prepare an HIA now to consider the suitability of the site, and inform its extent and any potential heritage mitigation in advance of the next draft of the Plan. The findings of the HIA would then need to inform the policy and supporting text.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
SIL01 - land at Mintlyn South, Bawsey
Representation ID: 98814
Received: 30/10/2019
Respondent: Historic England
The boundaries of this area of search (AOS) are in close proximity of a number of heritage assets comprising the ruined parish church of St Michael (grade II*) 650 metres to the west, the remains of St James' Church (scheduled monument), 1400 metres to the north west and a bowl barrow on Leziate Heath, 300 metres to the west.
Other non-designated assets exist and include a series of crop marks related to undated ditches and banks together with a possible Bronze Age barrow.
We welcome the reference in paragraph S1.2 to S1.4 to the nearby heritage assets and the need to provide a heritage statement and LVIA to identify appropriate mitigation with any planning application. We welcome the reference to this in the policy. The policy could be improved by including specific reference to the nearest heritage assets We also welcome the reference to archaeology requirements in the policy and supporting text.
Suggested change: Include specific reference to the nearest heritage assets to read 'heritage assets and their settings (including...)
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
AOS E - land to the north of Shouldham
Representation ID: 98815
Received: 30/10/2019
Respondent: Historic England
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
Paragraph E3 rightly confirms that this area of search contains numerous heritage assets comprising four scheduled monuments less than 400 metres from the area of search which include Pentney Priory to the north-eastern boundary (scheduled monument and two grade I listed buildings), the Motte and Bailey Castle in Wormegay to the north-western boundary, Shouldham Priory (scheduled monument) and village cross and Shouldham medieval settlement (scheduled monument) to the southern boundary. A further 5 listed buildings are located less than 300 metres within the area of search. They comprise the Church of St Michael (grade II*), the Church of St Botolph (grade I), Castle Meadow (grade II), Castle Road Bridge (grade II) and Village Cross (grade II).
As with previous submissions this is a large area of search at 815 hectares and therefore considerable potential exists to harm the historic environment. To avoid this requires an assessment of the setting and context between these heritage assets, including both designated and non-designated assets, to inform the decision-making process.
We note that a Heritage Impact Assessment has been prepared by Norfolk County Council for this Area of Search E and Site SIL02 which is welcomed. However, there are a number of shortcomings in the assessment that need to be addressed:
a) We note that the assessment only includes designated and not non-designated heritage assets and the wider historic environment as we have previously advised. The assessment should be extended to include non-designated heritage assets. In particular the assessment needs to consider the warren and the inter-relationship between the various heritage assets in the complex medieval landscape
b) The discussion of significance and setting of heritage assets is not particularly thorough and robust - again the inter-relationship between the medieval assets is key. This may lead to further recommendations for areas to be excluded from the area of search.
c) We recommend the inclusion of a graphical display of potential avoidance/mitigation in the HIA would be useful.
We note that the HIA recommended that the northern parts of the AOS nearest to Wormegay and to Pentney Priory should not be allocated. It would be helpful to include this map in the HIA.
The Area of Search and site allocation SIL 2 should therefore be reduced in size, and not simply covered with purple hatching. The excluded areas should be removed from the Plan altogether.
Suggested change: The HIA should be revised to include an assessment on non-designated assets and the wider historic landscape, to include a more thorough assessment of significance and setting which may in turn lead to further recommendations for areas to be excluded from the areas of search. This will provide a better understanding of the historic environment in this area and more helpfully inform the extent of the Area of Search and Site allocation. We recommend the inclusion of a graphical display of potential avoidance/mitigation measures in the HIA itself.
Depending on the findings of the revised HIA, the AOS and site area may need to be further reduced.
Regardless, we suggest that the areas hatched in purple are removed from Plan altogether.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
AOS F - land to the north of Stow Bardolph
Representation ID: 98816
Received: 30/10/2019
Respondent: Historic England
Two parcels are within the area of search and we have assumed that both could be selected for working, which potentially has a cumulative impact on the wider landscape. This landscape includes the setting of Wallington Hall (grade I) and 4 listed buildings within Stow Bardolph. The closest heritage asset to the AOS is The Cottage at Stow Bardolph, to the immediate south-east.
We welcome the reference to the historic environment in paragraphs F3 - F5 which acknowledge that this landscape has been shaped by parklands and farmed estates, themselves dating to the 16th Century, addresses the need for further field evaluation to understand the significance of archaeological deposits and in paragraph F6 deals with a transitional landscape between the Fens and the Brecks and promotes use of landscape and visual impact assessments, which is supported.
Historic England acknowledges that these are smaller areas of search when compared to other locations, albeit they are in close proximity. Consideration of cumulative impact is important.
Paragraph F4 should be amended to refer to the need to assess cumulative impacts on the historic environment.
Suggested change: Amend paragraph F4 for note the need for consideration of cumulative impacts on the historic environment.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Comment
Preferred Options consultation document
AOS I - land to the east of South Runcton
Representation ID: 98817
Received: 30/10/2019
Respondent: Historic England
We have previously reported no immediate concerns regarding this area of search providing it is well contained and does not impact on the setting of any heritage assets, subject to necessary assessment and mitigation. We have identified that this will apply to the setting of the Church of St Andrew (Grade II*), the Church of St Mary the Virgin (Grade II*) and a number of listed buildings together with the setting of the Shouldham Thorpe Conservation Area. Historic England has produced a Good Practice Advice (GPA 3) Note 3 on the setting of heritage assets.
We welcome the reference in paragraphs I4-I6 to the nearby heritage assets and the need to provide a heritage statement to identify appropriate mitigation with any planning application. We also welcome the reference to archaeology requirements in the policy and supporting text.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Comment
Preferred Options consultation document
AOS J - land to the east of Tottenhill
Representation ID: 98818
Received: 30/10/2019
Respondent: Historic England
Whilst there are no designated heritage assets within the site boundary, the Church of St Botolph at West Briggs (Grade I) is located at a distance of 325 metres to the area of search (AOS) boundary and around 1200/1250 metres to the Motte and Bailey castle in Wormegay village and 1600 metres to the Wormegay priory moated site (further to the north west).
Paragraph J4 accurately sets out these heritage assets and the need for a heritage statement to address setting and mitigation of impact should any future planning application come forward which is welcomed. As stated in other representations Historic England commends the methodology in the Good Practice Advice Note 3 on the setting of heritage assets. A methodology in 5 stages is set out and is built upon an understanding of the degree to which setting contributes to significance and an assessment of the effect of a proposal on that significance as well as measures to maximise and minimise harm.
Paragraph J4 sets out the potential for non-designated heritage assets and evaluation work to understand significance when at planning application stage.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
Policy MP13: Areas of Search for silica sand extraction
Representation ID: 98819
Received: 30/10/2019
Respondent: Historic England
We broadly welcome bullet points 3-6 of this policy. Bullet point 3 should also include reference to Registered Parks and Gardens. Bullet point 6 should also include reference to the potential impacts of de-watering on buried archaeology.
It should be made clear in the policy/supporting text that in preparing a detailed Heritage Statement/Assessment for the site, parts of the site may be found unsuitable for extraction due to harm to heritage assets.
Suggested change: Bullet point 3 should also include reference to Registered Parks and Gardens. Bullet point 6 should also include reference to the potential impacts of de-watering on buried archaeology.
It should be made clear in the policy/supporting text that in preparing a detailed Heritage Statement/Assessment for the site, parts of the site may be found unsuitable for extraction due to harm to heritage assets.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
SIL02 - land at Shouldham and Marham
Representation ID: 98820
Received: 30/10/2019
Respondent: Historic England
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
We note that a Heritage Impact Assessment has been prepared by Norfolk County Council for this Site SIL02 and AOSE which is welcomed. However, there are a number of shortcomings in the assessment that need to be addressed:
a) We note that the assessment only includes designated and not non-designated heritage assets and the wider historic environment as we have previously advised. The assessment should be extended to include non-designated heritage assets. In particular the assessment needs to consider the warren and the inter-relationship between the various heritage assets in the complex medieval landscape
b) The discussion of significance and setting of heritage assets is not particularly thorough and robust - again the inter-relationship between the medieval assets is key. This may lead to further recommendations for areas to be excluded from the area of search.
c) We recommend the inclusion of a graphical display of potential avoidance/mitigation in the HIA would be useful.
We note that the HIA recommended that the eastern part of the site should not be allocated. It would be helpful to include this map in the HIA.
The site allocation SIL 2 should therefore be reduced in size, and not simply covered with purple hatching. The excluded areas should be removed from the Plan altogether.
Suggested change: The HIA should be revised to include an assessment on non-designated assets and the wider historic landscape, to include a more thorough assessment of significance and setting which may in turn lead to further recommendations for areas to be excluded from the areas of search. This will provide a better understanding of the historic environment in this area and more helpfully inform the extent of the Area of Search and Site allocation. We recommend the inclusion of a graphical display of potential avoidance/mitigation measures in the HIA itself.
Depending on the findings of the revised HIA, the site area may need to be further reduced.
Regardless, we suggest that the areas hatched in purple are removed from the Plan altogether.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
Object
Preferred Options consultation document
Appendix 11 - Glossary
Representation ID: 98821
Received: 30/10/2019
Respondent: Historic England
Suggested change: Give a clearer distinction between designated and non-designated heritage assets. Use the term non- designated rather than undesignated in accordance with the NPPF.
Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019
Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]
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:
a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.
b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.
c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.
d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.
Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes 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.
Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.
We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
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.
If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.
