Minerals and Waste Local Plan: Pre-Submission Publication

Object

Representation ID: 99231

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Carstone Requirement and Shortfall
We note the section on Carstone. 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 that there is one site allocation later in the Plan for Carstone although the Plan states that this is of insufficient quality for use as a building stone.
We therefore 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.

Object

Representation ID: 99232

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We note that this section includes a list of factors that have been considered in the spatial strategy for minerals. We are very concerned to see that there is still no reference to the historic environment in this regard.

Object

Representation ID: 99233

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We have raised concerns about the wording in relation to harm to the historic environment in policy MP2.
In order to make this policy consistent with the NPPF and effective in securing sustainable development, we suggest that the policy wording is amended.

We welcome the addition of designated heritage assets as a bullet point in this policy. Conservation Areas should also be added to this list as they are designated heritage assets.
Substantial harm is a very high bar. Less than substantial harm is still harm and harm should be avoided in the first instance. We suggest that you reword this bullet point to delete the word substantial and add reference to significance and setting.
The bullet point would then read:
a designated heritage asset, including listed buildings, registered parks and gardens, [insert: 'conservation'] areas and scheduled monuments, or their settings if the proposed development would cause [delete: substantial] harm to [delete: or] the [delete: loss] [insert: 'significance'] of the heritage asset [insert: '(including any contribution to significance by setting)'].

Support

Representation ID: 99234

Received: 14/12/2022

Respondent: Historic England

We welcome the criteria based policy approach for Sand and Silica given the many factors that have made it difficult to allocate Areas of Search.
We welcome criteria c, d, e and f.

Comment

Representation ID: 99235

Received: 14/12/2022

Respondent: Historic England

We welcome the reference to the historic environment.

Support

Representation ID: 99236

Received: 14/12/2022

Respondent: Historic England

The cumulative impact of mineral workings on the historic environment can be significant. We therefore welcome this policy.

Support

Representation ID: 99237

Received: 14/12/2022

Respondent: Historic England

We welcome the reference to historic character and landscape characterisation in paragraph MP7.8.

Object

Representation ID: 99238

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We welcome the reference to restoration proposals being informed by the historic environment. We suggest a very slight amendment to the wording to read:
The scheme has been informed by the historic environment and historic landscape [insert: "characterisation and landscape character"] assessments and the restoration enhances the historic environment.
Historic landscape characterisation and landscape character assessments are slightly different but have complementary roles.

Comment

Representation ID: 99239

Received: 14/12/2022

Respondent: Historic England

We welcome the reference to the conservation benefits of carstone.

Comment

Representation ID: 99240

Received: 14/12/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are three listed buildings to the east of the site, including the Grade I listed Church of Mary Magdalene and Old Hall and Beetley Hall, both listed at grade II. Given the open nature of the landscape in this area, extraction at the site could have an impact on the wider setting of the church.
We welcome the specific reference to the nearest heritage assets to read ‘heritage assets and their settings (including the grade I listed Church of Mary Magdalene and grade II listed Old Hall and Beetley Hall)…’