Minerals and Waste Local Plan: Pre-Submission Publication

Comment

Representation ID: 99241

Received: 14/12/2022

Respondent: Historic England

There are no designated heritage assets on site. The grade II* church of St Peter, Manor Farmhouse listed grade II and a scheduled monument (a deserted medieval village) lie to the west of the sites whilst to the north of the site lies East Bilney and several listed buildings, the closest of which is the grade II listed Almshouses.
We welcome the specific reference to the nearest heritage assets in the policy.

Comment

Representation ID: 99242

Received: 14/12/2022

Respondent: Historic England

Although there are no designated heritage assets within the site boundary, the grade II listed Mill House and Windmill lie just to the south of the site. Given the proximity of these assets, we have concerns that extraction at the site will impact upon the settings of these assets. There are also a number of other listed buildings including the church of St Peter and St Paul to the north of the site as well as a scheduled monument. To the south east of the site lies the Carbrooke Conservation Area which also includes several listed building.
We welcome the specific reference to the nearest heritage assets in the policy.

Comment

Representation ID: 99245

Received: 14/12/2022

Respondent: Historic England

Although there are no designated heritage assets within the site boundary, there is a scheduled monument (Roman camp and settlement site) to the south of the site, grade II* listed All Saints Church to the east and scheduled monument Great Hautbois old church and grade II* listed Church of St Theobald’s to the north east of the site. Any extraction at the site has the potential to impact upon the settings of these heritage assets.
We welcome the specific reference to the nearest heritage assets in the policy.

Object

Representation ID: 99246

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We understand from the Council that planning permission has now been granted for this site and to that end the principle of development has been established.
Nevertheless, it is still important for the policy to set out an appropriate policy framework for the protection of the historic environment as the extant planning permission may not be implemented and an alternative application may be submitted.
In order to make this policy effective, we recommend that the policy would be improved by specifically referencing mitigation measures identified through the planning application process.

Whilst there are no designated heritage assets within the site boundary, there are a number of designated heritage assets nearby including the grade II listed Horstead Lodge to the east of the site, the Coltishall and Horstead Conservation Area to the north east of the site (containing a number of listed buildings including the grade I listed Church of St John the Baptist), and a Roman Camp scheduled monument just to the north of the site. We have concerns regarding the potential impact on the setting of these various heritage assets.
We understand that this site now has planning permission and to that end the principle of development has been established. Nevertheless, it is still important for the policy to set out an appropriate policy framework for the protection of the historic environment as the extant planning permission may not be implemented and an alternative application may be submitted.
Whilst we broadly welcome criteria f and g of the policy, the policy would be improved by specifically referencing mitigation measures identified through the planning application process.

Object

Representation ID: 99247

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We continue to have concerns regarding the potential impact of this allocation on heritage assets. We consider that there is insufficient historic environment evidence to justify its allocation.
Whilst we appreciate that an application is due shortly, we would still expect the preparation of a heritage impact assessment to inform the policy wording in the Local Plan, particularly, in respect of potential mitigation for the site.
Prepare a proportionate HIA now ahead of the application and EiP to consider the suitability or otherwise of the site and inform its extent and any potential heritage mitigation. The findings of the HIA would then need to inform the policy and supporting text.
In order to justify this allocation, ensure consistency with the NPPF and to make the policy wording effective, for this site we recommend an HIA is prepared now in advance of the EiP. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate and need not necessarily be particularly onerous. For this site 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.

Whilst there are no designated heritage assets within the site boundary, there are a number of designated heritage assets quite close by including a cluster of grade II listed buildings at Grange Farm, a cluster at Spixworth Hall and Meadow Farmhouse, also grade II listed. The grade I Church of St Peter and Church of the Blessed Virgin and St Andrew and the grade I listed Priory, also scheduled, both lie within the Horsham St Faiths Conservation Area to the west of the site. Minerals extraction in this location therefore has the potential to affect the setting of a number of designated heritage assets.
We note the proposed mitigation buffer to the south east boundary (shown on the map) of the site which is broadly welcomed. We do welcome criteria a, c and d.
However, given our concerns regarding the impact on a number of nearby designated assets we recommended 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.
Whilst we appreciate that the site is already allocated and that an application is due in 2023, we would still expect the preparation of a brief heritage impact assessment to inform the policy wording, particularly, in respect of potential mitigation for the site.

Object

Representation ID: 99248

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.
In our previous response we raised the issue of exploring the possibility of an alternative site for building stone be given that that this site is of insufficient quality for use as a building stone. 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.

Comment

Representation ID: 99250

Received: 14/12/2022

Respondent: Historic England

The Tottenhill Row Conservation Area is located to the west of the site. Mineral extraction has the potential to impact upon the setting of the conservation area. However, there is already some former mineral extraction closer to the Conservation Area. The nearest listed building is over 1 km away.
We welcome the specific reference to the nearest heritage assets in the policy.

Object

Representation ID: 99251

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.
We appreciate that an application was submitted for this site in 2018 and whilst Historic England originally objected to the proposal in August 2018 we recommended that an appropriate restoration scheme should be agreed including restoring the land opposite the church to grassland.
We note that criterion K does now refer to the field opposite the church must be restored to arable agricultural land which is welcomed. We suggest the removal of the word arable as pasture would also be acceptable.

Object

Representation ID: 99252

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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*) and a font against the south façade of Whitehouse Farmhouse (GII).
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 the supporting text to 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. We also welcome the reference to archaeology requirements in the policy and supporting text.
We welcome the reference to the listed church in the policy. We suggest that other listed structure, the font, is also referenced.

Comment

Representation ID: 99254

Received: 14/12/2022

Respondent: Historic England

We welcome the reference in paragraph M115.3 and 115.5 to the nearby heritage assets and the need to provide a heritage statement to identify appropriate mitigation with any planning application. We welcome the reference to a heritage statement in the policy as well as reference to nearby heritage assets. We also welcome the reference to archaeology requirements in the policy and supporting text.