Minerals and Waste Local Plan: Pre-Submission Publication

Object

Representation ID: 99255

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.

This site is located within the Glaven Valley Conservation Area. The nearest listed building is the grade II* remains of the church of St Peter and St Paul and the nearest scheduled monument is the Castle Hill Medieval ringwork at Hunworth. We have concerns regarding this site given its location within the conservation area.
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 e, f and g of the policy, the policy would be improved by specifically referencing mitigation measures identified through the planning application process.

Comment

Representation ID: 99256

Received: 14/12/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are a number of grade II listed buildings to the south of the site and the Upper Sheringham Conservation Area and Sheringham Hall registered park and garden lies to the north of the site.
We welcome the reference in paragraph M208.3 - 208.5 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 this in the policy including specific reference to heritage assets. We also welcome the reference to archaeology requirements in the policy and supporting text.

Object

Representation ID: 99257

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 these sites 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/imagesbooks/
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 boundaries, there are a number of grade I and grade II listed buildings in close proximity to the site. Of particular concern is the impact on the setting of the Grade I listed Church of St Mary, just 110m away and also the grade II listed White House Farm only 70 metres away. Whilst we note that indicative site buffers/screening are shown on the map, we are still very concerned at the potential impact of the proposed allocation on heritage assets.
We note that the plan states that users of the road would not have views of the mineral extraction when viewing the church, but that is not the same as not affecting the setting. Setting impacts can are not just visual but can include noise, dust, vibration etc.
Indeed, in relation to the previous application on this site we raised strong objections and we advised that ‘In considering the contribution to the historic significance of the church made by its setting, it is clear that some harm will result from the proposed quarry, both during its period of activity and from the permanent change to the landscape.’
Although we appreciate that unlike the previous application, the allocation is just to the north of the road. However, we continue to have concerns regarding the potential impact of the allocation on heritage assets.
To that end 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 an application is due in late 2022, 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.
We do welcome criteria a, b, g and h. In addition, we welcome the screening to the around the edge of the site as shown on the map extract.

Object

Representation ID: 99515

Received: 14/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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 and 30th October 2019.
Please also see our detailed comments in the attached table, Appendix 1.
SUMMARY
Whilst we welcome many of the changes you have made in this latest draft of the Plan and consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which remain and 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 key issues:
a) Insufficient Historic Environment Policy (MW1, WP2 and MP2)
Whilst we appreciate that you have made some changes to policy MW1 to include more references to the historic environment, which is welcome, it is still our view that there is currently insufficient policy provision for the historic environment in the Plan. 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. We are particularly concerned about the lack of detail in relation to below ground archaeology.
We have also raised concerns about the wording in relation to harm to the historic environment in policies WP2 and MP2.
In order to make these policies consistent with the NPPF and effective in securing sustainable development, we suggest that the policy wording is amended.
Further detail is set out in the attached table.

b) Site allocations requiring further assessment/ proportionate evidence
Thank you for the helpful update on the status of the various sites where we had previously requested a Heritage Impact Assessment (HIA). We appreciate that for some of those sites an HIA is no longer necessary (for example the site is no longer allocated).
However, we continue to have concerns about sites where permission has been granted but not yet implemented (MIN 207 and MIN 65), and also a couple of sites where an application is due (MIN 25 and MIN 96).
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.
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. We suggest it might be helpful to set up a meeting to discuss any outstanding issues and begin work on a Statement of Common Ground. Please suggest some potential meeting times (noting my part time hours). In the meantime, we look forward to continuing to work with you and your colleagues.