Heritage and historic assets

Policy POSP4: Historic Environment

  1. The historic environment of the Broads will be protected and enhanced.
  2. Key buildings, structures and features which contribute to the Broads’ character and distinctiveness will be protected from inappropriate development or change.
  3. Proposals which maintain, enhance, and provide better understanding of the significance of the overall cultural heritage value of the Broads will be sought through:
    1. Supporting the repair and appropriate re-use of buildings and structures of historic, architectural, cultural or landscape value where the repair and/or use would not be detrimental to the character, appearance or integrity of the building or structure, its context or setting; and
    2. Requiring the highest standard of design and highest quality of appropriate materials which will protect the historic environment and add to the future cultural heritage value of the locality.
  4. The archaeology of the Broads will be better understood, protected, and enhanced by:
    1. Protecting archaeology from inappropriate development or change; and
    2. Ensuring proposals take account of the area’s status as having ‘exceptional waterlogged heritage’.
  5. Appropriate development proposals that bring into use or improve an asset so it is no longer deemed at risk on the heritage at risk register will be supported where appropriate to their significance.

Reasoned Justification

The NPPF defines Historic Environment as ‘all aspects of the environment resulting from the interaction between people and places through time, including all surviving physical remains of past human activity, whether visible, buried or submerged, and landscaped and planted or managed flora’.

The Broads has a rich and varied cultural heritage. The historic environment makes a significant contribution to sustainable communities through supporting economic vitality, social and cultural links to the past and a dynamic and varied built environment. Much of the landscape of the Broads is a product of historic and cultural practices and is of itself an historic landscape. There are many designated and non-designated heritage assets (discussed later in this section).

Our policies aim to set new standards to complement the current character and to create development that will be valued in future. The design quality of new structures in the Broads may impact on identified features, and by requiring a high quality of design, it is hoped the cultural heritage value of the area will be enhanced.

The quality and type of materials used is important in historic contexts and sensitive landscapes. Modern materials such as uPVC or composite boarding or cladding, bargeboards, soffits and rainwater goods, or composite tiles and other roof coverings often visually compete with softer and traditional materials typically used on historic properties. Hard cement renders, as an example, can also restrict moisture movement and create damp within historic properties. It is often honest, simple, breathable and traditional materials that will be the most appropriate in historic contexts. Modern materials will need to be thought about carefully and given full justification for their use when used on or attached to historic properties or within their wider setting.

Heritage assets are defined by the NPPF as ‘a building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage asset includes designated heritage assets and assets identified by the local planning authority (including local listing)’.

  • Designated heritage asset. The NPPF defines these as World Heritage Sites, Scheduled Monument, Listed Building, Protected Wreck Site, Registered Park and Garden, Registered Battlefield or Conservation Area designated under the relevant legislation.
  • Non-Designated Heritage Assets. The NPPG says these are locally designated ‘buildings, monuments, sites, places, areas or landscapes identified as having a degree of significance meriting consideration in planning decisions, but which are not formally designated heritage assets’.

Some non-designated heritage assets can be found on the Authority's Local List, which identifies buildings and structures that significantly contribute to the local character but may not meet the strict criteria for nationally listed assets. It should be noted that not all non-designated heritage assets are on the local list. Some non-designated heritage assets have not been formally identified and may be discovered through the planning process.

There will be archaeological interest in a heritage asset if it holds, or may potentially hold, evidence of past human activity worthy of expert investigation. Heritage assets with archaeological interest are the primary evidence source about the substance and evolution of places, and the people and cultures that made them.

Heritage at Risk is a term applied to designated heritage assets at risk as a result of neglect, decay, or inappropriate development, or vulnerable to becoming so. The Authority generally supports improvements to the ‘at risk’ assets that will enable them to be taken off the register, but these changes must be in conformity with the other adopted policies of the Local Plan and with national planning policies.

The only Conservation Area at risk in the Broads is the Halvergate Marshes Conservation Area. One of the reasons for this is the poor condition of many of the numerous mill structures within it. has been a slight improvement in condition recently with some structures being repaired as part of the Water Mills and Marshes project and the separate repair of the Stracey Arms Mill.

Relevant sources of information

Reasonable alternative options

No policy

Original policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: No policy: 0 positives. 0 negatives. 3 ?

B: Preferred Option: 3 positives. 0 negatives. 0 ? Overall, positive.

C: Original policy: 3 positives. 0 negatives. 0 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has been used and applications have been determined in accordance with the policy.

Why has the alternative option been discounted?

Because the Broads benefits from many different types of heritage assets all around the area, to have strategic policy is considered prudent. The slight amendment which brings in materials is favoured as inappropriate materials can harm heritage assets.

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Policy PODM12: Heritage Assets

  1. All development will be expected to protect, preserve, or enhance the significance and setting of historic, cultural, and architectural heritage assets and elements of the wider historic environment that give the Broads its distinctive character.
  2. Designated Heritage Assets
    1. Development that would affect a Designated Heritage Asset or its setting will be considered in the context of national policy, having regard to the significance of the asset.
    2. Development proposals affecting conservation areas should seek to improve the conservation area. Proposals should ensure that the historic character and/or appearance of the area is preserved, enhanced, or seek betterment where there is currently a negative impact. In conservation areas, all development is expected to be of a particularly high standard of design and materials.
  3. Identified and unidentified non-designated heritage assets[55]
    1. Where local heritage assets (identified or unidentified) are affected by development proposals, their significance should be retained within development. Development resulting in harm to or loss of significance of a locally identified asset will only be acceptable where:
      1. there are demonstrable and overriding benefits associated with the development; and
      2. it can be demonstrated that there would be no reasonably practicable or viable means of retaining the asset within a development.
  4. Archaeology
    1. Sites of archaeological interest and their settings will be protected, enhanced, and preserved; development which has an unacceptable impact on a site of archaeological interest will not be permitted.
    2. Where it is considered appropriate in cases where development coincides with the location of a known or suspected archaeological interest, an archaeological field evaluation will be required.
    3. There will be a presumption in favour of preservation in-situ for Scheduled Monuments and other archaeological heritage assets of significance.
    4. Development proposals that will result in unavoidable harm to, or loss of, an archaeological heritage asset’s significance, will only be permitted where there is a clear justification in terms of public benefits arising from the development which outweigh that harm and, in the case of substantial harm/loss, also meet the following requirements:
      1. There is no less harmful viable option;
      2. The amount of harm has been reduced to the minimum possible; and
      3. Satisfactory provision is made for the evaluation, excavation, recording interpretation, dissemination and archiving of the remains and then interpretation, dissemination and archiving before the commencement of development.
    5. The Authority would also welcome public engagement as part of a development project to improve public understanding of the area’s archaeology.
  5. The unknowns
    1. Consideration will be given to the protection of heritage assets which have not been previously identified or designated but which are subsequently identified through the process of decision making, or during development. Any such heritage assets, including artefacts, building elements or historical associations which would increase the significance of sites and/or buildings, will be assessed for their potential local heritage significance before development proceeds.
    2. Where heritage assets newly identified through this process are demonstrated by evidence and independent assessment to have more than local (i.e., national, or international) significance, there will be a presumption in favour of their retention, protection, and enhancement.
    3. Where an asset has potential to be locally significant, it will be assessed against the criteria set out in the reasoned justification to this policy. Where this process demonstrates there is local significance, development proposals affecting these assets will be determined in accordance with criteria listed in section 3 of this policy.
  6. Linking to the past
    1. Where the Authority considers it appropriate, proposals will be required to recognise the importance of the historic environment through heritage interpretation measures.
  7. Demolition
    1. Where proposals which involve the unavoidable loss of any designated or local heritage asset are accepted exceptionally under this policy, a legally binding commitment from the developer must be made to implement a viable scheme before any works affecting the asset are carried out.
    2. Demolition of unlisted buildings in a conservation area will require justification in a heritage statement. The demolition of structurally sound buildings which make a positive contribution to the significance of a conservation area will be resisted unless there are exceptional circumstances, including when the demolition is proposed as part of a scheme for redevelopment which would make an equal or greater positive contribution to the Conservation Area.

Reasoned Justification

The Authority recognises the importance of protecting and preserving heritage and cultural assets, but new development may in some cases be appropriate to enable historic buildings and areas to react to changing circumstances. Development proposals will, however, be judged against their effect on the significance of the asset and its setting. This policy should be read in conjunction with the policy principles and information set out in the NPPG and NPPF.

Setting and heritage statements

Development that would affect the significance or setting of a Heritage Asset (designated or non-designated), including a Listed Building, a locally listed building, Conservation Area, Registered Park and Garden or Scheduled Monument or its setting, must be accompanied by a Heritage Statement. This statement should provide a schedule of works and analyse the impact of the proposal on the form, fabric, and setting of the asset and any features of historic or architectural interest, together with an assessment of the significance of the heritage asset to be affected. The statement should provide justification for the proposed works and their impact on the special character of the asset. When a Design and Access Statement is required, the Heritage Statement can form part of this.

Harm

In assessing the effect of development proposals on a Heritage Asset, consideration will be given to the significance of the asset and its setting, its intrinsic historic interest and rarity, and the contribution it makes to the character of the area. This will be weighed against the social and economic benefits of the proposal. Development that would cause less than substantial harm to the significance of a Listed Building, Conservation Area, or Scheduled Monument will only be permitted where the harm is outweighed by substantial public benefits of the proposal. (‘Significance’ can be defined as the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic, or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting[56]).

Non-designated heritage assets

Non-designated heritage assets include those on the Historic Environment record of Norfolk and Suffolk County Councils as well as the Broads Local List. There are also assets on neither of these lists that we know about and that have potential historic importance including landscape features. We assess one topic area at a time to understand the potential for other features or buildings to form part of the Local List. At the time of writing, the list includes mills and waterside chalets.

Archaeology

The Broads is a low-lying wetland area where the landscape has been shaped over centuries by a combination of physical, ecological, cultural, and historic factors. Archaeological remains are a finite resource, often highly fragile and vulnerable to damage and destruction. Compared to other wetland/former wetland and areas of the East of England, the archaeology of the Broads is comparatively under-investigated. The lakes, dykes and in some cases the rivers are themselves archaeological features, and it is likely that undiscovered archaeology exists owing to the largely undeveloped nature of the area.

The Broads contains important archaeological sites, many of which owe their preservation to waterlogged conditions that promote conservation of organic material. Large areas of the grazing marshes have not been investigated or developed, and they are likely to represent a reserve of significant archaeological artefacts and interest, given the rich archaeology in the immediate vicinity. The importance of the palaeo-environmental remains likely to be preserved in the wetland environment is recognised. Historic England has identified the Broads as an area of exceptional waterlogged heritage. Because of the soil conditions in the Broads, there is great potential for archaeology to be well preserved.

Where possible, development proposals should be located and designed to avoid damage to archaeological remains and should enable these remains to be preserved in situ. Norfolk County Council Environment Service Historic Environment Strategy and Advice Team and Suffolk County Council Archaeological Service (SCCAS) will be consulted on development proposals with the potential to have an adverse impact on a site of known or suspected archaeological interest. When a proposal has a potential adverse effect on a site of known or suspected archaeological interest, the development must be accompanied by archaeological field evaluations that detail the impact the proposal would have on these remains. In these cases, preservation by record secured through an agreed Written Scheme of Archaeological Investigation will be required, secured through appropriately worded planning conditions. All archaeological works will be required to be undertaken to proper professional standards, as defined by the Chartered Institute for Archaeologists (CIfA). Applicants can contact Norfolk County Council Environment Service Historic Environment Strategy and Advice Team (NCCES ) directly at hep@norfolk.gov.uk for pre-application advice. Charges apply for elements of NCCES involvement in planning cases not covered by the service level agreements with the Broads Authority. Suffolk County Council advises early consultation of the Historic Environment Record and assessment of the archaeological potential of the area at an appropriate stage in the design of new developments, so that the requirements of the NPPF and the East Suffolk Local Plan are met. SCCAS is happy to advise on the level of assessment and appropriate stages to be undertaken. They should be consulted for advice as early as possible in the planning application process.

Suffolk and Norfolk County Councils would also welcome the encouragement of public engagement as part of a development project to improve public understanding of the area’s archaeology.

Where development can take place and still preserve important features in situ, planning conditions will be sought to secure the implementation of effective management plans that ensure the continued protection of those features.

Newly identified assets

Heritage assets also include undesignated and unidentified assets that may be identified as being of significance during pre-application discussions or decision making, or that may be revealed during development. These may include assets of established community value and assets that contribute to an area’s sense of place and neighbourhood feel.

As part of the planning application process, consideration should be given to whether a heritage asset whose significance is not currently recognised or appreciated, but which becomes apparent through the application process, merits formal protection. Where, following assessment, such an asset is judged to be worthy of protection, the principle to be followed is that any proposals resulting in harm to or loss of significance will be assessed according to the degree of significance that the asset is agreed to possess, as would apply if it had already been formally recognised.

An independent assessment of heritage significance would normally be undertaken by Historic England (or any equivalent successor body that becomes responsible for heritage asset protection during the currency of this plan). Where the significance of newly discovered assets is judged not to be so great as to merit national protection, there may be a case for some form of local recognition, typically by including the asset, or the building or structure in which it has been discovered or of which it forms part, on the Authority’s Local List (see criteria in Non-designated heritage assets section below).

Non-designated heritage assets

Inclusion on a local list is:

  • To raise awareness of the area's special heritage and its importance to local distinctiveness of the Broads.
  • To inform owners, the local community, developers, and others about buildings which make a special contribution to the landscape of the Broads.
  • To help us when making decisions about development proposals and their effect on the character of the area.
  • To ensure the provision of specialist advice to owners to help protect the character and setting of buildings.

Local List Selection: The kind of structures that can be included on the Broads Local List is wide and varied including built parks and gardens, agricultural buildings, boatyards, drainage pumps, houses, bridges, locks, community buildings and monuments.

Inclusion depends on satisfying at least two criteria based on:

  • Age and integrity
  • Historic interest – historic association to people or events, social importance, or links to a lost lifestyle
  • Architectural interest or merit
  • Technological innovation or excellence
  • Visual, scenic, artistic or group value

Waterside Chalets are a group of buildings that have been assessed and formally added to the local list. They are particularly distinct to the Broads and contribute significantly to the wider character of the area. They tell us a lot about the evolving history of the Broads and changing social fashions. As land prices rise and the area becomes more desirable there is an increasing pressure to significantly alter or replace these structures with something larger and/or more permanent in construction and this policy seeks to help protect the best examples. More guidance can be found here.

Interpretation

The Authority considers that appropriate interpretation of the historic and cultural environment is an important aspect to development or change in the area. Such interpretation could range from street names that reflect the heritage of the site and retention of a particular feature to art or interpretation boards. The aim is to provide the link to the past and ensure that visitors and the community are aware of what the site was previously used for, or what happened on the site.

Demolition

The Authority considers that where the loss of a heritage asset has been exceptionally allowed, it is important to ensure that before any works or demolition take place and the heritage asset is permanently lost, a legally binding agreement should be in place that will ensure the redevelopment of the site as agreed within a specified timeframe.

Reasonable alternative options

The original policy, with no amendments.

No policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Keep original policy: 5 positives. 0 negatives. 0 ? Overall, positive.

B: Preferred Option - amend policy: 5 positives. 0 negatives. 0 ? Overall, positive.

C: No policy: 0 positives. 0 negatives. 5 ?

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used and schemes are in general conformity with the policies.

Why have the alternative options been discounted?

The amendments to the original policy seek to make the policy clearer mainly, but also seek to make the policy stronger and so the preferred policy is favoured.

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Policy PODM13: Re-use, Conversion or Change of Use of Historic Buildings

  1. Wherever possible, the building or structure should remain in the use for which it was originally designed.
  2. The re-use, conversion or change of use of a building or structure which is a heritage asset (designated or non-designated) will only be permitted where:
    1. Development proposals appropriately re-use redundant or under-used heritage assets with the optimal viable use[57], securing their long-term conservation and enhancement, including of their setting;
    2. A structural survey demonstrates that the building is capable of conversion where applicable and conversion, re-use or change of use can be undertaken without extensive building works, alterations or extensions that would lead to substantial harm to or loss of the asset's significance. The public benefits of the proposal will be weighed against the harm or loss in accordance with national policy and policy PODM12;
    3. The proposal is of a high-quality design, retaining the external and/or internal features that contribute positively to the character of the building, including original openings and materials, and with minimal intervention to the original form and fabric of the building (e.g., new openings);
    4. The proposal can be achieved in a way that preserves the structure’s historic, cultural and architectural features and its character;
    5. The nature, scale and intensity of the proposed use are compatible with, and would not prejudice, surrounding uses, or the character of the locality; and
    6. It would not adversely affect protected species or habitats.
  3. For non-designated heritage assets, where it is not possible for the structure to remain in the use for which it was originally designed, employment, recreation or tourism uses (excluding holiday accommodation) will be the next preference. Conversion to residential uses, which includes holiday accommodation, will only be permitted where employment, recreation or other tourism uses of the building are proven to be unviable.

Reasoned Justification

In most cases, the most effective way of protecting and preserving designated and non-designated heritage assets is to retain them in their original use. However, where these buildings can no longer sustain the use for which they were originally designed, finding an appropriate alternative use for the building often represents the best way of protecting it. The sensitive re-use of historic buildings is also good sustainable practice, both in terms of making the optimum use of the embodied energy of the building and to maintain a local skill base in the restoration of historic buildings and traditional construction techniques.

Nevertheless, when considering proposals for the re-use of historic buildings, close attention must be paid to the design of any such conversion to make sure it is appropriate for the character and appearance of the building and would not adversely affect its context or setting. In particular, the loss of the primary fabric of the building and internal or external features that contribute to its character can devalue its significance. Some buildings will not be suitable for re-use, and development proposals should be accompanied by a structural survey undertaken by a suitably qualified independent Structural Engineer to help determine whether the building is capable of conversion without works that would have a significant detrimental effect on its character. In accordance with Policy PODM12, a Heritage Statement (included within the Design and Access Statement where required) should also be submitted to provide a schedule of the proposed works, analyse the impact of the proposal on any important features of historic interest, and provide justification for the proposal. Policy PODM12, including information requirements for and the determination of such applications, should be read in conjunction with the NPPG. Applicants are encouraged to discuss their proposals at an early stage with the Authority and, as appropriate, with Historic England.

Where a building is listed, its optimum viable use may be proven to be residential and subject to all the criteria 2a-f being met this may be considered acceptable to ensure that the building is retained or brought back into a viable use rather than deteriorating in condition and potentially becoming ‘at risk’.

Where it is not possible for a non-designated building or structure to remain in the use for which it was originally designed, preference will be given to re-using the building for alternative employment, leisure, or tourism uses that will have social and economic benefits for the Broads. Conversion of an historic building to a residential use can often have an adverse impact on its character, given the scale and nature of work required to meet the expectations for a permanent residence. For this reason, such residential conversions tend to be considered as a last resort. Applications to convert a non-designated heritage asset to residential use will be expected to be accompanied by a report, undertaken by an independent Chartered Surveyor, which demonstrates why economic, leisure and tourism uses would not be suitable or viable because of inherent issues with the building. Issues relating to the personal circumstances of the applicant or because of a price paid for the building will not be taken into consideration. Details[58] should be provided of conversion costs and the estimated yield of the commercial uses, and evidence provided on the efforts that have been made to secure economic, leisure and tourism re-use for a continuous 12-month period. This will then be reviewed, which shall be carried out entirely at the applicant’s expense.

‘Significance’ is discussed in the reasoned justification to Policy PODM12 on Heritage Assets.

Applicants should be aware that historic buildings, particularly those in rural areas, have the potential to provide important breeding and roosting places for several species protected under a range of legislative provisions, including bats, barn owls or other nesting birds. If the presence of a protected species is suspected, the applicant will normally be required to submit a survey, undertaken by a suitably qualified ecologist, to establish whether the species is present, whether the development would harm the species, and what measures are proposed to avoid potential harm. There may be a requirement to provide compensatory features, although such features should not impact adversely on the structure and should not preclude appropriate development where it might bring a redundant asset or Building at Risk into use.

For conversions or re-use of buildings that are not historic buildings (designated or non-designated), please refer to PODM61.

Reasonable alternative options

The original policy, with no amendments.

No policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Keep original policy: 5 positives. 0 negatives. 0 ? Overall, positive.

B: Preferred Option - amend policy: 5 positives. 0 negatives. 0 ? Overall, positive.

C: No policy: 0 positives. 0 negatives. 5 ?

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used and schemes are in general conformity with the policies.

Why have the alternative options been discounted?

The amendments to the original policy seek to make the policy clearer mainly, but also seek to make the policy stronger. Also, the changes may enable the ongoing protection of assets and so the preferred policy is favoured.

  • [55] Non-designated heritage assets are Locally identified heritage assets. They are buildings on the Local List as well as those identified as having positive contributors within Conservation Area Appraisals. ↑

  • [56] Further guidance can be found in the NPPG: www.gov.uk/guidance/conserving-and-enhancing-the-historic-environment#decision-taking-historic-environment↑

  • [57] Sustaining heritage assets in the long term often requires investment and putting heritage assets to a viable use is likely to enable the maintenance necessary for their long-term conservation. Certain heritage assets may have limited or no scope for new uses and indeed may be so sensitive to change that alterations to accommodate a viable use would lead to an unacceptable loss of significance. It is important that any use is viable, not just for the owner, but also the future conservation of the asset. The optimum viable use may not necessarily be the most profitable one. If there is only one viable use, that use is the optimum viable use. If there is a range of alternative viable uses, the optimum use is the one likely to cause the least harm to the significance of the asset, not just through necessary initial changes, but also as a result of subsequent wear and tear and likely future changes. ↑

  • [58] Please see our adopted guide on marketing and viability assessment requirements: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0019/407404/Marketing-and-Viability-SPD.pdf↑

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