A stated requirement to build energy neutral houses within this area should be included.

There should be additional requirements to require a full environmental impact statement, requiring due consideration for a number of protected species known to be present in the area, including bats and amphibians.
Additional requirements on developers should be imposed to make any development entirely carbon neutral, self sufficient in energy generation and consumption, use of community ground source heat pump technology, installation of solar panels on every house, domestic wind generator turbines and rainwater harvesting according to best available environmentally sustainable development practices.

FW Properties consider Site VC BRO1 to be a suitable and deliverable location for new homes within the village. Development in this location, which is in close proximity to an established community, would represent sustainable development as defined within the National Planning Policy Framework. Not only is Brooke an appropriate location for growth with its current provision of services and amenities including the village primary school but also the site is a short distance from Poringland.

Site VC BRO1 is located immediately to the north of the 12 houses previously developed by FW Properties in 2015 – it is the same landowner and developer therefore progressing the proposals for VC BRO1. The site is immediately available and its development for 50 new homes is considered to be viable and deliverable. The development will provide a mix of dwelling types and sizes to meet local needs.

Vehicular access for both parts of the site from Norwich Road, together with the connections to services, will be provided by way of two adopted highways from a new roundabout (unless otherwise agreed with the Highways Authority). Pedestrian access will be from new footways along the frontages of both parts of the site which will link into existing footways and footpaths. There will also be a safe pedestrian crossing point over Norwich Road.

The site is not subject to any delivery constraints which would prevent its development for new homes and FW Properties believe that the site specific requirements attached to this draft allocation can all be fulfilled. The scheme layout will include some frontage based development and will also link into the current footpaths in this part of the village. The mature trees along the boundaries of the sites will be retained as part of the overall landscaping and screening of the development.

On this basis, FW Properties believe that Site VC BRO1 should be taken forward for allocation as it will make a valuable contribution to the planned housing growth in South Norfolk in the period up to 2041. The site is outside the area currently effected by nutrients neutrality so FW Properties will submit the planning application for this development at the appropriate time.

Leave the site alone.

The site is home to a wide variety of wildlife - bats, amphibians, Red Kite, deer, rabbits, field mice etc. Development of this land would cause significant disturbance to the ecology and wildlife habitats.

A full flood alleviation plan must be undertaken and presented before application can be considered, this should include engagement with local residents to assess the damage the proposed development would surely cause them as a result of flooding. A full environmental assessment should also be undertaken in order to ensure the welfare of the protected Forna present in the proposed site.

The area outlined in the planning application is subject to annual flooding due to the heavy clay content present in the soil, to which I am sure the developer is aware having successfully had their 2015 development on the same site flood on multiple occasions resulting in damage to the properties post sale. Further more multiple protected species have been regularly seen on or around the site, including but not limited to: Bats, Dormice, Breeding birds, Badgers and Water voles, therefore a full environmental survey should be undertaken to establish the location of each of the protected species on site as well adjacent plots of land, and in the case of water voles a 500m boundary from the site should be surveyed by a qualified ecologist.

* give clear rationale for Brooke's allocation of 'up to 50'
* reduce the allocation to c30 - in keeping with other village allocations. This reduces extent of ribbon development whilst still contributing to the identified housing allocation
* make safety considerations a requirement with particular regard to a roundabout and clarify whether safe crossing point refers to pedestrian lights or zebra crossing
* include information about concomitant provision of medical/educational services
* indicate how many houses will be 'affordable'.

My concerns are:
* no rationale for allocation of up to 50 houses. Few other allocations exceed 35, so unclear why Brooke has this number..
* safety. Road through Brooke is very busy and will become busier if other proposed village developments proceed. Installation of a roundabout is a recommendation rather than a requirement. Will developers seek a cheaper alternative?
* impact on services. Document does not take into account impact on services, especially medical and educational (primary and secondary)
* ribbon development. Although within the village boundary, northern development brings it closer to Poringland, risking urban sprawl.

These are flawed proposals. The Village Cluster approach to housing distribution proposed is neither necessary nor desirable. It is unnecessary because the housing need requirement, together with a reasonable buffer, can be met without the need to disperse development in this way. It is undesirable because the additional dispersal of housing that will be generated via village clusters will cause an unnecessary loss of countryside and be more environmentally damaging than an approach in which development is concentrated in and near to Norwich.

This is an unwarranted and inappropriate development of a site which will cause ecological harm. It beggars belief that South Norfolk Council is enabling large scale housebuilding on our precious countryside. This developer is not motivated to tackle the housing crisis. Their main motivation, unsurprisingly, is to maximise their profits. This can be seen from their constant building on greenfield sites, despite enough brownfield land being available.

Update the HIA to include the land to the west of the road.
Amend criterion 9 to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’

Thank you for consulting Historic England on the South Norfolk Village Clusters Local Plan Regulation 19 Draft Consultation. 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.
Please also see our detailed comments in the attached table. We provide a summary of the main comments below.
SUMMARY
We very much welcome the completion of the Heritage Impact Assessments for a number of sites. The assessments have helped to inform many of the policies
providing helpful recommendations for mitigation and enhancement which is welcomed.
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 four issues.
1. Heritage Impact Assessments
We are delighted to see that Heritage Impact Assessments have been prepared for
many sites. However, there are a few allocations where we recommend the preparation on an HIA now prior to EiP (e.g. VC BRO1 West, VC WOR1). The policy wording should then be amended accordingly. In the absence of an HIA we consider these sites are not sufficiently justified. There are also some settlement limit extensions where an HIA should also be prepared now ahead of EiP (e.g. SN0020SL, SN0588SL). Finally, there are some recommendations in HIAs that have not been incorporated into policy. The policies need to be amended to incorporate these HIA recommendations. This applies to a number of sites as set out in the attached table. Further details of all the relevant sites are given in Appendix A.
2. Settlement Limit extensions
We note that the smaller sites have not been included as allocations but instead the settlement limit has been extended to include that land. However, there are some extensions which would have an impact on the historic
environment and yet, in the absence of a site-specific policy, we are concerned about how the recommendations of the HIAs and any necessary mitigation/enhancement will be secured through an appropriate policy framework. The NPPF (para 16d) makes it clear that Plans should contain policies that are
clearly written and unambiguous, so it is evident how a decision maker should react development proposals. Further advice on the content of policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315 Revision date: 15 03 2019. It states that, ‘Where sites are proposed for allocation, sufficient detail should be given
to provide clarity to developers, local communities and other interested parties about the nature and scale of development’.
3. Archaeology Criterion
Many of the policies include an archaeology criterion which states that ‘The HER should be consulted to determine the need for any archaeological surveys prior to development’. Whilst we welcome the inclusion of a criterion for archaeology, in our view some
assessment is needed to inform any planning application (rather than waiting until after permission is granted but before development). This is consistent with the
policy set out in para 194 of the NPPF. We therefore advise that the archaeology criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ This applies to a number of sites in the Plan.
4. Site-Specific Issues
We have raised a number of quite site-specific issues in relation to the Bressingham, Little Melton, Rockland St Mary and Tasburgh sites. See the attached table for
further details of our concerns.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes suggested 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 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 then please do get back to me. We suggest it would be helpful for us to meet and discuss our comments, resolve any outstanding issues and
begin to prepare a Statement of Common Ground. Please contact us to suggest some possible meeting dates.