The site must be kept to a maximum of five houses if it is not to negatively impact the landscape.

1. The site will visually damage the landscape. The Waveney river valley at Earsham is an attractive and unspoiled landscape; it is unlikely that any screening will be adequate to conceal 25 houses.
2. Loss of high quality agricultural land - the land in the area is regularly used to graze cows and sheep.
3. Loss of important wildlife habitats - the area is popular for bird watching and hosts a number of species at risk such as egrets, barn owls and bats. These species do not reside in hedgerows but are affected by artificial lighting and traffic.

Earsham Parish Council accepts that the number of proposed properties has been halved since the first consultation took place, but still feel that 25 properties is too many for the area. It is appreciated that concerns regarding the entrance to any proposed build has been taken into account, but the concern is still there given the number of extra vehicles that potentially could come with 25 properties, it could be anything between 40 and 75. Speeding is an issue in the village, despite the Parish Council having purchased two SAM2 machines and more recently have installed a speed reduction sign outside the school. The Police have installed a black box just last week to look at the increased speeding issues, and it is felt that more vehicles that come with more housing are just going to add to the problem especially in the School Road area.
Safety for the primary school children, as well as pedestrians, is of paramount importance as it gets so busy at school drop off and pick up times, also the village has seen a big increase in vehicles visiting The Old Mill with its numerous businesses on site (which is great for local economy) but the only way to get to The Old Mill is via Church Road or School Road, these two roads converge not too far from the proposed site EAR1. A recent housing development on School Road (Granary Close) has also added to the vehicle numbers in recent years. Earsham Parish Council would like further consideration to be given to reduce the number of proposed housing even further for site EAR1 if is is not to be discounted altogether please.

Earsham Parish Council do not have any reason to doubt the validity of the soundness or legality of the Plan, however Parish Councillors still feel the problems with EAR1 for any density of building will exist because of its proximity, nearby school and local businesses located at The Old Mill

The Policy should be amended to provide a linear infill development on a reduced size with aprx. 5 units. The remainder of the of 25 unit allocation could be delivered with reasonable alternative sites in the village.

The policy in relation to this site has been shown to be unsound throughout early rounds of consultation stages, local opinion, HELAA Assessments and Sustainability Assessments.
The site has numerous issues and restrictions which are well documented relating to Heritage, Landscape, Flooding, Access, Land Ownership, Proximity to School and Highways Access. It is not sound to allocate a site with this level of constraints where other sites have been demonstrated as preferable or reasonable alternatives.
After ‘discussions’ (which do not appear to be documented) the site policy remains unsound and the mitigations proposed do not compensate the potential harm development here would cause. It is noted other reasonable alternative sites which may be preferable do not appear to have been discussed at the same level, or given the mitigation policies this site has been afforded.

Amend Policy VC EAR1 to add the following wording as a policy requirement:
‘The site is underlain by a defined Mineral Safeguarding Area for sand and gravel. Any future development on this site will need to address the requirements of Norfolk Minerals and Waste Core Strategy Policy CS16 - ‘safeguarding’ (or any successor policy) in relation to mineral resources, to the satisfaction of the Mineral Planning Authority.’

Please see attached for full submission.

Amend bullet point 1 to reference lower density on eastern part of site and views of the church.
Amend criterion 4 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.