Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 2620
Received: 03/03/2023
Respondent: Broads Authority
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
Policy does not mention assessing the potential impact on the Broads.
2nd bullet point of the policy needs to mention assessing potential impact on the Broads, as is written in para 16.17.
Where it says in 2nd bullet point there is a need for a fill Landscape Assessment, is that a LVIA? Does it need to mention the term LVIA to make it clear what is required? For example, this policy talks about a Landscape Assessment whereas policy VC ROC1 talks about a Landscape and Visual Impact Appraisal. Why the difference?
Policy does not mention assessing the potential impact on the Broads.
Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 2869
Received: 07/03/2023
Respondent: Mr Nick Goodge
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
This proposal will only make matters worse along "The Street" in Gillingham on the dangerous ninety degree bend where it is not only "single file" traffic but also a bling ninety degree with cars parked on the road. Anyone in these new dwellings will need use that bend to get to Beccles for any shopping etc.
Don't build there
This proposal will only make matters worse along "The Street" in Gillingham on the dangerous ninety degree bend where it is not only "single file" traffic but also a bling ninety degree with cars parked on the road. Anyone in these new dwellings will need use that bend to get to Beccles for any shopping etc.
Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3170
Received: 01/03/2023
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
There are no designated heritage assets on site. However, the site is adjacent to the Gedleston Conservation Area. There is also a pair of grade II listed cottages to the west of the site at West End. Any development of the site has the potential to impact on the significance of these designated heritage assets.
We welcome the preparation of the HIA. The HIA recommends that development needs to respect the form and layout of the Kells Estate. This is reflected in criterion 2.
Bullet point 4 states that the HER should be consulted to determine the need for any archaeological surveys prior to development. In our view, some assessment is needed to inform any planning application.
We therefore advise that bullet point 4 should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
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.
Support
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3218
Received: 08/03/2023
Respondent: Saffron Housing
Agent: Brown & Co
We consider this form of development that is part of the draft allocation for this village, led by the green credentials of the locality would result in tangible benefits for the community and provide housing in a holistic and sustainable way in order to create a vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that residential development can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares.
We are seeking amendments to the policy to increase the potential number of units on the site. Having undertaken some initial work on the site, we believe that the site is capable of delivering up to 25 units. This is in accordance with paragraph 119 of the NPPF which seeks to ensure the effective use of land in meeting the need for homes and other uses. Plans confirming that up to 25 units can be accommodated on the site, accompany these representations as separate documents showing an illustrative site layout, and a concept layout with opportunities and constraints.
See attached document.