FW Properties consider Site VC HAL1 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 Hales an appropriate location for growth but the site is also a short distance from the services and amenities provided by the market town of Loddon.

Site VC HAL1 is located immediately to the north of the allocated site VC HAL2 which is currently being developed by FW Properties for 23 new homes. It is the same landowner and developer progressing the proposals for both sites with VC HAL1 to be delivered as a seamless second phase to VC HAL2. The site is therefore immediately available and its development for 35 new homes is considered to be viable and deliverable. The scheme will provide a mix of dwelling types and sizes to meet local needs.

Vehicular and pedestrian access from Yarmouth Road to VC HAL1, together with the connections to services, will be provided by way of the adopted road being constructed as part of the current development of VC HAL2.

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. Whilst the majority of the site has a low risk of flooding, there is a one in a hundred year surface water flow path which runs from north to south across the site. This has been incorporated into the site layout plan for VC HAL1 as a new public open space which will connect into Briar Lane for pedestrians only and the wider public footpath network. The scheme layout will also respect the former Hales Hospital heritage asset which is located to the east of the site.

On this basis, FW Properties believe that Site VC HAL1 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 it is FW Properties’ intention to submit the planning application for its development during Quarter 2 2023 so that we can then hopefully be on site with the delivery of these new homes by the end of 2023.

Please see attached.

Amend Policy VC HAL1 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.

Add criterion to read
Protect views of the grade II listed Hales Hospital from Briar Lane, careful layout, design and landscaping, including 1 and 1.5 storey dwellings in the north east of the site to protect and enhance the listed building as recommended in the HIA.
Amend criterion 5 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.