Please see attached.

Add criterion to read:
‘Protect and enhance the grade II listed Hales Hospital through careful layout, design and landscaping’.
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.

We particularly welcome the clear and robust policy wording with respect to hedgerows/trees in Policy VC ROC: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ and Policy VC LMI: ‘Protection and enhancement of the ecological/biodiversity features of the site, including the established trees, hedgerows…’

We recommend that similar policy wording is applied to the policies listed below to ensure that the Local Plan consistently provides robust protection for all hedgerows/trees on these allocated sites, as appropriate. Where removal of any part of a hedgerow or a tree/s is absolutely unavoidable, we recommend that policy wording should also include reference to mitigation measures and ideally reflect the updated biodiversity duty required in the 2021 Environment Act to have regard to the enhancement of biodiversity.

VC BB1 (Barnham Broom), VC BRE1 (Bressingham), VC HAL2 (Hales and Heckingham), VC SWA2 (Swardeston), VC NEE1 (Needham), VC WOR2 (Wortwell), VC NEW2 (Newton Flotman), VC SPO3 (Spooner Row), VC TAS1 (Tasburgh), VC BUR1 (Burgh St Peter), VC WIN1 (Winfarthing)
Hedgerows (Priority Habitat)

Local Authorities have a duty under the NERC Act 2006 and the Environment Act 2021 to have regard to the conservation and enhancement of Priority Habitats in their decision making. Hedgerows are listed as a Priority Habitat under the requirements of section 41 of the NERC Act.
Also of relevance is: National Planning Policy Framework, (NPPF), 179: ‘-To protect and enhance biodiversity and geodiversity, plans should…62 b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.’

Trees
Trees are given some protection in legislation, for example, from the National Planning Policy Framework (NPPF). However, we strongly recommend that the Local Plan provides fuller, more detailed and comprehensive protection as described above.
National Planning Policy Framework (NPPF), 131: Trees make an important contribution to the character and quality of urban environments, and can also help mitigate and adapt to climate change. Planning policies and decisions should ensure that……. appropriate measures are in place to secure the long-term maintenance of newly-planted trees, and that existing trees are retained wherever possible.