Add criterion to read:
‘Careful layout and design to keep views open, retain visual prominence of windmill and incorporate views of windmill from public spaces’.
Amend criterion 6 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.

Notwithstanding our opposition to the whole concept of village clusters Hempnall Parish Council does welcome the fact that none of the other sites (other than VC HEM1) put forward by landowners/developers for inclusion in the SNVC plan have progressed in to the documents that are being circulated in the Regulation 19 consultation and we re-state our strong opposition to the inclusion of any further sites in Hempnall other than VC HEM1.

Hempnall Parish Council challenges the decoupling of the housing allocations for the South Norfolk Village Clusters and its associated policy from the rest of the GNLP as being unsound. The GNLP Regulation 19 consultation commenced before the South Norfolk Village Clusters Housing Allocations document (SNVCHAP) was published for its Regulation 18 consultation. This was despite the South Norfolk Local Development Scheme (accessed 18 February 2021 when it was labelled as “final”) stating that the SNVCHAP would be consulted on in February/March 2021, whereas it took place later in the year, ending on 2 August 2021. While it is reasonable for a Local Plan to comprise several separate documents, the GNLP and the SNVCHAP to be sound should follow the same, or at least a very similar timetable, otherwise it is impossible to judge whether the two (or more) documents are based on proportionate evidence.
Now that The SNVCHAP has progressed to its Reg. 19 consultation phase the difference in timelines between the GNLP and the SNVCHAP has become even more pronounced and this potentially renders both plans unsound. The outcome of the GNLP’s Public Examination with regard to issues around the SNVCHAP is currently unknown and until the Inspectors clarify these matters the soundness of the SNVCHAP is open to question.
These challenges to the GNLP included questioning the housing numbers, which if found to be unsound, would impact on the numbers to be allocated in the SNVCHAP. The housing numbers within the draft GNLP include the 1,228 in the draft SNVCHAP, within a total delivery target of 49,492 new dwellings to 2038. This figure would accommodate 22% more houses than “need”, along with a “contingency” location for growth. Additional housing, on top of these 49,492 will be provided by windfall development which will be in excess to that accounted for in the 49,492 figure, as only 1,296 windfall dwellings have been included, despite the Reg. 19 GNLP document forecasting that 4,450 windfalls will come forward during the plan period. Across the combined districts covered by the draft GNLP, sites already allocated by the current Local Plan, the Joint Core Strategy (JCS), should be delivered before there is any consideration of additional new sites, including all of those within the SNVCHAP. This is because any newly allocated sites will be in less sustainable locations than those already allocated in the JCS, and will therefore make it more difficult to adhere to Climate Change targets. The SNVCHAP is a means to deliver a policy of dispersal of housing, in largely less-sustainable car-dependent locations, with few employment opportunities. The development of greenfield sites, often on Best and Most Versatile (BMV) agricultural land, should be avoided.
To address these issues and to make the two plans sound they should run to the same timetable. As outlined above the inclusion of unnecessary housing numbers within the SNVCHAP in unsustainable locations makes the SNVCHAP unsound.
Given that the housing numbers proposed for inclusion in the GNLP could be found to be unsound and unnecessarily large this reinforces the view of Hempnall Parish Council which is that there is no need for additional sites to be allocated for housing in the village as part of the South Norfolk Village Clusters Plan and indeed there is no need for any allocations to be made anywhere in South Norfolk via the SNVCHAP.

Hempnall Parish Council policy states that the current recent development at Willow Drive together with infill (windfall) developments and the hoped for provision of social housing on the site now called VC HEM1 is considered the right amount of new housing for the village. In total these developments will increase the number of houses in the village by around 10% - a manageable amount which will enable the successful assimilation of the new households into the community but not an over large number which would threaten the character and environment of Hempnall.

Notwithstanding our opposition to the whole concept of village clusters Hempnall Parish Council does welcome the fact that none of the other sites (other than VC HEM1) put forward by landowners/developers for inclusion in the SNVC plan have progressed in to the documents that are being circulated in the Regulation 19 consultation and we re-state our strong opposition to the inclusion of any further sites in Hempnall other than VC HEM1.