It is my opinion that the agricultural field site south of Mill Road Ellingham for 25 units renders the VCHAP unsound for the following reason:
There would be a requirement to update the sewage network in Mill Road as it is not fit for the present dwellings as due to the lie of the land sewage can back up to the drains that the new site would connect to.
There is flooding in the road where the site would exit in spite of recent efforts to improve this.
The site exit is blind to the left, the road there is too narrow for cars to pass a bus. Surely no developer would want the expense of widening the road even if it were possible.
Residential amenity of at least one property would be severely adversely affected.
Open views to the Ellingham Mill Conservation Area would be compromised.

If the site approved then the original allocation of 12 houses would have less impact on the road structure and local residents.

I believe the development to the south of Mill Road is unsound for the following points.
Major issues with visibility at bends and at the junction.
Problems with surface water drainage
A loss of landscape views to the Church and surrounding area.
The impact it will have to existing dwellings in Mill Road
It is outside the village development area
25 houses amounts to a large estate and not a village cluster

Bullet point 4 does not really reflect what it is in the LVA – the LVA indicates a need for substantial planting, but the importance is not portrayed in the policy wording and needs improving.

Site is approximately 300m north of the nearest BA boundary.

Unfortunately, the LVA does not fully consider impacts on the Broads. However, it acknowledges that there will be long views to the site from the south (BA area), and identifies a need for substantial planting to contain the site along the southern boundary. This is supported.

Bullet point 4 does not really reflect what it is in the LVA – the LVA indicates a need for substantial planting, but the importance is not portrayed in the policy wording and needs improving.

On behalf of the landowner, we continue to support this site in line with our previous representations made in July 2021.

In relation to the specific requirements set out within the drafted policy, we comment as follows:

• 1.87ha of land for 25 dwellings – we agree that this is a much more rational site area that will lead to a logical extension of the existing settlement and will ensure the delivery of a more appropriate density of development.
• Highways works – we continue to agree that the necessary access requirements from Mill Road and offsite highways improvements in the form of appropriate carriageway widening and provision of a 2m wide footway to the recreation ground are necessary to make this development acceptable and provide wider benefits to the village.
• Promotion of 30mph speed limit on Mill Road – we agree with this policy requirement and consider this will provide wider benefits to the village.
• LVIA – We acknowledged in our previous representations that we recognise the particular landscape sensitivities with this site due to its location within the River Valley landscape area and proximity to The Broads, as well as heritage considerations. However, it should be noted that these same sensitivities apply to the entire village. We therefore agree that any planning application will need to be supported by an LVIA. We consider that the increased preferred site area provides additional opportunities to deliver a sensitively designed scheme considering all of the landscape and visual sensitivities.
• Layout and boundary treatments – We recognise and agree that there is a need to sensitively consider the layout and boundary treatment of a future scheme to ensure it respects the site’s location as a transition from the village to the rural area. Again, the increased site area and expected lower density will provide more opportunities for this to be delivered appropriately.
• Residential amenity – We agree that the impact on the residential amenity of existing properties on Mill Road will need to be considered carefully through the detailed design process. We consider that this is not an insurmountable issue and there is ample space within the site to ensure that the impact on existing properties is minimised.

We continue to consider the site to be suitable, available and achievable, and therefore deliverable within the Plan period.

The land should have been brought down to road level as planned but no one wanted to know. We now pay the price.

I live opposite the seven houses already built on the land already allocated for the new builds. Since they have been built, we get their seven houses worth of rainwater coming down their paved driveways, across the road and down our driveway, of three bungalows, flooding it completely. You have to wear waders or wellies to get to the road. It has even reached the front door of the first bungalow. We have to endure this stress with each reasonable rainfall and can't imagine the effect that twenty five more would have.

To make the allocation sound, the Highway Authority will require that it is extended to include the full frontage of Mill Lane from number 81 to the recreation ground.

Please see attached for full submission.

Amend policy VC ELL1 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.

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.