We therefore recommend that any policy wording includes reference to the need for an appropriate great crested newt assessment prior to determination, in order to ensure that the allocation is supported by the appropriate ecological evidence.

This site is within an amber zone for great crested newts.
This species is protected in the UK under the Wildlife and Countryside Act, 1981. It is a Priority Species under the UK Post-2010 Biodiversity Framework. It is also listed as a European Protected Species under Annex IV of the European Habitats Directive.
Joint Core Strategy for Broadland, Norwich and South Norfolk (Adopted 2014) Policy 1: All new developments will ensure that there will be….. no adverse impacts on European protected species in the area and beyond….

Explore opportunities to access the far part of the site by alternative means (not across the open area to protect the setting of the barn). Amend policy wording accordingly.
Amend criterion 7 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.

Proposed development in neighbouring villages, will put further pressure on existing infrastructure within Hethersett e.g. local schools, doctor's surgery. Hethersett Surgery currently has a patient count of 22,083, making it the fourth largest in the county. Any increase in housing within its catchment areas will further exacerbate its capacity.

n/a

Representation on the Policies Map:

Sequence (UK) Ltd support the allocation of land south of School Lane and east of Burnthouse Lane as defined on the Little Melton Policies Map under allocation VC LM1.

Sequence would suggest that Policy VC LM1 is revised to read as follows:

"Policy VC LM1: South of School Lane and East of Burnthouse Lane

3ha of land is allocated for approximately 35 dwellings.
The developer of the site will be required to ensure:

- Access from School Lane, with potential secondary pedestrian and cycle only access onto Braymeadow Lane;
- Footway improvements along the School Lane frontage, to link with existing provision;
- Provision of a parking area within the site (adjacent to School Lane) principally for school use, the nature and scale to be agreed with the Highways Authority, the Education Authority and Little Melton Primary School, as appropriate;
- South-east section of the site to remain undeveloped, and the layout and design on the adjoining areas to protect the rural setting of the listed barn, as detailed in the Heritage Impact Assessment;
- Access across the southeast section of the site, between the two elements to be developed, to be sympathetic to the setting of the listed barn;
- Proposals for the site to secure the long-term future of the listed barn;
- Historic Environment Record to be consulted to determine the need for any archaeological surveys prior to development;
- Protection and enhancement of the ecological/biodiversity features of the site, including the established trees, hedgerows and ponds, including appropriate reinforcement of planting on the southern and western boundaries, to contain the development in the rural landscape;
- Early engagement with Anglian Water regarding the need to phase development within the catchment of Whitlingham Water Recycling Centre."

Sequence (UK) Ltd has promoted the land that is subject to residential allocation VC LM1 and supports the broad aims of the policy to deliver approximately 35 new homes, as set out in representations both supporting paragraphs 23.1 - 23.13 as well as the Policies Map for Little Melton defining the site.

However Sequence does object to Policy VC LM1 in its current drafting as it is not considered to be sound. In particular the policy is neither justified as it is not an appropriate strategy, nor effective in terms of being deliverable over the plan period (paragraph 35 of the Framework 2021).

The policy as currently drafted is inconsistent with other policies and allocations in the plan in that it does not set out the area of land to be developed in hectares, nor the number of dwellings.

Therefore the policy should be updated to include the following: '3ha of land is allocated for approximately 35 dwellings' consistent with paragraph 23.13.

This revision to the policy would ensure that the policy is sound and a full text is provided in part 6 of this response. This includes taking the opportunity to address 2 drafting errors as follows:

1) The policy title should change ‘or’ for ‘of’ so this reads “South of School Lane….” and

2) The penultimate bullet point should see 'tress' replaced with 'trees.'

These 2 drafting errors in isolation do not raise concerns with the soundness of the plan and can be addressed through modifications.

Sequence also confirms that the site remains available, deliverable and viable, as set out in the attached Site Promoter Engagement Form.

The small-scale nature of these allocations is unlikely to require phasing in respect of Whitlingham WRC and therefore the policy requirement can be removed.

See attached document.