Policy wording should reflect the proximity of the CWS and include a requirement for any application to ensure indirect impacts on the CWS are avoided, in particular from off-site routing of run-off water.

The proposal is in close proximity to Bracon Hall County Wildlife Site, which is sensitive to changes in water quality that would result from run-off from the application site. The current active planning application for this allocation site proposes directing run-off water from the site, via a road side ditch, to an attenuation pond immediately adjacent to the CWS, but it is unclear if the CWS is safeguarded from overspill from the attenuation pond.

This site should be removed from the Village Clusters plan based on the above points.

Part B
5.
We (Bracon Ash Residents Group) consider the continued allocation of BRAl in the Local Plan to be
unsound because the evidence it is based upon is out of date and no longer relevant. NPPF "Reviews
at least every five years are a legal requirement for all local plans (Regulation 10A of the Town and
Country Planning (local Planning) (England) Regulations 2012}"
1. Since the 2015 Local Plan which allocated BRAl for 20 houses, 23 large houses have been built in the village that satisfy the housing requirement, therefore BRAl is no longer required and should be removed from the plan. The sq m of these new houses far outweighs the total
proposed previously in the plan. The significant increase in housing in the adjacent village of Mulbarton should also be considered in this housing requirement equation. The local housing need assessment is therefore also out of date and needs to be reviewed.
2. The sustainability assessment is out of date based on the changing populations of both Bracon Ash and Mulbarton since it was carried out. Mulbarton population has increased significantly since the sustainability assessment for BRAl, with some 200+ new houses and
Mulbarton services are approximately 1km away with both the primary school and doctors oversubscribed. This means residents from any new houses at BRAl would to travel by car (not sustainably) somewhere else - at least Smiles plus. Fundamentally the site is not sustainable as Bracon Ash has No services. There would, therefore be no economic benefit to Bracon Ash from any new houses or residents, only additional traffic, flooding and loss of
agricultural land.
3. The footpath to Mulbarton remains unsafe and substandard with no physical way to resolve, constrained by private land that is unavailable and a substandard carriageway width on the adjacent B1113.
Other areas of consideration include.
4. The requirement to front houses onto and access the site directly from the B1113 will introduce an unacceptable increase in road safety. A list of recent accidents and video footage is available on request.
5 . . Introduction of an urban development into a rural, low density, diverse, village setting with historic buildings does not meet NPPF objectives "fostering well-designed, beautiful and safe places, with accessible services". The scale and density of this proposal remains unacceptable.
6. The requirements for good design and highway safety cannot agree. The highways requirement for road frontage house does not equal good design. The site is therefore not suitable as these fundamental policies cannot be satisfied.
7. The adverse impacts of BRAl "would significantly and demonstrably outweigh the benefits as outlined above". There is no "net gain" from this development it will be an overall loss.
This site under the definition in the NPPF is not "justified".
8. The policy does not take account of other approved and proposed industrial development around the village, the lack of a combined policy risks the village turning into an urban and industrial area by accident!!
a. approved solar farm, - Cranes Road
b. proposed solar farm, - South of Marsh Lane 75+ acres
c. 50m pylons (East Anglia Green Energy Enablement) all of which have a combined impact of the village.
9. The village is not against development as a principle and has supported the Long Lane selfbuild project and also the various infill buildings around the village that have made good use of land within the development boundary at minimum impact on resources and character.
This is how the "local people of Bracon Ash would like to shape their surroundings".
10. Engagement with the community on BRAl has been unanimously negative on the first application for 52 dwellings and on this recent proposal for 23 dwellings from FW Properties for all the reasons listed that include, scale, urbanisation, highway safety and No Services.
11. There will be a negative social impact on a well-developed supportive community of introducing an urban estate into the village.
12. There will be a negative environmental impact of loss of land and habitat and potential run off into a County Wildlife site.
13. There is a very large proportion of public objection to the development of this site as it is currently proposed.

Part B
6.
This site should be removed from the Village Clusters plan based on the above points.

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.

The parish council believes that this site should be removed from the plan.

Bracon Ash & Hethel Parish Council has the following submissions in respect of the South Norfolk District Council Village Clusters Plan. (Comments attributed to relevant points on the South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft) at https://southnorfolkandbroadland.oc2.uk/document/12 - points may be duplicated)

The parish council was of the opinion that the Local Plan was unsound because the evidence it is based upon is out of date and no longer relevant. The NPPF states that “Reviews at least every five years are a legal requirement for all local plans (Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012)” There is no evidence of any reviews having taken place.

Comments on carried forward allocations

25.25 BRA1 – Land at Norwich Road

A previous planning application (2016/0713) was refused by South Norfolk Council for the following reasons:-

“A development in this location would lead to the unacceptable urbanisation of the area, by virtue of its scale and mass being inappropriate adjacent to the rural character of the existing settlement. The extent of proposed development would result in an overwhelming level of harm to the rural character and appearance of this edge of village gateway location.

The proposed development is not considered to present sufficient public benefits to justify causing less than substantial harm to the setting of the Grade II listed buildings known as Home Farm House and Thatch Cottage, in particular in the case of Home Farm House where there will be significant loss to its open countryside setting from development to the north.

The proposed development does not represent a sustainable development, having regard to the three tests set out in the National Planning Policy Framework (NPPF), by virtue of the harmful impact on the character and appearance of the existing area through unacceptable urbanisation and the setting of the adjacent listed buildings which significantly and demonstrably outweigh the identified benefit of providing 20 new dwellings in a location (Norwich Policy Area) where a 5 year housing land supply cannot be demonstrated and is therefore contrary to the aims of the NPPF 2012.”

There are no services in the village with shops, schools and medical facilites not safely accessible on foot and with limited opportunity to widen the marrow pavement. The school and doctors surgery is already oversubscribed.

Drainage is a major concern with no realistic solution available to deal with surface water, the ditch indicated for drainage does not belong to the site and there are no reiparian rights to use this. Any run off could damage the Bracon Ash County woiildlife site so any drainage must be via a road side ditch.

The main sewers in the village are currently not large enough to cope with existing drainage and results in frequent significant flooding in Mergate Lane and Hawkes Lane, often consisting of sewage.

Access and egress from the B1113 is a serious concern and the requirement to front houses onto and access the site directly from the B1113 will introduce an unacceptable increase in road safety and will impact on existing accesses into this road from neighbouring agricultural fields and Poorhouse Lane.

A sustainability assessment prepared by AECOM on behalf of South Norfolk Council stated “that the option of increasing development at lower order settlements i.e. service villages and other villages is also considered unreasonable given limited facilities in these locations and given the various planning permissions that are in place it is important to bear in mind the JCS Policy 9 requirement that “The locations of the smaller sites will be decided in accordance with the settlement hierarchy.”
It goes on to say “There are however, a few limited opportunities to delete a proposed allocation at settlements where planning permission has not yet been granted and where allocation numbers are above the minimum level. Specifically at Poringland, Swardeston, Stoke Holy Cross, Newton Flotman and Bracon Ash / Mulbarton where there is the potential to delete a proposed allocation.”

Bracon Ash & Hethel was originally allocated 20 – 30 houses and this number has already been built. In a village with no facilities or suitable pedestrian access the parish council believes there has been sufficient new homes built in the parish to satisfy demand.

The parish council believes that this site should be removed from the plan.