Remove site VC NEE1 from the allocation or materially reduce it in size. Instead allocate the site opposite (Greenacres, 11 High Road) as it is already a residential plot with significant roadside screening. Alternatively extend the Needham settlement limit to include Greenacres, 11 High Road and the frontage of Elm Farm.

A full objection statement and evidence to support alternative allocation at Greenacres, 11 High Road (including appendices) is provided as attachments.

Policy VC NEE1 results in the loss of a greenfield site on the edge of the village, when there are more suitable alternative reasonable options available. It is therefore not 'justified' as per paragraph 35b of the NPPF. It is important for Needham to retain the VC NEE1 site as an open field as it helps preserve the rural setting of the village by preventing a continuous line of development from the A143 roundabout. Development opposite site VC NEE1 would be more 'consistent' with paragraph 119 of the NPPF (effective use of land....while safeguarding the environment).

The development of site VC NEE1 should be considered in conjunction with the site opposite the Village Hall and Church. This will provide housing benefit and has the potential to enhance the village services by the provision of additional parking for the village hall and church. The original decision to exclude was made on inaccurate assumptions.

South Norfolk Village Cluster site ref: SN0156 & SN0156REV

Site opposite village hall, High Road, Needham

The development of site VC NEE1 should be considered in conjunction with the site opposite the village hall and church to benefit the contribution to the regional housing shortage and enhance village services/sustainability.

It has been stated the site opposite the village hall/church, High Road, Needham is not considered suitable for development based on defined reasons that are incorrect.
As part of the consideration of the above site it was commented: The site is adjacent to the settlement limit and the services of the village are accessible as there is a continuous footpath along High Road. However, the site is within the river valley with open, uninterrupted views from and of the Listed church. It would have a significant detrimental impact on the setting of the church and within the landscape, from the Angles Way trail and the wider footpath network.
We are proving a point of clarification in respect of the soundness of comments and assumption made regarding the above site.
The area around the aforementioned subject site has limited visibility from the Angles Way, only the church tower is visible, and when trees are in leaf the Church is not visible from the river valley or wider footpath network that runs in the river valley. (Please see the attached photos). We therefore believe the reason stated when considering sites in the village as suitable for development are not fully justified and based upon incorrect assumptions.
The river valley is also obscured from the roadway by various trees growing on the borders of the various fields, and doesn’t provide any particular uniqueness that wouldn’t be offset by the regional and local benefit of providing additional housing, improving the sustainability of the village.
It is also important to note that the site could be developed in such a way to protect an area in front of the church entrance to maintain views, and even provide space for parking for the church/village hall - on street parking is a known problem, particularly when the church is used for larger events (eg weddings, village hall events), as there is insufficient parking at the village hall. (See image attached)
The site has been considered in the past by social housing providers as suitable for development and the provision of housing so we were surprised it was excluded from provision during this process. This site could compliment the already allocated site (to the north of High Road) and enhance the utility and sustainability of the village.
In the past the site has also been approached to use land to improve drainage within the area. Development of the site would allow these improvements and therefore improve village services.
The footpath provision along High Road could also be improved.

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.

Modify supporting text to read:

The site currently has no network connectivity to the sewer system, therefore early engagement with Anglian Water is recommended regarding the requisitioning of new connection or the developer to consider alternative on-site treatment subject to the necessary permits.

Modify policy text to read:

Early engagement with Anglian Water regarding the requisitioning of new sewer connection or the developer to consider alternative on-site treatment.

See attached document.

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.