Request that the Council consider the inclusion of the frontage land of site SN0531 in the Village Clusters Housing Allocations Plan for up to 15 dwellings.

We suggest that a new assessment of the smaller frontage site will be considerably different from the Council’s original assessment of the larger site, and issues such as highways, heritage, flood risk and landscape impact will not be evident or as severe and more easily mitigated. Opportunities exist to connect to site to the footpath network to the west of the site as the intervening land is within the landowner's control, and no trees will require removal to obtain access. Any new dwellings could be very much in keeping with the character of the properties further north along Lower Road. The scheme would also be expected to deliver the 33% affordable housing policy requirement, subject to detailed technical work and the cost of any off-site infrastructure that may be required.

Rockland St Mary;
Plan is unsound;
The Local Plan is considered unsound in respect of a potential further allocation at Rockland St Mary as it has not properly assessed the potential of site SN0531 to be further reduced in size to comply with the Plans site size parameters and assessed accordingly.

Site SN0531 (land in the Heathcote Family control) was submitted to the Council as part of the previous ‘call for sites’ stage. The site included an area of land from the south of New Inn Road to land west of Lower Road, Rockland St Mary. Part of the site (the northern part) has been accepted as a proposed allocation and has been given the Policy/Allocation Reference VCROC1, which also includes the frontage site ref: SN2007 promoted by Durrants on behalf of Mrs Diana Davies and Mr Robert Loades. This site (VCROC1), is supported.

This ‘new’ representation is in respect of an ‘Omission Site’, i.e. part of the site SN0531 that is not proposed for allocation. The Heathcote Family have carefully considered the Council’s assessment of site SN0531 as set out in the Village Clusters Housing Allocations Plan – Updated Site Assessments Allocations and Settlement Limit Extensions (January 2023). Whilst it is accepted that a site of this size originally promoted may be outside of the scope of this Village Clusters Housing Allocations Plan, which generally seeks sites of between 12 and 25 dwellings, they do not agree with the Council's assessment that the site does not lend itself to easily being reduced in size. The Heathcote Family think that the site promotion can be reduced in size and are willing to do so, in order that it fits within the parameters of the Village Clusters Housing Allocations Plan i.e. smaller sites of between 12 and 25 dwellings.
The Heathcote Family suggest that the part of site SN0531 that fronts Lower Road, Rockland St Mary can be reduced in size and brought within the scope of the Village Clusters Housing Allocations Plan to accommodate 12-15 dwellings. It is acknowledged that this may require the village’s settlement boundary to be designated around the cluster of dwellings/buildings to the north, but a number of other settlements have their settlement boundaries in separate clusters, rather than contiguous (for instance Aldeby, Ashwellthorpe, Bramerton, Bunwell, Starton and Wortwell to name just a few). The cluster of dwellings to the north are clearly part of Rockland St Mary. The extent of the suggested frontage land is shaded red on the attached letter.

The Heathcote Family therefore request that the Council consider the inclusion of the frontage land of site SN0531 in the Village Clusters Housing Allocations Plan for up to 15 dwellings.

The Heathcote Family suggest that a new assessment of the smaller frontage site will be considerably different from the Council’s original assessment of the larger site, and issues such as highways, heritage, flood risk and landscape impact will not be evident or as severe and more easily mitigated. Opportunities exist to connect to site to the footpath network to the west of the site as the intervening land is within the Heathcote Family control, and no trees will require removal to obtain access. Any new dwellings could be very much in keeping with the character of the properties further north along Lower Road. The scheme would also be expected to deliver the 33% affordable housing policy requirement, subject to detailed technical work and the cost of any off-site infrastructure that may be required.

The impact and suitable mitigation would be required depending on ecological survey. Protection of the trees and wildlife would need adopting by a developer.

Suitable access identified to the highway to prevent potential incidents.

Development to be linear in line with existing village profile. The height, number and location needs to be identified to prevent impact on Yare valley views and surrounding valleys.

The Policy assessment highlights the implications. It does not address the ecological aspects such as impact on the wild life inhabitants in the trees, hedgerow and adjacent land. There is a colony of bats that utilise these trees which need consideration and management.

Further along the hedgerow badgers and other wildlife populate the location.

The exiting water pipe has frequent failures between its source and the village. Upgrades to both this and the sewage network which has failed at the rear to New Inn Hill/Green Lane in recent times.

Provision to safely access the site needs review.

Plan needs to consider an already threatened ecosystem and encourage biodiversity, rather than destroying or damaging fragile habitats.

The location does not consider the ecological and environmental pressures on Hellington Nature Reserve and an undesignated marshy field which is habitat to Common Spotted Orchids. The area is habitat for skylarks (red listed species), cuckoos, buzzards, bats, chinese water deer and muntjack, as well as a lot of the more common bird species.

In addition, increased surface water run off from urbanisation is likely to increase flood risk and alter the chemical balance of the groundwater, thereby altering the ecosystem viability of the beck and natural environment. Mature oak trees and root systems also need protecting.

Vehicular access onto The Street needs further analysis in terms of safety to both pedestrians and motorists.
25 dwellings will have a minimum of 30 cars, motorbikes etc - at peak times (morning and evening) the risk is considerable with very restricted visibility for emerging vehicles.

The owners of The Old Hall are benefit to a Restrictive Covenant from the Heathcote family (owners of proposed development land) clearly stating that they will have a right of veto over any development. This was instigated with the sole purpose of protecting the Farmstead and its environs. The proposed access onto The Street is clearly unsuitable for 25 dwellings - a serious safety issue. The Council have ignored their responsibility to “rigorously consider the impact of the development on Listed buildings and their setting” - this has not been evidenced in the grossly substandard HIA commissioned by the Council - the negative effects on The Old Hall Farmstead are immense; noise and light pollution, coupled with traffic volumes to name but a few….
If the Council continue to support this development, they must undertake to cover all legal costs incurred by the owners of The Old Hall in implementing the Restrictive Covenant.

The site is unsuitable due to poor access. It is not in keeping with the village building line.

The site is too far away from the centre of the village. This means that people will be using their cars to access the villages amenities like the shop, school and GP surgery increasing the volume of traffic on small country roads. The village doesn’t have adequate drainage system, the sewage pipes at the end of the village overflows when there is heavy rain. The village suffers from poor internet connection.

When permission was granted for Eel Catcher Close it was on the understanding that it didn’t set a precedence for further building on the site, however the opposite is now being stated.

Extremely poor vehicular and pedestrian access. The entrance is at the top of a blind summit. Previously there have been amber warning on access to Eel Catcher Close but for some reason this is no longer being mentioned. Nothing has changed to make it any less dangerous.

There is no footpath adjacent to the proposed site. The proposed footpath would mean people having no option but to cross on the blind summit or use the ‘additional’ footpath which would mean crossing the road on a bend to access the current footpath on the opposite side of the road. The additional footpath is next to Grade 2 buildings of historical interest and importance.

Rockland St Mary is a mainly linear settlement the proposed site is outside of this and out of keeping with The Street.

Planning has been refused twice in the past is this because it is unsafe and unsuitable?

I understand that a non evidence Heritage survey has been carried out, this does not seem to be adequate as it has missed that the proposed footpath is 1 metre away from listed building. The site is overlooked by The Old Hall this is a listed building, there is a heritage covenant stating no dwelling house can be built on that land.

A new housing development will be an eyesore for the birdwatchers and nature lovers walking the footpaths and visiting Rockland B-road. Sited on the hill any new development will be a visible for miles around and spoil the view from Rockland Broad.

It has been mentioned that an Oak Tree will have to be cut down, there is evidence of bats and owls living in the Oak Trees as well as the impact on the environment.

Evidence affordability allocation for housing
Evidence allocation priority for locals and, at least, Norfolk residents
Evidence concrete ideas for how to make footpaths and connections viable and safe for pedestrians
Show engagement with Anglian Water to ascertain drainage plan and issues - existing settlements subject to water flooding
How encourage residents at site to cycle or walk rather than drive into village?
How safeguard mature trees, wildlife hedging?
How ensure safe vehicular access to and exit from site?

Rural landscapes are undermined. Site assessment focuses unduly on landscape from ‘The Street’ but not from other vantage points in the village, fields and valley.
Natural habitat continuity and wildlife is under threat
Highways compliance: not achievable for safe pathways for pedestrian access and connection to services.
Inclusivity - disabled wheelchair access seems unachievable; VCROC1 encourages more car use into village.
v. Climate change: VCROC1 residents car dependant , safer to drive
vi. Utilities - at capacity for drainage, increase problems, health hazards and increased flooding in the village.
vii Affordability – no evidence, promised in Reg 18 consultations

Reduce plan to 4 or 5 houses end ways on to the road, or abandon plans altogether as access always going to be a problem.

Massive impact on a village that has just had 22 new houses on the other side of the road. Destruction of open access and views to the river valley for all residents this end of the village. Destruction of natural habitat. Very far from the village centre - almost a mile.
Houses refused in this area already as no precedent or need to extend the village boundary. Road access impossible. A dangerous hill and bend approach where traffic speeds up and removal of ancient trees and hedging would be needed. Eel catcher close would be enclosed on all sides if buildings were to go behind them, with very short gardens the veiws and privacy would be destroyed.
THe village is built in a line with all houses having open access to fields at the rear. THe ancient barn at the back of eel catcher close has protective covenant on the land .

Development not to proceed

1) The proposed development of the site would intrude into open landscape to the east of the village and is not in keeping with the historical linear pattern of development of the settlement.

2) It sits at the brow of New Inn Hill, which will cause limited visibility in both directions. The entrance and exit from Green Lane opposite the proposed site currently presents safety issues, with visibility restricted in both directions


3) Appointments at the local Doctors Surgery are difficult make with delays of weeks not uncommon.
Any increase in the see this situation deteriorate further

Given the harm identified and the fundamental access constraints it is clear this proposed allocation is unsound and no further development of this size be considered in the village to preserve the existing character of development within Rockland St Mary.

The site is not developable or deliverable because it will: increase traffic use to unsafe levels with dangerous exit onto New Inn Hill/The Street; increase footfall to dangerous levels on narrow and inadequate pavements; result in an exit road not wide enough while disrupting heritage buildings; seriously impair the heritage/visual appearance of the village and fundamentally change the character of the village, destroying the current beautiful long view; threaten local biodiversity, endangering flora and fauna, including the Common Spotted Orchid threatened by run off from the construction site into the steam system feeding the orchid marsh-field.

Much smaller development of affordable housing to mirror Eel Catcher Close.

Huge visual impact on landscape for the size of development with potential to continue to increase. Unsafe access as road narrows due to cars parked opposite. Unsafe increase of flow of traffic through the village with potential of 50 plus extra vehicles passing through or using shop, school and doctors. Close proximity to Broads causing damage to wildlife. Surface water and sewage capacity concerns.

Less than half the properties and to resemble Eel Catcher Close.

It will change the visual impact and character of the village and intrude into the landscape and destroy the wide open space there. It will have a negative impact on the Broads and wildlife especially affecting hedges and trees. Access small with limited vision splay. Unsafe increase of vehicles through the village. Impact on visitors/tourists to the village for the Broads, landscape, views and wildlife. Surface water drainage and sewage concerns as the Broads area has flooded before.

The development does not need to be any bigger than the existing Eel Catcher close.

Adverse affect to landscape creating a negative visual impact. Poor access for size of development. Added pressure of vehicles on the street which is busy already at peak times, especially if there are problems with surrounding roads. Development too close to the Broads and will affect wildlife in that area which has regular visitors. Could set a precedent to increase building there further into the future which is what has already happened after Eel Catcher close.

Ensure
Just one close to reflect what has already been built and ensure homes are affordable.

These homes are too be affordable but affordable to who? the young people living in this village on a minimum wage will not be able to buy these to stay in this village.
The access for more homes will impact on the one village road and its safety, also the impact to the environment and the arable land with more pollution being generated.

It should not proceed as it is based on an unsound HIA, fails to liaise adequately with Historic England's preferred methodology for assessing impact on Historic buildings, and proceeding will put the council on shaky ground legally due to the substandard HIA and the failure to identify the considerable harm to the historic buildings that developing this land would result in. At the very least the external HIA provided should be considered and adopted.

Structural assessment of the effects of a footpath on a listed building which would be less than 1 metre from the proposed footpath to the west of the site.

Impact on the Setting of Three listed buildings, adversely affecting both their understanding and their significance.

Three Grade II listed buildings lie in immediate proximity to this site: The Old Hall, a 17th century farmhouse, and two grade II listed 19th century former farm buildings converted to dwellings, which together make up a farmstead. Historically, the majority of the land that comprises the proposed site made up part of the landholding of this farmstead (evidence available).
These buildings are listed because of their national significance. The Glossary of the National Planning Policy Framework (NPPF), states that the ‘significance’ of a heritage asset such as these is derived ‘not only from its physical presence but from its setting’. With this in mind the value of a heritage asset is affected both by ‘views of or from an asset’ and the ability to ‘understand the relationship between the asset and its surroundings’.

In the case of this farmstead, its heritage significance lies in its architectural and historic interest as a group of agricultural buildings and associated farmhouse, typical of the region and periods, and their setting, which is rural in character and includes the agricultural land immediately adjacent to the farmstead to the South and East with which these buildings have had a long standing historical functional relationship. Some of this land is included in site VC ROC1.

The agricultural and open character of this land permits views outwards to the east and south from the farmstead, as well as towards the assets from this aspect. These views are across a largely unchanged rural landscape that is essential for an understanding of their former function and thereby an appreciation of their significance.
Residential development on this land therefore would erode the agricultural, rural setting to the south and east of the assets that not only contribute tangibly through visual attributes to the setting of these assets, but also through historic functional relationships relating to land use and ownership. This would be detrimental to an understanding of the historic significance of these listed buildings giving rise to substantial harm.

Historic England raised concerns at the Regulation 18 consultation stage with regards to the impact on the listed buildings listed above and suggested a heritage impact assessment be undertaken.
In a highly irregular fashion according to our legal advisors, the County Council ‘commissioned’ this themselves.

Unfortunately, it is of astoundingly poor quality, with little or no evidence of accuracy or sufficient detailed researching of the proposed site’s historic connections with the heritage assets.

Subsequently, an externally commissioned Heritage Impact Assessment has objectively concluded ‘the assessment of South Norfolk District Council to date has not adequately appraised of recognized the significance nor potential impact on these statutorily designated heritage assets’.
In fact it has found the Councils assessment to be woefully inadequate. It fails to identify the historic significance of the Old Hall as a former farmhouse with attendant listed former agricultural farm buildings. By extension, it fails to acknowledge the contribution that the land of VC ROC1, which shares a historical functional relationship with the farmstead makes to its significance, and subsequently has inadequately regarded it.

It has also entirely failed to identify a listed building in the farmstead 134B as distinct from another in the farmstead. It has wrongly located this and adjoining building, siting them as on the road frontage, when in fact they immediately adjoin the western site boundary. 134B is entirely outward looking onto the proposed site. Given that the visual and physical relationship with these building and the site has been completely incorrectly interpreted, the impact appraisal from the council cannot be relied upon.

Local authorities have a statutory duty to rigorously consider the impact of development on ‘listed buildings or their setting’. It is abundantly clear in the that they have failed to do that. The application of these statutory duties has been rigorously tested in the High Court and Court of Appeal (Mr Justice Lindblom, Forge Field Society v Sevenoaks DC [2014]).

We will have no hesitation in trying them for ourselves in Court if required, having sought expert legal advice in the last few weeks.

The guidance in the NPPF is clear that decision makers should ‘give great weight to the conservation of designated heritage assets’, with a ‘presumption against’ development that would give harm to settings of listed buildings.
The Council’s assessment’s failure to adequately understand the significance of the assets means that consequently it fails to accurately assess the potential for harm to them. The evidence base for appraising the site suitability is clearly unsound.
On this basis, this site does not even meet the basic test for soundness for positive plan making as set out in paragraph 190 of the NPPF and therefore the Council is ignoring its statutory duty to follow national planning policy.


Covenants on the land
The title deeds of The Old Hall as mentioned above (title number NK484850) has the following listed in the charges register ‘the owner of of land marked as 236 will not, without the the written consent of the owner of The Old Hall, erect any ‘dwellinghouses’ on any part of the land numbered 236’. We have attached the conveyancing plan for reference. Land marked 236 includes the whole area of the proposed development sight. This only adds weight to the significance of the link between the farmstead and land. We, the owners of The Old Hall, absolutely object to a contravention of this restrictive covenant for the purpose of development of this site, and as such would aggressively pursue this in a private legal proceedings if the site is approved.
Infrastructure and sustainability

The proposed increase of 50 dwellings to Rockland St Mary would follow the recent addition of 21 dwellings at Bee Orchard Way. This amounts to a 20% increase in total number of dwellings in the village in a few years. This is far more than is necessary or needed in a rural village, is a disproportionately large proposal for the size of our cluster, and more than the village can cope with, as itemised in the following points:

-The utility services in this area are already stretched to breaking point. Water is frequently cut off or reduced in pressure and UK Power Network have stated that there is no spare capacity for Electrical supplies. Drainage and sewers at this side of the village are also at capacity. Further development in this area will considerably worsen the situation and risks harm to flora, fauna the increased flooding. The site directly boardersThe Broads area which is a strictly controlled conservation area. Development in this site and is a flood plain. Increased run off would from the the site as a result of development could disrupt will disrupt this environment and excess water running down New Inn Hill could cause flooding at the Staithe and contaminate the waterways connected to the River Yare. To rectify the power, water and drainage issues to accommodate such an increase in housing would require a huge investment and would result in significant further disruption.

-The proposed site is a long way from the hub of the village i.e. near the shop, GP surgery and school. In fact it is over 1 km from the shop and 1.5 km from the school. This means inhabitants of the proposed site are likely to use their cars to access amenities. The village shop, surgery and importantly the school have little parking provision, necessitating people from the proposed site driving and parking on the The Street. The increased vehicle traffic poses a significant risk to pedestrians and cyclists and an inconvenience to villagers, particularly at rush hour and school pick up times. I would suggest the traffic impact from this site, particularly from the shop to the school is more considerable than at the other proposed site in Rockland, distance from amenities.



Precedents
The Regulation 18 document sited that the recent approval of the Eel Catcher Close development in 2017 set a precedent for development of the site. This is categorically not the case. Eel Catcher Close was deemed an ‘exception site’ for developing outside the Village Development Area, only because it was used for social housing. By definition an exception site cannot form a precedent for further open market residential development outside the boundaries of the settlement. This omission of detail in the ‘reasoned justification’, we assume was not intentionally disingenuous, but undoubtedly invalidates it as a justification altogether if the proposal is for private development.

Moreover, a precedent for permission refusal was set in May 2017, when an application for a single dwelling directly opposite site SN2007 was refused (2017/0638/O). The grounds for refusal were stated as " outside the development area, had an adverse effect on the character and landscape of the rural area, and was unsustainable". With this in mind we cannot see how the planning authority can support an application in the same location, for 25 times the number of houses, that would have a far more profound impact on the character and landscape of the rural area and much more unsustainable.

As part of the recent Greater Norwich Local Plan, the land owner of part of the proposed site at new Inn Hill initially proposed the development of 200 homes. This was met with 70 objections (only one other site had more objections). Approval of this site would no doubt result in the landowner pursuing the original number of dwellings, quoting precedent.

Access and highway safety
The road access to the proposed site is at a dangerous stretch of road close to junctions with Green Lane and Eel Catcher Close and would be at the blind brow of New Inn Hill. Green Lane is the only point of access to the village playground and the footpath to the Ted Ellis nature reserve and so levels of pedestrian traffic including young children are high and will only be higher were the development to proceed on this site. The access to the site is on a much used national cycling route. It has a blind and tight entrance. Further increase to local traffic, which could reasonably be predicted to be 50 additional vehicles at this site, would certainly add to what is already a dangerous spot. I would suggest that the allocation of an Amber listing for the Highways safety at this site dramatically underestimates the risk at this intersection.

With regards to the proposed footpath on the western boundary of the site, I have significant concerns. The proposed pathway would pass within 1 metre of a listed building (134B The Street). Not only would it entirely disrupt the privacy of the property internally and externally, but it risks damaging the structural integrity of the building in its construction, given that it is a 19th century agricultural building which likely has little by way of foundations and solid footing.
In addition, the route of the pathway makes is unsound in terms of safety, opening onto The Street at a location that has no pavement on that side (nor is there space on the verge for one) and is on a blind corner. This demonstrates that the proposal has entirely failed to consider the functionality of its plan.



Summary
In summary, the proposed development at VCROC1 should not proceed. The council’s HIA fails at the most basic level (it is unsound) and building on this site would significantly erode the significance and understanding of the Old Hall Farmhouse and Farmstead, going against guidelines outlined in the NPPF (please see the attached privately commissioned HAI for sound reasoning) ie its legality is questionable. The council’s use of exemption sites as precedents in the justification of the use of this site is a total contradiction, whilst failing to acknowledge the precedent it has set by refusing other planning immediately adjacent is hypocritical. Finally, proceeding would essentially be ignoring the concerns of over 70 people who objected during the Regulation 18, which was almost more than any other site in South Norfolk and would further erode trust in local government and its processes.

Review of and adoption of the external Heritage Impact Assessment we have commissioned or at the very least re-perform the HIA using Historic England's suggested methodology.
Highways Agency has not assessed the impact of the proposed footpath at the West site and how it meets The Street. If this is unsafe either due to its proximity to a Historic Listed building which exclusively looks out onto it and cannot proceed, there is no other practicable, safe pedestrian access to the site.

The heritage impact assessment (HIA) performed by the council regarding the preferred site VCROC is so unsound and erroneous that not only does it call in to question the overall assessment of the VROC1 site, but it must also raise serious concerns about the Heritage Impact Assessments done at all other sites which are part of the Village Clusters Housing Allocation Plan.

The HIA fails on even the most basic of tasks, for example it
1. Fails to even correctly identify which houses are listed as part of The Old Hall farmstead.
2. It appears to have been only assessed from the road, which doesn’t follow basic HAI methodology
3. 134B Small Barn is listed and faces almost exclusively onto the VC ROC1 site, contrary to what the HIA states. The proposed budling and footpath would come within 1 metres of this listed building and 2 metres of a kitchen and living room window.
4. It does just about manage to identify that the Old Hall and the surrounding listed former farm buildings were once part of a farmstead, but does not link that the only farmland still in direct contact with the farmstead was formerly part of the farm.
5. Furthermore, it failed to go even a small step further to identify that amputating the farmland from the historic farmstead would erode the agricultural setting of the farmhouse and farmstead (looking outwards from and to) and would give rise to harm to the historical buildings by diminishing the understanding and significance of them.

The HIA is so lacking in basic detail and evaluation that it cannot be trusted to make sound evaluation of the VC ROC1 site. Developing on the VC ROC1 site will cause significant harm to a historic listed farmhouse and farmstead, and is completely at odds with the statutory duty to follow the National Planning Policy Framework (NPPF). Causing harm to historical buildings by developing next to them and going against the NPPF, has been tested in court and is something we will have no hesitation to do if the proposed Regulation 19 goes ahead.

Please see Objection from Louisa Godley and Julie Church which elaborates further and provides a privately commissioned HIA for the site which unlike the council’s is based on sound methodology and analysis.

Surveyor’s reports needed on the structural implications to existing listed buildings.
Perform a sound heritage impact assessment or review and adopt the attached independent heritage impact assessment

In the introduction to its Heritage Impact Assessments report the Council states that the role of the heritage impact assessment is to:-

“identify key heritage assets and settings that may be affected by new development on sites considered for inclusion within the VCHAP”
“understand the significance of the heritage asset, including the features that contribute to its significance”
“explore the impact of development on the significance of the heritage asset and/or the setting”

The Council has FAILED in all of the above roles and, as such, NO WEIGHT can be given to the contents of that report with regard to the proposed development of the land. This is evidenced as follows.

The report has completely FAILED TO IDENTIFY a listed property (page 132). Legally, any heritage impact assessment should be made from the geographic perspective of the proposed development site and it is clear that this was not the case or Small Barn, 134B The Street, a Grade II listed property (List Entry number 1050428), could not fail to be identified, as it has an open aspect over the entire site. The “neutral” impact rating given in the report is therefore null and void. Reference has only been made to Old Hall Barn (with which Small Barn shares its listing number), the Northern aspect of which runs adjacent to The Street.

Secondly, page 131 names List Entry 1050429 also as Old Hall Barn. This property is not Old Hall Barn (see previous paragraph) but Tall Barn.

The National Policy Planning Framework states that “Significance’ in terms of heritage-related planning policy […] is defined as the value of a heritage asset to this and future generations because of its heritage interest. Significance derives not only from a heritage asset’s physical presence, but also from its setting”. It is clear that the agricultural setting of the three listed buildings (The Old Hall and its associated barns (now converted to residential use)) is key to conveying an understanding of their history and irrevocable links with the agricultural land which lies adjacent to the South and East. Furthermore, the original farmstead survives in its entirety which further strengths its heritage value. Moreover, the Deeds to all properties contain covenants stating that residential development cannot ensue without consent of the owners of The Old Hall. These restrictions in themselves highlight the strong historical connection between the farmstead and its setting.

The fact that the Heritage Impact Assessment has not only completely failed to address the issue of the significance of these heritage assets, along with the complete OMISSION of an entire heritage asset which overlooks the whole site, cannot fail to call into question the soundness of said report and, as such, demonstrates that it cannot be relied upon as a decision making tool in the planning process.

The Introduction to the Heritage Impact Assessment states that Grade II listed buildings are classed as having “Medium” significance. This does not correspond with their conclusion that the impact of any development would be “neutral”. By definition, a Grade II listed building is one which “is recognised as being of national importance” and statute dictates that the setting of that building is integral to its heritage value.

In conclusion, it would therefore be illegal and morally wrong for any development to take place on proposed site allocation VC ROC1. Indeed, should the need arise, we would have no hesitation in taking legal action both with regard to individual covenants and the complete lack of robustness of the Heritage Impact Report, the preparation of which has been undertaken by the council, which we understand is surprising, such reports normally being commissioned by an independent assessor.

A precedent for permission refusal was set in May 2017, when an application for a single dwelling directly opposite site SN2007 was refused (2017/0638/O). The grounds for refusal were stated as "outside the development area, had an adverse effect on the character and landscape of the rural area, and was unsustainable". With this in mind, I cannot see how the planning authority can support any application in the same location, for 25 times the number of houses, that would have a far more profound impact on the character and landscape of the rural area.

1) There is a covenant attached to The Old Hall, which prohibits the development of of the proposed site VCROC1, and the rest of the adjoining field. And the house developed within the curtilage of the Old Hall in 2018 retains the same benefits of that title.

2) The Eel Catcher Way development is not a precedent - this was an exception site limited to social housing, not private housing.

3) The planners have not taken into account the listed buildings to the west, and have failed to list all the listed buildings amongst the documentation, and it's vital their setting is protected.

4) The public utilities cannot cope with the additional housing. UK power network advised our neighbours when building their property in 2018 that there was 'zero capacity' for additional housing.

5) In 2017, the planners refused permission for a single-story dwelling directly opposed the proposed site - yet they now seek to build 25 dwellings in the exact same location - which is illogical.

Provide the outcome of the Amber flags issues raised in Reg 18.
Provide information regarding social/affordable housing at the proposed site.

Outstanding/unanswered points
• ‘Amber’ flags regarding Highways and Heritage/Landscape/Visual landscape concerns raised during HELAA/site survey have not been resolved satisfactorily.
• The developments will result in a significant vehicular impact across the whole village.
• The proposals are in conflict with the stated Objective 3 of the South Norfolk Village Cluster plan which is to “Protect the character of their villages and settings” – which are a natural asset for the County.
• The proposals for Rockland St Mary provide no evidence of or commitment to affordable or social housing, as per Annex 2 of the NPPF.

plan should be abandoned, and not viable in many respects.

The plan has changed since the original call for sites. There were a huge number of objections and these have been ignored. The two sites have now been put together and there seem to be no sense of reaction to the objections to the plan. This would increase the nitrate levels that drain into the Yare from the top of New INN HIll. It will destroy the only breathing space where all the villagers walk their dogs . It would create a dangerous and impossible place for a road junction. All dog walkers park in the dyke car park and cross lower down as the top of the hill is a dangerous spot. There is no precedent for building here, as social housing was put in this place with very strong provisions for no more houses here. The legal process does not seem to have been followed in that the red warning from the highways department has been ignored. The open space is the only one in the village and it is enjoyed by everyone. The houses in eel catcher would be enclosed in an estate, removing all space and open access. There is a protected barn beside the close that is legally protected as far as the adjoining land is concerened. No one seems to have visited the site or made a proper impact survery. I am disgusted that this site was even suggested. We villagers have had enough of large developers trying to cash in on rural landscape.

This is a large development for this area. So I would expect the following:
All the houses need to be affordable and in keeping with the village structure ie along The Street and not behind it. Improvements to infrastructure required as part of plans - such as water & electrical supply to accommodate additional load on system. Note existing black outs and low water pressure issues.
Plans to improve travel links through the village and the link to Norwich for bikes, cars and pedestrians. The main link road is already busy and realistically Norwich is likely the main employment and services hub for this development so an increase in motor vehicle traffic is inevitable. Also note these roads are already becoming increasingly risky for walkers and cyclists with increasing traffic.
Long term as well as short term assessments of the impact on the local habitat/environment - especially where it is likely increasing the load on an already overloaded Broad ie Rockland Broad & Surlingham Broad.
Impact assessment on flooding from additional run-off with realistic practical long term methods of mitigation.

In summary : Large high value private housing attracts 'second home' owners and unlikely to be affordable to the local community that needs them.
Local infrastructure impacted. Rockland St Mary already suffers low water pressure, eletrical blackouts.
Nutrient Nutrality and no mention of an Habitats Regulations Assement anywhere I can find.
Rain water run off and additional sewage load on the system.
Development behind existing houses out of character with the village.
Poor road, cycle and public transport links to and from nearest employment areas & amenities.

Given that a planning application for a single storey dwelling was refused in 2017, as it was deemed it would have an adverse effect on the character and landscape of the area, it would be impossible for the LPA to justify permission for a development of 25 homes.

The proposal is not sound, nor is it complaint .

In particular, the plan falls far short in assessment of the Grade II Listed buildings which are situated adjacent to the site. The Heritage Impact Assessments carry little credibility ; they have been carried out in a slipshod manner, containing many errors, the most significant of which is the omission of one Grade II Listed property which has an open aspect over the entire site.

The development of this size in this location is completely unsuitable in terms of road safety, existing utilities and the rural nature of the village.

Trust in the process has waned due to an unsatisfactory and inaccurate evidence base.

The plan is not sound or compliant.

Objective 3 of the South Norfolk Village Cluster Plan is to ‘protect the character of their villages and settings’ and the plan does not concur with this objective. Additionally, the Heritage Impact assessments are not sound and therefore cannot be used as a decision making tool in the planning process.

To place a development of this size at this site would harm the village in every way possible. Historically planning permission has, rightly, been refused at this site and there can be no justification for that decision to be overturned.

The site needs to be significantly reduced to mirror Eel Catcher Close and could therefore share that access way and continue the linear style of the village.

This site will cause a visual detrimental impact on the landscape which is currently open. It is not in keeping with the latest development, Eel Catcher close and looks to dwarf this site. Also have concerns that this site could be extended further in the future. The access is unsafe and not big enough and does not have enough vision splay . There will be an increase of traffic through the village to access the school, shop, Drs and commute to Norwich. Detrimental to the Broads and wildlife which this village is known for and has visitors for that reason.

A smaller development of no more than 10 dwellings like Eel Catcher Close and so affordable housing, to run alongside Eel Catcher to continue the linear style of the existing village.

Unsafe access way which appears very tight for the size of this development. The site is too large and will intrude into the landscape creating a detrimental visual impact. It is very close to the Broads which brings visitors to this village for the rural views and wildlife which will both be impacted by a development of this size. There will be an increase to flow of traffic through the village on a road that is already busy and used as a rat run from the A146. Surface water and sewage concerns.

Amend Policy VC ROC1 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.

We strongly object to the proposed designation of the above site for residential development as, in our view, it is not legally compliant, nor is it sound, for the following reasons:-
1. In designating this site, planners have taken no or insufficient note of its distance from village amenities (shop and surgery about 1.3km, school 1.6km approx.), which would cause dangerous long walks or, more likely,
many more traffic movements on a very dangerous stretch of road. Access from VCROC1 to the road would be precarious, on a bend on the crest of the hill.
The alternative site proposed VCROC2 is much nearer school (0.3km ) and the shop and surgery adjoin that site.
2. The planners have taken no account of the group of listed buildings to the west of the site. It is important that they and their setting be protected.
When a proposed development could harm the setting of listed buildings, there is a strong presumption against planning permission being granted, which planners have completely ignored. This is a statutory obligation,
proven also by legal cases ( Barnwell v East Northants and others ). No development, and thus presumably no designation for development, that could harm the listed buildings or their setting should be permitted.
3. The public utilities do not cope with the existing load, let alone this additional proposal. Water supplies are off at least once a week, either in or near the village and the supply is not fit for purpose. When building our house UK Power Network advised that there was" zero capacity" for
supplying any additional dwellings. The foul drainage system is also at capacity and surface water run off is already common place on Low Road and would worsen with new development, as proposed.
4. The planning authority have stated that the development of Eel Catcher Close, adjoining VCROC1 to the west and north, is a precedent. This is absolutely not true as Eel Catcher Close was an exception site, thus
restricted to social housing and cannot be taken as precedent for subsequent private development. Otherwise every exception site would have a large private development on adjoining farmland.
The planners have also chosen to ignore the fact that in 2017 they refused planning consent for a single dwelling directly opposite this site (2017/06380/0 ). That is precedent and it is absolutely inconsistent for them to now seek to designate 25 dwellings in the same location.
5. On 19.08.1992 we purchased the Old Hall, Rockland St Mary, which adjoins VCROC1. In 2018 we built a single dwelling within the curtilage and thus share the same title from when the The Old Hall was originally
sold away from ownership including site VCROC!, on 16 June 1960. In that original sale there was a covenant which prohibited the development for housing of the whole of VCROC1 and much of the rest of the field,
absolutely proving that the relationship between The Old Hall and its curtilage ( now including Meadow House, where we live) and the adjoining land ( including VCROC1 ) is of great importance. For clarification we
subsequently sold The Old Hall to the present owners.
In the early stages of this consultation over 70 letters or submissions objected to the original proposal. Apart from planning considerations, this is part of an important open landscape overlooking the Yare valley, has amazing wildlife including owls, buzzards and skylarks, and is well used by dog walkers and parishioners. It would be very sad if this land is allowed to be developed and in our view we believe that should not be the case.

The consultation process needs to be re-started with a new compliant website.

Proposal should be refused.

Having visual difficulties and having confirmed with a member of the MIND team the website fails to conform to the web accessibility legislation 2018. I and 8 neighbours in Eel Catcher Close have found the website impossible to navigate, impossible to register (no password code sent after email put in) and PDFs on the site will not magnify or indicate letters large enough. The consultation process needs to be re-started with a new compliant website.

Eel Catcher Close would be enclosed by houses destroying access to fields. There is a covenant protecting the land behind Eel Catcher Close for social housing. We have just had 21 new houses built at Bee Orchid Way opposite and there is no excuse to exceed the village boundary. Proposal should be refused.

Add wording to criterion 4 to read ‘Careful consideration should be given to the relationship of the footpath to the listed barn and appropriate materials used’.
Add new criterion to read:
‘The most western part of the site should be left open to protect and enhance the setting of the listed buildings.’
Amend criterion 5 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 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.