Para. A5; Policy BAW1 - Not sound
The allocation of 35 units at Bawburgh (BAW1) is not sustainable. It will not enable the village to grow and thrive. The school is over-subscribed. The local doctors surgery, the Humbleyard Practice in Hethersett, is over-subscribed by 5,000 people. Bawburgh is not part of a cluster of nearby villages as confirmed by Council officers in their briefing to Parish Councils on 26.01.2023. Answer to Question 25: "The village is not clustered with others...". The allocation is unsound and fails para 79 of the NPPF.

Para. A7; Policy BAW1 - Not sound
The proposed allocation BAW1 is 1.4ha therefore contrary to Paragraph 69 of the NPPF.

Para. A13; Policy BAW1 - Not sound
The Bawburgh Primary School serves just the single parish of Bawburgh. It is over-subscribed. There is no capacity to extend the school and the proposed housing allocation could not viably fund any extension to the school.

Para. A27; Policy BAW1 - Not sound
The Council's assessment criteria fails to consider appropriate densities for propose sites. It suggests 25 units per hectare which is an urban densities not appropriate to rural allocations.
25 units are proposed on 1.4ha under BAW1. The most recent permission (2018/1550) was for 10 bungalows on 1.13 ha (i.e. 9 units per ha). BAW1 should be the same density of 9 units (bungalows) per hectare.

Para. A32; Policy BAW1
The sustainability assessment does not look at school, employment or health capacities in the villages.

Para. 6 - Not sound
Bawburgh is not part of a village cluster

Para. 6.3 - Not sound
The primary school has no capacity and is over-subscribed.

Para 6.5; BAW1 - Not sound
The site exceeds 1.0ha which is the upper limit as prescribed by para 69 of the NPPF. The new development of bungalows (10 units) permitted under 2018/1550 has a density of 9 units per hectare. BAW1 should be same density and comprise bungalows.

Para 6.6; BAW1 - Not sound
The proposed site has open views to and from the A47 contrary to para. 6.6
The form of any new development should respect the existing form of dwellings and village hall. New development should be bungalows.

Para 6.11; BAW1 - Not sound
Only 1 ha should be allocated at a density of 9 units per hectare. The development should be bungalows.

Policy BAW1 - Not sound
The design of dwellings should be bungalows to reflect form of existing development as the site is on the top of the plateau. Only 9 units to be developed on 1 hectare.
Modifications:
Allocation BAW1 -
Reduce site to 1.0ha
Max density 9 units per ha
Form of development to be bungalows

Yes, I do wish to participate in a hearing sessions.
It is essential to present evidence to show allocation BAW1 is unsustainable in terms of employment, education and health. The proposed allocation BAW1 is at inappropriate density add the site is too large. Bungalows rather than houses.

Mention should be made that houses will strive to attain zero carbon and use low embodied carbon materials in construction.

We can find no mention of houses being built with installation of low carbon technology or increased use of low embodied carbon materials in construction.
Table 3.1 and 6.9
Houses : 'Support timely delivery of an appropriate mix of housing types and tenures to ensure supply of high-quality housing across the village clusters which meets the needs of South Norfolk residents and diversify the housing market to help maintain delivery.’

Evidence is needed to show how emissions will be reduced. Good low carbon public transport services should be provided between villages which have been formed as 'clusters' and share facilities such as shops, surgeries, schools and other basic conveniences.

Evidence that houses will be built with installation of low carbon technology and increased use of low embodied carbon materials in construction.

The car dependence of new development makes the plan inconsistent with the following paragraphs from the NPPF:

152:
The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

154:
New development should be planned for in ways that:

b) can help to reduce greenhouse gas emissions, such as through its location, orientation and design. Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.

This is inconsistent with sporadic development in villages that do not have facilities such as shops, surgeries, schools and other basic conveniences accessible by means of low-carbon transport. Indeed the opposite is true - this car dependent form of development will increase emissions.

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.