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Object

South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)

Representation ID: 2922

Received: 07/03/2023

Respondent: Clayland Architects

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Unacceptable heritage impacts in conflict with NPPF and local Design Guides. There are no clear and convincing justifications as to why this development cannot be achieved on reasonable alternative sites which do not have this level of heritage impact.

Change suggested by respondent:

scheme should be reduced in size and scale to linear infill development to prevent isolated 'backland development'

Full text:

The HIA and LVA referred to in this policy are not available to review however it is considered unsound to allocate a site within this sensitive heritage setting of a Grade 1 Church (Church of All Saints, 205m) and Grade 2 Listed Buildings (The Close, 29m).
The Sustainability Appraisal (SA) Interim Report, May 2021 noted “SN0390 at Earsham standing out as very close” to Grade 2 Listed assets and should be considered within the immediate setting of their Listed Building. The SA concludes development of a site in this location could have “the potential to substantially urbanise the rural setting of The Close.” This negative impact on a Heritage Asset would cause a conflict to The NPPF (para 189, 193, 199 Policy 2. table 8. 2.) rendering this allocation unsound.
Inline with NPPF para 200- There are no clear and convincing justifications as to why this development cannot be achieved on reasonable alternative sites which do not have this level of heritage impact.
A Key Design Principle within the South Norfolk Place Making Guide (p.41) which should be considered in relation to this site seeks to “Ensure that key views to landmark churches, particularly those on the valley crest skyline are preserved and that new development protects and enhances the setting of landmark features.” This principle does not appear to have been observed with this allocation.