It is good that the dwellings will not overlook the existing bungalows but again we need a footpath along the development but my worries are still the excess traffic

My worry is that the extra cars will create a problem as all the local services are at the far end of the village. Walkers will also be hindered by this. We would request a footpath to be included.

No modification to the Plan but in respect of the Council’s site assessment as this appears at appendix B, my client would like to make the following points for consideration within the context of the emerging VCHAP and the HELAA as an when this evidence base document is next updated:
Part 3 - Access to the site. There is an existing gateway (access) onto The Street and approximately 6-8 meters from the sites Southern boundary. This was the original gateway for machinery etc. onto the field on the northern side of the footpath and can be reinstated to serve any
development on the site. Furthermore, there is considered to be appropriate visibility both northwards and southwards along The Street from this point of access.
Part 3 - Better Broadband for Norfolk – It is identified that the site lies outside of the proposed fibre installation area. My client has a 'tail' into the B4RN fibre broadband network on the plot at the northern end and the
main cable runs along the western fence line to the southern boundary.
Part 3 - Utilities infrastructure – My client was not aware that there were sewers crossing this site and indeed, considers this not to be the case.

My client supports the inclusion of their site known as land south of Green Pastures (site ref. SN3002SL) within the settlement boundary of Tivetshall St Mary as this is being redrawn as part of the emerging VCHAP process. The inclusion of my client's site within the settlement boundary is required on grounds of Local Plan 'soundness'. Please find statement (PDF) appended to this submission for further details.
Our Statement (PDF) also makes reference to comments made within the context of the Updated Site Assessments for Allocations and Settlement Limit Extensions supporting information/document
(SNDC, January 2023) and for the consideration of Council Officers in respect of the emerging VCHAP. We kindly request that this information is also used to inform the HELAA review of my client's site as and when this particular evidence base document is next updated.
No modification. We support the extension of the settlement limits of the Tivetshall St Mary Settlement Boundary as part of the emerging VCHAP process whereby it incorporates my client's site known as land south of Green Pastures (SNDC site ref. SN3002SL).
To seek the inclusion of my client's site known as land south of Green Pastures (SNDC site ref. SN3002SL) within the settlement boundary of Tivetshall St Mary within the context of the emerging South Norfolk Village Clusters Housing Allocations Plan (VCHAP).

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.