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

Object

Representation ID: 3144

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 3145

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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’.

Object

Representation ID: 3146

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 3147

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 3149

Received: 01/03/2023

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Plan states that maps showing site boundaries are included alongside the policies. However, this is not the case. They are not included in the PDF version of the plan but on separate individual settlement policy maps. It would be helpful if site maps were included in the Plan itself next to the policy.

Support

Representation ID: 3150

Received: 01/03/2023

Respondent: Historic England

We welcome the reference to the historic environment and landscapes in Objective 3.

Support

Representation ID: 3151

Received: 01/03/2023

Respondent: Historic England

We very much welcome the preparation of the Heritage Impact Assessments to inform the site selection process and site allocation policies.

Support

Representation ID: 3152

Received: 01/03/2023

Respondent: Historic England

We very much welcome the preparation of the Heritage Impact Assessments to inform the site selection process and site allocation policies.

Support

Representation ID: 3153

Received: 01/03/2023

Respondent: Historic England

We very much welcome the preparation of the LVAs to inform the site allocation policies.

Support

Representation ID: 3154

Received: 01/03/2023

Respondent: Historic England

We very much welcome the preparation of the LVAs to inform the site allocation policies.