Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

A. Introduction and Background

A.1. South Norfolk Council recently adopted the Greater Norwich Local Plan (GNLP), produced jointly with Broadland District and Norwich City Councils, which identifies how many homes need to be built between 2018 and 2038 across the three Council areas. Within the overall housing requirement, the GNLP sets a target for a minimum of 1,200 homes on new allocations across 48 Village Clusters in South Norfolk. To meet this target, the South Norfolk Village Clusters Housing Allocations Plan (The Village Clusters Plan) aims to deliver sustainable growth within the villages of South Norfolk, in accordance with Government's national planning policies and guidance.

A.2. The Plan seeks to allocate a series of smaller sites, typically within the range of 12 to 50 homes, across the 48 Village Clusters, to accommodate at least 1,200 new homes. The Plan also defines the Settlement Limits for the villages within these clusters, making provision for further smaller sites and incorporating revisions to reflect development that has occurred, or has been permitted since the boundaries were last updated. The threshold of 12 dwellings for allocations is consistent with the GNLP and reflects the fact that sites smaller than this are less likely to achieve the required element of affordable housing.

A.3. The Council previously published a Regulation 19 pre-submission version of the Village Clusters Plan between 23 January and 8 March 2023. The Regulation 19 version of the Plan was the one which the Council intended to submit to the Secretary of State for Examination in Public and, ultimately, adopt as part of the Local Plan. However, following the close of the Regulation 19 publication period it became apparent that a site of 25 dwellings in Rockland St Mary (VC ROC2) could no longer be considered achievable, as a suitable vehicular access cannot currently be delivered. Combined with a reduction in 5 dwellings on VC TAS1 (Tasburgh) in response to concerns raised by Historic England, the total allocations in the Village Clusters Plan fell below the minimum 1,200 dwellings required by the GNLP.

A.4. The Council assessed several options for addressing the shortfall including: extending allocations already published in the Regulation 19 document; reviewing 'reasonable alternative' sites from the earlier Regulation 18 consultation; and assessing a handful of new sites submitted during the 2023 Regulation 19 period. Between 11 December 2023 and 5 February 2024, the Council consulted on Alternative Sites and Focused Changes to address both the shortfall, plus a small number of other issues which had emerged during the Regulation 19 publication. A series of 13 sites which could replace the losses and potentially make a modest increase to the numbers were presented. These were selected taking into account the three Plan Objectives set out in the January 2023 Regulation 19 document. The Regulation 18 focused consultation asked three key questions:

• How big should the buffer be above 1,200 dwellings to ensure that this minimum number is delivered between now and 2038.
• Were the sites presented suitable for allocation?
• Was there anything specific that should be taken into account when developing any of these sites, and which could form criteria in a site-specific policy for the site, if it were allocated?

A.5. The representations to the focused Regulation 18 consultation have been assessed by the Council, and the Council's responses are set out in the Part 4 of the Statement of Consultation. The Statement of Consultation also details the representations and Council responses from the previous Regulation 18 and Regulation 19 stages. The Council is now publishing a final series of proposed changes to the 2023 Regulation 19 plan, as an Addendum to that document.

A.6. Following the focused Regulation 18 consultation, the Council is proposing:

• three new sites (VC BAR2, Barford, for approximately 40 dwellings and community facilities; VC BRM1, Broome for at least 12 dwellings; and VC EAR2, Earsham for up to 25 dwellings)
• four extended sites (VC DIT1 REV, Ditchingham, extended by 10 dwellings; VC GIL1 REV, Gillingham, extended by 5 dwellings; VC SPO1 REV, Spooner Row, extended by 20 dwellings; and VC WIC1 REV, Wicklewood, extended by 10 dwellings)
• one site with increased density (VC SWA2 REV, Swardeston, increased by 10 dwellings)

Consequently, the sites published in this Regulation 19 Addendum are expected to meet the minimum GNLP requirements, as follows:

This consultation

A.7. The current consultation is under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012. Comments can be submitted between 9am on Monday 12 August 2024 and 5pm on Monday 7 October 2024. Details on how to submit comments can be found on the Council's website at https://southnorfolkandbroadland.oc2.uk/. Further advice can be obtained using the following:

• Email: localplan.snc@southnorfolkandbroadland.gov.uk
• Call: 01508 533805
• In writing:
  Place Shaping Team
  South Norfolk Council
  The Horizon Centre
  Broadland Business Park
  Peachman Way
  Norwich NR7 0WF

A.8. It should be noted that this consultation only relates to the proposed modifications in the Addendum. The remainder of the January 2023 Regulation 19 document is (a) not part of this consultation and (b) will be taken forward to be submitted to the Secretary of State subject to the changes proposed through this addendum.

A.9. The consultation is set out in two main parts:

Part 1, Cluster Chapters - for those Clusters where substantial changes are proposed from the 2023 Regulation 19 document, such as new sites, amended sites, changes in site capacity and/or significant changes to the policy criteria, an updated Cluster chapter is included. Changes from the 2023 Regulation 19 document are illustrated with new text in red and deleted text struck through. These Chapters are intended to replace in their entirety the equivalent chapters in the 2023 Regulation 19 plan. Those Clusters chapters are:

• Barford, Marlingford, Colton and Wramplingham
• Bawburgh
• Ditchingham, Broome, Hedenham and Thwaite
• Earsham
• Gillingham, Geldeston, and Stockton
• Mulbarton, Bracon Ash, Swardeston and East Carleton
• Rockland St Mary, Hellington and Holverston
• Spooner Row and Suton
• Tacolneston and Forncett End
• Tasburgh
• Wicklewood

Part 2, Schedule of other major changes – this schedules sets out a list of other factual modifications to various Policies, and consequential changes to supporting text, including updates to the site areas of several allocations, so that the text accurately reflects the Policy maps. This schedule includes a proposed change to the Monitoring text in the Plan which sets out that once development on the Village Cluster Plan allocation sites is complete, they will be considered to be inside the Settlement Limit for the purposes of future planning applications and decisions. This schedule also notes that a number of other minor factual updates will also need to be made to reflect issues such as the publication of an updated NPPF in December 2023 and adoption of the GNLP in March 2024.

A.10. In addition, a full set of Policy Maps has been published alongside this consultation document, where relevant these reflect the changes made as part of this Addendum.

A.11. During the Regulation 19 period anyone may make a formal representation relating to the soundness of and/or legal and procedural compliance of the Plan. Further guidance relating to this is available in the accompanying Representation Form Guidance Note at the link above.

Supporting Evidence

A.12. In preparation for the Regulation 19 Addendum, the Council has updated key elements of the evidence base, which are published alongside this document. These are:

(6) Sustainability Appraisal (SA)

A.13. The scope of the Sustainability Appraisal was established with the specified bodies in accordance with legal requirements in autumn 2020. SA commentaries have been used consistently as part of the decision-making process throughout the preparation of the Plan.

A.14. An update to the SA has been produced to consider the addendum sites in the context of the Plan as a whole and is available as part of the Supporting Documents.

(1) Habitats Regulation Assessment (HRA)

A.15. The Habitat Regulations Assessment (HRA) has been prepared to identify European sites within or near the Village Cluster area that may be directly, or indirectly, affected by the allocations within this Plan and concludes on whether there are any significant effects likely as a result of the Plan proposals.

A.16. The HRA has been updated to reflect the final choice of sites included in this addendum document, as well as taking on board the adoption of the GNLP and the proposed approach to Nutrient Neutrality. The HRA is available as part of the Supporting Documents.

(2) Heritage Impact Assessments (HIA)

A.17. Following advice received from Historic England, Heritage Impact Assessments (HIA) have been prepared for selected sites which may impact on heritage assets (Listed Buildings, Conservation Areas, archaeological remains etc.). The HIAs have informed the site selection process and helped shape the detailed allocation policies for the preferred sites in both the January 2023 Regulation 19 document and this Addendum.

A.18. Relevant new or updated HIAs have been prepared for six of the sites in this Addendum and are available to view as Supporting Documents. In addition, several other HIAs have been prepared or updated in response to previous representations received and/or to reflect the most up-to-date information available.

(3) Landscape and Visual Appraisals (LVA)

A.19. Following the 2021 Regulation 18 consultation it was determined that the site selection process would benefit from Landscape Visual Appraisals (LVAs) to consider in greater detail the potential landscape and visual impact of developing rural sites, often on the edge of a settlement. LVAs have been completed for all of the sites in this Addendum, with the findings being used to inform the site-specific policies where appropriate. These LVAs can be found in the Supporting Documents to this consultation.

(2) Strategic Flood Risk Assessment (SFRA)

A.20. Stage 2 Strategic Flood Risk Assessments (SFRAs) specifically focusing on sites within the South Norfolk Village Clusters area were undertaken to both inform the choice of sites and help develop the policies in the January 2023 Regulation 19 document. The SFRA was updated following legislative changes made in Autumn 2022 and this also required and update to the Stage 1 element of the SFRA. The latest SFRA documents can be found as part of the Supporting Documents.

(3) Water Cycle Study (WCS)

A.21. The South Norfolk Water Cycle Study (WCS) builds upon the WCS produced to support the production of the GNLP. The South Norfolk element provides specific information relating to the sites within the Village Cluster Plan area, taking into account existing commitments and development outside the Plan area that connects to Water Recycling Centres (WRC) within the Village Cluster Plan area. This work has been updated as part of the final choice of sites for this Addendum, including re-engagement with stakeholders and use of the latest information from Anglian Water. The latest WCS can be found as part of the Supporting Documents.

(3) Viability Appraisal (VA)

A.22. An updated Viability Appraisal (VA) was prepared to support the January 2023 Regulation 19 Village Clusters Plan. This included looking at the potential impact of addressing Nutrient Neutrality. The purpose of the South Norfolk VA was firstly to confirm that the small-scale sites in the South Norfolk Village Clusters locations remain viable taking into account the latest data, including increased building costs, and secondly to identify whether the development typologies identified would generate sufficient surplus, over and above a normal developer profit, to cover any increased costs associated with Nutrient Neutrality. Given the length of time that has elapsed since the December 2022 version of the VA, and the continued volatility of the development sector, a June 2024 update has been produced and is available as part of the Supporting Documents.

Composite Regulation 19 Document

A.23. To assist with understanding the contents of this Addendum in the context of the 2023 Regulation 19, a composite document has been produced which shows all of the proposed changes within the overall Regulation 19 document. This composite document does not form part of the current consultation, and is for information purposes only, to aid understanding of the highlighted changes in the Addendum and how they fit with the overall Village Clusters Plan.

A.24. As noted above, several factual updates have also been included in the Composite document, which reflect the updates to the Supporting Evidence summarised above, plus other changes, such as the publication of a revised National Planning Policy Framework in December 2023. These will be highlighted in a schedule of minor changes which will accompany the submission document.

PLEASE NOTE:

A.25. The preceding sections set out the context for the Addendum consultation and will not form part of the final submitted Village Clusters Plan.