A.32. The preparation of the
Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 2495
Received: 27/02/2023
Respondent: Collins & Coward Limited
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The sustainability assessment does not look at school, employment or health capacities in the villages.
Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3043
Received: 08/03/2023
Respondent: South Norfolk Green Party
Legally compliant? No
Sound? No
Duty to co-operate? Yes
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.’
Mention should be made that houses will strive to attain zero carbon and use low embodied carbon materials in construction.
Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3051
Received: 08/03/2023
Respondent: South Norfolk Green Party
Legally compliant? No
Sound? No
Duty to co-operate? Yes
This car dependent form of development will increase emissions and is inconsistent with the following paragraph from the NPPF:
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.
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.
Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3199
Received: 01/03/2023
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We are concerned at the over-reliance of GIS distance-based analysis for the Sustainability Appraisal (paras 5.3.7 – 5.3.10). The report itself comments of the limitations of this and states that it is not technically appraisal. And little or no potential to reach conclusions on significant effects. The report uses the example of biodiversity features. The same issue applies for heritage assets.
We do however welcome the preparation of Heritage Impact Assessments (noted at para 5.3.18)
The analysis at section 9.8 seems to pick up on the findings of the HIAs and also the inclusion of many of those recommendations in the supporting text or policies of the Plan which is welcomed.
In future SA reports, please ensure the correct notation is used for listed buildings e.g. grade1 should be grade I, grade 2 should be grade II.
The findings of the Analysis on pages 69-95, further highlights our concern that some of the analysis has been overly focused on distance.
We note that Scheduled monuments do not appear in Table A.