QUESTION 1: The Village Clusters Plan needs to ensure the allocation of 1,200 dwellings on new sites, for delivery in the period up to 2038. In terms of the overall number to be allocated, which of the three options above do you consider the most appropri

Thank you for consulting Norwich City Council on the South Norfolk Village Cluster Plan.

We are pleased to see that the plan is moving forward and progressing as the plan will help deliver much needed homes within the Greater Norwich area and contribute towards meeting the housing targets sets out within the emerging Greater Norwich Local Plan.

As previously, we do not intend to comment on individual sites or the policy approach; however we are keen to encourage that development is planned for in the most sustainable way. Therefore any decisions should be informed by the Sustainability Appraisal and prior to finalising and submitting the plan for its examination, South Norfolk should be satisfied that the policy approach and the sites chosen will deliver housing in a sustainable manner.

Thank you for the opportunity to provide comments on South Norfolk Council’s Focused Regulation 18 Consultation on Alternative Sites and Focused Changes for the Draft Village Clusters Housing Allocations Plan (VCHAP).

National Highways is a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN), which within the area this includes the A11 and A47.

National Highways’ wishes to continue to be involved through the production of the Plan, in particular to issues and proposed allocation sites relating to Transport issues and the Strategic Road Network in the area. It is acknowledged that the that once adopted, the VCHAP will become part of the Development Plan for South Norfolk.

Regarding the letter you sent us dated 6 December 2023. We would like to tell you that any work for new housing does not fall within the area of influence affect of our association.

We would like to stress however that should any new housing be considered in any area of South Norfolk that adequate provision is made for there to be regular bus service and also for provision where possible for bus shelters and for up to date timetable information.

We reluctantly support option (i ) and reject the other two options, our rationale is that there is a need to maintain the village culture within Norfolk as villages rather than small townships. We believe any further material developments, particularly in our area of Barford, will place unmanageable pressure on already oversubscribed services such as Gp practices, dentists schooling etc. An example of our concern is that fellow villagers are already being asked to leave their nearest Gp practice after 40 years due to excessive patient numbers.

There has been a very thorough review of the final selected sites by South Norfolk Council with the minor shortful of the 1200 now made up by the same, thorough, identification process. However, given the Plan is to be scrutinised by the Secretary of State's Examiner, we agree it is sensible to add a carefully considered buffer to ensure sufficient dwellings are available in the event of any rejections.
We consider option three above of 60 - 70 dwellings to be appropriate and adequate given the indepth review and selection of the sites by South Norfolk Council.

Barford and Wramplingham Parish Council consider that Option 1 is the most appropriate. The GNLP already includes a significant housing delivery buffer. Therefore, releasing a large buffer of extra land on greenfield “village cluster” sites is unnecessary.
We continue to question our grouping with Marlingford & Colton as a village cluster when there are so few facilities and no shops on the ground. (Many of the businesses that show up on a google search are digital and not servicing residents). In addition, Barford is approximately 4 miles from the nearest accepting doctors’ surgery (Humbleyard Practice), there is no public transport, and we understand that many residents must travel even farther afield.

See attachment for full representation.

See attachment for full representation.

See attachment for full representation.

Option 1 (i) - 30 Dwellings. Releasing as few greenfield sites as possible is of paramount importance to protect rural Norfolk's special character.

If a buffer is required it should be at the minimum required, as set out in the previous consultation, to avoid setting aside too many greenfield sites.

See attachment for full representation.

Option One is the least worst in the case of the Barford cluster, where your planning officers have made errors and omissions in the level of facilities and amenities available. The cluster cannot support large numbers of new houses. Details provided of: absence of shops, removal of employment, misidentified plantation, failing flood scheme, B1108 traffic hazard and struggling GP service.
1. "there are several specialty (speciality??) shops across the cluster's settlements." I only know of a beauty salon, three pubs (two currently closed) and the garage on the Watton road (described to me as "a life saver on many occasions" by a friend in Colton) that you are planning to knock down for VC BAR 1
2. "There are several industrial and commercial units located within the centre of the village, which provide local employment opportunities." You are proposing to remove around three of these to develop VC BAR 1
3. "the popular plantation on the east side, positively contribute to the form and character of the village." Do you mean the bat willows that have been commercially harvested (they were quite popular) or do you think that they are poplar trees; which they are not?
4. "Much of the central part of Barford forms part of the Barford Flood Alleviation Scheme which helps to control flooding in the village" Correct, but there is insufficient thought, planning given as to how the water exits the scheme to the River Tiffey. There is only one route, through a network of private ditches, not all well maintained. They are privately owned, not accessible by digger and largely have to be hand dug by ageing landowners.
5. Either of the schemes proposed for the village of Barford would lead to an increased number of vehicle movements crossing the carriageway of the B1108 as they attempt to turn right into the village on a double blind bend. Unfortunately it is a very gentle bend that does not slow the traffic down. Many vehicles do not obey the 40mph and tend to continue travelling at the national speed limit.
6. The villages lie in the Humbleyard GP practice area, which is already struggling with the amount of new build houses AND is a six or seven mile round walk from the village, there being no public transport to Hethersett (or Cringleford, let alone Mulbarton)

If new houses need to be built to match demand then those new developments should be chosen with the utmost care, attention and consideration for the environment and communities around the site.

If a site is chosen, it should be done so without consideration of ‘outside pressures’ or persuasion and focus on the facts of the location and whether it is suitable.

In particular, decision makers should consider whether the *quantity* of new houses is in proportion to the existing houses in the area - factoring in other developments in the area in that calculation.

Local utilities, amenities, infrastructure and services should all be sufficient to support the development - residents have a right to be able to see their doctors for example, and new residents should easily and conveniently be able to travel in the local area to the development using public transport.

Flooding is a real problem in many areas of south norfolk, and if a site is near areas prone to flooding - then covering surfaces with non-pourous materials will further exacerbate the issue. As would building ‘up stream’ or on higher ground to those flooding areas - as water that would usually soak into the ground would be forced into (potentially overrun) sewage systems.

Finally, historic precedent set by previous planning permission applications on the specific areas should be very seriously reviewed - development decisions need to be consistent with historical decisions.

We have no comments to make.

See attachment for full representation.

Question 1) - The Village Clusters Plan needs to ensure the allocation of 1,200 dwellings on new sites, for delivery in the period up to 2038. In terms of the overall number to be allocated, which of the three options above do you consider the most appropriate?

It is noted that as a result of a review of the selected housing allocations, some sites have been removed from the proposed Plan or the number of dwellings proposed to be allocated have been reduced. We therefore feel that it is sensible to include a healthy buffer to ensure that the Plan delivers sufficient dwellings, as some further sites may be rejected by the inspector or can’t be delivered for other reasons. Option (ii) therefore represents the most appropriate approach. It should also be noted that there are other shortlisted sites that have not been allocated and one in particular ref: SN0274REVA /B which was regarded as a ‘shortlisted site’ which represents an available and sustainable location for additional housing located outside of the Nutrient Neutrality catchment zone.

Question 10a) - Do you agree with the proposed allocation VC GIL1 REV, South of Geldeston Road and Daisy Way, Gillingham, on 2.92ha, for approximately 40 dwellings. Please explain your response.

Yes, this is fully supported, the site can easily accommodate approximately 40 dwellings as evidenced by the illustrative site layout submitted with planning application ref: 2022/1993. The site is very well located, as it is adjacent to the school and can offer the school expansion land, public open space, affordable housing and suitable access connections to the village and the commercial development to the north-east. As the planning agents for this planning application, we are working with all agencies to ensure that all aspects of the development comply with Council policy. It should also be noted that the site is located outside of the Nutrient Neutrality catchment zone. The Flood Risk Assessment which has been undertaken shows that the site of the proposed revised allocation, and the land to the east is outside of the Environment Agency’s projected flood zone, and so additional dwellings can be considered there too, either as part of the proposed revised allocation or otherwise.

Question 10b) - Do you think there are any specific requirements that should be added to the allocation policy to accommodate the extra 5 dwellings?

None

Natural England welcomes the opportunity to comment on South Norfolk Council’s South Norfolk Village Cluster Housing Allocation Plan (VCHAP) which aims to deliver at least 1,200 homes across smaller sites in villages, and help to ensure a consistent approach to planning across the South Norfolk rural area, with policies aligned with the National Planning Policy Framework (NPPF).

Natural England has noted the production of the latest iteration of the Interim Sustainability Appraisal (SA) Report, dated November 2023, and prepared by AECOM. Natural England has no specific comments to make on the scope of this and considers the aforementioned document to be satisfactory.

Should the proposal be amended in a way which significantly affects its impact on the natural environment, then in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, please consult Natural England again.

Support option 1 which minimises the release of greenfield land.

I choose option 1 as the least-worse case. But I understand there is already a considerable buffer of houses available within the GNLP and do not believe this VCHAP exercise is necessary. Furthermore, I consider the amount of new housing proposed would be disproportionate for the village of Barford.

I consider Option I to be most appropriate. 1. It's consistent with the previous approach and 2. The developers of those developments that do go ahead will no doubt apply to squeeze more properties on the land than was originally agreed, so a small 'buffer' would be created in that way.

When we're talking about building new houses to meet demand, it's essential to be really careful and thoughtful about where these developments go. We should be paying close attention to how they'll affect the environment and the communities nearby.

When we pick a site for new houses, it should be based solely on what makes sense for that location, not on outside pressures or persuasion. We need to look at the facts and see if it's the right fit.

One key thing to think about is whether the number of new houses matches up with the number of existing houses in the area. We also need to consider any other developments happening nearby.

We can't forget about the basics like utilities, amenities, and infrastructure. It's crucial that these can handle the new development. People have a right to access things like healthcare, and it should be easy for new residents to get around using public transport.

In some parts of South Norfolk, flooding is a big concern. If a site is close to flood-prone areas, using non-porous materials for surfaces can make the problem worse. Building uphill from these flood-prone areas could also force water into already overwhelmed sewage systems.

Lastly, we should take a good look at what past planning permission applications in the area have been approved for. We need to make sure that our decisions today align with what's been done in the past, so there's consistency in our choices.

The requirement for 1200 new homes is arbitrary and focuses development on greenfield sites with motivated land owners as opposed to brownfield sites in urban and suburban areas which have key housing needs. The nutrients credit scheme is only just being rolled out and this will reduce focus on development in the Waveney area. The VCP process should be reviewed in line with that scheme to release housing development in more appropriate locations.

Should the VCP go ahead, a buffer of circa 30 dwellings (2.5% above the minimum) is the most appropriate as this minimises the release of greenfield land.

Small rural and semi rural villages are not appropriate for such a big allocation.
This programme was not meant to drive overdevelopment into small villages but ensure their natural sustainable growth. Unfortunately the scheme got corrupted.
The number of houses needs to be limited as much as possible to preserve the historical heritage and character of the village, it’s natural environment and biodiversity. We’re collectively responsible to protect our way of living within the rural setting. Barford is a small and thriving community which should be protected from overpopulation.
Increasing its size by 3rd or half will destroy it.

We do not feel that option ii) is appropriate. The emphasis for planning locations of development should focus on brownfield and previously developed sites, including windfall sites, to meet local housing need whilst preserving the countryside. It is also important to give consideration to the potential impact of site development on local biodiversity and designated sites as well as ensuring that future allocations do not impede the delivery of the upcoming Nature Recovery Network for Norfolk. Whilst the Nature Recovery Network map for Norfolk is not yet available, it is anticipated within the lifetime of this plan’s production, and we would expect the plan allocations and policies to actively support the delivery of the county’s Nature Recovery wherever possible.
It is critical that County Wildlife Sites continue to be protected by policies within Local Plans as they are not afforded the legal protection given to SSSIs, SPAs and SACs and are vulnerable to indirect impacts. We therefore recommend that policy protection is always afforded to any allocations in close proximity to CWSs, through a requirement for these issues to be specifically addressed in an ecological assessment accompanying an application. The wording below taken directly from the Joint Core Strategy for Broadland, Norwich and South Norfolk (Adopted 2014) Policy 1, describes the aim to enhance such environmental assets.
‘..In areas not protected through international or national designations, development will: minimise fragmentation of habitats and seek to conserve and enhance existing environmental assets of acknowledged regional or local importance. Where harm is unavoidable, it will provide for appropriate mitigation or replacement with the objective of achieving a long term maintenance or enhancement of the local biodiversity baseline.’
In addition, Policy 3,The Natural Environment, of the soon to be adopted Greater Norwich Local Plan, states that:
“Development proposals should enhance the natural environment through:
• Being designed to respect, retain, and enhance, natural assets, taking account of local design and other guidance, such as Landscape Character Assessment;
• Avoiding harm to designated and non-designated assets of the natural environment, having regard to their level of significance (local, national and international) in accordance with the requirements of the NPPF and relevant policies in other Development Plan Documents and Neighbourhood Plans;
• Undertaking a relevant assessment (such as a landscape or ecological assessment) if impacts to a natural asset might arise”

A buffer of circa 30 dwellings (2.5% above the minimum). This would be consistent with the previous approach in the January 2023 Regulation 19 (see Table 1 above). Whilst this approach minimises the release of greenfield land, the limitations of this approach have been demonstrated by the need to carry out an additional consultation as a result of the loss of a limited number of sites/dwellings from those previously proposed.

See attachment for full representation.

We would reluctantly support option 1, to maintain the village character.
We have so few facilities & no shops.
School and GP surgeries have very limited spaces (if any).
Environmental issues such as flooding and water drainage to be addressed before further developments considered.

Thank you for inviting Sport England to comment on the above document.

INTRODUCTORY COMMENTS

Sport England is the Government agency responsible for delivering the Government’s sporting objectives. Maximising the investment into sport and recreation through the land use planning system is one of our priorities. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields.

Sport England has assessed this consultation in the light of Sport England’s Planning for Sport: Planning for Sport Guidance (‘Guidance’).

The overall thrust of the Guidance is that a planned approach to the provision of facilities and opportunities for sport is necessary, new sports facilities should be fit for purpose, and they should be available for community sport. To achieve this, our objectives are to:

PROTECT the right opportunities in the right places
ENHANCE opportunities through better use of existing provision
PROVIDE new opportunities to meet the needs of current and future generations.

Sport England’s aim in working with the planning system is to help provide active environments that maximise opportunities for sport and physical activity for all, enabling the already active to be more so and the inactive to become active. The importance of sport should be recognised as a key component of local plans, housing allocations and should not be considered in isolation.

The following comments are provided within the context of:

• National Planning Policy Framework (DCLG, 2023).
• Sport England’s Planning for Sport webpages including Planning for Sport Guidance https://www.sportengland.org/how-we-can-help/facilities-and-planning/planning-for-sport

COMMENTS ON THE 2021 SOUTH NORFOLK VILLAGE CLUSTERS HOUSING ALLOCATIONS PLAN

Site Allocation

Sport England have reviewed the proposed land allocations and have the following comments:

• SN6000, Land north of Chapel Street, Barford

Within this strategic site there are playing pitches, car parking and a village hall. The village hall would provide ancillary facilities for the playing field. Mitigation is proposed to relocate the playing field and village hall to the field located to the north of the existing site. Sport England requests that the policy refers to the loss of the playing field and ancillary facilities (village hall and any associated car parking) re-location and that they should be replaced by equivalent or better provision in terms of quantity and quality in a suitable location to the north of the site, in accordance with criteria b of paragraph 103 in the National Planning Policy Framework. To ensure sufficient mitigation is delivered wording in the policy should be included to the affect of ‘the loss of playing field and ancillary facilities (car parking and a village hall) resulting from the proposed development shall be replaced by equivalent or better provision in terms of quantity and quality in a suitable location to the north of the existing site.’

Closing Comments on Site Allocations

Sport England would like to highlight that any allocation that does not clearly indicate the protection or replacement of a sports facility would be contrary to the NPPF, paragraph 103, and Sport England’s Planning Policy unless the specific facility is identified as surplus within a robust borough wide sport facility strategy. Sport England, therefore, advise that the allocations are clear that sports facilities are protected or replaced in advance of any development in accordance with the criteria in paragraph 103 of the NPPF.

Where on-site or off-site replacement provision is required to facilitate the development of a site, the replacement site should be referenced in the policy and if appropriate a related site allocation should be made in the plan to provide certainty that the facility can be replaced in practice.

Please note that if Sport England has missed any sport facility that falls within any land allocation, then this does not mean the facility is surplus to current or future need. As stated in the NPPF, sport facilities should be protected unless they are surplus to current or future needs, replaced or lost to another sport facility the benefits of which outweighs the harm caused by the loss.

Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered through planning obligations or CIL. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has or will have in place.

In line with the Government’s NPPF (including Section 8) and its Planning Practice Guidance (Health and wellbeing section), consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s Active Design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.

The new NPPF appears to suggest that the target for an additional 1200 homes in rural villages is no longer required. This suggests that option i) (a buffer of c30 dwellings) is the most appropriate of the options presented. Further sites should only be included where there is local support or the site proposed is consistent with an approved neighbourhood plan.