QUESTION 1: Do you agree

Support

Representation ID: 1360

Received: 02/08/2021

Respondent: M. Gaze & Co Ltd

Agent: Wilson Wraight LLP

We support the three objectives for the Village Clusters Plan which will assist with the delivery of sustainable development in accordance with the three sustainability objectives of the NPPF as set out in Paragraph 8.

Overall, the three Objectives for the Village Clusters Plan will assist the Council with meeting the national policy objectives set out in the NPPF by providing much needed new housing which will contribute towards maintaining a supply of deliverable sites and protect village communities whilst supporting rural services and facilities.

Comment

Representation ID: 1441

Received: 02/08/2021

Respondent: Lanpro Services Ltd

Although Lanpro offers support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, we cannot support the significant emphasis that is placed upon rural village clusters (outside of the old Norwich Policy Area (NPA)). An alternative strategy is suggested within these representations.

Comment

Representation ID: 1450

Received: 02/08/2021

Respondent: Glavenhill Limited

Agent: Lanpro Services Ltd

Although Glavenhill offers support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, they cannot support the significant emphasis that is placed upon rural village clusters (outside of the old Norwich Policy Area (NPA)). An alternative strategy is suggested within these representations.

Object

Representation ID: 1455

Received: 02/08/2021

Respondent: Mr and Mrs Anthony and Rebecca Bond

Agent: La Ronde Wright Ltd

Suggested alterations and broadening of elements of Objectives 1 & 2, to take into account the change to electric vehicles in the Plan period, that development should be across the range of settlements found in each cluster, and that development should not be limited to strictly in-fill sites.

Object

Representation ID: 1456

Received: 02/08/2021

Respondent: Mr Humphrey Berney

Agent: La Ronde Wright Ltd

Objective 1 - the wording at present would likely be interpreted in application decision-making to permit 'in-fill' self-build development opportunities; however this is likely in many circumstances to be too restrictive to meet the overall thrust of the Village Clusters objectives, and should be broadened to refer to edge-of-settlement or similar, so as to include appropriate parcels of land on the side of / immediately adjacent to existing development.

Object

Representation ID: 1483

Received: 02/08/2021

Respondent: Hales & Heckingham Parish Council

Hales & Heckingham Parish Council do not agree with the objectives of Village Cluster Plan. Building new houses where there are no local jobs and limited amenities only increases the number of car journeys and puts pressure on insufficient resources.

Object

Representation ID: 1492

Received: 02/08/2021

Respondent: Hales & Heckingham Parish Council

No. The JCS allocated Hales and Heckingham 10 new houses. To date 70 dwellings have been built and 20 more approved. During that time no investment has been made to improve village infrastructure. Amenities are extremely limited with no village hall. Heckingham Park was built with fitness facilities for residents but no access for other members of the village. This approach does not protect village communities or support rural services/facilities. No investment was made to improve broadband delivery to existing houses. The village is a mobile “not spot”. Further development without investment in existing village infrastructure increases social problems.

Object

Representation ID: 1495

Received: 02/08/2021

Respondent: Hales & Heckingham Parish Council

Hales & Heckingham Parish Council do not agree with the objectives for the Village Clusters Plan. Hales and Heckingham are in danger of being dormitory villages without the provision of local amenities to support the lives of residents.

Object

Representation ID: 1496

Received: 02/08/2021

Respondent: Hales & Heckingham Parish Council

Hales & Heckingham Parish Council do not agree with the objectives of Village Cluster Plan. Building new houses where there are no local jobs and limited amenities only increases the number of car journeys and puts pressure on insufficient resources.

Object

Representation ID: 1555

Received: 02/08/2021

Respondent: Rosconn Strategic Land

RSL considers Objective 1 of the VCP to be unsound due to the disproportionate level of growth directed to the Village Clusters when alternative options are available to direct growth in more sustainable locations and these have not yet been adequately considered.
See attached letter for full response.

Comment

Representation ID: 1579

Received: 02/08/2021

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

See attached letter for full response.
Objective 1: To ensure delivery of target would recommend an over-allocation of c.20%. (for any sites that fail to come forward).
Support objective to ensure appropriate mix of house
types, sizes and tenures, but object to inclusion of specific policy on housing mix.
• Objective 2: Support objective to provide opportunities for new housing in a range of settlements to support local services/facilities.
• Objective 3: support objective to ensure scale/location/density of housing is well related
to form/character of existing villages, but consider that Objective fails to recognise NPPF para 124 focus on making efficient use of land. Therefore needs amending to ensure it achieves efficient densities that also relate well to local character.

Comment

Representation ID: 1627

Received: 28/07/2021

Respondent: Marlingford and Colton Parish Council

See full comments.
There are already sufficient allocated sites for housing proposed in the JCS to be carried forward to the GNLP in the Norwich fringe parishes, main towns, and key service centres to keep pace with the predicted rates of development. The exceptions should be brownfield sites, particularly those within Norwich, which should be prioritised in a 'brownfield first' policy.
Any additional sites should be in and close to Norwich.
The existing settlement hierarchy should be maintained.
This 'new GNLP' seems to have moved the focus for a lot of the new housing away from the NDR and its corridor.
There is no demonstrable need for the scale and category of housing which development of the sites proposed in the GNLP would result in.
considerable disconnect between the developers' objectives and community needs.

Comment

Representation ID: 1636

Received: 30/07/2021

Respondent: Hopkins Homes Limited

In response to Question 1, in respect of the three defined ‘Objectives’ of ‘Meeting Housing Needs’, ‘Protecting village communities and supporting rural services and facilities’ and ‘Protecting the character of villages and their settings’, it is agreed that these are laudable aims and ones which Hopkins Homes would support, but as will be discussed further within our subsequent representations, without further amendment to the overall quantum and individual scale of development being proposed within the various Allocations of the Plan, it unfortunately appears unlikely that these aims will be met.

Object

Representation ID: 1673

Received: 31/07/2021

Respondent: Mulbarton Parish Council

SNVC Objective 1

No. Those communities that wish to build more houses should be provided with help and support to allow them to do so. This can already be achieved through the Neighbourhood Plan process and other schemes. Conversely, communities which are not seeking any more house-building in their area should not be required to allocate their own resources to oppose allocations derived from the Greater Norwich Local Plan target.
The first sentence of this Objective should read to ‘allocate viable and deliverable sites in response to requests from, and in consultation with, local communities and consistent with existing Neighbourhood Plans
SNVC Objective 2 – No. This objective, as worded, is meaningless and unnecessary. Where local schools are at risk of closure, or bus services are not economically viable, dialogue should be initiated with the affected community to resolve the difficulties by considering a range of alternatives. This may or may not lead to more houses. Conversely, where local services have reached the point of collapse due to past developments, more houses will make the situation worse for at least the next ten years. These communities can be protected and supported by concentrating house building in urban areas with economies of scale.
The objective, as worded, makes no reference how new housing development will support local services and facilities, rather than overwhelm them. No reference is made for the need to protect local services and facilities. The objective should be removed entirely.
SNVC Objective 3 – No. Experience of local planning shows that ‘ensure appropriate landscaping measures’ cannot be relied upon to produce acceptable outcomes. The word “appropriate” is not defined. What does “appropriate” mean, what will it look like, how will anyone know if it's “appropriate” and what criteria will be used against which it is measured? The wording should be changed to give the local community a formal role in approving any landscaping measures, with the clear possibility of the site not being allocated if the proposals rejected.

Comment

Representation ID: 1737

Received: 17/08/2021

Respondent: Barton Willmore

In summary, the Village Clusters are likely to be the least sustainable locations for growth
across the Greater Norwich area, yet they are proposed to accommodate a significant portion of the
GNLP’s housing growth. Allocating such a significant element of the GNLP’s anticipated growth to these
areas, where there are limited / no services and limited / no public transport, would be contradictory
to the principles of sustainable development and the overall vision of the GNLP. We do not
believe the approach proposed by the Village Clusters Plan has been justified and it is clearly
not consistent with national policy. It does not respond to the principles of sustainable development,
and it does not appear an effective assessment of the environmental impacts of this approach has been
undertaken.

Object

Representation ID: 1752

Received: 02/08/2021

Respondent: Hempnall Parish Council

We consider that the VCHAP approach to allocating new housing is misguided and damaging because it involves dispersing an unnecessary level of development into villages with very negative consequences for climate and landscape. Pursuing such a policy would result in significant loss of countryside and green spaces.
Furthermore we consider that the VCHAP is unnecessary because the Total Housing Potential suggested for the GNLP is too high (49,492) and if it were reduced to the level required to address local housing need, as assessed by the standard method i.e. 40,541 dwellings, then allocations in village clusters would not be needed.
Please see the attached representation for full response.

Object

Representation ID: 1764

Received: 02/08/2021

Respondent: Pigeon Investment Management Ltd

The GNLP strategy to direct at least 1,200 homes to South Norfolk Village Clusters has been proposed in advance of assessing the suitability of potential sites within South Norfolk. Therefore the decision to ‘ringfence’ this element of the GNLP housing requirement has been taken without having first assessed whether there are suitable sites to deliver this strategy. We therefore feel this is not an ‘appropriate strategy’, as required by paragraph 35 of the NPPF.
We consider it is necessary to assess the potential Village Cluster sites in isolation, but also to assess them alongside other potential allocation sites within the Main towns and Key Service Centres. Settlement limits should also be reviewed across all settlements in South Norfolk.
In addition, GNLP is yet to be subject to Examination and there are outstanding objections that have not yet been resolved. As such, it is premature to progress the Village Clusters Plan.
See attached for full response.

Comment

Representation ID: 1767

Received: 02/08/2021

Respondent: Little Melton Parish Council

LMPC broadly agrees with the Objectives but does not agree that the current process has met the aims
described in Objective 1 to provide opportunities for self-builds. LMPC was expecting the VCHAP process to
provide an opportunity for local people to comment on possible changes to the settlement boundary. Several
recent PAs have been refused as being outside the Settlement Boundary (one PA was also inside the
Landscape Protection zone), people are now confused that there is a Prefered Site that is not even adjacent
to the Settlement Boundary and is inside the Landscape Protection zone - this undermines faith in the
planning system.

Comment

Representation ID: 1774

Received: 02/08/2021

Respondent: Edward Gosling

Yes, but not entirely, I believe there are inconsistencies &/or problems:
1) We have sites involving the construction of 12 to 50 dwellings going to meet the 1200 dwelling requirement in the GNLP, but smaller sites of less than 12 dwellings not counting towards this 1200 dwelling requirement. This seems inconsistent with SNVC Objective 3 in protecting the character of villages as larger sites of 12 to 50 dwellings by their very nature have far greater impact and yet apparently, they are the only way of fulfilling the 1200 dwelling requirement!
2) SNVC Objective 3 states: “Ensure that the scale, location and density of housing is more related to the form and character of existing villages…” The particular question here is what is actually meant by “scale” and how is it determined? Within the South Norfolk village cluster housing allocation plan there are essentially 1200 dwellings to be built and 48 village clusters in which to build them. This would average out at 25 dwellings per village cluster! I believe the issue of “scale” needs further consideration and clarification.

Object

Representation ID: 1783

Received: 02/08/2021

Respondent: Orbit Homes

Agent: David Lock Associates

We wish to maintain our objection to the preparation of the SNVCHP
in isolation from the GNLP.
No justification has been given as to why the village clusters
allocations for South Norfolk could not be included and considered
as part of the GNLP. Indeed, the village cluster allocations for
Broadland District are included and allocated as part of the GNLP
and the policy framework for the decision to allocate village clusters
throughout the Greater Norwich area is set out in policy 7.4 of the
GNLP (and therefore there is a logic to include all site allocations
justified under GNLP policies, including those in South Norfolk
village clusters, within the GNLP itself).
The decision to separate the analysis and decision making for South
Norfolk Village Cluster allocations from the remainder of the GNLP
is both confused and unjustified. Given the close working relationship between both Councils – including a shared website and consultation platforms for
the local plan – nowhere in the consultation material does it state the reason for the separation
of South Norfolk village cluster allocations from the remainder of the local plan.
The preparation of the SNVCHP in isolation gives rise to a number of plan-making and procedural concerns:
(i) Transparency in Planmaking and Development Management
(ii) Disconnected timeframes for planmaking, assessment and Examination
(iii) Failure to deliver on overarching Local Plan Objectives
Given the above, it is our opinion that in order to move to a sound local planning framework
for the Greater Norwich area, the preparation of the SNVCHP and GNLP should be combined
from this point on, resulting in a joint Local Plan Examination capable of effective decision
making.

Comment

Representation ID: 1785

Received: 02/08/2021

Respondent: South Norfolk Green Party

Re Objective 2 - this is the wrong way round. Local services/facilities should be supporting the village clusters and their inhabitants.
No mention of retrofitting older properties to bring them up to date with modern standards of insulation etc.
Also it is obvious that cost of newly housing is oo high for local people unless they have already got a step on ‘housing ladder’. If we want to sustain our local communities, a large proportion of new build should be Affordable Housing, and not a developers’ charter. If too much large housing is built we will have precious little countryside left. Villages will not thrive if suitable housing is not provided.
Agree with others that quantity of development is unnecessarily high and distribution of development is unsustainable.

Comment

Representation ID: 1819

Received: 16/07/2021

Respondent: Broads Authority

Objective 3 - Protect the character of villages and their settings
• As written, no objectives refer to the protection of the environment. At the very least, number 3 should be expanded to include not just protecting the setting of the village, but setting of other assets in the area like heritage and protected landscapes.

Comment

Representation ID: 1821

Received: 16/07/2021

Respondent: Broads Authority

Assessment of sites
• Why has the Norfolk HELAA been amended? The whole point was to ensure a sustainable pattern of development across Norfolk. You may want to thoroughly explain why such changes to the Norfolk-wide approach have been made.
• What extra distances have you used?
• Also, when you say ‘safe and convenient access to those services’, what mode of travel is that by? How has the quality of the route and likelihood of someone using the route in all weather, at all times of the year been assessed?

Throughout
• Throughout, in the form and character sections, you talk about having links to various other places /being well served. Is this a road link, pedestrian link, public transport? It might be an idea to say what mode the link relates to. The commentary seems all about the car at the moment.
• Do you need to summarise access to the various services in the main document?
• Did you want to say where the bus goes to and if there is a peak hour trip?
Maps
• The legend says that blue is rejected sites and sites being assessed in Neighbourhood Plans (NP). Are all blue sites doing both things? Could a site just be rejected and not be assessed in a NP? If a site is being rejected by the Local Plan, how can it then be successfully included in a NP?
• Should you plot on the maps where the services are?

Comment

Representation ID: 2000

Received: 27/07/2021

Respondent: CPRE Norfolk

Please see attachment for full response.
We comment on problems with the preferred sites for housing with a SL suffix in the SNVCHAP reg. 18 draft. It would appear that SL in this context stands for “settlement limit (extensions)”, as they are for sites smaller than 12 dwellings, as outlined in ‘the Introduction and Background’ section under ‘Village Clusters’. However, their status is not fully explained, other than an implication that they are not “new allocations” as they are covered under a separate point.
it is clear that the SNVCHAP preferred sites with a SL suffix should not be described as ‘windfall sites’ or counting towards the GNLP’s ‘windfall allowance’ as they are all sites which have clearly been identified for housing in the development plan i.e. the SNVCHAP. Therefore, either these sites should be removed from the SNVCHAP or they should be re-designated as allocated sites, and thus count towards the 1,200 houses allocated in the SNVCHAP.

Comment

Representation ID: 2004

Received: 02/08/2021

Respondent: Suffolk County Council

Please see attached for full response:
This response makes comments regarding cross boundary issues which may result from the chosen distribution of the Village Clusters Local Plan.
Education - Bungay, Beccles and Worlingham have allocated development in the Waveney Local Plan, along with associated education infrastructure. The expansion of Beccles and Worlingham will deliver new primary school. Allocations in Bungay set aside land for the expansion of Bungay High School.
Some cross boundary movement of pupils is inevitable - VCHAP should ensure there is sufficient education capacity within Norfolk to meet needs of new housing.
Flood and Water Management - more recent “Level 2” water cycle study from GNLP evidence base has not been included - not clear why?
PRoW and Countryside Access - where possible policies should support connections of public rights of way between the counties.
Transport - Other than SA, there does not appear to be any other transport evidence within supporting documents. While SCC does not envisage significant impacts on highway network, a high level assessment of the impact caused by the Village Clusters Local Plan should be undertaken.

Comment

Representation ID: 2022

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We broadly support object 3 Protect the character of villages and their settings. However, we suggest that specific reference is made to the historic environment in this objective. Also, it is not just about protecting the character of villages and their settings but also the wider landscape
Include reference to the need to protect and enhance the historic environment in this objective.
Include reference to wider landscapes.

Comment

Representation ID: 2025

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
We are concerned that there is insufficient evidence in relation to the historic environment to support some of the site allocations.
Whilst the HEELA methodology and site assessments are a helpful starting point, we are looking for more detail, particularly in relation to the amber sites.
Unfortunately, the assessments do not follow the five-step methodology for site allocations set out in our Advice note 3 on site allocations. They do not properly consider significance of heritage assets, the contribution of setting to that significance, impact of development upon significance of those assets and do not consider potential mitigation and enhancement.
Therefore, Heritage Impact Assessments should be prepared for a number of sites; this is imperative to ensure a robust evidence base for the Local Plan. These should be prepared in advance of the next draft of the Plan to inform whether some sites are suitable, but for majority of sites to inform potential mitigation and policy wording. This is a matter of priority, given the timetable for the Plan.
HIAs should consider the issue of the capacity of the sites including issues in relation to height and impact on historic environment. They should consider significance of assets, impact of development upon significance of those assets, and make recommendations about potential mitigation.
Should a HIA conclude that a particular site could be allocated, the findings of the HIA should inform the policy wording.
Paragraph 32 of NPPF makes it clear that significant adverse impacts should be avoided wherever possible and alternative options pursued. Only where these impacts are unavoidable should suitable mitigation measures be proposed.

Comment

Representation ID: 2026

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
Evidence Base:
We have set out our concerns in relation to insufficient historic environment evidence to support some site allocations and the need for HIAs.
It is important that your plan is underpinned by appropriate evidence.
Any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base. Sources include:
• National Heritage List for England. www.historicengland.org.uk/the-list/
• Heritage Gateway. www.heritagegateway.org.uk
• Historic Environment Record.
• National and local heritage at risk registers. www.historicengland.org.uk/advice/heritage-at-risk
• Non-designated or locally listed heritage assets (buildings, monuments, parks and gardens, areas)
• Conservation area appraisals and management plans
• Historic characterisation assessments e.g. the Extensive Urban Surveys and Historic Landscape Characterisation Programme or more local documents. www.archaeologydataservice.ac.uk/archives/view/EUS/
• Environmental capacity studies for historic towns and cities or for historic areas e.g. the Craven Conservation Areas Assessment Project. www.cravendc.gov.uk/CHttpHandler.ashx?id=11207&p=0
• Detailed historic characterization work assessing impact of specific proposals.
• Heritage Impact Assessments looking into significance and setting especially for strategic sites or sites with specific heritage impacts
• Visual impact assessments.
• Archaeological assessments.
• Topic papers.
We advise you to carefully consider the list above.
We advocate the preparation of a topic paper in which you can catalogue the evidence you have gathered and to show how that has translated into the policy choices you have made. Do this from the start, as a working document, that you add to throughout the plan preparation process, not just before EiP.
It can also be useful to include in this a brief heritage assessment of each site allocation, identifying any heritage issues, what you have done to address them and how this translates into the wording in your policy for that site allocation policy.

Comment

Representation ID: 2027

Received: 21/07/2021

Respondent: Historic England

Please see attachments for full response.
General comments on allocations
It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal.
The policy wording should mention the specific designated heritage assets both on site and nearby.
The policy and supporting text should also refer to specific appropriate mitigation measures e.g. landscaping or careful design or maintaining key views or buffer/set back/breathing space etc.
Typical wording for the policy criterion might be:
Development should conserve or where appropriate enhance the significance of heritage assets including [list heritage assets on site and nearby – these should include designated and non-designated heritage assets] including any contribution made to their significance by their settings. Appropriate mitigation measures [as identified through the Heritage Impact Assessment] including … will be required.’
Therefore, please revisit the site allocations and ensure that policy wording/supporting text is consistent with the advice above.
By making these changes to policy wording the Plan will have greater clarity, provide greater protection to the historic environment and the policies will be more robust.
Given the inclusion of reference to significance and setting we suggest that these terms (which are quite technical) are included in a glossary.

Support

Representation ID: 2146

Received: 14/07/2021

Respondent: Norfolk County Council - Strategic Planning Team

Please see attachment for full response.
Response to Question 1 - The County Council welcomes / supports the underlying objectives to the Plan as set out in SNVC Objectives1,2, and 3. In particular the County Council supports Objective 2 in respect of protecting village communities and supporting rural services and facilities.