Sustainability Appraisal Report (Reg. 18)

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Comment

Village Clusters Housing Allocations Plan (Reg. 18) - Supporting Documents

Representation ID: 1738

Received: 02/08/2021

Respondent: Barton Willmore

Representation Summary:

The Sustainability Appraisal Report (SA) supporting this consultation is flawed on the basis that the 1,200 homes needs to be allocated to the Village Clusters. As noted previously, this is an option still to be Examined through the GNLP process and may not be formally endorsed. All options within the SA for distribution of 1,200 homes (i.e., Striking a balance, Accessibility led, and Dispersal led) would reasonably be expected to score lower against the criteria of the Sustainability Appraisal (SA) when compared to locations adjoining/within the largest settlements.
As an example, Table 9.1 of the SA identifies a significant constraint of a smaller settlement to be accessible to key services. It notes the average distance (noting some locations will be more distant than the average) between a ‘preferred site’ and GP, Primary School and Secondary School is 3.3km, 0.7km and 5km respectively. This would not be the case in a location such as Wymondham where these key services are readily accessible by walking, cycling or access to regular public transport.
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

Village Clusters Housing Allocations Plan (Reg. 18) - Supporting Documents

Representation ID: 1784

Received: 02/08/2021

Respondent: Orbit Homes

Agent: David Lock Associates

Representation Summary:

We consider that the preparation of a standalone Sustainability Appraisal (SA) for the SNVCHP
in isolation of the GNLP raises a number of procedural concerns.
As outlined above, allocations for new housing sites at Village Clusters within Broadland District
have been included as part of the GNLP. They have therefore been appropriately reviewed
and assessed as part of the SA for the GNLP, taking into account overall plan sustainability
objectives and assessment criteria.
In contrast, the allocations for the SNVCHP are being assessed as part of an entirely separate
SA process. The SA Framework for the GNLP is substantially different to the SA Framework
for the SNVCHP – the relevant extracts of both Scoping Reports are included at Enclosure 1a
& 1b to this representation. This leads to a fundamentally different assessment of the potential
site allocations, and inevitably, leads to different outcomes.
The preparation of a SA in isolation from the GNLP results in a scenario where the sustainability
of the Development Plan has not been assessed as a whole but rather in parts against
significantly different SA frameworks. This is not a sound approach, and it is difficult to
ascertain how an Inspector would be able to confirm the soundness of the decision making
process and confirm the suitability of site allocations in respect of two separate sustainability
assessments on this basis.

Attachments:

Object

Village Clusters Housing Allocations Plan (Reg. 18) - Supporting Documents

Representation ID: 1825

Received: 20/07/2021

Respondent: Norwich City Council

Representation Summary:

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

We are pleased to see that the plan is moving forward and progressing, although we still would have preferred the sites to have been allocated through the GNLP process.

We do not intend to comment on individual sites or the policy approach; however we do note that the SA appraisal favours option 2 (accessibility led) whereas South Norfolk’s emerging approach is option 1 (striking a balance). As the plan moves forward it is important that the plan is informed by the SA findings.

Comment

Village Clusters Housing Allocations Plan (Reg. 18) - Supporting Documents

Representation ID: 2065

Received: 21/07/2021

Respondent: Historic England

Representation Summary:

Please see attachments for full response.
We are concerned at the over-reliance of GIS distance-based analysis for the Sustainability Appraisal (paras 5.1.1 – 5.13). The report itself comments on the limitations of this and states that it is not technically an appraisal. And little of no potential for reach conclusions on significant effects. The report uses the example of biodiversity features. The same issue applies for heritage assets.
A purely distance based approach is not appropriate. The impact of proposals on the significance of heritage assets should be taken into consideration at an early stage. In terms of sites, this should be based on more than just measuring the proximity of a potential allocation to heritage assets.
Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. The application of a standard proximity test (e.g. is the site within a set distance of a heritage asset) should not be used as it can lead to misleading results.
A simple matrices approach is not considered sufficient. We would want to see a narrative-based approach that properly considers more nuanced issues in relation to setting and significance of both designated and non-designated heritage assets.
The analysis at section 9.8 again seems to overly focus on proximity.
We welcome the reference at 9.8.6 for the need to ensure policy in place to mitigate for historic environment impacts. We have identified a number of sites where we consider further heritage assessment is needed. These assessments should make recommendations regarding appropriate mitigation and this should then be incorporated into individual site policy wording.
In future SA reports, please ensure the correct notation is used for listed buildings eg grade1 should be grade I, grade 2 should be grade II.
The findings of the Analysis on pages 48-52, and Table A further highlights our concern that the analysis has been overly focused on distance.
We note that Scheduled monuments do not appear in Table A.
The appraisals from p76 following do give a slightly fuller discussion of the historic environment; however, the analysis is still somewhat superficial.
This again points to the need for HIAs of particular sites.