Object
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3052
Received: 08/03/2023
Respondent: South Norfolk Green Party
Legally compliant? No
Sound? No
Duty to co-operate? No
SNGP oppose the concept of village clusters because it is not settlement hierarchy, which concentrates development in 'sustainable' locations i.e. where there are alternatives to private cars for most necessary trips. If you can't get between parts of the same cluster without a car, you are not improving the sustainability of those places.
The NFPP says
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.
South Norfolk Green Party are opposed to the whole concept of village clusters because it nullifies the point of settlement hierarchy, which means to concentrate development in locations where it is 'sustainable' i.e. where there are alternatives to the private car for most necessary trips. If you start clustering villages together where you can't actually get between parts of the same cluster without a car, you are not in any way improving the sustainability of those places.
The car dependence of new development makes the plan inconsistent with the following paragraphs from the NPPF:
152:
The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.
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.
This is inconsistent with sporadic development in villages that do not have facilities such as shops, surgeries, schools and other basic conveniences accessible by means of low-carbon transport. Indeed the opposite is true - this car dependent form of development will increase emissions.