Support
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 3979
Received: 24/09/2024
Respondent: Norwich City Council
Supportive of Council identifying sites to cover shortfall to meet minimum GNLP requirement and provide buffer.
Do not intend to comment on individual sites but reiterate need for development to be planned in a sustainable way. Pleased to see adjustments made reflecting previous comments.
Prior to submission South Norfolk Council should be satisfied that the option chosen will deliver housing in a sustainable manner and is informed by the findings of the SA.
None stated.
Thank you for consulting Norwich City Council on the proposed addendum to the South Norfolk Village Cluster Plan.
We are supportive of South Norfolk identifying additional sites at this stage in order to prevent there being a shortfall which would result in the total allocation in the Village Clusters Plan falling below the minimum 1,200 required by the GNLP. The additional sites means that the minimum GNLP requirement would still be met and also allows a buffer which will ensure that the plan is more robust.
Previously we have not commented on the merits of individual sites and we do not intend on doing so as part of this consultation but we reiterate the importance of making sure that development is planned for in the most sustainable way. In the earlier stages of the plan making process we were concerned that the preferred approach did not perform as well as the ‘accessibility approach’ and we were pleased to see that adjustments were made to the plan which resulted in the preferred approach performing broadly on a par with the reasonable alternative in terms ‘accessibility’ It is however noted that the appraisal highlights that the Village Cluster Plan still gives rise to tensions with certain sustainability objectives.
Taking into account the above, we do not wish to make representation or object to the addendum to the plan but we would ask that prior to submitting the plan for its examination that South Norfolk Council is satisfied that the option chosen will deliver housing in a sustainable manner and is informed by the findings of the SA.
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4038
Received: 06/10/2024
Respondent: Ms Emily Nolan
Legally compliant? No
Sound? No
Duty to co-operate? No
The proposed developments are out of proportion with the villages, the houses will not be sustainable and these plans seem at odds with the net zero plans the UK has committed to. The building industry is one of the least sustainable. The use of green sites is inappropriate when there are plenty of brown field sites for housing.
The number one commitment needs to be sustainability.
The proposed developments are out of proportion with the villages, the houses will not be sustainable and these plans seem at odds with the net zero plans the UK has committed to. The building industry is one of the least sustainable. The use of green sites is inappropriate when there are plenty of brown field sites for housing.
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4046
Received: 06/10/2024
Respondent: Ms Julie Bache
Legally compliant? No
Sound? No
Duty to co-operate? No
The VCHAP in and of itself is a non-sustainable plan. It was the brain-child of Michael Gove under the previous Conservative government and is set to disrupt villages all across England. It sets out to add 'small development's. Some of the sites are not small at all. For example: We have two proposed sites in Barford, totalling 65 houses. Our village less than 300 houses, so this would be a 20% uplift in housing in a TINY village with no facilities, other than a village hall and a garage (which itself would be demolished for the proposed 20 houses!)
The VCHAP should be changed to a TCHAP - i.e. Village to TOWN. Small towns can sustain developments of clusters of 20-45; but a village can (often) not. Housing allocations should be added to Towns, thus retaining villages to be just that, villages. Otherwise there will be nothing else apart from small towns, if all villages are developed and subject to the desire (not need) for 'growth'. Towns have shops/doctors and all sorts of infrastructure available which simply are not there in (most small) villages.
The VCHAP in and of itself is a non-sustainable plan. It was the brain-child of Michael Gove under the previous Conservative government and is set to disrupt villages all across England. It sets out to add 'small development's. Some of the sites are not small at all. For example: We have two proposed sites in Barford, totalling 65 houses. Our village less than 300 houses, so this would be a 20% uplift in housing in a TINY village with no facilities, other than a village hall and a garage (which itself would be demolished for the proposed 20 houses!)
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4126
Received: 07/10/2024
Respondent: Rainier Developments and Strategic Land
Agent: Ceres Property
Legally compliant? No
Sound? No
Duty to co-operate? No
As confirmed through case law (see Heard), whilst it is not necessary to keep open all options for the same level of detailed examination at all stages, at each stage the preferred option and reasonable alternatives must be assessed to the same level of detail.
GNLP3033 (‘the Site’) was expressly identified earlier within the plan-making process as a reasonable alternative. However, it does not appear to have been assessed at all as part of the Regulation 19 Addendum SA, let alone to the same level of detail as the sites that are proposed for allocation.
The lack of assessment of this site-specific alternative is a concern in terms of compliance with the SEA Regulations.
Additionally, no consideration appears to have been given as part of the SEA process as to whether Long Stratton, as a settlement, should accommodate some of the new residential site allocations required for the VCHAP.
Separately, Regulation 13 concerns the procedural requirements of consultation on the SEA. It requires inter alia that, as soon as reasonably practicable after the preparation of the SEA, the responsible authority should bring it to the attention of persons who are affected or likely to be affected by, or have an interest in its findings.
Two concerns arise from this relating to the Regulation 19 Addendum SA .
Firstly, it is not clear if an Environmental Report was prepared to support the Regulation 18 iteration of the Addendum to the VCHAP. If it was, then Rainier should, as interested persons, have been consulted on this. If it was not, then this would give rise to a different concern, given the need for plans to be informed by sustainability appraisal which meets legal requirements throughout their preparation (NPPF paragraph 32).
Secondly, it is not clear from the information available via the website that comments are being invited on the Regulation 19 Addendum SA itself. The online consultation portal does not appear to have a facility for commenting on the Regulation 19 Addendum SA, only the Regulation 19 Addendum.
The Cogent3 judgment confirms defects in the SEA process can be resolved, even at a very late stage in the plan-making process. However, it is important to recognise that an important lesson from Cogent was that additional requirements to ensure the SEA process complies with the SEA Regulations.
As part of the measures to ensure a legally complaint SEA, we suggest it will be necessary to appraisal all reasonable alternatives, including directing growth to Long Stratton and, specifically, appraising GNLP3033.
For the reasons described above, even if appraisal of additional sites and options through SEA was not required, it would nevertheless be necessary to undertake consultation on the Regulation 19 SA Addendum, given the apparent lack of consultation on the Environmental Report itself to date.
In considering the Site / GNLP3033 in relation to the SA objectives and framework in the Regulation 19 Addendum SA, it is evident that it would score positively (sustainable location, access to facilities, bus services, ecological designations, agricultural value, Conservation Area).
See attachment for full representation.
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4129
Received: 07/10/2024
Respondent: Mr Joel Chant
Legally compliant? No
Sound? No
Duty to co-operate? No
The VCHAP is not a sustainable proposition. It is a disruptive plan to many villages. It does not always offer small sites as it claims. Some are large and the ones for Barford are out of scale with the size of this village. There are currently no facilities in Barford other than the small school, garage and village hall. The latter two are threatened by the two developments currently proposed. Increasing the housing stock by 20% is excessive and should be reviewed.
The VCHAP is a one size fits all policy which should be reviewed and changed by the new Government. It is not fit for purpose. Small quiet villages like Barford having such a large increase in population is neither necessary nor welcome. The lack of facilities here in our village do not facilitate yet more housing.The plan should be scrapped.
The VCHAP is not a sustainable proposition. It is a disruptive plan to many villages. It does not always offer small sites as it claims. Some are large and the ones for Barford are out of scale with the size of this village. There are currently no facilities in Barford other than the small school, garage and village hall. The latter two are threatened by the two developments currently proposed. Increasing the housing stock by 20% is excessive and should be reviewed.
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4169
Received: 07/10/2024
Respondent: Rainier Developments and Strategic Land
Agent: Ceres Property
Legally compliant? No
Sound? No
Duty to co-operate? No
As confirmed through case law (see Heard), whilst it is not necessary to keep open all options for the same level of detailed examination at all stages, at each stage the preferred option and reasonable alternatives must be assessed to the same level of detail.
GNLP0321 and GNLP1023 (which together constitute the Site) were expressly identified earlier within the plan-making process as reasonable alternatives. Despite this, it appears that they have not been considered as potential allocation through the Regulation 19 Addendum SA, let alone to the same level of detail as the sites that are proposed for allocation.
The lack of assessment of this site-specific alternative is a concern in terms of compliance with the SEA Regulations.
Additionally, no consideration appears to have been given as part of the SEA process as to whether Poringland / Framingham Earl, as a settlement, should accommodate some of the new residential site allocations required for the VCHAP.
In considering the Site in relation to the SA objectives and framework in the Regulation 19 Addendum SA, we consider it would be assessed as having a number of positive impacts and identified as a sustainable site for residential development.
Located in sustainable location, access to bus services, no ecological designations, low agricultural value, not located close to Conservation area.
The Cogent3 judgment confirms defects in the SEA process can be resolved, even at a very late stage in the plan-making process. However, it is important to recognise that an important lesson from Cogent was that additional requirements to ensure the SEA process complies with the SEA Regulations.
Having regard to all of the above, in the preparation of an Environmental Report that properly considered the Site, as required given that it is an amalgamation of two reasonable alternatives, and assessed it to the same level of detail as required, the Site would represent an eminently sustainable option for growth. It is submitted that it would be a more sustainable option than the additional sites that the Regulation 19 Addendum proposes to allocate.
See attachment for full representation.
Support
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4201
Received: 26/10/2024
Respondent: Natural England (Norfolk and Suffolk)
Natural England has no comments to make on the South Norfolk Village Clusters Housing Allocations Plan (SNVCHAP) - Regulation 19 Pre-submission Addendum.
Natural England is broadly satisfied and in agreement with the findings of both the Sustainability Appraisal (SA) of the SNVCHAP – SA Report Update (AECOM, June 2024), and the updated Habitats Regulations Assessment of the SNVCHAP (Lepus Consulting, June 2024), which considers the final choice of sites included in the above addendum document.
We have no further comments to make at this stage.
Natural England has no comments to make on the South Norfolk Village Clusters Housing Allocations Plan (SNVCHAP) - Regulation 19 Pre-submission Addendum.
Natural England is broadly satisfied and in agreement with the findings of both the Sustainability Appraisal (SA) of the SNVCHAP – SA Report Update (AECOM, June 2024), and the updated Habitats Regulations Assessment of the SNVCHAP (Lepus Consulting, June 2024), which considers the final choice of sites included in the above addendum document.
We have no further comments to make at this stage.
Support
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Representation ID: 4205
Received: 24/09/2024
Respondent: KCS Development Ltd
Agent: Cara Chambers
(Representation relates to VC SPO1)
The updated Sustainability Appraisal re-confirms the conclusions of the previous Sustainability Appraisal, and confirms:
‘Spooner Row stands-out on account of rail connectivity, albeit there is a very limited service, and there is not thought to be any potential for an improved service, in the context of the current plan. The village is also close to the A11, but regular bus services do not pass through the village.” The report also flagged Spooner Row as: “… one example of a village where the potential for higher growth to consolidate the built form, and potentially deliver-on place-making objectives, might be envisaged. However, this is highly uncertain, as there is a need to give weight to protecting the existing character of the settlement…”’
We welcome these continued conclusions that Spooner Row, and the site, are sustainable.
See attachment for full representation.