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Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 3940

Received: 05/09/2024

Respondent: NHS Norfolk and Waveney Integrated Care System

Representation Summary:

There are 4 villages whereby the most local GP practice that covers those villages within its catchment area is located across the local authority border in East Suffolk. Two GP practices will be affected by any population increases. These practices are either currently working through a planning application for an extension funded by CIL or are in early discussions about a potential premises scheme via a potential application for CIL funding.

The ambulance service, EEAST, are in a unique position that intersects health, transport and community safety and does not have capacity to accommodate the additional growth resulting from the proposed development combined with other developments in the vicinity. This development is likely to increase demand upon existing constrained ambulance services and nationally set blue light response times. The capital required through developer contribution would form a proportion of the required funding for the provision of capacity to absorb the patient growth and demand generated by this development. Any funding would be used towards the capital cost of providing new additional ambulances and/or new additional medical equipment, which for an ambulance service is their physical infrastructure, and/or new additional parking space(s) for ambulances at existing ambulance stations.

Change suggested by respondent:

None specified. ICS would encourage continued working with LPA.

Full text:

See attachment for full submission

Attachments:

Object

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 3984

Received: 26/09/2024

Respondent: Norfolk County Council - Highways

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Highway Authority previously expressed support for access to the site via Hamilton Way to the south. The access from Hamilton Way through the consented development (2019/1925) does not extend to the allocation boundary, potential resulting in an undeliverable allocation.

Change suggested by respondent:

The boundary of VCDIT1 requires modification to ensure it can be accessed from the estate road of application 2019/1925.

Full text:

See attachment for full representation.

Attachments:

Object

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 3987

Received: 30/09/2024

Respondent: Historic England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We welcome the preparation of the HIA for the site. The HIA recommends that archaeological investigation should be required prior to development commencing due to the cropmarks on site.

We therefore welcome the reference to archaeological investigation prior to commencement of development on site in paragraph 3.20.

The current reference to archaeology at criterion 6 is insufficient. We suggest that the wording is slightly amended to read:

Norfolk’s Historic Environment Service is consulted prior to application to determine the need for any archaeological assessments.

Change suggested by respondent:

Amend criterion in relation to archaeology to read:

Norfolk’s Historic Environment Service is consulted prior to
application to determine the need for any archaeological assessments.

Full text:

See attachment for full representation.

Object

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 4009

Received: 02/10/2024

Respondent: Ditchingham Farms Partnership

Agent: Evolution Town Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Please see the submitted representation statement. The extension to site VC DIT1 REV is not a sound amendment to the SNVC Housing Allocations Plan. Other sides such as the land adjoining Wildflower Way represent a more sustainable allocation. Without consulting on wider sites to cover the projected housing land shortfall, we consider the plan unsound, and legally non-compliant and that it has not been prepared in compliance with the duty to cooperate.

Change suggested by respondent:

Please see the submitted representation statement. The extension to site VC DIT1 REV is not a sound amendment to the SNVC Housing Allocations Plan. Other sides such as the land adjoining Wildflower Way represent a more sustainable allocation. Without consulting on wider sites to cover the projected housing land shortfall, we consider the plan unsound, and legally non-compliant and that it has not been prepared in compliance with the duty to cooperate.

Full text:

Please see the submitted representation statement. The extension to site VC DIT1 REV is not a sound amendment to the SNVC Housing Allocations Plan. Other sides such as the land adjoining Wildflower Way represent a more sustainable allocation. Without consulting on wider sites to cover the projected housing land shortfall, we consider the plan unsound, and legally non-compliant and that it has not been prepared in compliance with the duty to cooperate.

Attachments:

Object

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 4020

Received: 26/09/2024

Respondent: Norfolk County Council - Minerals and Waste Team

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Norfolk County Council in its capacity as the Mineral Planning Authority considers that Policy VC DIT1 REV is currently unsound; as it is inconsistent with national policy (NPPF paragraph 218), and the adopted Development Plan in Norfolk (policy CS16 of the Norfolk Minerals and Waste Core Strategy), in relation to mineral resource safeguarding. Proposed allocation VC DIT1 REV is over 2ha in size and underlain by a safeguarded mineral resource, sand and gravel. Therefore, the allocation of the site for development without policy requirements to avoid needless sterilisation of the mineral is not consistent with national policy.

The Mineral Planning Authority recognises that reference to underlain mineral resource has been included in the supporting text, however, we request inclusion of a requirement to avoid needless sterilisation of the mineral resource in the policy itself. We consider that it is appropriate and relevant for the requirements of a strategic policy (in this case Policy CS16 of the Norfolk Minerals and Waste Core Strategy) to be included in a site allocation policy where it sets out how the policy will apply to a specific site at the development management stage.

Change suggested by respondent:

In order to include measures to avoid needless sterilisation of the safeguarded mineral resources, in accordance with paragraph 218 of the NPPF, the policy wording for this site should be amended to include the following as a policy requirement:

‘This site is underlain by a safeguarded mineral resource; therefore investigation and assessment of the mineral will be required, potentially followed by prior extraction to ensure that needless sterilisation of viable mineral resource does not take place.’

Full text:

See attachment for full representation.

Attachments:

Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 4106

Received: 02/10/2024

Respondent: Water Management Alliance

Representation Summary:

Major development - If surface water discharges within the watershed catchment of the Board's IDD, we request that this discharge is facilitated in line with the Non-statutory technical standards for sustainable drainage systems (SuDS).

Full text:

See attachment for full representation

Attachments:

Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 4136

Received: 07/10/2024

Respondent: Environment Agency

Representation Summary:

For consistency and clarity, we recommend the wording of VC DIT1REV regarding “Early engagement with Anglian Water" is changed to reflect the wording for VC BRM1.

Full text:

As mentioned in our response to the VCHAP Alternative Sites & Focused Changes Regulation 18 Consultation, there are currently capacity issues at Ditchingham WRC. We are pleased to see the potential need for phasing to allow for upgrades to Ditchingham WRC due to the cumulative impact of recent and planned growth referred to in paragraph 3.18, although reference to potential phasing has been removed from the policy wording for VC DIT1REV. This now simply requires developers to ensure early engagement with Anglian Water to identify “connection to the local water recycling network”.
Policy VC BRM1, which is also served by Ditchingham WRC, requires the developer of the site to ensure “Early engagement with Anglian Water (AW) to ensure that there is adequate capacity, or capacity can be made available, in the wastewater network”. This wording seems stronger and more appropriate than the proposed wording for VC DIT1REV, which is for a significantly larger allocation. For consistency and clarity, we therefore recommend the wording of VC DIT1REV is changed to reflect the wording for VC BRM1.

Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Representation ID: 4173

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Anglian Water supports the policy requirement for early engagement for development at this site. There is limited dry weather flow permit headroom at the WRC to accommodate future growth in the catchment. As a result, the increase in the number of dwellings on the site, together with VC BRM1 and any additional windfall development coming forward, may cumulatively result in insufficient headroom being available at the WRC. Ditchingham WRC does not have an identified growth scheme for AMP8 (2025-2030) in our PR24 Business Plan. Therefore, should a growth scheme be required it would not be delivered until beyond 2030, and development would need to be phased accordingly.

The additional area identified to increase capacity of the site, impacts on another sewer (surface water) crossing the site, in addition to the foul sewer and water main. The policy requirement is therefore essential to ensure the protection of our assets and that they are appropriately accommodated within the development layout design.

Full text:

See attachment for full representation.

Attachments: