South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)

Given that the housing numbers proposed for inclusion in the GNLP could be found to be unsound and unnecessarily large this reinforces the view of Hempnall Parish Council which is that there is no need for additional sites to be allocated for housing in the village as part of the South Norfolk Village Clusters Plan and indeed there is no need for any allocations to be made anywhere in South Norfolk via the SNVCHAP.

Hempnall Parish Council challenges the decoupling of the housing allocations for the South Norfolk Village Clusters and its associated policy from the rest of the GNLP as being unsound. The GNLP Regulation 19 consultation commenced before the South Norfolk Village Clusters Housing Allocations document (SNVCHAP) was published for its Regulation 18 consultation. This was despite the South Norfolk Local Development Scheme (accessed 18 February 2021 when it was labelled as “final”) stating that the SNVCHAP would be consulted on in February/March 2021, whereas it took place later in the year, ending on 2 August 2021. While it is reasonable for a Local Plan to comprise several separate documents, the GNLP and the SNVCHAP to be sound should follow the same, or at least a very similar timetable, otherwise it is impossible to judge whether the two (or more) documents are based on proportionate evidence.
Now that The SNVCHAP has progressed to its Reg. 19 consultation phase the difference in timelines between the GNLP and the SNVCHAP has become even more pronounced and this potentially renders both plans unsound. The outcome of the GNLP’s Public Examination with regard to issues around the SNVCHAP is currently unknown and until the Inspectors clarify these matters the soundness of the SNVCHAP is open to question.
These challenges to the GNLP included questioning the housing numbers, which if found to be unsound, would impact on the numbers to be allocated in the SNVCHAP. The housing numbers within the draft GNLP include the 1,228 in the draft SNVCHAP, within a total delivery target of 49,492 new dwellings to 2038. This figure would accommodate 22% more houses than “need”, along with a “contingency” location for growth. Additional housing, on top of these 49,492 will be provided by windfall development which will be in excess to that accounted for in the 49,492 figure, as only 1,296 windfall dwellings have been included, despite the Reg. 19 GNLP document forecasting that 4,450 windfalls will come forward during the plan period. Across the combined districts covered by the draft GNLP, sites already allocated by the current Local Plan, the Joint Core Strategy (JCS), should be delivered before there is any consideration of additional new sites, including all of those within the SNVCHAP. This is because any newly allocated sites will be in less sustainable locations than those already allocated in the JCS, and will therefore make it more difficult to adhere to Climate Change targets. The SNVCHAP is a means to deliver a policy of dispersal of housing, in largely less-sustainable car-dependent locations, with few employment opportunities. The development of greenfield sites, often on Best and Most Versatile (BMV) agricultural land, should be avoided.
To address these issues and to make the two plans sound they should run to the same timetable. As outlined above the inclusion of unnecessary housing numbers within the SNVCHAP in unsustainable locations makes the SNVCHAP unsound.
Given that the housing numbers proposed for inclusion in the GNLP could be found to be unsound and unnecessarily large this reinforces the view of Hempnall Parish Council which is that there is no need for additional sites to be allocated for housing in the village as part of the South Norfolk Village Clusters Plan and indeed there is no need for any allocations to be made anywhere in South Norfolk via the SNVCHAP.

Hempnall Parish Council policy states that the current recent development at Willow Drive together with infill (windfall) developments and the hoped for provision of social housing on the site now called VC HEM1 is considered the right amount of new housing for the village. In total these developments will increase the number of houses in the village by around 10% - a manageable amount which will enable the successful assimilation of the new households into the community but not an over large number which would threaten the character and environment of Hempnall.

Notwithstanding our opposition to the whole concept of village clusters Hempnall Parish Council does welcome the fact that none of the other sites (other than VC HEM1) put forward by landowners/developers for inclusion in the SNVC plan have progressed in to the documents that are being circulated in the Regulation 19 consultation and we re-state our strong opposition to the inclusion of any further sites in Hempnall other than VC HEM1.

Notwithstanding our opposition to the whole concept of village clusters Hempnall Parish Council does welcome the fact that none of the other sites (other than VC HEM1) put forward by landowners/developers for inclusion in the SNVC plan have progressed in to the documents that are being circulated in the Regulation 19 consultation and we re-state our strong opposition to the inclusion of any further sites in Hempnall other than VC HEM1.

Hempnall Parish Council challenges the decoupling of the housing allocations for the South Norfolk Village Clusters and its associated policy from the rest of the GNLP as being unsound. The GNLP Regulation 19 consultation commenced before the South Norfolk Village Clusters Housing Allocations document (SNVCHAP) was published for its Regulation 18 consultation. This was despite the South Norfolk Local Development Scheme (accessed 18 February 2021 when it was labelled as “final”) stating that the SNVCHAP would be consulted on in February/March 2021, whereas it took place later in the year, ending on 2 August 2021. While it is reasonable for a Local Plan to comprise several separate documents, the GNLP and the SNVCHAP to be sound should follow the same, or at least a very similar timetable, otherwise it is impossible to judge whether the two (or more) documents are based on proportionate evidence.
Now that The SNVCHAP has progressed to its Reg. 19 consultation phase the difference in timelines between the GNLP and the SNVCHAP has become even more pronounced and this potentially renders both plans unsound. The outcome of the GNLP’s Public Examination with regard to issues around the SNVCHAP is currently unknown and until the Inspectors clarify these matters the soundness of the SNVCHAP is open to question.
These challenges to the GNLP included questioning the housing numbers, which if found to be unsound, would impact on the numbers to be allocated in the SNVCHAP. The housing numbers within the draft GNLP include the 1,228 in the draft SNVCHAP, within a total delivery target of 49,492 new dwellings to 2038. This figure would accommodate 22% more houses than “need”, along with a “contingency” location for growth. Additional housing, on top of these 49,492 will be provided by windfall development which will be in excess to that accounted for in the 49,492 figure, as only 1,296 windfall dwellings have been included, despite the Reg. 19 GNLP document forecasting that 4,450 windfalls will come forward during the plan period. Across the combined districts covered by the draft GNLP, sites already allocated by the current Local Plan, the Joint Core Strategy (JCS), should be delivered before there is any consideration of additional new sites, including all of those within the SNVCHAP. This is because any newly allocated sites will be in less sustainable locations than those already allocated in the JCS, and will therefore make it more difficult to adhere to Climate Change targets. The SNVCHAP is a means to deliver a policy of dispersal of housing, in largely less-sustainable car-dependent locations, with few employment opportunities. The development of greenfield sites, often on Best and Most Versatile (BMV) agricultural land, should be avoided.
To address these issues and to make the two plans sound they should run to the same timetable. As outlined above the inclusion of unnecessary housing numbers within the SNVCHAP in unsustainable locations makes the SNVCHAP unsound.
Given that the housing numbers proposed for inclusion in the GNLP could be found to be unsound and unnecessarily large this reinforces the view of Hempnall Parish Council which is that there is no need for additional sites to be allocated for housing in the village as part of the South Norfolk Village Clusters Plan and indeed there is no need for any allocations to be made anywhere in South Norfolk via the SNVCHAP.

Hempnall Parish Council policy states that the current recent development at Willow Drive together with infill (windfall) developments and the hoped for provision of social housing on the site now called VC HEM1 is considered the right amount of new housing for the village. In total these developments will increase the number of houses in the village by around 10% - a manageable amount which will enable the successful assimilation of the new households into the community but not an over large number which would threaten the character and environment of Hempnall.

Notwithstanding our opposition to the whole concept of village clusters Hempnall Parish Council does welcome the fact that none of the other sites (other than VC HEM1) put forward by landowners/developers for inclusion in the SNVC plan have progressed in to the documents that are being circulated in the Regulation 19 consultation and we re-state our strong opposition to the inclusion of any further sites in Hempnall other than VC HEM1.