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

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 also makes the SNVCHAP unsound and therefore it should not be adopted.

CPRE Norfolk 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.

CPRE Norfolk and others made several challenges to the soundness of the Reg. 19 GNLP in the consultation and at its Public Examination. The result of these challenges is not known at present (31 January 2023) e.g. whether they will result in the GNLP not being adopted or in Major Modifications being necessary. Now that the SNVCHAP has gone to its Reg. 19 consultation this difference in timelines for the two plans makes them both unsound. Without knowing the outcome of the GNLP’s Public Examination with regard to issues around the SNVCHAP it is unsound to make any judgement about the latter.

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, given the 1,228 dwellings in the SNVCHAP are unnecessary development.

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 also makes the SNVCHAP unsound.

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 also makes the SNVCHAP unsound and should therefore not be adopted.

CPRE Norfolk 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.

CPRE Norfolk and others made several challenges to the soundness of the Reg. 19 GNLP in the consultation and at its Public Examination. The result of these challenges is not known at present (31 January 2023) e.g. whether they will result in the GNLP not being adopted or in Major Modifications being necessary. Now that the SNVCHAP has gone to its Reg. 19 consultation this difference in timelines for the two plans makes them both unsound. Without knowing the outcome of the GNLP’s Public Examination with regard to issues around the SNVCHAP it is unsound to make any judgement about the latter.

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, given the 1,228 dwellings in the SNVCHAP are unnecessary development.

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 also makes the SNVCHAP unsound.

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 also makes the SNVCHAP unsound. Therefore the SNVCHAP should not be adopted.

CPRE Norfolk 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.

CPRE Norfolk and others made several challenges to the soundness of the Reg. 19 GNLP in the consultation and at its Public Examination. The result of these challenges is not known at present (31 January 2023) e.g. whether they will result in the GNLP not being adopted or in Major Modifications being necessary. Now that the SNVCHAP has gone to its Reg. 19 consultation this difference in timelines for the two plans makes them both unsound. Without knowing the outcome of the GNLP’s Public Examination with regard to issues around the SNVCHAP it is unsound to make any judgement about the latter.

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, given the 1,228 dwellings in the SNVCHAP are unnecessary development.

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 also makes the SNVCHAP unsound.