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

It is submitted that the facilities at the A146/A143 should be described in greater detail in relation to planning application 2020/0491 which includes a farm shop and application 2023/0187 (still to be determined) which seeks to provide an electric vehicle charging hub and associated shop, a drive-thru cafe/restaurant/sandwich shop/bakery and two buildings for use within Class E (g) (iii), B2 and B8 including trade counters and ancillary showrooms.

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

1.1. The following submissions consist of firstly comments on section 16 “Gillingham, Geldeston, and Stockton” of the Regulation 19 Pre-submission Draft of the South Norfolk Village Cluster Allocations Plan with specific comments on Gillingham.

1.2. The second set of submissions relates to the non-allocation of an area of land to the north of the street reference (SN0274) and the impact that this has on the soundness of the plan in relation to the residential allocations.

16. Gillingham, Geldeston, and Stockton
Form and Character
Gillingham

16.1.
NO COMMENTS

16.2.
NO COMMENTS

Services and Community Facilities
16.5. The cluster has a range of social and community facilities comprising a primary school, village hall and motel in Gillingham and a village hall and pub in Geldeston. Gillingham has a regular bus service to all local towns. There is a more limited bus service in Geldeston, to Diss, Bungay, Beccles and Yarmouth. There is a petrol station, with a convenience store, and fast-food restaurants to the north at the A146/A143 roundabout, which have a direct pedestrian/cycle link from the village.
COMMENT: It is submitted that the facilities at the A146/A143 should be described in greater detail in relation to planning application 2020/0491 which includes a farm shop and application 2023/0187 (still to be determined) which seeks to provide an electric vehicle charging hub and associated shop, a drive-thru cafe/restaurant/sandwich shop/bakery and two buildings for use within Class E (g) (iii), B2 and B8 including trade counters and ancillary showrooms. The area provides both services to the residents of the village as well as job opportunities. The ongoing expansion of the area can help to support the housing increase.

Settlement Limit
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
Gillingham
16.6. The Settlement Limit is in two parts. The first includes the main built form of the settlement. The second part is around the school and adjoining housing, an area which has been extended to include the recent development at Daisy Way, which was allocated in the 2015 Local Plan.
COMMENTS: The boundary of the Settlement Limit (red line) around Daisy Way and Tulip Close does not encompass all of the dwellings which have been approved and built. A strange ‘gap’ has been created between the boundary of the proposed allocation and the proposed settlement boundary.

VC GIL1
16.8. The site lies to the south of a detached area of existing residential development and Gillingham St Michael's Primary School, south of Geldeston Road/The Street, at the western end of the village. The site is well located for the local services, including a newly created pedestrian and cycle route to services at the A143/A146 junction, and buses on the main Norwich/Beccles route. Main facilities in Beccles are also within a reasonable cycling distance of the site.
COMMENT It is submitted that in addition to the reference to ‘services,’ there should be a reference to local employment opportunities offered by the facilities.

16.9.
NO COMMENTS

16.10.
NO COMMENTS

16.11. At the Regulation 18 stage of the VCHAP the site boundaries were drawn further to the east and included areas within Flood Risk Zones 2 and 3a and tidal flooding. Following the outputs of the Stage 2 Strategic Flood Risk Assessment (SFRA), the site boundaries were moved further east. However, this also incorporates areas at both surface and fluvial (Zones 2 and 3a) flood risk in the south-western corner and a remaining small area of tidal flooding in the southeast corner, which it is recommended are left undeveloped. Development of the site will require a site-specific Flood Risk Assessment (FRA) and strategy, to inform the layout of the site.
COMMENT The need for a full FRA is noted.

16.12. The site is immediately south of Gillingham St Michael's Primary School and would landlock the school if developed out in its entirety. The VCHAP currently proposes 35 dwellings on this site and a further 20 within the school catchment at Geldeston (VC GEL1), which would add a modest
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
number of pupils to the school. As both villages also experienced growth under the 2015 Local Plan and Gillingham has other sites that were shortlisted in the VCHAP Regulation 18, which are still being actively promoted, it would be reasonable to expect that there will continue to be growth in the future. As such, the County Council has requested that 0.5ha of land be safeguarded for the expansion of the Primary School, that would facilitate integration with remainder of the site when brought forward.
COMMENT The land requirement is noted.

16.13. The site is noted as being amber for great crested newt, due to the pond adjacent to the school. The site is also within an SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England.
COMMENT The need is noted

16.14. Although the site is 2.36ha, the allocation is for approximately 35 dwellings, reflecting the need to safeguard 0.5ha of land for F1(a) use for the Primary School and the need to address flood risk issues.

Policy VC GIL1: South of Geldeston Road and Daisy Way
2.36 ha of land is allocated for approximately 35 dwellings.
The developer of the site will be required to ensure:
 Vehicular and pedestrian access via Daisy Way;
 Pedestrian links to footpaths Geldeston FP8 and FP9 to the west of the site;
 Facilitation of the formal diversion of footpath Gillingham FP12, or the incorporation of the formal route into the layout of the site;
 A site-specific Flood Risk Assessment (FRA) and strategy that has regard to the issues identified in the Stage 2 VC Strategic Flood Risk Assessment (SFRA), to inform proposals for the site and preparation of a Flood Warning and Evacuation Plan;
 A full Landscape Assessment to inform the scale, form and density of the development, as well as the extent of the protection and enhancement of the existing vegetated boundaries;
 0.5ha of land set aside for Use Class F1(a), for future expansion of Gillingham St Michael's Primary School.
COMMENT The overarching requirements as set out in section 16.4 are noted

1.3. During the call for sites stage of the VCHAP two sites were put forward for Gillingham.
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
1.4. The land to the south of The Street is a proposed allocation in the plan. The land to the north of The Street has not been included as an allocation.
1.5. It is submitted, for the reasons set out below, that the uncertainty surrounding the implementation of the plan as a result of the impact of Nutrient Neutrality undermines the overall aims of achieving a proscribed number of dwellings.
1.6. The land to the north (SN0274) was shortlisted as a potential allocation. While the exact extent of the Flood Zone would need to be established in detail it was noted that there were few other planning constraints. It was also noted that the site would help to provide good connections to the service/employment land to the north.
1.7. The allocation of the northern site could provide much-needed amenities like a proper playground and a Multi-Use Games Area as shown in the proposed application. An all-weather area that can be used as a coloured playground and can be designed to accommodate a wide range of sports, training and games. A MUGA pitch would be an important community asset for the village.
1.8. The need for affordable housing within Gillingham could be increased by the construction of a greater number of units than would normally arise from the Local Plan percentages.
1.9. The allocation of the site would enable a continuous flow of housing development to take place rather than the ‘feast and famine’ which results from the plan-making cycle of the Local Plan process.
1.10. The VCHAP both in the main report and the Viability Appraisal document details, as far as possible, the impact of Nutrient Neutrality.
1.11. The Viability Appraisal seeks to determine if “a ‘surplus’ is generated to enable either a Nutrient Neutrality Tariff to be levied for ‘off-site mitigation, that a proposed development has sufficient capacity to cover any increase in ‘on-site mitigation costs, or, a combination of both ‘on’ and ‘off-site costs”. The final details have yet to be modelled and resolved and this introduces a degree of uncertainty in meeting the aims of the plan.
1.12. At present, there appears to be no time frame available as to when the issues associated with Nutrient Neutrality and possible ‘Tariff’ will; be resolved. In
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
addition, it is uncertain if the developers of the sites will be able to comply with any tariff requirements.
1.13. Residential land allocations in some settlements are located within Nutrient Neutrality Zones. This means that while the VCHAP process can move forward there is a strong possibility that the construction of dwellings will be delayed for a yet unknown time. The table, taken from the VCHAP documentation shows those settlements, including the site allocations which are being ‘brought forward’ from the previous plan are currently subject to ‘Nutrient Neutrality constraints.
1.14. The table shows that of the 1122 dwellings shown as allocations 413 (37%) are subject to nutrient Neutrality constraints. Of the 173 dwellings carried forward from 2015 145 (84%) are subject to Nutrient Neutrality constraints
1.15. The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.
1.16. It is submitted that the plan is over-optimistic regarding the impact of Nutrient Neutrality on the allocations. As a result, it fails the test of soundness.

G D Smith
Landmark Associates
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)

Encompass all of the dwellings which have been approved and built around Daisy Way and Tulip Close.

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

1.1. The following submissions consist of firstly comments on section 16 “Gillingham, Geldeston, and Stockton” of the Regulation 19 Pre-submission Draft of the South Norfolk Village Cluster Allocations Plan with specific comments on Gillingham.

1.2. The second set of submissions relates to the non-allocation of an area of land to the north of the street reference (SN0274) and the impact that this has on the soundness of the plan in relation to the residential allocations.

16. Gillingham, Geldeston, and Stockton
Form and Character
Gillingham

16.1.
NO COMMENTS

16.2.
NO COMMENTS

Services and Community Facilities
16.5. The cluster has a range of social and community facilities comprising a primary school, village hall and motel in Gillingham and a village hall and pub in Geldeston. Gillingham has a regular bus service to all local towns. There is a more limited bus service in Geldeston, to Diss, Bungay, Beccles and Yarmouth. There is a petrol station, with a convenience store, and fast-food restaurants to the north at the A146/A143 roundabout, which have a direct pedestrian/cycle link from the village.
COMMENT: It is submitted that the facilities at the A146/A143 should be described in greater detail in relation to planning application 2020/0491 which includes a farm shop and application 2023/0187 (still to be determined) which seeks to provide an electric vehicle charging hub and associated shop, a drive-thru cafe/restaurant/sandwich shop/bakery and two buildings for use within Class E (g) (iii), B2 and B8 including trade counters and ancillary showrooms. The area provides both services to the residents of the village as well as job opportunities. The ongoing expansion of the area can help to support the housing increase.

Settlement Limit
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
Gillingham
16.6. The Settlement Limit is in two parts. The first includes the main built form of the settlement. The second part is around the school and adjoining housing, an area which has been extended to include the recent development at Daisy Way, which was allocated in the 2015 Local Plan.
COMMENTS: The boundary of the Settlement Limit (red line) around Daisy Way and Tulip Close does not encompass all of the dwellings which have been approved and built. A strange ‘gap’ has been created between the boundary of the proposed allocation and the proposed settlement boundary.

VC GIL1
16.8. The site lies to the south of a detached area of existing residential development and Gillingham St Michael's Primary School, south of Geldeston Road/The Street, at the western end of the village. The site is well located for the local services, including a newly created pedestrian and cycle route to services at the A143/A146 junction, and buses on the main Norwich/Beccles route. Main facilities in Beccles are also within a reasonable cycling distance of the site.
COMMENT It is submitted that in addition to the reference to ‘services,’ there should be a reference to local employment opportunities offered by the facilities.

16.9.
NO COMMENTS

16.10.
NO COMMENTS

16.11. At the Regulation 18 stage of the VCHAP the site boundaries were drawn further to the east and included areas within Flood Risk Zones 2 and 3a and tidal flooding. Following the outputs of the Stage 2 Strategic Flood Risk Assessment (SFRA), the site boundaries were moved further east. However, this also incorporates areas at both surface and fluvial (Zones 2 and 3a) flood risk in the south-western corner and a remaining small area of tidal flooding in the southeast corner, which it is recommended are left undeveloped. Development of the site will require a site-specific Flood Risk Assessment (FRA) and strategy, to inform the layout of the site.
COMMENT The need for a full FRA is noted.

16.12. The site is immediately south of Gillingham St Michael's Primary School and would landlock the school if developed out in its entirety. The VCHAP currently proposes 35 dwellings on this site and a further 20 within the school catchment at Geldeston (VC GEL1), which would add a modest
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
number of pupils to the school. As both villages also experienced growth under the 2015 Local Plan and Gillingham has other sites that were shortlisted in the VCHAP Regulation 18, which are still being actively promoted, it would be reasonable to expect that there will continue to be growth in the future. As such, the County Council has requested that 0.5ha of land be safeguarded for the expansion of the Primary School, that would facilitate integration with remainder of the site when brought forward.
COMMENT The land requirement is noted.

16.13. The site is noted as being amber for great crested newt, due to the pond adjacent to the school. The site is also within an SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England.
COMMENT The need is noted

16.14. Although the site is 2.36ha, the allocation is for approximately 35 dwellings, reflecting the need to safeguard 0.5ha of land for F1(a) use for the Primary School and the need to address flood risk issues.

Policy VC GIL1: South of Geldeston Road and Daisy Way
2.36 ha of land is allocated for approximately 35 dwellings.
The developer of the site will be required to ensure:
 Vehicular and pedestrian access via Daisy Way;
 Pedestrian links to footpaths Geldeston FP8 and FP9 to the west of the site;
 Facilitation of the formal diversion of footpath Gillingham FP12, or the incorporation of the formal route into the layout of the site;
 A site-specific Flood Risk Assessment (FRA) and strategy that has regard to the issues identified in the Stage 2 VC Strategic Flood Risk Assessment (SFRA), to inform proposals for the site and preparation of a Flood Warning and Evacuation Plan;
 A full Landscape Assessment to inform the scale, form and density of the development, as well as the extent of the protection and enhancement of the existing vegetated boundaries;
 0.5ha of land set aside for Use Class F1(a), for future expansion of Gillingham St Michael's Primary School.
COMMENT The overarching requirements as set out in section 16.4 are noted

1.3. During the call for sites stage of the VCHAP two sites were put forward for Gillingham.
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
1.4. The land to the south of The Street is a proposed allocation in the plan. The land to the north of The Street has not been included as an allocation.
1.5. It is submitted, for the reasons set out below, that the uncertainty surrounding the implementation of the plan as a result of the impact of Nutrient Neutrality undermines the overall aims of achieving a proscribed number of dwellings.
1.6. The land to the north (SN0274) was shortlisted as a potential allocation. While the exact extent of the Flood Zone would need to be established in detail it was noted that there were few other planning constraints. It was also noted that the site would help to provide good connections to the service/employment land to the north.
1.7. The allocation of the northern site could provide much-needed amenities like a proper playground and a Multi-Use Games Area as shown in the proposed application. An all-weather area that can be used as a coloured playground and can be designed to accommodate a wide range of sports, training and games. A MUGA pitch would be an important community asset for the village.
1.8. The need for affordable housing within Gillingham could be increased by the construction of a greater number of units than would normally arise from the Local Plan percentages.
1.9. The allocation of the site would enable a continuous flow of housing development to take place rather than the ‘feast and famine’ which results from the plan-making cycle of the Local Plan process.
1.10. The VCHAP both in the main report and the Viability Appraisal document details, as far as possible, the impact of Nutrient Neutrality.
1.11. The Viability Appraisal seeks to determine if “a ‘surplus’ is generated to enable either a Nutrient Neutrality Tariff to be levied for ‘off-site mitigation, that a proposed development has sufficient capacity to cover any increase in ‘on-site mitigation costs, or, a combination of both ‘on’ and ‘off-site costs”. The final details have yet to be modelled and resolved and this introduces a degree of uncertainty in meeting the aims of the plan.
1.12. At present, there appears to be no time frame available as to when the issues associated with Nutrient Neutrality and possible ‘Tariff’ will; be resolved. In
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
addition, it is uncertain if the developers of the sites will be able to comply with any tariff requirements.
1.13. Residential land allocations in some settlements are located within Nutrient Neutrality Zones. This means that while the VCHAP process can move forward there is a strong possibility that the construction of dwellings will be delayed for a yet unknown time. The table, taken from the VCHAP documentation shows those settlements, including the site allocations which are being ‘brought forward’ from the previous plan are currently subject to ‘Nutrient Neutrality constraints.
1.14. The table shows that of the 1122 dwellings shown as allocations 413 (37%) are subject to nutrient Neutrality constraints. Of the 173 dwellings carried forward from 2015 145 (84%) are subject to Nutrient Neutrality constraints
1.15. The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.
1.16. It is submitted that the plan is over-optimistic regarding the impact of Nutrient Neutrality on the allocations. As a result, it fails the test of soundness.

G D Smith
Landmark Associates
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)

It is submitted that in addition to the reference to ‘services,’ there should be a reference to local employment opportunities offered by the facilities.

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

1.1. The following submissions consist of firstly comments on section 16 “Gillingham, Geldeston, and Stockton” of the Regulation 19 Pre-submission Draft of the South Norfolk Village Cluster Allocations Plan with specific comments on Gillingham.

1.2. The second set of submissions relates to the non-allocation of an area of land to the north of the street reference (SN0274) and the impact that this has on the soundness of the plan in relation to the residential allocations.

16. Gillingham, Geldeston, and Stockton
Form and Character
Gillingham

16.1.
NO COMMENTS

16.2.
NO COMMENTS

Services and Community Facilities
16.5. The cluster has a range of social and community facilities comprising a primary school, village hall and motel in Gillingham and a village hall and pub in Geldeston. Gillingham has a regular bus service to all local towns. There is a more limited bus service in Geldeston, to Diss, Bungay, Beccles and Yarmouth. There is a petrol station, with a convenience store, and fast-food restaurants to the north at the A146/A143 roundabout, which have a direct pedestrian/cycle link from the village.
COMMENT: It is submitted that the facilities at the A146/A143 should be described in greater detail in relation to planning application 2020/0491 which includes a farm shop and application 2023/0187 (still to be determined) which seeks to provide an electric vehicle charging hub and associated shop, a drive-thru cafe/restaurant/sandwich shop/bakery and two buildings for use within Class E (g) (iii), B2 and B8 including trade counters and ancillary showrooms. The area provides both services to the residents of the village as well as job opportunities. The ongoing expansion of the area can help to support the housing increase.

Settlement Limit
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
Gillingham
16.6. The Settlement Limit is in two parts. The first includes the main built form of the settlement. The second part is around the school and adjoining housing, an area which has been extended to include the recent development at Daisy Way, which was allocated in the 2015 Local Plan.
COMMENTS: The boundary of the Settlement Limit (red line) around Daisy Way and Tulip Close does not encompass all of the dwellings which have been approved and built. A strange ‘gap’ has been created between the boundary of the proposed allocation and the proposed settlement boundary.

VC GIL1
16.8. The site lies to the south of a detached area of existing residential development and Gillingham St Michael's Primary School, south of Geldeston Road/The Street, at the western end of the village. The site is well located for the local services, including a newly created pedestrian and cycle route to services at the A143/A146 junction, and buses on the main Norwich/Beccles route. Main facilities in Beccles are also within a reasonable cycling distance of the site.
COMMENT It is submitted that in addition to the reference to ‘services,’ there should be a reference to local employment opportunities offered by the facilities.

16.9.
NO COMMENTS

16.10.
NO COMMENTS

16.11. At the Regulation 18 stage of the VCHAP the site boundaries were drawn further to the east and included areas within Flood Risk Zones 2 and 3a and tidal flooding. Following the outputs of the Stage 2 Strategic Flood Risk Assessment (SFRA), the site boundaries were moved further east. However, this also incorporates areas at both surface and fluvial (Zones 2 and 3a) flood risk in the south-western corner and a remaining small area of tidal flooding in the southeast corner, which it is recommended are left undeveloped. Development of the site will require a site-specific Flood Risk Assessment (FRA) and strategy, to inform the layout of the site.
COMMENT The need for a full FRA is noted.

16.12. The site is immediately south of Gillingham St Michael's Primary School and would landlock the school if developed out in its entirety. The VCHAP currently proposes 35 dwellings on this site and a further 20 within the school catchment at Geldeston (VC GEL1), which would add a modest
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
number of pupils to the school. As both villages also experienced growth under the 2015 Local Plan and Gillingham has other sites that were shortlisted in the VCHAP Regulation 18, which are still being actively promoted, it would be reasonable to expect that there will continue to be growth in the future. As such, the County Council has requested that 0.5ha of land be safeguarded for the expansion of the Primary School, that would facilitate integration with remainder of the site when brought forward.
COMMENT The land requirement is noted.

16.13. The site is noted as being amber for great crested newt, due to the pond adjacent to the school. The site is also within an SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England.
COMMENT The need is noted

16.14. Although the site is 2.36ha, the allocation is for approximately 35 dwellings, reflecting the need to safeguard 0.5ha of land for F1(a) use for the Primary School and the need to address flood risk issues.

Policy VC GIL1: South of Geldeston Road and Daisy Way
2.36 ha of land is allocated for approximately 35 dwellings.
The developer of the site will be required to ensure:
 Vehicular and pedestrian access via Daisy Way;
 Pedestrian links to footpaths Geldeston FP8 and FP9 to the west of the site;
 Facilitation of the formal diversion of footpath Gillingham FP12, or the incorporation of the formal route into the layout of the site;
 A site-specific Flood Risk Assessment (FRA) and strategy that has regard to the issues identified in the Stage 2 VC Strategic Flood Risk Assessment (SFRA), to inform proposals for the site and preparation of a Flood Warning and Evacuation Plan;
 A full Landscape Assessment to inform the scale, form and density of the development, as well as the extent of the protection and enhancement of the existing vegetated boundaries;
 0.5ha of land set aside for Use Class F1(a), for future expansion of Gillingham St Michael's Primary School.
COMMENT The overarching requirements as set out in section 16.4 are noted

1.3. During the call for sites stage of the VCHAP two sites were put forward for Gillingham.
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
1.4. The land to the south of The Street is a proposed allocation in the plan. The land to the north of The Street has not been included as an allocation.
1.5. It is submitted, for the reasons set out below, that the uncertainty surrounding the implementation of the plan as a result of the impact of Nutrient Neutrality undermines the overall aims of achieving a proscribed number of dwellings.
1.6. The land to the north (SN0274) was shortlisted as a potential allocation. While the exact extent of the Flood Zone would need to be established in detail it was noted that there were few other planning constraints. It was also noted that the site would help to provide good connections to the service/employment land to the north.
1.7. The allocation of the northern site could provide much-needed amenities like a proper playground and a Multi-Use Games Area as shown in the proposed application. An all-weather area that can be used as a coloured playground and can be designed to accommodate a wide range of sports, training and games. A MUGA pitch would be an important community asset for the village.
1.8. The need for affordable housing within Gillingham could be increased by the construction of a greater number of units than would normally arise from the Local Plan percentages.
1.9. The allocation of the site would enable a continuous flow of housing development to take place rather than the ‘feast and famine’ which results from the plan-making cycle of the Local Plan process.
1.10. The VCHAP both in the main report and the Viability Appraisal document details, as far as possible, the impact of Nutrient Neutrality.
1.11. The Viability Appraisal seeks to determine if “a ‘surplus’ is generated to enable either a Nutrient Neutrality Tariff to be levied for ‘off-site mitigation, that a proposed development has sufficient capacity to cover any increase in ‘on-site mitigation costs, or, a combination of both ‘on’ and ‘off-site costs”. The final details have yet to be modelled and resolved and this introduces a degree of uncertainty in meeting the aims of the plan.
1.12. At present, there appears to be no time frame available as to when the issues associated with Nutrient Neutrality and possible ‘Tariff’ will; be resolved. In
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
addition, it is uncertain if the developers of the sites will be able to comply with any tariff requirements.
1.13. Residential land allocations in some settlements are located within Nutrient Neutrality Zones. This means that while the VCHAP process can move forward there is a strong possibility that the construction of dwellings will be delayed for a yet unknown time. The table, taken from the VCHAP documentation shows those settlements, including the site allocations which are being ‘brought forward’ from the previous plan are currently subject to ‘Nutrient Neutrality constraints.
1.14. The table shows that of the 1122 dwellings shown as allocations 413 (37%) are subject to nutrient Neutrality constraints. Of the 173 dwellings carried forward from 2015 145 (84%) are subject to Nutrient Neutrality constraints
1.15. The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.
1.16. It is submitted that the plan is over-optimistic regarding the impact of Nutrient Neutrality on the allocations. As a result, it fails the test of soundness.

G D Smith
Landmark Associates
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)

The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.

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

1.1. The following submissions consist of firstly comments on section 16 “Gillingham, Geldeston, and Stockton” of the Regulation 19 Pre-submission Draft of the South Norfolk Village Cluster Allocations Plan with specific comments on Gillingham.

1.2. The second set of submissions relates to the non-allocation of an area of land to the north of the street reference (SN0274) and the impact that this has on the soundness of the plan in relation to the residential allocations.

16. Gillingham, Geldeston, and Stockton
Form and Character
Gillingham

16.1.
NO COMMENTS

16.2.
NO COMMENTS

Services and Community Facilities
16.5. The cluster has a range of social and community facilities comprising a primary school, village hall and motel in Gillingham and a village hall and pub in Geldeston. Gillingham has a regular bus service to all local towns. There is a more limited bus service in Geldeston, to Diss, Bungay, Beccles and Yarmouth. There is a petrol station, with a convenience store, and fast-food restaurants to the north at the A146/A143 roundabout, which have a direct pedestrian/cycle link from the village.
COMMENT: It is submitted that the facilities at the A146/A143 should be described in greater detail in relation to planning application 2020/0491 which includes a farm shop and application 2023/0187 (still to be determined) which seeks to provide an electric vehicle charging hub and associated shop, a drive-thru cafe/restaurant/sandwich shop/bakery and two buildings for use within Class E (g) (iii), B2 and B8 including trade counters and ancillary showrooms. The area provides both services to the residents of the village as well as job opportunities. The ongoing expansion of the area can help to support the housing increase.

Settlement Limit
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
Gillingham
16.6. The Settlement Limit is in two parts. The first includes the main built form of the settlement. The second part is around the school and adjoining housing, an area which has been extended to include the recent development at Daisy Way, which was allocated in the 2015 Local Plan.
COMMENTS: The boundary of the Settlement Limit (red line) around Daisy Way and Tulip Close does not encompass all of the dwellings which have been approved and built. A strange ‘gap’ has been created between the boundary of the proposed allocation and the proposed settlement boundary.

VC GIL1
16.8. The site lies to the south of a detached area of existing residential development and Gillingham St Michael's Primary School, south of Geldeston Road/The Street, at the western end of the village. The site is well located for the local services, including a newly created pedestrian and cycle route to services at the A143/A146 junction, and buses on the main Norwich/Beccles route. Main facilities in Beccles are also within a reasonable cycling distance of the site.
COMMENT It is submitted that in addition to the reference to ‘services,’ there should be a reference to local employment opportunities offered by the facilities.

16.9.
NO COMMENTS

16.10.
NO COMMENTS

16.11. At the Regulation 18 stage of the VCHAP the site boundaries were drawn further to the east and included areas within Flood Risk Zones 2 and 3a and tidal flooding. Following the outputs of the Stage 2 Strategic Flood Risk Assessment (SFRA), the site boundaries were moved further east. However, this also incorporates areas at both surface and fluvial (Zones 2 and 3a) flood risk in the south-western corner and a remaining small area of tidal flooding in the southeast corner, which it is recommended are left undeveloped. Development of the site will require a site-specific Flood Risk Assessment (FRA) and strategy, to inform the layout of the site.
COMMENT The need for a full FRA is noted.

16.12. The site is immediately south of Gillingham St Michael's Primary School and would landlock the school if developed out in its entirety. The VCHAP currently proposes 35 dwellings on this site and a further 20 within the school catchment at Geldeston (VC GEL1), which would add a modest
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
number of pupils to the school. As both villages also experienced growth under the 2015 Local Plan and Gillingham has other sites that were shortlisted in the VCHAP Regulation 18, which are still being actively promoted, it would be reasonable to expect that there will continue to be growth in the future. As such, the County Council has requested that 0.5ha of land be safeguarded for the expansion of the Primary School, that would facilitate integration with remainder of the site when brought forward.
COMMENT The land requirement is noted.

16.13. The site is noted as being amber for great crested newt, due to the pond adjacent to the school. The site is also within an SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England.
COMMENT The need is noted

16.14. Although the site is 2.36ha, the allocation is for approximately 35 dwellings, reflecting the need to safeguard 0.5ha of land for F1(a) use for the Primary School and the need to address flood risk issues.

Policy VC GIL1: South of Geldeston Road and Daisy Way
2.36 ha of land is allocated for approximately 35 dwellings.
The developer of the site will be required to ensure:
 Vehicular and pedestrian access via Daisy Way;
 Pedestrian links to footpaths Geldeston FP8 and FP9 to the west of the site;
 Facilitation of the formal diversion of footpath Gillingham FP12, or the incorporation of the formal route into the layout of the site;
 A site-specific Flood Risk Assessment (FRA) and strategy that has regard to the issues identified in the Stage 2 VC Strategic Flood Risk Assessment (SFRA), to inform proposals for the site and preparation of a Flood Warning and Evacuation Plan;
 A full Landscape Assessment to inform the scale, form and density of the development, as well as the extent of the protection and enhancement of the existing vegetated boundaries;
 0.5ha of land set aside for Use Class F1(a), for future expansion of Gillingham St Michael's Primary School.
COMMENT The overarching requirements as set out in section 16.4 are noted

1.3. During the call for sites stage of the VCHAP two sites were put forward for Gillingham.
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
1.4. The land to the south of The Street is a proposed allocation in the plan. The land to the north of The Street has not been included as an allocation.
1.5. It is submitted, for the reasons set out below, that the uncertainty surrounding the implementation of the plan as a result of the impact of Nutrient Neutrality undermines the overall aims of achieving a proscribed number of dwellings.
1.6. The land to the north (SN0274) was shortlisted as a potential allocation. While the exact extent of the Flood Zone would need to be established in detail it was noted that there were few other planning constraints. It was also noted that the site would help to provide good connections to the service/employment land to the north.
1.7. The allocation of the northern site could provide much-needed amenities like a proper playground and a Multi-Use Games Area as shown in the proposed application. An all-weather area that can be used as a coloured playground and can be designed to accommodate a wide range of sports, training and games. A MUGA pitch would be an important community asset for the village.
1.8. The need for affordable housing within Gillingham could be increased by the construction of a greater number of units than would normally arise from the Local Plan percentages.
1.9. The allocation of the site would enable a continuous flow of housing development to take place rather than the ‘feast and famine’ which results from the plan-making cycle of the Local Plan process.
1.10. The VCHAP both in the main report and the Viability Appraisal document details, as far as possible, the impact of Nutrient Neutrality.
1.11. The Viability Appraisal seeks to determine if “a ‘surplus’ is generated to enable either a Nutrient Neutrality Tariff to be levied for ‘off-site mitigation, that a proposed development has sufficient capacity to cover any increase in ‘on-site mitigation costs, or, a combination of both ‘on’ and ‘off-site costs”. The final details have yet to be modelled and resolved and this introduces a degree of uncertainty in meeting the aims of the plan.
1.12. At present, there appears to be no time frame available as to when the issues associated with Nutrient Neutrality and possible ‘Tariff’ will; be resolved. In
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
addition, it is uncertain if the developers of the sites will be able to comply with any tariff requirements.
1.13. Residential land allocations in some settlements are located within Nutrient Neutrality Zones. This means that while the VCHAP process can move forward there is a strong possibility that the construction of dwellings will be delayed for a yet unknown time. The table, taken from the VCHAP documentation shows those settlements, including the site allocations which are being ‘brought forward’ from the previous plan are currently subject to ‘Nutrient Neutrality constraints.
1.14. The table shows that of the 1122 dwellings shown as allocations 413 (37%) are subject to nutrient Neutrality constraints. Of the 173 dwellings carried forward from 2015 145 (84%) are subject to Nutrient Neutrality constraints
1.15. The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.
1.16. It is submitted that the plan is over-optimistic regarding the impact of Nutrient Neutrality on the allocations. As a result, it fails the test of soundness.

G D Smith
Landmark Associates
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)