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

Sites should be allocated where they provide green amenity space for the benefit of the development and the wider village, not just on where they can be fitted in as it appears in this plan. Access improvements must be taken advantage of where offered for wider benefit alongside landscape features to protect historic and natural features. The Barford allocated site only offers landscape improvement based on an opinion after commercial premises have been taken away and not replaced. Wider landscaping and highways improvement around Back Lane would make the whole plan work better in isolation and for the wider community. My proposal would be to leave the businesses in place and allocate the vacant land to the north and south of Back Lane. Back lane's access onto the B1108 can then be moved north to a safe vision splay helping the development and through traffic. Landscaping and access to amenity land for the development and wider community will benefit all. Ideas of what can be achieved are attached with the exact layout to be agreed.
Adopting the allocation in the current VCHP only provides the houses, it removes business premises and offers no environmental value to anyone. There are better schemes available.

Whilst i can support the landscape improvement value to Barford of removing the garage site, the change of use to housing is compromised by the access next to the B1108 junction which is now unsuitable for residential use given the volume of traffic. The development also removes premises for two active businesses and employment, without allocation of an alternative in the village. The development ignores the significant amenity space, improved access for Back Lane and landscaping available from other proposed sites. 20 houses will be on a busy B road with poor access and limited amenity space.

The plan should take into account wider benefits to housing development such as provision of green space and improved access where available. These should be considered alongside environmental benefits and and benefits to the wider community. This allocation simply fits 20 houses onto a commercial site, it offers no benefits beyond the housing itself. Landscape improvements are there but limited given the size of the plot and the need for housing, amenity provision and environmental benefit are negligible. I would propose that the commercial site is retained for employment allowing the vacant land south and north of a remodeled Back Lane to provide the housing and green space. This would deliver significantly enhanced amenity land and a safer, improved access for Back Lane onto the B1108 for use by the development and other traffic. The plan must take account of the amenity and environmental benefits available on other available sites.

Whilst I can understand the landscape improvement value to Barford of removing the commercial site, the change of use to housing removes premises for two businesses and employment, without an alternative site allocated in the village. The site is also compromised by the access next to the B1108 junction which is now unsuitable for residential use given the volume of traffic. The development ignores the significant amenity space, improved access for Back Lane and landscaping available from other proposed sites. 20 houses will be on a busy B road with poor access and limited amenity space.

Objection relating to the exclusion of site SNO552 from the South Norfolk Village Clusters Housing Allocations Plan.

My client Silfield Ltd wishes to object to the Regulation 19 version of the emerging South Norfolk Village Clusters Housing Allocations Plan (VCHAP) as published for consultation. This is on the basis that the emerging VCHAP fails to meet the tests of soundness as outlined in paragraph 35 of the National Planning Policy Framework. The housing allocations contained within the VCAP that seek to deliver circa. 1,200 new dwellings in South Norfolk Council area are not positively prepared, nor justified, nor effective or otherwise consistent with Government guidance contained in the National Planning Policy Framework.

As your Council is aware from the previous representations made by Silfield Ltd, the company is proposing to deliver a new publicly accessible Country Park on land they own at Barford. As explained previously the delivery of this major public benefit will be enabled by a modest proportionate amount of private and affordable housing within the village of Barford.

As evidenced in the previous Silfield Ltd submissions to the emerging VCHAP and emerging Greater Norwich Local Plan, this 29 ha County Park is required to address existing acknowledged deficiencies in public open space provision within this part of South Norfolk. As such failure to allocate the Barford Country Park and enabling housing development to offset the impact of future planned VCHAP housing growth cannot be the most effective strategy in this instance.

Failure to deliver this clear opportunity to increase the amount of public open space, create a healthier Barford and offset the impacts of housing growth and climate change also fails to comply with current and emerging national policy contained in paragraphs 84, 92, 98, 123 and 130 of the National Planning Policy Framework. The current VCHAP strategy that seeks to deliver no strategic public open spaces to offset the impact of 1,200 new homes is not positively prepared (having regard to the clear opportunity being presented) or effective.

It is also clear that my client’s promoted SNO552 site has not been properly assessed when compared against other sites competing for planned housing growth in the VCAP. As such site SNO552’s exclusion from the VCHAP is not justified in this instance. My client contends that it simply cannot be the case that my client’s SNO552 site (with the landscape and recreational enhancements being offered in the Country Park) would have a greater landscape impact than emerging allocated site VCHAD1 at Haddiscoe.

Furthermore, it also cannot be the case that the SNO552 site has the potential for a greater ecological and landscape impact than that of emerging site VCGEL at Geldeston that is located some 450m from a Nationally important RAMSAR site. It also cannot be the case that site SNO552 has inferior vehicular access arrangements to emerging allocated sites VCW001 at Woodton, VCBAP1 at Brooke, VCHEM1 at Hempnall and VCBAP1 at Bergh Apton contained in the VCHAP. The point my client is making is that the comparison of competing sites in arriving at the VCHAP housing allocations has not been correctly undertaken and as a result the emerging allocations do not meet the tests of soundness.

I trust that this objection is made correctly and my client is able to attend the forthcoming Examination in Public to take part in the discussions relating to overall public open space provision, the impacts of new housing growth and the suitability of some of the emerging housing sites to accommodate planned growth.

My client would also welcome a further discussion with the Council’s Place Making Team regarding the inclusion of the SNO552 site and the related Country Park in the submission version of the emerging VCHAP.