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

Response/Representations Soundness and Viability
The wider issues of Nutrient Neutrality (‘NN’) will result in both delays and overall viability challenges for development of sites across the NN affected area of the Plan. This is because the mitigation strategy – and thus potential solutions and the deliverability/final cost thereof remains uncertain. It is totally uncertain at this stage of the proceedings whether the sites proposed in this Plan are capable of accepting the financial burden of NN mitigation as such the development proposal contained in the Plan will at best be delayed for an unknown period. The test of viability cannot take place until a solution to the NN problem is resolved.
The Plan proposes a development of 1,200 new dwellings in the period ending March 2038 most of which will arise from sites identified for the first time in the Plan and most of which are currently undevelopable as a result of NN.
South Norfolk Council is well versed with the problem NN but can offer no positive certainty as to when a solution will come forward and at what cost.
Dwelling completions arising from the Plan were initially forecast to take place in 2024/25 this forecast has been revised resulting in a 4 year delay.
Development was originally projected to be completed over a period of 14 years this has now been revised to 10 years resulting in an unjustified 40% annual average increase in completions.
The conclusion we reach is that South Norfolk Council consider it will be, at best, 6+ years from now before completions under this Plan are delivered assuming the NN matter is resolved.
We therefore conclude the Plan based on the up-to-date published evidence is unsound and unviable as the cost of NN mitigation has not been demonstrated.
The uncertainty surrounding NN mitigation and cost renders the proposals contained in this Plan unsound and incapable of being progressed.

Paragraph A.10 sets out the requirement to deliver at least 1,200 homes through the VCHAP my representations consider such a delivery is unsound for the reasons I have set out.
Paragraph A.38 sets out the Viability Appraisal, my representation considers the Viability Appraisal is in adequate and fails to justify the plans Viability which in turn concludes the Plan is unsound.

Response/Representations Soundness and Viability
The wider issues of Nutrient Neutrality (‘NN’) will result in both delays and overall viability challenges for development of sites across the NN affected area of the Plan. This is because the mitigation strategy – and thus potential solutions and the deliverability/final cost thereof remains uncertain. It is totally uncertain at this stage of the proceedings whether the sites proposed in this Plan are capable of accepting the financial burden of NN mitigation as such the development proposal contained in the Plan will at best be delayed for an unknown period. The test of viability cannot take place until a solution to the NN problem is resolved.
The Plan proposes a development of 1,200 new dwellings in the period ending March 2038 most of which will arise from sites identified for the first time in the Plan and most of which are currently undevelopable as a result of NN.
South Norfolk Council is well versed with the problem NN but can offer no positive certainty as to when a solution will come forward and at what cost.
Dwelling completions arising from the Plan were initially forecast to take place in 2024/25 this forecast has been revised resulting in a 4 year delay.
Development was originally projected to be completed over a period of 14 years this has now been revised to 10 years resulting in an unjustified 40% annual average increase in completions.
The conclusion we reach is that South Norfolk Council consider it will be, at best, 6+ years from now before completions under this Plan are delivered assuming the NN matter is resolved.
We therefore conclude the Plan based on the up-to-date published evidence is unsound and unviable as the cost of NN mitigation has not been demonstrated.
The uncertainty surrounding NN mitigation and cost renders the proposals contained in this Plan unsound and incapable of being progressed.

Paragraph A.10 sets out the requirement to deliver at least 1,200 homes through the VCHAP my representations consider such a delivery is unsound for the reasons I have set out.
Paragraph A.38 sets out the Viability Appraisal, my representation considers the Viability Appraisal is in adequate and fails to justify the plans Viability which in turn concludes the Plan is unsound.