Village Clusters Housing Allocations Plan - Alternative Sites & Focused Changes (Reg. 18)

Comment

Representation ID: 3437

Received: 24/01/2024

Respondent: Taylor Wimpey

Agent: James Bailey Planning Ltd

Taylor Wimpey note the Interim Sustainability Appraisal and agree that it is important to maintain a healthy buffer of housing sites over and above the minimum dwelling requirement.

However, the Council must also be able to demonstrate transparently that the sites identified can be delivered in order to meet the test of soundness if it is to be "Effective". At the same time, the Plan must be based on the most appropriate strategy, informed by robust evidence and guided by the Sustainability Appraisal if it is to be "Justified".

Object

Representation ID: 3440

Received: 24/01/2024

Respondent: Taylor Wimpey

Agent: James Bailey Planning Ltd

After reviewing the supporting evidence there are still significant questions regarding the access to the site, as recognised in the Sustainability Appraisal which notes that further work is required.

Surprising that the Council is consulting on another site, similar to Rockland St Mary, that has access risks as the Sustainability Appraisal acknowledges there is no conclusive evidence suitable access can be achieved.

Sites must be 'deliverable', otherwise they should be discounted.

In the document, Norfolk County Council Highways raise some substantial concerns regarding the access to this site: “From a Highways perspective the entire frontage needs improvement; could widen Wheel Road, however this would require substantial hedge removal.” This was related to the previous larger site, they have not provided comments in relation to the smaller site being consulted on. Unclear why further consultation with Highways has not taken place and resulted in inconclusive policy text in the document.

No evidence has been provided to show that safe access and visibility splays are achievable or viable. Again this is raised in the Sustainability Appraisal.

No indication that the site promoters have been contacted since 2016. This was before the access requirements were raised and other viability considerations, such as nutrient neutrality, were raised. This needs to be considered due to the strain Nutrient Neutrality has put on small and medium size house builders.

Is the site is allocated, this would result in a total of 62 new dwellings, which is not insignificant for a rural area and raises if infrastructure requirements and planning benefits have been considered.

Site assessments do not appears to considered primary school capacity, yet many are oversubscribed, such as Alpington and Bergh Apton. not evidence that cumulative impact has been considered. Have the Council considered if piecemeal development with contribute appropriately to infrastructure?

Object

Representation ID: 3441

Received: 24/01/2024

Respondent: Taylor Wimpey

Agent: James Bailey Planning Ltd

Question rationale behind including a previous omission site that was omitted due to impact on the landscape. The Landscape Visual Appraisal concludes that the site would have significant impacts on views and the landscape.

Question whether the impact has been been considered alongside Objectives 2 and 3 of the Plan.

Objective 3 is to ‘Protect the character of villages and their settings'. Allocation of this site would be at odds with this. The Sustainability Appraisal also queries the rationale behind the site due to it extending the village and the Grade II Listed building opposite.

This site would increase total development to 70 dwellings, which the Sustainability Appraisal questions.

Objective 2 is ‘Protect village communities and support rural services and facilities’. While additional growth could support services, the Sustainability Appraisal questions if the scale is at odds with the small-scale nature of the Plan. Piecemeal development could also miss planning benefits.

No evidence that cumulative impact has been considered, such as primary school capacity. Will piecemeal development contribute appropriately to infrastructure?

Little evidence to support deliverability as acknowledged in the Site Assessment. Also acknowledges that site is contingent on delivery of SN0552REVB. The sites need to be planned comprehensively and allocated as one site and must be considered as a whole.

Object

Representation ID: 3443

Received: 24/01/2024

Respondent: Taylor Wimpey

Agent: James Bailey Planning Ltd

Site extends linear settlement of Broome which does not score well for accessibility as stated in the Sustainability Appraisal. The site also extends into the Countryside and would alter the edge of the village significantly, as note din the Sustainability Appraisal.

No other reasonable alternatives in Broome, therefore the Sustainability Appraisal considers the alternative option of further development in Ditchingham. However this would extend a site further form 45 to 57 dwellings, which the Sustainability Appraisal raises as potentially going against the Objectives of the Plan.

Therefore the question is raised if the Plan has failed to provide a clear and appropriate strategy towards delivering sustainable rural growth?

It is difficult to achieve sustainable growth with smaller sites without significantly impacting the Countryside. Other sites could be more sustainable, however this may not be possible if sites become too large and contrary to the Plan objectives.

When identifying additional sites, there needs to be a clear rationale. Is there a preference for dispersed growth? Or a preference to focus on higher order settlements?

Object

Representation ID: 3444

Received: 24/01/2024

Respondent: Taylor Wimpey

Agent: James Bailey Planning Ltd

This allocation would result in a total of 50 dwellings being allocated in Earsham.

It is a smaller parcel of a wider site that could come forward in the future. Therefore have planning benefits been missed by not considering the whole site?

This highlights tensions between the desire to support local services while also providing additional benefits. Unclear if additional benefits or infrastructure improvements will be required from these developments and piecemeal development makes these difficult to secure.

Have all of the alternatives been fully explored to ensure that the strategy is the most appropriate? For example, would allocating 50 on the whole site be better than separate sites in Earsham? No evidence this has been explored. Rationale behind allocating parts of sites must be fully explained in order to be "Justified".

Object

Representation ID: 3445

Received: 24/01/2024

Respondent: Taylor Wimpey

Agent: James Bailey Planning Ltd

Question whether the Council have fully explored the benefits of maximising the full extent of field parcels. The Sustainability Appraisal highlights the need to ensure that benefits are maximised with ongoing scrutiny of the appropriate growth quantum.

Sustainability Appraisal also raises the possibility of expanding SPO2. It is noted that this could be of a strategic nature and at odds with the Plan, however it raises the question why this site has not been explored over SPO1 due to its sustainable nature and location close to the train station?

Now 4 sites in Spooner Row. Are the Council satisfied with allocating 4 smaller sites, as opposed to fewer larger sites, as being appropriate?

It is appreciated that the intention is to allocate less that strategic sites, when a settlement is taking 80 new dwellings is the Council satisfied that this total meets the Objectives of the Plan?