Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC BRM1: Land west of Old Yarmouth Road
The text says, ‘The developer is therefore encouraged to enter into early engagement with AW regarding this matter’. This should be stronger – to say ‘must’.

Light pollution
Most of the proposed sites are on the edge of settlements. Particular care and attention need to be given to any proposals for external lighting as well as any design that has a lot of glazing. Lighting in such edge of settlement areas needs to be fully justified, serve a specific purpose, be of the right design and intensity so as to not affect dark skies, such as the intrinsic dark skies of the Broads. Reference to lighting being only needed if fully justified and well designed needs to be made in relevant policies, especially the following as they are close to, albeit separated from, the Broads. Also, design with lots of glazing need to be avoided unless there is going to be automated shades incorporated into the design.

• Policy VC BRM1: Land west of Old Yarmouth Road
• Policy VC EAR2: Land north of The Street
• Policy VC GIL1REV: South of Geldeston Road and Daisy Way

We recommend that for sites on the edge of settlement you include wording such as: ‘Given that this site is on the edge of the settlement, particular care and attention will be given to lighting of such schemes. This includes external lighting, as well as mitigation for designs with lots of glazing. Schemes will need to fully justify the need for lighting, provide detail of the design and ensure that lighting is on only when it is needed, and designed to not add to light pollution. Designs with a lot of glazing are required to provide mitigation in the form of automated shades that are shut between dusk and dawn.’

Policy VC GIL1REV: South of Geldeston Road and Daisy Way
Our concern is incremental pressure and expansion of development around Gillingham. Again, one of the main concerns is lighting and so consideration of lighting is of particular reference to this policy.

The policy states: ‘The boundary of the site 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’. This should be made stronger and state ‘which must be left undeveloped’ as it is not acceptable to be allocating development in Zones 2 and 3a.

It also states; ‘The developer of the site is recommended to enter into early engagement with Anglian Water…’. Again, this should be stronger – to say ‘must’.

Policy VC BRM1: Land west of Old Yarmouth Road
The text says, ‘The developer is therefore encouraged to enter into early engagement with AW regarding this matter’. This should be stronger – to say ‘must’.

HAD1 Land south of Haddiscoe Manor Farm
Don’t need the word ‘that’ in the first sentence, it doesn’t make sense of the bullet points following.

It also states; ‘The developer of the site is recommended to enter into early engagement with Anglian Water…’. Again, this should be stronger – to say ‘must’.

Light pollution
Most of the proposed sites are on the edge of settlements. Particular care and attention need to be given to any proposals for external lighting as well as any design that has a lot of glazing. Lighting in such edge of settlement areas needs to be fully justified, serve a specific purpose, be of the right design and intensity so as to not affect dark skies, such as the intrinsic dark skies of the Broads. Reference to lighting being only needed if fully justified and well designed needs to be made in relevant policies, especially the following as they are close to, albeit separated from, the Broads. Also, design with lots of glazing need to be avoided unless there is going to be automated shades incorporated into the design.

• Policy VC BRM1: Land west of Old Yarmouth Road
• Policy VC EAR2: Land north of The Street
• Policy VC GIL1REV: South of Geldeston Road and Daisy Way

We recommend that for sites on the edge of settlement you include wording such as: ‘Given that this site is on the edge of the settlement, particular care and attention will be given to lighting of such schemes. This includes external lighting, as well as mitigation for designs with lots of glazing. Schemes will need to fully justify the need for lighting, provide detail of the design and ensure that lighting is on only when it is needed, and designed to not add to light pollution. Designs with a lot of glazing are required to provide mitigation in the form of automated shades that are shut between dusk and dawn.’

Policy VC GIL1REV: South of Geldeston Road and Daisy Way
Our concern is incremental pressure and expansion of development around Gillingham. Again, one of the main concerns is lighting and so consideration of lighting is of particular reference to this policy.

The policy states: ‘The boundary of the site 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’. This should be made stronger and state ‘which must be left undeveloped’ as it is not acceptable to be allocating development in Zones 2 and 3a.

It also states; ‘The developer of the site is recommended to enter into early engagement with Anglian Water…’. Again, this should be stronger – to say ‘must’.

Policy VC BRM1: Land west of Old Yarmouth Road
The text says, ‘The developer is therefore encouraged to enter into early engagement with AW regarding this matter’. This should be stronger – to say ‘must’.

HAD1 Land south of Haddiscoe Manor Farm
Don’t need the word ‘that’ in the first sentence, it doesn’t make sense of the bullet points following.