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

Object

Representation ID: 3985

Received: 26/09/2024

Respondent: Norfolk County Council - LLFA

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The LLFA considers one element which forms part of this SNDC Village Clusters Housing Allocations Plan Regulation 19 Pre-submission Addendum consultation document (Policy SWA2REV: Land on Main Road, Swardeston) to be unsound when assessed against the tests for soundness set out in Paragraph 35, Criteria C: Effective and Criteria D: Consistent with National Policy of the National Planning Policy Framework (NPPF) for the following reasons:

• In Policy SWA2REV and its supporting text, there is an absence of references made to the consideration of surface water and flood risks associated with the site and any future development of it. Furthermore, the absence of the consideration of flood risk in the Policy text for SWA2REV is considered inconsistent with the approach adopted by SNDC as part of the Village Clusters Housing Allocations document for other proposed site allocations when compared to other sites with similar flood risk issues. This means the Policy fails to support the principles set out in the NPPF (19th December 2023) in respect of the consideration of flood risk management.

• The LLFA are not objecting on the grounds of the principle of the development of the site, but on the level of information required within Policy SWA2REV relating to flood risk and the consideration of flood risk management and its supporting text that will guide the site’s future deliverability.