Village Clusters Housing Allocations Plan (Reg. 18) - Supporting Documents

Comment

Representation ID: 1738

Received: 02/08/2021

Respondent: Barton Willmore

The Sustainability Appraisal Report (SA) supporting this consultation is flawed on the basis that the 1,200 homes needs to be allocated to the Village Clusters. As noted previously, this is an option still to be Examined through the GNLP process and may not be formally endorsed. All options within the SA for distribution of 1,200 homes (i.e., Striking a balance, Accessibility led, and Dispersal led) would reasonably be expected to score lower against the criteria of the Sustainability Appraisal (SA) when compared to locations adjoining/within the largest settlements.
As an example, Table 9.1 of the SA identifies a significant constraint of a smaller settlement to be accessible to key services. It notes the average distance (noting some locations will be more distant than the average) between a ‘preferred site’ and GP, Primary School and Secondary School is 3.3km, 0.7km and 5km respectively. This would not be the case in a location such as Wymondham where these key services are readily accessible by walking, cycling or access to regular public transport.
In summary, the Village Clusters are likely to be the least sustainable locations for growth across the Greater Norwich area, yet they are proposed to accommodate a significant portion of the GNLP’s housing growth. Allocating such a significant element of the GNLP’s anticipated growth to these areas, where there are limited / no services and limited / no public transport, would be contradictory to the principles of sustainable development and the overall vision of the GNLP. We do not believe the approach proposed by the Village Clusters Plan has been justified and it is clearly not consistent with national policy. It does not respond to the principles of sustainable development, and it does not appear an effective assessment of the environmental impacts of this approach has been undertaken.