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

Object

Representation ID: 1784

Received: 02/08/2021

Respondent: Orbit Homes

Agent: David Lock Associates

We consider that the preparation of a standalone Sustainability Appraisal (SA) for the SNVCHP
in isolation of the GNLP raises a number of procedural concerns.
As outlined above, allocations for new housing sites at Village Clusters within Broadland District
have been included as part of the GNLP. They have therefore been appropriately reviewed
and assessed as part of the SA for the GNLP, taking into account overall plan sustainability
objectives and assessment criteria.
In contrast, the allocations for the SNVCHP are being assessed as part of an entirely separate
SA process. The SA Framework for the GNLP is substantially different to the SA Framework
for the SNVCHP – the relevant extracts of both Scoping Reports are included at Enclosure 1a
& 1b to this representation. This leads to a fundamentally different assessment of the potential
site allocations, and inevitably, leads to different outcomes.
The preparation of a SA in isolation from the GNLP results in a scenario where the sustainability
of the Development Plan has not been assessed as a whole but rather in parts against
significantly different SA frameworks. This is not a sound approach, and it is difficult to
ascertain how an Inspector would be able to confirm the soundness of the decision making
process and confirm the suitability of site allocations in respect of two separate sustainability
assessments on this basis.