Comments of Policy 7.5

I have concerns about this policy, particularly the idea of allowing up to 3 dwellings on infill sites within a recognisable group of dwellings. My concerns are as follows:

1. It’s not clear, within an individual parish, whether these 3 dwellings are to be on a single site or can be single houses on 3 separate plots. This needs to be clarified as the NPPF (Para 16(d) requires policies to be “clearly written and unambiguous”.
2. It is very unclear why this policy is being introduced and it appears to be contrary to other policies in the plan intended to:
• “ensure safe, convenient and sustainable access to on-site and local services and
facilities including schools, health care, shops, leisure/community/faith facilities and libraries (Policy 2 – Sustainable Communities)
• “reduce the need to travel, particularly by private car”;
• “secure the highest possible share of trips made by sustainable travel”;
• “ensure that new housing will be close to every-day services and jobs”;
• locate growth in villages “where there is good access to services to support their
retention” (Para 140 - Climate Change Statement).
The NPPF states (Para 148) that “the planning system should support the transition to a low carbon future in a changing climate…” and “New development should be planned for in ways that…can help to reduce greenhouse gas emissions, such as through its location, orientation and design” (Para 150(b))
3. In recent years, many planning applications have been refused by South Norfolk Council on infill sites outside development boundaries. One of the reasons often quoted is along the following lines: “the location of the site and its remoteness from services and facilities would result in over-reliance on the private car, which will not minimise greenhouse gas emissions and is not located to use resources efficiently. As such, such sites are contrary to Policy 1 of the JCS and Policy DM3.10 of the SNLP Development Management Policy Document 2015”*. To introduce Policy 7.5 would indicate that the Councils are disagreeing with these recent refusals at a time when the issues of greenhouse gas emissions and climate change are being taken much more seriously. This makes no sense. It is now generally recognised that we are dealing with a climate emergency and the government has a target of going to zero carbon by 2050. During the lifetime of the plan over the next 18 years up to 2038, concerns over global warming are only likely to increase, and this policy will run counter to this trend. Although the government is banning the sale of petrol and diesel cars from 2035, older ones will still be being driven many years beyond the lifetime of the plan.
4. With over 175 parishes in South Norfolk and Broadland, the number of houses that could be constructed under Policy 7.5 exceeds 500 and will simply consolidate hamlets that have no or few services and are therefore in unsustainable locations. Furthermore, in the towns and larger villages, the edge of development boundaries are far from services in the town/village centres and still predominantly involve the use of the private car.
5. There is also the issue of how Policy 7.5 will be monitored over the lifetime of the plan. For example, if an application comes forward in 2035 for an infill house in a hamlet, will anyone remember that 3 were given permission, say, 10 years earlier? And even if they do, will this carry much weight with the 2035 planning committee?
6. This raises the issue of precedent, and whether Members will, in future, be prepared to refuse infill dwellings in any of the hundreds of hamlets in rural South Norfolk and Broadland. There is therefore a real prospect of the consolidation of hundreds of unsustainable hamlets within the lifetime of the plan.
7. The policy requires that “Proposals will respect the form and character of the settlement and have no detrimental impact on the landscape and natural environment” but this requirement should also refer to the historic heritage (Conservation Areas and Listed Buildings), flood risk areas, etc.
8. In conclusion, I believe this policy runs counter to the international, national and
local policies trying to reduce the need to travel by private car and should therefore be deleted from the GNLP.

• Policy DM3.10 states that “All development should support sustainable transport and development objectives, utilise all opportunities to integrate with local sustainable transport networks, be designed to reduce the need to travel and to maximise the use of sustainable forms of transport appropriate to the location”)