I can see no justification for changing the settlement hierarchy by merging the bottom three tiers into a single ‘village clusters’ category. The purpose of the hierarchy is to direct development towards suitable areas with good access to public transport and services. In the current hierarchy, settlements in the bottom two tiers had very little in the way of services and were therefore deemed generally unsuitable for development. The proposed approach, by incorporating all settlements into ‘clusters’, creates a situation where development can be allowed even in tiny villages with no services. The statement in para 340 that primary school catchments “provide a proxy for social sustainability” is completely meaningless: every location is within a primary school catchment area, and clearly not every location is equally viable as a settlement. There is no evidence that allowing housing development in areas with few or no services results in services being created: unless sustainability is designed in and public transport provided from the start, it just results in more car dependency and an absence of community as everyone gets used to needing their car to get to work, shops, etc.
To give just one example of a ‘village cluster’ that serves no meaningful purpose: Haveringland, as a small village with no school and next to no services of any kind, is expected to look to Horsford for these services within its ‘cluster’. These villages are four miles apart with no bus service, linked by a road with no safe walking route – so in what possible way do they form a ‘cluster’ or serve the aim of reducing car use?
In practice, I note that (rightly) no sites in Haveringland or Felthorpe have been allocated. The site allocations document acknowledges that development in Felthorpe would be inappropriate because “it has poor access to core services and facilities in Horsford some distance away. In particular there is no safe walking route to Horsford Primary School which is over 3km away.” This is a logical assessment, and the same conclusion would have been reached under the existing settlement hierarchy – so why change the policy at all? It is really unclear what the purpose is; but the language suggesting that development in tiny villages can make them more sustainable, or that villages only accessible from each other by car form a sustainable ‘cluster’, is contrary to good planning practice, and risks development in these locations being approved later on.

The 2018 Growth Options consultation also showed a large majority against this proposed change to the settlement hierarchy:
“Of those who responded, 67 favoured option SH1, 17 did not. Answers to question 24 generally favoured keeping the lower settlement hierarchy tiers of 4. Service Villages, 5. Other Villages, and 6. Smaller Rural Communities...22 respondents were in favour of the Village Group approach, and 53 against.”
So why has it been adopted?