Object

Representation ID: 21975

Received: 16/03/2020

Respondent: Ms Carol Sharp

At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, it will be 2038 before the allocation of development land for 82% of the 44,500 new homes in the existing Local Plan, the Joint Core Strategy (JCS) is used up.

In these circumstances we consider that any new sites allocated in the GNLP should be phased in when most of the existing JCS sites have been used. Otherwise developers will “cherry-pick” the most profitable sites and newly allocated green field sites in less sustainable locations will be developed first.

Paragraph 6 of the Introduction is clear that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’ It will be difficult if not impossible to meet these targets if new housing to the scale proposed in the draft strategy is dispersed across the rural areas of Broadland and South Norfolk. The main justification for this appears to be the availability of primary school places in the “village clusters”, whereas there are more important measures for sustainability which should be taken into account, including the number of car journeys and journeys by delivery vehicles to new housing, along with the associated congestion and pollution resulting from them.

‘South Norfolk Council intends to prepare a separate village clusters plan covering sites for small-scale housing in the rural parishes of South Norfolk that collectively form primary school clusters, whilst the Broadland village cluster plan forms part of this Local Plan.’ Surely this should be produced at the same time as the GNLP so that the allocated housing can be considered and commented upon alongside it.

In the current Joint Core Strategy (JCS) Local Plan, housing and other growth was to be in and close to Norwich, with minimal new development to be permitted in the rural policy areas of Broadland and South Norfolk.

In this new draft plan there are to be ‘a minimum of 1,200’ dwellings on top of the existing commitment of 1,349. As there are already sites ‘to accommodate 9% more homes than ‘need’, along with two ‘contingency’ locations for growth’ (page 37) and does not include windfall developments in its housing totals, the word “minimum” should be replaced with ‘maximum’ or ‘up to’ as is the case with the figures for Broadland’s “village clusters”. The approach for the 2 authorities should be identical.