Comment

Representation ID: 22004

Received: 16/03/2020

Respondent: Ms Carol Sharp

SNGP are concerned as to why JCS current settlement hierarchy categories of Service Villages, Other Villages, smaller rural communities and the countryside have been removed in favour of “Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside and is not even offered as an ‘alternative approach’ in the draft GNLP.

The entire purpose of a settlement heirachy is to determine the definitions that can be used to assess their sustainability for growth. Rural communities are very different from service villages and adding to these villages means more car journeys to their nearest service villages.

Housing should be allocated appropriate to each category of community/settlement within their own setting, landscape and context rather than lumping them together in a “village cluster”.

Even if the “village clusters” are adopted it would still be important to limit these to the area within their settlement boundaries and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.

We are concerned that the “village clusters” in Broadland and South Norfolk are being dealt with in a different way as the GNLP is a strategic plan for the whole of Greater Norwich, and that “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

The maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’.