Comment

Representation ID: 22122

Received: 13/03/2020

Respondent: MDPC Town Planning

Number of people: 2

Horsford is not identified as a Key Service Centre (KSC) in the draft plan. This is despite having a greater population than all of the other KSC’s save for Hethersett and Poringland/Framlingham Earl.
Instead, Horsford is envisaged as a village cluster combined with Felthorpe and Haveringland.
We question why Horsford is not recognised as a Key Service Centre when the GNLP’s own Horsford Assessment Booklet recognises that Horsford has a range of services and facilities including two primary schools, a shop, medical centre, post office, village hall, pharmacy, public house, industrial area, recreation ground, place of worship (including a nursery), convenient bus stop and direct access to Norwich Broadway ; and given that Horsford is the 9th largest settlement in the overall area.
Firstly, with regard to the identified KSC’s, whilst leaving aside Hethersett and Poringland/Framlingham Earl, which are the only two identified KSC’s with bigger populations that Horsford, it is the case that Horsford is comparable to the other identified KSC’s.
Reviewing the Assessment Booklets for relevant KSC & VC sites, it would appear that the main distinction seems to be that Acle, Loddon, Reepham and Wroxham have high school or secondary school facilities and Brundall and Acle have rail connections, but otherwise the range of facilities are broadly the same as in Horsford. In addition, in the case of Hingham, also identified as a KSC, there do not appear to be any more facilities that those offered in Horsford.
Turning to the identified settlements under the Village Cluster (VC) category under Policy 7.4, only sites in the Broadland DC area could be assessed in comparison to Horsford. It would appear that:
 Cawston, Brandiston and Swannington
 Coltishall, Henstead and Stemminghall
 Foulsham and Themelthorpe
 Freethorpe, Halvergate and Wickhampton
 Alderford, Attelbridge, Little Witchingam and Morton on the Hill and
 Lingwood and Burlingham, Strumpshaw and Beighton
All have a similar range of services to those offered in Horsford but 11 further clusters have fewer facilities and therefore there is a clear distinction.
Failing to recognise Horsford as a Key Service Centre (or otherwise removing the “Service Village” category of settlement), and treating this as part of a VC, means the approach of the GNLP and its approach to sustainability appraisal and site selection is flawed. It does not appear to be the case from the information presented that Horsford is subject to any particular development constraints that cannot be overcome by well-prepared development schemes (such as that currently proposed for the Site (See APPs 1 &3). However, by treating Horsford as part of a VC, the capacity of Horsford for Growth is artificially reduced by a policy construct.
The identification of Horsford as part of a VC restricts its capacity for new development in line with the proposed settlement hierarchy. In light of the above, we see no clear justification for this approach.
In the current development plan, Horsford is defined as a “Service Centre” and its reclassification appears to have arisen from the decision to remove that designation and instead introduce a concept of “village clusters” which was not even mentioned in the GNLP Growth Options paper in January 2018. The draft GNLP refers to this as “Grouping all smaller villages and the countryside in the village clusters” but it simply is not the case that Horsford is a “smaller” village.
Given the above, it is considered that Horsford should be identified as a KSC or at the very least a Service Centre, along with the villages referred to above as previously was the case. If it is identified as a Village or part of a cluster under the auspices of the proposed VC Policy (7.4) then it is contended that this would unfairly discriminate against its potential for growth and would hamper the overall strategic objective of delivery of housing.