Comment

Representation ID: 22228

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

Consistent with our views set out above we consider that the GNLP should seek to take an evidence-based approach towards the identification of the capacity of every settlement across the plan area to accommodate growth. Where sites are identified that are both deliverable and can enhance the sustainability of a settlement through the delivery of a proportionate number of new homes they should be identified as allocations in the plan. This process should be indivisible from the exercise undertaken to inform the spatial distribution of growth across the plan area.

We are pleased to see that such an evidence-led process has been closely observed in directing growth towards the Village Cluster tier across Broadland. The profile of each cluster across the district provided as part of the evidence base of the plan takes a clear stepped approach to identifying site allocations. This is done by firstly identifying the capacity that exists in the local community infrastructure; then considering whether there are any additional development constraints applicable to the village or cluster; and finally through an assessment of whether appropriate sites exist within each cluster to deliver an appropriate level of growth up to the level of capacity offered by the local primary school in particular.

This process has resulted in the identification of proposed allocations at 10 of the 25 Village Clusters across Broadland. Of these, five of the clusters have been allocated between 10-20 dwellings, eight will receive between 20-40 dwellings and two will host a range of 40-60 dwellings. This identification of suitable sites has then informed the level of growth to be directed towards Broadland’s network of clusters – stated as 480 dwellings.

Whilst Hainford / Stratton Strawless represents one of the 10 Village Clusters not proposed to receive any growth we are pleased to confirm that our client’s proposal at Harvest Close, Hainford (site reference GNLP2162) is now able to overcome the single principle constraint at the village that led to the current decision not to direct growth towards the cluster. Our client’s revised proposals are explained in detail at Annex 2. Importantly, as the housing figure for the Village Cluster tier has been formulated though a ‘bottom-up’ approach (that is, through the identification of suitable sites rather than by way of an arbitrary apportionment of growth) it is clear that additional sites can be identified at this tier without conflicting with the GNLP’s spatial strategy.

By comparison, the approach proposed in respect of South Norfolk’s Village Clusters is far from evidence based and, in contrast to the methodology applied at Broadland, seeks to prescribe the network an arbitrary growth figure of 1,200 dwellings. The draft GNLP then indicates that allocations to meet this requirement across South Norfolk’s villages will be identified in a separate plan to be produced by South Norfolk District Council at a later date. This strategy is speculative and uncertain in nature and risks placing an onerous requirement on South Norfolk to allocate sites that are either undeliverable or unsustainable – or potentially both. Put simply, there is no evidence currently available to suggest that the district’s villages comprise sites that can appropriately accommodate what is a strategic level of new growth.

This approach significantly undermines strategic approach to delivery in these settlements and cannot be considered to be in accordance with paragraphs 17 – 22 of the NPPF which make clear that strategic policies should provide a clear strategy for bringing sufficient land forward to address objectively assessed needs over the plan period. The scale of growth that must be delivered through the district’s Village Clusters plan (1,200 homes, representative of almost 15% of all new allocations across the Greater Norwich area) is clearly of strategic importance in the context of the GNLP.

To defer the identification and allocation of sites to meet such a significant level of growth to a future plan without an assessment of the ability of the villages it covers to accommodate new homes is clearly a flawed approach. We consider that in order to accord with the NPPF, allocations in the village clusters must be brought back into the GNLP and based on a thorough assessment of need and capacity. In turn, this may (and arguably should) result in the redirection of a proportion of this growth either towards Broadland’s village network or more suitably to higher tiers of the hierarchy.