Object

Representation ID: 23087

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We wish to express concerns generally regarding the approach to the allocation of sites for development across numerous Development Plan Documents (DPD). Our comments set out in the covering letter (under the heading Procedural Concerns) provide further details.
Specifically, we object to the approach taken within the draft GNLP Sites document in respect of South Norfolk Council’s intention to unilaterally prepare a separate Village Clusters Plan covering new and carried forward sites for housing in their village clusters, whilst the sites to be allocated for housing in the village clusters in Broadland District are included within the draft GNLP Sites document. We make three points of objection in principle:

i. Firstly, the GNLP is a joint plan. Decisions on site allocations should be made in the context of meeting whole plan objectives, evidence and SA relating to the plan area as a whole. Unlike the Broadland site allocations for village clusters, the decision-making process regarding the South Norfolk Village Cluster site allocations - which presumably is to be undertaken unilaterally by South Norfolk Council separately from joint planmaking - is neither logical nor transparent. This approach undermines and acts counter to the GNLP whole plan objectives and SA conclusions, which in turn risks the soundness of the Village Clusters document and the GNLP Plan as a whole. This is clearly not a desired outcome for any of the three authorities;
ii. Secondly, the Village Clusters document proposes to allocate sites for c.1,200 dwellings in total. The scale of housing land required to meet this requirement – and the options for how this requirement might best be met in a way which meets wider plan objectives - is such that if tests of soundness are to be met, can only be considered as an inherent part of the GNLP;
iii. Thirdly, the timing of a separate South Norfolk Village Clusters document has led to a blanket approach of postponing the assessment of sites within/around village clusters that have been promoted through the GNLP call for sites process until the preparation of this document takes place. Again, this risks undermining the overall soundness of the evidence base, SA and content of both plans as the assessment of cumulative impact or reasonable alternatives cannot be done in a holistic or robust manner;

Furthermore, some of the sites promoted through the call for sites process within/around village clusters are strategic in nature and scale. For example, site GNLP2101 (promoted for a residential-led mixed use development) at Spooner Row includes a site area of 77.26ha. Whilst this site has been assessed as part of the Housing and Economic Land Availability Assessment (HELAA) Addendum October 2018, it has not been subject to the same detailed site assessment process as sites considered for allocation within the draft GNLP Sites document. Rather, it is proposed that such sites will be subject to future consultation by South Norfolk Council, with no indicative timescales provided for when, how or against what objectives this further consultation will take place or how it will link with the progression and examination of the GNLP. However, a number of sites including GNLP21011 are considered strategic in scale, and as such go well beyond what should be reasonably considered as part of a separate or ‘lower order’ site allocation document.

None of the sites listed in the footnote below have been considered for allocation within the draft GNLP Sites document. As such, none of the sites have been subject to the same detailed site assessment as the sites considered for allocation within the GNLP despite being of a similar scale and nature. Rather, these sites will be subject to further, separate, consultation by South Norfolk Council.

In addition to the procedural disparity this creates – and one which will add to the complexity around site assessment and a confusion amongst public or wider stakeholders wishing to engage with the plan making process – the failure to consider such strategic scale sites compromises the growth strategy in a number of ways:

• it cannot fully consider all of the proposed strategic infrastructure that may be required for the Plan period within the GNLP;
• it assumes that the village clusters will remain at the same position within the GNLP settlement hierarchy; and
• it prevents the GNLP growth strategy being tested against all available reasonable alternatives.

On the basis set out above, we object to the approach proposed within the draft GNLP Sites document to allocate 1,200 dwellings within a separate DPD document on the grounds that it has led to a flawed site assessment process which compromises the proposed growth strategy and the soundness of the GNLP as a whole.

We suggest that to remedy the situation and to ensure that the GNLP can move effectively through Regulation 19 and Examination, those sites to be allocated for development at the village clusters in South Norfolk should be considered and allocated as part of the GNLP Sites document. There is an opportunity to undertake the necessary assessment (in tandem with the additional SA work we suggested is also needed to test reasonable spatial strategy alternatives to Policy 12) in the period between the end of consultation (Regulation 18c) and the next round of consultation (Regulation 19) scheduled for January/February 2021.


If GNDP continue to pursue a separate South Norfolk Village Clusters document as a separately-assessed and unilaterally-determined DPD, then we have serious reservations over the soundness of the Plan as a whole and its likely success at Examination.