Object

Representation ID: 24260

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

During the regulation 18C consultation a comprehensive submission was made by Hingham Town Council raising objection some sites being deemed as unsuitable
for development and not being put forward for consultation as reasonable alternatives. With specific reference to the site assessments, the Town Council consider that there are a number of contradictions within the site assessments, the conclusion of sites put forward for housing development and the decisions on some
sites to be deemed unsuitable, are extremely flawed and not based on proportionate evidence.

Of the sites consulted on during the Regulation 18C consultation, as previously stated the Town Council and residents consider GNLP0520 unsuitable for
development and objections were made against the site as a preferred option. Objections were also made against the following sites being deemed unsuitable
and not being put forward for consultation as “reasonable alternatives”: GNLP0298 and GNLP 0335, GNLP0501 and GNLP0502.

The Town Council in their regulation 18C representation expressed that these options should be further explored. With regard to GNLP0501 and 0502 there was
a potential for community benefit, if additional land for the sports centre could have been incorporated with highway access being achievable via land owned by the Town Council. It is understood that the landowner is not pursuing development of GNLP0501 and GNLP0502 at this time, therefore this representation will not
make further reference to these sites.

With regard to GNLP0298 and GNLP0335 (the same developer is promoting both sites), although housing numbers proposed are a concern, the development of
these sites would offer the future community benefit of a community woodland and the access link to land which could have a potential to help achieve the
aspirations of the community and Town Council by providing an area of land (GNLP0395) which could be utilised for improving Hingham’s infrastructure/facilities.
It is recognised that any development on agricultural land will have an initial negative impact on biodiversity and wildlife. NPPF 174b states plans should “pursue
opportunities for securing measurable net gains for biodiversity”. The allocation of GNLP0520 and GNLP0503, when judged against the proposal of delivering a community woodland in conjunction with GNLP0298 and GNLP0335, is contrary to NPPF para 174b.

As already demonstrated the Town Council consider the allocation of GNLP0520 and GNLP0503 in the GNLP to be unsound, and therefore the GNLP should not be
adopted with the inclusion of either site.

Due to the GNLP rejection of other sites promoted, no other sites in Hingham have been subject to public consultation as reasonable alternatives/sites with the
potential for being developed. Therefore, residents have not made their views known via the consultation process in relation to the potential of GNLP0298 and
GNLP0335 as housing allocation. Of the sites submitted (and remaining available) GNLP0298 and GNLP0335 would appear to offer an alternative to GNLP0520,
however residents views, such as submitted to the Town Council (evidence 3a) should be sought.
The GNLP is not justified, it has not fully taken into taking into account reasonable alternatives and the decisions to include GNLP0520 /GNLP0503 and reject
alternatives sites is not based on proportionate evidence.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence