Object

Publication

Representation ID: 24448

Received: 22/03/2021

Respondent: C Kemp

Agent: La Ronde Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy 7.4 is unjustified, ineffective, not positively prepared, and not consistent with national policy. Policy 7.4 states that new sites in village clusters will be allocated through a South Norfolk Village Clusters Housing Allocations Local Plan. It is considered that the subdivision of an integral element of the GNLP is not proactive or justified when considering the cumulative growth over the three districts for the next 18 years. The policy states that 1200 homes will be allocated within South Norfolk, however it does not specify where development will be located or whether the strategy will propose equal disbursement of new dwellings across the district or concentrate development within a few key areas. This lack of clarity is in conflict with paragraph 16 of the NPPF which states that policy should be clearly written and unambiguous, resulting in the policy currently being inconsistent with national policy.

Irrespective of how development is proposed across South Norfolk, it is viewed that the second element of the policy, which relates to additional sites, is too restrictive to facilitate growth and ensure vitality of rural communities in accordance with paragraph 78 of the NPPF. Although it is understood why the GNLP proposes only in full development is acceptable, such a policy undermines and destroys the quintessential essence of the character and appearance of rural villages. Simply put, infill development encourages the subdivision of plots and the creation of highly dense development which is incongruous with the historic evolution of most traditional villages. Such a policy will see the densification as well as the upward extension of the more rural localities to the detriment of the character and appearance of the area which is not considered to be a justified approach.

Overall, it is considered that policy 7.4 is inappropriate in its current form as insufficient information has been provided as to how the village cluster allocations will ultimately look and function. There are a number of uncertainties at present regarding where development will be located which undermines any potential assessment of the policy. It is considered the best approach would be an even spread of development across the district, however even with this proposed it is viewed that the overly restrictive idea of infill development only will ultimately, in the long term, undermine the viability of most rural economies.

As such the lack of clarity regarding the proposed wording of the policy and lack of information about where development will be located is in inconsistent with paragraph 16 of the NPPF. Furthermore, the overly restrictive infill only policy is in conflict with paragraph 78 of the NPPF. As such the failure to accord with national policies is considered to render the policy and the GNLP unsound in accordance with paragraph 35 of the NPPF and the proposed overly restrictive strategy is considered to be an unjustified approach.

Change suggested by respondent:

In order to make the policy sound it is considered that policy 7.4 should be re consulted on, alongside all other policies that relate to housing when the South Norfolk Village Clusters Housing Allocations Local Plan becomes available. This way a united and informed policy can be carefully considered in light of the wider strategic policies of the GNLP. Irrespective of this however, it is considered that additional development should be supported that relates well to existing settlements and subject to other criteria, such as highway safety, design, and reflection of local densities, for example.

If a more flexible approach regarding the wording of the policy is not adopted, then specific site allocations in rural areas should be considered. For example, looking at Thurston/Ashby St Mary, the site located North of Mill Road, would be an ideal location for residential development. The site relates well to the existing settlement and would be located in a position that allows easy access onto the common. Development here would bolster the local economy whilst also allowing the village to grow in a controlled manner without relying upon significant densification as the current policy proposes, to meet local needs.

Full text:

Policy 7.4 is unjustified, ineffective, not positively prepared, and not consistent with national policy. Policy 7.4 states that new sites in village clusters will be allocated through a South Norfolk Village Clusters Housing Allocations Local Plan. It is considered that the subdivision of an integral element of the GNLP is not proactive or justified when considering the cumulative growth over the three districts for the next 18 years. The policy states that 1200 homes will be allocated within South Norfolk, however it does not specify where development will be located or whether the strategy will propose equal disbursement of new dwellings across the district or concentrate development within a few key areas. This lack of clarity is in conflict with paragraph 16 of the NPPF which states that policy should be clearly written and unambiguous, resulting in the policy currently being inconsistent with national policy.

Irrespective of how development is proposed across South Norfolk, it is viewed that the second element of the policy, which relates to additional sites, is too restrictive to facilitate growth and ensure vitality of rural communities in accordance with paragraph 78 of the NPPF. Although it is understood why the GNLP proposes only in full development is acceptable, such a policy undermines and destroys the quintessential essence of the character and appearance of rural villages. Simply put, infill development encourages the subdivision of plots and the creation of highly dense development which is incongruous with the historic evolution of most traditional villages. Such a policy will see the densification as well as the upward extension of the more rural localities to the detriment of the character and appearance of the area which is not considered to be a justified approach.

Overall, it is considered that policy 7.4 is inappropriate in its current form as insufficient information has been provided as to how the village cluster allocations will ultimately look and function. There are a number of uncertainties at present regarding where development will be located which undermines any potential assessment of the policy. It is considered the best approach would be an even spread of development across the district, however even with this proposed it is viewed that the overly restrictive idea of infill development only will ultimately, in the long term, undermine the viability of most rural economies.

As such the lack of clarity regarding the proposed wording of the policy and lack of information about where development will be located is in inconsistent with paragraph 16 of the NPPF. Furthermore, the overly restrictive infill only policy is in conflict with paragraph 78 of the NPPF. As such the failure to accord with national policies is considered to render the policy and the GNLP unsound in accordance with paragraph 35 of the NPPF and the proposed overly restrictive strategy is considered to be an unjustified approach.