Question 45. Do you support or object or wish to comment on the overall approach for the village clusters? Please identify particular issues

Hainford Parish Council have examined the draft plan in detail and this is their considered response.

GNLP consultation-draft proposals document Feb 2020

POLICY 1 – SUSTAINABLE GROWTH

Q13 Do you agree with the proposed settlement hierarchy?

No. The Parish Council does not support the Village cluster proposal.
Whilst there may be some justification for clusters in ‘remote’ rural areas,
most villages are able to continue to access services as they currently do.
Becoming part of a cluster will result in inevitable exposure to wider and unnecessary development and the ultimate loss of existing settlement boundaries and village identity.

Q14 Do we support the approach to housing numbers?

No. The Parish Council is of the view that the 9 /10% extra allocations as well as additional windfall sites is excessive given that there are sufficient sites allocated to meet predicted demand.


POLICY 7- 4 VILLAGE CLUSTERS

Q45. Do you support or wish to comment on the overall approach for the village clusters? Please identify particular issues.

No. We do not support the proposed policy for village clusters.
Most villages are able to continue to access services as they do already without the need to cluster. The policy is intended to enable wider development which will result in the ultimate loss of existing settlement boundaries and the risk of unnecessary development. We are aware that the redefinition of settlement boundaries is to be considered at a later stage in the plan
Q46. Do you support or wish to comment on the approach for specific village clusters?

We strongly object to the proposed cluster of Hainford with Stratton Strawless or any other village and firmly believe that Hainford should retain its stand alone village status as are other nearby villages. The residents of Hainford value their rural aspect and independence and the reasons for linking Stratton Strawless to Hainford are weak.

a) The majority of family size accommodation in Stratton Strawless is situated west of the A140 where there are other nearby schools which are closer and more accessible than Hainford without the requirement to cross the busy A140 at peak times, Hevingham school is 0.4 miles, Marsham Primary School 1.4 miles and Horsford (with supermarket, Doctors surgery, Post Office,social club, leisure facilities, take away food outlet, library, excellent public transport links etc.) is also closer.
b) The largest concentration of homes on the eastern side of the A140 are on the mobile home park which we understand is for residents over the age of 55. For the residents who may live on the eastern side of the A140 and require primary school facilities there is also nearby Buxton school.

In addition to the above we object to the proposal that there is the potential for the development of 50/60 dwellings because there is insufficient capacity to sustain that level of development due to lack of facilities and infrastructure to support this.

The Officers have already stated that there is no capacity for Hainford school to expand and all 9 proposed sites for Hainford were discounted by planners mainly due to there being no safe pedestrian access to the school ( a crucial underlying criteria for development in the policy) and no feasible way to address this. There were Highways concerns, widespread flooding issues, and visual impact and break out into the country side. Added to which the public transport service is very limited with the last daily service from the city at 18.15 .We understand that the Policy requirements are to avoid development where there is a reliance on the private motor vehicle.

Therefore Hainford Parish council objects to the proposal to become part of a cluster and to the ultimate redefinition of our settlement boundary in order to facilitate wider development and to the proposal that there is the capacity to support a further 50/60 dwellings.

The villages in a large number of cases, particularly South Norfolk, can not soak up this additional housing quantity for the same reasons as many of the service areas can not, my village directly relies on the infrastructure (doctors/schools etc) of the Poringland/Framingham Earl area which can not support the developments already ongoing and planned in that area therefore the villages in the immediate area around Stoke Holy Cross, Brooke, Woodton, Kirstead, Shotesham, Bergh Apton, Alpington, Seething, can not support further housing either.

Response to GNLP -particularly as it affects Poringland and district

I support the overall plan for the area in meeting its duties in providing housing, work spaces and leisure activities in the GNLP area.

I welcome the GNLP in its treatment of Poringland and district. The stress on infrastructure, highways and avoiding further linear development is welcome since we have another 520 - odd homes to be built in the coming period. The stress on infrastructure is evident in a primary school that is heavily oversubscribed and a secondary school that may well have to restrict its 'out of catchment' offers of places.

Highways are already showing signs of inability to cope, with a main through route severely congested at school opening and closing times and a road surface that has been significantly compromised by successive attempts of utilities to keep up with present demand.

it is recognised that development may well result from offers of infrastructure improvement that 'cannot be refused' but I would counsel against further development at either end of the conurbation which would tend to emphasise its linear reputation.

For the future, there is a significant governance issue in extending the built-up area into the neighbouring villages. By doing so the issue of one village supporting the infrastructure and services at a Parish level whilst the surroundings pay nothing, effectively, becomes a real issue to be solved by the Boundary Commission. The inclusion of the areas of neigbouring parishes into 'Poringland' recognises this issue and tacitly accepts that they be treated as one organic whole, no matter what the parish boundaries are at present.

My final issue is to do with development of villages to the south which predominantly use the B1332 (formerly A146) through the village for
commuting. I support the stand of SNC in looking at permitting
development in clusters of villages - it can be seen that these villages are becoming unsustainable with their populations becoming aged, pale and affluent, bereft of shops, schools and pubs. There will be resistance to SNC's approach but, no matter what resistance to the strategy, this may well be the only method of preventing the villages becoming 'ghosts'.

I commend the GNLP and support it - particularly in its approach to Poringland sites that have been offered for development.

I have not been able to find the South Norfolk villages cluster plan. I am concerned that the clusters could result in dispersed housing into the countryside.

No justification for the cluster plan. No justification for the quantity of development. No criteria relating to suitability for development. SNDC confirm this is a political move to satisfy urban areas. Landowners/builders given initiative in choosing sites. No local community involvement in the plan.
Detailed comments submitted by email

Please see attachments for full representation

I have read the response from Hainford Parish Council in regard to policy one, questions 13 & 14 and policy 7, item 4, questions 45 & 46 and I, as a resident of Hainford fully agree with their responses.

I have noted with some despondency that in the published record of flood incidents from June 2017, we have been clustered with Spixworth and Horsham St. Faiths in regard to the number of ‘recorded flood incidents’ totalling 13. Pardon the pun, but this appears to be ‘watering down’ the flood statistics for Hainford, I live in *Redacted* Hainford and this road is almost permanently flooded during the winter months. The last month, this road has been abmissmal for access *redacted*, perhaps someone from Broadland District Council would like to visit to observe what we have to put up with.
And, for future reference, give the flood statistics for Hainford as a stand alone village and not cluster us with other villages to hide the extent of the problems we have.

As we all know statistics can say whatever the statistician wants them to say, but it’s not always correct.

Please see attachment

The "village clusters" concept is entirely unsustainable in that it relies upon accessing small pockets of geographically disparate infrastructure which will result in the need for increasing numbers of private car journeys and, given the decreasing availability of public transport, clean or otherwise, works directly contrary to the plan's stated environmental objectives.
Additionally, SNDC talk of a "minimum of 1, 200 houses" in these clusters. This should, at least, be corrected to 1, 200 MAXIMUM. If they actually do envisage 1,200 minimum then they are creating a sort of uncontrolled, open-ended 'free for all".

Village Cluster Statement - Greater Norwich Local Plan (GNLP)
Despite extensive consultation on the GNLP South Norfolk District Council (SNDC) has, at the very last minute, decided to embark on a “separate village cluster housing site allocation plan”. It is looking for a minimum of 1200 sites. This wildly exceeds the statement at the SNDC presentation that the GNLP seeks 9% of 7840 (=705 sites) in village clusters for the whole of the GNLP area. There is no explanation or justification offered for this plan or the quantity of housing.

SNDC has informed the Parish Council that the village cluster idea arises from urban areas stating that “rural areas should take their share”. This appears therefore as a purely political move. This view is confirmed by the fact that no planning justification has been advanced by SNDC. The other worrying aspect is that the initiative appears to be handed to landowners and builders to identify sites.

If the cluster exercise is to have any credibility it must contain a number of features:
(a) there must be some reasoning underlying the quantity of housing sites being sought.
(b) there must be a planning rationale for identifying clusters setting out how they will work together.
(c) there must be a set of criteria relating to suitability for development. These to include how they will meet local housing need, proof of sustainability relating to transport etc, provision of infrastructure, availability of services such as schools and doctors, and environmental enhancement.
(d) there must be a process of community consultation.

Brockdish and Thorpe Abbotts Parish Council is not against development but is very concerned that it must be justified and properly planned. The present plan does not meet that requirement.

“Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside. It is difficult to understand the justification for changing the current settlement hierarchy within the JCS to that proposed in this draft plan, in particular by eliminating the JCS categories of Service Villages, Other Villages, smaller rural communities and the countryside, which provided opportunities for a more nuanced approach to housing allocation, appropriate to each category of community/settlement within their own setting, landscape and context. The “village cluster” approach is a relatively crude one, with much more of a ‘one size fits all’ approach. CPRE Norfolk is particularly disappointed to see that the current JCS settlement hierarchy is not even offered as an ‘alternative approach’ in the draft GNLP, and wishes to see this rectified.

Even if the “village clusters” are adopted it would still be important to limit these to the area within their settlement boundaries and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.

The different approach for “village clusters” in Broadland compared to those in South Norfolk is not acceptable given the emphasis on the GNLP being a strategic plan for the whole of Greater Norwich. The “village clusters” in Broadland and South Norfolk should be treated in the same way if they are to be included in the final GNLP. This means that a maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’. We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

CPRE Norfolk is concerned by the use of primary school catchments acting as ‘a proxy for social sustainability’, with apparently no other sustainability measures being taken into account when decided on the amount and location of housing within “village clusters”. This does not make the proposed allocated housing within “village clusters” sustainable as required by the NPPF. Other measures should be taken into account within the social, economic and environmental spheres.

Otley Properties Ltd supports the approach to village clusters in South Norfolk, and wish their sites at Seething to be considered through the Village Clusters Site Allocations document:
GNLP0405 North/South of Brooke Road, Seething (allocation/settlement boundary revision);
GNLP0406 West of Seething Street, Seething (settlement boundary revision);
GNLP0587 West of Seething Street; Seething (settlement boundary revision);
GNLP0588 West of seething street, Seething (site now has pp) (settlement boundary revision); ;
GNLP1035 South of Wheelers Lane, Seething(allocation or settlement boundary revision);
GNLP2148 West of Mill Lane, Seething (12 dwellings) (allocation).
They also wish a further site at Burgh Apton to be considered.

Hibbett & Key Ltd support the approach to village clusters and wish their site at Alpington ref: GNLP0400 Land at Church Meadow to be considered for allocation in the South Norfolk Village Clusters Housing Site Allocations document.

“Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside. It is difficult to understand the justification for changing the current settlement hierarchy within the JCS to that proposed in this draft plan, in particular by eliminating the JCS categories of Service Villages, Other Villages, smaller rural communities and the countryside, which provided opportunities for a more nuanced approach to housing allocation, appropriate to each category of community/settlement within their own setting, landscape and context. The “village cluster” approach is a relatively crude one, with much more of a ‘one size fits all’ approach. Hempnall Parish Council is particularly disappointed to see that the current JCS settlement hierarchy is not even offered as an ‘alternative approach’ in the draft GNLP, and wishes to see this rectified.

Even if the “village clusters” are adopted it would still be important to limit development to the areas within their development boundaries of settlements and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.

The different approach for “village clusters” in Broadland compared to those in South Norfolk is not acceptable given the emphasis on the GNLP being a strategic plan for the whole of Greater Norwich. The “village clusters” in Broadland and South Norfolk should be treated in the same way if they are to be included in the final GNLP. This means that a maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’. We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

We do not accept that the basis for Village Clusters should be primary schools. A village strategy should satisfy the housing needs for all generations. Norfolk villages have different attractions and benefits and is why many people chose to live in a certain village or a certain part of a village. Many families dislike block development, so why is GNLP/SNC adopting a single site approach for Clusters? A development convenient to a school doesn’t guarantee a young family purchase or a walk to school. All village sites submitted should be considered on their own merit and a quality decision made.

I consider that the free for all, hands off approach to Village clusters of 4024 dwellings or 9% of growth will negatively damage the character and scale of many of our villages and lead to further transportation issues, without achieving "social sustainability" by supporting rural life and services.
It is just spreading the dormitory everywhere.
Add in some windfall development, 3 dwellings a parish and the Plan ticks all the boxes for a free for all !

The Policy 7.4 approach to allowing additional housing development within settlement boundaries is supported.

The concept of 'village clusters' has the virtue of being novel but the plan seems to assume that it is an accepted concept and has some legitimacy. One this basis it is proposed that additional housing development (very attractive to developers) is permitted without any concomitant infrastructure to support such development. The use of primary school catchment areas as a proxy for sustainability is neither explained or justified and in our view represents a crude measure for planning. The production by SNDC of a separate (possibly unconnected) plan typifies the disjointed approach indicative of this draft plan

The policy should make mention of prioritising brownfield development.

The concept of " Village Clusters" appears to be entirely invented to justify the dispersal of housing into the countryside. It is a change from the settlement hierarchy in the JCS that is not explained.
Why are the "Village Clusters" in Broadland being treated differently from those in South Norfolk? This seems grossly unfair to both areas.
Why are a range of sustainability measures not being used to calculate the level of housing required in the "Village Clusters" over and above the current one that solely uses the availability of primary school places.

Lanpro offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth. However, we do not support the significant amount of growth to be directed to village clusters, potentially allowing a significant number of new homes (1200, 15% of all new allocations) to be located in small settlements in the rural area of South Norfolk (outside of the old Norwich Policy Area). Other small sites are identified within the rural parts of Broadland. Without knowing where the South Norfolk sites are and whether they are accessible and sustainable in all respects, we are concerned that the approach is neither sustainable or compatible with the objectives in relation to tackling climate change.

We consider that a more sustainable approach, that would be in line with the overall objectives and vision set out for the Growth Strategy would be to allocate 400 of the South Norfolk 1200 to cluster villages and key service centres within the old NPA parts of South Norfolk and 500 as the first phase of a new settlement at Hethel in the Cambridge – Norwich Tech corridor. There is scope for a some more rural dispersal to contribute to the vitality of small rural villages and therefore, the remaining 300 should only be allocated to small cluster villages in the more rural parts of South Norfolk (outside the old NPA) where there is walkable access to a primary school and good public transport links to other key services. Any Broadland allocations outside of the old NPA should also only remain if the same applies.

Allocating 500 of the homes to a new settlement at Hethel would also provide land to expand the opportunity for hi-tech engineering jobs within the growth corridor. In this location the homes would help to ensure that the plan “will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor” (paragraph 108).

They will also:
“strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” (Delivery Statement page 36).

The current strategy allows significant dispersal to small rural village clusters and without further explanation and justification, we are concerned that this may not make a positive contribution to these key threads of the plan. It could have negative impacts in terms of increasing the number of private car and other journeys and it will place greater demand on small local schools and services. These demands are more difficult and costly to address within a spread of small rural villages rather than within a new settlement where social infrastructure can be properly planned and funded from the outset with corresponding economies of scale.

As currently proposed, the settlement hierarchy presents an unambitious variation on the previous Joint Core Strategy (JCS) with an unjustified increase in rural dispersal. The draft plan states that 82% of the new housing requirement to 2038 is made up of existing JCS allocations that have been carried forward (paragraph 156). This means that including the proposed uplift on existing allocations, 36,503 homes out of a total housing figure of 44,343 are carried forward.

Glavenhill Ltd offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth. However, we do not support the significant amount of growth to be directed to village clusters, potentially allowing a significant number of new homes (1200, 15% of all new allocations) to be located in small settlements in the rural area of South Norfolk (outside of the old Norwich Policy Area). Other small sites are identified within the rural parts of Broadland. Without knowing where the South Norfolk sites are and whether they are accessible and sustainable in all respects, we are concerned that the approach is neither sustainable or compatible with the objectives in relation to tackling climate change.

We consider that a more sustainable approach, that would be in line with the overall objectives and vision set out for the Growth Strategy would be to allocate 400 of the South Norfolk 1200 to cluster villages and key service centres within the old NPA parts of South Norfolk and 500 as the first phase of a new settlement at Hethel in the Cambridge – Norwich Tech corridor. There is scope for a some more rural dispersal to contribute to the vitality of small rural villages and therefore, the remaining 300 should only be allocated to small cluster villages in the more rural parts of South Norfolk (outside the old NPA) where there is walkable access to a primary school and good public transport links to other key services. Any Broadland allocations outside of the old NPA should also only remain if the same applies.

Allocating 500 of the homes to a new settlement at Hethel would also provide land to expand the opportunity for hi-tech engineering jobs within the growth corridor. In this location the homes would help to ensure that the plan “will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor” (paragraph 108).

They will also:
“strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” (Delivery Statement page 36).

The current strategy allows significant dispersal to small rural village clusters and without further explanation and justification, we are concerned that this may not make a positive contribution to these key threads of the plan. It could have negative impacts in terms of increasing the number of private car and other journeys and it will place greater demand on small local schools and services. These demands are more difficult and costly to address within a spread of small rural villages rather than within a new settlement where social infrastructure can be properly planned and funded from the outset with corresponding economies of scale.

As currently proposed, the settlement hierarchy presents an unambitious variation on the previous Joint Core Strategy (JCS) with an unjustified increase in rural dispersal. The draft plan states that 82% of the new housing requirement to 2038 is made up of existing JCS allocations that have been carried forward (paragraph 156). This means that including the proposed uplift on existing allocations, 36,503 homes out of a total housing figure of 44,343 are carried forward.

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

The amount of housing especially in South Norfolk is too much. By definition the housing will be on greenfield sites, further reducing arable land and amenity of the countryside. This attempt through the GNLP to remove the protection of 'other villages' from the JCS by joining villages up to create larger and larger communities without any infrastructure is unfortunate and misplaced. One of the things Norfolk is known for are the unspoilt villages and countryside, this will be lost as more and more space is taken up in the name of 'economic development'

We would support the distribution of some growth to smaller settlements in order to support their vibrancy and sustainability. These clusters are predicated on school catchment areas and justification for the proposed scale of development is based on the school’s ability to expand, however in a number of villages the schools are either at capacity or landlocked, thus preventing their expansion. It is considered that further work is required to ensure that the levels of development proposed in these areas is deliverable, and would not result in students needing to be transported to other areas to attend school as this would be counter-intuitive.

Please see attached for full submission

Please see attached for full submission

Please find attached representations.
These representations are made on behalf of KCS Developments in respect of the Greater Norwich Local Plan to 2036.
Our Client is promoting five sites within Spooner Row which can deliver between 173 and 246 dwellings along with community facilities. Spooner Row is proposed to fall within the lowest tier of the settlement hierarchy within the GNLP – the “village clusters” – despite previously being identified as a service village within the Core Strategy. These representations demonstrate that this approach is flawed and underplays the significance of settlements such as Spooner Row.

Policy 7.4 Village Clusters
Q 45/Q46
Happy with the general approach.
It is understood that SNDC will embark on their own Cluster Policy consultation and this response has been made with that in mind and the opportunity to maker further comments at the appropriate time.

Please see attached for full submission