Settlement Map

Object

Representation ID: 24409

Received: 22/03/2021

Respondent: ClientEarth

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

It would appear that the adverse effects [identified in the SA report] have been exacerbated by the decision to plan for ….. development on greenfield land and in unsustainable locations.
The impact of this decision is clear from looking at a few examples of the Sustainability Appraisal’s assessment of allocations made in the plan:
• In respect of the Key Service Centre allocations (at C.9.12.2): “It is assumed that this policy would be in conformity with the requirements of other polices, such as Policy 4, to promote sustainable transport. This could potentially help to improve access to workplaces and social infrastructure. However, as these Key Service Areas are located in primarily rural areas across Greater Norwich, improvements to transport infrastructure set out in Policy 4 would be unlikely to provide all site end users with sustainable connections to Norwich city centre, Norfolk and nationally.”
• In respect of the Village Clusters allocations:
o “There is a vast network of [Public Rights of Way] across Greater Norwich. This would be likely to provide good pedestrian access within and around these settlements. However, many of the Village Clusters are situated in remote areas within Greater Norwich, with limited access to railway stations, which are primarily located within Norwich and the east of the Plan area, with some stations also located to the west of South Norfolk. Site end users in more rural locations would also be expected to have limited access to regular bus services, despite some expected transport improvements in line with Policy 4. It is likely that a large proportion of site end users would be situated outside the target distance of public transport links. The rural location of development proposals under this policy would be expected to contribute to a relatively high reliance on personal car use…” (C.10.12.1)
o “Under this policy, it is likely that development will occur at a number of greenfield sites, which would be expected to result in a net loss of agriculturally and ecologically valuable soils. As the significant majority of soils in the Plan area are Grade 3 land, it is likely that this policy would result in a net loss of BMV land. This impact would be permanent and non-reversible and would also reduce the carbon sink capacity of soils across the Plan area.” (C.10.14.1)
• In respect of site GNLP4054 – for provision of 400 dwellings:
o “Sites GNLP4052 and GNLP4054 comprise previously undeveloped land and are located outside the existing settlement of Hethersett. Therefore, the proposed development at these two sites could potentially contribute towards the urbanisation of the countryside.” (D.17.4.4)
o “The nearest convenience stores, Park Drive Stores and Tesco Express, are located in the centre of Hethersett. Sites GNLP4052 and GNLP4054 are located outside the target distance to these shops.” (D.17.6.1)
o “Hethersett Surgery is located in the centre of Hethersett. Sites GNLP4052 and GNLP4054 are located wholly or partially outside the target distance to this GP surgery.” (D.17.8.5)
o “Hethersett Woodside Infant and Nursery School and Hethersett Voluntary Controlled Junior School are located in the south of Hethersett village. Little Melton Primary School is located to the north of the cluster. Both sites in this cluster are situated wholly or partially outside the target distance to these schools.” (D.17.10.1)
o “Sites GNLP4052 and GNLP4054 are located wholly or partially outside the target distance to a bus stop providing regular services. … The closest railway station to Hethersett is Wymondham Railway Station, located approximately 6km to the south west of the cluster. This is outside the target distance …” (D.17.12.1 and D.17.12.2)
o “The proposed development at Sites GNLP4052 and GNLP4054 would be likely to result in a major negative impact on natural resources due to the loss of 20ha or more of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils.” (D.17.14.2)