Stage C Evidence Base

Object

Representation ID: 23088

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the inclusion of GNLP2168 (Silfield Garden Village) as a ‘reasonable alternative’ withn the Sites Assessment and are of the view that if allocated could deliver sustainable growth and help to meet the objectives and ambitions of the GDNP.
We consider that SGV as a reasonable alternative site would be of great value to the GDNP in meeting the housing needs of the GNLP and this is covered in more detail in our representation on the Strategy Document.
However, we strongly object to the approach to the site assessment taken within the draft GNLP Sites document. Our comments below should be read in conjunction with the comments made on the approach to village clusters set out above which are interlinked to how the site assessment approach has been undertaken and preferred sites decided.
The decisions made within the draft GNLP Sites document are informed by the individual site assessment booklets which in turn have been informed by the various iterations of the HELAA.
It is noted that no site assessment booklets have been produced for the South Norfolk Village Clusters given the proposed approach to produce a separate document to allocate these sites (see comments on this approach in Section 2).
The individual site assessment booklets set out a 7-stage approach to the site assessment process. The process is outlined as follows:

THE SITE ASSESSMENT APPROACH
• Stage 1 – List of sites promoted in the settlement;
• Stage 2 – HELAA tables;
• Stage 3 - Summary of consultation comments;
• Stage 4 - Discussion of submitted sites;
• Stage 5 – Shortlist of reasonable alternative sites for further assessment;
• Stage 6 – Detailed site assessments of reasonable alternative sites; and
• Stage 7 – Settlement based appraisal of reasonable alternative sites and identification of preferred sites.
On this basis, it is not clear how the SA has featured in the site assessment process. We suggest that this is made more explicit for the next round of consultation, and would welcome any clarity on this point in the meantime.
In addition, some of the site assessment stages which have taken place are vague in detail and process. For example, the Stage 3 commentary recorded includes both attributed and non-attributed commentary (so it is unclear whether comments are from promoters, the Council, other stakeholders of objectors), and whilst it includes some stakeholder comments (eg. Wildife Trust) it does not include others.
Equally, Stage 4 (Discussion of Submitted Sites) does not include any written evidence (such as written minutes of discussions; a record of what criteria shaped these discussions; or a list of main outcomes), so it is not clear to a member of the public or a developer why a particular site has been excluded from the next stage of assessment.
We suggest that without further clarity on this matter, the assessment process is flawed. Again, this matter should be addressed as part of the next round of consultation.

Sustainability Appraisal comment in attachments.