Publication

To make the plan sound, a dedicated policy to provide clarity and facilitate rural growth is needed. Such a policy can support windfall proposals, or allow for limited development, but in either case, would supplement the existing rural economies, facilitating growth. Growth exceeding that of 5 dwellings is considered necessary to have any significant impact upon rural vitality, and given the current proposed policy would not require affordable housing contributions, is not considered to be a justified approach. Instead either a windfall policy that assesses each settlement should be proposed, or a policy which allows for a windfall scheme of up to x% of existing housing stock be allowed. This could also have in a clause that allows the standard percentage to be increased if provision is made for the developer to provide benefits for the rural community, such as provision for village shops, or new footpaths aiding sustainability.

Taking the village of Frettenham for example, if no revision to the policy is proposed, then specific allocations should be proposed. Out of the allocations that have been proposed at Regulation 18, GNLP2076 & GNLP2078 would be ideal proposals. Such a development would ensure a good proportion of growth is available which would supplement the existing local facilities in a more substantial way than ad hoc development of 3 to 5 dwellings that the current policy would allow. Such a development would aid in not only creating a more sustainable settlement, where new business can be attracted, but also secure the existing facilities with a wider customer base, especially in light of the recent economic challenges national lockdowns have created.

Policy 7.5 is considered not positively prepared justified, compliant with national policy or effective due to the restrictions on growth that are placed on the more rural areas of the districts. The NPPF states in paragraph 78 that "housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." Policy 7.5 does not supports this national direction, instead through proposing an allocation only approach, coupled with an ineffective windfall proposal, the policy impedes rural economies which require new development, and new residents to be sustainable. Given the GNLP does not identify allocations for growth or provide a significant policy to support needed village and rural community growth, it is considered the GNLP is not compliant with national policies and is unsound in accordance with paragraph 35 of the NPPF.

To make the plan sound, a dedicated policy to provide clarity and facilitate rural growth is needed. Such a policy can support windfall proposals, or allow for limited development, but in either case, would supplement the existing rural economies, facilitating growth. Growth exceeding that of 5 dwellings is considered necessary to have any significant impact upon rural vitality, and given the current proposed policy would not require affordable housing contributions, is not considered to be a justified approach. Instead either a windfall policy that assesses each settlement should be proposed, or a policy which allows for a windfall scheme of up to x% of existing housing stock be allowed. This could also have in a clause that allows the standard percentage to be increased if provision is made for the developer to provide benefits for the rural community, such as provision for village shops, or new footpaths aiding sustainability.

Taking the village of Frettenham for example, if no revision to the policy is proposed, then specific allocations should be proposed. Out of the allocations that have been proposed at Regulation 18, GNLP2076 & GNLP2078 would be ideal proposals. Such a development would ensure a good proportion of growth is available which would supplement the existing local facilities in a more substantial way than ad hoc development of 3 to 5 dwellings that the current policy would allow. Such a development would aid in not only creating a more sustainable settlement, where new business can be attracted, but also secure the existing facilities with a wider customer base, especially in light of the recent economic challenges national lockdowns have created.

Policy 7.5 is considered not positively prepared justified, compliant with national policy or effective due to the restrictions on growth that are placed on the more rural areas of the districts. The NPPF states in paragraph 78 that "housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." Policy 7.5 does not supports this national direction, instead through proposing an allocation only approach, coupled with an ineffective windfall proposal, the policy impedes rural economies which require new development, and new residents to be sustainable. Given the GNLP does not identify allocations for growth or provide a significant policy to support needed village and rural community growth, it is considered the GNLP is not compliant with national policies and is unsound in accordance with paragraph 35 of the NPPF.

To make the policy and plan sound, it is considered that a more flexible policy be proposed. Policies HOU03 and HOU05 of the Breckland Local Plan (see Annex 1) facilitate a more flexible approach that directly responds to the needs of custom/self-builders. These policies recognise the principle aspirations of self-builders and sets a favourable framework for approving self-build dwellings in small villages and hamlets outside of settlement boundaries. This is done by allowing for development in more rural locations and actively encouraging smaller sites, which are more likely to be delivered through a windfall style policy, than tying self-build plots in large housing allocations. It is considered that given the overall need for the joint authorities, that a mix of dedicated allocations in more rural locations be provided, alongside a policy that actively supports small scale self-build and custom build plots on land that relates well to existing settlements.

Policy 5 states that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom build plots. It is considered that this policy is not effective to ensure the delivery of self or custom build dwellings.

Speaking from a practical point of view, the attraction of custom and self-build dwellings lies in the flexibility of the design and layout. Given the size of the proposed allocations within the GNLP, it is fair to assume that volume house builders will be delivering the majority of sites, this means in reality that economies of scale will be used to produce standardised dwellings, where bespoke units will appear incongruous. Additionally, incorporating a small proportion of self or custom build dwellings within such schemes are unlikely to attract the individuals looking for purpose built bespoke homes. As such, the strategy is considered to be unjustified as the plan does not respond to the evidence that custom builders prefer development on smaller, more rural sites, not within large housing allocations.

The policy states that 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots unless there is no need, or plots have been marketed for 12 months and have not been sold. Given that these plots will be unattractive to self builders, it is likely any need will not be met by this policy as vacant plots will eventually be re-developed when final phases of large allocations are completed. Additionally, logistical complexities of delivering sites with multiple contractors simultaneously will further reduce the attraction for smaller self-builders.

This means that there are questions regarding the deliverability of the policy over the plan period given that an inadequate strategy has been provided that is not positively prepared. This is because the policy is not providing enough flexibility and choice to address the areas objectively assessed need, and will fail to secure delivery of a mix of sites to enable choice for self-builders. As such the policy is found to be ineffective, not positively prepared, and unjustified in conflict with paragraph 35 of the NPPF.

To make the GNLP sound in accordance with paragraph 35 of the NPPF, it is considered necessary that a further study into the implications of COVID-19 and the future of employment needs to be commissioned. Looking at rural communities, the option of providing flexible working spaces could be the key to unlocking not only the vitality but the viability of the more rural settlements. Currently the provision of large-scale employment allocations requires mass commuting to work. Instead, the creation of a policy that allows for flexibility of the smaller scale and bespoke employment uses within small settlements would allow for local people to commute sustainably (by walking, for example) thus reducing the carbon footprint, and supplementing the GNLP’s aspirations of providing for a healthier, more vibrant community. Such a policy would also help support rural economies by providing for more employment opportunities locally, as well as helping retain football within existing settlements where future viability of local facilities are questionable following the national lockdowns and associated loss of earnings.

Taking the settlement of Frettenham, if the policy is not amended, then specific allocations should be considered that would facilitate growth. We can see that there are facilities in Frettenham, and sustainable transportation options available for local people, however the option to walk to work will always have a lower carbon footprint than public transport. Furthermore, through providing a small number of employment opportunities locally, we can in accordance with paragraph 83 of the NPPF, supplement the sustainable growth and expansion of the settlement through well designed new buildings, providing local jobs for local people, as well as accommodating the smaller more bespoke businesses such as the arts and crafts sector and the tech industry, which would be incongruous with larger employment site allocations. Furthermore, it is prevalent that such industries do not wish to own large scale factories in traditional employment locations. As such a dedicated policy should be provided regarding the growth of small employment opportunities in more rural locations for the more bespoke businesses, or specific allocations should be promoted, such as GNLP2076 and GNLP2078.

Additionally, it is necessary that the policy is modified in either case to take account of the availability locally of brownfield sites that may not directly fall within the settlement but are adjacent to, or relate well to the settlement boundaries in accordance with paragraph 84 of the NPPF.

Policy 7.4 is not positively prepared, justified, compliant with national policy or effective as it does not consider distinguish between brownfield and greenfield land. The policy fails to prioritise brownfield development, or take into consideration brownfield land that is not infill which could make a more effective use of the land. Similarly, the policy does not address the need for enhancing the environment and improving the sustainability of existing rural businesses that may exist outside settlement limits.

Furthermore, Policy 7.4 states that small scale employment uses will be acceptable in principle within development boundaries. This is permitted through the reuse of rural buildings or through the potential expansion of existing employment sites. However, the policy does not take into consideration recent trends regarding the vast number of home working, and the need for small office space close to home for all sectors of the market. Currently, the assumption is that home working means people working from their own individual dwellings, however looking at the employment land assessment addendum 2020, no consideration has been given to the proliferation of office space and the potential for existing businesses wanting to move to less dense localities where there is more scope for incorporating employee welfare facilities and social distancing measures. As such, given the last year, it is considered the policy is unjustified in this regard. Furthermore, when coupled with the rise in entrepreneurial spirit and home businesses that have arisen during the lockdowns, there is an increased demand for small multipurpose spaces, ideally close to existing residential properties in more rural locations. The provision of such units will supplement existing rural economies in unprecedented ways, capitalising upon the radical shift of home working that the recent pandemic has caused, however the policy makes no effective or justified approach to addressing recent shifts in working.

The evidence base for employment uses and employment space was gathered in 2016 and 2017, and supplemented in 2020, based on a forecast model done in 2017. As such, it is considered that the evidence base does not adequately reflect the current circumstances as no one could have predicted the recent pandemic and the consequences for employment space. This has resulted in the proposed policy based on an unjustified strategy.

It is considered in accordance with paragraph 35 of the NPPF, that the policy does not pose an appropriate strategy taking into account reasonable alternatives. and is considered to be unjustified, unsound, not compliant with national policy and not effective.

It is considered necessary that the second sentence, which relates to positive consideration of custom and self-build, be revised to provide further clarity as to the aspirations of the policy. Additionally, it should be made clear where such dwellings should be located in order to receive policy support, as well as clarity regarding the quantity of self and custom build that will be supported. For example, GNLP2076 and GNLP2078 allocations both propose a number of self-build plots which help the local authority address its need to deliver service plots for self-build accommodation. At the moment it is assumed that policy 7.5 would be supportive of these schemes if they came forward, however, to undertake the necessary infrastructure such as the access road to reach the plots and make good the site for development, more than five plots would have to be delivered. As such, although the policy states that positive consideration will be given, the policy currently, if interpreted correctly, is too restrictive to actually facilitate the aspiration of the delivery herself and custom build dwellings.

Policy 7.5 is considered to be inconsistent with national policy as well as not being positively prepared or effective. The policy states that positive consideration will be given to custom and self-build dwellings. Although it does not provide sufficient clarity as to how it will be supported. Reading the policy at face value, the policy is split into two sections, the first sentence is part A which relates to small scale residential development, which is expanded upon through the four bullet points. Part B is the second sentence which reads “positive consideration will be given to self and custom build.” The NPPF in paragraph 16 requires that “plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.” Regarding the second element of policy 7.5, there is a lack of clarity regarding the support for self and custom build dwellings. No indication is given as to where these units have to be located, unless it is meant for the policy reader to interpret that this second element is also applied to development adjacent to a development boundary or adjacent to a recognisable group of dwellings. Furthermore, the lack of an ‘S’ at the end of self and custom build implies that support will only be given for a single unit. As we know viability is a fundamental consideration when it comes to development, and economies of scale are more often than not necessary to facilitate development. Under the current wording of the policy, it is unclear if a scheme, for example, was to propose five or more serviced plots for custom and self-build dwellings whether this would be supported. As such this lack of clarity, is in direct conflict with paragraph 16 of the NPPF. Furthermore, given the lack of clarity, there is a clear inconsistency with national policy and questions over the interpretation and ultimately the deliverability of the aspirations of the policy, resulting in an unjustified and ineffective strategy that is not positively prepared.