Growth Options document

SECTION 6 – TOPIC POLICIES

THE ECONOMY

Context

6.1 There is significant potential for economic growth in Greater Norwich. The City Deal has been signed with Government to promote accelerated growth, the LEP's economic strategy identifies Greater Norwich as the region's main engine of growth and the Norwich Cambridge Tech Corridor initiative promotes further growth of high tech industries which are growing in significance nationally and internationally. In addition, Norwich is part of the "Fast Growth Cities" group^[41] whose ability to attract knowledge-based businesses puts them in a strong position to continue to grow in the future. Key growth sectors are the life sciences and biotechnology, agri-tech, food and drink, creative and digital industries and high-value engineering. Other industries including retailing, tourism and financial services, remain important to the area.

6.2 While economic growth will occur, changes in the way we work mean that there may not be a need to retain all the current employment land. This section therefore seeks your views on how the plan can best support economic growth.

6.3 The NPPF requires local plans to assist in building a strong competitive economy by setting out a clear economic vision and strategy for the area to encourage sustainable economic growth and address barriers to investment, including a poor environment or any lack of infrastructure, services or housing.

6.4 Policies should also be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances and there is a particular focus on the expansion of knowledge driven, creative or high technology industries.

6.5 In relation to employment land, the long term protection of sites allocated for employment use should be avoided where there is no reasonable prospect of a site being used for that purpose.

6.6 The NPPF also requires plans to ensure the vitality of town centres by promoting competitive town centre environments, setting out policies for their management and growth and allocating sites for town centre uses^[42].

6.7 In relation to the rural economy, local plans should support sustainable economic growth and a strong rural economy by taking a positive approach to the growth of rural businesses, agricultural businesses, tourism and leisure developments and support local services and facilities.

6.8 The Housing White Paper^[43] states that economic development is dependent on housing need being provided for and that changes to the NPPF will be made so that non-strategic employment land that has been vacant for five years should be considered for starter home led development.

6.9 The current Greater Norwich policy approach^[44] is wide ranging and covers a number of economic development issues, some of which are not directly related to land-use planning. It:

• seeks to develop the local economy in a sustainable way to support jobs and economic growth both in urban and rural locations. The strategy aims to provide for a rising population, develop Greater Norwich's role as an engine of the wider economy, facilitate forecast job growth potential and increase the proportion of higher value, knowledge economy jobs. At the same time, it aims to ensure that opportunities are available for the development of all types and levels of jobs in all sectors of the economy and for all the workforce;
• requires sufficient employment land to be allocated in accessible locations and, consistent with the overall strategy, to meet identified need and provide for choice; and
• includes policies to help address the needs of small, medium and start-up businesses; larger scale needs; to overcome constraints to the release and development of key sites; and to control other uses on employment land.

6.10 Through a number of measures, it also facilitates opportunities for innovation, skills and training; promotes tourism, leisure, environmental and cultural industries, and supports the rural economy and diversification.

6.11 Feedback from the Issues workshops highlighted the importance of early funding and delivery of infrastructure improvements to support economic growth and the need for a more flexible approach to economic development which recognises the difficulties of influencing where businesses wish to locate. The importance of the economic opportunities presented by connections to Cambridge and increasingly in the future to Great Yarmouth was also emphasised.

6.12 The draft vision for the GNLP promotes a strong economy for Greater Norwich and the economy objective is to support and promote the growth of an enterprising, creative, broad based economy with high productivity and a skilled workforce.

6.13 The plan will need to continue to provide a wide ranging approach to supporting economic development and growth.

The supply of employment land

6.14 The area currently has around 340 hectares of undeveloped employment land that is allocated or permitted. The Employment, Town Centres and Retail study concludes that, even to support an enhanced level of employment growth, the overall need for land is significantly less at 114 hectares.

6.15 There are a number of issues to take into account when considering how much land should be allocated:

• There is a need for supply to exceed demand to provide choice and competition and to provide for the full range and scale of business requirements, and to ensure that there is a good distribution of local opportunities across the urban and rural area;
• Much of the available land is in extensions to strategic sites, building on success and providing long term certainty for investment extending into the future beyond 2036;
• Significant amounts of land are targeted at strategic needs and particular sectors (e.g. around the airport, at NRP, the Food Enterprise Zone and at Hethel);
• The long term success of the city centre as an engine of growth must be supported;
• The balance between city centre office development, which uses land more intensively and efficiently, and more expansive business parks;
• Too much allocated land could undermine growth by reducing certainty for developers and increasing the risk of investment in supporting infrastructure needed to bring sites forward;
• The HWP proposal that non–strategic employment land should be considered for Starter Homes led development may have a major impact.

6.16 Current larger allocations of undeveloped land are:

Site	Size	Note
Airport Business Park	35ha	An undeveloped area to the north of the NDR and east of the A140
Aeropark (a permission rather than an allocation)	40ha	Within the airport curtilage just south of the NDR
Rackheath	25ha	Within the northern part of the NEGT, no specific site has been identified and the scale of growth could be reviewed through a master-planning process
Broadland Business Park (BBP)	15ha	Northern extension of BBP (Laurel Farm).
Broadland Gate	18ha	Next to BBP
NRP	40ha	Extension of the existing NRP
Longwater	11ha	Extensions to the existing employment area
Food Enterprise Zone	19ha	The FEZ is a wider area, mostly unallocated, but includes a site in Honingham, benefitting from a Local Development Order
Browick Road, Wymondham	22ha	A site on the eastern side of the town adjacent to the A11
Hethel	20ha	An extension to the existing Hethel Engineering Centre and adjacent to Lotus Cars

6.17 In addition to these large sites, there is also a wide range of smaller employment sites throughout the area.

6.18 Additional employment land has been put forward for inclusion in the GNLP. Significant proposals include:

• Land at Honingham/Easton which would extend the Food Hub either independently or as part of a new village;
• Land adjacent to the NRP. In particular, 64 hectares of land which wraps around most of the Norfolk and Norwich Hospital has been proposed for commercial and employment use (site GNLP 0331 in the Site Proposals document) – business, office, academic, medical and healthcare facilities. Some of this land might be logically needed for healthcare uses if the hospital wishes to expand at some point by 2036;
• Land at Wymondham/Hethel for a new village including a strategic employment site specialising in advanced engineering and technology.

Options

6.19 There is no evidence to justify increasing the overall supply of employment land. Further increasing supply for which there is no demand increases uncertainty, risking investment to bring sites forward. It also increases the risk of encouraging uses that will be damaging to the city and town centres.

6.20 While there is no overall need for additional land there could be a need for new allocations. Justification could include small sites to support housing growth or larger sites targeted at specific economic sectors.

6.21 Given the NPPF focus on retaining and enhancing "strategic" employment land, there is a need to identify such areas. Failure to do so could lead to the loss of strategic employment land, in full or in part, to housing or other uses over time, and would dilute the certainty for potential new occupiers that particular locations are available. It would also hinder the attractiveness for marketing purposes of Greater Norwich as a key employment location.

6.22 Three reasonable alternatives have been identified for the supply of employment land:

Option EC1: Broadly maintain the current supply of employment land. While there could be some minor changes, currently allocated employment land would continue to be allocated, and land already allocated or developed for employment uses would not be identified for redevelopment for other uses e.g. residential. This could be an appropriate strategy, but would run the risk of there being an excessive amount of land available, which might lead to pressure to "convert" some land to other types of use in an unplanned manner (i.e. through applications rather than the GNLP itself). This is considered to bea reasonable alternative.

Option EC2: Significantly reduce the overall level of supply while still maintaining choice and flexibility. As the principle of development is already established, employment land could be re-allocated for other uses (such as housing) rather than de-allocated. This is considered to be a reasonable alternative.

Option EC3: Develop a criteria-based policy allowing windfall development. This may be an appropriate policy choice alongside either EC1 or EC2 as it would provide flexibility. There is a possibility that locational requirements could change as new technologies develop in a rapidly changing economy. This is considered to be a reasonable alternative.

Retail and Town Centre Policy

6.23 The NPPF requires a sequential approach to locate retail and other town centre uses within appropriate centres before edge or out of centre locations are considered.

6.24 The NPPF also requires the definition of a hierarchy of "town" centres. This helps ensure development of new retailing, services, offices and other town centre uses at a scale that is appropriate to the centre. The current levels of the hierarchy are:

1. Norwich City Centre (a nationally significant retail centre);
2. Town Centres, and Large District Centres within the Norwich urban area (these provide a relatively broad range of shops and services and function as a focus for the community and for public transport);
3. Large Village Centres and District Centres within the Norwich urban area (groups of shops usually containing at least one supermarket or superstore and non-retail service uses such as banks, building societies and restaurants);
4. Local Centres (small groupings of shops, typically comprising a general grocery store, and other small shops of a local nature).

6.25 The centres currently identified at each level can be found in JCS Policy 19. A new district centre on Hall Road, Norwich has recently been built. The NEGT will be served by a single new district centre within the Beeston Park development.

Accommodating expenditure growth

6.26 The Employment, Town Centres and Retail study provides evidence that local rates of "special forms of trading" i.e. expenditure that is not spent in traditional bricks and mortar shops, is higher than the national average. It also advises that retail needs forecast beyond 2027 are unreliable. Based on local data on special forms of trading, the local plan would need to provide for new comparison goods floorspace of around 11,100 sq.m net in the Norwich Urban Area, 2,300 sq.m net in the South Norfolk rural area and 400 sq.m net in the Broadland rural area. Comparison goods are most non-food goods.

6.27 There is no quantitative need for any additional convenience goods (i.e. food and everyday items) floorspace in the Norwich urban area over the period to 2027. There is an over-supply in Aylsham and Harleston and therefore there is no quantitative need for any additional convenience goods provision in these two towns. For the other smaller centres there is a need for up to: 2,500 square metres net in Diss; 300 in Wymondham, 1,200 for small centres in rural South Norfolk and 900 in rural Broadland. Where there is no quantitative need there may be a qualitative need, for example to provide a small supermarket in an under-served area of new housing.

6.28 In accordance with the sequential approach this floorspace should be accommodated in appropriate town, district or local centres.

Options

6.29 While the development management policies documents currently have a sequential approach to new retail development, the strategic nature of the GNLP means that the issue should be covered in the plan. There is no evidence that the levels of the hierarchy are inappropriate but some centres may have changed their positon in the hierarchy due to gains or losses of facilities. Therefore two reasonable alternatives have been identified:

Option EC4: Maintain the current retail and town centre hierarchy. The current hierarchy in paragraph 6.24 is considered to be a reasonable alternative.

Option EC5: Focus new development for retail of comparison goods primarily within existing town centres (i.e. levels 1 and 2 in para 6.24) with perhaps some out of centre allocations. Evidence suggests that there will be a significant growth in retail expenditure on comparison goods. It also indicates that the average turnover across Norwich city centre is lower than comparable centres such as Cambridge. The quality of the offer in the city centre also lags behind some competitor centres. However, there could be some scope for out of centre development in sustainable locations, particularly if there is limited physical scope within the city centre and market towns to accommodate further comparison goods expenditure. This is considered to be a reasonable alternative.

The rural economy

6.30 Current policy^[45] supports the rural economy and diversification by promoting:

• the re-use of redundant non-residential buildings for commercial uses (including tourism and possibly affordable housing);
• farmers markets, farm shops and cottage industries;
• e-commerce in villages;
• development of a food hub;
• rural businesses including tourism.

6.31 Technological changes during the plan period that are difficult to predict are likely to have a significant impact on the rural economy. Question 39 below covers broadband.

6.32 A Food Enterprise Zone west of Easton and south of the A47 has been agreed by Government. This will enhance rural development through the growth of food and farming businesses, including encouraging greater collaboration with research and education institutions, particularly those at Easton College and the NRP. A Local Development Order (LDO) covering an initial 10 ha part of the Food Enterprise Zone was approved in 2017. This creates a simplified planning regime for agriculture related development.

ACCESS AND TRANSPORTATION

Context

6.33 Access and transport is fundamental in day to day life. A well-functioning transport system and access to jobs, services and information is vital to the economy of the area and the well-being and quality of life for residents. Making the most of infrastructure required to support the existing strategy will help support delivery of the growth proposed in the GNLP.

6.34 Section 4 of the NPPF covers transport issues. It^[46] states that transport policies are important to achieving sustainable development, but that urban and rural areas can present different challenges. Patterns of development which facilitate the use of sustainable transport modes, reducing congestion and greenhouse gas emissions, are encouraged for local plans^[47]. It also states that infrastructure investment strategies to support the growth of airports and other large generators of traffic should be supported^[48]. Development should, amongst other factors, be located and designed to support public transport, walking and cycling, minimise conflict between traffic and cyclists/pedestrians and where possible incorporate facilities for ultra-low emission vehicles^[49]. All developments generating significant volumes of traffic should be required to provide a Travel plan^[50].

6.35 Current Greater Norwich access and transport policy^[51] covers a number of separate areas, including strategic transport improvements (such as the Long Stratton by-pass, NDR and various rail and airport improvements), encouraging walking and cycling, boosting broadband connectivity, and improving public transport to and from Main Towns and Key Service Centres. The policy supports the Norwich Area Transportation Strategy (NATS) and identifies this as the detailed means by which transport improvement across the urban area of Norwich will be developed and delivered. The policy identifies strategic improvements to better link the area with the rest of the county and beyond and promotes travel choice and sustainable modes. It also recognises that the area is a mix of rural and urban and access in which travel issues vary, with the use of the private car being particulalrly important to the rural economy.

6.36 Annual Monitoring Reports detail a variety of transport and accessibility indicators, including commuting mode breakdown (car, cycling etc), carbon dioxide emissions and access to housing and services. A number of other transport measures are monitored through NATS monitoring, although this does not necessarily take place every year.

6.37 The main transport and accessibility issues emerging from the issues workshops were:

• There are merits to both concentration and dispersal of growth and the plan should promote a balanced mix of both;
• The A11 should be the focus of growth;
• There is a need to promote better rail connections to London and Cambridge;
• More should be made of the local rail network;
• There is a need to secure funding and delivery of transport infrastructure improvements to support growth;
• Norwich Airport is important to the local economy;
• Recent transport improvements in Norwich city centre were welcomed;
• There is a need to consider congestion on radial routes and Inner and Outer ring roads;
• Bus Rapid Transit and other bus improvement measures need to be made to support the services people need, including simpler cross-service ticketing;
• Buses need to be cheaper relative to parking and park-and-ride costs;
• Car use remains important in rural areas, but there is a need to provide better routes for walking and cycling to schools and for commuting;
• Growth should be located to support the viability of bus services; and
• Fast broadband connectivity is key for all parts of Greater Norwich, with rural areas particularly in need of speed improvements.

Strategic Transport issues

6.38 Strategic transport connections are important to the local economy and growth. The recognition of and support for such improvements in the GNLP can be of considerable assistance when funding bids are being proposed, as well as being potentially necessary to support the scale of growth proposed. The GNLP will therefore include a policy on supporting strategic improvements. The wording of the strategic element of the current JCS policy will need updating to reflect recent progress on the NDR and recent Government funding commitments for improvements to the A47 and rail improvements planned as a result of the recent franchise announcements and to Norwich to London rail services.

6.39 The Roads Investment Strategy has identified improvements on the A47 trunk road at Blofield to North Burlingham, Thickthorn and Easton to East Tuddenham with these starting in 2021/22, 2020/21 and 2021/22 respectively. A new nine year East Anglian rail franchise commenced in October 2016. This will deliver significant improvements to rail services including more services and faster journeys across the network, with two trains providing 90 minute journey times between Norwich and London each way per day, and Norwich to Cambridge services extended to Stansted Airport every hour. In addition, the policy will need to recognise that the county council has identified the Norwich Western Link as one of its infrastructure priorities. As it develops, the GNLP will reflect progress towards delivery of the scheme.

The Development and Implementation of Transport Improvements

6.40 NATS is founded on the principles of enabling growth through the provision of sustainable development and increasing accessibility through widening transport choice. NATS covers the wider urban Norwich area, so does not cover the whole of Greater Norwich. This reflects the areas of greatest transport concentration and pressure. Outside this area transport improvements are dealt with on a local basis. While the GNLP will need to identify the strategic transport improvements necessary to support growth in the plan, smaller-scale area-wide transport improvements to manage the impact of growth and pick up existing traffic issues in Norwich built-up area will continue to be managed through NATS.

6.41 NATS is being reviewed alongside the development of the GNLP, with public consultation exercises taking place at the same time. There are very clear and obvious links between the GNLP and the review of NATS – different patterns of future growth will impose different transport pressures and transport improvements will need to be delivered in a timely way to support planned growth.

Promoting healthier lifestyles, sustainable travel choices and greater accessibility to broadband

6.42 National and local policy is to reduce reliance on the private car and to promote more sustainable and healthy travel choices. Other approaches than that would not accord with local and national policy and are therefore unreasonable.

6.43 Related to this is a key desire to improve the speed and reach of high-speed broadband connectivity across Greater Norwich. The Better Broadband for Norfolk programme aims to make high-speed broadband available to more than 95% of Norfolk's premises by spring 2020.

6.44 National Building Regulations R1 were updated in 2016 to require new buildings to have physical infrastructure to support high-speed broadband (i.e. ducting within the building), but there is no requirement to provide external or site-wide infrastructure beyond the access point. Currently, there cannot be a requirement for broadband connections in local plans, although the HWP proposes to require local plans to set out how high quality digital infrastructure will be delivered in their area.

6.45 The next generation of mobile phone networks will be 5G, and the rollout is expected to commence in 2020. Significantly more base and booster stations will be required than for the current 3G and 4G networks. The draft NSF^[52] states that all Norfolk authorities will aim to work with the telecommunications industry to produce shared guidance on the location of base and booster stations for the 5G network by the end of 2018, with the potential to include this in emerging local plan documents.

6.46 To be consistent with national and local policy, the GNLP will promote healthier lifestyles, sustainable travel choices and greater accessibility to broadband.

Option

6.47 It is considered necessary to have a positive policy on non-car transport improvements and improved broadband connectivity. The alternative approach of leaving this to NATS and the market to bring forward schemes is unreasonable. This is because it would probably not be viewed as positively planning for the longer-term, and would run the risk of reducing opportunities to connect up GNLP policy with Building Regulations and infrastructure investment programmes by utility providers.

Option TRA1: Broadly continue the current approach[53] to encourage public transport improvements, walking and cycling improvements and a better, faster, more comprehensive broadband network. This option would enable positive consideration to be given to such measures, and would help support any funding bids that may present themselves. Improved broadband provision is a key issue, and the influence that a 5G mobile network (with ultra-high speeds) could have on this is significant too. This is considered to be the favoured option.

DESIGN

Context

6.48 As well as providing the homes and jobs we need, well-designed new development can add positively to existing places and create attractive new communities. This can be achieved through good design creating new green spaces and habitats, along with improved access to local services and sustainable transport networks. Good design is therefore essential to ensuring that Greater Norwich continues to be an attractive place to live.

6.49 The importance of good design in new development is recognised throughout the NPPF, and section 7 is titled Requiring good design. The Government "attaches great importance to the design of the built environment…good design…is indivisible from good planning and should contribute positively to making places better for people"^[54].

6.50 Local plans should also "develop robust and comprehensive policies that set out the quality of development that will be expected for the area", allowing for the establishment of "a strong sense of place", to "create and sustain an appropriate mix of uses" and "create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion"^[55].

6.51 Other Government policy^[56] means that few additional standards can be required in local plan policies. For the few allowable optional standards, local evidence is required to justify need. For example, developers must not be required to exceed security standards in individual dwellings; there is a national internal space standard on the minimum size of homes which can be applied through local plans where there is evidence that it is needed; and there are optional higher building regulation specifications for accessibility of buildings^[57].

6.52 Since publication of the JCS, Building for Life (BfL), used in the adopted policy^[58] to provide a means of assessing design quality, has evolved into BfL12. The system now assesses performance against 12 questions, with a traffic-light system (BfL used to be a points score out of 20) and is a collaborative dialogue, rather than an assessable standard. The Design Council recommends avoiding explicitly requiring all developments to achieve 12 greens, but 'expecting developments to demonstrate they are targeting BfL12' for outline applications. Importantly, additional standards must not compromise the viability of schemes.

6.53 The density of development can often be an important element of good design. The NPPF tells LPAs to "set their own approach to housing density to reflect local circumstances"^[59].

6.54 Current policy^[60] requires development to the 'highest standards', creating a strong sense of place and respecting local distinctiveness. To achieve this, the protection of the landscape, townscape and the historic environment is prioritised. Further requirements cover; providing landscaping/public art; ensuring cycle/walk friendly neighbourhoods; increasing use of public transport; designing out crime; the use of sustainable/traditional materials and avoiding impact on environmental assets. Developments of 500+ dwellings or 50,000m² non-residential development are required to be master-planned and 10+ dwellings should achieve at least 14 points in BfL. Design & Access statements for non-residential development are required to show how it meets similar high standards.

6.55 The districts' development management policies provide further detail to address design in slightly different ways, but all deal with local character, scale and density. Norwich's local plan^[61] requires the national minimum internal space standards and a proportion of wheelchair accessible homes^[62] . Neither South Norfolk nor Broadland currently impose such standards.

6.56 Current Greater Norwich policy^[63] covers density of development. It says that development will: "make the most efficient appropriate use of land, with the density varying according to the characteristics of the area, with the highest densities in centres and on public transport routes". Neither the South Norfolk Development Management Policies document, nor the Broadland equivalent, specify any minimum density requirements for development, emphasising the importance of considering appropriate densities in the context of local character. The Norwich Development Management Policies document expresses similar sentiments about respecting existing character and function, but also states^[64] that a minimum net density of 40 dwellings per hectare should normally be achieved in this wholly urban area, with higher densities normally acceptable in the city centre and areas close to other retail centres and the public transport network.

6.57 The density of individual planning applications is often calculated, but neither South Norfolk nor Broadland monitor density specifically. Norwich does, however, and since 2008/9, about 90 per cent of dwellings completed have been at densities of more than 40 dwellings per hectare.

6.58 Relatively little was said in the Issues workshops about design and density, apart from emphasising the general importance of high-quality design in new development.

6.59 The GNLP's draft objective for communities promotes well-designed developments with good access to jobs, services and facilities. The homes objective focuses on the delivery of high quality homes of the right size, mix and tenure to meet people's needs throughout their lives. The environment objective promotes design which protects and enhances the built and natural environment, makes best use of natural resources and addresses climate change.

6.60 The HWP has a great deal to say on the importance of good design, and is particularly strong on the need for communities to have a stronger voice in the design of new housing. It proposes^[65] that the NPPF will be amended to require local plans "to set out clear design expectations following consultation with local communities". Area Design Codes and the greater use of Local Development Orders are also encouraged^[66].

6.61 In relation to space standards for residential dwellings, the HWP says^[67] that the Government "will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer".

6.62 In relation to density, the HWP states^[68] that it is the Government's intention to amend the NPPF to make clear that low-density housing should be avoided (where there is an identified shortage of housing land), and the scope for higher-density development in urban areas well-served by public transport should be considered.

Options

6.63 Not having a design and density policy in the GNLP, simply relying on existing development management policies, is unreasonable as the NPPF clearly requires a specific policy approach to be taken in new local plans. It would also risk a policy vacuum in some areas currently covered by JCS policies 1 and 2. Two reasonable alternatives have been identified:

Option DE1: Broadly continue with the existing design and density policy approaches, with some relatively minor changes and updating, covering general high-quality design, recognising local character, encouraging walking and cycling etc. This would address, albeit in a fairly basic manner, the requirements of NPPF para 58. This approach could be appropriate, but may not enable full recognition of emerging national policy changes, with an increased focus on high-quality design and density. This is considered to be a reasonable alternative.

Option DE2: Create a stronger policy approach to design and density, including giving a clear policy approach to higher-density development in appropriate locations or scenarios. There are links to the housing delivery policies. This approach would allow most of the existing policy content to be rolled forward, with appropriate updates, but it could allow greater specificity of design requirements. It could also allow identification of areas suitable for higher-density development, and perhaps specify minimum densities. It could consider the question of residential space standards, design quality and wheelchair accessibility too. This is considered to be a reasonable alternative.

HOUSING

Context

6.64 Increasing the delivery of housing is a key aim of Government policy and is a significant issue in Greater Norwich. However, it is important that the GNLP ensures that a plan-led approach can be taken so that much needed housing is delivered in locations where it minimises the need for additional infrastructure and enables new residents to have sustainable access to services and jobs.

6.65 The NPPF^[69] requires local plans to set out strategic priorities to deliver the homes needed in the area and highlights the need for authorities to:

• Plan for a mix of housing based on current and future demographic trends, market trends and the needs of various groups, such as families, older people, self-builders, people with disabilities and service families; and
• Identify the size, type, tenure and range of housing required in particular locations, reflecting local demand.

6.66 Much of the key evidence base for housing need in Greater Norwich is in the 2017 SHMA. Chapters 4 and 5 (Core Matters) discuss the overall housing needs of the Greater Norwich area and more specific SHMA evidence is discussed in the relevant sections below.

6.67 Current policy in Greater Norwich^[70] covers a number of housing issues, including: the scale and distribution of housing growth; the mix of housing required for balanced communities; the delivery of affordable housing; delivery of Housing with Care; and planning for Gypsies and Travellers and Travelling Showpeople.

6.68 Annual Monitoring Reports (AMRs) in recent years have shown that housing delivery has been variable. In the Norwich Policy Area (NPA), there is not currently a five-year supply of land (the figure for the end of 2015/16, the most recent available, is 4.70 years). The housing land supply position in the two Rural Areas is much higher, being 28.4 years in the Broadland Rural Area and 39.6 years in the South Norfolk Rural Area. The delivery of affordable housing overall in Greater Norwich has also been short of that required in recent years.

6.69 Discussions at the Issues workshops in relation to housing delivery covered: early funding of infrastructure being critical to support housing; affordability; the need for developments to offer a balanced mix of housing which considers the needs of an ageing population; general support for appropriate densities of housing; space standards; adaptable homes; and local distinctiveness.

6.70 While the HWP does not have any formal status at present, it is nonetheless a clear statement of the Government's intent and is therefore important. Many of the proposals to speed up the delivery of housing would, if implemented, have important effects on the preparation of local plans. A Government consultation, Planning for the right homes in the right places, which ran from September-November 2017, fleshed out some the HWP intentions.

6.71 The draft GNLP objective To enable delivery of high quality homes of the right size, mix and tenure to meet people's needs throughout their lives, will contribute to the vision to grow vibrant and healthy communities.

What should the minimum affordable housing threshold be?

6.72 Current Greater Norwich policy states that affordable housing will be sought on all sites of 5 dwellings or more, with stepped thresholds of 20%, 30% and 33% (for sites of 16 dwellings or more). However, a written ministerial statement in November 2014 (which is reflected in the Planning Practice Guidance) states that developments of fewer than 11 dwellings should not be required to provide affordable housing contributions (the Government's reasoning being that small and medium-sized builders need support). Whilst this does not supplant the primacy of the development plan in the determination of planning applications, it is considered likely to be included in an updated version of the NPPF, which is expected in spring 2018.

6.73 Greater Norwich is a mix of urban areas and extensive rural areas, with many small settlements. Smaller sites have tended to be an important source of affordable housing, particularly in more rural areas. Applying a minimum threshold for affordable housing is closely linked to the minimum allocation size that the GNLP will have, but having too high a threshold for affordable housing would risk delivering less affordable housing through Section 106 agreements linked to planning applications.

6.74 Irrespective of the affordable housing threshold chosen for the GNLP, it is proposed to require the affordable rented: low-cost home ownership ratio evidenced in the SHMA rounded to 80:20 for sites of 50 or fewer dwellings.

Options

6.75 Two potential policy alternatives are suggested for this issue, requiring affordable housing on sites of five or more dwellings, and on sites of eleven or more dwellings. Two further options are considered to be unreasonable:

• Requiring affordable housing on sites of fewer than five dwellings. This approach would strongly conflict with Government policy to support small and medium-sized housebuilders, and would also be likely to generate viability concerns, meaning that some sites may have to go through additional negotiations to reduce or set aside the policy requirement, potentially delaying the delivery of housing.
• Only requiring affordable housing on sites of more than 15 dwellings. Excluding sites smaller than 15 from affordable housing requirements is likely boost their viability. However, it could also significantly diminish the delivery of affordable housing, as many sites in Greater Norwich, particularly brownfield sites, tend to be smaller than this. This would therefore eliminate a significant source of affordable housing supply from smaller "windfall" sites that will come forward during the plan period. This approach could also reduce the choice of allocation sites, with potential detrimental impacts on character and appearance and also on securing mixed and balanced communities.

Option AH1 - A proportion of affordable housing would be sought on all sites of five or more dwellings or 0.4 hectares or more (as per current JCS Policy 4) Historically many small sites have been developed across Greater Norwich. With the potential decline of 100% affordable housing exception sites, smaller sites could become the main source of affordable housing in smaller settlements. The approach would, however, conflict with the threshold set out in national guidance, which is sites of 11 or more dwellings. Therefore, very clear evidence would be needed to show a local necessity, which would outweigh the approach advocated in the PPG (and, potentially in 2018, the NPPF). The effect of this policy approach on site viability could be minimised by allowing the amount/tenure balance of sites to be adjusted in appropriate circumstances. Notwithstanding the above, because of the potential importance of a lower threshold to the delivery of affordable housing in smaller settlements, this approach is currently considered to be a reasonable alternative.

Option AH2 - A proportion of affordable housing would be sought on all sites of 11 or more dwellings (or 0.5 hectares or more). This approach is consistent with current Planning Practice Guidance and may well be enshrined in future changes to the NPPF. The effect of this policy approach on site viability could be minimised by allowing the amount/tenure balance of sites to be adjusted in appropriate circumstances. Therefore, this approach is considered to be a reasonable alternative.

Application of affordable housing percentage requirements on sites

6.76 The 2017 SHMA conclusion^[71] is that a total of 11,030 affordable houses need to be provided over the period 2015-2036. With the figures rolled forward to the end of March 2017, this total has fallen to 10,333 (697 were delivered in 2015/16 and 2016/17). This is 26.5% of the total planned housing need for Greater Norwich (see section 4 above). However, it is inevitable that not all sites will be able to deliver a policy-compliant level of affordable housing. Circumstances can change, and the GNLP, as with all local plans, will need to recognise this through a viability exemption.

6.77 The SHMA evidence is that the amount of affordable housing need varies significantly across the three districts, from 19.9% in South Norfolk, and 24.4% in Broadland to 38.3% in Norwich (these figures will be slightly different with the delivery in 2015/16 and 2016/17 taken into account). However, as the GNLP is a joint plan, with a proportion of Norwich's "overspill" housing being accommodated in Broadland and South Norfolk, applying these differential rates is not a reasonable policy approach to take.

6.78 Recognising that a reasonable policy approach in the GNLP is to plan for a higher amount of housing than the OAN (to reflect the ambitions of the City Deal), as explained in section 4 above, there are several alternative policy approaches.

6.79 Similar to current Greater Norwich policy^[72], it is proposed that a viability test be allowed for. This would allow for the proportion of affordable housing to be provided to be reduced or the balance of tenures^[73] to be adjusted where infrastructure or affordable housing costs would render a site unviable in current market conditions. It is also proposed that any applicant making a viability case to reduce the affordable housing requirements would need to do so using an open-book process. This means that the viability report could not, as a rule, be kept confidential.

Options

6.80 Seeking less than 27% affordable housing on all sites above the qualifying threshold is considered to be unreasonable. While this could increase the viability of most sites, it would risk under-delivery of the overall affordable housing target. It would also mean that a higher overall housing figure might be needed to get close to delivering 11,030 affordable houses, which could cause difficulties if excessive amounts of market housing would be needed to help deliver the required amount of affordable housing. Under-delivering affordable housing would also have negative social impacts in terms of alleviating over-crowded accommodation and "hidden families".

Option AH3 - Seek 27% affordable housing on all sites above the qualifying threshold This is the most straightforward application of the requirement for affordable housing in Greater Norwich, providing clarity and consistency between sites. Any possible impact on viability could be mitigated by allowing the amount/tenure balance of sites to be adjusted in appropriate circumstances, where evidence shows that the site would not be viable for the full amount of affordable housing. Experience would dictate that not all sites will be able to meet a 27% requirement on viability grounds. Therefore, setting a requirement at 27% could risk under-delivery of affordable housing. This could be mitigated by ensuring that there is an appropriate delivery buffer incorporated in the scale of housing allocation to ensure sufficient sites are available to deliver the overall affordable housing requirement. Therefore this approach is considered to be a reasonable alternative.

Option AH4 – Seek more than 27% affordable housing on all sites above the qualifying threshold The SHMA identifies an overall affordable housing requirement of 27%. Experience would dictate that not all allocated sites will be able to meet a 27% requirement on viability grounds. Therefore, requiring a higher affordable housing requirement would help to mitigate potential under-delivery on some sites. This approach could, however, make sites less attractive to develop, as they would not be as profitable, thereby reducing the incentive for a developer to build; this would consequently negatively impact on delivery. It would run a significant risk of developers challenging a higher figure as being excessive. Nonetheless this approach is considered to be a reasonable alternative, subject to clear demonstration that the higher requirement was viable.

Option AH5: Specify the affordable housing amount with the potential for phasing on certain larger sites (perhaps 100+), with a more general policy for smaller sites This approach would allow consideration of the viability and the specifics of certain sites (which may have significant infrastructure requirements impacting on viability), and might allow specific sites to be identified for Build-to-Rent and/or other tenures, as appropriate. This could also allow larger sites – particularly new settlements – to be treated flexibly, with lower amounts of affordable housing to be acceptable in early phases of development. Clearly, potentially allowing a lower amount of affordable housing would risk an overall under-delivery of affordable housing, but this risk might be limited by requiring clawback provisions to be part of planning permissions for all such sites. Subject to more detailed information and consideration, this is considered a reasonable alternative.

Tenure split for affordable housing

6.81 The evidence of the 2017 Central Norfolk SHMA is that the split between affordable/social rented dwellings and low-cost home ownership (LCHO) should be 79:21 (which would be sensibly rounded to 80:20 for simplicity on sites below 50 dwellings). Whilst it is recognised that the definition of "affordable housing" may perhaps be broadened in the next update to the NPPF to include other tenures, such as Starter Homes, it is believed that this would not justify a different split. As an example, were the changes to come about, Starter Homes, Discounted Market Sales Housing, and some forms of intermediate housing would all "count" as LCHO products.

6.82 The evidence from recent AMRs is that, broadly, the current split of 85:15^[74], is met, even if reduced levels of affordable housing are accepted as being justified on viability grounds.

6.83 The Government sees Build-to-Rent (the large-scale construction and management of blocks or groups of dwellings) as having potential to increase housing delivery, benefit from off-site construction techniques and tap into less traditional sources of housing finance such as pension funds. The economics of Build-to-Rent schemes are different to normal and there may be an argument to consider the merits of such potential sites differently.

Options

6.84 There is no evidence to apply a different affordable housing ratio to that established in the SHMA as doing so would risk insufficient affordable and social rented dwellings being provided. Consequently, this is an unreasonable approach.

Option AH6: Require all qualifying sites to provide the SHMA-evidenced ratio of rented and low-cost home ownership housing on all sites The most straightforward approach is to apply the rounded SHMA requirements of a 79:21 split (rounded to 80:20 for sites of 50 or below for simplicity) between rented and low-cost home ownership products across all qualifying sites. Compliance with such a policy would, in broad terms, ensure that the needs for different tenures are met. Therefore, this is the favoured option.

Rural Windfall, Exception Sites and Small Sites

6.85 Current Greater Norwich policy allows for housing on "exception" sites, either through allocations in Other Villages or above, or elsewhere on a windfall basis, where there is an identified local need. It does not mention cross-subsidy specifically, but says that such houses should be made available "in perpetuity", although the NPPF glossary on "Rural Exception Sites" says that small numbers of market homes may be allowed at the LA's discretion (to cross-subsidise the affordable housing), for example where there is no grant funding available for affordable housing. In some cases, funding from the Homes and Communities Agency (shortly to be re-named Homes England) may be available to support specific sites.

6.86 The HWP suggests that a broader mix of tenures will be classed as "affordable housing" in the future, including Starter Homes. It states^[75] that Starter Homes are intended, with local connection tests, to be acceptable on rural exception sites, although it is not made clear whether such a tenure mix could be 100% Starter Homes.

6.87 The HWP also states^[76] that local plans should have policies to support small "windfall" sites, including allowing an element of cross-subsidy. By "small" it is assumed that what is meant is 10 or below, so potentially below the affordable housing threshold. The worry is that this could mean that most of the historic sources of exception sites could potentially come forward for all-market schemes instead – so why would any landowners want to offer such sites at below market levels if this changes?

6.88 It also raises questions about the extent to which the GNLP should consider restricting, if at all, the total number of sites/dwellings which would be allowed under the "small sites windfall" policy that the HWP indicates will be necessary.

6.89 There is also a desire on the part of some to make some provision for Custom Build plots/sites in smaller settlements.

Options

6.90 Two reasonable alternatives are identified below:

Option AH7: Allow "small sites windfalls" to be permitted adjacent to development boundaries (i.e. sites of 10 or fewer to also include garden plots), subject to them meeting certain criteria (such as acceptable landscape impact, highways impact, access to services etc.) in all settlements with a development boundary. This could be an appropriate policy, making smaller sites more easily available for development, increasing flexibility and it would become difficult to resist if the NPPF is changed to encourage this. However, properly-planned growth in the GNLP will allocate an appropriate number of dwellings to defined settlements to meet the overall housing need. A policy allowing extra "windfall" sites could therefore potentially lead to more of such sites coming forward, with developers attracted by the fact that these sites might be below the affordable housing threshold. It could also make providing infrastructure more difficult and expensive to plan for and deliver (for example, water supply and treatment and providing school places). This option could therefore affect the plan-led approach in Greater Norwich. This is considered a reasonable alternative, albeit one with some drawbacks.

Option AH8: Don't allow any small-scale windfall sites for market housing, only for genuine "exception" sites (including an element of cross-subsidy, if necessary). On the basis that appropriate allocations will be made to enable villages to "thrive", as discussed in the HWP, such a policy could may also affect the plan-led approach. This option will be easier to justify if a more dispersed pattern of growth is chosen. This option is regarded at the current time as a reasonable alternative.

Housing mix – relative ratios of house sizes by bedrooms

6.91 The evidence from the 2017 SHMA ^[77] sets out the mix of dwelling sizes required separately for flats (1 and 2+ bedrooms) and houses (2, 3, 4, and 5+ bedrooms). It also has separate breakdowns for market housing and affordable housing. This reflects some of the recent tax and benefits changes, including changes to Local Housing Allowance (LHA) rates, and the Spare Room Subsidy. The table below includes the percentages:

Figure 6 Objectively Assessed Need Housing Mix (excluding the City Deal implications)

	Bedrooms	Market Housing (numbers and percentages)		Affordable Housing (numbers and percentages)		Total (numbers and percentages)
Flats	1	1,285	4.5%	2,725	24.7%	4,010	10.2%
	2+	1,352	4.8%	1,404	12.7%	2,756	7.0%
Houses	2	3,227	11.3%	2,863	26.0%	6,090	15.4%
	3	16,393	57.6%	3,238	29.4%	19,631	49.7%
	4	4,982	17.5%	661	6.0%	5,643	14.3%
	5+	1,215	4.3%	140	1.3%	1,355	3.4%
TOTAL		28,454	100%	11,031	100%	39,485	100%

6.92 There are some significant differences between the mixes for market and affordable housing. For instance, the percentage of flats required is only 9.3% of market dwellings, whereas it is 37.4% of affordable dwellings, and three-bedroom houses constitute 57.6% of market housing need, compared to only 29.4% of affordable housing need. Individual figures for the three Greater Norwich districts^[78] show considerable differences too. As might be expected, given its younger and generally less prosperous population, Norwich has a significantly greater proportional need for one- and two-bedroom properties than Broadland and South Norfolk, especially for affordable housing.

6.93 It is important to note that the figures above only relate to the OAN figure for Greater Norwich. Should it be decided that the GNLP will plan to accommodate more than OAN (see section 4), then it would introduce a little more flexibility in terms of housing mix (overall) – in other words, if certain sites could not deliver the SHMA-proposed mix of housing sizes, the overall market housing and affordable housing OAN targets (by numbers) might still be met or exceeded.

6.94 There will always need to be some flexibility in this policy area to enable specific proposals to be considered on their merits (i.e. constrained brownfield sites, or to avoid 1-bed flats/houses on small sites in areas where the grain of development is larger houses in spacious plots). The proposal below would be intended to apply to all sites, whether they be allocated or windfall.

6.95 All sites above the threshold would be expected to provide the housing mix in line with the most recent evidence. Currently this is figure 6 above, drawn from the 2017 SHMA, but this may change in future updates of the SHMA.

Options

6.96 Allowing different housing ratio mixes to apply for Broadland, Norwich and South Norfolk is unreasonable. The current evidence base shows that Norwich has a much higher need for 1-2 bedroomed properties, proportionately speaking, than the other two districts. However, requiring different figures to be applied for each district would run the risk of restricting much needed smaller dwellings in Norwich fringe locations like Thorpe St Andrew and Cringleford, which are likely to accommodate some of Norwich's unmet need. Two reasonable alternatives have been identified:

Option AH9: Specify a threshold above which the identified housing mix would apply. This would require smaller sites (perhaps 10-50 houses) delivering affordable housing to deliver a mix of smaller and larger dwellings. Sites below the threshold would not need to meet the mix. This would be appropriate if, for example, a rigid application of a mix would require a small brownfield site to provide a four-bedroom house as part of a mix when an all-flatted scheme would be more appropriate and sensible. This option is regarded at as a reasonable alternative.

Option AH10: Do not require the identified housing mix need to be required on all sites individually. JCS Policy 4 does not have a threshold, instead requiring housing proposals "to contribute to the mix of housing required to provide balanced communities and meet the needs of the area". Overall, it may be that schemes would naturally balance out – higher-density schemes would be expected to deliver more 1 and 2-bed dwellings, whereas more rural schemes might deliver more 3 and 4-bed dwellings. Larger schemes, particularly greenfield sites, tend to provide generally the right mix organically. Also, not requiring a mix explicitly would also allow some flexibility in relation to the ratios of flats and houses as the need/demand for flats is higher in some areas than others. This is considered a reasonable alternative.

Older people & care accommodation

6.97 There is a rapidly-ageing population nationally and locally, which has significant implications for planning and plan-making. All Norfolk's local authorities are working hard to try to reduce pressure on the social care and hospital budgets through a range of "early help" measures, and key amongst them is a desire to help keep people at home for as long as possible before moving into residential care accommodation. There is also increasing demand for specialist retirement-type accommodation, sometimes called "extra-care". This accommodation includes an element of care which helps people to "down-size" to more appropriate and desired accommodation more easily. The NPPF, and the HWP, make clear that planning for older people's housing needs is very important.

6.98 The 2017 SHMA says that, on a trend basis, about 1,900 extra "institutional" people are expected by 2036 across Greater Norwich, with the figure not counted as part of the OAN total. However, this does not necessarily mean that this requires an equivalent increase in residential institution bed-spaces, because specialist older people's accommodation may be more appropriate. If more housing with care or sheltered accommodation is provided, rather than care homes, then there will be a need for some additional figures to be added to OAN, and this is the position Norfolk County Council is promoting in the Promoting Independence strategy. The county council is doing further work on this issue and there should be some up-to-date figures available in the next few months.

Housing with Care, Extra-Care Housing and Retirement Housing

6.99 Four reasonable alternatives are detailed below:

Option AH11: Enable residential care accommodation uses[79] to be appropriate on any allocated housing sites, subject to a criteria-based policy Many housing sites are either existing commitments, or will be newly allocated in the GNLP. One approach could be to allow specialist residential care accommodation (use class C2) to be provided on allocated housing sites. This would enable such accommodation to be provided on a wide range of housing sites in a variety of locations. This approach would need to be practised alongside a criteria-based policy: residential care accommodation is normally best-placed where it is well-related to local services, particularly a GP surgery, public transport and shops. This is to enable staff, residents and visitors to have good access. However, it is recognised that there can be competition for many of these housing sites, and some retirement-type uses can sometimes be outbid by market housing developers due to higher build costs. This is considered a reasonable alternative.

Option AH12: Make specific allocations for residential care and retirement care[80] uses Some sites, such as those benefitting from good access to services including healthcare, public transport and shops, are particularly suitable for specifically allocating for residential and retirement care uses. This option is regarded at as a reasonable alternative.

Option AH13: Develop a criteria-based policy to enable new retirement/care accommodation to be accommodated on land outside settlement boundaries and/or on other types of land within settlement boundaries It can sometimes be difficult for developers and operators to find the right sites in the right locations for the these kind of uses – higher build costs can mean that market housebuilders can often outbid retirement/care developers for sites. A criteria-based policy could enable unallocated sites to come forward when a need has been demonstrated, but probably only in higher-order settlements. This could be extended to include under-used or unviable employment land, which will normally be within settlement boundaries. Several such schemes have been approved in Greater Norwich in the last few years. This option is regarded as a reasonable alternative.

Option AH14: Require an amount of C2 residential care and/or C3 extra-care or retirement uses to be accommodated on "qualifying" housing allocations in particular locations Given the difficulties that are sometimes experienced in securing land for retirement/care type accommodation, one option is to require part of larger allocations to be set aside for retirement and/or care accommodation. Whilst this might have some viability implications, it is clear that the need for these types of accommodation is increasing with the ageing population, potentially justifying such a proactive approach. This option is regarded as a reasonable alternative.

Caravans and houseboats needs

6.100 National planning policy for Gypsies & Travellers and Travelling Showpeople is set out in Planning Policy for Travellers Sites (PPfTS) which is an adjunct to the NPPF.

6.101 The NPPF^[81] and PPfTS require that the accommodation needs of Gypsies and Travellers are met through the local plan which needs to identify a supply of specific, deliverable sites to provide 5 years' worth of sites against locally set targets. Local pans are also required to identify a supply of specific, developable sites, or broad locations for years 6-10 and, where possible, for years 11-15.

6.102 A key change introduced in PPfTS alters the planning definition of Gypsies and Travellers to exclude those who have ceased travelling permanently. Only those who are "of nomadic habit of life", including those who are temporarily non-nomadic, are classified as Gypsies and Travellers for planning purposes.

6.103 Under the requirements of the Housing and Planning Act 2016, local authorities are now required to carry out assessments of those residing or resorting to caravans or houseboats. Consultants were commissioned to carry out this work.

6.104 The key findings of the 2017 Norfolk Caravan & Houseboat Accommodation Needs Assessment (ANA) are that:

• There is little need for houseboat moorings outside the Broads Authority area;
• There is limited need (as distinct from demand) for more park homes in Greater Norwich;
• There is need for more Gypsy & Traveller pitches across Greater Norwich; and
• There is need for some additional Travelling Showpeople pitches in Greater Norwich to address over-crowding on two current sites.

Current policy

6.105 Current Greater Norwich policy^[82] quantifies the need for new Gypsy and Traveller pitches to 2026, including new transit provision, based on figures in the former East of England Plan. However, these figures were updated by a Greater Norwich Gypsy and Traveller Needs Assessment in 2012 (which itself has now been superseded by the 2017 ANA), and so are of little relevance now. Policy 4 states that sites should normally not contain more than 10-12 pitches and should be in locations with good access to services, with some provision to be provided in association with large-scale strategic housing growth.

6.106 All three districts have existing criteria-based development management policies to assist in the determination of Gypsies & Travellers planning applications, including transit sites. However, in the light of changes to the national definition of Gypsies and Travellers for planning purposes in the PPfTS and the findings of the Caravans and Houseboats ANA, there may be a case for a new policy approach.

Current accommodation

6.107 Current accommodation for Gypsies and Travellers is a mixture of public sites in South Norfolk and Norwich, and private sites in South Norfolk and Broadland. There are two Travelling Showpeople yards in Norwich (one large) and a site in South Norfolk. There is also a transit site for Gypsies and Travellers at Costessey in South Norfolk.

Future accommodation needs

6.108 The position in relation to future accommodation for Gypsies and Traveller needs is complicated. There is a lack of clarity about whether the change to the definition of Gypsies and Travellers introduced through PPfTS applies to those who are nomadic for work-related reasons or to those who are nomadic for cultural reasons. Most existing case-law supports the first definition, which is the so-called "tighter" approach. The alternative or "looser" approach could also apply to those who travel mainly for cultural reasons, to attend festivals, social gatherings and so on. The ANA includes both sets of figures but emphasises that it is for the Greater Norwich authorities to decide which are more appropriate. The Greater Norwich authorities are of the view that the so-called "tighter" definition is the more appropriate one to use, in line with current practice, but it is recognised that as case-law and appeal decisions continue to evolve nationally, the situation might change.

6.109 The ANA does not make findings on an identified "split" of public site need against private site need, but the findings of the surveys show that most Gypsies and Travellers would prefer to live on a small family site, rather than as part of a larger site with other families. Some families and individuals can likely afford to buy and develop their own site if they can find a suitable and available site; some could afford to develop a site, but not to buy it (at least to begin with); and others are not likely to be able to afford to buy or develop a site, and so would need to live on a public site.

6.110 The findings of the ANA show that Gypsies and Travellers are not wedded to living in a specific Greater Norwich district; whilst, in many cases, wanting to stay fairly close to existing family members, they do not draw a distinction between the three districts. This is useful information, and bolsters the recommendation in the PPfTS^[83] that authorities prepare a joint local plan and "set targets on a cross-authority basis to provide more flexibility in identifying sites". The ANA therefore provides the need figures for the whole of Greater Norwich, not broken down into district-level figures.

6.111 The ANA concludes that whilst there is additional need for temporary stopping places, this does not necessarily need to be in the form of transit sites, but could be through "negotiated stopping places", where very limited facilities would be available for up to 28 days every year.

6.112 In relation to Travelling Showpeople, given the large vehicles and fairground equipment that needs to be stored and transported, the plots that are required are somewhat larger than a Gypsy and Traveller pitch. Frequent travelling also means that good access to the major road network is important.

6.113 The Caravans and Houseboats ANA has therefore identified the scale of the need for Gypsies and Travellers (under the "tighter" definition), Residential Caravan Dwellers, Houseboat Dwellers and Travelling Showpeople as:

Accommodation type/Period	2017-2022	2022-2027	2027-2032	2032-2036	Total
Gypsies and Travellers	-2	11	11	11	31
Travelling Show people	25	6	7	8	46
Residential Boat Dwellers	0	0	0	0	0
Residential Caravan Dwellers	91	5	5	5	106

Options

Houseboats

6.114 Making specific allocations of land for permanent and/or temporary houseboat moorings is considered to be unreasonable as there is no evidence of need in Greater Norwich, and no potential sites have been put forward through the Call for Sites.

6.115 The reasonable alternatives are:

Option HB1: Develop a criteria-based policy to allow for moorings for houseboats (temporary or permanent) to come forward in appropriate areas in Greater Norwich, subject to evidence of need There are virtually no permanent, permitted moorings for houseboats in Greater Norwich, with the Broads area having most, and the Accommodation Needs Assessment does not identify any needs over the period to 2036. However, the current local plans do not contain a houseboat policy to allow new applications to be assessed against. Developing a criteria-based policy is therefore considered a reasonable alternative.

Option HB2: Continue with the current approach of not having a policy to judge applications for moorings for houseboats against, relying instead on the NPPF and other development plan policies. As the number of applications for new houseboat moorings is likely to be very low, there may be a case for not having a policy covering this matter in the GNLP – it is not required for a Local Plan to have a policy to cover every possible planning scenario. This option is regarded at as a reasonable alternative.

Gypsies & Travellers

Options

6.116 Having only a criteria-based policy is not an appropriate option. It would reduce the level of certainty that the level of identified need would be provided, given the practical difficulties that there can sometimes be in finding acceptable sites for new Gypsy and Traveller pitches to be located on. It would also run contrary to the PPfTS^[84] which requires local planning authorities to set pitch targets for Gypsies and Travellers and plot targets for Travelling Showpeople which address the likely permanent and transit accommodation needs. PPfTS requires authorities to identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of sites against the target, as well as to identify a supply of specific, developable sites or broad locations for growth for years six to ten and, where possible, years 11-15.

Option GT1: Make specific allocations of land to deliver the quantified need for new Gypsy and Traveller accommodation pitches (as well as a criteria based policy) This would give the greatest certainty that the scale of required need would be planned for, especially in the first five years of the plan period. These allocations could be new sites and/or extensions to existing sites. This policy approach would need sit alongside a criteria-based policy to judge new windfall applications against, as required by Planning Policy for Traveller Sites. This is therefore considered the favoured option.

Option GT2: Require larger housing allocations (say 150+) to include a certain number of Gypsy & Traveller pitches to help meet the overall level of need This could help meet the overall level of need, and would help secure mixed communities and promote "peaceful and integrated co-existence between the site and the local community"[85]. This option is regarded at as a reasonable alternative.

Travelling Showpeople

6.117 Evidence from the Caravans and Houseboats ANA shows that the current site at Mousehold is over-crowded and that about an additional 46 plots are needed in Greater Norwich or North Norfolk, 25 of which are required from 2016-2021. They generally need to be well-located in relation to the major road network due to the regular use of HGV vehicles. Such plots also need to be fairly large, to allow the storage of both touring caravans and fairground equipment.

Option

6.118 Given the practical difficulties that there can be in finding appropriate sites for new Travelling Showpeople plots to be located on (no new sites have been provided since the JCS has been adopted, despite an identified need), it is necessary to allocate sites.

Option TS1: Make allocations to deliver some or all of the need for new Travelling Showpeople plots, along with a criteria based policy This gives the greatest certainty that the scale of required need would be planned for. Due to constraints at existing sites preventing extensions, these sites would need to be new sites. Such a policy approach would be best practised alongside a criteria-based policy to judge new windfall applications against. Allocating to meet the most or all of the identified level of need is therefore considered the favoured option.

Residential Caravans/Park Homes

6.119 The ANA concludes that there is a need/demand for about 106 dwellings in Greater Norwich to 2036, most of which is in the period 2017-2022. The two main sources of need/demand for this type of accommodation are firstly those who choose this accommodation for affordability reasons, and secondly those who choose it for "lifestyle" reasons. In addition, some who self-identify as a Gypsy or Traveller, but who do not travel at all for work reasons, likely form part of the need/demand in this category.

6.120 Some existing caravan parks could perhaps expand to meet need, and other sites new sites could also be considered.

Option

6.121 Having only a criteria-based policy would not be a reasonable approach to take, as it would not demonstrate how the Greater Norwich authorities would best meet the identified need/demand for this type of accommodation.

Option RC1: Make allocations to deliver at least part of the quantified need/demand for new Residential Caravans, along with a criteria based policy Such locations would generally be outside existing settlement boundaries, albeit they could be included within new/expanded settlement boundaries. As with Gypsies and Travellers, a criteria-based policy to assess potential new sites against would also need to be included Allocating to meet the most or all of the identified level of need is therefore considered the favoured option.

CLIMATE CHANGE

Context

6.122 Local plans, particularly those which deliver housing and jobs growth, must take account of their impacts on climate change. National policy^[86] requires that the net UK carbon account for six key greenhouse gases is reduced by 80% by 2050 and imposes a legal duty^[87] to include "Policies designed to secure that the development and use of land in the local planning authority area contribute to mitigation of, and adaption to, climate change".

6.123 Climate change is highlighted in the NPPF as "central to the economic, social and environmental dimensions of sustainable development"^[88], with LPAs told to "adopt proactive strategies to mitigate and adapt to climate change"^[89]. LPAs are also instructed to "plan for new development in locations and ways which reduce greenhouse gas emissions"^[90] and "take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape"^[91] . Energy issues are covered in paragraphs 6.179 to 6.187 below.

6.124 The JCS covers climate change in Policy 1: Addressing Climate Change and Protecting Environmental Assets, although the matter also finds expression in several other JCS policies. The two "parts" to climate change are addressed in Policy 1: mitigation (through locating and designing development to use resources efficiently and minimising greenhouse gas emissions) and adaptation (the location and design of new development to be adapted to a changing climate and more extreme weather).

6.125 Annual monitoring results show that carbon dioxide (CO₂) emissions per capita have generally decreased year-on-year across Greater Norwich since 2011/12. However, it is unclear whether, with a growing population, overall emissions have risen over the period.

6.126 The GNLP's draft environment objective is: To protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change and the communities objective is: To grow vibrant, healthy communities giving people a high quality of life in well-designed developments with good access to jobs, services and facilities. The overall vision is relevant to climate change too: To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment. It is also important to note that greenhouse gas emissions/climate change is one of the Sustainability Appraisal objectives and so reasonable alternatives for all policies will all be assessed against it.

Option

6.127 No alternative approaches to the favoured option have been identified.

CC1 Continue the current policy approach The favoured option is for the GNLP to include a policy to consider the impacts of climate change based on the current policy approach.

AIR QUALITY

Context

6.128 Successful planned growth needs to take account of its impacts on air quality. Air quality impacts on health and quality of life and the plan should take positive steps to address current air quality problems. This section discusses how the plan should tackle the issue.

6.129 The NPPF^[92] requires that planning policies should ensure that, taking into effect cumulative impacts and the presence of any Air Quality Management Areas (AQMAs), compliance with air quality values should be achieved. The inter-relationship between planning and air pollution is further detailed, with new development in AQMAs being required to be consistent with the local Air Quality Action Plan and the importance of assessing cumulative impacts of developments on air quality being particularly noted. ^[93]

6.130 There are limited references to air quality in the JCS, although poor air quality in Hoveton (just across the bridge from Wroxham, in North Norfolk district) is noted. An AQMA was designated in Hoveton and so development in Wroxham may impact air quality in Hoveton, and vice versa.

6.131 There has been at least one AQMA in Norwich since 2003. Four individual AQMAs were amalgamated into a single Central Norwich AQMA in 2012, covering the area within the Inner Ring Road. Norwich City Council published the most recent Air Quality Action Plan in 2015, and an Air Quality Annual Status Report was published in 2016. The action plan details measures to be taken to reduce nitrogen dioxide (NO₂) to below threshold levels, largely focussing on transport and travel measures. NATS has an important role in tackling these issues through implementation measures such as prioritising sustainable transport.

6.132 All three Greater Norwich authorities have existing development management policies covering air quality^[94], although the precise details and coverage vary. All three authorities also have development management policies requiring Transport Assessments and/or Travel Plans to be prepared and submitted alongside relevant applications, which must encourage sustainable modes of travel.

6.133 Air quality, particularly in Norwich, was noted as a concern by stakeholders at the Issues workshops, and it was felt that traffic reduction should be tackled. The need for better monitoring of air quality elsewhere in Greater Norwich was also raised as an issue.

6.134 In July 2017, in response to the requirements of the High Court, the Government published the UK Plan for Tackling Roadside Nitrogen Dioxide Concentrations. In it, 29 local authority areas are identified as having exceeded NO₂ target levels persistently, and so are required to take local action to resolve the issue within the shortest time possible. No particular measures are mandated, but they could include retro-fitting improved engines to local buses, support for cycling, changes to infrastructure and the introduction of vehicle charging zones. No Greater Norwich authorities are on the current list, but should NO­₂ emissions worsen in Norwich, or not improve sufficiently, it is conceivable that Norwich could be added to the list later. The Government also announced in July 2017 that the sale of new petrol- and diesel-fuelled cars would be banned in the UK by 2040.

6.135 The draft GNLP environment objective is: To protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change and the communities objective is: To grow vibrant, healthy communities giving people a high quality of life in well-designed developments with good access to jobs, services and facilities. The overall vision is relevant too: To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment.

How should air quality be covered in the GNLP?

6.136 The potential implications of development on air quality (and vice versa) will be considered through the development of the GNLP. Individual sites will be considered through the site assessment process, and relevant planning applications may need to demonstrate how they have assessed air pollution impact. Given the increased recognition of the dangers caused by poor air quality, the existing development management policies may need to be strengthened to enable air quality impacts to be assessed and mitigated.

6.137 There are links to other issues, and not just NATS. For example, improving the availability of high-speed broadband in rural areas could potentially facilitate greater home-working, and so reduce the need to travel by motorised vehicles. Two reasonable alternatives have been identified:

Options

Option AQ1 – Require planning applications which have the potential to impact on air quality to be accompanied by air pollution impact assessments and mitigation measures This approach could see policy criteria developed against which types of planning applications would be judged, and/or in which areas of Greater Norwich would need to be accompanied by air pollution impact assessments. The results of the assessments would need to influence the design and layout of the scheme, and would be expected to also influence other potential mitigation measures (such as open space provision, tree-planting, cycle-path provision, public transport provision, any electric vehicle charging points etc). There are potential benefits from having an over-arching air quality policy in the GNLP, to better ensure that cumulative and consequential impacts of developments can be considered on a similar basis throughout Greater Norwich. It would also clearly demonstrate that the requirements of the NPPF in relation to air quality are being considered. A further benefit is that this policy approach could evolve with the review of the NATS programme. This is considered to be a reasonable alternative.

Option AQ2 – Do not have a specific policy in the GNLP on air quality There is already existing policy coverage of air quality matters and related issues in the three districts' development management policies documents. Taken with the NPPF requirements in relation to air quality, specific policy coverage in the GNLP could represent unnecessary duplication. However, there is an existing AQMA in Norwich, and with the Government's increased focus on improving air quality nationwide, a new, up-to-date policy to detail how relevant applications will need to consider the issue of air quality may be needed. Although arguably a less positive approach than Option AQ1, this is also considered to be a reasonable alternative.

THE ENVIRONMENT

FLOODING

Context

6.138 Given the likely impact of climate change on increasing flood risk, it is important that the GNLP, like current planning policy for Greater Norwich, steers new development away from flood risk areas as far as possible. The plan must ensure that development mitigates against, and if necessary, is adapted to flood risk.

It is also important that statutory bodies and undertakers have full regard to flood risk and provide clear advice to the local planning authorities to enable them to assess planning applications.

6.139 To achieve this, the NPPF states that LPAs should take "full account" of flood risk^[95] and requires local plans to "take account of climate change over the longer term, including factors such as flood risk". ^[96] It also makes it clear how local plans should consider the assessment, and implications, of flood risk in seeking to steer development to areas with the lowest probability of flooding^[97], with the Planning Practice Guidance providing much more detail.

6.140 Current Greater Norwich flood risk policy^[98] emphasises that mitigation of any existing risk to be undertaken through good design and the use of sustainable drainage (SuDS) techniques. More detailed flood risk policies are in development management documents. Monitoring results over the years since 2011/12 show that no developments have been approved against the advice of the Environment Agency.

6.141 The main flood-related issue raised at the Issues workshops was the need to consider a whole-catchment approach to water management – such as flood storage in more upstream parts of river catchments.

6.142 A Stage 1 Strategic Flood Risk Assessment (SFRA) has been carried out for the Greater Norwich area, alongside the production of SFRAs for Great Yarmouth, North Norfolk and King's Lynn and West Norfolk Borough Council by the same consultancy, JBA. The SFRA has been prepared with the ongoing involvement of Norfolk County Council (as Lead Local Flood Authority) and the Environment Agency. It applies the latest climate change allowances to models of river (fluvial) flooding, taking into account existing information on tidal/coastal flooding, groundwater flooding and surface water flooding (amongst other types). The SFRA maps show that some fluvial flood areas have expanded (as would be expected, given that the most recent climate change allowances require higher levels of rainfall and river flow to be taken into account), but there are no major differences compared to the previous (2007) SFRA that was prepared to inform the JCS. Surface water flooding has been the main type of flooding in Greater Norwich in recent years, caused by intense rainfall overwhelming drainage infrastructure, and the 2017 SFRA details some of these events.

6.143 The main fluvial flood risks are along the main rivers (the Wensum, Yare, Waveney and their tributaries), although smaller, non-main rivers can also have areas of risk. Norwich is the area with most (about 11,000) properties at risk of flooding in a 1 in 100-year flood event, and the city was named an Indicative Flood Risk Area by the Environment Agency in July 2017. Surface water flooding is known to be an issue in various settlements, including parts of Norwich, Poringland/Framingham Earl, Harleston, Long Stratton, Acle and Aylsham.

6.144 The draft GNLP environment objective is: To protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change. The overall vision is relevant too: To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment.

How should flooding and flood risk be covered in the GNLP?

6.145 There is relatively little flexibility in how flood risk should be considered in preparing a local plan. In essence, development should be located away from areas of highest flood risk through the application of the Sequential Test^[99]. If, following consideration of the Sequential Test, it is felt that, consistent with wider sustainability objectives, it is not possible for development to be located in lower flood-risk areas, then the Exception Test can be applied^[100]. Parts of the centre of Norwich are most likely to fall into this category, but other areas of Greater Norwich, where there is brownfield land in town centres, could also do so.

6.146 All relevant planning applications^[101] must be accompanied by a site-specific Flood Risk Assessment. Mitigation of residual flood risk is important, as stated in the NPPF, and where possible, new developments should reduce flood risk overall. The use of SuDS techniques is strongly encouraged by the SFRA, and it also recommends that all relevant applications be accompanied by a Surface Water Drainage Strategy, to show how the design and drainage of a scheme will prevent properties from flooding from surface water. A key issue for the GNLP to consider is the extent to which a whole-catchment approach to flood risk should be practised.

Option

6.147 Some LPAs rely on requiring new development to follow the NPPF requirements only. However, as this approach would not meet the clear recommendations of our SFRA, especially to deal with surface water flooding risks, and would risk a lack of co-ordination between sites and a lack of clarity about the long-term maintenance regime for SuDS infrastructure, it is unreasonable. Based on national policy and local evidence, a favoured option has been identified:

Option FR1 – Require all relevant applications to undertake a site-specific Flood Risk Assessments and to provide a Surface Water Drainage Strategy showing how any SuDS infrastructure will be maintained in perpetuity This approach follows NPPF and Greater Norwich SFRA recommendations, requiring flood risk and drainage matters to be considered at the very earliest stages of a scheme's design. This is the favoured option.

NATURE CONSERVATION, GREEN INFRASTRUCTURE AND HABITATS REGULATION ASSESSMENT MITIGATION

Context

6.148 Greater Norwich's high quality natural environment is a significant factor in defining the area. Maintaining and enhancing these natural assets provides benefits for existing and new communities. It is important that the impacts of growth on the natural environment are mitigated both for environmental reasons and because the character of the area is key to the local economy, supporting successful growth.

6.149 Greater Norwich has a number of nature conservation sites that are protected under international legislation or agreements – Special Protection Areas (SPAs), Special Areas of Conservation (SACs) and Ramsar sites. In addition, the Norfolk and Suffolk Broads has a status equivalent to that of a National Park. Other sites are designated nationally, principally Sites of Special Scientific Interest (SSSIs), and a variety of habitats and species are protected under the 1981 Wildlife and Countryside Act.

6.150 Green infrastructure (GI) is defined in the NPPF Glossary as "a network of multi-functional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities". Section 11 of the NPPF is entitled Conserving and Enhancing the Natural Environment and details the main national policies on environmental protection, which include a range of requirements, such as planning for the creation, protection enhancement and management of green infrastructure and biodiversity^[102]. The NPPF also says that "Great weight" should be given to conserving the landscape and scenic beauty of the Broads^[103] and criteria-based policies should be developed which will distinguish between the hierarchy of designated sites^[104]. This is important to the GNLP as development and recreation and tourism pressure on the Broads is significant.

6.151 Current Greater Norwich policies^[105] cover the protection of nationally and internationally designated nature conservation sites, and promotes improvements to open spaces, green infrastructure and biodiversity. The proposed Green Infrastructure Network for Greater Norwich^[106] is a map showing the key existing and planned areas of protection and improvement. The three districts all have individual development management policies protecting lower-tier designated nature conservation sites.

6.152 The Habitat Regulations Assessment (HRA) for the JCS highlighted the particular pressures on the Broads, and various mitigation measures were identified as being required, including buffer zones and alternative destinations to help manage visitor pressure on the Broads and other nearby nature conservation sites. The need for mitigation measures was identified for the homes allocated in the NEGT in Broadland^[107] with greater detail considered in the now-adopted Growth Triangle Area Action Plan.

6.153 The AMRs show that a number of improvements to the GI network have been delivered, or are planned to be delivered, as new development has been permitted and delivered. The condition of designated nature conservation sites has generally improved since 2011/12 too, although it remains below target for SSSIs.

6.154 Attendees at the Issues workshops believed there to be a deficiency of green infrastructure in Greater Norwich, focussing particularly on the availability of accessible semi-natural green spaces, such as country parks. The problem of funding and maintenance of such spaces was recognised, but self-funding (through car-parking charges, on-site café etc.) was identified as an option. Improved links to GI outside Greater Norwich were also identified as being important.

6.155 Various pieces of evidence base work have been undertaken, or are still underway, in relation to nature conservation and GI. A Recreation Impacts Study – Visitor Surveys at European Protected Sites was carried out across Norfolk and published in 2017. The study concludes that, in Greater Norwich, tourism and pressure from a growing population of local residents will continue to increase, especially in the Broads. Further work will be likely to need to be done to investigate the capacity of specific sites to absorb visitor pressure. Working with the other Norfolk LAs to investigate cumulative impacts and potential mitigation measures will therefore be important.

6.156 A Green Infrastructure Mapping Project is also underway across the whole of Norfolk. When complete later in 2017 this should allow the expansion of the current Greater Norwich GI network, which is viewed as an exemplar project, into the rest of Norfolk and the adjoining counties.

6.157 The HRA for the GNLP, which must be prepared to accompany any local plan, is also underway. The HRA screening report identifies different types of impact and mitigation for SAC, SPA and Ramsar sites. Potential impacts on European-designated sites identified include:

• Increased urbanisation of the countryside leading to fly tipping, littering or predation by domestic animals;
• Increased ground water abstraction, leading to detrimental impacts on biodiversity through:
  • changing the balance of freshwater to saline water in coastal wetlands;
  • depleting river flows and increased potential for saline water incursion;
  • depleting river flows with the effect of reducing dilution of pollutants and nutrients;
  • reduced ground water inputs/irrigation of fen areas
• Chemical release or water recycling plant failure resulting in pollution from waste water discharges;
• Increased emissions from vehicular traffic;
• Disturbance and trampling from people and especially dog walkers where nutrient enrichment from dog excrement is also an issue.

6.158 The draft GNLP environment objective is: To protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change. The overall vision is relevant too: To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment.

How should nature conservation and Green Infrastructure be covered in the GNLP?

6.159 There are a large number of internationally designated nature conservation sites in the area both in the Broads and in Greater Norwich itself, such as the Wensum Valley. Legally, the GNLP will need to include a policy to ensure that new development does not have a negative impact on these designated sites. Without mitigation measures, some housing sites could probably not be allocated or permitted. Potential impacts on the designated nature conservation sites will depend partly on the growth distribution options and the housing sites chosen.

Options

6.160 Two possible approaches are suggested for protecting the designated sites:

Option NC1 – Require housing developments to provide additional green space on-site to address the impact of housing growth on designated nature conservation sites This approach could be particularly appropriate for new development near designated sites, especially near the Broads. Such developments are likely to attract regular visitors (especially dog-walkers) to designated sites, adding to pressure there. Larger developments could provide "Suitable Alternative Natural Green Space" (SANGS) on their sites; smaller developments would have to make payments to provide the SANGS elsewhere. This is a reasonable alternative.

Option NC2 – Require housing developers to make payments so that impacts on the designated nature conservation sites are addressed. Payments could be used to fund measures such as: relocating parking, improved signage, wardens, other management measures, directing visitors to less sensitive parts of the sites or other locations and reducing vehicular access to designated sites. This is also a reasonable alternative. Implementation will require agreement and work with other authorities and organisations, particularly the Broads Authority.

6.161 It will also be essential that the multi-functional GI network established in the JCS^[108], which is intended to provide a long term focus for investment, continues to be developed. Parts of this network have been added to or improved in recent years, in many cases with CIL funding. Greater Norwich's approach to developing the GI network is planned to be extended county-wide through the NSF.

LANDSCAPE

Context

6.162 The varied landscapes of Greater Norwich, as well as the unique landscape of the neighbouring Broads, are a major asset for the area. Therefore it is essential that new development is focussed in areas where it will minimise impacts on the landscape and respects its character, being designed to take account of and enhance landscape settings.

6.163 The NPPF states that valued landscapes should be protected and enhanced^[109], and LPAs are required to set criteria-based policies against which development proposals potentially affecting protected landscape areas^[110]. A "hierarchy" approach to policies should be practised, reflecting the distinctions between national and local landscape designations, with intrinsically dark landscapes protected from light pollution through effective planning policies^[111]. Where appropriate, landscape character assessments should be prepared, along with historic landscape character assessments^[112].

6.164 Various landscape character assessments have previously been undertaken to support local plan documents. There are no nationally-designated landscape areas in Greater Norwich, although the Broads Authority area has status equivalent to a National Park, and there is thus a statutory duty to "conserve and enhance the natural beauty, wildlife and cultural heritage of the area". Current Greater Norwich policy^[113] highlights that there are five distinct countryside character areas. Various areas are of particular historic and cultural significance, and there are sensitivities on the urban edges of Norwich and market towns. The Broads area is clearly of particular significance.

6.165 Current policy states the importance of maintaining important "Strategic Gaps"^[114] between Wymondham and Hethersett and between Hethersett and Cringleford. The precise geography of these gaps is set out in the South Norfolk Development Management Policies Document^[115]. JCS Policy 2 also emphasises the urban/rural transition and the treatment of key "gateways". South Norfolk policy^[116] defines four planning policy tools to protect the landscape setting of Norwich:

1) The Norwich Southern Bypass Landscape Protection Zone (NSBLPZ - much of the A47 corridor around the south of Norwich);

2) Key Views (long-distance views into Norwich from the south-west and south-east);

3) Undeveloped Approaches (various road and rail corridors with a distinctive rural character); and

4) Gateways (distinct landscape/townscape changes which mark the "arrival" into Norwich.) The Norwich Local Plan also identifies key gateways, both on the edge of the city council area, and on the edge of the city centre.

6.166 Finally, Rural River Valleys and Urban Valley Fringe landscape areas are identified as having special qualities^[117], with the Norwich policies recognising the significance of the Wensum and Yare valleys in landscape terms^[118].

6.167 Broadland policies^[119] focus on its Landscape Character Assessment SPD, and the protection of gaps between settlements, although these are not formally designated as Strategic Gaps.

6.168 The Broadland North East Growth Triangle AAP has a policy^[120] protecting an area either side of the NDR from inappropriate development. This is similar to the A47 southern by-pass protection zone in the South Norfolk Local Plan.

6.169 The AMRs show that landscape protection policies generally work well. Relatively few applications that might adversely affect key landscape designations tend to be made, because of the high chance of refusal, and those that are tend to have significant mitigation requirements. More generally, landscape character is an important consideration in a number of planning applications, and the layout and design of schemes need to take into account the effect of landscape character.

6.170 One major housing application within the Wymondham-Hethersett Strategic Gap was approved on appeal by the Secretary of State in 2016, comprising about 12 hectares of land (up to 300 dwellings), and two small applications in one of the Strategic Gaps were approved by South Norfolk Council.

6.171 At the Issues workshops key valley forms and geological/geomorphological landforms were felt to need appropriate protection, including some undesignated sites. Some attendees also asserted that a robust assessment of the need for, and extent of, any Strategic Gaps should be undertaken, particularly in locations where their existence might prevent the delivery of much needed housing.

6.172 The draft GNLP environment objective is: To protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change. The overall vision is relevant too: To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment.

How should landscape be covered in the GNLP?

6.173 Two main areas need to be covered: firstly, landscape character and specific landscape protection policies; and secondly, the need for, and location and extent of, any Strategic Gaps.

Landscape character and protection

6.174 The existing landscape character evidence base in Greater Norwich is up-to-date; whilst landscape character can alter over time due to changes caused by new development and differing land management practices, these changes tend to be slow and rarely alter the fundamental character of landscapes.

6.175 The slightly different approaches to landscape taken in South Norfolk, Norwich and Broadland could be continued, or a similar approach could to be taken to landscape protection in Broadland as exists in South Norfolk.

Options

Option LA1 – Retain the current South Norfolk Local Plan approach, extending the principles to those parts of Broadland closest to Norwich, including the route of the Norwich Northern Distributor Road. This approach recognises that maintaining the setting of Norwich in relation to its rural hinterland is important, with the considerable development pressures that exist in fringe areas. It does not mean that development would be inappropriate, but the sensitivity needs to be recognised. Similarly, some key landscape types – particularly the Broads, rural river valleys, and the Yare and Wensum valleys are of particular landscape sensitivity. Some more detailed landscape work would be necessary to identify locations for Key Views, Undeveloped Approaches and Gateways in the Broadland/Norwich transition zone. This is considered to be the favoured option.

Option LA2 – Retain the general current approach to landscape protection in the current three separate local plans This option recognises there are different policy frameworks dealing with landscape issues in the three districts in current local plans, and that this could be rolled together into the GNLP. This might not enable a more consistent approach to be taken in the GNLP, including a wider consideration of impacts on the Norwich/Broadland boundary, but it is considered to be a reasonable alternative.

Strategic Gaps

6.176 Strategic Gaps are not purely a type of landscape designation. They are generally used where there is separation between settlements, and that separation is an important in retaining the identity of separate settlements and, often, in the landscape character of the area.

6.177 The two current Strategic Gaps in Greater Norwich were designated after considerable debate and challenge in the adopted South Norfolk development management policies document. Broadland development management policy EN2 highlights the gaps between settlements as one of the landscape characteristics that must be taken into account when considering development proposals, but does not identify and designate any specific Strategic Gaps.

Option

6.178 No alternatives have been identified for this issue.

Option SG1 – Assess whether any new locations should be designated as Strategic Gaps. The two current Strategic Gaps were subject to rigorous debate in the production of the South Norfolk local plan, and are likely to remain a soundly based (notwithstanding that some residential permissions have been allowed in the two Gaps subsequently). The current South Norfolk policy (DM4.7) does not completely prohibit non-agricultural development in the Gap, but is criteria-based. A similar criteria-based policy would appear appropriate in the GNLP, alongside the consideration of the correct geography of the two current Gaps, and any other areas that might now be considered appropriate to be designated as new Strategic Gaps This is considered to be the favoured option.

ENERGY

Context

6.179 Local plans must demonstrate a positive strategy to promote the delivery of renewable and low carbon energy^[121]. There has been a significant growth in renewable energy production in Greater Norwich in recent years, largely from small and large-scale solar installations and wind energy, along with a more limited amount of biomass development. However, recent Government policy and legislation^[122] mean that local plan policies cannot require energy efficiency for dwellings in excess of Building Regulations requirements, and wind turbines can only be developed in areas specifically identified in Local or Neighbourhood Plans.

6.180 Current Greater Norwich policy^[123] requires developers to maximise the use of decentralised and renewable or low carbon energy (DRLCE) sources, with a 'Merton Rule' requirement for sites of 10+ dwellings or 1,000m² of non-residential development to provide 10% of the scheme's expected energy requirements from these and maximise opportunities for sustainable construction. Larger schemes (500+ dwellings or 50,000m² non-residential development) should maximise energy from DRLCE sources.

6.181 This has been monitored in the AMR by CO₂ emissions per capita, which have reduced, and by the capacity of renewable energy permitted, which has fluctuated, although permitted development rights mean there may be significant micro-generation installations which are not recorded.

6.182 There was considerable discussion of the energy issues at the Issues workshops. Some felt that there should be a push for more rooftop solar/photovoltaics as the recent development of battery technology could enable better and more effective storage of locally-generated renewable electricity.

6.183 Wind turbines were believed to sometimes be "imposed" on communities and consequently taking more local control and ownership should be considered, perhaps through Neighbourhood Plans. Others felt that wind power should only be considered offshore, instead of using valuable agricultural land.

6.184 Some felt that solar farms should only be allowed on agricultural land of grades 3-5 (i.e. not the highest quality grades 1-2). Others believed that it is unnecessary to have policies on energy use because Building Regulations deal with the issues.

How should energy be covered in the GNLP?

6.185 Some evidence suggests that the minimum development size appropriate for decentralised energy is approximately 500 dwellings, but in a densely developed location, decentralised energy can be provided for existing dwellings so the minimum development threshold could perhaps be lower. The "Merton Rule" requirement could potentially be increased but this could end up increasing costs overall, causing reductions in the spending on fabric of the buildings (i.e. for greater energy efficiency). One main issue identified is the limited previous consideration of local grid connections, particularly at strategic employment locations, and the need to consider this at an early stage in the planning process. The capacity of the grid and local grid connections are likely to take on increased importance and are a key Duty to Co-operate issue.

Options

6.186 There are two unreasonable approaches in this policy area. Not having a policy at all, merely relying on the national and DM policies already adopted by districts is considered to be unacceptable as this option would not conform to the NPPF^[124] requirement for a positive strategy to promote energy from renewable and low carbon sources and to maximise renewable and low carbon energy development.

6.187 A second unreasonable approach would be to require a higher minima of DRLCE sources than the current JCS – there is no current evidence that this is achievable.

Option EN1: Keep a "Merton" policy approach, but remove sustainable construction content to avoid conflict with recent Government policy changes. Also identify suitable locations for wind and/or solar power. This option would be a positive step towards helping to meet carbon reduction targets and would meet the requirements of the NPPF. This is considered to be the favoured option.

WATER

Context

6.188 Greater Norwich, like many parts of the south and east of England, experiences low levels of rainfall and is defined by the Environment Agency as an area of water stress. At the same time it has and neighbours internationally important water based environmentally protected sites. In addition, the Water Resources Management Plan 2014 emphasises the need for new development to be water efficient throughout the Anglian Water area, promoting water efficiency, enhanced metering and additional leakage control. The Inspectors at the JCS examination firmly supported a policy approach focussing on water quality and efficiency. It is therefore essential that growth in Greater Norwich addresses water efficiency and quality issues.

6.189 The NPPF^[125] states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of ………. water supply and demand considerations". A requirement for all housing development to have higher levels of water efficiency than the Building Regulations can be set if there is local evidence that it is needed and it will not affect viability.

6.190 A water policy, supported by an Advice Note to aid implementation, is included in the JCS and has been encouraged regionally for a number of years, previously through the Regional Spatial Strategy and more recently in the emerging Norfolk Strategic Framework. There needs to be a long term commitment to addressing water issues whilst promoting growth.

6.191 Water issues discussed at the Issues workshops included the role of the Building Regulations, capacity in waste water treatment networks (WWTW) and the use of reed-bed filtration techniques. Inclusion of a water policy in the GNLP would help to implement draft plan objectives to promote the timely delivery of infrastructure and to protect and enhance the natural environment, make best use of natural resources, mitigate against, and adapt to, climate change.

6.192 The current JCS policy requires sufficient infrastructure to be provided to meet the needs of additional growth, whilst at the same time generally promoting water efficiency, protection of water quality and protection of areas of environmental importance. It also mentions specific infrastructure upgrades, including strategic sewers and upgrades to Whitlingham and other WWTW.

6.193 Specifically in relation to water efficiency in new housing development, changes to the Building Regulations in 2015 removed the ability to continue to apply the adopted JCS policy requirement of 80 litres per person per day (lpppd). The standard Building Regulations requirement is 125 lpppd, but the 2015 changes continue to allow for a higher standard of 110 lpppd to be applied, if evidence supports it and it is viable.

6.194 Viability of development is not affected by water efficiency requirements. The cost per dwelling of implementing the higher Building Regulations water efficiency standard of 110 lpppd is only £10 and the emerging GNLP viability study has shown that such a low additional cost will have no impact on development viability.

6.195 The requirement for water efficiency applies equally to non-housing development, so it is appropriate to continue the JCS approach, supported by an updated Advice Note using BREEAM standards, of requiring non domestic development to be water efficient.

6.196 Taking the above into consideration, continuation of the current approach is suitable and no alternatives have been identified for water.

Option

Option W1: Require sufficient infrastructure to meet the needs of additional growth, whilst at the same time promoting water efficiency (using available standards), protection of water quality and areas of environmental importance. This is the favoured option.

COMMUNITIES

Context

6.197 The GNLP must provide the policy background to enable new communities to grow which have a range of services, good access, and enable people to lead active and healthy lifestyles. The NPPF^[126] has as a Core Principle that planning should: "Take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs. It says that local plans should "promote the retention and development of local services and community facilities in villages such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship"^[127]. It also requires that LPAs should "create sustainable, inclusive and mixed communities"^[128] and promotes healthy communities^[129].

6.198 Current Greater Norwich policy^[130] covers four main areas: health (including healthy living and care homes needs); crime (designing out crime); education (supporting tertiary education facilities, expansion to/new schools; and community infrastructure and cohesion (new community facilities, libraries and community integration).

6.199 The AMRs record a range of indicators for healthy and active living, including obesity, life expectancy and the accessibility to leisure and recreation facilities. There are no clear trends for these indicators in recent years, and recorded crime levels have also fluctuated somewhat. The AMR also records the level of education qualifications – broadly, these have all improved in recent years.

6.200 There was general support for the need for healthy communities to be developed at the Issues workshops. Some attendees believed that there is a deficit of GI across Greater Norwich, with accessibility of semi-natural green spaces for residents important.

6.201 The draft GNLP communities objective is to grow vibrant, healthy communities giving people a high quality of life in well-designed developments with good access to jobs, services and facilities.

Location of affordable housing within sites

6.202 The amount of affordable housing secured through Section 106 agreements on normal "market" housing sites is covered in the Housing Delivery section of the GNLP. The provision of affordable housing as part of sites above the affordable housing threshold is an important part of achieving mixed and balanced communities and the location of affordable housing within sites can be important, too.

6.203 Affordable housing on a mixed should be "tenure-blind" – in other words, it should be very difficult to tell the affordable housing from external appearance of the building. "Pepper-potting" of affordable houses is the generally preferred approach (i.e. mixing affordable houses with market houses), but it is recognised that for Registered Providers (companies managing affordable houses), there can sometimes be economies of scale in the locating small clusters of affordable houses together. An outcome to avoid is the location of all the affordable housing for a development to be located in one part of the site together.

Options

6.204 Not setting policy for the distribution of affordable housing across and within housing sites would be unreasonable. This is because it would run a significant risk of "affordable only" sections of development sites being created and would be contrary to the NPPF.

Option COM1: Affordable housing should usually be spread evenly across housing sites and should be tenure-blind in appearance. It is accepted that management scales of efficiency may sometimes militate in favour of small clusters of affordable dwellings rather than individual affordable dwellings. However, overall this approach is to avoid the danger of affordable housing (particularly social/affordable rented) being located away from the main body of 'market' housing, thus risking the creation of unmixed and unbalanced local communities. It would not apply to "exception" sites (which will be mostly or entirely affordable housing anyway. This is considered to be the favoured option.

Health Impact Assessments

6.205 Current policy^[131] requires that Health Impact Assessments (HIAs) are undertaken to support "large-scale" housing proposals, with the threshold specified at 500 dwellings in the accompanying advice note. HIAs assess the potential effects of a scheme on active lifestyles and the health of a population and identify the health care facilities required to support the development. This should help inform the design and layout to best allow for walking, cycling, open space and recreation and mitigate the impacts of vehicular traffic, especially in relation to air quality and noise.

Options

Option COM 2: Require that developers submit a Health Impact Assessment for sites of 500 dwellings plus The HIA would show how the layout and facilities of new communities would give people the best opportunities to live healthy and active lifestyles and identify the health care facilities required to support the development.Where larger sites are sub-divided, the overall size of the site would be used as the threshold, with an overarching masterplan and/or design code necessary covering the whole site              This is the favoured option.

Option COM 3: Do not require that developers prepare and submit a Health Impact Assessment for any scale of development. Instead, only the requirements of the NPPF and any relevant adopted Development Management policies would need to be taken into account. Voluntary HIAs would be welcomed, however, and there could be supporting text even without a policy This is a reasonable alternative.

Neighbourhood Planning

6.206 Neighbourhood Plans provide local communities with the power to develop a shared vision for their neighbourhood and shape the development and growth of their local area. They give local communities the ability to choose where they want new development to take place, to say what new buildings should look like and what infrastructure should be provided. They are prepared in consultation with the local community and be the subject of a local referendum before they are "made" (adopted). They should support the strategic needs set out in the local plan and plan positively to support local development. When made they become part of the development plan and are considered alongside the district local plan when planning applications are determined.

6.207 As of September 2017, a number of neighbourhood plans have been "made" (adopted) in Greater Norwich. For further information on these, see the Broadland webpage and the South Norfolk webpage.

6.208 A number of further parishes have been the subject of area designation and plans for these parishes are at various stages of preparation. Neighbourhood plans can be brought forward at any time and can be developed before or at the same time as the local planning authority is producing its local plan. It is for the local planning authority to work closely with neighbourhood planning groups to minimise any conflicts between policies in the neighbourhood plan and the emerging local plan.

6.209 There is an opportunity for local communities to bring forward sites for development in neighbourhood plans in parallel with the developing local plan process and accordance with the emerging level of growth agreed with the local planning authority and share evidence the evidence being prepared by the Local Planning Authority and vice versa. Where there is a "made" neighbourhood plan, the local community will also benefit from enhanced Community Infrastructure Levy contributions. The councils therefore encourage local communities to prepare neighbourhood plans, particularly where those communities are identified for growth. If there is any conflict between plans the decision maker must favour the policy which is contained in the last document to become part of the development plan.

6.210 An important part of the assessment of the "Basic Conditions" tests of a Neighbourhood Plan is that the policies of the Neighbourhood Plan are in "general conformity" with the strategic policies contained in the development plan for the area (i.e. the various local plan documents).

Option

Option NP1: Identify which polices in the GNLP are classed as "strategic" for Neighbourhood Planning. The strategic policies in the GNLP will be identified and set out in a table in supporting text. This is the favoured option.

CULTURE

Context

6.211 Culture comes into many aspects of planning. It is of particular significance in Greater Norwich, both due to the current breadth and depth of the cultural offer available and the potential for culture to play an increasing role as our communities grow. The NPPF states that planning should support strategies to improve …. cultural wellbeing for all, and deliver sufficient community and cultural facilities to meet local needs. Many of the uses that could be classified as 'cultural' facilities are also classified as Town Centre Uses in the NPPF, indicating that a significant element of cultural provision will relate to the strategy for the city and town centres.

6.212 Within the JCS culture is specifically contained within Policy 8 'Culture, Leisure & Entertainment'. This clearly places culture as part of the wider 'offer' the Greater Norwich area, with venues and events being seen as bringing economic benefits, related to both visitors and residents, both in terms of direct income generation and spin-off effects for the wider economy. Cultural assets which enhance the local economy include museums, galleries, theatres, sports venues and festivals; specific events and venues mentioned include Norwich City Football Club and the Royal Norfolk Show. The scope of JCS Policy also sets culture within the wider context of the history, architecture and landscape of the Greater Norwich, recognising the multitude of historic buildings such as Norwich Cathedral, Norwich Castle, Blickling Hall and Wymondham Abbey, and the distinctive landscapes of the area. Culture also performs a function in terms of building and maintaining community identity.

6.213 The three development management policies documents also contain a number of cultural elements.

6.214 Currently there is little evidence from the AMR on the extent to which the existing policy has been used directly, either to support other local plan documents or through the development management process. Whilst the role of culture is referred to in the Norwich and South Norfolk development management policy documents, it is principally in the context of main town centre uses. Currently there a no indicators in the AMR which effectively measure the effectiveness of the current policy.

6.215 The Issues workshops had no direct outputs related to culture, the workshop outputs identified a need to build on current employment strengths, and to emphasise the local lifestyle to attract inward investments. Cultural and creative industries are already strong in the Norwich area and the role of the breadth of cultural facilities is a key factor in the high quality of life in the area.

6.216 Because of the broad influence of culture in the wider sense, a number of the draft GNLP objectives include elements that are relevant:

• The economy objective makes specific reference to promoting the growth of a 'creative and broad based economy', which would undoubtedly include the creative and cultural sectors;
• The communities objective emphasises the need 'to grow vibrant, healthy communities', again this would indicate that protection of cultural assets and the provision of new facilities, in the broadest sense, will be a factor in the delivering this objective; and
• The environment objectiveincludes the protection and enhancement of the built and natural environment.

How should Culture be covered in the GNLP?

6.217 The main question in developing a Culture policy is the extent to which it needs to be set out as a standalone policy within the GNLP, rather than being an integral element of other policies. Because all of the GNLP policies are currently in their formative stages, the extent to which the elements related to culture will be covered remains uncertain. Three reasonable alternatives have been identified:

Options

Option CUL1: Broadly retain the current approach in existing JCS Policy 8 'Culture Leisure and Entertainment'. This policy would primarily act as a basis to make requirements: Future development management policies in terms of open space, design etc.; Site Specific elements of this plan or other documents, such as Neighbourhood Plans or Area Action Plans; For the protection of particular assets, such the Norfolk Showground. The potential consequence of continuing with the current policy approach is that there could continue to be some repetition in the GNLP. For example, the current approach includes: the provision of public art and the promotion of innovative design, which are/could also be covered in a design policy; built facilities for leisure, which are/could equally be included in a communities policy; and access to green spaces, country parks and the wider countryside, which are/could be included in an environment or GI policy. This is a reasonable alternative.

Option CUL2:Develop a simplified Culture policy focussing just on the protection, enhancement and provision of facilities. This policy alternative would focus on the protection, enhancement and provision of facilities specifically for culture i.e. theatres, cinemas, concert venues, galleries, museums and other venues/spaces which are used for cultural events. This option is likely to need consequent development management policies and/or supplementary planning documents to ensure any criteria for the protection of existing facilities are clearly set out, or for new facilities which might fall outside defined development boundaries of outside the defined city or town centres. This is a reasonable alternative.

Option CUL3: Do not have a specific policy on Culture. This would effectively incorporate all of the current JCS Policy 8 elements into other polices within the GNLP i.e. open space/leisure/community space and building provision within a 'communities' policy; access to the countryside through the GI element of an 'environment' policy; innovative design/public art within a 'design policy'; and protection of entertainment venues and support for creative industries within the 'economy' and/or 'retail centres' policy (for those cultural venues and facilities, such as markets, cinemas, galleries etc. which are classified as Town Centre uses in the NPPF). For this policy approach to be effective it would be necessary for culture to be a clear underlying theme throughout the plan, noting that it forms an essential element of many different aspects, including the economy, protection and enhancement of existing assets and leisure/recreation time. This is a reasonable alternative.

THE BROADS

Context

6.218 The Broads, which have a status equivalent to a National Park, border various parts of Greater Norwich, mostly along the main rivers of the Bure, Yare and Waveney. The Broads Authority has its own local plan and is the planning authority for most planning applications within its area. Due to the Broads importance, national policy and legislation recognises their special character and nature. The main functions of the Broads Authority and others in relation to the Broads^[132]are: conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads and promoting public opportunities to enjoy the special qualities of the Broads. This means that the GNLP is required to contribute to these functions.

6.219 Current Greater Norwich policy^[133] details how planning applications close to, but outside, the Broads area should take into account its special characteristics:

JCS 18 - The Broads

In areas of close proximity to the Broads Authority particular regard will be applied to maintaining and enhancing the economy , environment, tranquillity, setting, visual amenity, recreational value and navigational use of the Broads.

Opportunities will be taken to make better use of the benefits of the Broads, and to support its protection and enhancement while ensuring no detrimental impact on the Broadland SPA, Broadland Ramsar and Broads SAC.

6.220 A policy focussing on the Broads needs to be kept, with suggested modifications including:

• Provide greater clarity about the need for the Greater Norwich authorities to have due regard to National Park and Broads objectives^[134];
• Adding reference to the Broads area's purposes and protected status as well as its conservation designations;
• Add references to the protection of landscape character in the Broads;
• Provide greater clarity about how the Greater Norwich authorities should work closely together when considering planning proposals on the boundary with, or near to, the Broads; and
• Ensure that the policy requires proposals near to the Broads area have regard to the protection of the tranquillity and dark skies of the Broads.

6.221 It is important to note that any applications for areas outside the Broads, but which could potentially affect the Broads, would need to take into account the special character of the Broads, relevant Broads Local Plan policies and national policies and legislation, irrespective of whether there is a local plan policy covering this matter.

6.222 There was relatively little discussion of the Broads at the Issues workshops. However, the need for strong policies to recognise valued landscapes was highlighted, as was adequate provision of and maintenance of GI.

6.223 The most relevant objective is the environment objective to protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change.

Option

6.224 Given the equivalent National Park status of the Broads and the strong protection set out in legislation and national planning policy for the Broads area, a positive policy approach should be taken.

Option BR1: Have a specific policy covering development proposals close to the Broads, requiring the special characteristics and nature of the Broads area to be taken into account. The Broads area has long "borders" with the three Greater Norwich districts (particularly Broadland and South Norfolk), and settlements such as Acle, Brundall, Loddon and Wroxham are partly within the Broads. Consideration of the potential implications of planning applications on the Broads from land which is close to, but outside, the Broads area, is therefore important. This is the favoured option.