We write in response to your latest consultation (Regulation 18) on the Greater Norwich Local Plan. We note that the Partnership has decided not to allocate any sites smaller than 0.5ha, including Site GNLP2151, and understand that these small sites will only be considered now as extensions to the development boundary, rather than as site allocations.

However, we do not feel that this method reflects Paragraph 68 of the NPPF, which seeks to allocate at least 10% of the housing requirements on small and medium sites under one hectare. Rather, it ensures that only medium and large sites between 0.5+ ha are allocated.

The draft plan only allocates sites for 12 or more dwellings with a minimum target density of 25 dwellings per hectare and at least 0.5ha. This will ensure that allocated sites will only deliver major development. It also limits the overall mix of sites, meaning that small sites are likely to only be considered acceptable if immediately adjacent to the existing adopted development boundary, whereas medium and large sites could potentially be allocated some distance apart from the development boundary.

Taken together, this proposed method would inadvertently ensure that all small sites and minor residential developments are excluded from the allocation process entirely, despite the fact that it is well known that smaller sites both support smaller builders and are built out more quickly, having a large impact on ensuring a consistent and adequate housing supply is maintained.

We feel this method is not in line with the spirit and intention of Paragraph 68 of the NPPF and seek for the GNDP to reconsider its position on small sites and consider providing them with allocation status.

With regard to Site GNLP2151 specifically, we draw your attention to the fact that this site is brownfield land and although set apart from the current Reedham development boundaries, it provides quick and easy sustainable access to the village’s services and facilities.

The larger sites submissions (GNLP1001 and GNLP 3003) both propose estate scale housing of 20-30 dwellings. Reedham is a quiet village near the Broads National Park and this type of large-scale housing development is inappropriate to the character and appearance of the village. Instead, the GNDP should consider allocating small sites, such as site GNLP2151 and GNLP2175, to ensure that more modest development that is able to retain the village character is delivered.