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 0.5 ha, including Site GNLP3026, 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 GNLP3026 specifically, we draw your attention to the fact that this site already lies entirely within the adopted Wymondham development boundary. As a result, the main issue the landowners are trying to rectify through the site allocations process is the removal of the site from the Policies Map as protected recreation/amenity land.

The site is narrow and previously formed part of the school playing fields until Norfolk County Council sold it off in 2018. It is now in private ownership and has no public access. The loss of this narrow strip of land from the wider recreation/amenity land designation will make little material difference to the area, given that it remains adjacent to a large amount of recreation space at the school for which the public has access. As a result, it could provide much-needed housing in an extremely sustainable location in one of the Council’s major growth areas.

Furthermore, the landowners would like to raise the point that there is little purpose retaining the recreation/amenity land designation in the new local plan on this site. It is clear that both the school itself and Norfolk County Council have undertaken an assessment which has clearly shown that the land is surplus to requirements; otherwise, it would not have been sold. As a result, this site is now redundant and is unlikely to ever revert back to recreation or amenity use.

The landowners, therefore, respectfully request that the recreation/amenity land designation on this site is reconsidered and that the new local plan allows for the site to be used for residential development.