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 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.

As a result, we would like to put forward a new site of approximately 0.5 hectares shown on the attached site plan for consideration as an allocation for new small-scale housing development for up to eight dwellings. A Greater Norwich Call for Sites form and location plan is attached.

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 has been in the same family since 1981. Until 2005, the site was overgrown with trees and brambles. In 2005, the land was cleared and a fence erected. It is unknown how or why the northern part of the site (shown in green on the attached plan), was shown as protected recreation/amenity land on the current local plan Policies Maps. To the landowner’s knowledge, the site has never been open for public access, nor has it ever been used for recreation or amenity purposes.

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 is not open for recreation or amenity use and the landowners has no plans to allow the public to use it for such purposes. The public has access to much more substantial recreation and amenity facilities very close by at Kett’s Park Community & Recreation Centre, which is only 230 metres to the south, or Ashleigh Primary School only 230 metres to the north. The continued protection of this site for recreation or amenity purposes provides no benefit to or the wider public or the landowners.

When coupled with the remainder of the landowners’ landholding, the site could provide much-needed housing in an extremely sustainable location in one of the Council’s major growth areas.

Therefore, the landowners respectfully request that the recreation/amenity land designation on this site is reconsidered and that the new local plan considers allocating the site for residential development.