The proposed Settlement Hierarchy is, in principle, supported. It is recognised that The Norwich Urban Area and Main Towns, such as Wymondham, provide a range of services and amenities and are, therefore, the most sustainable and suitable locations for the majority of growth within the Greater Norwich Urban Area.
Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth in accordance with the identified settlement hierarchy.
Whilst the principle of identifying the Norwich urban area as the focus for most of the identified housing growth is supported, the ability of existing allocations / commitments, as well as certain new allocations, to deliver the scale of growth forecast is, without the provision of clear evidence demonstrating the delivery of certain sites in accordance with criteria contained within the NPPF, questioned. This is highlighted by the fact that the draft Local Plan states at various locations that there is uncertainty regarding the delivery of 1,200 dwellings at the Carrow Works site in Norwich.
With specific regard to existing allocations and commitments, the reliance on certain strategic sites is questioned. More specifically, North Rackheath has, in part, been allocated since 2010 and was initially earmarked for delivery in the 2010-2011 Annual Monitoring Report (AMR) during 2013/2014. Since this initial allocation, the scale of growth forecast for North Rackheath has been increased to 3,000 units (Reference GT:16). However, development is yet to start on site. The latest AMR (2018/19) now envisages that development will commence on site in 2022/23. This demonstrate a considerable delay in the delivery of the site and questions whether, in accordance with the draft GNLP Delivery Statement, it can be considered to represent a site where there is a reasonable prospect of delivery.
Similarly, the Beeston Park allocation, which is forecast to deliver 3,520 homes has, since its first inclusion in an AMR in 2013/14, been delayed by 4 years.
On this basis, there is considerable doubt as to whether there is clear evidence that large strategic sites that are identified as ‘existing deliverable commitments’ can be relied on. Similarly, there is, as acknowledged by the draft Local Plan and detailed above, doubt as to whether certain strategic allocations within the Norwich Urban Area, notably Carrow Works (1,200 units), can be delivered.
In addition, whilst the concept of village extensions is, in principle, supported, we would, based on the evidence provided to date, question the ability of a minimum of 1,200 dwellings to be delivered within South Norfolk Village Clusters.
As we understand, South Norfolk Council are preparing a South Norfolk Village Cluster Site Allocations Document. The need to prepare this document has arisen as a result of the previous Regulation 18 consultation stages into the draft Greater Norwich Local Plan not identifying the choice of sites in the village clusters that would address the requirements in those settlements. (See paragraph 2.1 of South Norfolk Village Clusters Allocations Document – Site Assessment Process and Draft Timetable, Agenda Item 5, Regulation & Planning Policy Committee, 18th February 2020.)
The scale of development focused in the village clusters will range from 12 units up to 1 hectare i.e. 20-25 homes. Based on the 48 village clusters identified in Appendix 1 of the above referenced document, it will mean that each cluster has to accommodate the maximum number of units i.e 25, if the minimum of 1,200 units within South Norfolk village clusters is to be provided.
Given that the identified village clusters are, partly due to their rural location, likely to present a range of issues relating to constraints i.e. utilities, flood risk, suitable access, and impact i.e. landscape and biodiversity, it is difficult, particularly without the provision of clear evidence, to see how the scale of growth directed to the South Norfolk village clusters can be justified. In addition, given the scale of the developments in the villages clusters i.e. a maximum of 25 units, they will not be of a sufficient scale to ensure the provision of social and community infrastructure.
On this basis, we suggest that the quantum of growth directed to both the Norwich urban area and the village clusters in South Norfolk cannot, without the provision of clear evidence relating to delivery, be relied on. Accordingly, a suitable proportion of this housing growth should be reallocated to alternative settlements within the settlement hierarchy, which are capable of demonstrating that they can deliver housing growth; specifically the allocation of sites that would otherwise classed as contingency sites.