The overall purpose of the plan is generally set out clearly within the introduction. However, Lanpro make the following observations and suggestions:

a) It would be useful if the base date of the plan was set out in the introduction as well as the end date of 2038 to save hunting for this in the document.

b) The commitment in paragraph 5 to “build on our strengths” and particularly “to help turn our world class knowledge and ideas into world class jobs, particularly in sciences and biotechnology, agri tech, food and drink, information and communication technology (ICT), digital creative industries and high-value engineering” is supported.

Our concern is whether this commitment will be achieved through the preferred growth strategy and particularly whether the allocations for housing and employment are adequate and in the right place to achieve this goal. We will expand upon this point later in our representations.

c) Paragraph 9 rightly recognises that upcoming bans on fossil fuels in homes and cars will become major factors affecting development through the plan period, particularly in relation to energy policy and transportation. Our concern is whether this is a clear reflection of what the preferred growth strategy will actually help achieve, particularly with regard to transportation. We will expand upon this point later in our representations.

d) Paragraph 12 identifies important strategies and initiatives including the LEP’s Norfolk and Suffolk Economic Strategy (2017) and the Cambridge-Norwich Tech Corridor initiative (2018) both of which have been signed up to by the Greater Norwich local authorities. Lanpro suggest that greater clarity is needed on how the plan knits together with and supports these strategies in a meaningful way.

e) Paragraph 13 refers to the Greater Norwich City Deal Growth requirements agreed with Government in 2013 being met through the Greater Norwich Local Plan. The introduction should explain what the City Deal requirements are in terms of numbers, otherwise the reference is meaningless to readers, particularly the general public. Either in the introduction or elsewhere in the document should be an explanation of how these numbers have been accounted for in the overall housing requirement. This is currently unclear within the document.

f) An approach as set out at paragraph 22, that looks beyond the end date of the plan by setting a strategy that can be sustainably added to in the long term is important and is supported in principle.

g) Paragraph 24 explains that new allocations on small sites in South Norfolk villages are not included in the document. Paragraph 25 states:

“In South Norfolk there are more villages clustered around more primary schools. South Norfolk, therefore, intend to prepare a separate village clusters plan covering new sites for small scale housing in the rural parishes that collectively form primary school clusters.”

This statement does not provide clear reasoning for the omission of these sites from the draft plan at this stage. Firstly, it does not explain “more villages” in comparison to where, or what. It also doesn’t justify why even if there is more primary school clustering in South Norfolk than presumably Norwich or Broadland, this should be the deciding factor in determining the growth strategy for South Norfolk. The Cambridge-Norwich Tech corridor runs through South Norfolk District and paragraph 5 of the introduction puts the focus on planning to and building on our strengths, particularly referencing the Cambridge-Norwich Tech Corridor and its high value jobs. It would, therefore, make much more sense if this was a main consideration in the choice of locations for housing within South Norfolk.

A clear justification is needed if a strategy of significant dispersal (as proposed at present) to small sites in the rural area and towns like Diss and Harleston is to provide the focus in South Norfolk, otherwise it is difficult to understand how this can be a sound approach. It places doubt upon the intent in paragraph 5 to build upon the strengths identified therein and also upon the delivery of the Vision for Greater Norwich in 2038 set out in paragraph 108. This states:

“by promoting this Greater Norwich Local Plan our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech corridor.”

An explanation should be provided as to how the number of 1200 homes (15% of new allocations) can be relied upon on small sites in South Norfolk when the sites have not yet been identified or assessed.

We consider that it is premature to ask stakeholders to comment on the acceptability of an overall growth strategy for the next 20 years, when 15% of the new allocations are missing. We appreciate the intent to get on with producing the plan, but these sites form a fundamental part of the overall strategy and without identification of these, the strategy is clearly not sound.