The employment growth target is stated as 33,000 jobs for the plan period. Paragraph 55 states that 29,100 jobs were delivered 2011-2018. The previous regulation 18 Growth Strategy consultation suggested a target of 45,000 jobs for the new plan period based on the East of England Forecast Model (EEFM) and City Deal (13,000 more than JCS target). The GVA Grimley Study 2017 suggested 44,000 jobs would be needed. There is no explanation in the draft document for the significant reduction other than it is based upon the EEFM. This should be explained and justified. Again, it would appear that the additional above target jobs growth agreed through the City Deal has not been included. The 33,000 figure seems unambitious in the context of the Vision set out for the Cambridge Norwich Tech Corridor and the number of jobs previously delivered in the 7 years to 2018.

Lanpro, therefore, consider that the employment growth target number should be more ambitious and would suggest that the previously specified 45,000 figure still remains appropriate. The number should be specified within Policy 1 which currently does not include any target figure.

Greater emphasis should also be included within the policy on supporting knowledge intensive employment growth in the Cambridge-Norwich Hi-Tech corridor in line with paragraph 108 of the Vision and Objectives for Greater Norwich.

The plan allocates employment sites totalling around 360 hectares including land on the strategic sites referred to above.

Notably, at paragraph 3.44 of the GVA 2017 report. It states:
“The Norwich urban area extends beyond the city centre, accommodating a diverse array of economic activity within its various business parks, industrial estates and specialist facilities. Often these sites make a distinct offer to businesses which, given the scale of each, is likely to direct the future nature of activity and development. As such infill, intensification and redevelopment of the existing estates will act as important locations for a range of activities, "however, may offer few options to diversify the existing portfolio".”

Norfolk County Council’s Employment Land Monitoring Report 2018-2019[1], states that whilst there may be in excess of 400 hectares of monitored employment land (‘monitored land’ is land without planning permission) there are only 48.4 hectares of employment land with outline planning permission across the County. Clearly, in itself, land with outline planning permission can be speculative in nature.

In summary, we submit, that the emerging GNLP will be reliant upon an employment land supply that is not flexible or diverse enough; that is not ambitious enough; is made up of key sites which either have infrastructure constraints to delivery, or have other environmental constraints to expansion; and as such the emerging GNLP plan will conflict with the NPPF and is unsound.