Glavenhill Ltd do not support the proposed settlement hierarchy as currently proposed. Although we offer support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, without first understanding where these sites are to be located and whether they are in fact sustainable, we cannot support the significant emphasis that is placed upon rural village clusters (outside of the old NPA). As currently drafted, the plan potentially allows a significant number of new homes (1200, 15% of all new allocations) to be located in small settlements in the rural area of South Norfolk. Other small sites are identified within the rural parts of Broadland. We do not consider this approach to be sustainable or compatible with the objectives in relation to tackling climate change.

The draft plan indicates that more homes (new allocations and commitments) are proposed in the cluster villages (9%) than in the key service villages (8%), yet cluster villages represent the bottom tier of the settlement hierarchy. As the bottom tier, they should have a correspondingly lower amount of growth in the hierarchy, otherwise this is not a sensible hierarchical approach to growth.

We consider that a more sustainable approach, that would be more in line with the overall objectives and vision set out for the Growth Strategy would be to clearly direct 400 of the South Norfolk 1200 to cluster villages and key service centres within the old NPA parts of South Norfolk and 500 as the first phase of a new settlement at Hethel in the Cambridge – Norwich Tech corridor. There is scope for a limited amount of more rural dispersal to contribute to the vitality of small rural villages and therefore, the remaining 300 should only be allocated to small cluster villages in the more rural parts of South Norfolk (outside the old NPA) where there is walkable access to a primary school and good public transport links to other key services. Any Broadland allocations outside of the old NPA should also only remain if the same applies.

Allocating 500 of the homes to a new settlement at Hethel would also provide land to expand the opportunity for hi-tech engineering jobs within the growth corridor. In this location the homes would help to ensure that the plan “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” (paragraph 108).

They will also:
“strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” (Delivery Statement page 36).

The current strategy of significant dispersal to small rural village clusters will make no positive contribution to these key threads of the plan. It will have negative impacts in terms of increasing the number of private car and other journeys and it will place greater demand on small local schools and services. These demands are more difficult and costly to address within a spread of small rural villages rather than within a new settlement where social infrastructure can be properly planned and funded from the outset with corresponding economies of scale.

As currently proposed, the settlement hierarchy presents an unambitious variation on the previous Joint Core Strategy (JCS) with an unjustified increase in rural dispersal. The draft plan states that 82% of the new housing requirement to 2038 is made up of existing JCS allocations that have been carried forward (paragraph 156). This means that including the proposed uplift on existing allocations, 36,503 homes out of a total housing figure of 44,343 are carried forward.

Of the 7840 new housing allocations included in the draft plan, 4395 are to be located within Norwich and its fringe parishes. This is supported because these are clearly sustainable locations within Greater Norwich with good access to jobs and higher order services. However, despite the plan’s emphasis in its Vision (page 31) and Delivery Statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes (new allocations) are proposed within the corridor itself, at Wymondham. By contrast, 400 are proposed in Diss which is neither within the Strategic Growth Area, the Cambridge Norwich Tech corridor, or close enough to Norwich to benefit from higher order services.

It is recognised that towns like Diss and Aylsham should accommodate some additional housing growth and do offer their own job opportunities and service provision. However, this should not take precedence over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Strategic Growth Area and Cambridge Norwich Tech corridor. Therefore, it is proposed that numbers in Diss should be halved to 200 and numbers in Harleston, which is also well outside of the Tech corridor and Strategic Growth Area, should be reduced to 150. The displaced 500 homes should be relocated within the Tech Corridor/ Strategic Growth Area. Some of these should be placed in a new settlement at Hethel.

Overall, Glavenhill Ltd’s conclusion is that the plan is saying the right things about future ambitions for Greater Norwich and the Tech corridor, but doing another, by virtue of directing too much growth to the rural areas outside of both the Tech corridor and the newly identified Strategic Growth Area. This needs to be addressed by ensuring that 900 of the 1200 homes proposed for village clusters in South Norfolk are redirected to villages within the old NPA area (400) with 500 to a new settlement at Hethel to support the Cambridge Norwich Tech corridor. The remaining 300 allocations in the rural parts of South Norfolk should only be in cluster villages where there is good walking access to a primary school and good public transport links to other key services. The same approach should be taken in Broadland. In addition, 500 homes should be redistributed from Diss and Harleston into the Tech corridor at Hethel and/or Strategic Growth Area. A new Garden Village settlement at Hethel could deliver up to 2000 homes within the plan period to 2038 with more beyond.