Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21783

Received: 16/03/2020

Respondent: Brown & Co

Representation Summary:

We would raise concerns regarding the manner in which existing housing commitments and proposed new allocations have been counted towards the housing figures. It is considered that there is significant risk of double counting, particularly where some developments which are already being delivered are being proposed as new allocations. There appears to be no consistency between the circumstances as to whether sites are counted as delivered, existing commitments, or new allocations.

Full text:

We would raise concerns regarding the manner in which existing housing commitments and proposed new allocations have been counted towards the housing figures. It is considered that there is significant risk of double counting, particularly where some developments which are already being delivered are being proposed as new allocations. There appears to be no consistency between the circumstances as to whether sites are counted as delivered, existing commitments, or new allocations. Some settlement booklets refer to no allocations being carried forward, whilst the corresponding table within the Strategy document or Area Action Plan indicates that there are existing commitments to be carried forward.
We would raise concern regarding the deliverability of a significant proportion of housing by virtue of previous non-delivery, significant infrastructure restraints, and viability. Furthermore, we would raise concern regarding the ability to deliver a significant proportion of housing within the Plan period, and in particular in a timescale which means they can be relied upon to maintain a valid five-year housing land supply.
We object to the proposed strategy for growth as it is considered incompatible with the overall purpose of the plan, in particular the delivery of sustainable development which meets the challenges of climate change, and supports ambitious local and national targets for carbon neutrality. Additionally, it is not considered that the proposed distribution of growth is suitably forward thinking to facilitate the transition to a post-carbon economy, and the emergence of the region as the UK leader in clean growth.
The proposed new settlement Honingham Thorpe provides the opportunity to deliver growth differently, with purpose built infrastructure from day one and energy efficient and climate smart technologies built into the fabric of the community, to deliver a community with zero-carbon principles.