Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22263

Received: 16/03/2020

Respondent: Barton Willmore

Representation Summary:

Q1 & Q2) Please comment on or highlight any inaccuracies within the
introduction & Is the overall purpose of the Plan Clear?
2.3 Recognition of the role of the A11, and Cambridge Norwich Tech Corridor is welcomed, but
this needs to be reflected better in the wider growth strategy. The chapter also highlights
some positive things about the sustainability agenda – and the impacts of this – notably the
potential ban on gas boilers, phasing out of diesel cars etc. However, this places even more
emphasis on the need for growth to be in sustainable locations that have their immediate
needs served from a local community perspective. There is a danger that those less affluent
in society are impacted harder – due to cost associated with electric vehicles and
decarbonising, and this places an even greater need for development to be planned in
settlements of sufficient critical size to support a wider range of local services, and in a
comprehensive manner to serve the needs of the local population and minimise the need to
travel for smaller journeys – i.e. trips to a local convenience store, to drop children at primary
school, or to have access to an area of parkland/open space.
2.4 Accordingly, we do not support the Authorities’ proposal to ‘reserve’ the allocation of 1,200
homes to Villages as part of a separate Plan document. This approach pre-judges that is the
right number of homes to be allocated, before a full assessment of where housing could most
sustainably be accommodated. Some villages may have sufficient services to support small
scale growth, particularly where they are located within the wider A11 and Tech Corridors,
or served by public transport, but directing additional homes to Villages (many of which have
limited to zero services) on a very small scale as advocated – i.e. maximum 1 hectare in size
but accommodating between 15 and 25 units – as advocated in the Village clusters plan and
referenced in paragraphs 25 and 26, risks being totally at odds with the principles of
sustainable development.Q1 & Q2) Please comment on or highlight any inaccuracies within the
introduction & Is the overall purpose of the Plan Clear?
2.3 Recognition of the role of the A11, and Cambridge Norwich Tech Corridor is welcomed, but
this needs to be reflected better in the wider growth strategy. The chapter also highlights
some positive things about the sustainability agenda – and the impacts of this – notably the
potential ban on gas boilers, phasing out of diesel cars etc. However, this places even more
emphasis on the need for growth to be in sustainable locations that have their immediate
needs served from a local community perspective. There is a danger that those less affluent
in society are impacted harder – due to cost associated with electric vehicles and
decarbonising, and this places an even greater need for development to be planned in
settlements of sufficient critical size to support a wider range of local services, and in a
comprehensive manner to serve the needs of the local population and minimise the need to
travel for smaller journeys – i.e. trips to a local convenience store, to drop children at primary
school, or to have access to an area of parkland/open space.
2.4 Accordingly, we do not support the Authorities’ proposal to ‘reserve’ the allocation of 1,200
homes to Villages as part of a separate Plan document. This approach pre-judges that is the
right number of homes to be allocated, before a full assessment of where housing could most
sustainably be accommodated. Some villages may have sufficient services to support small
scale growth, particularly where they are located within the wider A11 and Tech Corridors,
or served by public transport, but directing additional homes to Villages (many of which have
limited to zero services) on a very small scale as advocated – i.e. maximum 1 hectare in size
but accommodating between 15 and 25 units – as advocated in the Village clusters plan and
referenced in paragraphs 25 and 26, risks being totally at odds with the principles of
sustainable development.2.5 Some villages and smaller settlements may be appropriate for growth, but to provide
additional homes in the manner suggested, would mean between 50 and 80 separate
allocations. This would mean development was never of a critical mass enough to support
existing or new facilities. This will mean such development is almost wholly reliant on the
private car, and totally at odds with the principle of sustainable development. As such the
allocations of all sites should be brought into the one plan increasing the overall amount of
housing to be delivered in this plan by 1,200 and directing growth to settlements that have
the services, and transport connections to support growth.
2.6 Furthermore, the idea of simply ‘rolling forward’ existing allocations suggests that the
Authorities have not undertaken an assessment of whether they are currently delivering
growth. The role of a new Plan is to assess the most sustainable means of achieving the
needs of the Authorities to 2038 and directing it in a means that is sustainable and
‘deliverable’. As we shall detail in later sections of these representations, there are existing
allocations that are clearly not ‘delivering’ as highlighted in the significant housing shortfall
that has occurred against planned growth in previous Joint Plan. The shortfall of housing has
made the affordability of housing even less within the reach of the population. This is
highlighted in the SHMA and on page 16 of the Strategy highlighting the salary multiple in
South Norfolk has risen to 8.8 x average salary. This is worse than the national average,
where the UK has declared a housing crisis, and it is essential that this plan identified the
most sustainable strategy for achieving the growth that is required, rather than simply relying
on, and rolling forward previous allocations.

Full text:

Full representations (with appendices) submitted in response to the current Regulation 18 consultation of the Greater Norwich Local Plan on behalf of Landstock Estates Ltd and Landowners Group Ltd.