Comment

Representation ID: 22272

Received: 16/03/2020

Respondent: Barton Willmore

Q6, Q7 & Q8 – Vision & Objectives for Greater Norwich
2.12 The vision is broadly supported, but the means of achieving it and how growth is distributed
is not supported by our client. For reasons set out in responses to latter questions, the
number of homes to be delivered should be increased, to improve affordability, particularly
in context of shortfalls to date. To reduce emissions and enhance green infrastructure,
development needs to be planned for in a means that minimises the number of trips
undertaken. People will always need to travel for work, and for various other purposes, and
it is important therefore to locate growth in areas where public transport is accessible.
However, it is also essential to minimise the number of small trips – i.e. to a convenience
store; to a local school etc. particularly for those less affluent who may not be able to afford
electric and hybrid vehicles in the short-medium term. The plans for NE Wymondham
presented will provide immediate day to day convenience needs and a primary School serving
in excess of circa. 1,000 homes within walking distances of the Site, alongside access to bus
stops within walking distances with services into Norwich and the train station, as well as
dedicated cycle access to Norwich.
2.13 Paragraph 114 of the Strategy advises that jobs growth will be delivered on strategic sites in
and around Norwich, with good access to the public transport and the major road network.
However, the Cambridge – Norwich tech corridor represents the most sustainable option to
achieve such growth, but equally it is essential that new homes are made available in the
same corridor to cater for those that may be employed by the new jobs. Strong cycle links
into the City Centre are also essential, and this highlights the need to focus development in
locations where public transport, major roads and cycle access is readily available.
Wymondham is one such location within the Tech Corridor. The Authorities’ desire to locate
up to 1,200 homes in villages – based on allocations that would support no more than 25
homes, would in most instances mean that none of these three criteria would apply. To
actively set aside an arbitrary number of homes (1,200) potentially in areas where there are
limited services, no cycle facilities and limited public transport, would be contradictory to the
principles of sustainable development, and thus contrary to the NPPF and the NPPG. It would
fail all 4 tests of soundness contained in Paragraph 35 of the NPPF.2.14 Paragraph 117 highlights that sustainable communities will be where people have good access
to “services and facilities including schools, health care, shops, leisure, and community
facilities and libraries – which in turn reduce the need to travel”. Accordingly, irrespective of
previous allocations, this Local Plan should undertake services audits of each settlement
(including the villages), outside the obvious case of the city centre, and identify a hierarchy
of centres. Those centres with the greatest variety of services and accessibility should then
be identified as the priority for accommodating future growth. There appears to be no suchassessment within the Local Plan or its supporting evidence base, and thus the soundness of
the strategy for growth is brought immediately into question. Indeed the Growth locations
identified in Map 7 appear to have no rationale, aside from simply carrying forward allocations
from the previous plan period irrespective of whether they have delivered, or meet the tests
of soundness for compliance with national policy in 2020, as opposed to when the previous
iteration of the Plan was prepared.
2.15 Similarly, our client wholly supports the sentiment of Paragraph 126, seeking to achieve a
radical shift away from the use of the private car. Locations with good quality footpath and
cycle links, as well as access to public transport are the most likely locations to achieve such
a shift. This is the case for land to the northeast of Wymondham, which has footpath links to
the town centre, and dedicated cycle routes into Norwich City Centre. However, achieving
this shift will be far more difficult in rural locations and small settlements, where roads are
narrow and cannot accommodate cycle/footpaths.
2.16 The Plan’s Objectives are set out on Page 34, with reference to promoting the ‘delivery’ of
housing, jobs and infrastructure to meet needs. The word delivery being key, as it is a key
test of the NPPF. The previous Plan period has failed to deliver the needs of the Greater
Norwich Area, particularly in respect of housing as set out in our response to Question 9.
This has impacted on affordability and access to housing. The Plan should recognise the
shortfalls of over 6,100 homes across the Norwich Policy Area and seek to remedy it through
directing growth to locations that have delivered successfully.