Comment

Representation ID: 22293

Received: 16/03/2020

Respondent: Barton Willmore

Q41 - 42) Consultation Questions for Policy 7.2 – The Main Towns

2.72 The Main Towns consist of the settlements of Wymondham, Aylsham, Diss and Harleston. Policy 1 of the Draft Strategy also identifies Long Stratton as a Main Town. Clearly Wymondham is a settlement at least twice the size of any subsequent settlement, and given the services available, it should be identified as a ‘Large Main Town’ in a means that separates it from the other towns. An audit of facilities and services should be undertaken to support this assertion and create a hierarchy of settlements for which Wymondham should be singled out as the largest town and the most suitable to accommodate growth. This would support the basis for the additional 1,000 homes identified for Wymondham as a ‘contingency’ location, and also support the case for it to accommodate a portion of the additional growth we have identified as (a) needing to be identified to accommodate additional homes linked to the Growth Deal; and a buffer of 20%; and (b) needing to be re-allocated as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46). 2.73 We do not object to the identification of Long Stratton given the existing growth committed for the town and its location within the Norwich Policy Area, but as set out in response to Question 13, we do believe the allocation needs scrutinising as based on NLP 2016 evidence, we believe it is unlikely that 1,800 homes can be delivered in Long Stratton before 2038.

2.74 As acknowledged at paragraph 308 of the Draft Strategy the Main Towns play a vital role in the rural economy, providing employment opportunities and services for wider hinterlands. We agree with this description but consider Wymondham to have additional roles and services which elevates it above the other Main Towns. Furthermore, Wymondham is located within the Norwich Policy Area (and SHMA ‘Core Area’) and within the Cambridge Norwich Tech Corridor.

2.75 Given the emphasis of the GNLP to focus housing, employment and infrastructure growth within a ‘Strategic Growth Area’ (illustrated on the Key Diagram of the Draft Strategy) which broadly reflects the Cambridge Norwich Tech Corridor, it is unclear why Wymondham is not a key location for growth within the Plan, and separated out as such within a settlement hierarchy.

2.76 Policy 7.2 identifies Wymondham to have an existing deliverable commitment of 2,463 dwellings (including delivery 2018/19). The AMR identifies 1,140 dwellings to be delivered in the next 5-years (2019/20 to 2023/24) with a further 328 dwellings to be delivered in the remainder of the JCS Plan Period. 2.77 For 2026 and beyond the AMR identifies a supply of only 502 dwellings for the latter phases of South Wymondham (477 dwellings) and for London Road/Sutton Lane (35 dwelling). This level should be significantly increased given its previous success in delivering homes, to accommodate at least a portion of the homes we have identified as (a) needed to accommodate additional homes linked to the Growth Deal and a buffer of 20%; and (b) needed for re-allocation as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46).

2.78 The Draft Strategy proposes to allocate an additional 100 dwellings only in Wymondham, across 2no. sites (50 dwellings each). Across the extended Plan Period (2026 – 2038) there is only likely to be circa. 600 dwellings delivered in Wymondham, despite the key location of the settlement within the Cambridge Norwich Growth Corridor and past strong housing delivery. This simply does not represent sustainable planning, and by raising its position within the settlement hierarchy the case can be made to support additional growth that needs to be re-allocated.

2.79 The GNLP does give some recognition to Wymondham, by acknowledging it as a settlement that could accommodate a contingency of 1,000 dwellings. This was based on whether “the GNLP area does not meet its local plan targets”. We have highlighted for reasons above, that the GNLP does not (a) plan for enough housing growth to meet need, particularly as a result of the Growth Deal; and (b) needs to re-allocate land that cannot deliver the anticipated level of housing – i.e. in the Growth Triangle; Carrow Works; Long Stratton and the Village Clusters. Accordingly the ‘contingency’ for Wymondham should be enacted into this Local Plan now, and additional growth beyond the 1,000 dwelling contingency should be allocated to Wymondham given its sustainable location within the A11 and Cambridge to Norwich tech corridor.

2.80 The supporting assessment of Wymondham identifies that there are 7 ‘reasonable’ sites that could accommodate additional growth. Park Farm (Site GNLP2168) and Stanfield Road (Site GNLP1055) are identified as new settlements, for which there is no need identified. However, Sites GNLP2155, GNLP2150 and principally GNLP0525R, were identified as ‘reasonable’ sites that together could knit circa 1,730 new dwellings into the housing that has already been delivered at the former Rugby Club; planned at Elm Farm, and located to the north of Tuttles Lane and Norwich Road. As set out in Chapter 3, our client has land that is available, nonconstrained and deliverable, that can provide a new sustainable community heart to the existing housing that has been delivered to date, that is permitted at Elm Farm, in addition to a further 600 homes, supported by a new primary school and a Local Centre. This land can also deliver a new Country Park and land for a new Sixth Form College. 2.81 The land offers the opportunity to create a new sustainable community that delivers infrastructure to the immediate community and has wider benefits to the town in respect of open space and education provision. This is a well located site within the A11 and Cambridge – Norwich Tech corridor, with good access to trains, bus facilities and dedicated cycle routes. It should form at least part of additional land allocations to Wymondham, necessary to deliver the growth required, and in need of being re-allocated for the reasons set out in responses to previous questions.

2.82 As detailed in Section 3 there is an existing education capacity constraint in Wymondham which was not addressed at the time of adoption of the Wymondham Area Action Plan but confirmed by the Examining Inspector as a matter which justified an early review of the Plan and needing a solution. A solution to this is achievable, through the re-location of Wymondham High Sixth Form, and supported by Norfolk County Council Education. However, this is not currently being addressed by the adopted Development Plan, nor would it be addressed by the emerging GNLP in its current form.

2.83 Only through the allocation of sufficient growth to Wymondham will the GNLP resolve the ongoing education capacity constraint. The education ‘issue’ therefore must be dealt with through this plan-making process, and our client’s land offers the opportunity to address that constraint through the provision of sustainable new community that will also bring local shops and services, a new Primary School and a new public park.

2.84 In order to achieve the Vision and Objectives set by the Growth Strategy, including realising the full potential of the Cambridge Norwich Growth Corridor and meeting existing infrastructure requirements, it is necessary for the Plan to support Wymondham as a key location for growth, beyond current commitments.

2.85 In addition to the above, whilst we have no objection to the Main Towns receiving additional growth to ensure they continue to successfully achieve their roles as providers of employment and services to serve rural areas, but it is clear, for the reasons we have established Wymondham, should be set apart as a new settlement hierarchy to accommodate a higher portion of the additional growth.

2.86 Notwithstanding the above comments, we do question why Harleston, as the smallest Main Town, is identified for allocations totalling 450 dwellings in addition to the existing commitments (173 dwellings). Harleston is the least accessible Main Town, not being located on the rail network or on an A road which connects to Norwich and is not located within the Norwich Policy Area or the SHMA Core Area.

2.87 The Draft Strategy is therefore not considered to be justified or effective in line with the requirements of the Framework. As such, the proposed strategy is considered unsound.