Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22296
Received: 16/03/2020
Respondent: Barton Willmore
Q48) Any other Comments?
2.96 As set out within our March 2018 representations to the Growth Options Consultation Document we continue to support the use of a Policy area focused towards Norwich City.
2.97 Historically this has been achieved with the Norwich Policy Area (NPA) which enabled growth to be focused in the right areas to deliver a Norwich-centric spatial strategy and allow for appropriate monitoring.
2.98 The SHMA (2017), identifies that the NPA itself does not form a functional housing market area (HMA). As such, the Growth Options Consultation Document identified the GNLP would no longer include an NPA specific housing land supply.
2.99 The Draft Strategy contains no reference to the NPA or the ‘Core Area’ which the SHMA identifies as a functional HMA.
2.100 We strongly object to the loss of a Policy Area focused towards Norwich City with the Draft Strategy continuing the approach to confuse the role of a SHMA for the purposes of determining Housing Needs and a specific policy based area to ensure the right growth is delivered in the right locations.
2.101 The Greater Norwich Technical Report prepared to support our March 2018 representations (Appendix 2) the NPA continues to represent a relevant area to direct growth, being an appropriate Travel to Work Area where future job growth will be focused.
2.102 The GNLP evidence base further provides support for a functional HMA, in the form of a ‘Core Area’ (including Acle, Aylsham and Loddon). However, given no other settlements outside this area are sufficiently self-contained to establish a separate HMA (or areas), the SHMA concludes the most appropriate HMA, for the plan, is the Central Norfolk HMA.
2.103 Nevertheless, there is a clear evidence an area exists with the strongest functional connection to the Norwich Urban Area.
2.104 We strongly urge the GNLP to continue the approach set by the NPA in directing growth to a defined area (whether NPA or similar distinction) with the strongest functional relationship to Norwich. The boundary of this area should also reflect the preferred spatial strategy i.e. towards an A11 focus.
2.105 Without a Policy Area focusing growth in key locations, there are risks that the strategy will fail.
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.