Comment

Representation ID: 22465

Received: 16/03/2020

Respondent: Gladman Developments

2.3 Policy 7.2 Main Towns
Allocations at Wymondham
2.3.1 Gladman welcome proposals made under Policy 7.2 for further growth to be allocated at Wymondham in addition to existing commitments. It is however considered that the 100 dwellings planned for through the Draft GNLP at Wymondham is not enough to meet housing and employment needs (see main representations) and does not provide sufficient flexibility within the housing land supply to ensure the deliverability of planned requirements. The level of new growth to be directed to the settlement should be substantially increased.
2.3.2 In Wymondham, committed development accounts for 96% of the total growth requirements of the Local Plan over the period 2018-2038. The emerging GNLP therefore does very little to influence the strategy of the town, with policies to have limited effect in directing where, how and in what form development takes place in the town.
2.3.3 The effects of this are twofold. Firstly, growth in the town will not respond to the latest evidence base of need. For example, as drafted, the Plan will fail to respond to the housing needs of the elderly with no allocations for elderly accommodation, and little scope provided for elderly appropriate accommodation through the 100 dwellings allocated in Wymondham through the draft GNLP. Secondly, the GNLP does nothing to respond to the town’s location within the A11 tech corridor, and therefore fails to make the most of this opportunity, rendering it ineffective in this regard, and potentially harming the achievement of planned economic growth in the wider plan area.
2.3.4 Gladman notes the proposal to identify 1,000 dwellings worth of contingency in Wymondham to respond to unmet housing need. Noting the size of the Wymondham, its sustainability, and location as part of the Tech Corridor, Gladman consider that Wymondham forms one of the most appropriate locations within the plan area at which to address any housing shortfall and/or provide additional flexibility to respond to plan targets.
2.3.5 It is however considered that this additional growth should be planned for now, in the form further housing allocations in the Plan, rather than offset to a later date. Such an approach would increase the flexibility of housing land supply provided within the GNLP and heighten its durability against unpredicted changes which might occur over the plan period. Allocating land for a further 1,000 dwellings in the Plan would also address comments made above regarding the effectiveness of the GNLP in addressing the needs of Wymondham itself, as well as broader housing need. The plan making process provides a good opportunity for the infrastructure requirements of Wymondham and any future development to be understood with a solution planned for. Planning for this upfront would reduce any delay in meeting housing needs, which may not be possible through the planning application process.
Strategic Gaps
2.3.6 Gladman consider that strategic gaps should be reviewed and revised through the plan making process of the Greater Norwich Plan. As currently defined, the extent of the strategic gaps potentially forms an unnecessary constraint to development within the plan area, preventing the development of otherwise sustainable sites for development through the GNLP. Since defined and last reviewed the context for each strategic gap is likely to have altered considering more recent development changing the nature of the strategic gap and changing the need to retain land within this designation to fulfil its purpose.
2.3.7 Evidence of this is clear in the case of the strategic gap currently defined between Wymondham and Hethersett. In recent years the character of land at the north eastern edge of Wymondham along Norwich Common has significantly altered with new housing and employment development along the north of this road which has served to urbanise this area.
2.3.8 In response to this, Gladman commissioned FPCR to undertake an assessment of the Strategic Gap to consider how land included within this designation functions as an important part of the identified gap. This evidence (provided in Appendix 2) concludes:
 The gateway into Wymondham from the East is formed by Elm Farm Business Park. This is the most eastern extent of Wymondham;
 The B1172 (Norwich Common) represents the only visual receptor for the gap, given general absence of public footpaths and obscured views on the A11;
 Inter-visibility along the B1172 is however limited given intervening vegetation and built development;
 The settlement pattern in Wymondham has recently altered from a nucleated settlement following recent development in the north east of the town; and  There is a limited degree of openness within the strategic gap between Wymondham and Hethersett owing to existing intervening vegetation and built development.
2.3.9 Taking the above into account FPCR conclude that by maintaining the current minimum width of the Strategic Gap it is unlikely that further development will compromise inter-visibility, physical separation or perceived openness, with opportunities available to mitigate adverse effects on openness.
2.3.10 On account of this evidence, Gladman believe there is clear justification to revise the extent of the Strategic Gap defined at the edge of Wyondham to exclude land south of Norwich Common from within the gap to provide a new boundary defined at the entrance of the town provided at Elm Farm Business Park. Further commentary is provided within section 3 of this representation about how the land being promoted by Gladman at Norwich Common, Wymondham could be developed whilst safeguarding the integrity of the wider strategic gap.