Object

Representation ID: 23068

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We have fundamental concerns with the draft Plan as it stands. These derive from the
Introductory sections of the Plan, and although our concerns do not relate to inaccuracies in terms
of what the Plan is to achieve, we are concerned with how the Plan itself aligns with the stated
position and its lack of alignment with the proposed policies. This is turn means that the purpose
of the Plan is not clear.

Paragraph 2 indicates that the GNDP have taken a long-term view of development needs to ensure
the development in the right place and at the right time. We contend that the GNDP has not
taken a long-term view or sought to locate development in the right place at the right time. As
is set out in further detail in response to Policy 1, the GNLP does not plan for sufficient housing
to meet the local needs in accordance with the National Planning Policy Framework (NPPF) and
National Planning Policy Guidance (NPPG). It does not take a long-term view in terms of the
growth of the Cambridge-Norwich Tech Corridor, and in policy terms, does little to encourage or
stimulate the success of the Corridor. This stance is not aligned with wider strategies and
initiatives, and therefore we consider the aim of the plan is undermined.

The Plan is not considered to identify sites to meet Greater Norwich’s growth needs from 2018 –
2038 sustainably. The preferred sites identified are not the most sustainable when compared to
reasonable alternatives and the Plan defers the allocation of sites for 1,200 homes to a future
‘Village Clusters’ Plan, which is discussed further in respect of Policy 1.

The introductory section sets out the context of other strategies which ‘provide the context for
development in Greater Norwich’. We agree with all of the initiatives and strategies referenced
but have grave concerns that this draft Plan does not align its growth strategy with them, as
detailed further below:
• Projects of national significance – improvements to A11 trunk road. This recently dualled
and important link between Cambridge and Norwich has been subject to substantial
investment. It is imperative that growth should maximise and support the investment
that has already been made. In this context allocating growth at SGV, with a new junction
on the A11 (funded by the development) would capitalise on these improvements, rather
than rely on significant and potentially uncertain future road improvements.
• Economic Growth – as is set out in Appendix 3 (Technical Review of Housing Need
prepared by Turley), we contend that the Plan does not make sufficient provision for
housing to meet the economic growth requirements.
• Transport Priorities including Transforming Cities – the recent Transforming Cities funding
bid includes allocation of funding for a mobility hub at Wymondham Station. The case
for investment should be supported through reaffirming Wymondham’s position in the
settlement hierarchy and its growth capabilities in this context. In accordance with
achieving sustainable development in line with the NPPF, the GNLP should align growth
locations with sustainable transport improvements. There is not sufficient recognition for
the growth potential of Wymondham, either in the context of the settlement hierarchy;
its location within the Tech Corridor; and its sustainable transport connections (with
planned investment). The GNLP should plan comprehensively for strategic growth at
Wymondham in this context and not simply provide for smaller scale sites incrementally.
• The GNLP indicates at paragraph 22 that there is a need for the Plan to look beyond the
current end date of 2038 by setting a strategy that can be sustainably added to in the
long term. This approach is not reflected in the policies contained within the plan. There
is, in fact, recognition that a new settlement may be needed in a review of the plan but
that the reason one is not to be allocated now is due to the long period for such
developments to establish (Paragraph 168 of the GNLP Strategy Document) . This wholly
contradicts paragraph 22. To plan ahead, the GNLP should be proactive in identifying and
allocating a new settlement to allow strategic scale growth to progress with certainty,
both for those responsible for its delivery and for the local communities affected.
• Paragraphs 24 - 26 indicates that a separate document is to be produced to allocate ‘small
sites’ across South Norfolk. This significantly undermines the purpose of the Plan by not
making clear how the Plan is treating its strategic policies in accordance with paragraphs
17 – 22 of the NPPF. These should make sufficient provision for housing (para 20) and
should provide a clear strategy for bringing sufficient land forward to address objectively
assessed needs over the plan period. We recognise that the NPPF allows for non-strategic
policies to be covered in a separately where they set out more detailed policies for specific
areas, neighbourhoods or types of development. However, the scale of growth attributed
to the Village Clusters document (at 1,200 homes) is considered significant in the context
of the relatively minimal new allocations made.
• Worryingly, it is also clear from the Interactive Mapping used by GNLP that it is not just
small sites that have been deferred for assessment in this separate plan. Some medium
to large scale sites across South Norfolk have also been deferred and therefore are not
assessed as part of the GNLP. Given that this is a Joint Local Plan, the approach of
preparing a separate document for just one constituent authority in isolation is not
considered a robust approach to plan making and risks making the GNLP ineffective. We
strongly consider that land for the 1,200 homes should be allocated within the current
GNLP: this is the only way to ensure growth options are considered holistically, particularly
in the context of infrastructure requirements.