Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23074
Received: 16/03/2020
Respondent: Orbit Homes
Agent: David Lock Associates
There is, however, considered to be a significant lack of clarity regarding the approach to
distributing growth as there are multiple different locational criteria taken into account in addition
to the settlement hierarchy. This causes confusion and means that it is difficult to determine
whether the approach to distributing growth is robust. The priorities for locating growth, as
suggested in GNLP, include:
• ‘Growth broadly follows the settlement hierarchy’;
• ‘Focusses most of the growth in locations with best access to jobs, services and existing
and planned infrastructure in and around the Norwich Urban Area and the Cambridge
Norwich Tech Corridor’;
• ‘In the strategic growth area – which also includes the Cambridge Norwich Tech Corridor’.
It is not clear which of these take precedence and how they are intended to interrelate. As such,
it is not appropriate to simply ask whether there is agreement with the distribution of housing
within the hierarchy as this is not the only factor affecting the location of growth. This approach
should be clarified.
It is also not clear, apart from the allocations in the Norwich Urban Area, how the growth and
distribution strategy is reflective of any of the other reasonable alternatives considered in the
2018 Growth Options consultation. Worryingly, apart from providing a brief rationale as to why
alternative approaches have not been pursued in respect of Policy 1, there is no formal SA of
alternative approaches to the distribution of homes and the level of housing growth. Despite
reference to options being considered at previous Regulation 18 stages, this is not a robust
approach and could put at risk the draft plan in respect of its locational strategy as it has not been
subject to testing against alternatives. Flaws of the Sustainability Appraisal (SA) are covered in
the separate SA representation.
Furthermore, the simplistic approach of relating growth distribution to the settlement hierarchy
fails to have regard for alignment with other strategies, initiatives and investment in the area.
The Plan makes these other important considerations very clear in its introductory chapters with
particular reference to the transport network, recent and planned improvements, Transport for
Norwich, the Norfolk County Council Rail Prospectus, East West Rail and the Transforming Cities
Programme. In this context, the A11 corridor is clearly well placed to accommodate growth in
light of recent improvements and its role as the spine of the Cambridge – Norwich Tech Corridor.
Wymondham itself is a focus for investment under the Transforming Cities Programme; its railway
station is positioned on the potential extension of East West Rail and it is a growing hub for public
transport accessibility. This is not however, then reflected in the distribution of growth.
For full representation, please refer to the attached documents.