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Representation ID: 23075

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

Alignment of Settlement Hierarchy with Spatial Strategy
There is reference at paragraph 153 to the strategic sites contributing to the Cambridge-Norwich Tech Corridor and there is clearly a commitment throughout the Plan to supporting the Corridor and focusing growth within it. There is, however, no specific attribution of growth to the Corridor as a spatial area. Thus, there is no tangible evidence within the Plan as to how it is being supported. We strongly suggest that GNLP take an area-based approach to distributing growth; this has been partially undertaken for the Norwich Urban Area but then fails to articulate the Corridor as a spatial area for allocating sites. We contend that if the growth within the Corridor (excluding that which is attributed to the Norwich Urban Area in any case) was to be separately
identified, it would highlight that there is not in fact any significant policy support for strategic growth within the Corridor that is not delivering growth for the Norwich
Urban Area.

The Role of Wymondham as second in the hierarchy
Furthermore, we also raise concerns regarding Wymondham’s role and status. Wymondham is the largest settlement outside of the urban area and therefore placed second in the hierarchy. It is positioned at the heart of the Tech Corridor and is within the strategic growth area. The town is well served by local facilities, is situated within immediate access onto the A11 and benefits from a stopping station on the Norwich–Cambridge Rail Line. On this basis and in accordance with the distribution of growth principles set out above, Wymondham should be a key focus for
strategic-scale development.

Wymondham, however, receives the lowest quantum of growth of all the ‘main towns’ with only 100 new units allocated. We assume that the rationale for this approach is in part due to the existing commitments which already exist on the edge of the town. However, this approach is not reflective of the locational criteria that supposedly inform the distribution of future growth and we suggest that as part of the plan-making process and reviewing reasonable alternatives for growth, the locational criteria for future growth should be applied notwithstanding existing commitments. Existing commitments, coupled with the locational criteria and advantages identified in the paragraph above, simply serve to reinforce that Wymondham is an excellent location for planned strategic growth.

Impact of Contingency Allocations
We note that Wymondham is proposed as the location for a contingency provision of 1,000 additional dwellings should delivery of housing in the GNLP area not meet local plan targets (p106). However, no site(s) are identified for this contingency nor any locational criterial which would govern the selection of preferred sites or locations for this contingency in or around the town.

This approach runs counter to both the objectives and the clarity of the plan, instead providing a laissez-faire policy framework which will invite any number of speculative applications for circa 1,000 units or more numerous smaller scale applications to be submitted for consideration. There are a number of significant risks in this approach, for the main part associated with piecemeal infrastructure contributions and unmeasurable impact on existing services and the transport network. At 1,000 units, a single scheme would not be of the scale necessary to deliver significant new infrastructure on site or in totality but would instead place additional pressure on current
facilities. If multiple smaller schemes come forward to meet the contingency, these could only deliver modest localised highway improvements or financial contributions towards infrastructure.

In respect of achieving well planned growth and providing certainty around associated infrastructure delivery, a number of soundness issues can be raised with the current approach, related to:
• The uncertainty around planning for and being able to secure necessary infrastructure if
Wymondham accommodates 1,000 units in one or more unknown location(s);
• The same uncertainty applies if 1,200 units are allocated in currently unknown or
unidentified villages; and
• The failure to meet the requirement of assessing reasonable alternatives in terms of
specially considering alternatives to a) the contingency approach and b) the specific allocation of 1,200 units to the Village Clusters Document.

We strongly recommend that the 1,000-unit contingency should be attributed to the allocation of a Garden Village at Silfield.

Impact of South Norfolk Village Clusters Document It is also important to note that 1,200 homes are attributed to a future ‘South Norfolk Village Clusters Document’. In real terms this accounts for circa 15% of all new allocations within the GNLP and as such, from a hierarchy and distribution perspective, cannot be considered a sound approach that collectively means the villages accommodate approximately the same level of growth as the new allocations in the main towns.

Furthermore, the ability of the villages to accommodate growth has not been assessed and is therefore unknown. To attribute such a high figure towards them, given their position on the hierarchy, is therefore a significantly flawed approach and one that is likely to be undermined at Examination. No reasonable alternative for allocating this level of growth elsewhere within South
Norfolk or the wider GNLP area has been considered. This is a material error in the Sustainability Appraisal of the Plan and calls into question the soundness of plan making in this regard.

We strongly recommend that the 1,200 units as yet unidentified in a future Village Clusters Document should form part of the overall housing requirement to be met explicitly in the GNLP and such be attributed within the allocation of SGV.

Consideration of New Settlements
The supporting text to draft Policy 1 indicates that no new settlement is proposed at this time “as a significant proportion of the allocated sites are strategic scale commitments of 1,000 homes plus and the establishment of any new settlement is likely to take a long time” (Paragraph 168). This is a flawed assertion and has no grounding in the plan-led approach in terms of assessing reasonable alternatives and undertaking a sustainability appraisal of growth options. A similar
statement is provided in the accompanying Site Assessment booklets.

The existence of strategic commitments or other concurrent allocations have no bearing on whether a new settlement provides a more, or the most, suitable and sustainable growth option for a Local Plan. The assessment of the new settlement growth options within the Sustainability Appraisal and Site Assessment Booklets is inherently flawed and requires substantial review. We cover this point in more detail in our representations on these documents.

The approach to assessment of alternatives undertaken by the GNLP and the consequential decisions in arriving at the preferred policy option raises serious and wide-ranging issues of soundness. Most importantly, the alternative option accommodating growth at a new settlement rather than within the other growth typologies allocated (primarily urban extensions and village
clusters) has not been robustly or appropriately considered. We contend that if a robust assessment of all types of growth and distribution had been undertaken as the starting point of the GNLP, SGV would rate very highly against other reasonable alternatives given its locational characteristics, sustainability and self-containment credentials and ability to provide new facilities and amenities and investment in infrastructure.

We consider that the inconsistencies and flawed approach to the spatial distribution of growth set out within the Plan lead to a significant question mark over a large number of the proposed allocations. We contend that the current approach to the allocation of sites for least 5,200 homes does not represent the most sustainable option when considered against other reasonable alternatives. Given this level of inconsistency, we consider that the current assessment hitherto undertaken will undermine the progress of the Regulation 19 Plan, and its progress to Examination. On this basis we strongly recommend the GNDP undertakes a comprehensive review of the methodology and its conclusions prior to moving any further towards the publication of a Reg 19 Plan.


Suggested Alternative – A Deliverable Spatial Strategy and Planning Positively for Comprehensive Long-Term Growth

A Deliverable Spatial Strategy
In terms of hierarchy considerations, whilst we do not disagree with the stated role of Norwich and it being the main focus for growth, we are concerned that at 69%, the proportion of growth attributed to the urban area places too much reliance on a single growth location within Greater Norwich. This undermines the rationale and purpose of preparing a joint Local Plan. 4.30 It is understood that delivery issues have been experienced in bringing forward development within the growth triangle at north east Norwich. This area has extensive existing growth commitments - the equivalent to a major new settlement in its own right - with a significant amount still to be built out. The focus on Norwich – whilst logical in principle as the tier one settlement - has resulted in additional growth being allocated in north east Norwich in the draft Plan. However, when considering the current delivery position and the opportunities which derive from a joint plan for a wider area, the soundness of an approach which imposes further reliance on this area in terms of future delivery rates, particularly in the context of market saturation, is questioned.

The NPPF paragraph 73 requires that strategic policies should include a trajectory indicating the expected rate of delivery over the plan period. No such trajectory has been included in any of the Reg 18 stages of the plan thus far and on this basis we consider that a spatial strategy and approach to allocations relying on such a significant amount of existing commitments in the absence of this information is unsound. There is no evidence to suggest such numbers are deliverable or achievable within the plan period.

Furthermore, the continued focus of new allocations in the growth triangle does not align with supporting the Tech Corridor as a spatial growth pole. Lying on the far side of Norwich, growth here does not lend itself to reinforcing important connections with Cambridge, nor to supporting more sustainable patterns of movement along the A11/rail corridor. Neither does it align in terms of providing homes to support the economic hubs and jobs growth within the Tech Corridor.

On this basis, we suggest that rather than allocating a further 1,400 new homes to the growth triangle, a more appropriate and robust approach would be to redistribute this growth to align closely with the spatial objectives of the Tech Corridor thereby supporting the economic growth and success of Greater Norwich as well as providing a much-needed re-balancing of the local housing offer and a wider choice of locations within which to deliver new homes. Silfield GV would be an appropriate and deliverable location to accommodate this growth.

Similarly, we would question the GNDP decision to include an allowance for new homes from Carrow Works as part of the approach to housing allocations. Whilst we wholly support the redevelopment of brownfield land and the Councils’ ambition to create a new urban quarter for Norwich – and its consequent allocation as a ‘strategic regeneration area’ – we question the soundness of relying on the provision for 1,200 new homes to be delivered on this site as part of the housing strategy.

Despite the stated uncertainty about its delivery (as expressed on pages 46 and 94), the 1,200- home allocation represents circa 15% of the total housing numbers allocated in the plan. There is no rationale given for including a site for which there is significant uncertainty, nor does this approach accord with the NPPF.

Thus, we suggest that rather than making an explicit allocation for this level of housing, the GNDP treat the contribution to made from this site in the same way as a ‘windfall’ category. This approach would not only accord with the Plan’s overall approach of ‘building in flexibility to support higher than trend economic growth’ (page 45) but would be in line with the NPPF and Government’s objective to significantly boost the supply of housing (NPPF paragraph 59). Should Carrow Works deliver a proportion of its capacity within the plan period, this will serve to further boost the supply in Norwich. This approach would reduce the risk of the Plan failing to deliver its full housing requirement and having to make increased contingency allocations during or soon after the process to adoption. Maintaining the inclusion of the current contribution from Carrow Road as a firm and deliverable allocation undermines the soundness of the Plan looking ahead to Regulation 19 and the Examination, and risks incurring delay and further uncertainty over future growth locations.

In terms of meeting the consequent shortfall of 1,200 homes, we suggest re-distributing this growth from the Norwich Urban Area to the Tech Corridor would go some way to meeting our wide-ranging concerns regarding the mismatch between Plan objectives and spatial growth allocations. Silfield GV would be an appropriate and deliverable location to accommodate this growth.

Planning Positively for Comprehensive Well-Planned Growth

We have set out above our reasoning for the requirement for GNLDP to undertake a re-running of the assessment of alternatives to include new settlement scale growth from the outset. This would allow reconsideration of the overall spatial growth strategy, and importantly, would allow a full and proper assessment of the role that SGV can play as part of this strategy.

We have also set out above why the GNDP needs to plan comprehensively for the long-term growth of Wymondham rather than make small scale allocations in favour of future contingencies and/or village cluster sites.

Attributing the 1,000 contingency sites and the 1,200 units as yet unidentified through Village Cluster at SGV would provide certainty and accord with the Plan-led approach advocated by the NPPF. Whilst SGV has the capacity to deliver up to circa 6,500 new homes – and an allocation for the full extent of the GV should be made in this Plan - the re-allocation of the identified potential shortfall of 2,200 homes to the GV would be deliverable within the Plan period.

Wymondham, by virtue of its location and position in the hierarchy, will continue to be an appropriate focus for growth in perpetuity and across future plans. There is, therefore, a need to plan properly for its growth and ensure a comprehensive approach to its infrastructure requirements and the long-term future of the town. This should be taken forward through identifying the strategic growth potential of Wymondham, irrespective of past development commitments, but this time adopting a holistic view of the town’s future needs in terms of education, employment opportunities and role as an economic destination in the Tech Corridor.

In this context, SGV would be well placed, as a strategic allocation for a garden village, to address these long-term infrastructure considerations. It provides the ability to ‘re-balance’ the growth of the town and establish a more positive relationship with the A11, maximising the accessibility this provides for the town and not perceiving it as a barrier to growth. Reviewing the role of Wymondham and its growth potential in the context of allocating a garden village at Silfield, would align with other initiatives and funding such as the potential Transforming Cities investment and the Tech Corridor whilst removing the uncertainty over the location and impact of future growth – through both speculative or contingency sites – which is so damaging to local communities and runs counter to effective plan making.

We therefore strongly suggest that the GNDP review the current approaches taken towards the growth of Wymondham in favour of making an allocation at SGV to plan positively and with certainty the growth of Wymondham and ensure the town can secure necessary infrastructure provision to safeguard against pressure on services now and into the long-term.