Comment

Representation ID: 23190

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

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Policy 1 proposes the following settlement hierarchy:
1. Norwich urban area (Norwich and Norwich Fringe)
2. Main towns (Aylsham, Diss, Harleston, Long Stratton and Wymondham)
3. Key service centres
4. Village clusters
It states that growth is distributed in line with the settlement hierarchy to provide good access to
services, employment and infrastructure through urban and rural regeneration, along with sustainable
urban and village extensions. It focusses most of the housing, employment and infrastructure growth
in the Strategic Growth Area (i.e. Norwich, the A11 corridor and the Growth Triangle), but also allocates
growth to towns and villages to support vibrant rural communities.
Orbit Homes is broadly supportive of the proposed settlement hierarchy, but as set out in the separate
representations prepared by David Lock Associates promoting Silfield Garden Village on behalf of Orbit
Homes and Bowbridge Strategic Land, it considers that Wymondham should be considered above the
other main towns. Wymondham is the second largest settlement in Greater Norwich and is almost twice
the size of the next largest town. There is therefore a good argument for it to be considered above the
other main towns in the hierarchy as a ‘key town’. It is also strategically located in the heart of the
Cambridge to Norwich Tech Corridor and is ideally placed to provide strategic scale growth that is
sustainable and deliverable.
Orbit Homes therefore consider that the settlement hierarchy should be changed as follows:
1. Norwich urban area (Norwich and Norwich Fringe)
2. Key town (Wymondham)
3. Main towns (Aylsham, Diss, Harleston, and Long Stratton and Wymondham)
4. Key service centres
5. Village clusters
In Table 1 below, we provide a comparison of the distribution of existing and proposed growth to
different levels of the hierarchy.

See Attachment for Table 1

Table 1 above demonstrates that, compared to existing commitments, the strategy for new allocations
focusses a significantly higher proportion of growth to the village clusters (increased from 6.5% of
existing commitments to 21.5% of new allocations), broadly similar levels of growth to the main towns
(increased from 14%-16%) and key service centres (decreased from 8 to 6.5%) and a significant
decrease in growth directed to the Norwich urban area (decreased from 71.5% to 56%).
Orbit Homes is aware of Norwich City Council’s objections1 to this change of focus, as it considers
additional growth should be focussed on the city and that this change in strategy goes against the
professed aims of the GNLP’s Climate Change Statement to deliver growth in sustainable locations that
reduce the need to travel. Orbit Homes recognises this argument and notes that there has been no
assessment of the ability of village clusters in South Norfolk to accommodate the high level of growth
proposed. Orbit Homes is however concerned that, due to significant existing commitments, any
significant additional growth in and adjoining the Norwich urban area would suffer from the same
deliverability issues that have plagued the current development plan. To avoid this issue whilst ensuring
development is directed to sustainable locations, Orbit Homes considers that a higher proportion of the
housing requirement should be directed to deliverable sites at the Main Towns.
As set in Orbit Homes’ representations to Policy 7.2, the Main Towns are sustainable locations with
deliverable housing options that could deliver much of the growth needed in Greater Norwich. As set
out under Question 14 below, Orbit Homes considers that the proposed housing requirement should be
significantly increased to account for City Deal growth commitments. In this respect, it would clearly
be inappropriate to allocate the same proportion of growth to village clusters if a higher requirement is
set. A higher proportion of this additional growth will therefore need to be met in settlements further
up the hierarchy, and particularly in the Main Towns, where the resultant strategic levels of growth
would be most sustainably accommodated.