Object
Publication
Representation ID: 23659
Received: 12/03/2021
Respondent: Welbeck Strategic Land III Ltd
Number of people: 2
Agent: James Bailey Planning Limited
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Policy 7.4 Village Clusters (para. 380-388)
5.61 The GNLP Reg 19 document is proposing that Village Clusters will provide 4,220 homes through
existing commitments and further allocations. This is around 9% of the total for the plan period
to 2038.
5.62 It is noted in para.382 that a separate South Norfolk Village Clusters Housing Site Allocations Local Plan is being produced, for a minimum of 1,200 homes in addition to the 1,392 already committed in the Village Clusters.
5.63 In the absence of this document, and its associated evidence base, the quantum of growth being proposed cannot be relied upon.
5.64 It is this approach to the Village Clusters, and specifically the South Norfolk Village Clusters, that
Welbeck Land is strongly opposed to.
5.65 The minimum 1,200 new homes in the South Norfolk Village Clusters therefore represents almost a 50% increase on the committed development.
5.66 This would appear at odds with the approach taken by the GNLP towards the larger more sustainable settlements, notably the Main Towns or Key Service Centres.
5.67 This radically different approach towards guiding future development needs to be fully and properly understood, as it would appear a significant departure from the previous approach being advocated in the Reg 18(c) of the GNLP, and also contrary to what is considered to be good and sound sustainable planning.
5.68 Para. 381 suggests providing this level of growth in Village Clusters will promote social sustainability and will help support rural life and services. The GNLP Reg 19 document also suggests that this approach will also benefit small-scale builders and will provide choice to the
market in helping to ensure the delivery of housing in popular village locations.
5.69 However, it is suggested that the approach outlined in para. 381 can also be met by the promotion of ‘windfall sites’ which allows for “very small developments limited to 3 to 5 homes, adjacent to settlement boundaries” (para.379 for Key Service Centres).
5.70 Para. 387 states that “policies 1 and 7.4 also support windfall development for affordable housing in the village clusters in both Broadland and South Norfolk, with some market housing permitted where it supports viability, including self/custom-build. The policies allow for infill and
small extensions in those parts of village clusters which have a settlement boundary.”
5.71 It is therefore questioned whether the approach being taken with the Village Clusters is actually
needed, or indeed is needed to the level of housing growth being proposed, when the approach to ‘windfall sites’ is being actively promoted through the GNLP as well.
5.72 The wording of Policy 7.4 refers to supporting a range of sites within Village Clusters. The policy
goes on to say this can be achieved by providing new sites, along with infill development in settlement boundaries, with additional sites being provided by affordable / market housing schemes.
5.73 This is in addition to the potential for ‘windfall sites.’
5.74 As a result, although this approach may appear commendable, it must be noted that this could also be unregulated. Unlike the Urban Area; Main Towns; or Key Service Centres, there are no specific allocations identified for some of the Village Clusters. Instead, there is a large pot of housing growth that still needs to be found. How can this be regulated, or equally proportioned
to make sure it meets the aim of supporting a mix of housing sizes and types across the Village Clusters? Is this not the purpose of the ‘windfall sites’ approach, which would be better suited to this purpose?
5.75 ‘If’ it is believed that the wording in the policy stating: “The cumulative amount of windfall development permitted during the plan period should not have a negative impact on the character and scale of settlements in any village cluster” is sufficient to control unregulated
growth, then surely this wording and the approach to ‘windfall sites’ is sufficient in its own right, and there is no need to identify such large numbers to Village Clusters in the first instance.
5.76 There remain grave concerns at the new approach the GNLP is now advocating within the Regulation 19 document, which has not previously been proposed.
5.77 It is therefore questioned how this approach has been reached, and on what basis it is considered to be the best approach to the distribution of housing growth as the spatial strategy for such a vast and widely differing area.
5.78 Welbeck Land therefore does not agree with the approach being taken towards Village Clusters, and it is suggested in the absence a proper and evidenced approach, then this strategy is totally unjustified and unsound.
5.79 The ‘Housing Comparison Table’ set out below, compares the housing identified between the various Reg 18 and Reg 19 documents (see attached representation).
5.80 It has considered the difference in existing sites and proposed allocations, and comments on the different approaches taken by the GNLP.
5.81 It should be noted that only the Broadland Village Clusters have been added and analysed as part of the ‘Housing Comparison Table’.
5.82 The South Norfolk Village Clusters are being calculated in their own separate document, that
forms part of the total 9% from Policy 7.
5.83 At the time of writing, the South Norfolk Village Clusters Housing Allocations Plan was looking
to identify 1,200 new homes across South Norfolk. Further consultation on the document is anticipated later in 2021.
Please see the full representations made by James Bailey Planning Ltd. on behalf of Welbeck Land in the accompanying document - section 7.4 village clusters.
Welbeck land strongly disagrees with the spatial growth strategy that is being proposed by the GNLP in the Reg 19 document.
The new approach being taken towards the Village Clusters is not supported and is considered to be both unsound and unjustified.
The identification of Village Clusters based on primary school catchment areas is also questioned as a suitable or sustainable approach to future planning growth.
At the same time, there is also a continued reliance on allocating undelivered, or stalled sites, which is also considered to be unjustified and unsound.
Overall, there appears to be no justifiable reason or rationale for the change from the approaches between the Reg 18(c) and the Reg 19 GNLP documents.
Please see the full representations made by James Bailey Planning Ltd. on behalf of Welbeck Land in the accompanying document.
1. EXECUTIVE SUMMARY
1.1 These representations have been prepared by James Bailey Planning Ltd. on behalf of Welbeck Strategic Land III Limited (Welbeck Land), with input from BasfordPowers, Sterling Transport Consultancy Ltd, Waterman Group, and Cannon Consulting Engineers. James Bailey Planning Ltd. are now instructed to represent Welbeck Land in this matter having inherited the instruction from Bidwells.
1.2 Welbeck Land have substantial interests in Wymondham in which they seek to promote large
scale development on the basis that the land represents a highly sustainable and suitable site for development.
1.3 These representations relate to the Greater Norwich Local Plan (GNLP), Regulation 19 PreSubmission Draft Plan document, February 2021.
1.4 They relate to the two parts of the plan, together with submissions on the legal compliance and soundness of the GNLP, both in terms of how it has been prepared and if it meets the prescribed tests of soundness.
1.5 While these representations consider all aspects of the GNLP, there is a specific focus on Section 5 – The Strategy, and particularly Policy 7 – Strategy for areas of growth. The representations concentrate specifically on the proposed growth for the Main Town of Wymondham.
1.6 In essence, the spatial growth strategy as currently being proposed by the GNLP Reg 19 is seriously questioned.
1.7 There are long standing sites that continue to be allocated that have failed to deliver over a number of years, and there is an unjustified growth being proposed towards ‘Village Clusters’.
1.8 The distribution of housing associated with the approach being taken in the GNLP Reg 19 document does not seem proportional or well considered or compatible with the requirement to promote a sustainable spatial strategy.
1.9 In essence, Welbeck Land consider that rather than solving any problems, this policy change creates additional new ones, notwithstanding the obvious difficulty of trying to judge whether the new “Cluster” allocations will be successful or not, when there is no indication where a significant proportion of them will actually be located.
1.10 Welbeck Land have continued to promote land to the north of Tuttles Lane East in the town of Wymondham (ref: GNLP0006) over a number of years, through the ‘Call for Sites’ requests, and then through previous stages of the emerging Local Plan.
1.11 It is suggested that the previous representations and submissions made to the earlier stages of the emerging GNLP, notably those at Reg. 18(c) stage previously submitted by Bidwells, remain relevant and should therefore still be considered as the document moves forward towards Examination by an Independent Inspector.
1.12 The Wymondham Area Action Plan (WAAP) was adopted by South Norfolk Council in October 2015. It identified a series of sites for the growth of housing, employment, and infrastructure. Delivery of some of the allocated housing sites remains a problem.
1.13 In March 2020, Wymondham Town Council submitted a Neighbourhood Area application,
designating the whole civil parish, which South Norfolk Council has confirmed. Progress on the Neighbourhood Plan remains unclear at the time of preparing these representations.
1.14 In summary, it is considered there is insufficient growth being proposed by the GNLP for Wymondham during the plan Period up to 2038. As an identified ‘Main Town’, there is also a weight of expectation that an appropriate level of growth will be ascribed to Wymondham, which has failed to materialise through the GNLP Reg 19 document.
1.15 It is believed that there are also mixed messages coming from the GNLP process. During the Reg 18(c) stage, Wymondham had a contingency identified for 1,000 new homes, however this has now been removed at the current Reg 19 stage. Conversely, Costessey (without comparable linkages or connections to Wymondham) had a contingency site identified at Reg 18(c) stage, which has carried through to an 800-unit contingency site in the Reg 19 document. This approach appears wholly unjustified and inconsistent.
1.16 There is also a large reliance on existing strategic sites being retained as allocations within the latest GNLP Reg 19 document, which have failed to be delivered over a number of years, such as the site at North Rackheath. This casts serious doubt not only of the delivery of these sites, but on the growth over the plan period. If allocated sites are not brought forward, then it will not be long before ‘hostile applications’ are made.
1.17 What is clear is that GNLP Reg 19 document appears to place an overreliance on delivery coming
forward through ‘windfall sites’, with a significantly disproportionate amount of housing growth being directed to the ‘Village Clusters’.
1.18 However, the South Norfolk Village Clusters Housing Site Allocations Local Plan is yet to be produced. Therefore, it is surely unjustified to place a reliance on a document that itself has yet to be tested.
1.19 The impact of Covid-19, and the knock-on effect of change in people’s habits, such as working arrangements and commuting patterns, is also considered within these representations. It is suggested that the current global pandemic is likely to have an impact on future housing growth, which the GNLP still has time to properly consider.
1.20 It is therefore believed that, although being positively prepared, the approach being taken to the spatial growth strategy across the Greater Norwich area is fundamentally flawed, and on this basis is therefore ‘unsound’ as it is neither justified nor effective.
1.21 To modify part of this deficiency, Welbeck Lane request that the land north of Tuttles Lane East, previously identified as a “reasonable alternative” in the Reg 18(c) document, be recognised as a formal allocation at Wymondham for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wymondham High School.
1.22 It is considered that identifying sites, such as land north of Tuttles Lane East at Wymondham, will help to provide a robust and proper planning approach to spatial growth. Allocating sites that prove their suitability; availability; and deliverability, in the most sustainable locations, will also enable the necessary infrastructure to be properly costed, programmed, and implemented.
1.23 In summary, the GNLP:-
• Over relies on long standing strategic site proposals, despite the knowledge from past history that some of them are unlikely to come to fruition within the Plan period;
• Introduces a change in policy direction to significantly increase reliance on development of small Village Cluster sites;
• Reduces the clear benefit to be gained from developing sustainable and available Main Town sites;
• Actually reduces proposals for certain Main Towns despite there being a clear expectation of new development;
• Is inconsistent in proposing certain Main Town sites to the detriment of other clearly more sustainable Main Town sites; and
• Proposes a spatial growth strategy that is fatally flawed, and therefore “unsound”.
1.24 Welbeck Land asks the Inspector to propose allocation of land to the north of Tuttles Lane
East for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wyndham High School. This action would go a long way to clarifying the clear deficiencies of the Plan as currently proposed and could easily be achieved without any need to delete other
current proposals.
1.25 The latest version of the Illustrative Masterplan for the site has been included as Appendix One.
1.26 A draft Statement of Common Ground has also been prepared to accompany these
representations and is attached as Appendix Two.
1.27 A Transport Working Note has been prepared to support these representations and is included
as Appendix Three.
THE NEXT SECTION OF THIS SUBMISSION IS SET OUT IN CHRONOLOGICAL ORDER AGAINST
THE GREATER NORWICH LOCAL PLAN (GNLP) REGULATION 19 PRE-SUBMISSION DRAFT PLAN
DOCUMENT FEBRUARY 2021.
See full representation attached.