Object
Publication
Representation ID: 23661
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 7.2 The Main Towns (para. 345-370)
5.37 Wymondham is identified in the GNLP as a ‘Main Town’, (para. 345).
5.38 The vital role that towns play in the rural economy, is acknowledged, and supported. Indeed, Welbeck Land welcome the acknowledgement in the GNLP that “they are engines of rural growth and it is important that they are enabled to grow at appropriate scales, having regard
to infrastructure and environmental issues, to enable them to thrive.”
5.39 Wymondham has a population of approximately 14,500 people and is one of the County’s larger
market towns. It is the largest settlement in South Norfolk District. Wymondham is situated nine miles from Norwich and is well-connected to local road and rail networks.
5.40 Wymondham as a town is located to the south-west of Norwich. It is close to the A11 and is served by 2x separate junctions, with the B1172 dissecting the centre of the town.
5.41 Wymondham also benefits from having its own train station. It also has a series of education and health care facilities, and it also has a wide variety of shops, facilities, and other amenities. These are well documented in the adopted WAAP.
5.42 It can therefore be seen and agreed that Wymondham is a highly sustainable location. As such,
Welbeck Land are therefore happy to agree and support that Wymondham is identified as a ‘Main Town’ in Policy 7.2, and as per the settlement hierarchy.
5.43 It is interesting to note that the GNLP have identified 550 additional homes “to support the continued vitality of Aylsham and to locate an appropriate amount of growth in this main town” (para. 352)
5.44 Para. 358 raises concern with Diss as a location for growth: “While delivery of housing has been good in recent years, associated environmental constraints place limits on the potential for housing expansion. Local evidence111 shows that traffic constraints, particularly on Victoria Road, also reduce the potential for significant additional expansion.”
5.45 Therefore, despite having identified reservations about the ability of the town to delivery housing growth, the GNLP still sees fit to allocate 400 new houses to Diss.
5.46 Harleston is identified as having good transport links, and therefore has further allocations of 555 new dwellings across two sites.
5.47 It is notable that the GNLP has chosen not to make any allocations at Long Stratton at the Reg 19 stage, and instead are relying on the existing allocations through the Long Stratton Area Action Plan.
5.48 Para. 367 notes that a total of 150 new houses have been identified for Wymondham across the two sites in GNLP Reg 19 document. Further growth is reliant on the delivery of the sites within the Wymondham Area Action Plan.
5.49 The supporting text refers to several significant infrastructure benefits for the town of Wymondham. This includes the access to the ‘Cambridge-Norwich Tech Corridor’; the improvements to water capacity being proposed by Anglia Water; and the improved access to
the railway station.
5.50 As a consequence, it should therefore reasonably follow that with the suitability and sustainability of Wymondham, reinforced by the infrastructure referred to in the supporting text, Wymondham should accommodate a proportionally significant amount of the future growth for the ‘Main Towns’ as part of the GNLP.
5.51 Policy 7.2 identifies a total of 6,806 new houses towards the Main Towns, which is 14% of the growth during the plan period. This is made up of 5,151 of existing commitments and 1,655 new allocations. On this basis, 24.3% are new housing allocations.
5.52 The simple calculations above clearly demonstrate that there is a reliance on the existing commitments at both Long Stratton and Wymondham, both of which have Area Action Plans in place. In reality, many of the sites in these Area Action Plans have already failed to meet their
expected delivery timeframes, a fact that should surely bring into question the confidence in these sites.
5.53 It is therefore considered that there is a fundamental flaw in the continued reliance of the delivery of existing sites in these Area Action Plans, at the expense of properly considered growth across all of the Main Towns.
5.54 Aylsham, Diss and Harleston account for almost 91% of the new allocations in the emerging GNLP, whilst Wymondham and Long Stratton account for less than 10%.
5.55 Welbeck Land therefore strongly disagrees with the approach being taken towards the spatial distribution of strategic growth, especially across the Main Towns.
Please see the full representations made by James Bailey Planning Ltd. on behalf of Welbeck Land in the accompanying document - Section regarding Policy 7.2.
It is considered that the spatial strategy of the GNLP would be better suited to following a more traditional and sustainable approach to the distribution of growth through the agreed settlement hierarchy.
In the case of South Norfolk, Welbeck Land strongly suggest the site on land north of Tuttles Lane East, Wymondham (GNLP00006), should become an allocated site.
The site on land north of Tuttles Lane East, Wymondham (GNLP00006), has the ability to deliver more suitable and sustainable growth, whilst addressing the identified infrastructure issues and requirements of one of the GNLP's largest settlements.
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.