Object

Representation ID: 24292

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation in particular sections 4.5.9 - 4.5.26, section 5.2, section 6.1 - Land at Norwich Common, Wymondham and section 6.2 - Land at Burston Road, Diss

Policy 7.2 – The Main Towns
4.5.9 Gladman on the whole is supportive of Policy 7.2 which distributes growth to the Main Towns of the Greater Norwich Area, recognising the need for these locations to accommodate growth and support the wider aims of the urban area.
4.5.10 The sustainability and suitability of both Diss and Wymondham as locations for further development is welcomed by Gladman. It is considered that the allocations made at both settlements through the Local Plan however is insufficient.
Wymondham
4.5.11 Wymondham is identified within the GNLP as a Main Town and has good transport links, including mainline rail services to Norwich, Cambridge and Stansted Airport. Wymondham is the main town serving the south-west of Greater Norwich and has potential to contribute to the development of the Cambridge Norwich Tech Corridor
. Wymondham is located at the
heart of the A11 Cambridge to Norwich Tech corridor meaning that the town should play an important role in fulfilling this economic potential over the plan period with further employment and housing land required. Despite its location, the GNLP only proposes to allocate 150 new homes to the Main Town of Wymondham.
4.5.12 The Regulation 18 Draft GNLP included the potential provision of a contingency site around
Wymondham for the delivery of up to 1,000 dwellings. Gladman note that the regulation 19 GNLP has removed the reference to a potential contingency site around the edge of Wymondham without providing justification for its removal.
4.5.13 Given previous comments made above relating to the quantum of development proposed to come forward in and around the Norwich Urban Area, Gladman question the inclusion of a contingency site around Costessey as opposed to Wymondham. If the market is failing to deliver homes around the edge of Norwich, providing further land for residential development
in the same location will not solve the matter. Taking this into consideration Gladman propose that the inclusion of land around Wymondham, where much needed education capacity can be provided on site, should be included within the GNLP.
4.5.14 Taking into consideration the comments made above in relation to housing need and the case for flexibility in planned levels of supply, should committed and other sites fail to come to fruition, Gladman believe that not only should a contingency site around Wymondham be included, but that the site should be allocated. Allocating the land for housing provides
greatest certainty that site can come forward without delay, is available and deliverable for housing and reduces the need for a future review.
4.5.15 In this regard, Land off Norwich Common, Wymondham represents a logical extension to the
settlement and should be further considered for allocation through the plan making process.
4.5.16 Gladman consider that strategic gaps should have been reviewed and revised through the plan making process of the GNLP. Since defined and last reviewed the context for each strategic gap is likely to have altered taking into account more recent development. Evidence
of this is clear in the case of the strategic gap between Wymondham and Hethersett. In recent years the character of the land at the north eastern edge of Wymondham along Norwich Common has significantly altered with new housing and employment development along the north of this road.
4.5.17 A thorough evidence-based assessment of all effected land parcels, together with wider related land has not been undertaken to consider whether strategic gaps remain a relevant and necessary designation to prevent the coalescence of settlements. As such, Gladman
contend that the inclusion of the ‘rolling over’ of the strategic gap policy without a review is not based upon up-to-date evidence and is therefore not sound.
Diss
4.5.18 Gladman is supportive of the identification of Diss as a Main Town within the settlement hierarchy. Diss has the widest range of shops and services of the main towns, as well as a broad range of employment opportunities. The town is located to the north west of the
junction of the A140 and A143 and benefits from rail connections to Norwich and London as well as acting as hub for local bus links. As such, the settlement forms a sustainable and logical location for further development.
4.5.19 Diss has a key role to play in supporting the surrounding villages and rural hinterland through
its services and facilities. The retail offering of Diss is key in this supporting role with the large rural catchment extending in to parts of South Norfolk and northern Suffolk. As such, Diss demonstrates positive vitality and viability and has the opportunity to support further housing growth. There would be strong justification to provide further growth than is currently proposed in Diss due to this strong retail offering and other services, along with the good transport links to Norwich and beyond.
4.5.20 In progressing from the Regulation 18 consultation draft of January 2020 to the now submission version currently being consulted, matters have taken a backward step in Diss. The proposed strategy is now one which seeks to defer to the allocation of housing sites to the
emerging Diss and District neighbourhood plan. One proposed allocation for 150 dwellings remains, with the emerging neighbourhood plan to determine the location of the remaining 250 dwellings to be allocated to Diss. In combination with the existing commitment of just
over 300 dwellings, from the base date of the plan period, this takes the total housing target for Diss to just over 743 during the plan period.
4.5.21 For one of the main towns, the most significant settlement in the south of the plan area serving a wide rural hinterland with the largest retail offer outside of Norwich, this is an insufficient development quantum.
4.5.22 Reasons stated for limiting the level of growth towards Diss are attributed to environmental constraints and traffic constraints, based upon local evidence. Gladman are promoting land south of Burston Road (GNLP4049). Assessed following the close of the Regulation 18 consultation, the site is recognised as suitable for further consideration (Diss booklet of sites
evidence base paper). Based on the concept plan prepared to date we have sought to address ‘amber’ scoring issues, summarised as townscape and landscape considerations, to show that environmental impact is not an insurmountable constraint. Therefore, the issue in bringing this site forward is not an environmental one but instead highlighted as highways. It therefore follows that environmental concerns cannot be a reason for limiting growth in Diss.
4.5.23 Instead, the limiting factor is considered to be purely a highways constraint. Recognising this fact, it is therefore considered inappropriate to leave the decisions around the majority of housing allocations of Diss to the emerging neighbourhood plan. Seeking to resolve the
highways issue in Diss is considered to be a strategic matter best tackled during the local plan making process, not through the neighbourhood plan. We would welcome allocations being left to the community to decide if this was in addition to a suitable quantum of development
steered towards Diss.
4.5.24 Paragraph 102 of the Framework is clear that transport issues should be considered from the earlier stages of plan-making so that potential impacts of development on transport networks can be addressed. Whilst issues have been identified it is considered that there is currently insufficient evidence to seek to limit the quantum of development directed towards to Diss
for these reasons. If this was such an insurmountable issue, referring site allocations to the neighbourhood plan, a mechanism inappropriate to tackle highways constraints is only likely to exacerbate the highways issue.
4.5.25 The Diss Network Improvement Strategy (April 2020) has identified a number of junctions requiring improvement and options for providing these improvements. It appears that little regard has been had for changing transport technology and usage over the plan period and how this could alleviate highways concerns. For example, as a longer-term impact of the
coronavirus pandemic commuting patterns may change allowing for further growth in one of the main towns where services and facilities are readily available, allowing development to be focussed in locations which are or can be made sustainable, as per Paragraph 103 of the Framework.
4.5.26 Instead, we are left to rely on a report which states that by 2036 the Morrison’s junction would be over capacity with improvements needed. Doing nothing to address this is therefore not considered to be an option. Other options assessed, and ruled out, to address this can be summarised as either a northern link road or southern link road. These are considered to be
extreme options which would cement commuting patterns rather than seeking to support a shift. Further testing should have been undertaken to determine a quantum of development that could be satisfactorily delivered without the need for new link roads. .. In this regard, further development than identified would be expected to contribute towards unlocking the necessary improvements identified.

5.2 MAIN TOWNS
5.2.1 Gladman supports the identification of Diss and Wymondham as Main Towns and submits that the sites we are actively promoting in these locations should be allocated to offer greater flexibility and to ensure that the housing need can be met over the plan period.