Object
Publication
Representation ID: 24354
Received: 22/03/2021
Respondent: Fuel Properties Ltd
Agent: Iceni Projects Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy 2 – Sustainable Communities
2.4 We support the aim of Policy 2 to promote sustainable communities and to ensure development is of a high quality and mitigates and adapts to climate change.
2.5 However, we are concerned that the current wording at Point 9 of the Policy is not sufficiently clear and would create uncertainty for developers and decision makers. In relation to water management and efficiency, the draft policy currently indicates that “if the potential to set more demanding standards [above Building Regulations Part G and BREEAM Very Good] locally is established by the
Government, the highest potential standard will be applied in Greater Norwich.
2.6 In our view, the above wording does not provide sufficient certainty as to how development proposals
should be assessed, as required by paragraph 16(d) of the NPPF, as it is currently unknown what future standards might be identified by Government. This would also generate significant uncertainty regarding the deliverability of development in Greater Norwich given any as-yet undefined future standards cannot be factored into the overall viability assessment supporting the Plan. As such, it is impossible to establish whether the requirement to meet any future standards would be viable or place an undue burden on developers in the local context and thus pose a risk to the delivery of development.
2.7 In order to ensure the soundness of the policy, we therefore recommend that this sentence is deleted.
In our view, any future standards that might be introduced by Government should be dealt with as part of a review of the Local Plan, when the relevant detail is available.
2.8 Furthermore, it is unclear how part iii of the policy relates to the requirements set out at Points 1-10
above. Given the second part of the policy (i-iv) seeks to set out measures to assist the approach identified in 1-10, the reference to delivery timescales does not directly relate to the requirements above which deal with sustainable and high quality development. We therefore recommend that this element be removed from the policy and dealt with elsewhere in the Plan if considered necessary. In terms of the general intention to ensure prompt delivery of a scheme, we support the broad intention to ensure developments progress in a timely manner, however we would emphasise the need for
flexibility within delivery plans to acknowledge various risks and factors that may delay the delivery of
a site beyond the control of a developer, and that there should be appropriate acknowledgement that
any such plans are illustrative. This would not affect the Local Authority’s legal powers including
compulsory purchase.
See attachment for full representation
See attachment for full representation
On behalf of our client, Fuel Properties (Norwich) Ltd, we provide our comments on the Greater Norwich Plan Pre-Submission Draft Strategy (Regulation 19 Publication Stage), published for consultation in February 2021.
Fuel Properties (Norwich) Ltd are the developers of the Carrow Works site in east Norwich, which is identified in the emerging Greater Norwich Local Plan as being within the East Norwich Strategic Regeneration Area. The wider Regeneration Area has the potential to deliver some 4,000 new homes and 6,000 jobs, and will act as a catalyst for longer term regeneration of the wider area. The Carrow Works site comprises an important and substantial part of the East Norwich Strategic Regeneration Area and provides a significant opportunity to deliver growth for Norwich City the Greater Norwich
area.
Our client welcomes the opportunity to provide comments on the emerging Greater Norwich Local Plan and to work collaboratively with the authority and key stakeholders as the plan progresses.
See attachment for full representation.