To ensure that strategic infrastructure can be provided through the development of the strategic sites identified in the Local Plan, and that specific sites do not bear a disproportionate burden of infrastructure provision, the policy should be amended to make provision for a reduction in other policy requirements, such as affordable housing, and the potential for CIL exemption, where appropriate, in order to ensure that developments required to deliver strategic infrastructure are viable.

In addition, it is considered that site specific viability appraisals should be undertaken for the strategic sites (1000+ units) to ensure that, notwithstanding the identified infrastructure requirements, the developments are viable, with the option for bespoke policy requirements and CIL arrangements for the sites if necessary. This approach would be in accordance with paragraph 005 of the Planning Practice Guide, and paragraph 34 of the NPPF, and will ensure that the local plan is deliverable over the plan period and, therefore, sound.

Comments on behalf of clients Hopkins Homes, Persimmon Homes, Taylor Wimpey regarding site GNLP0132 in Sprowston

The strategic objectives in relation to transport, education, energy, water and health infrastructure are generally supported. However, the Policy is not currently entirely sound, as certain elements are not justified, effective or consistent with national policy.

More specifically, the policy fails to acknowledge that the requirement to accommodate or deliver strategic infrastructure may have implications for the viability of some of the larger strategic sites. For instance, a requirement for an individual site to accommodate a large item of strategic infrastructure, such as a secondary school, which is required to facilitate growth in the wider area, and not just to meet the demand generated by the site itself, is likely to impact on the viability of that particular site in a disproportionate and unfair manner.

Such impacts have not been properly considered or reflected in the Viability Study that underpins the Regulation 19 Plan; this is at odds with paragraph 34 of the NPPF. Paragraph 005 of the Planning Practice Guide makes it clear that it is important to consider the specific circumstances of strategic sites, and that plan makers can undertake site specific viability assessments for sites that are critical to delivering the strategic priorities of the plan, such as sites that enable or unlock other development sites.