Object
Publication
Representation ID: 24440
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 6 of the Regulation 19 draft Greater Norwich Local Plan states that “sufficient employment land is allocated in accessible locations to meet identified need and provide for choice.” This is disputed. The preferred sites and existing allocations do not objectively address identified needs, and that the proposed approach is not justified or sound in accordance with paragraph 35 of the NPPF.
The reliance on existing allocations undermines the policy. The evidence base Employment Land Assessment Addendum 2020 states: “Certain potential sites are large scale brownfield sites which would require significant site clearance and remediation in order to prepare the site for new employment development, which could affect the viability of delivering any form of employment activity on the site.” There is a reasonable alternative site forming a small part of the original site GNLP0177-B which would help to ensure a greater choice of employment venue better suited to the current trend and need for accommodation of a smaller scale in accessible locations. It suffers no significant viability concerns due to contamination and other issues.
Furthermore, the greater Norwich local plan allocates only 54.2 hectares of employment land for the next 17 years. It is considered that this is an exceptionally conservative estimate and that greater amounts of land may well be needed for future purposes. As already shown through the events of last year during the pandemic it is important to have a choice of places of employment within easy reach of new and existing homes. As such the GNLP needs to be more flexible providing opportunity for new creative industries and encouraging diversity in typology as much as possible to weather future crises. Through the allocation of more employment generating land of the type proposed at the Racecourse Community Park (site GNLP0177-B ) it is considered that the Greater Norwich Local Plan would be more robust as well as the local economy being more resilient through the provision and facilitation of greater choice of employment space and new opportunities close to existing homes and a Park and Ride.
The Greater Norwich Local Plan relies significantly upon undelivered previously allocated land. This land amounts to 229.9 hectares of land, as of April 2018, which will have been undeveloped for multiple reasons. It is fair to assume that not all of these reasons will have been overcome, and other issues impeding delivery have arisen. As such, further employment land, particularly smaller sites, need to be allocated to address existing and anticipated needs as a result of recent trends.
Policy 6 also states that development should seek to enhance the environment and economy of centers and villages with more dispersed services to protect their function and avoid the loss of commercial premises or local services.
As part of the Racecourse Community Park (GNLP0177-B ) a large area of public open space is to be provided. This land not only offers a wealth of biodiversity enhancements but usable public open space that would supplement and enhance the provision offered to both Hethersett and Cringleford. Furthermore, this site would result in more dispersed services within an easily accessible location to both residential areas. As such policy 6 would in theory be supportive of this development coming forward. The small parts of this site proposed for build development would perfectly supplement the employment provision proposed as part of the current draft Greater Norwich Local Plan.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.