GNLP3053

The site has not previously been promoted for redevelopment for other purposes because it was an operational industrial site. There is a pressing need for new housing in Norwich and this brownfield site is ideally situated to make a significant contribution in a sustainable location which could lead to substantial townscape and access benefits.

The council’s affordable housing policy seeks 33% provision but many housing schemes are contending that the provision of affordable housing is not viable. A scheme will need to be subject to a viability assessment.

The site benefits from substantial heritage significance and a riverside location, there is an opportunity to create a whole new quarter around the heritage and open space assets.

I am supportive of this residential led allocation and its importance in unlocking the ENSRA. It has the capacity to deliver a significant number of affordable units alongside other uses which will result in a balanced and vibrant community ,however , this must be balanced with delivery which relies on commercial viability.
The delivery of homes within this allocation should not be disadvantaged by a "blind 33%" affordable housing contribution without regard to other affordable housing policies particularly with regard to encouraging brownfield development, CIL contributions, social value and community benefits.

Unlike other allocation policies there is no reference to water efficiency forming part of the design of this student accommodation.

Please also see comments relating to Policy 2 of the Sustainable Communities of the Strategy document.

Please see attached for full submission

For full representation, please refer to attached documents

Summary of main points

• Some sites in Norwich are on the riverside and we would like them to make the most of their riverside location.
• Reference to the Broads and its various documents would be welcomed in some areas.
• Some policy wording is not defined it seems and it may be useful to do so.
• Improved reference to show on maps and to say that part of the Utilities Site is in the Broads area, but that both LPAs will work together to bring forward East Norwich development sites.
• Consideration relating to peat and carbon rich soils.
• Consistency of wording in some policies.

Main document

General comments:
• Throughout you refer to ‘post-carbon economy’. Is this an obvious enough term? Is it defined well enough? Does it adequately cover climate change, mitigation and adaptation? Also, by referring to ‘carbon’ only, you do not seem to include other greenhouse gases. I wonder if the use of this term, throughout the document, needs checking to see if it is the most appropriate term for what you are trying to say. At the very least, an explanation of what it means would be helpful.
• Throughout you refer to ‘inclusive growth’. I do not know what this is. What is to be included in the growth? The term might be acceptable, but you may want to define it somewhere as what it actually means is not clear or obvious.
• BREEAM references: you refer to single issues of BREAAM (energy and water on their own) in the document. As part of my discussions with BRE, it seems that they do not recognise the use of single issues, but rather a whole scheme needs to meet BREEAM criteria. You may wish to contact BRE about this to ensure any policy approach is deliverable.

Detailed comments:
• Box, page 6, Para 4, last sentence: refers to some aspects being repeated. I don’t understand; what is repeated?
• Page 8, para 1: has the Broads Local Plan and Broads Plan helped influence the document? Should they be mentioned?
• Page 24, para 95: do you mean increases of between the two figures quoted in each bullet point? Adding the word ‘between’ might make it read better.
• Page 28 – you refer to the Broads as a National Character Area, but it has the status equivalent to a National Park and is a Nationally Protected Landscape. Please say those things in this section of the Local Plan.
• Page 29, para 105 – have you thought about addressing peat and other carbon rich soils in the Local Plan?
• Page 32, para 119. You mention houseboats later on in the document, but could that be mentioned here – along the lines of ‘working with the Broads Authority, so too will the needs of houseboats be met’?
Page 34, environment section of the vision – recommend you mention the landscape impact on the Broads and its setting.
• Page 35, Environment objective – what about the setting of these things?
• Page 38, climate change statement – have you thought about carbon rich soils like peat? Have you thought about heat, cooling and extremes of weather (not just the effect of flooding)?
• Page 46, a how does this split fit with what is said at para 132?
• Page 51, Policy 1, bullet 2 – what do you mean when you say ‘local level’?
• Page 51, Policy 1, ‘support vibrant communities’ – do you mean help ensure communities remain or become vibrant?
• Page 52, Policy 1, second para under table: where you refer to negative impact on the character of the settlement, it seems also prudent to refer to the area in general – for example to consider the impact on the Broads and its setting.
• Page 61, policy 2: The first paragraph ends with ‘as appropriate’ – what does that actually mean in terms of applying the policy? What does ‘sustainable access’ actually mean? ‘What are ‘local services’? Point 10 – would that standard be in place until a Government standard is put in place? Is that worth saying in the policy?
• Page 62, footnote 73 – is that policy wording? Or is that policy in the DM documents of the districts? If that is the case, you might want to clarify that.
• Page 66, para 193 – NSPF version 2 is not draft, it is endorsed. The emerging NSPF is version 3.
• Page 72, para 212 – refers to 2019. You might want to update this in the next version of the Local Plan.
• Page 76, policy 4, transport. You talk of non-car developments and high densities in Norwich. Other places like towns have good access to services and public transport – are they going to have non-car developments and high densities?
• Page 79, para 248 – support reference to the Broads Authority and houseboats – please add something like ‘…for residents of houseboats in the area, through policies that enable the delivery of residential moorings.’
• Policy 5 supporting text – is it prudent to say that the Broads Authority will have regard to/defer to the affordable housing policies of the districts and so this policy will also be used, in parts, by the Broads Authority?
• Page 81, Policy 5: The first para uses the term ‘should’ a few times – is that weak wording? Under affordable housing – does it matter that an applicant might say they are sub-dividing a site for another reason and so could do it? Is it more that sub-dividing is not allowed, and that is because some developers may seek to avoid affordable housing obligations? What is ‘good access’?
• Page 81, Policy 5: what is ‘sustainable access’? What are ‘ancillary uses’? Marketed for up to or at least 12 months? How should they be marketed?
• Page 83, para 1: ‘…tenures of homes within…’. Para 3, what are locations with ‘good access’ – we say within a development boundary. Another consideration for location of such facilities is how staff and visitors can access it. Para 5 ‘…encourages new sites…’
• Page 87, policy 6: What are ‘significant residential and commercial developments’?
• Page 95, map 9 – do you include the part of the Utilities Site that is in the Broads – suggest you do and maybe show it in another colour and amend the key accordingly.
• Page 99, para 2 – isn’t office to residential permitted development?
• Page 100 – East Norwich. Is the East Norwich Strategic Growth Area Masterplan SPD in place? How will the Broads Authority be involved in its production? Is that the same thing that is referred to in the next para before the next bullet points? Should you refer to, even if it is as a footnote, that some of the Utilities site is in the Broads and there is a policy in the Local Plan for the Broads for that and that is consistent with this policy and we will work together etc?
• Page 111, Para 346: ‘…as shown in appendix 5…’. What is ‘good access’? What is a ‘safe route’?
• Page 112, policy 7.4, final para above ‘employment’: what about impact on character of the nearby area like the Broads.
• Page 114, policy 7.5 – do you want to say ‘subject to other policies’? Does the approach contradict page 113 ‘..without breaching normal planning criteria and the sustainable site selection process’.
• Page 114 – is another alternative to not allow this approach?

Typo/grammar
• Box, page 6, Para 4, first sentence: ‘documents will be assembled and as part of the next stage…’
• Page 7, para 6: ‘This will ensure that Norwich continues to be both…’
• Page 24, para 91: ‘flood risk in new development, locating development the great majority of development away from…’
• Page 53, end of footnote 62: ‘…based on the feedback and for each site.’
• Page 56, para 173: ‘The Sustainable Communities policy are wide ranging’. ‘Community policies are’ or ‘Community policy is’?
• Page 57, densities row: ‘…for different parts of the area’
• Page 78, para 239 – ‘it also includes minimum…’
• Page 90, para 267, bullet iii: ‘the essential role that of the other parts of the urban area…’
• Page 93, top: ‘…of key city centre..’
• Page 114, para 350: ‘’’through policies other policies in this plan’

Sites Document

General comments
• Suggest bullet points are numbered for ease of reference.
• I have a concern that there is little translation of strategic ecological gain to site policies. For example I could not find any site specific reference to sites that are within the GNLP Green Infrastructure (GI) Corridors, despite some of the sites, for example around Acle, Whitlingham/Trowse etc being in the junction of major adjoining corridors. I would expect that in these major biodiversity intersections opportunities to enhance wildlife corridors would be highlighted on a site basis. When Net Gain requirement is introduced via the Env Bill will this be picked up at this point?
• Some of the allocations/reasonable alternatives are on or close to or on deep peat resource so it is relevant to include the treatment of carbon rich soils and reference to ‘net zero’ targets. Excavation of deep peat is a significant emitter of carbon into the atmosphere and thus should be shown to significantly influence site choice.
• We asked in the past about this, but it is not included in the documents that I can see. We safeguard former rail tracks from development for their potential future use as PROWs. Go to page 211: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0004/1581916/Local-Plan-for-the-Broads.pdf. Here is the map, page 3: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0008/1565837/SSTRACKS_RAILWAYS.pdf. Are you able to/have you included a policy to safeguard the land from development?

GNLP0068
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word ‘should’ seems to weaken the requirement. CC4b for example does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 5 – so will they provide a river side path? Or maybe do it? Part of the bullet says to do it and then the other says potentail future extension – suggest this is clarified. GNLP0401 equivalent bullet points implies the walkway/cycleway will be provided as part of the scheme. Is the scheme expected to provide the walkway/cycleway and to what standard?

GNLP0409R
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Bullet point 7 – so will they provide a river side path? Or maybe do it? Part of the bullet says to do it and then the other says potentail future extension – suggest this is clarified. GNLP0401 equivalent bullet points implies the walkway/cycleway will be provided as part of the scheme. Is the scheme expected to provide the walkway/cycleway and to what standard?
• Page 24, para 2 – so the policy refers to car free or low car usage, but the offices will have a car park; is that contradictory?

GNLP0401
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Where it says ‘respect its riverside location’ what does that mean? Could it make the most of its riverside location?
• Bullet point 2 – so will the development be on the existing car park?
• Bullet point 4 implies the walkway/cycleway/ will be provided as part of the scheme – but other policies are not that clear. Is the scheme expected to provide the walkway/cycleway and to what standard?

R10
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b for example does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 2 - implies the walkway/cycleway will be provided as part of the scheme – but other policies are not that clear. But then it says ‘should’ (which 0068 equivalent bullet point does not include) link to a future extension? This may need clarifying. Is the scheme expected to provide the walkway/cycleway and to what standard?

GNLP0360
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 1 – last part refers to not prejudice future development of or restrict options for the adjoining sites. But the Utilities site is over the river, so not adjoining. Should the policy refer to the Utilities site in this sentence as well?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• There appears to be no mention of protecting and enhancing designated / non-designated heritage assets. There is a listed lime kiln on the site and I think potentially some locally identified HAs.

GNLP3053
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 1 – last part refers to not prejudice future development of or restrict options for the adjoining sites. But the Utilities site is over the river, so not adjoining. Should the policy refer to the Utilities site in this sentence as well?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• There appears to be little mention of designated heritage assets and there are a number on site / immediately adjacent, including the scheduled and highly graded Carrow Priory, listed former industrial buildings and Carrow House on King Street and the site is within the Bracondale CA.

CC7
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Unlike other policies with a waterside frontage, the following wording is missing. Why is that? Could/should it be added?
o A scale and form which respects and takes advantage of its riverside context,
o High quality landscaping, planting and biodiversity enhancements particularly along the river edge;
o Protection of bankside access for maintenance purposes.

CC16
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Where it says ‘respect its riverside location’ what does that mean? Could it make the most of its riverside location?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• Reference is made to the Bracondale Conservation Area but there are Heritage Assets in the vicinity, including the schedule Boom Towers and I think listed buildings on the Carrow Works site / Papermills Yard site.

CC8
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Unlike other policies with a waterside frontage, the following wording is missing. Why is that? Could/should it be added?
o A scale and form which respects and takes advantage of its riverside context,
o High quality landscaping, planting and biodiversity enhancements particularly along the river edge;
o Protection of bankside access for maintenance purposes.

CC4b
• Could it make the most of its riverside location?

GNLP2137
• I note this is a reasonable alternative. If this is taken forward then we would welcome wording that covers the issues addressed above.

GNLP1001
• The site is on higher ground, close to our boundary and potential visual receptors: Wherrymans Way, the river, railway, Ferry Road and Reedham Drainage Mill.
• The site might also be visible from the opposite valley side but against a backdrop of existing settlement.
• There is a risk that new built development/housing, if not sensitively handled could have adverse impacts on the setting of the Broads.
• The possible landscape effects could be mitigated by low ridge heights, reduced scale/massing and screen planting.