GNLP0102

Thank for giving us the opportunity to consult on your proposals for the sites in the Diss area.

The Town Council has been working with the Diss and District Neighbourhood Plan Steering Group comprising the parishes of Brome and Oakley, Burston and Shimpling, Diss, Palgrave, Roydon, Scole and Stuston on the emerging plan, which we expect to consult on later this year. In addition we have worked with consultants AECOM who have advised and helped us develop our evidence base on Housing Needs, Design and Design Codes and also Site Assessment. It was interesting to note that AECOM considered that all the Diss and Neighbourhood Plan area to be rural in nature, a fact they felt should be fully considered in the site densities we allow.

Whilst we agree with most of your recommendations for the sites in the Diss area, there are a few we would like to consult further on. All the GNLP sites were discussed in Council on 19th February 2020 and our recommendations were approved unanimously.

Please see attachment

Please see attached

The GREATER NORWICH Regulation 18 Consultation 2020
PROPOSALS FOR DISS

Whatever the merits of the Greater Norwich Local Plan for Norwich there are few for Diss. The clue is in the name. It may stretch credulity to include Long Stratton in Greater Norwich, but the reasons for doing so cannot include Diss, and do not try. The local plan provisions for Diss are in no way recognisable as a creative and workable plan. They are a recipe for the decline of Diss’s role and regional centre as a historic market town. Consultation 18 divorces Diss from its essential support settlements and, despite the gnlp political introduction, there are no housing-matching specific plan proposals for new jobs, supporting infrastructure, schools, roads, health care, Proposals and consultation are limited to a bureaucratic scatter of housing sites without context, an exercise in allocating housing numbers simply to achieve a total, leading to added settlement girth within restricted boundaries, a kind of planning obesity, creeping encroachment on agricultural land and a lottery allocation of added wealth for selected peripheral land owners.

WHY DOES THE GNLP (particularly Regulation 18 proposals) FAIL TO LIVE UP TO THE TITLE OF A LOCAL PLAN?
It fails to link Diss to its surrounding support villages. It specifically severs proposals for those settlements from its proposals for Diss, which as a market town relies on its surrounding villages as they rely on Diss. No plan for Diss as a market town commercial and social centre can be relevant if it limits its consideration to its parish boundary and treats surrounding settlements in separate categories of ‘Service and ‘Other’. These settlements need planning as an essential element of a Greater Diss.

It fails to grant Diss the same growth zone considerations applied for Norwich. Diss may be far smaller than the County capital, but it has its own integral support and growth zone and no Local Plan should ignore that context. Diss parish of some 7,500 has a population hinterland of 50-70,000 dependant on the commercial or social attraction. A simple mid-distance hinterland virtually fills a ten mile circumference, a weighted gravitational assessment on population (2012) in competing centres reduces that hinterland to the north, west and south of Diss to five miles circumference. The audience support for Diss Corn Hall (2015) shows the ‘reach’ of Diss into the myriad of its surrounding Villages and Hundreds beyond the ten mile circumference. A local plan needs to take this hinterland into consideration and treat it as an integral element of Diss’ future.













Hinterland assessments
By travel, at settlement mid-points By population gravitational weighting By Corn Hall Audience 2015

It fails to acknowledge that Diss, the sole centre in the County other than Norwich, has a rail station providing a swift link direct to the heart of London’s financial centre. This already attracts significant commuter traffic. For 30 years this pattern of home/work commuting has greatly increased, will continue to be a potent urban generator, but has not been built into the parameters guiding the plan.

It claims to relate a confetti allocation of dwelling consents to primary school access, with a child’s pedestrian link to a primary schools set as the criterion for a new housing site. But it fails to assess the need and thus location for new Primary Schools. The plan accepts existing catchment areas and assumes the existing schools can accommodate all children from new housing. Or, indeed for any new social services. It is not a plan, it is a housing numbers game.
It mentions but fails to resolve the traffic difficulties of Park Road and Victoria Road Diss, ignoring the need and potential for a hinterland bypass link between the A143 and A1066. There are no proposals for infrastructure to support the allocated housing sites, nor analysis that road, water, drainage and communication capacity will be available.

It fails to provide any Action plan or proposals for Diss Town Centre. It has no proposals for the linkage of the Diss Park to the proposed Waveney riverine parkland. It fails to mention the town centre and the increasing number of empty commercial properties let alone attempting to adopt plan policies that will help the centre to survive.







Empty properties in the Diss Heritage Triangle and Market
Place. There are further significant vacancies down Mere Street


It still continues retail use amongst those approved for Sites DIS 6 & 7, (Committed Sites up to 2018) despite the rejection of retail warehousing use on appeal for Diss 7 and the accepted deleterious impacts retail development that it would have had have on existing traders and Diss’ historic town centre. The Development Management Committee in refusing consent may have hid behind the fact the site was on the periphery of a conservation area, but the inspector recognised the adverse economic impacts it would have had. This review of the plan should take the opportunity to change the approved uses for committed sites.
















It continues the cult of ‘borderism’ that has plagued all plans in the past, accepting that plan responsibility ceases at the County boundary and thus fails to acknowledge the Diss Town Council and Mid-Suffolk’s efforts to establish a Neighbourhood plan that includes those zones that form part of Diss’ hinterland south of the River Waveney. For planning purposes a ‘Greater Diss Growth Zone’ paralleling the Norwich approach should include the core parishes of the emerging Neighbourhood plan … Diss, Roydon, Burston & Shrimpling, Scole, Palgrave, Stutson and Brome and Oakley. This, at least, would provide some logical context for a comprehensive plan that includes housing as but one of its elements.








A POSSIBLE DIFFERENT APPROACH FOR THE DISS AND EYE SPATIAL REGION.



















These two diagrams compare the planning base for Greater Norwich as set out in the 2010 Key Diagram from the Joint Core Strategy with that for the south of the District and north Mid-Suffolk. That for Greater Norwich seeks to take into account a broad range of plan elements. That for the south of South Norfolk is a collection of parishes each treated separately and has no planning relevance whatsoever.















Rather than using this parish patchwork as a series of boxes within which to allocate peripheral housing additions to each settlement an extension of the JCS Strategy approach for the Norwich Growth Area would be to attempt a similar consideration of the needs of a planned axis between Diss and Eye. This would entail the establishment of a joint South Norfolk-Mid-Suffolk development and implementation unit, difficult but possible, and would provide for a matching basis of plan consideration across the county boundary. It would also permit a more imaginative and attractive solution to housing provision to include, perhaps, a new high-density yet garden village community.

COMMENTS ON REGULATION 18 ‘PROMOTED SITES’
Housing Sites:
GNLP0342 and 0250
Specific provision should made at the outset to restrict the housing site area so as to identify, allocate and gift adequate extra land for Diss cemetery and the link road, not leaving these needs contingent on planning conditions.
GNLP0102, 0185 and 1054
It is inappropriate to squeeze housing into the middle of an employment site and adjacent to a railway. The site should remain in employment use. Diss needs more land designated for employment use and a policy to generate new work opportunities.
GNLP0341 (Parish Fields)
A strictly limited number of dwellings might be permitted provided they were designed specially for the site and, as public benefit for the use of land designated as ‘Important Local Open Space to be retained’, the remainder of Parish Fields were deeded over to Diss Town Council and developed as a public park.
GNLP0599, 1044, 1003
None are currently designated for the next plan period, but should they be considered they need to be designed and built as part of a special Walcot Green village design with its own open surrounds, not treated as added Diss girth.

Site Commitments up to 2018
DIS 3
This critical, if small, site on the edge of the A1066 has high visual impact. It may look convenient on a map to complete zoned residential to a straight line, but this is desk-planning with little regard to the actual look and feel of the land. The site needs to revert back to open space so as to emphasise and not diminish the value of the landscape gap between Diss and Roydon and to avoid allotments butting up against housing. A planted woodland strip along the this edge of housing land would be beneficial to the look and character of the town.
DIS 6
Retail use should be deleted from the sui generis approved uses for this site and compulsory purchase made of the ‘ransom’ strip on the ‘Morrison’s internal roundabout so as to allow traffic to access DIS 6 (and the bus station) from the internal Morrison road approach. Provision should be made for a landscape walk connection from the bus station south to DIS 2, to include a walkway strip alongside the electricity sub-station.
DIS 2 & 7
Retail use should be deleted from the sui generis approved uses for DIS 7 and effort made to help relocate the feather factory and to create a landscape connection between the Diss Town Park and DIS 2.

SUMMARY
The GNLP may or may not deliver a sufficient supply of homes for the next plan period. But it fails to do more than generally acknowledge primary criteria under the JCS for future economic, social or environmental objectives and their impacts on Diss and its surrounds. It fails to identify how the proposed number and location of new homes will relate to the Diss of the future. There are no plan specifics to ensure the vitality of the town centre, nor any consideration of how such housing will promote a healthy and safe community. No proposals deal with the need and provision of sustainable transport or high quality communication. There is no recognition of the importance of the rail link, or proposals for better linkage between station and town. The housing provision, site by site, may have associated provisions affecting their layout (no mention is made of design quality) but these remain subsidiary and ancillary to each housing designation, rather than satisfying broader policies. The Local Plan Consultation 18 restricts itself to sites for new housing, lacks a full and realistic context, is devoid of policies to ensure well-designed places or conservation of natural and historic assets and environment and without these fails to meet the requirements set out in the National Planning Policy Framework.

Conversion of this site to residential development would be contrary to the need to retain land for employment purposes. Although effectively a brownfield site, the temptation to introduce further high density housing in this area, where first families will want to extend or sell, should be resisted. Residential development of this 3.6ha (plus 1.01 ha for GLNP0185) in Diss is unjustified.

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.

Thank you for consulting Norfolk Wildlife Trust on the draft Greater Norwich Local Plan. We have attempted to comment wherever possible in response to the questions set out in the consultation, but have a number of comments which cover multiple policies or supporting documents and so have compiled our comments in this letter.
See attached for full submission

We write on behalf of our client, Frontier Agriculture Limited (‘FAL’), in relation to land west of Sandy Lane, Diss (‘the Site’).

We hereby provide our client’s representations to the current Regulation 18 consultation on the draft Greater Norwich Local Plan (‘GNLP’) in relation to the Site. These representations follow submissions to the previous Call for Sites exercise by our client.

This correspondence provides our client’s representations to the current consultation in order to assist the production of the new Local Plan. We would however welcome the opportunity to meet with Officers in due course, in order to discuss the enclosed comments in more detail.
The Site
By way of background, FAL is the landowner and occupier of land west of Sandy Lane, Diss (‘the Site’), which extends to circa 3.6ha.

The Site is located within the defined Development Boundary for Diss, is adjacent to Diss Railway Station and is accessible by a range of transport modes. The Site is currently occupied by a range of B Class uses associated with our client’s operation, which include a seed processing plant, crop protection store, grain store, and a grain and seed laboratory.

The Site is fully controlled by FAL and there are no significant constraints to its future development.
General Comments
The National Planning Policy Framework (‘NPPF’) requires all Local Plans to be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally.

Local planning authorities should positively seek opportunities to meet the development needs of their area and Local Plans should meet objectively assessed needs with sufficient flexibility to adapt to rapid change.
They should be consistent with the principles and policies of the NPPF, and should be aspirational but realistic to address spatial implication of economic, social and environmental dimensions.

As the GNLP emerges, it is important that it adheres to the requirements of the NPPF in positively promoting
new development across the Local Plan area.
Site Specific Allocation.

The Site is proposed to be allocated for development in the emerging GNLP under Site Specific Policy GNLP0102 (‘the Policy’). This identifies the Site as being suitable for at least 200 homes of which 33% are
intended to be affordable.

Our client fully supports the principle of the allocation of the Site for comprehensive redevelopment. The
intensification of the development capacity of the Site reflects its sustainable location, accessibility and
deliverability within the emerging Plan period. The redevelopment of the Site can help to meet strategic
objectives in terms of residential or employment floorspace within the GNLP area.

Our client does however have a number of comments in relation to the specific requirements of the Policy,
which are detailed further below. We also comment on the Site Specific Policies in relation to nearby sites,
where relevant.

Proposed Land Uses
Whilst our client supports the proposed allocation of the Site for residential development, we consider that the
Policy should also include flexibility to support redevelopment for employment uses (Class B). This would reflect the existing and established land use and would still provide support for appropriate intensification should residential development not be realised. Given the existing use of the Site, such development would be an appropriate alternative use of the Site and acceptable in land-use terms.

The Policy should be amended to include flexibility and support for both residential or employment land uses.
This would ensure the Plan is positively prepared and will make the most effective use of previously developed
land.

In terms of the proposed allocation for residential development, we have the following comments:
 Number of Homes: The Site is identified for development of at least 200 homes. Whilst our client
supports the general approach to the Site and the acknowledgement of its significant potential in terms
of development capacity, the Policy should remain flexible. The specific number of homes is a useful
indicative figure for the development capacity of the Site but it should not be set as a minimum threshold
given the embryonic stage of redevelopment.

Flexibility would reflect the need for an appropriate masterplanning exercise to be undertaken in order
to determination an appropriate quantum or range of dwellings that could be accommodated. For example, it may be that following this exercise, the Site is considered more suitable for a lower quantum than set out in the Policy, depending on site specific design requirements and an appropriate housing
mix.
It is therefore recommended that the Policy be amended to allow for flexibility as to the precise quantum
of homes that could be delivered on the Site. Whilst the capacity of 200 homes can be maintained
within the Policy, this should be as an indicative capacity figure and not a minimum requirement which
may be unduly restrictive.
 Affordable Housing: The viability of the Site and any future redevelopment scheme is unknown at
this stage. Given the historic employment use of the site, there is the potential for increased costs
linked to matters such as remediation. In order to maximise the potential of the site through comprehensive redevelopment the site specific policy should not impose specific requirements linked
to the deliverability of affordable housing in percentage or unit terms.
Any future redevelopment of the Site for residential land uses would be subject to the primary policies
relating to affordable housing within the wider GNLP. It follows that an appropriate level of affordable
housing can be determined at the application stage subject to appropriate viability evidence.
A flexible site specific policy would ensure a viable development scheme can be prepared and
promoted. That would ultimately ensure the full development capacity of the Site can be realised which
in turn would deliver the maximum amount of affordable housing to help meet the requirements of the
GNLP.

Specific Matters
The Policy goes on to list eight ‘specific matters’ that any development of the Site is expected to address. We
comment on a number of these specific requirements below:
 Station Car Park Expansion: The 4th bullet point of the Policy suggests that any development
should“…safeguard land to expand the car parking facility at the train station”. No further details are
provided and it is unclear if the intention of the Policy is to either i) ensure that development of the Site
does not prejudice the ability of adjacent land (i.e. outside of the Site) to be used for additional car
parking; or ii) if there is an expectation that land within our client’s ownership should be utilised.

If the latter is intended, then we wish to object to that specific requirement, given that it is not necessary
to achieve appropriate development of the Site. There is no specific requirement or policy justification
for an expansion for the station car park onto the Site, and due to the Site’s location immediately adjacent to the station, it’s development would not generate a
requirement for additional station car parking. Finally, such an approach would reduce the ability to deliver an appropriate quantum of residential development on the site.
If an expansion of the car park is required it would be more appropriately located on land allocated
under Policy DIS 8, which adjoins Station Road. That site adjoins the main station access and would
provide a more coherent form of development.
The Policy should therefore be amended to either i) remove the 4th bullet point in its entirety, or ii)
amend the requirement to clarify that redevelopment of the Site should not prejudice the expansion of
the station car park on adjoining land (i.e. outside the boundary of the Site).
 Widening of Sandy Lane on Frontage: The 5th bullet refers to the widening of Sandy Lane to a minimum of 5.5m along the ‘extent of frontage’. Whilst our client has no objection to incorporating the widening of Sandy Lane into the Site as part of any future development, for the avoidance of any doubt, this should be reworded to clarify that the widening relates to the ‘extent of the site frontage’.

The Policy cannot require the redevelopment of the Site to deliver widening along the entirety of Sandy Lane.

Provision of Footway on Site Frontage: The 6th bullet point of the Policy refers to the provision of a 2m wide footway at the Site frontage, extending northwards to connect with Frenze Hall Lane. Whilst our client would expect the site frontage to include an appropriate footway, it is not considered that there is justification for an extension northwards to Frenze Hall Lane. It is expected that development of the Site would include pedestrian routes to ensure links towards the Railway Station and Station Road, which in turn provide the main pedestrian routes towards existing facilities in Diss. This includes the shared pedestrian / cycle route along Victoria Road and which provides appropriate accessibility for users.

The Policy should be amended to remove reference to the extension of the footway north beyond the Site frontage.

It is also noted that the Local Plan proposes to carry forward the DIS 9 allocation, which includes delivery of improved footpath links to the town centre and railway station. It is recommended that this policy be reworded to incorporate the widening of Sandy Lane into that site in order to continue to widening of Sandy Lane north (i.e. as proposed under the 5th bullet of Policy GNLP0102) and to allow wider improvements along the road in order to link in with those proposed along the frontage of our client’s Site.

The above matters will ensure that the emerging Local Plan is appropriately formulated to ensure the future development of the Site can be delivered in an appropriate manner, whilst allowing for reasonable flexibility.

Summary and Conclusion
We trust that these formal representations will be afforded the appropriate weight by the LPA and assist in the formulation of the emerging Greater Norwich Local Plan.
Frontier Agriculture Ltd supports the principle of the allocation of the Site, subject to the detailed considerations as set out above. We would welcome the opportunity to discuss the contents of this letter with Officers in due course. The Response Form has also been completed and is included with this correspondence.