Question 1: Please comment on or highlight any inaccuracies within the introduction

Object

Representation ID: 23068

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We have fundamental concerns with the draft Plan as it stands. These derive from the
Introductory sections of the Plan, and although our concerns do not relate to inaccuracies in terms
of what the Plan is to achieve, we are concerned with how the Plan itself aligns with the stated
position and its lack of alignment with the proposed policies. This is turn means that the purpose
of the Plan is not clear.

Paragraph 2 indicates that the GNDP have taken a long-term view of development needs to ensure
the development in the right place and at the right time. We contend that the GNDP has not
taken a long-term view or sought to locate development in the right place at the right time. As
is set out in further detail in response to Policy 1, the GNLP does not plan for sufficient housing
to meet the local needs in accordance with the National Planning Policy Framework (NPPF) and
National Planning Policy Guidance (NPPG). It does not take a long-term view in terms of the
growth of the Cambridge-Norwich Tech Corridor, and in policy terms, does little to encourage or
stimulate the success of the Corridor. This stance is not aligned with wider strategies and
initiatives, and therefore we consider the aim of the plan is undermined.

The Plan is not considered to identify sites to meet Greater Norwich’s growth needs from 2018 –
2038 sustainably. The preferred sites identified are not the most sustainable when compared to
reasonable alternatives and the Plan defers the allocation of sites for 1,200 homes to a future
‘Village Clusters’ Plan, which is discussed further in respect of Policy 1.

The introductory section sets out the context of other strategies which ‘provide the context for
development in Greater Norwich’. We agree with all of the initiatives and strategies referenced
but have grave concerns that this draft Plan does not align its growth strategy with them, as
detailed further below:
• Projects of national significance – improvements to A11 trunk road. This recently dualled
and important link between Cambridge and Norwich has been subject to substantial
investment. It is imperative that growth should maximise and support the investment
that has already been made. In this context allocating growth at SGV, with a new junction
on the A11 (funded by the development) would capitalise on these improvements, rather
than rely on significant and potentially uncertain future road improvements.
• Economic Growth – as is set out in Appendix 3 (Technical Review of Housing Need
prepared by Turley), we contend that the Plan does not make sufficient provision for
housing to meet the economic growth requirements.
• Transport Priorities including Transforming Cities – the recent Transforming Cities funding
bid includes allocation of funding for a mobility hub at Wymondham Station. The case
for investment should be supported through reaffirming Wymondham’s position in the
settlement hierarchy and its growth capabilities in this context. In accordance with
achieving sustainable development in line with the NPPF, the GNLP should align growth
locations with sustainable transport improvements. There is not sufficient recognition for
the growth potential of Wymondham, either in the context of the settlement hierarchy;
its location within the Tech Corridor; and its sustainable transport connections (with
planned investment). The GNLP should plan comprehensively for strategic growth at
Wymondham in this context and not simply provide for smaller scale sites incrementally.
• The GNLP indicates at paragraph 22 that there is a need for the Plan to look beyond the
current end date of 2038 by setting a strategy that can be sustainably added to in the
long term. This approach is not reflected in the policies contained within the plan. There
is, in fact, recognition that a new settlement may be needed in a review of the plan but
that the reason one is not to be allocated now is due to the long period for such
developments to establish (Paragraph 168 of the GNLP Strategy Document) . This wholly
contradicts paragraph 22. To plan ahead, the GNLP should be proactive in identifying and
allocating a new settlement to allow strategic scale growth to progress with certainty,
both for those responsible for its delivery and for the local communities affected.
• Paragraphs 24 - 26 indicates that a separate document is to be produced to allocate ‘small
sites’ across South Norfolk. This significantly undermines the purpose of the Plan by not
making clear how the Plan is treating its strategic policies in accordance with paragraphs
17 – 22 of the NPPF. These should make sufficient provision for housing (para 20) and
should provide a clear strategy for bringing sufficient land forward to address objectively
assessed needs over the plan period. We recognise that the NPPF allows for non-strategic
policies to be covered in a separately where they set out more detailed policies for specific
areas, neighbourhoods or types of development. However, the scale of growth attributed
to the Village Clusters document (at 1,200 homes) is considered significant in the context
of the relatively minimal new allocations made.
• Worryingly, it is also clear from the Interactive Mapping used by GNLP that it is not just
small sites that have been deferred for assessment in this separate plan. Some medium
to large scale sites across South Norfolk have also been deferred and therefore are not
assessed as part of the GNLP. Given that this is a Joint Local Plan, the approach of
preparing a separate document for just one constituent authority in isolation is not
considered a robust approach to plan making and risks making the GNLP ineffective. We
strongly consider that land for the 1,200 homes should be allocated within the current
GNLP: this is the only way to ensure growth options are considered holistically, particularly
in the context of infrastructure requirements.

Comment

Representation ID: 23096

Received: 31/03/2020

Respondent: Salhouse Parish Council

Please see our more detailed responses to the questions below, which make our concerns clear. In particular we have a major concern with the Draft Strategy as it makes no mention of using phasing for the delivery of new housing. We consider that any new sites allocated in the GNLP should be phased by being placed on a reserve list, and under phased development only built out when most of the existing JCS sites have been used. Inclusion of all the sites for immediate development will lead to developers “cherry-picking” the most profitable sites and newly allocated green field sites in less sustainable locations will be developed first, with even more land banking of currently allocated sites. In short, deliver the already allocated 82% of the 44,500 new homes, before giving permissions on the remaining 18%.
The current Local Plan, the Joint Core Strategy (JCS) was adopted in March 2011 with amendments adopted in January 2014: it has been in place for just over 6 years. When adopted, it was considered to be the blueprint for development in Norwich, Broadland and South Norfolk until 2026, and in doing so provided clear signals about where growth should and should not take place. In the introduction to the current consultation document it is stated that housing, jobs, services and infrastructure needs to be provided at the right time ‘and in the right places’. CPRE Norfolk questions how the response to this has changed so markedly since adoption of the JCS and well before that Local Plan was due to expire. In particular, the construction of the Broadland Northway (NDR) (noted in paragraph 7 of the introduction) was largely intended to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle. Moreover, there was a clear focus for housing and other growth to be in and close to Norwich, with minimal new development to be permitted in the rural policy areas of Broadland and South Norfolk. The GNLP strategy seems to be contradicting the direction of travel envisaged in the JCS and appears to undermine the planning process. A great strength of the JCS is the protection it gave to the rural areas: this seems to be sacrificed in the GNLP Draft Plan.
Paragraph 6 of the Introduction is clear that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’ It will be difficult if not impossible to meet these targets if new housing to the scale proposed in the draft strategy is dispersed across the rural areas of Broadland and South Norfolk. The main justification for this appears to be the availability of primary school places in the “village clusters”, whereas there are more important measures for sustainability which should be taken into account, including the number of car journeys and journeys by delivery vehicles to new housing, along with the associated congestion such vehicles will result in.
The introduction mentions in paragraph 25 that South Norfolk District Council will draw up its own South Norfolk Village Clusters Housing Site Allocations document. CPRE Norfolk is very concerned that by adopting such an approach this allocations document will not receive the same level of scrutiny as the main draft strategy document. We are also very concerned that the number of additional dwellings on top of the existing commitment of 1,349 houses is given as ‘a minimum of 1,200’. The use of the word ‘minimum’ is unnecessary and potentially very alarming, as in effect this gives no limit to the maximum number of houses which could be allocated in those “village clusters”. Given the draft plan provides enough committed sites ‘to accommodate 9% more homes than “need”, along with two “contingency” locations for growth’ (page 37) and does not include windfall developments in its housing totals, the word “minimum” should be replaced with “maximum” or “up to” as is the case with the figures for Broadland’s “village clusters”. Why is there this discrepancy in language between two authorities which are part of the same Local Plan: it appears to be inconsistent and illogical.