Question 2: Is the overall purpose of this draft plan clear?

ludricious putting in more houses in wortwell when we dont have the infrastructure its over crowding the the schools and the doctors when we already struggle to get a single appointment its going to devalue properties in wortwell this villiage is a retirement villiage what are you trying to do to this local community just creating massive problems with more houses and low cost we moved out from a new housing estate because the low cost created burglaries, drugs,and misbehaving do not pass this you will destroy this retirement villiage and loose all the residents build near towns not villiages.

Sustainability has to be the key word: in energy consumption; in transport; and in the environment. It seems that the plan, in principle at least, has these three elements embedded in it. The proof will be in the detailed implementation, of course.

The purpose of the plan is clear for those who have some background in the process, however I am sure for many lay people it must be difficult to understand the terminology. Whether the ideals can be met is of course another question.

All looks fairly clear in spelling out the reason for the plan.

What seems abundantly clear is that the current strategy favours developers' profits over the real needs of the community. Environmental protection, while given lip service is, in reality, largely ignored. The large number of new vehicle movements that would be generated by the "village clusters" idea, based as it is on false infrastructure assumptions, is a prime example of this conflicted strategy.

Para 22 "we also need to look beyond the end date" this statement assumes that additional growth is required and that planning for the future follows the patterns of the past twenty/thirty years. with more national resource assets lost to infrastructure and development Planning should be placing a much higher defence barrier against the continuing loss of habitat and agricultural resource and providing an even stronger requirement for zero carbon development/retrofit. A resource efficient circular economy.

Major conflicts and tensions in the overall plan purpose between growth in homes, jobs and infrastructure and achieving sustainable development. Eg how will plan contribute to net zero carbon by 2050 or moreover to the County Council's environmental policy to achieve carbon neutrality by 2030 and at the same time support road investment programmes?
Joint Core Strategy failed to deliver sustainable development - eg transport's share of carbon has increased; the NDR was delivered but not the bus rapid transit system promised; and inadequate numbers of affordable homes were built. GNLP offers more of the same.

No As a parish council we have found this whole document a difficult and less than easy document to navigate. We feel it has not been written in a way that will attract a high level of public comment. We feel that the inspector viewing this document should not accept its content and have it rewritten so that the community can engage with it. The web portal is difficult to navigate and is of poor design to encourage all members of society to engage with the questions being asked.

The notion of an integrated three council plan is clearly logical. Unfortunately the contents of the plan does imply a bias in favour of developers and pay little if any attention to residents, place and, critically, the environment and no attempt to consider seriously the carbon footprint of the plan. The focus is on housing provision rather than overall planning of a sub region. The housing targets are significantly in excess of that which is required and contains reference (at page37) of two additional contingency locations.

The overall purpose of the plan is generally set out clearly within the introduction. However, Lanpro make the following observations and suggestions:

a) It would be useful if the base date of the plan was set out in the introduction as well as the end date of 2038 to save hunting for this in the document.

b) The commitment in paragraph 5 to “build on our strengths” and particularly “to help turn our world class knowledge and ideas into world class jobs, particularly in sciences and biotechnology, agri tech, food and drink, information and communication technology (ICT), digital creative industries and high-value engineering” is supported.

Our concern is whether this commitment will be achieved through the preferred growth strategy and particularly whether the allocations for housing and employment are adequate and in the right place to achieve this goal. We will expand upon this point later in our representations.

c) Paragraph 9 rightly recognises that upcoming bans on fossil fuels in homes and cars will become major factors affecting development through the plan period, particularly in relation to energy policy and transportation. Our concern is whether this is a clear reflection of what the preferred growth strategy will actually help achieve, particularly with regard to transportation. We will expand upon this point later in our representations.

d) Paragraph 12 identifies important strategies and initiatives including the LEP’s Norfolk and Suffolk Economic Strategy (2017) and the Cambridge-Norwich Tech Corridor initiative (2018) both of which have been signed up to by the Greater Norwich local authorities. Lanpro suggest that greater clarity is needed on how the plan knits together with and supports these strategies in a meaningful way.

e) Paragraph 13 refers to the Greater Norwich City Deal Growth requirements agreed with Government in 2013 being met through the Greater Norwich Local Plan. The introduction should explain what the City Deal requirements are in terms of numbers, otherwise the reference is meaningless to readers, particularly the general public. Either in the introduction or elsewhere in the document should be an explanation of how these numbers have been accounted for in the overall housing requirement. This is currently unclear within the document.

f) An approach as set out at paragraph 22, that looks beyond the end date of the plan by setting a strategy that can be sustainably added to in the long term is important and is supported in principle.

g) Paragraph 24 explains that new allocations on small sites in South Norfolk villages are not included in the document. Paragraph 25 states:

“In South Norfolk there are more villages clustered around more primary schools. South Norfolk, therefore, intend to prepare a separate village clusters plan covering new sites for small scale housing in the rural parishes that collectively form primary school clusters.”

This statement does not provide clear reasoning for the omission of these sites from the draft plan at this stage. Firstly, it does not explain “more villages” in comparison to where, or what. It also doesn’t justify why even if there is more primary school clustering in South Norfolk than presumably Norwich or Broadland, this should be the deciding factor in determining the growth strategy for South Norfolk. The Cambridge-Norwich Tech corridor runs through South Norfolk District and paragraph 5 of the introduction puts the focus on planning to and building on our strengths, particularly referencing the Cambridge-Norwich Tech Corridor and its high value jobs. It would, therefore, make much more sense if this was a main consideration in the choice of locations for housing within South Norfolk.

A clear justification is needed if a strategy of significant dispersal (as proposed at present) to small sites in the rural area and towns like Diss and Harleston is to provide the focus in South Norfolk, otherwise it is difficult to understand how this can be a sound approach. It places doubt upon the intent in paragraph 5 to build upon the strengths identified therein and also upon the delivery of the Vision for Greater Norwich in 2038 set out in paragraph 108. This states:

“by promoting this Greater Norwich Local Plan our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech corridor.”

An explanation should be provided as to how the number of 1200 homes (15% of new allocations) can be relied upon on small sites in South Norfolk when the sites have not yet been identified or assessed.

We consider that it is premature to ask stakeholders to comment on the acceptability of an overall growth strategy for the next 20 years, when 15% of the new allocations are missing. We appreciate the intent to get on with producing the plan, but these sites form a fundamental part of the overall strategy and without identification of these, the strategy is clearly not sound.

There is a stated objective to protect our environment and habitats and create new green spaces. I am unable to locate any initiative within the plan which achieves this. The insistence on “full dualling” of the A47 is in direct opposition to such an objective.As far as I can deduce from map 4 in section 2 Most of the remaining “major habitat sites in norfolk” will soon be flooded so where will these species be relocated to?

The overall purpose of the plan is generally set out clearly within the introduction. However, Glavenhill Ltd make the following observations and suggestions:

a) It would be useful if the base date of the plan was set out in the introduction as well as the end date of 2038 to save hunting for this in the document.

b) The commitment in paragraph 5 to “build on our strengths” and particularly “to help turn our world class knowledge and ideas into world class jobs, particularly in sciences and biotechnology, agri tech, food and drink, information and communication technology (ICT), digital creative industries and high-value engineering” is supported.

Our concern is whether this commitment will be achieved through the preferred growth strategy and particularly whether the allocations for housing and employment are adequate and in the right place to achieve this goal. We will expand upon this point later in our representations.

c) Paragraph 9 rightly recognises that upcoming bans on fossil fuels in homes and cars will become major factors affecting development through the plan period, particularly in relation to energy policy and transportation. Our concern is whether this is a clear reflection of what the preferred growth strategy will actually help achieve, particularly with regard to transportation. We will expand upon this point later in our representations.

d) Paragraph 12 identifies important strategies and initiatives including the LEP’s Norfolk and Suffolk Economic Strategy (2017) and the Cambridge-Norwich Tech Corridor initiative (2018) both of which have been signed up to by the Greater Norwich local authorities. Lanpro suggest that greater clarity is needed on how the plan knits together with and supports these strategies in a meaningful way.

e) Paragraph 13 refers to the Greater Norwich City Deal Growth requirements agreed with Government in 2013 being met through the Greater Norwich Local Plan. The introduction should explain what the City Deal requirements are in terms of numbers, otherwise the reference is meaningless to readers, particularly the general public. Either in the introduction or elsewhere in the document should be an explanation of how these numbers have been accounted for in the overall housing requirement. This is currently unclear within the document.

f) An approach as set out at paragraph 22, that looks beyond the end date of the plan by setting a strategy that can be sustainably added to in the long term is important and is supported in principle.

g) Paragraph 24 explains that new allocations on small sites in South Norfolk villages are not included in the document. Paragraph 25 states:

“In South Norfolk there are more villages clustered around more primary schools. South Norfolk, therefore, intend to prepare a separate village clusters plan covering new sites for small scale housing in the rural parishes that collectively form primary school clusters.”

This statement does not provide clear reasoning for the omission of these sites from the draft plan at this stage. Firstly, it does not explain “more villages” in comparison to where, or what. It also doesn’t justify why even if there is more primary school clustering in South Norfolk than presumably Norwich or Broadland, this should be the deciding factor in determining the growth strategy for South Norfolk. The Cambridge-Norwich Tech corridor runs through South Norfolk District and paragraph 5 of the introduction puts the focus on planning to and building on our strengths, particularly referencing the Cambridge-Norwich Tech Corridor and its high value jobs. It would, therefore, make much more sense if this was a main consideration in the choice of locations for housing within South Norfolk.

A clear justification is needed if a strategy of significant dispersal (as proposed at present) to small sites in the rural area and towns like Diss and Harleston is to provide the focus in South Norfolk, otherwise it is difficult to understand how this can be a sound approach. It places doubt upon the intent in paragraph 5 to build upon the strengths identified therein and also upon the delivery of the Vision for Greater Norwich in 2038 set out in paragraph 108. This states:

“by promoting this Greater Norwich Local Plan our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech corridor.”

An explanation should be provided as to how the number of 1200 homes (15% of new allocations) can be relied upon on small sites in South Norfolk when the sites have not yet been identified or assessed.

We consider that it is premature to ask stakeholders to comment on the acceptability of an overall growth strategy for the next 20 years, when 15% of the new allocations are missing. We appreciate the intent to get on with producing the plan, but these sites form a fundamental part of the overall strategy and without identification of these, the strategy is clearly not sound.

Mid Suffolk District Council supports the Greater Norwich Local Plan as written and will continue to engage with South Norfolk Council through the duty to co-operate and on any matters arising from the preparation of the Diss and District Neighbourhood Plan.

The overall purpose of the draft plan is clear.

The retention of the existing adopted Growth Triangle Area Action Plan and allocations therein, particularly GT16, North Rackheath is SUPPORTED. However, the introductory section of the plan should make clearer the fact that the GNLP is focussed on additional growth to meet housing delivery and other targets and the contribution of the allocated sites in retained parts of the Development Plan forms a baseline in the GNLP, only, and will not be re-examined.

In the event that the independent Inspector appointed to examine the soundness of the Plan seeks to review the overall housing numbers, the landowners and promoters of the GT16 allocation would wish to provide appropriate representation.

No. The content describes relationships between adjacent planning authorities within the context of housing development. The integration between these authorities and local plans should be made clear beyond housing, for example how increased development within one plan area might lead to increased recreational pressure within another area. Examples might include provision of electric vehicle charging points at the start and end of journeys combined with information to promote enjoyable experiences at that end point.

The purpose of the plan is considered to be clear; to deliver new housing in a sustainable way so as to meet the challenges of climate change, and the move to a post-carbon economy. However, we would raise concerns as to whether the proposed approach to the distribution of growth, the carrying forward of a substantial percentage of previously allocated sites (82%), and the approach to new allocations, appropriately support this purpose.
Climate change, and the move to a post-carbon economy will be key factors to guiding growth, and the proposed flexibility within the draft strategy is welcomed. However, in times of such rapid change, complex challenges and significant opportunities a change to the status quo is required. The proposed carrying forward of allocations and concentration of growth to existing urban areas is considered to be misaligned with the aspirations of the Greater Norwich Local Plan, particularly in the context of Norwich City Council having declared a climate emergency and pledging to be carbon neutral by 2030, and the national target of 2050. Such an approach is considered to fail to adequately adapt to the changing circumstances and priorities of the Greater Norwich area, and beyond.
As such we would raise concerns that the strategy for growth and associated allocations are not forward thinking enough to deliver truly sustainable, resilient and attractive communities.
We would also raise concern regarding the delivery of a significant proportion of proposed carried forward allocations, in light of their not being delivered within the previous plan period. These sites should be subject to appropriate scrutiny, and more detailed evidence required from landowners and developers in order to demonstrate the ability to deliver within the Plan period. Without such, the delivery of the Strategy is placed at risk through opportunistic largescale development which undermines place-making, sustainability and climate resilience.

Please see attached for full submission

Please see attached for full submission

Full representations (with appendices) submitted in response to the current Regulation 18 consultation of the Greater Norwich Local Plan on behalf of Landstock Estates Ltd and Landowners Group Ltd.

I attach the feedback from Broadland Green Party members on the GNLP Consultation.

Each section is identified but not all questions have been answered. However, all questions are included to maintain the numbering.

See attached

For full representation, please refer to attached documents

Please find attached a Regulation 18 Stage C Consultation Representation in relation to GNLP0125, Land West of West Lane, Horsham St Faith.

Please find attached a Regulation 18 Stage C Consultation Representation in relation to GNLP0520, Land South of Norwich Road, Hingham.

Please see attached for full submission
Note that Salhouse Parish Council largely endorses the comments by CPRE, and so we have integrated these comments into our response.