Question 13: Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

The settlement hierarchy does not seem to recognise the distinctly rural nature of many parts of Norfolk, it does not acknowledge the need to preserve it, or its huge environmental value enhancing the quality of life for everyone in Norfolk. The entire plan is based on growth in jobs and growth in housing. There should be some areas in which this growth should not be considered a vital necessity!

Hainford Parish Council have examined the draft plan in detail and this is their considered response.

GNLP consultation-draft proposals document Feb 2020

POLICY 1 – SUSTAINABLE GROWTH

Q13 Do you agree with the proposed settlement hierarchy?

No. The Parish Council does not support the Village cluster proposal.
Whilst there may be some justification for clusters in ‘remote’ rural areas,
most villages are able to continue to access services as they currently do.
Becoming part of a cluster will result in inevitable exposure to wider and unnecessary development and the ultimate loss of existing settlement boundaries and village identity.

Q14 Do we support the approach to housing numbers?

No. The Parish Council is of the view that the 9 /10% extra allocations as well as additional windfall sites is excessive given that there are sufficient sites allocated to meet predicted demand.


POLICY 7- 4 VILLAGE CLUSTERS

Q45. Do you support or wish to comment on the overall approach for the village clusters? Please identify particular issues.

No. We do not support the proposed policy for village clusters.
Most villages are able to continue to access services as they do already without the need to cluster. The policy is intended to enable wider development which will result in the ultimate loss of existing settlement boundaries and the risk of unnecessary development. We are aware that the redefinition of settlement boundaries is to be considered at a later stage in the plan
Q46. Do you support or wish to comment on the approach for specific village clusters?

We strongly object to the proposed cluster of Hainford with Stratton Strawless or any other village and firmly believe that Hainford should retain its stand alone village status as are other nearby villages. The residents of Hainford value their rural aspect and independence and the reasons for linking Stratton Strawless to Hainford are weak.

a) The majority of family size accommodation in Stratton Strawless is situated west of the A140 where there are other nearby schools which are closer and more accessible than Hainford without the requirement to cross the busy A140 at peak times, Hevingham school is 0.4 miles, Marsham Primary School 1.4 miles and Horsford (with supermarket, Doctors surgery, Post Office,social club, leisure facilities, take away food outlet, library, excellent public transport links etc.) is also closer.
b) The largest concentration of homes on the eastern side of the A140 are on the mobile home park which we understand is for residents over the age of 55. For the residents who may live on the eastern side of the A140 and require primary school facilities there is also nearby Buxton school.

In addition to the above we object to the proposal that there is the potential for the development of 50/60 dwellings because there is insufficient capacity to sustain that level of development due to lack of facilities and infrastructure to support this.

The Officers have already stated that there is no capacity for Hainford school to expand and all 9 proposed sites for Hainford were discounted by planners mainly due to there being no safe pedestrian access to the school ( a crucial underlying criteria for development in the policy) and no feasible way to address this. There were Highways concerns, widespread flooding issues, and visual impact and break out into the country side. Added to which the public transport service is very limited with the last daily service from the city at 18.15 .We understand that the Policy requirements are to avoid development where there is a reliance on the private motor vehicle.

Therefore Hainford Parish council objects to the proposal to become part of a cluster and to the ultimate redefinition of our settlement boundary in order to facilitate wider development and to the proposal that there is the capacity to support a further 50/60 dwellings.

I would prefer less housing in the main towns, until their infrastructure is substantially improved and a greater percentage in the villages to ensure they survive as living communities and not as towns for holiday lets and weekenders. This would mean a greater investment in public transport

We agree with the proposed settlement hierarchy and broadly agree with the distribution of housing within that hierarchy.
In particular, we support the identification of Wymondham as one of the main towns and it is clear that Wymondham is by far the largest of the five main towns. Given the geography of the areas in which the five main towns are located then there is an argument for a greater proportion of the total housing growth to be steered to those five towns. The wording in Policy 1 specifically refers to Hethersett (which is not a main town but a key service centre) and Wymondham alongside the Norwich urban area which highlights the importance of these two rural settlements.

Please see attachments for full representation

I have read the response from Hainford Parish Council in regard to policy one, questions 13 & 14 and policy 7, item 4, questions 45 & 46 and I, as a resident of Hainford fully agree with their responses.

I have noted with some despondency that in the published record of flood incidents from June 2017, we have been clustered with Spixworth and Horsham St. Faiths in regard to the number of ‘recorded flood incidents’ totalling 13. Pardon the pun, but this appears to be ‘watering down’ the flood statistics for Hainford, I live in *Redacted* Hainford and this road is almost permanently flooded during the winter months. The last month, this road has been abmissmal for access *redacted*, perhaps someone from Broadland District Council would like to visit to observe what we have to put up with.
And, for future reference, give the flood statistics for Hainford as a stand alone village and not cluster us with other villages to hide the extent of the problems we have.

As we all know statistics can say whatever the statistician wants them to say, but it’s not always correct.

Please see attachment

I object to the proposed establishment of "village clusters" The idea of clustering adjoining villages appears to be a thinly veiled arrangement to merge communities and so provide wide swathes of land for future housing. The current target of AT LEAST 1200 new houses is almost as much as the existing commitment. Compare that to Norwich and the larger towns who are only expected to provide a further quarter of their current expansion. It is nonsensical to push development out into the remoter communities where by and large there is virtually no local employment. CLIMATE CHANGE WILL REQUIRE LOCAL JOBS.

If the objective is, as stated in para 125, to achieve a "radical shift away from...private car and encourage walking, cycling and use of clean public transport", then allocation of housing sites where infrastructure and services already exist is essential.
On this basis a fundamental reappraisal, not only of the current proposals, but of many sites already in the system is required.

The proposed settlement hierarchy and the proposed distribution of housing, as set out in Policy 1, is supported. However, it is not clear why new settlements have been identified as reasonable alternatives, including for Wymondham. The new settlement option is not part of the development strategy for GNLP, and the difficulties associated with the delivery of new settlements has been highlighted in the Growth Options 2018 document, the New Settlements Topic Paper 2018, and the Interim Sustainability Appraisal 2018 e.g. long lead-in times, and inability to deliver policy compliant levels of affordable housing in initial phases of development.

I can see no justification for changing the settlement hierarchy by merging the bottom three tiers into a single ‘village clusters’ category. The purpose of the hierarchy is to direct development towards suitable areas with good access to public transport and services. In the current hierarchy, settlements in the bottom two tiers had very little in the way of services and were therefore deemed generally unsuitable for development. The proposed approach, by incorporating all settlements into ‘clusters’, creates a situation where development can be allowed even in tiny villages with no services. The statement in para 340 that primary school catchments “provide a proxy for social sustainability” is completely meaningless: every location is within a primary school catchment area, and clearly not every location is equally viable as a settlement. There is no evidence that allowing housing development in areas with few or no services results in services being created: unless sustainability is designed in and public transport provided from the start, it just results in more car dependency and an absence of community as everyone gets used to needing their car to get to work, shops, etc.
To give just one example of a ‘village cluster’ that serves no meaningful purpose: Haveringland, as a small village with no school and next to no services of any kind, is expected to look to Horsford for these services within its ‘cluster’. These villages are four miles apart with no bus service, linked by a road with no safe walking route – so in what possible way do they form a ‘cluster’ or serve the aim of reducing car use?
In practice, I note that (rightly) no sites in Haveringland or Felthorpe have been allocated. The site allocations document acknowledges that development in Felthorpe would be inappropriate because “it has poor access to core services and facilities in Horsford some distance away. In particular there is no safe walking route to Horsford Primary School which is over 3km away.” This is a logical assessment, and the same conclusion would have been reached under the existing settlement hierarchy – so why change the policy at all? It is really unclear what the purpose is; but the language suggesting that development in tiny villages can make them more sustainable, or that villages only accessible from each other by car form a sustainable ‘cluster’, is contrary to good planning practice, and risks development in these locations being approved later on.

The 2018 Growth Options consultation also showed a large majority against this proposed change to the settlement hierarchy:
“Of those who responded, 67 favoured option SH1, 17 did not. Answers to question 24 generally favoured keeping the lower settlement hierarchy tiers of 4. Service Villages, 5. Other Villages, and 6. Smaller Rural Communities...22 respondents were in favour of the Village Group approach, and 53 against.”
So why has it been adopted?

The proposed settlement hierarchy and the proposed distribution of housing, as set out in Policy 1, is not wholly supported. As a single defined settlement, it seems contradictory to define Marsham as a Village Cluster. Marsham is a sustainable location for growth, having the following facilities:
• Marsham Primary School
• All Saints Church
• A village hall
• The Plough Public House
• Velocity Strength and Fitness gym
• Various employment units at Norwich Old Road

Furthermore, The Green bus stops (refs. NFODGDTM and NFODGDTP) provide very frequent bus services to Norwich, Sheringham, Reepham and Cromer (Service Nos. 3, 43, 43A, 43B, 44A, 56, X40 and X44). The X40 and X44 are express services providing excellent commuter connections to Norwich city centre.

We maintain that Marsham is a sustainable location with good levels of accessibility and connectivity. The development of circa 35-40 houses at the former Fengate Farm will help maintain existing village services and potentially support the introduction of new shops and services.

We supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the concept of “village clusters” has been introduced into the planning process. For many reasons they appear to be a flawed unsustainable concept. A real strength of the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore we are very disappointed that this distinction has been abolished. The Rural Policy Areas gave real protection to the countryside: this is threatened by the introduction of the village cluster approach. This is another example of how the Draft GNLP contradicts the existing agreed Local Plan.

As noted above in our response to Q1 CPRE Norfolk has serious misgivings about the separation of the sites and allocations for new housing in the South Norfolk Village Clusters from the rest of the GNLP and its current consultation. In addition, we strongly object to the use of the open-ended statement that these South Norfolk “village clusters” will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number as is the case for the Broadland “village clusters”. If the reason for this separation is, as was given at the recent GNDP meeting of 6th January 2020, the lack of suitable sites coming forward in these South Norfolk “village clusters”, then this gives another good reason why the delivery of housing should be phased. Clearly the sites included in the JCS have undergone rigorous assessment and their inclusion in the Local Plan is an acknowledgement of their suitability for development. It makes absolute sense that these suitable sites should be developed first especially given the fact that any new sites coming forward are deemed to be unsuitable.

Paragraph 163d states that the strategy for location of growth ‘focusses reasonable levels of growth in the main towns, key service centres and village clusters to support a vibrant rural economy’, before suggesting that the approach to “village clusters” is ‘innovative’. The claim that providing new housing in such locations will support services is, we contend, largely illusory. Instead, additional new housing will lead to more car and delivery vehicle journeys, with residents travelling longer journeys to access the services they require such as health services and a supermarket. Given that the majority of any such new houses will be larger “family” homes, with children just or more likely to be of secondary or tertiary school or college age than of primary school age. This will have further impacts on carbon reduction due to the additional journeys needed to secondary schools or colleges.

It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable option for the distribution of housing in terms of the environment (e.g. minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; ensuring that everyone has good quality housing of the right size; maintaining and improving the quality of life; reducing deprivation; promoting access to health facilities and healthy lifestyles; reducing crime and the fear of crime; promoting access to education and skills; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes; conserving and enhancing the historic environment and heritage assets; minimising waste generation; promoting recycling; minimising the use of the best agricultural land; maintaining and enhancing water quality and its efficient use) is Option 1: urban concentration close to Norwich. In terms of all these factors taken together the least desirable option as shown on this chart is Option 4: dispersal. We therefore strongly support urban concentration in and close to Norwich as the way forward, because it is best for the environment, minimising climate change and the well-being of residents.

There is very little economic evidence to suggest that cementing new housing estates on the edges of villages will bring any boost to local services, but rather they will put a strain on these services, where they exist.

We cannot understand why the table showing the same set of factors in the Interim Sustainability Appraisal for the GNLP on page 42 shows some different results from the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option.

Given the clear benefits and advantages from these documents for the environment, climate change and other areas, as well as other reservations around lack of sustainability and issues of delivery, we strongly urge the GNDP to remove the requirement for additional new sites for housing in the “village clusters” from the GNLP.

Hempnall Parish Council supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the concept of “village clusters” has been introduced into the planning process. For many reasons they appear to be a flawed unsustainable concept. A real strength of the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore we are very disappointed that this distinction has been abolished. The Rural Policy Areas gave real protection to the countryside: this is threatened by the introduction of the village cluster approach. This is another example of how the Draft GNLP contradicts the existing agreed Local Plan.

As noted above in our response to Q1 Hempnall Parish Council has serious misgivings about the separation of the sites and allocations for new housing in the South Norfolk Village Clusters from the rest of the GNLP and its current consultation. In addition, we strongly object to the use of the open-ended statement that these South Norfolk “village clusters” will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number as is the case for the Broadland “village clusters”. If the reason for this separation is, as was given at the recent GNDP meeting of 6th January 2020, the lack of suitable sites coming forward in these South Norfolk “village clusters”, then this gives another good reason why the delivery of housing should be phased. Clearly the sites included in the JCS have undergone rigorous assessment and their inclusion in the Local Plan is an acknowledgement of their suitability for development. It makes absolute sense that these suitable sites should be developed first especially given the fact that any new sites coming forward are deemed to be unsuitable.

Paragraph 163d states that the strategy for location of growth ‘focuses reasonable levels of growth in the main towns, key service centres and village clusters to support a vibrant rural economy’, before suggesting that the approach to “village clusters” is ‘innovative’. The claim that providing new housing in such locations will support services is, we contend, largely illusory. Instead, additional new housing will lead to more car and delivery vehicle journeys, with residents travelling longer journeys to access the services they require such as health services and a supermarket. Given that the majority of any such new houses will be larger “family” homes, with children just or more likely to be of secondary or tertiary school or college age than of primary school age. This will have further negative impacts on carbon reduction due to the additional journeys needed to secondary schools or colleges.

It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable option for the distribution of housing in terms of the environment (e.g. minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; ensuring that everyone has good quality housing of the right size; maintaining and improving the quality of life; reducing deprivation; promoting access to health facilities and healthy lifestyles; reducing crime and the fear of crime; promoting access to education and skills; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes; conserving and enhancing the historic environment and heritage assets; minimising waste generation; promoting recycling; minimising the use of the best agricultural land; maintaining and enhancing water quality and its efficient use) is Option 1: urban concentration close to Norwich. In terms of all these factors taken together the least desirable option as shown on this chart is Option 4: dispersal. We therefore strongly support urban concentration in and close to Norwich as the way forward, because it is best for the environment, minimising climate change and the well-being of residents.

There is very little economic evidence to suggest that cementing new housing estates on the edges of villages will bring any boost to local services, but rather they will put a strain on these services (especially the provision of health care and education) , where they exist.

We cannot understand why the table showing the same set of factors in the Interim Sustainability Appraisal for the GNLP on page 42 shows some different results from the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option.

Given the clear benefits and advantages from these documents for the environment, climate change and other areas, as well as other reservations around lack of sustainability and issues of delivery, we strongly urge the GNDP to remove the requirement for additional new sites for housing in the “village clusters” (including Hempnall) from the GNLP.

The proposed Settlement Hierarchy is, in principle, supported. It is recognised that The Norwich Urban Area and Main Towns, such as Wymondham, provide a range of services and amenities and are, therefore, the most sustainable and suitable locations for the majority of growth within the Greater Norwich Urban Area.
Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth in accordance with the identified settlement hierarchy.
Whilst the principle of identifying the Norwich urban area as the focus for most of the identified housing growth is supported, the ability of existing allocations / commitments, as well as certain new allocations, to deliver the scale of growth forecast is, without the provision of clear evidence demonstrating the delivery of certain sites in accordance with criteria contained within the NPPF, questioned. This is highlighted by the fact that the draft Local Plan states at various locations that there is uncertainty regarding the delivery of 1,200 dwellings at the Carrow Works site in Norwich.
With specific regard to existing allocations and commitments, the reliance on certain strategic sites is questioned. More specifically, North Rackheath has, in part, been allocated since 2010 and was initially earmarked for delivery in the 2010-2011 Annual Monitoring Report (AMR) during 2013/2014. Since this initial allocation, the scale of growth forecast for North Rackheath has been increased to 3,000 units (Reference GT:16). However, development is yet to start on site. The latest AMR (2018/19) now envisages that development will commence on site in 2022/23. This demonstrate a considerable delay in the delivery of the site and questions whether, in accordance with the draft GNLP Delivery Statement, it can be considered to represent a site where there is a reasonable prospect of delivery.
Similarly, the Beeston Park allocation, which is forecast to deliver 3,520 homes has, since its first inclusion in an AMR in 2013/14, been delayed by 4 years.
On this basis, there is considerable doubt as to whether there is clear evidence that large strategic sites that are identified as ‘existing deliverable commitments’ can be relied on. Similarly, there is, as acknowledged by the draft Local Plan and detailed above, doubt as to whether certain strategic allocations within the Norwich Urban Area, notably Carrow Works (1,200 units), can be delivered.
In addition, whilst the concept of village extensions is, in principle, supported, we would, based on the evidence provided to date, question the ability of a minimum of 1,200 dwellings to be delivered within South Norfolk Village Clusters.
As we understand, South Norfolk Council are preparing a South Norfolk Village Cluster Site Allocations Document. The need to prepare this document has arisen as a result of the previous Regulation 18 consultation stages into the draft Greater Norwich Local Plan not identifying the choice of sites in the village clusters that would address the requirements in those settlements. (See paragraph 2.1 of South Norfolk Village Clusters Allocations Document – Site Assessment Process and Draft Timetable, Agenda Item 5, Regulation & Planning Policy Committee, 18th February 2020.)
The scale of development focused in the village clusters will range from 12 units up to 1 hectare i.e. 20-25 homes. Based on the 48 village clusters identified in Appendix 1 of the above referenced document, it will mean that each cluster has to accommodate the maximum number of units i.e 25, if the minimum of 1,200 units within South Norfolk village clusters is to be provided.
Given that the identified village clusters are, partly due to their rural location, likely to present a range of issues relating to constraints i.e. utilities, flood risk, suitable access, and impact i.e. landscape and biodiversity, it is difficult, particularly without the provision of clear evidence, to see how the scale of growth directed to the South Norfolk village clusters can be justified. In addition, given the scale of the developments in the villages clusters i.e. a maximum of 25 units, they will not be of a sufficient scale to ensure the provision of social and community infrastructure.
On this basis, we suggest that the quantum of growth directed to both the Norwich urban area and the village clusters in South Norfolk cannot, without the provision of clear evidence relating to delivery, be relied on. Accordingly, a suitable proportion of this housing growth should be reallocated to alternative settlements within the settlement hierarchy, which are capable of demonstrating that they can deliver housing growth; specifically the allocation of sites that would otherwise classed as contingency sites.

In the first instance I do not consider that the level of "growth" proposed is sustainable for us or the future generations. Continuing to march on heads down with the same acceptance of "growth" as desirable above everything else is not sustainable. The location of development Policies 1 and 7 place suburbia 3 miles and more from the City Centre demanding transport journeys for work and leisure. Increasing the population of Towns and Villages places even more people on the move. Our private bus companies are inadequate now. Adding another 100,000 people will only further break the systems.

Within the draft plan the concept of 'village clusters' is not explained and the reader is left to assume that this concept has some planning precedent. The terms do not appear in the Joint Core Strategy (adopted in 2011) and, judging by the withdrawal of South Norfolk from the village clustering part of the plan, the concept arrived 'oven ready' at a very late stage in the GNLP process. Our view is that this approach has rendered the GNLP growth strategy seriously flawed.

I agree that with the GNLP that Horsford should have no allocation of sites, other than GNLP0264. Horsford has been allocated 479 homes to date, which equated to 11.9% of the 9% total housing growth as identified by GNLP. I have reservations in regard to "village clusters", (Horsford falls in this group) would this mean that settlement boundaries redefined around the perimeter of these cluster villages which would mean that green field land is vulnerable to further development - and sites could be built on that are not suitable for development on the the fringe of the village.

The proposed Settlement Hierarchy is supported; the Norwich Urban Area, including the fringe parishes such as Sprowston, is clearly the most sustainable location for growth, given the range of services available, and it is therefore appropriate to focus the majority of growth, including new allocations, here.

The proposed Settlement Hierarchy is supported; the Norwich Urban Area, including the fringe parishes such as Old Catton and Sprowston, is clearly the most sustainable location for growth, given the range of services available, and it is therefore appropriate to focus the majority of growth here.

The explanatory text para 160 states (below) that the policy supports small brownfield sites as windfall that are not necessarily sites in or adjacent villages.

Windfall developments
160. Windfall developments provide additional potential for housing delivery not counted in the above table. The policy supports appropriate windfall development, including sites in and adjacent to villages and small brownfield sites. Based on previous local trends, the likely scale of windfall development is in the region of 3,870 dwellings between 2018 and 2038. Demand will determine whether windfall development is instead of, or in addition to, allocated growth.

Agree that appropriate windfall development should be allowed for to deliver housing and that small brownfield sites should also be considered appropriate subject to site specific matters. There is a clear national drive for the re-use of brownfield sites. However Policy 1 as currently drafted does not clearly allow for this.
H1 sets out windfalls are acceptable as follows
• Within settlement boundaries in accordance with the above settlement hierarchy;
• Elsewhere in village clusters, subject to the requirements of policy 7.4.
• On sites of up to 3 dwellings in all parishes, subject to the requirements of policy 7.5.
A further bullet point should be added to refer to small brownfield sites – which could be outside of settlements. It would also be helpful to have some understanding of ‘small’.

As currently drafted, there is a risk that suitable brownfield sites of a decent size, such as site GMLP0454, which is capable of providing approx 34 houses falls between the thresholds of not being allocated in this Plan and not meeting the Policy as currently drafted, which would not be in the interests of prioritising the use of brownfield land over greenfield. It is requested that GMLP0454 is reconsidered for allocation as part of this Plan.

Lanpro do not support the proposed settlement hierarchy as currently proposed. Although we offer support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, without first understanding where these sites are to be located and whether they are in fact sustainable, we cannot support the significant emphasis that is placed upon rural village clusters (outside of the old NPA). As currently drafted, the plan potentially allows a significant number of new homes (1200, 15% of all new allocations) to be located in small settlements in the rural area of South Norfolk. Other small sites are identified within the rural parts of Broadland. We do not consider this approach to be sustainable or compatible with the objectives in relation to tackling climate change.

The draft plan indicates that more homes (new allocations and commitments) are proposed in the cluster villages (9%) than in the key service villages (8%), yet cluster villages represent the bottom tier of the settlement hierarchy. As the bottom tier, they should have a correspondingly lower amount of growth in the hierarchy, otherwise this is not a sensible hierarchical approach to growth.

We consider that a more sustainable approach, that would be more in line with the overall objectives and vision set out for the Growth Strategy would be to clearly direct 400 of the South Norfolk 1200 to cluster villages and key service centres within the old NPA parts of South Norfolk and 500 as the first phase of a new settlement at Hethel in the Cambridge – Norwich Tech corridor. There is scope for a limited amount of more rural dispersal to contribute to the vitality of small rural villages and therefore, the remaining 300 should only be allocated to small cluster villages in the more rural parts of South Norfolk (outside the old NPA) where there is walkable access to a primary school and good public transport links to other key services. Any Broadland allocations outside of the old NPA should also only remain if the same applies.

Allocating 500 of the homes to a new settlement at Hethel would also provide land to expand the opportunity for hi-tech engineering jobs within the growth corridor. In this location the homes would help to ensure that the plan “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” (paragraph 108).

They will also:
“strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” (Delivery Statement page 36).

The current strategy of significant dispersal to small rural village clusters will make no positive contribution to these key threads of the plan. It will have negative impacts in terms of increasing the number of private car and other journeys and it will place greater demand on small local schools and services. These demands are more difficult and costly to address within a spread of small rural villages rather than within a new settlement where social infrastructure can be properly planned and funded from the outset with corresponding economies of scale.

As currently proposed, the settlement hierarchy presents an unambitious variation on the previous Joint Core Strategy (JCS) with an unjustified increase in rural dispersal. The draft plan states that 82% of the new housing requirement to 2038 is made up of existing JCS allocations that have been carried forward (paragraph 156). This means that including the proposed uplift on existing allocations, 36,503 homes out of a total housing figure of 44,343 are carried forward.

Of the 7840 new housing allocations included in the draft plan, 4395 are to be located within Norwich and its fringe parishes. This is supported because these are clearly sustainable locations within Greater Norwich with good access to jobs and higher order services. However, despite the plan’s emphasis in its Vision (page 31) and Delivery Statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes (new allocations) are proposed within the corridor itself, at Wymondham. By contrast, 400 are proposed in Diss which is neither within the Strategic Growth Area, the Cambridge Norwich Tech corridor, or close enough to Norwich to benefit from higher order services.

It is recognised that towns like Diss and Aylsham should accommodate some additional housing growth and do offer their own job opportunities and service provision. However, this should not take precedence over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Strategic Growth Area and Cambridge Norwich Tech corridor. Therefore, it is proposed that numbers in Diss should be halved to 200 and numbers in Harleston, which is also well outside of the Tech corridor and Strategic Growth Area, should be reduced to 150. The displaced 500 homes should be relocated within the Tech Corridor/ Strategic Growth Area. Some of these should be placed in a new settlement at Hethel.

Overall, Lanpro’s conclusion is that the plan is saying the right things about future ambitions for Greater Norwich and the Tech corridor, but doing another, by virtue of directing too much growth to the rural areas outside of both the Tech corridor and the newly identified Strategic Growth Area. This needs to be addressed by ensuring that 900 of the 1200 homes proposed for village clusters in South Norfolk are redirected to villages within the old NPA area (400) with 500 to a new settlement at Hethel to support the Cambridge Norwich Tech corridor. The remaining 300 allocations in the rural parts of South Norfolk should only be in cluster villages where there is good walking access to a primary school and good public transport links to other key services. The same approach should be taken in Broadland. In addition, 500 homes should be redistributed from Diss and Harleston into the Tech corridor at Hethel and/or Strategic Growth Area. A new Garden Village settlement at Hethel could deliver up to 2000 homes within the plan period to 2038 with more beyond.

Why has there been a change from the JCS to introduce the concept of "Village Clusters"?
It is not proven that the "Village Cluster" concept will 'focus reasonable levels of growth ... to support a vibrant rural community'.
Concentrating housing growth near to Norwich is more environmentally friendly in a hugh number of ways rather than dispersing the growth into the rural areas that do not have the infrastructure, services or jobs to support it or for it to support.

Glavenhill Ltd do not support the proposed settlement hierarchy as currently proposed. Although we offer support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, without first understanding where these sites are to be located and whether they are in fact sustainable, we cannot support the significant emphasis that is placed upon rural village clusters (outside of the old NPA). As currently drafted, the plan potentially allows a significant number of new homes (1200, 15% of all new allocations) to be located in small settlements in the rural area of South Norfolk. Other small sites are identified within the rural parts of Broadland. We do not consider this approach to be sustainable or compatible with the objectives in relation to tackling climate change.

The draft plan indicates that more homes (new allocations and commitments) are proposed in the cluster villages (9%) than in the key service villages (8%), yet cluster villages represent the bottom tier of the settlement hierarchy. As the bottom tier, they should have a correspondingly lower amount of growth in the hierarchy, otherwise this is not a sensible hierarchical approach to growth.

We consider that a more sustainable approach, that would be more in line with the overall objectives and vision set out for the Growth Strategy would be to clearly direct 400 of the South Norfolk 1200 to cluster villages and key service centres within the old NPA parts of South Norfolk and 500 as the first phase of a new settlement at Hethel in the Cambridge – Norwich Tech corridor. There is scope for a limited amount of more rural dispersal to contribute to the vitality of small rural villages and therefore, the remaining 300 should only be allocated to small cluster villages in the more rural parts of South Norfolk (outside the old NPA) where there is walkable access to a primary school and good public transport links to other key services. Any Broadland allocations outside of the old NPA should also only remain if the same applies.

Allocating 500 of the homes to a new settlement at Hethel would also provide land to expand the opportunity for hi-tech engineering jobs within the growth corridor. In this location the homes would help to ensure that the plan “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” (paragraph 108).

They will also:
“strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” (Delivery Statement page 36).

The current strategy of significant dispersal to small rural village clusters will make no positive contribution to these key threads of the plan. It will have negative impacts in terms of increasing the number of private car and other journeys and it will place greater demand on small local schools and services. These demands are more difficult and costly to address within a spread of small rural villages rather than within a new settlement where social infrastructure can be properly planned and funded from the outset with corresponding economies of scale.

As currently proposed, the settlement hierarchy presents an unambitious variation on the previous Joint Core Strategy (JCS) with an unjustified increase in rural dispersal. The draft plan states that 82% of the new housing requirement to 2038 is made up of existing JCS allocations that have been carried forward (paragraph 156). This means that including the proposed uplift on existing allocations, 36,503 homes out of a total housing figure of 44,343 are carried forward.

Of the 7840 new housing allocations included in the draft plan, 4395 are to be located within Norwich and its fringe parishes. This is supported because these are clearly sustainable locations within Greater Norwich with good access to jobs and higher order services. However, despite the plan’s emphasis in its Vision (page 31) and Delivery Statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes (new allocations) are proposed within the corridor itself, at Wymondham. By contrast, 400 are proposed in Diss which is neither within the Strategic Growth Area, the Cambridge Norwich Tech corridor, or close enough to Norwich to benefit from higher order services.

It is recognised that towns like Diss and Aylsham should accommodate some additional housing growth and do offer their own job opportunities and service provision. However, this should not take precedence over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Strategic Growth Area and Cambridge Norwich Tech corridor. Therefore, it is proposed that numbers in Diss should be halved to 200 and numbers in Harleston, which is also well outside of the Tech corridor and Strategic Growth Area, should be reduced to 150. The displaced 500 homes should be relocated within the Tech Corridor/ Strategic Growth Area. Some of these should be placed in a new settlement at Hethel.

Overall, Glavenhill Ltd’s conclusion is that the plan is saying the right things about future ambitions for Greater Norwich and the Tech corridor, but doing another, by virtue of directing too much growth to the rural areas outside of both the Tech corridor and the newly identified Strategic Growth Area. This needs to be addressed by ensuring that 900 of the 1200 homes proposed for village clusters in South Norfolk are redirected to villages within the old NPA area (400) with 500 to a new settlement at Hethel to support the Cambridge Norwich Tech corridor. The remaining 300 allocations in the rural parts of South Norfolk should only be in cluster villages where there is good walking access to a primary school and good public transport links to other key services. The same approach should be taken in Broadland. In addition, 500 homes should be redistributed from Diss and Harleston into the Tech corridor at Hethel and/or Strategic Growth Area. A new Garden Village settlement at Hethel could deliver up to 2000 homes within the plan period to 2038 with more beyond.

Hopkins Homes supports the settlement hierarchy including the identification of Wroxham as a key service centre. This is in recognition of the good level of services and its sustainable location. However, Hopkins Homes objects to the spatial distribution of new homes contained in Policy 1 and specifically, the lack of allocations in Wroxham. This will not provide a positively prepared or justified plan for the following reasons:

1. The spatial strategy perpetuates the development strategy in the current Joint Core Strategy and will not address the persistent patterns of under delivery which have been recorded over a long period.
2. The spatial strategy will not address development needs in sustainable rural locations such as Wroxham.
3. The proposed spatial strategy will not address identified needs in the Wroxham Neighbourhood Plan, including housing for older people.
4. The distribution of growth is not justified. There is no technical case to preclude development at Wroxham.

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

We are pleased that the greater part of the new GNLP developments will be in the Norwich area. Fortunately, Norwich has many brownfield sites available. Even more important, Norwich has the infrastructure and services to support development. For example; hospitals, universities, research parks, good schools, museums, entertainment facilities, public transport and so on.
It is, therefore, of concern that South Norfolk are proposing 1200 additional dwellings by providing for estate development throughout the village clusters as well as an extra 400 small scale windfall houses. These would be in addition to the 1349 dwellings already allocated and would overwhelm infrastructure.

Hingham Town Council consider the Hierarchy to be flawed. Several parishes have been designated as Key Service Centres, at no point in the document is there a definition for a “Key Service Centre”. The lack of concrete criteria for a “Key Service Centre” renders the designation of such an entity meaningless.
Hingham Town Council object to any new sites being allocated for house building in revised local plans to 2038 until all existing allocations in current core strategies have been developed.
There is no evidence in the policy document of commitment to improved infrastructure in Hingham to enable the town to sustain the quoted 120 new homes, in particular additional primary school places and improvements to the road and footway network in the town.

Hingham has a allocation of 120 new homes (including 16 existing commitment), however the consideration of Windfall sites as being “acceptable in principle” – of sites of up to 3 homes within each parish would mean the ACTUAL homes that will be delivered is potentially unquantifiable (Policy 7.5 is ambiguous in its meaning and needs clarification).
Housing figures are not discussed inline with actual need within the community or taking into account the number of vacant properties already in existence.
Hingham Town Council have been told that “deliverability” is a key component to housing development site allocation. The Council would like to sate that just because something is deliverable it does not mean that it is right for a community, and there are concerns regarding the push to deliver housing development “en masse” which could potentially overwhelm the town’s facilities and infrastructure. The GNLP runs until 2038 and the Town Council are of the opinion that a phased approach to delivering smaller developments, as and when needed, with a higher focus on affordability for local people would be a more acceptable and appropriate approach.
Hingham Town Council object to any new sites being allocated for house building in revised local plans to 2038 until all existing allocations in current core strategies have been developed.

No, following my direct discussion with Professor James Wood at Cambridge currently actively engaged in Cambridge -Norwich high tech links who is very positive about the programme “we have very strong links and hope that a lot of biotech will continue” his statement on housing needs now and future for this is that “Wealthy people will always source housing but No one is working to build the housing for the people who most need it, the minor technicians , veterinary nurses and innumerable support staff. Robust and well managed social housing schemes are the best way to provide this”