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

Comment

Representation ID: 21605

Received: 16/03/2020

Respondent: Aylsham TC

Although at this stage it is not of direct interest to Aylsham and its residents there is a view that too much emphasis has been placed on school catchment areas rather than geographical links

Object

Representation ID: 21729

Received: 16/03/2020

Respondent: Brown & Co

It is considered that a new settlement is a suitable option now. Traditional strategic development in Greater Norwich has placed pressure on existing infrastructure and communities, resulting in the need for significant investment in upgrades in order to provide power, waste water treatment and other social infrastructure. The programme of works required to facilitate a number of strategic and non-strategic proposed and existing allocations is significant, requires significant investment and will, and already has, detrimentally impacted upon the timely delivery of development.

Object

Representation ID: 21821

Received: 12/03/2020

Respondent: Barford Parish Council

Barford and Wramplingham Parish Council do not agree with the proposed hierarchy and distribution of housing: the village cluster site allocations and development are inconsistent with the more centralised location of industrial development e.g. on the Norwich Research Park and in Norwich. Furthermore, continued expansion of villages and therefore the village cluster approach just puts more and more strain on the limited local amenities and services if and where they exist. The village cluster policy seems to be an environmentally deleterious, but local authority-backed policy to the benefit of landowners, developers and house builders.

Object

Representation ID: 21848

Received: 12/03/2020

Respondent: Hempnall Parish Council

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.

Object

Representation ID: 21894

Received: 12/03/2020

Respondent: Barton Willmore

(Representations made on behalf of KCS Developments)

The GNLP advises that settlements within the bottom three tiers of the current framework would be merged into a single lowest tier of “Village Clusters” within a settlement hierarchy of just four tiers. This would serve to underplay the significance of Spooner Row as a service centre in terms of its scale, function and facilities as well as its capacity to accommodate future growth within the Cambridge to Norwich Growth Tech Corridor. This approach is flawed.
The grouping together of “Service Villages”, “Other Villages” and “Smaller Rural Communities and the Countryside” into a single lowest tier within a settlement hierarchy comprising just four rather than six tiers as is currently the case would significantly undermine the function and role that Service Villages can play in accommodating future growth.
Service Villages such as Spooner Row include a range of functions and services which are more closely aligned to the functions and service characteristics of Service Centres than they are to Other Villages which are defined by their offer of just a very basic, narrow range of services. Service Villages such as Spooner Row are much more sustainable settlements capable of accommodating much higher housing growth than Other Villages and Smaller Rural Communities and the Countryside. Spooner Row benefits from a range of local services such as primary school, village hall, church and a public house. Development of the settlement presents the opportunity to enhance these facilities and also provide a village shop. Spooner Row benefits from being well connected due to its situation along the A11 corridor and benefits from a railway station with services to Norwich and Cambridge which is key to its future growth.
If the settlement hierarchy is to continue to be rationalised into four tiers, we would recommend that Service Centres and Service Villages should be combined into a single 3rd tier and Other Villages combined with Smaller Rural Communities and the Countryside to form a 4th tier.
Proposed Distribution of Housing
In terms of the proposed distribution of housing within the hierarchy, the preferred option selected by the Council combines concentrating most of the development in and around Norwich and on the Cambridge Norwich Tech Corridor, with an element of dispersal to villages to support thriving rural communities.
Our Client supports this approach in principle as it would serve to ensure that there is a focus for delivering development along the A11 corridor, fulfilling the Spatial Objectives of supporting the Cambridge to Norwich Tech Corridor, plus locating growth near to jobs and infrastructure. The merging of a number of tiers within the Settlement Hierarchy however does not support this proposed distribution of growth, with Service Villages potentially missing out on growth by being categorised within Village Clusters even if they are situated within the Tech Corridor.
The GNLP proposes to allocate and permit housing growth of 4,024 homes within village clusters. This accounts for circa 9% of the total for Greater Norwich in the plan period. As discussed above, village clusters comprise of settlements which are currently categorised as service villages, other villages, smaller rural communities and the countryside. This accounts for a large proportion of settlements within Greater Norwich. The Core Strategy identifies 61 service villages and 39 other villages. The distribution of 4,024 homes across these settlements would result in a very low level of growth within each (circa 42 within each over the Plan Period) which is not likely to support their continued sustainability or viability.
There are clear differences between settlements within the village clusters and if the proposed hierarchy is to be adopted there needs to be clear recognition that larger villages such as Spooner Row should accommodate more growth than smaller villages which were previously lower in the settlement hierarchy.
Spooner Row is situated along the A11 corridor within the Cambridge to Norwich Tech Corridor. As well as being situated along the A11 corridor it also benefits from a railway station which is key to the settlement’s future growth. The proposed distribution of growth would result in this highly sustainable settlement which has the capacity to accommodate a generous amount of growth missing out on growth and the potential to improve its local services.
The distribution of growth should explicitly support more growth in certain service villages such as Spooner Row and more limited growth in other villages and smaller rural communities to reflect their sustainability and potential for additional growth.

Comment

Representation ID: 21924

Received: 24/03/2020

Respondent: Horsford Parish Council

It is proposed that Horsford falls into the remit of Village Clusters with regard to the Settlement Hierarchy.
Page 47 of the Final Draft Strategy states:
Table 7 Housing growth 2018 to 2038 (figures rounded)
Village Clusters:
- Homes 2018: 46100
- Homes 2038 (and increase): 50124 (+4024)
- Increase: 9%
- % of Total Housing Growth: 9%

Horsford are accepting of the one site identified, Policy GNLP0264, as a preferred option providing 30-40 new homes in the cluster. However, we have concerns about the access road from this development onto Horsbeck Way, which just moves the Dog Lane access issues one road further along.
We are in agreement with the GNLP statement that NO other sites within Horsford should be considered for allocation. This is justified by the following statistics:
394 homes already with existing planning permission on various sites, plus the recent uplift of 45 homes on the Kingfisher Meadow Site passed for development on 8 January 2020 and the additional 40 on the new allocation Policy GNLP0264, Dog Lane, Horsford. These 479 homes equate to 11.9% of the 9% total housing growth. When you consider there are 20 villages that fall within the proposed Village Cluster, Horsford have delivered a total quantity of homes way above and beyond what is expected of a service village, in comparison to other proposed cluster villages like Blofield Heath (107 dwellings) Gt & Little Plumstead (140 dwellings) and Coltishall, Horstead with Stanninghall and Belaugh (70 dwellings). GNLP states that “The Towards a Strategy document identifies 2,000 dwellings in total should be provided between all the “village clusters”.” Horsford have delivered a huge proportion 23.9% of this total, which is not that far from 1/3 of the expectation!
Paragraph 132 claims that new quality development will be located so loss of green-field land is minimised. Horsford Parish Council believe this can only be achieved by not allocating additional sites to Horsford or other “village clusters”. Also by clustering villages, will settlement boundaries be redefined around the perimeter of these clusters, which will mean that more green-field sites are vulnerable to further allocation. If this is the case, then Horsford Parish Council are against adopting this approach to the proposed distribution of housing within the hierarchy, as its green-field areas are then susceptible to development.

Support

Representation ID: 21940

Received: 13/03/2020

Respondent: UEA Estates & Buildings

Agent: Bidwells

The proposed Settlement Hierarchy and the identification of the UEA as part of the Norwich Urban Area is supported. The UEA is a world class research university, being a leader in creative writing, life and environmental sciences. The presence of the UEA in Norwich has significantly contributed to Norwich’s recent economic, social and cultural growth. The UEA’s presence has enabled Norwich to attract many young, skilled workers to the area and, importantly, helped retain them locally.

Therefore, the UEA support the scale of growth directed to the Norwich Urban Area, including 4,395 new dwellings. Development on GNLP0133-C and GNLP0133-E will help to support and meet a particular area of housing growth in the Norwich Urban Area.

Comment

Representation ID: 21983

Received: 16/03/2020

Respondent: Ms Carol Sharp

We supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the unsustainable concept of “village clusters” has been introduced into the planning process. 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.
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.

Object

Representation ID: 22019

Received: 15/03/2020

Respondent: Mulbarton Parish Council

A real strength in the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore MPC are very disappointed that this distinction has been abolished and the impact this would have on the village.

MPC has serious misgivings about the separation of sites and allocations for new housing in the “village clusters” that will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number which concerns the residents of Mulbarton who have already seen wholesale development of their village in the last decade.

The claim that providing new housing in such locations will support services have proved in Mulbarton to be untrue with little increase in services and has led to increased transport with the knock on effect for climate change.

Object

Representation ID: 22096

Received: 13/03/2020

Respondent: Quantum Land

Agent: Barton Willmore

We object to the spatial strategy for housing and the various linked policies associated with delivering that spatial strategy – Policy 1 and Policies 7.1-4. Our main objections are:
1.The lack of focus and housing allocations proposed for the “Key Service Centres” in comparison to lower settlement hierarchy tiers; and
2.The allocation of no housing growth to Brundall;
Of the 7,840 dwellings proposed for new allocations, they are distributed as follows:
1.Norwich Urban Area 56% (4,395 units)
2.Main Towns 16% (1,250 units)
3.Key Service Centres 7% (515 units)
4.Village Clusters 21% (1,200 units)
Whilst the focus on the urban area of Norwich Urban Area is appropriate, we consider that the balance across the settlement hierarchy is not optimal or justified. The “Main Towns” and “Key Service Centres” have individually less housing directed to them than the bottom of the settlement hierarchy, the “village clusters”, which has more dwellings. In fact, the second and third tiers of the settlement hierarchy have almost the same number in totality as the bottom tier. This seems unjustified given that they are the least sustainable locations for growth.
This if illustrated in that of the 9 key Service Centres only 4 have any new dwellings proposed and 1 of those 3 have only 15 units. Brundall has no housing allocated to it all despite being one of the closest and well-connected settlements to Norwich.
It is acknowledged that in both the Main Towns and Key Service Centres there are many “reasonable alternatives” that exist and so under alternative spatial approaches, a different spatial pattern could be achieved more sustainably. This is acknowledged in the consultation questions asked which notes:
“The 8% proportion of new housing in key service centres could be increased as many reasonable alternative sites have been proposed in key service centres. However, overall the preferred option is considered to provide a suitable amount of growth in relation to the settlement hierarchy, infrastructure and local constraints. The Sites document sets out the preferred option and reasonable alternative sites.”
We consider the spatial distribution should be reconsidered.

Support

Representation ID: 22129

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

The preferred option for the Local Plan combines the concentration of the majority of development in and around Norwich and on the Cambridge to Norwich Tech Corridor, a large focus on market towns, with an element of dispersal to villages. This approach is supported and provides a balance across a range of the objectives of the Local Plan.

This approach would see housing commitments providing a total minimum deliverable commitment of 6,342 within the Main Towns over Plan period of 2018 – 2038.

The settlement hierarchy’s recognition of the contribution that the Main Towns like Diss make to the delivery of housing is acknowledged and supported. While it is acknowledged that Norwich should be the principal focus growth, the market towns have an important role in creating a vibrant sub-region, and in the case of Diss serve wide hinterlands from which people are drawn to use the town’s shops, services, and facilities, including both primary schools and secondary schooling as well as the train station.

In addition to the above, the preferred settlement hierarchy follows a typical approach and looks at the different levels of services between places, we support the clustering of villages within the countryside and believe this recognises that in some cases, existing businesses within the villages provide services not only for the village that they are located in, but also for smaller neighbouring settlements which may rely on the services they provide.

Comment

Representation ID: 22153

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

3. POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY
3.1 Policy 1 sets out the proposed strategy and includes the proposed housing requirement, the proposed employment land requirement, the approach to five-year land supply and the spatial strategy. These are addressed below.
3.2 Policy 1 also sets out the approach to supporting infrastructure and the proposed distribution of development which are addressed in greater detail in Policies 4 and 7.1 to 7.4 respectively. These matters are responded to under those Policies rather than in response to Policy 1.

Support

Representation ID: 22162

Received: 16/03/2020

Respondent: Norwich Liberal Democrats

Number of people: 3

We support the continuation of the settlement hierarchy as defined in the JCS with the primary focus of planned development in the Norwich urban area.

Comment

Representation ID: 22177

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Spatial Strategy
3.39 The Table at Policy 1 details the distribution of housing supply across the settlement hierarchy, including proposed new allocations as follows;
- Norwich urban area - 30,560 dwellings – approximately 70% of supply
- Main towns – 6,342 dwellings – approximately 14% of supply
- Key Service Centres – 3,417 dwellings – approximately 8% of supply
- Village clusters – 4,024 dwellings – approximately 9% of supply
3.40 Policies 7.1 to 7.5 provide further detail on the distribution of sites and the composition of existing and proposed allocations with regard to their size and brown or green field status.
3.41 Our clients raise concern over the proposed spatial strategy of the emerging GNLP owing to its over reliance on housing delivery in the Norwich urban area and the proposed discrepancy in terms of settlement hierarchy between the quantum of housing allocated to Main Towns, Key Service Centres and Village Clusters.
3.42 While the Norwich urban area is a sustainable location for growth, reliance on this area for the delivery of approximately 70% of the housing growth of the GNLP up to 2038 places a requirement on existing infrastructure to accommodate an additional 30,560 dwellings in the plan period, it also requires an annual delivery rate within the area of 1,698 dwellings per annum over each of the next 18 years. This requires that the level of development in Norwich urban area alone is broadly consistent with that which has been achieved across the entire GNLP plan area since 2008. This does not appear to be realistic. If the necessary boost to housing supply is to be achieved this will require a greater range and choice of sites across all of the sustainable settlements within the plan area.
3.43 Moreover, reference to Policy 7.1 demonstrates that delivery within the Norwich Urban Area is predicated on two substantial brownfield regeneration areas, the Northern City Regeneration Area and the East Norwich Strategic Regeneration Area and several urban extensions of over 1,000 dwellings each.
3.44 Brownfield regeneration is costly and time consuming and often involves the bringing together of multiple delivery partners to achieve. The likelihood of the totality of development proposed through regeneration delivering in the plan period is therefore slim.
3.45 New strategic urban extensions can also be timely to deliver with the need for new strategic infrastructure in terms of highways and drainage to be delivered in advance of new homes.
3.46 The Councils have not produced evidence to substantiate the delivery trajectory of the brownfield regeneration sites or the urban extensions in the Norwich Urban Area. We reserve the right to comment further on this matter at the Regulation 19 consultation stage. Delay in delivery at either source of supply could prejudice the delivery of the housing requirement of the GNLP and therefore go to the soundness of the plan.
3.47 Additional certainty over the delivery of the housing requirement could be achieved by changing the emphasis of the spatial strategy by allocating more housing to the Main Towns, including Wymondham, and the Key Service Centres with an associated reduction in the percentage to be delivered in Norwich urban area and the Village Clusters.
3.48 Additionally, we have concerns over the fact that more dwellings are proposed in the spatial strategy across Village Clusters than are allocated at Key Service Centres, including a minimum of 1,200 dwellings through a South Norfolk Village Clusters Housing Site Allocations Development Plan Document.
3.49 Without certainty over the supply of land to deliver such a quantum of development in South Norfolk Village Clusters the soundness of the spatial strategy is questionable. As a percentage of the overall new housing allocations in the Reg 18 GNLP the current spatial strategy delegates approximately 15% to a document outside of its control (1200/7,840). This is not considered to be a reasonable approach and prejudices the delivery of the emerging GNLP by 2038.
3.50 A Settlement Hierarchy approach to the distribution of development would look to allocate a higher percentage of housing to more sustainable locations with smaller amounts being allocated to lower order settlements in recognition that small developments at villages can help maintain service provision, provide vitality and help address local market and affordable housing needs.
3.51 In failing to provide an increased number of dwellings at Main Towns and Key Service Centres the Councils are also missing the opportunities presented by Pigeon to provide new community facilities that can support existing and proposed new development in sustainable locations for the plan period and beyond.
3.52 The preceding representations on the Spatial Strategy are all set in the context that the identified housing need does not even accord with the minimum set by national policy and does not take account of the needs of specific groups. It is therefore evident that the quantitative elements of the Spatial Strategy will need to be revised to ensure that housing needs can be met across the GNLP area. This should be achieved through directing more growth to the Main Towns and Key Service Centres to counterbalance the disproportionate levels of growth proposed within the Norwich urban area and Village Clusters. Small and Medium sized sites
3.53 Paragraph 68a of the NPPF requires that at least 10% of the housing requirement should be provided on small and medium sites of no larger than 1ha. This requires that 4,434 homes of the identified housing requirement for 44,340 homes is provided on such sites. However, as identified previously, the proposed housing requirement is insufficient to ensure that the actual housing needs will be met. It will therefore be necessary to increase the number of homes provided on small and medium sites accordingly.
3.54 In paragraph 164 (6), the GNLP indicates that 12% of homes allocated are on small and medium sites. However, 12% of allocations does not equate to 12% of the housing requirement as required by the NPPF. It is therefore likely that it will be necessary to identify additional small or medium allocations to accord with national policy.
3.55 The Land at Rightup Lane, Wymondham has a developable area of 1ha which will be developed in two phases. Through discussions with the local highway authority it has been identified that only the first 8 dwellings can be delivered in the first phase owing to the current access arrangements. The area of this parcel would be significantly less than 1ha. The remaining dwellings on a site significantly below 1ha would then be delivered potentially through a different access point provided through Phases 3 and 4 of a neighbouring development. The Land at Rightup Lane therefore may operate as two independent sites with different access arrangements, such that these should be considered as two separate small rather than medium allocations.
3.56 It has also been identified by Development Management officers in the Site Assessment Booklet that the Land at Rightup Lane is suitable for allocation subject to highways constraints being addressed, such that this would provide an appropriate site for allocation to address the existing shortfall in small or medium sized sites.

Comment

Representation ID: 22224

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

As a start point, we broadly agree with the classification of settlements within the hierarchy itself. In particular we are pleased to acknowledge that Aylsham is identified as one of the principle settlements of the plan area, falling on the second tier of the hierarchy as a ‘Main Town’ and comprising a location for growth that is second only to Norwich itself in terms of importance.

We do, however, have concerns in respect of the proposed distribution of growth. In particular we are concerned about the continued reliance placed on strategic sites within the Norwich urban area as well as the proportionally significant level of growth to be directed towards South Norfolk’s Village Clusters.

The strategic sites issue is pertinent due to the chronic under-delivery of existing large allocations adjacent to and within the Norwich urban area, a matter which by Norwich City Council’s own admittance must be acknowledged by the plan1. The 2018/19 monitoring year was the first since the start of the Joint Core Strategy (JCS) plan period to see delivery in the Norwich Policy Area (NPA) meet its annual housing requirement. Otherwise, growth in the NPA took around 10 years to gather pace with exceptionally slow delivery in the first eight years of the plan period, as shown in the table below:

Table 1: Annual and cumulative delivery in the NPA since the adoption of the JCS Year Requirement Delivery Surplus / Deficit (cumulative) [see covering letter for table]


This lag in delivery during the early years of the plan is representative of the significant lead in times associated with large-scale strategic sites and stands to be replicated once again in the event that the reliance on large sites in and around the Norwich urban area is maintained by the GNLP.
The level of growth to then be directed to South Norfolk’s rural area raises two separate concerns. The first relates to the current complete lack of evidence assessing to the availability and deliverability of sites across the smaller villages of the district. The absence of such evidence means that the direction of such a high proportion of growth towards South Norfolk’s village network – currently proposed at 1,200 homes or 15.5% of all residual growth – represents a strategy that is neither justified nor even demonstrably deliverable. The second concern is that such a high level of growth in the rural area is entirely unsustainable (by comparison the main town tier, the second highest tier of the hierarchy comprising the most sustainable non-urban settlements, is only proposed to receive 50 more homes than South Norfolk’s villages).

To avoid further issues in respect of deliverability (a concern relating to the levels of growth directed towards both the Norwich urban area and South Norfolk villages tiers) whilst ensuring development is directed to sustainable locations, it is our clear view that a higher proportion of the housing requirement should be directed to deliverable sites at the Main Towns. Aylsham in particular represents a sustainable settlement with at least three medium-scale deliverable housing options (we consider our client’s site to be principle amongst them – see Annex 1) that would provide a significant contribution towards the growth needed across Greater Norwich. As it stands, and in light of these concerns, we recommend that the current proposed distribution of growth should be recast to reflect the suitability of the Main Towns. Resultantly, this tier of the hierarchy should receive a notably increased level of growth.

Regardless of the current approach to the distribution of growth, and as set out in our response to Question 14 below, it is our view that the proposed housing figure will also require a significantly uplift to account for City Deal and Tech Corridor growth commitments. To ensure the plan successfully allocates a range of additional sustainable and – vitally – deliverable sites that are able to meet an increased need for new homes from the earliest years of the plan period we consider that a large proportion of this additional growth will inevitably need to be met on unconstrained sites at the larger settlements of the hierarchy.

We therefore strongly suggest that the Main Towns should play a prominent role in meeting these additional needs. The identification of deliverable sites at the five Main Towns should be the priority due to the sustainability benefits these settlements offer, allied with their clear capacity to grow. These opportunities should then be complemented by additional sites across the remainder of the hierarchy in instances where it is clear development is deliverable and would result in wider sustainability benefits.

Support

Representation ID: 22254

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

The proposed settlement hierarchy and the proposed distribution of housing, as set out in Policy 1, is supported.

Comment

Representation ID: 22276

Received: 16/03/2020

Respondent: Barton Willmore

Q13) Do you agree with the proposed Settlement Hierarchy and the proposed
distribution of housing within the hierarchy?
2.33 Simply put, No. Firstly, as highlighted in our response to Question 9, we believe the amount
of homes to be identified within the GNLP should as a very minimum be consistent with
housing need calculated by the Standard Method and then be increased to account for the
Growth Deal, advocated in the SHMA. This would also help make up for the shortfall we have
highlighted against the GNLP to 2026. Second, as detailed in our response to questions 38 to
46, the proposed distribution of housing within the hierarchy is unjustified and would not be
effective at delivering housing requirements over the plan period.
2.34 We would stress that a number of the allocations that appear to have been ‘rolled forward’
are failing to deliver homes. Allocation GT6 (Land at Brook & Laurel Farm) has not yet
commenced, despite permission being granted in June 2014. Work is yet to commence on
Allocation GT11, and we note that planning permission has not yet been granted for the
Larkfleet Homes site East of Broadland Business Park. Combined these sites are anticipated
to deliver 1,450 homes. Accounting for the “Nathaniel Lichfield & Partners Start to Finish –
How Quickly do large scale housing sites deliver” (NLP November 2016) on average these
sites would take 5.3 years to actually deliver houses, of which circa 13 months would be post
approval of planning. The lead in time for smaller sites below 500 units extends to circa 2
years from the grant of planning permission. Sites GT13, GT14, DRA1, HEL1 and REP1 fall
into this category. The AMR provides no evidence of delivery or update on progress. As such
to carry forward such allocations, the Authorities must (a) be confident (through the provision
of clear evidence) that they will be granted planning permission and commence in the Plan
period; and (b) be confident that sites GT6 and GT11 will start delivering units before 2028
given the average build out rates for sites of this size are identified by NLP to represent no
more than 86 dwellings per annum on Greenfield sites and no more than 52 dwellings per
annum on brownfield sites.2.35 In addition, we highlight that Sites GT12 and GT16 are anticipated to deliver 3,500 and 3,000
dwellings respectively in the Plan period. To date neither have commenced – despite being
anticipated to deliver from 2019/2020 and 2016/2017 respectively. In the case of GT12, the
latter phases are dependent on Infrastructure Forward Funding. Neither sites have secured
detailed permission for any phase. Even if permission was to be granted now, accounting for
NLP lead in times, they would not commence before 2021. This is ambitious, and even then
would have to deliver housing at a rate of 220 dwellings per annum in the case of GT12, and
227 dwellings per annum in the case of GT16 (as set out in the AMR which anticipates no
housing on site until 2024). NLP 2016, highlights average build out rates of 171 dwellings per
annum on greenfield sites of this size, reducing to 148 dwellings per annum for brownfieldsites. Based on these averages and the anticipated delivery rates in the 2018/2019 AMR, it
would result in a housing shortfall of over 1,200 homes in itself. Accordingly, these allocations
should be reduced to 2,927 (GT12) and 2,388 (GT16) respectively. The shortfall must be
accounted for elsewhere.
2.36 Further, we would highlight that the sites identified above are within the Growth Triangle,
where there are clearly questions over deliverability. Allocating additional homes to the
Growth triangle in the context of under-delivery on housing to date (a shortfall of 6,169
homes in the NPA), and uncertainty over delivery of sites, would further undermine confidence
in the ability of the GNLP to deliver on its needs to 2038.
2.37 In addition we note that Page 46 of the GNLP highlights uncertainty over the site of Carrow
Works. This accounts for a further 1,200 homes. If there is uncertainty over delivery it should
be removed from the Plan. Accordingly, accounting for Carrow Works, and the reductions to
allocations GT12, and GT16 we have highlighted above, a further 2,400 need to be identified
in the Plan to alternative locations, notwithstanding the additional housing we believe should
be provided for in response to Question 9.
2.38 We would also stress that Long Stratton is subject to 2no. Hybrid applications submitted Jan
and Feb 2018 for 600 dwellings (213 detailed) and 1,275 dwellings (zero detailed)
respectively. Both applications remain undetermined. Based on the NLP lead in times, it is
unlikely either of these will deliver any houses before 2023/24 (accounting for 5.3 years for
schemes of 500-999 dwellings and 5.7 years for schemes of 1,001 – 1,499 dwellings). Based
on average build out rates of 86 dwellings per annum, it is unlikely all of the 1,800 homes
can be delivered within the plan period to 2038, requiring a further adjustment.2.39 Accounting for the matters we highlight in paragraphs 2.33 – 2.36 above, the distribution of
housing set out in Map 7 and Policy 1 should be adjusted. In addition, we strongly object to
simply allocating 1,200 additional homes to South Norfolk Village clusters on the grounds of
sustainable development. These 1,200 homes should be brought back into the GNLP. Together
there is therefore a need to identify additional land for circa 4,000 homes as a minimum,
which would increase to circa 13,000 further homes should growth from the New Deal be
planned for, as we advocate in response to earlier questions.
2.40 As set out in our March 2018 representations we endorse a strategic growth option which
serves and supports an identified ‘Core Area’ whilst focusing and delivering development
along the A11 corridor, fulfilling the Spatial Objectives of supporting the Cambridge to
Norwich Tech Corridor plus locating growth near to jobs and infrastructure. We continue to
advocate this approach which will fulfil the Vision and Objectives of the GNLP, whilst achievingthe full potential of the Cambridge Norwich Tech Corridor in a sustainable way that is
consistent with the Climate Change Statement. This area should be the focus of
accommodating the above shortfall, and the Housing Growth Allocations and Policy 1 should
be updated to reflect that.
2.41 The proposed dispersal should align more closely with the Growth Strategy. As discussed
above there are aspects of the current approach which need amending and will require
additional new allocations to be identified. This should include locating additional
development in Wymondham, one of the largest towns on the Cambridge Norwich Tech
Corridor, and a reduction in reliance of Sites in the Growth Triangle in recognition of past
poor delivery.

Object

Representation ID: 22282

Received: 16/03/2020

Respondent: Hugh Crane Ltd

Agent: Savills

For full representation, please refer to the attached documents.

Support is given to the approach to focus development on the area around Norwich but additional consideration should be given to the inclusion of Blofield and Blofield Heath within the Strategic Growth Area to support growth aspirations for Greater Norwich.

Furthermore additional consideration should be given to the grouping of access to facilities at Blofield and Blofield Heath given the approach taken within the Neighbourhood Plan.

Consequentially it is considered appropriate to allocate additional growth to Blofield Heath.

Comment

Representation ID: 22323

Received: 16/03/2020

Respondent: Hopkins Homes

Whilst Hopkins Homes agrees with the broad strategy outlined, we do consider that a number of the existing villages within the wider Greater Norwich Area, both within and beyond the defined ‘Norwich Policy Area’ benefit from sufficient sustainability credentials so as to be able to accommodate greater levels of housing growth than are currently proposed.

Notably, Hopkins Homes have proposed sites on the periphery of the villages of Mulbarton and Scole within South Norfolk, both of which settlements benefit from facilities and good connections with nearby higher-order market towns which enable them to accommodate higher levels of growth than are currently envisaged through the proposed Strategy.

In respect of Mulbarton, the existing population in excess of 3,500 is higher than that of over half of the designated Key Service Centres, as confirmed by the data contained in Table 1 on Page 11 of the Draft Plan, which therefore further confirms the appropriateness of higher levels of proportionate housing growth than currently proposed within the Draft Plan.

Comment

Representation ID: 22325

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

3. POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY
3.1 Policy 1 sets out the proposed strategy and includes the proposed housing requirement, the proposed employment land requirement, the approach to fiveyear land supply and the spatial strategy. These are addressed below.
3.2 Policy 1 also sets out the approach to supporting infrastructure and the proposed distribution of development which are addressed in greater detail in Policies 4 and 7.1 to 7.4 respectively. These matters are responded to under those Policies rather than in response to Policy 1.
Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplacebased house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplacebased house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 201938 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.
3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy. 3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.
Exceeding the minimum housing need
3.12 The standard method also only provides the minimum local housing need, and the PPG (2a-010) identifies that this should be exceeded including in situations where there is a growth strategy or where strategic infrastructure improvements may drive an increase in housing need or where previous assessments of need are significantly greater than the standard method. All three of these situations arise in Greater Norwich.
The City Deal
3.13 Paragraph 13 of the Draft Local Plan identifies that the Greater Norwich City Deal requirements will be met through the Draft Local Plan. As the Greater Norwich City Deal forms a growth strategy which has been agreed with Government, the Local Plan is required to meet the requirements of the City Deal as this forms part of national policy as set out in paragraph 6 of the NPPF.
3.14 The City Deal identifies that strategic infrastructure is needed including to deliver a step change in housing delivery. It sets a target for an average of 3,000 homes per annum in the period 2014-19 and for 37,000 homes to be delivered in the period 2008-26.
3.15 MHCLG Live Tables identify that only 10,715 houses were built in the period 2014-19 in addition to the equivalent of 581 homes provided as student and older persons bedspaces. This provides a total of 11,296 or an average of only 2,259 homes per annum. It is therefore apparent that the short-term target of the City Deal has not been met and that accordingly this shortfall of 3,704 homes should be addressed as soon as possible to achieve the objectives of the City Deal. No such short-term uplift to remedy this shortfall is made within the Draft Local Plan contrary to the requirements of national policy in the form of the City Deal.
3.16 In the period 2008-19, the MHCLG Live Tables identify an equivalent of 19,416 housing completions, which means that in order to provide 37,000 homes in the period 2008-26 it will be necessary to deliver the remaining 17,584 in the period 2019-26 or an average of 2,512 per annum. However, the housing need identified in emerging Policy 1 of 40,550 homes 1 only provides for an average need of 2,028 homes per annum. The housing need of the Draft Local Plan therefore again does not provide a sufficient number of homes to meet the housing needs identified in the City Deal.
3.17 It is therefore evident that the Draft Local Plan does not meet any of the targets of the City Deal and that it is accordingly not effective, not justified, not positively prepared and inconsistent with national policy.
Previous assessments of need
3.18 The SHMA for Central Norfolk identifies that there was a need to deliver 44,714 homes from 2015-36 to accord with the City Deal. In the period 2015-18, the equivalent of 6,680 homes were delivered and so there is a residual need for 38,034 homes from 2018-36, or 2,113 per annum.
3.19 Assuming that this need remained constant across the period 2036-38, there would be a need for 42,260 homes to accord with the City Deal based on the latest assessment of housing need. The Local Plan does not therefore provide a sufficient number of homes to meet the latest assessment of need or to accord with the City Deal.
The housing need of students
3.20 The standard method is informed by the 2014-based household projections which assume that the five-year migration trends which were experienced in the period 2009-14 will be maintained. The Higher Education Statistics Authority (HESA) identified that University of East Anglia (UEA) had 16,640 students and the Norwich University of the Arts had 1,485 students in 2009 providing a total of 18,125, but that this had increased to 18,140 by 2014 with 16,265 at UEA and 1,875 at the University of Arts. The 2014-based projections which inform the standard method therefore assumes that the student population will increase by 15 people over five years or 3 per annum.
3.21 Paragraph 45 of the Draft Local Plan however indicates that the Universities in Norwich are expected to expand. In particular, the University of East Anglia (UEA) has announced plans to increase its students from 15,000 to 18,000 in the next decade, an increase of 300 students per annum. 3.22 The increased migration of 297 students per annum3, even assuming that the student population of the University of the Arts remains constant, are not taken into account in the projections.
3.23 These additional students at UEA will clearly have an impact on the housing need in Greater Norwich which is not taken into account within the standard method. Either these will generate a need for an additional 2,970 bedspaces which is equivalent to 1,042 houses or if these students are accommodated in the housing stock it will be necessary to deliver an additional 1,042 homes to accommodate them. It will be necessary to deliver such accommodation to meet the objectively assessed needs and to accord with the Vision of the GNLP.
3.24 Once the needs of these additional students are taken into account this would increase the minimum local housing need from either 41,379 or 41,361 to either 42,421 or 42,403 homes over the plan period. This broadly accords with the 42,260 homes necessary to accord with the City Deal.
The needs of those in institutional accommodation
3.25 The SHMA for Central Norfolk identifies a need for 3,909 people aged 75 or over to be accommodated in residential institutions over the period 2015-36. The 2014 based institutional population projections identify an increase of 2,060 such people within the GNLP area over the period 2015-38 comprising 1,088 in Broadland, 291 in Norwich and 681 in South Norfolk.
3.26 In the period 2015-18, a total of 234 bedspaces in older persons communal establishments were built, including 7 in Broadland, 225 in Norwich and 2 in South Norfolk. This leaves a residual need for 1,826 bedspaces in the period 2018-36, comprising 1,081 in Broadland, 57 in Norwich and 679 in South Norfolk.
3.27 The household projections which inform both the SHMA and the standard method do not include this population and the SHMA correctly recognises that in the absence of 1,826 bedspaces in communal establishments the population who would have occupied these will remain in the dwelling stock rather than releasing them as assumed in the projections. 3.28 It is therefore apparent that there is a need for 1,826 bedspaces in communal establishments in addition to the standard method and that in the absence of such provision the housing requirement will need to increase as fewer dwellings will be released to the market. The number of dwellings that would not be released in the absence of such residential institutions is 987 using the calculation identified in the PPG (63-016a) comprising 584 in Broadland, 33 in Norwich and 369 in South Norfolk.
3.29 It will therefore either be necessary to make provision for the 1,826 bedspaces or increase the housing requirement by 987 homes to meet the objectively assessed needs within the GNLP and to accord with the Vision of the GNLP. This would result in a need for either 43,408 or 43,390 homes or to 42,421 or 42,403 homes and 1,826 bedspaces.
The housing requirement
3.30 The Delivery Statement on page 37 indicates that the Draft Local Plan provides a sufficient supply of housing sites to exceed the identified housing need of 40,550 homes by 9%. However, as identified above, there is actually a need for at least 42,400 homes to accord with the City Deal, meet the minimum local housing need and to accommodate the growth plans of UEA as well as a need for an additional 1,800 bedspaces in communal establishments.
3.31 In order to provide sufficient flexibility to ensure that these minimum needs will be delivered, taking account of the non-delivery of sites, it has been found by numerous Inspectors that it is appropriate to set the housing requirement above the minimum housing need4 as the Draft Local Plan seeks to do.
3.32 In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 23,637 housing completions in the period 2008-19. However, only 18,835 homes have been delivered which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 25%. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement 25% in excess of the minimum need for circa 42,400 homes. This would produce a housing requirement for circa 53,000 homes. This is illustrative that there is a need for a significant contingency allowance in Greater Norwich to ensure that needs are actually met. It is therefore recommended that the proposed contingency of 9% is retained as a minimum but this should be significantly greater, which in addition to the minimum housing need for circa 42,400 homes produce a housing requirement for at least 46,216 homes.
Contingency to respond to changes
3.33 The Government has identified an intention to review the standard method in September 2020 and this will be required to be responded to in the Greater Norwich Local Plan to meet the minimum local housing needs at the point of submission as required by the PPG (2a-008). This proposed review of the standard method means that the minimum housing needs may change from the 42,400 identified above. It may be that the minimum housing needs increase significantly and accordingly a sufficient developable supply (including the required contingency set out above) should be planned for to ensure that the emerging GNLP will be able to respond to the identified minimum needs at the point of submission as required by the PPG (2a-008).
3.34 Whilst it is not possible to identify the need which will arise from this review at present, it is considered that a sufficient developable supply (including the required contingency set out above) should be planned for to significantly exceed the identified need for at least 42,400 homes and provide confidence that the minimum needs arising from the review will be able to be accommodated.
Employment Land Requirement
3.35 As set out in the GNLP, there is no quantitative need for additional employment sites across the GNLP area as a whole. Nevertheless, the GNLP allocates an additional 40ha providing a total of 360ha of employment land allocations to meet the underlying demand and provide choice to the market.
3.36 Whilst these allocations will assist the economic growth of the area and represent positive planning, if a significant proportion of these are actually developed and occupied, they will be dependent upon greater numbers of incommuters from outside of the plan area. Accordingly, an appropriate monitoring framework should be put in place to ensure that a sufficient number of homes are provided to accommodate the workforce to avoid the resultantenvironmental harms of a greater dependency on long-distance commuting flows.
3.37 If the monitoring framework indicates that a greater number of jobs have been accommodated than the growth in the resident workforce such that the economy of the area becomes more dependent upon unsustainable long-distance incommuting flows, this should trigger an immediate review of the GNLP alongside a policy response with residential planning applications being considered more favourably until such time as the GNLP review is adopted to address the imbalance.
3.38 Similarly, if an insufficient amount of employment land is actually developed and occupied, this should trigger an immediate review of the GNLP to bring forward additional employment land allocations alongside a policy response to consider employment planning applications more favourably in the interim.
The approach to five-year land supply
3.39 Policy 1 proposes that the five-year land supply will be assessed across the plan area and that enough allocations are provided to demonstrate a five-year land supply at adoption. However, there is no evidence that this is the case as the GNLP is not supported by a housing trajectory contrary to paragraph 73 of the NPPF. Pegasus Group reserve the right to respond on this matter when the necessary evidence is made available.
Spatial Strategy
3.40 The Table at Policy 1 details the distribution of housing supply across the settlement hierarchy, including proposed new allocations as follows;
- Norwich urban area - 30,560 dwellings – approximately 70% of supply
- Main towns – 6,342 dwellings – approximately 14% of supply
- Key Service Centres – 3,417 dwellings – approximately 8% of supply
- Village clusters – 4,024 dwellings – approximately 9% of supply
3.41 Policies 7.1 to 7.5 provide further detail on the distribution of sites and the composition of existing and proposed allocations with regard to their size and brown or green field status. 3.42 We have concerns over the proposed spatial strategy of the emerging GNLP owing to its over reliance on housing delivery in the Norwich urban area and the proposed discrepancy in terms of settlement hierarchy between the quantum of housing allocated to Main Towns, Key Service Centres and Village Clusters.
3.43 While the Norwich urban area is a sustainable location for growth, reliance on this area for the delivery of approximately 70% of the housing growth of the GNLP up to 2038 places a requirement on existing infrastructure to accommodate an additional 30,560 dwellings in the plan period, it also requires an annual delivery rate within the area of 1,698 dwellings per annum over each of the next 18 years. This requires that the level of development in Norwich urban area alone is broadly consistent with that which has been achieved across the entire GNLP plan area since 2008. This does not appear to be realistic. If the necessary boost to housing supply is to be achieved this will require a greater range and choice of sites across all of the sustainable settlements within the plan area.
3.44 Moreover, reference to Policy 7.1 demonstrates that delivery within the Norwich Urban Area is predicated on two substantial brownfield regeneration areas, the Northern City Regeneration Area and the East Norwich Strategic Regeneration Area and several urban extensions of over 1,000 dwellings each.
3.45 Brownfield regeneration is costly and time consuming and often involves the bringing together of multiple delivery partners to achieve. The likelihood of the totality of development proposed through regeneration delivering in the plan period is therefore slim.
3.46 New strategic urban extensions can also be timely to deliver with the need for new strategic infrastructure in terms of highways and drainage to be delivered in advance of new homes.
3.47 The Councils have not produced evidence to substantiate the delivery trajectory of the brownfield regeneration sites or the urban extensions in the Norwich Urban Area. We reserve the right to comment further on this matter at the Regulation 19 consultation stage. Delay in delivery at either source of supply could prejudice the delivery of the housing requirement of the GNLP and therefore go to the soundness of the plan. 3.48 Additional certainty over the delivery of the housing requirement could be achieved by changing the emphasis of the spatial strategy by allocating more housing to the Main Towns and the Key Service Centres, including Hethersett with an associated reduction in the percentage to be delivered in the Norwich urban area and within the Village Clusters.
3.49 Additionally, we have concerns over the fact that more dwellings are proposed in the spatial strategy across Village Clusters than are allocated at Key Service Centres, including a minimum of 1,200 dwellings through a South Norfolk Village Clusters Housing Site Allocations Development Plan Document.
3.50 Without certainty over the supply of land to deliver such a quantum of development in South Norfolk Village Clusters the soundness of the spatial strategy is questionable. As a percentage of the overall new housing allocations in the Reg 18 GNLP the current spatial strategy delegates approximately 15% to a document outside of its control (1200/7,840). This is not considered to be a reasonable approach and prejudices the delivery of the emerging GNLP by 2038.
3.51 A Settlement Hierarchy approach to the distribution of development would look to allocate a higher percentage of housing to more sustainable locations with smaller amounts being allocated to lower order settlements in recognition that small developments at villages can help maintain service provision, provide vitality and help address local market and affordable housing needs.
3.52 The Reg 18 GNLP allocates more development to Village clusters than to Key Service Centres which is a counter intuitive approach to achieving sustainable development. We consider this matter should be addressed by allocating additional sites at Hethersett, with Pigeon being able to provide land for the development of new community facilities, over and above sites for new housing development.
3.53 In failing to provide an increased number of dwellings at Main Towns and Key Service Centres the Councils are also missing the opportunities presented by Pigeon to provide new community facilities that can support existing and proposed new development in sustainable locations for the plan period and beyond. 3.54 The preceding representations on the Spatial Strategy are all set in the context that the identified housing need does not even accord with the minimum set by national policy and does not take account of the needs of specific groups. It is therefore evident that the quantitative elements of the Spatial Strategy will need to be revised to ensure that housing needs can be met across the GNLP area. This should be achieved through directing more growth to the Main Towns and Key Service Centres to counterbalance the disproportionate levels of growth proposed within the Norwich urban area and Village Clusters.

Comment

Representation ID: 22364

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

3. POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY
3.1 Policy 1 sets out the proposed strategy and includes the proposed housing requirement, the proposed employment land requirement, the approach to fiveyear land supply and the spatial strategy. These are addressed below.
3.2 Policy 1 also sets out the approach to supporting infrastructure and the proposed distribution of development which are addressed in greater detail in Policies 4 and 7.1 to 7.4 respectively. These matters are responded to under those Policies rather than in response to Policy 1.
Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplacebased house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplacebased house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 201938 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.
3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy. 3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.
Exceeding the minimum housing need
3.12 The standard method also only provides the minimum local housing need, and the PPG (2a-010) identifies that this should be exceeded including in situations where there is a growth strategy or where strategic infrastructure improvements may drive an increase in housing need or where previous assessments of need are significantly greater than the standard method. All three of these situations arise in Greater Norwich.
The City Deal
3.13 Paragraph 13 of the Draft Local Plan identifies that the Greater Norwich City Deal requirements will be met through the Draft Local Plan. As the Greater Norwich City Deal forms a growth strategy which has been agreed with Government, the Local Plan is required to meet the requirements of the City Deal as this forms part of national policy as set out in paragraph 6 of the NPPF.
3.14 The City Deal identifies that strategic infrastructure is needed including to deliver a step change in housing delivery. It sets a target for an average of 3,000 homes per annum in the period 2014-19 and for 37,000 homes to be delivered in the period 2008-26.
3.15 MHCLG Live Tables identify that only 10,715 houses were built in the period 2014-19 in addition to the equivalent of 581 homes provided as student and older persons bedspaces. This provides a total of 11,296 or an average of only 2,259 homes per annum. It is therefore apparent that the short-term target of the City Deal has not been met and that accordingly this shortfall of 3,704 homes should be addressed as soon as possible to achieve the objectives of the City Deal. No such short-term uplift to remedy this shortfall is made within the Draft Local Plan contrary to the requirements of national policy in the form of the City Deal.
3.16 In the period 2008-19, the MHCLG Live Tables identify an equivalent of 19,416 housing completions, which means that in order to provide 37,000 homes in the period 2008-26 it will be necessary to deliver the remaining 17,584 in the period 2019-26 or an average of 2,512 per annum. However, the housing need identified in emerging Policy 1 of 40,550 homes only provides for an average of 2,028 homes per annum. The housing need of the Draft Local Plan therefore again does not provide a sufficient number of homes to meet the housing needs identified in the City Deal.
3.17 It is therefore evident that the Draft Local Plan does not meet any of the targets of the City Deal and that it is accordingly not effective, not justified, not positively prepared and inconsistent with national policy.
Previous assessments of need
3.18 The SHMA for Central Norfolk identifies that there was a need to deliver 44,714 homes from 2015-36 to accord with the City Deal. In the period 2015-18, the equivalent of 6,680 homes were delivered and so there is a residual need for 38,034 homes from 2018-36, or 2,113 per annum.
3.19 Assuming that this need remained constant across the period 2036-38, there would be a need for 42,260 homes to accord with the City Deal based on the latest assessment of housing need. The Local Plan does not therefore provide a sufficient number of homes to meet the latest assessment of need or to accord with the City Deal.
The housing need of students
3.20 The standard method is informed by the 2014-based household projections which assume that the five-year migration trends which were experienced in the period 2009-14 will be maintained. The Higher Education Statistics Authority (HESA) identified that University of East Anglia (UEA) had 16,640 students and the Norwich University of the Arts had 1,485 students in 2009 providing a total of 18,125, but that this had increased to 18,140 by 2014 with 16,265 at UEA and 1,875 at the University of Arts. The 2014-based projections which inform the standard method therefore assumes that the student population will increase by 15 people over five years or 3 per annum.
3.21 Paragraph 45 of the Draft Local Plan however indicates that the Universities in Norwich are expected to expand. In particular, the University of East Anglia (UEA) has announced plans to incre3.22 The increased migration of 297 students per annum3, even assuming that the student population of the University of the Arts remains constant, are not taken into account in the projections.
3.23 These additional students at UEA will clearly have an impact on the housing need in Greater Norwich which is not taken into account within the standard method. Either these will generate a need for an additional 2,970 bedspaces which is equivalent to 1,042 houses or if these students are accommodated in the housing stock it will be necessary to deliver an additional 1,042 homes to accommodate them. It will be necessary to deliver such accommodation to meet the objectively assessed needs and to accord with the Vision of the GNLP.
3.24 Once the needs of these additional students are taken into account this would increase the minimum local housing need from either 41,379 or 41,361 to either 42,421 or 42,403 homes over the plan period. This broadly accords with the 42,260 homes necessary to accord with the City Deal.
The needs of those in institutional accommodation
3.25 The SHMA for Central Norfolk identifies a need for 3,909 people aged 75 or over to be accommodated in residential institutions over the period 2015-36. The 2014 based institutional population projections identify an increase of 2,060 such people within the GNLP area over the period 2015-38 comprising 1,088 in Broadland, 291 in Norwich and 681 in South Norfolk.
3.26 In the period 2015-18, a total of 234 bedspaces in older persons communal establishments were built, including 7 in Broadland, 225 in Norwich and 2 in South Norfolk. This leaves a residual need for 1,826 bedspaces in the period 2018-36, comprising 1,081 in Broadland, 57 in Norwich and 679 in South Norfolk.
3.27 The household projections which inform both the SHMA and the standard method do not include this population and the SHMA correctly recognises that in the absence of 1,826 bedspaces in communal establishments the population who would have occupied these will remain in the dwelling stock rather than releasing them as assumed in the projections. ase its students from 15,000 to 18,000 in the next decade, an increase of 300 students per annum. 3.28 It is therefore apparent that there is a need for 1,826 bedspaces in communal establishments in addition to the standard method and that in the absence of such provision the housing requirement will need to increase as fewer dwellings will be released to the market. The number of dwellings that would not be released in the absence of such residential institutions is 987 using the calculation identified in the PPG (63-016a) comprising 584 in Broadland, 33 in Norwich and 369 in South Norfolk.
3.29 It will therefore either be necessary to make provision for the 1,826 bedspaces or increase the housing requirement by 987 homes to meet the objectively assessed needs within the GNLP and to accord with the Vision of the GNLP. This would result in a need for either 43,408 or 43,390 homes or to 42,421 or 42,403 homes and 1,826 bedspaces.
The housing requirement
3.30 The Delivery Statement on page 37 indicates that the Draft Local Plan provides a sufficient supply of housing sites to exceed the identified housing need of 40,550 homes by 9%. However, as identified above, there is actually a need for at least 42,400 homes to accord with the City Deal, meet the minimum local housing need and to accommodate the growth plans of UEA as well as a need for an additional 1,800 bedspaces in communal establishments.
3.31 In order to provide sufficient flexibility to ensure that these minimum needs will be delivered, taking account of the non-delivery of sites, it has been found by numerous Inspectors that it is appropriate to set the housing requirement above the minimum housing need4 as the Draft Local Plan seeks to do.
3.32 In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 23,637 housing completions in the period 2008-19. However, only 18,835 homes have been delivered which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 25%. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement 25% in excess of the minimum need for circa 42,400 homes. This would produce a housing requirement for circa 53,000 homes. This is illustrative that there is a need for a significant contingency allowance in Greater Norwich to ensure that needs are actually met. It is therefore recommended that the proposed contingency of 9% is retained as a minimum but this should be significantly greater, which in addition to the minimum housing need for circa 42,400 homes produce a housing requirement for at least 46,216 homes.
Contingency to respond to changes
3.33 The Government has identified an intention to review the standard method in September 2020 and this will be required to be responded to in the Greater Norwich Local Plan to meet the minimum local housing needs at the point of submission as required by the PPG (2a-008). This proposed review of the standard method means that the minimum housing needs may change from the 42,400 identified above. It may be that the minimum housing needs increase significantly and accordingly a sufficient developable supply (including the required contingency set out above) should be planned for to ensure that the emerging GNLP will be able to respond to the identified minimum needs at the point of submission as required by the PPG (2a-008).
3.34 Whilst it is not possible to identify the need which will arise from this review at present, it is considered that a sufficient developable supply (including the required contingency set out above) should be planned for to significantly exceed the identified need for at least 42,400 homes and provide confidence that the minimum needs arising from the review will be able to be accommodated.
Employment Land Requirement
3.35 As set out in the GNLP, there is no quantitative need for additional employment sites. Nevertheless, the GNLP allocates an additional 40ha providing a total of 360ha of employment land allocations to meet the underlying demand and provide choice to the market.
3.36 Whilst these allocations will assist the economic growth of the area and represent positive planning, if a significant proportion of these are actually developed and occupied, they will be dependent upon greater numbers of incommuters from outside of the plan area. Accordingly, an appropriate monitoring framework should be put in place to ensure that a sufficient number of homes are provienvironmental harms of a greater dependency on long-distance commuting flows.
3.37 If the monitoring framework indicates that a greater number of jobs have been accommodated than the growth in the resident workforce such that the economy of the area becomes more dependent upon unsustainable long-distance incommuting flows, this should trigger an immediate review of the GNLP alongside a policy response with residential planning applications being considered more favourably until such time as the GNLP review is adopted to address the imbalance.
The approach to five-year land supply
3.38 Policy 1 proposes that the five-year land supply will be assessed across the plan area and that enough allocations are provided to demonstrate a five-year land supply at adoption. However, there is no evidence that this is the case as the GNLP is not supported by a housing trajectory contrary to paragraph 73 of the NPPF. Pegasus Group reserve the right to respond on this matter when the necessary evidence is made available.
Spatial Strategy
3.39 The Table at Policy 1 details the distribution of housing supply across the settlement hierarchy, including proposed new allocations as follows;
- Norwich urban area - 30,560 dwellings – approximately 70% of supply
- Main towns – 6,342 dwellings – approximately 14% of supply
- Key Service Centres – 3,417 dwellings – approximately 8% of supply
- Village clusters – 4,024 dwellings – approximately 9% of supply
3.40 Policies 7.1 to 7.5 provide further detail on the distribution of sites and the composition of existing and proposed allocations with regard to their size and brown or green field status.
3.41 Our clients raise concern over the proposed spatial strategy of the emerging GNLP owing to its over reliance on housing delivery in the Norwich urban area and the proposed discrepancy in terms of settlement hierarchy between the ded to accommodate the workforce to avoid the resultant quantum of housing allocated to Main Towns, Key Service Centres and Village Clusters.
3.42 While the Norwich urban area is a sustainable location for growth, reliance on this area for the delivery of approximately 70% of the housing growth of the GNLP up to 2038 places a requirement on existing infrastructure to accommodate an additional 30,560 dwellings in the plan period, it also requires an annual delivery rate within the area of 1,698 dwellings per annum over each of the next 18 years. This requires that the level of development in Norwich urban area alone is broadly consistent with that which has been achieved across the entire GNLP plan area since 2008. This does not appear to be realistic. If the necessary boost to housing supply is to be achieved this will require a greater range and choice of sites across all of the sustainable settlements within the plan area.
3.43 Moreover, reference to Policy 7.1 demonstrates that delivery within the Norwich Urban Area is predicated on two substantial brownfield regeneration areas, the Northern City Regeneration Area and the East Norwich Strategic Regeneration Area and several urban extensions of over 1,000 dwellings each.
3.44 Brownfield regeneration is costly and time consuming and often involves the bringing together of multiple delivery partners to achieve. The likelihood of the totality of development proposed through regeneration delivering in the plan period is therefore slim.
3.45 New strategic urban extensions can also be timely to deliver with the need for new strategic infrastructure in terms of highways and drainage to be delivered in advance of new homes.
3.46 The Councils have not produced evidence to substantiate the delivery trajectory of the brownfield regeneration sites or the urban extensions in the Norwich Urban Area. We reserve the right to comment further on this matter at the Regulation 19 consultation stage. Delay in delivery at either source of supply could prejudice the delivery of the housing requirement of the GNLP and therefore go to the soundness of the plan.
3.47 Additional certainty over the delivery of the housing requirement could be achieved by changing the emphasis of the spatial strategy by allocating more housing to the Main Towns, including Diss, and the Key Service Centres with anassociated reduction in the percentage to be delivered in Norwich urban area and the Village Clusters.
3.48 Diss in particular is identified in the Reg 18 GNLP as having capacity for additional employment development. Diss is a net importer of workers with 2011 Census data showing only 4,939 economically active people living in the town compared to the 5,623 people working there. In order to balance homes and jobs and provide for sustainable development it is necessary for more houses to come forward at Diss, especially given the re-allocation of 10.8ha of employment land at the Town in the Reg 18 GNLP.
3.49 Additionally, we have concerns over the fact that more dwellings are proposed in the spatial strategy across Village Clusters than are allocated at Key Service Centres, including a minimum of 1,200 dwellings through a South Norfolk Village Clusters Housing Site Allocations Development Plan Document.
3.50 Without certainty over the supply of land to deliver such a quantum of development in South Norfolk Village Clusters the soundness of the spatial strategy is questionable. As a percentage of the overall new housing allocations in the Reg 18 GNLP the current spatial strategy delegates approximately 15% to a document outside of its control (1200/7,840). This is not considered to be a reasonable approach and prejudices the delivery of the emerging GNLP by 2038.
3.51 A Settlement Hierarchy approach to the distribution of development would look to allocate a higher percentage of housing to more sustainable locations with smaller amounts being allocated to lower order settlements in recognition that small developments at villages can help maintain service provision, provide vitality and help address local market and affordable housing needs.
3.52 In failing to provide an increased number of dwellings at Main Towns and Key Service Centres the Councils are also missing the opportunities presented by Pigeon to provide new community facilities that can support existing and proposed new development in sustainable locations for the plan period and beyond.
3.53 The preceding representations on the Spatial Strategy are all set in the context that the identified housing need does not even accord with the minimum set by national policy and does not take account of the needs of specific groups. It is therefore evident that the quantitative elements of the Spatial Strategy will need to be revised to ensure that housing needs can be met across the GNLP area. This should be achieved through directing more growth to the Main Towns and Key Service Centres to counterbalance the disproportionate levels of growth proposed within the Norwich urban area and Village Clusters.

Object

Representation ID: 22398

Received: 16/03/2020

Respondent: Norwich Green Party

We have the following concerns:

Norwich urban area: although we wish to see growth concentrated in and around Norwich, we do not wish to see growth allocated to areas which are not well served by public transport. EG we do not support strategic allocation at Taverham off Fir Covert Road because there are no plans or funding for upgrading public transport infrastructure along Fakenham Road. The failure to secure adequate Transforming Cities funds will prevent upgrading to public transport system for serving growth communities unless new sources can be obtained.

Main towns: growth should be limited to nodes on rail network.

Key service centres: growth should be limited to nodes on rail network.

Village clusters: oppose on climate change grounds, apart from identification of sites for local social housing.
'Delivery' skews distribution of housing allocations in favour of dispersal options. Delivery has nothing to do with sustainability; it is not an objective in the SA and should be disregarded for purpose of weighing up policies on sustainability grounds.

Comment

Representation ID: 22430

Received: 16/03/2020

Respondent: Gladman Developments

5.1 Question 13: Settlement Hierarchy
Settlement Tiers
5.1.1 It is agreed that the Norwich Urban Area, including fringe parishes such as Costessey, forms the principal settlement within the joint plan area and wider region. The continued identification of the Norwich Urban Area at the top of the settlement hierarchy is supported by Gladman and is it accepted that the Urban Area should accommodate the largest proportion of new development planned for the plan period.
5.1.2 The inclusion of Diss and Wymondham as Main Towns in the second tier of the settlement hierarchy is supported. Gladman agrees that both settlements provide some of the most logical and sustainable locations for new development within the Greater Norwich Plan area beyond Norwich itself. Further development should therefore be directed towards both Diss and Wymondham through the GNLP.
Gladman also supports the identification of Poringland as a “Key Service Centre”. Poringland represents one of the more sustainable settlements listed as a “Key Service Centre” in the draft settlement hierarchy. Proportionate development relative the role and level of sustainability should be directed to Poringland.
Distribution of Development
General comments on Distribution
5.1.3 The Plan adopts Option 3, supporting the Cambridge to Norwich Tech Corridor as the basis for the distribution of development through the GNLP. It is acknowledged that the Tech Corridor forms a core role in the economic ambitions of the GNLP and as a result it is both appropriate and sound to concentrate new development towards this broad strategic location. However, as advised in our previous representations, the implementation of this strategy should not come at the cost of maintaining the sustainability and important role played by settlements which fall outside this corridor. It is important that sufficient development is directed to these settlements to support their longer-term sustainability and functionality. Opportunities should also be taken to focus growth towards those settlements which are well served by public transport to support climate change objectives. As such, Gladman consider that a mix of Options 2, 3 and 4 should form the basis of the distribution of growth adopted through the GNLP rather than Option 3 alone.
Norwich Urban Area
5.1.3 The Norwich Urban Area forms the largest built area in the plan area and wider county and is home to the largest and most diverse housing need. The Norwich Urban Area has the greatest range of services and facilities, the most diverse retail offer, and forms the economic hub of the plan area and wider county. The City Deal and strategic growth corridor initiatives provide significant opportunities for job creation, largely concentrated in the Norwich urban area. This means that the Norwich Urban Area plays an integral role to achieving the economic ambitions of the joint Plan which should be responded to through the allocation of additional land for development through the GNLP.
5.1.4 Gladman is supportive of Costessey being identified as the location for the planned 1,000 dwelling contingency. Costessey forms an integral part of the Norwich Urban area, with strong public transport links into Norwich City Centre, as well as access to the strategic road network. The infrastructure in and around Costessey is already well developed and Costessey benefits from a wide range of existing services and facilities, as well as access to local sources of employment. Importantly, Costessey is located on the opposite side of the Norwich Urban Area to the strategic growth triangle, which is to experience significant levels of growth over the plan period. Costessey has relatively limited commitments and as such there is little to suggest that additional supply directed to the settlement would result in a saturated market and reduced housing delivery. Costessey therefore represents a suitable location at which further housing needs can be realistically be sustainably accomodated.
5.1.5 Gladman however considers that the contingency site identified for Costessey is needed now and as such should be identified as an allocation for housing through the GNLP. Further homes are required in the Norwich urban area to respond to the extended plan period, as well as to capitalise on and secure the delivery of strategic economic objectives for the Norwich to Cambridge Technology Corridor. The Site should be allocated for housing now, to ensure that there is sufficient flexibility provided in the housing land supply to ensure full delivery of housing needs identified for the Norwich urban area should housing delivery at the Growth Triangle be lower than anticipated.
Diss
5.1.6 Diss is a market town located in the very south of the plan area, and forms an important service, retail and employment role for a large rural hinterland which extends beyond the plan area into North Suffolk. Further development is required in Diss to maintain and protect the quality of services and facilities available in the town.
5.1.7 Only limited growth is identified for Diss through the GNLP as drafted. Supporting information advising highways constraints appears to be founded on a much higher level of growth than proposed and known to be available. The role of new development in addressing broader constraints, such as school capacity, does not appeared to have been fully explored. 5.1.8 It is considered that the strategy for Diss fails to adequately support the sustainability of the town, or its role as a service centre for wider rural area. The limited growth identified for the town does not support opportunities and objectives to enhance the retail offer in the town. Diss forms the most appropriate location for development in the south of the plan area. It is also well served by public transport, and additional growth here would align to climate change policy and objectives by minimising reliance on unsustainable modes of transport. Further allocations should therefore be sought at the town.
Wymondham
5.1.9 Wymondham is sustainable settlement located on the A11 corridor. The town is the largest population centre in the plan area outside the Norwich urban area. It features a wide range of services and facilities including a primary school, secondary school, food store, doctor’s surgery, pharmacy, and community centre. The town benefits from rail links to Norwich and Cambridge, with a high-quality bus route into Norwich City Centre.
5.1.10 Wymondham is located within the Norwich to Cambridge Tech Corridor with access to both the A11 and the Norwich to Cambridge railway line. The growth corridor forms the heart of the spatial strategy for the draft GNLP, yet despite Wymondham’s strategic position within the corridor, minimal additional growth is planned in the settlement in addition to already committed development.
5.1.11 Gladman consider that the absence of allocations in Wymondham significantly reduces the effectiveness of the GNLP in delivering Tech Corridor ambitions and opportunities to the town and respond to evidence of updated needs and policy requirements which will not be captured by existing commitments. Gladman acknowledge the potential for further growth in the town brought by the possible contingency. Gladman is supportive of the Councils consideration of further opportunities for growth in Wymondham, however consider that this contingency should be made an allocation to make the most of Strategy Growth Corridor opportunities, and respond to overall concerns submitted later in these representations regarding the proposed housing requirement and amount of development planned.
Poringland
5.1.12 Poringland is a sustainable settlement, featuring a primary school, GP surgery, Secondary School, Pharmacy, Community Centre, and Food Store. The village is also served by highly regular bus services to Norwich. Poringland therefore represents both a suitable and sustainable location for new development and forms arguably the most appropriate Key Service Centre at which to meet development needs. 5.1.13 Currently, the draft Plan does not seek to direct any growth to Poringland beyond committed development. Gladman does not consider this to represent a sound strategy noting the above sustainability credentials which makes the settlement the principal option for accommodating rural housing needs. Opportunities for further sites for allocations should be sought and identified through the GNLP.

Comment

Representation ID: 22438

Received: 16/03/2020

Respondent: Mr Derek Jones

Number of people: 2

Agent: Bidwells

Great Plumstead and Little Plumstead is identified as a Service Village in the Joint Core Strategy for Broadland, Norwich and South Norfolk, recognising its suitability as a location for small/medium scale residential development. Great Plumstead and Little Plumstead is designated as a Village Cluster in the draft GNLP. The Housing Spatial Distribution set out in Policy 1 of the GNLP Draft Strategy Document (Regulation 18) advises that, within Broadland, new sites in Village Clusters must be identified to deliver up to 480 dwellings. Policy 1 adds that those 480 additional dwellings will be distributed amongst those Broadland Village Clusters with ‘higher potential’ to accommodate growth.

Appendix 5 of the GNLP Draft Strategy Document lists Great and Little Plumstead among those Broadland Village Clusters with ‘higher potential’ to accommodate growth of 50-60 dwellings in the Plan period. This reflects the range of services and amenities available within the Village Cluster, which includes a primary school, village shop, village hall with car park, playing field and playground, church, allotments and a bowling green. Moreover, a local community group, with support from the Parish Council, has recently achieved planning permission for a new Community Shop/ Café with a post office, located within the Walled Garden on the Little Plumstead Hospital site. This is currently under construction, and is due to open in Summer 2020. The village is served by a bus service (KonectBus 5C), which runs through the village along Church Road, providing hourly access between the village and Norwich, Monday-Saturday. All of these services are within walking distance of GNLP0420R.

Despite this, no sites in Great and Little Plumstead have been identified for growth in the Plan period to 2038. Seemingly, the rationale for excluding new allocations from Great and Little Plumstead is due to the presence of significant existing commitments in the Village Cluster (129 dwellings). However, there does not appear to be any commentary as to whether these 129 consented dwellings are considered deliverable in terms of the NPPF definition, or if they are included in the 995 dwellings across Broadland’s Village Clusters which are considered deliverable in Policy 1 of the GNLP Draft Strategy Document.

From further review of Appendix 5 of the GNLP Draft Strategy Document, the emerging draft allocations across Broadland’s Village Clusters have been identified to deliver a minimum of 358 dwellings, and a maximum of 517 dwellings. This offers no guarantee that the required 480 additional dwellings are deliverable in the Plan period to 2038.

With this in mind, we consider that more sites across the Broadland Village Clusters should be allocated to give the GNLP greater resilience in securing a deliverable supply of housing land to 2038. GNLP0420R is ideally placed to provide this resilience, by providing small-scale residential development, in accordance with the parameters of the current call for additional sites across Broadland and South Norfolk’s Village Cluster.

GNLP0420R is a site which is entirely deliverable, and should be taken forward as a site allocation to secure sustainable growth in Great and Little Plumstead to 2038.

Comment

Representation ID: 22449

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution
2.1.1 Gladman supports the identification of Poringland (including Framlingham earl) as a Key Service
Centre in the settlement hierarchy. As Poringland is evidenced as the fifth largest settlement outside
the Norwich Urban Area, development at a scale to reflect the size of the settlement should be
deemed appropriate.
2.1.2 Poringland has a wide range of services and facilities including a primary school, doctor’s surgeries,
local shops, a supermarket, public houses and a post office. The town also benefits from a regular
bus service into Norwich City Centre. The settlement, therefore, forms a sustainable and logical
location for new development.
2.1.3 Gladman are concerned that currently no further growth is directed towards Poringland. The town
provides a sustainable setting for future growth, in a place where people want to live. Deliverable
sites should come forward in this location that could contribute to local economic, social and
environmental aspirations. Gladman believe the spatial strategy for housing growth needs to direct
higher numbers to sustainable settlements within the ‘Key Service Centres’ tier, such as Poringland.
This would help alleviate the pressure of delivery for larger strategic sites, with smaller allocations
that could deliver during the early stages of the adoption of the plan. .

Comment

Representation ID: 22454

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution (Question 13)
2.1.1 Gladman is supportive of the identification of Diss as a Main Town within the settlement hierarchy.
Diss has the widest range of shops and services of the main towns, as well as a broad range of
employment opportunities. The town is located to the north west of the junction of the A140 and
A143 and benefits from rail connections to Norwich and London as well as acting as hub for local
bus links. As such, the settlement forms a sustainable and logical location for further development.
2.1.2 Diss has a key role to play in supporting the surrounding villages and rural hinterland through its
services and facilities. The retail offering of Diss is key in this supporting role with the large rural
catchment extending it to parts of South Norfolk and northern Suffolk. As such, Diss demonstrates
positive vitality and viability and has the opportunity to support further housing growth. There
would be strong justification to provide further growth than is currently proposed in Diss due to
this strong retail offering and other services, along with the good transport links to Norwich and
beyond.
2.1.3 It is the view of Gladman that should the preferred strategy be transposed to the publication version
of the plan this would represent a missed opportunity. Currently two further sites are identified in
Diss to provide only a further 400 dwellings in addition to existing commitments. This gives a total
of 743 dwellings between 2018-2038, a level of growth is comparable to that of Harleston, a main
town that does not benefit from the same transport links as Diss and serving a much reduced retail
catchment.
2.1.4 It is suggested in the consultation document that growth at Diss has been limited due to highways
constraints and congestion being considered a barrier to significant growth. This in itself is based
upon local evidence, the Diss Network Improvement Strategy (February 2020), which Gladman do
not consider to be a robust document.
2.1.5 This Strategy only considers four scenarios for future growth of varying scales ranging from
background traffic growth to significant northern and southern growth. Gladman consider there to
a gap in the ranges considered. Neither the northern nor southern areas are determined to be
deliverable but there is no further investigation to investigate the ‘tipping point’. Indeed, it is
suggested in the strategy that should the GNLP pursue a different option to those tested these
would also need to be tested, as the document currently does and therefore additional testing will
be required. As well as this testing Gladman suggest that other scenarios could be investigated as
it is Gladman’s view that additional growth than that proposed in the preferred options
consultation document could be accommodated at Diss. We are willing to engage with the Council
to see if development proposals being promoted by Gladman could provide assistance in
addressing highways constraints.

Comment

Representation ID: 22457

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution (Question 13)
2.1.1 Gladman is supportive of the identification of Costessey as being included as part of the Norwich
Urban Area within the settlement hierarchy. Within Costessey, there is a diverse range of services
and facilities including a primary school, secondary school, food stores, doctor’s surgery and
pharmacy, all within walking distance of the Site. The Site benefits from being in close proximity to
a high quality, frequent bus service which provides at least four buses an hour into the centre of
Norwich in less than 20 minutes. Norwich Railway Station is located approximately five miles from
the Site and provides frequent direct services to a number of locations including Ipswich, London
and Cambridge.
2.1.2 The preferred option for the distribution of development to focus growth around Norwich as well
as the within the Cambridge Norwich Tech Corridor is supported by Gladman. This corridor holds
significant potential for economic growth over the plan period and will hold a key role in securing
the economic ambitions of the emerging Plan, particularly in delivering identified job targets. The
concentration of housing in this corridor will help secure a sustainable distribution of development
over the plan period and support economic growth.
2.1.3 Norwich is established as the pre-eminent regional centre for the East of England and as such the
city accommodates the majority of the jobs, key services and economic, leisure and cultural facilities
to serve the majority of Norfolk and parts of North Suffolk. It is therefore appropriate that the
Norwich Urban Area, including Costessey, forms the location for the largest concentration of
development over the plan period (inclusive of the proposed contingency). The Plan’s approach in
this regard is therefore justified.

Comment

Representation ID: 22463

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution (Question 13) 2.1.1 Gladman is supportive of the identification of Wymondham as a Main Town within the settlement hierarchy. Wymondham is home to a diverse range of services and facilities inclusive of primary school and secondary school provision, food store, doctor’s surgery, pharmacy, and community centre. The town benefits from rail connections to Norwich and Cambridge, and from high quality bus links to Norwich. As such, the settlement forms a sustainable and logical location for new development.
2.1.2 It is noted by Gladman that Option 3 (supporting the Cambridge to Norwich Tech Corridor) has been selected by the Councils as the basis for the spatial strategy of the Local Plan. This corridor holds significant potential for economic growth over the plan period and will hold a key role in securing the economic ambitions of the emerging Plan, particularly in delivering identified job targets. The concentration of housing in this corridor will help secure a sustainable distribution of development over the plan period and support economic growth.
2.1.3 The location of Wymondham in the heart of this strategic corridor means that the town will and should play an important role in fulfilling this economic potential over the plan period with further employment and housing land required. Wymondham therefore forms one of the most appropriate location within the plan area at which to concentrate development over the plan period (inclusive of the proposed contingency). The Plan’s proposed approach in this regard is therefore justified.

Support

Representation ID: 22467

Received: 16/03/2020

Respondent: Breckland District Council

Section 5 The Strategy Policy 1:- The Sustainable Growth Strategy Paragraph 168.
We support the development strategy proposals and in particular that no new settlements are proposed at Honingham Thorpe, Hethel and Silfield. However, we would welcome the opportunity to engage with GNLP were these proposals to come forward in the future.

Para 169 - For information Breckland also has planned significant growth along the A11 corridor at Attleborough, Snetterton Heath and Thetford.

Comment

Representation ID: 22470

Received: 16/03/2020

Respondent: Breckland District Council

Breckland DC seeks confirmation that the proposed growth from GNLP will not be of detriment to the growth planned within Breckland.
In particular the Council is concerned that the cumulative growth impacts on transport, power, water supply have been adequately addressed.

For information, BDC has significant growth in these areas with 4000 dwellings and employment land west of London Road at Attleborough, the significant employment growth plans for Snetterton Heath and housing and employment growth along A47 particularly at Dereham.

BDC has concerns whether the proposed improvements on A11 and A47 will be sufficient to meet the needs of the cumulative growth from the two planned areas. Equally is there sufficient Railway capacity to cope with increased growth.

Under the Duty to Cooperate, Breckland District Council would welcome the opportunity to engage with GNLP to explore a joint approach to any constraints which may arise as a result of the cumulative growth in both planned areas
see full response attached