Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

We do not need more house than we already have because there is insufficient employment for extra people in the immediate area. By building extra housing it would require workers to travel long distances to work, which is environmentally damaging.

The fundamental problem that this plan has is that it is suggesting that the ‘more of the same’ mass development and large scale migration into the County, is in some way ‘sustainable’. The experience of the previous 30+ years of significant development in and around Norwich has proved to be exactly the opposite –that it is NOT sustainable. The impacts on traffic numbers, air pollution, water resources, loss of countryside and open space, damage to biodiversity, extreme and dangerous pressure on the health services and social services – all of which are now in crisis – emphasises that this policy of ‘growth’ has not worked. Sustainability is the golden thread that runs through the planning system and is emphasised in the NPPF – to fail this test is to fail to justify the proposals and they should not proceed. – Clearly by any reading of the term sustainability, the current model and policies have failed, and the proposals in this new plan which continue on the same route, must therefore be deemed to fail the basic test of sustainability.
The statements throughout the document indicate time and again that the new proposed development will somehow bring improvements to peoples lives, their environment and their social and employment welfare. However, there does not appear to be any evidential justification for any such statements. Without any empirical evidence to support such statements, and in the light of past experience, to state that ‘more of the same’ will actually bring different results is clearly misleading and wrong. All such statements and allusions should be struck from the plan and in their place, it needs a clear indication of the effects and results of the development of the past 30 years – not dressed up and partially chosen bits of statistics that cover up the real truth of what people know to have happened in their county and to their lives, but an independently undertaken review of all the above areas of the functioning of the GNDP area (by at least two teams of independent academics from universities not in the region – who will allow peer review and accountability to their reports) this will then provide the basis for a new plan and a new set of objectives with information to allow reasoned judgement.
In the meantime, the proposals in the report to continue to add further development to the GNDP area should be halted as it is clearly unsustainable to propose more development when the existing development has failed to produce a sustainable, good society, economy and environment. There is already a vast amount of consented development potential which has yet to be realised in the current Plans – and which will no doubt continue to contribute to the decline in the quality of life of the County. There is therefore NO justification for more until proven evidence is available and presented to the Public in a manner which is not partisan and biased, and which will allow real assessment of the true effects of such development to be understood balanced against any benefits.

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

GNLP consultation-draft proposals document Feb 2020

POLICY 1 – SUSTAINABLE GROWTH

Q13 Do you agree with the proposed settlement hierarchy?

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

Q14 Do we support the approach to housing numbers?

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


POLICY 7- 4 VILLAGE CLUSTERS

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

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

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

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

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

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

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

Q14: At present, the growth strategy is very strongly based on the vast majority of housing growth (69%) taking place in the Norwich Urban Area. There may be a question as to whether the housing market can support such a high proportion of new housing being concentrated in this area. We note and agree with the total housing provision being a minimum figure of 44,340 new homes.
In respect of the housing commitments presented under Policy 1, we wish to query the figure of 4,024 homes attributed to village clusters. At present, there is no South Norfolk Village Clusters Housing Site Allocations document and therefore it is not possible to consider whether the above figure is achievable or suitable. This document should be published simultaneously with the Greater Norwich Local Plan or indeed, preferably, be combined with it.
We do not understand the approach to contingency sites set out in paragraph 162. The specific contingency at Costessey raises a number of questions:
• Why is Costessey the preferred location for a contingency site? This does not appear to be explained in the Strategy;
• What is the basis of the figure of 1,000 dwellings? and
• What is meant by ‘low delivery of allocated housing sites’ and how will this be measured? Additional clarification is required as to how this policy approach would be monitored.
We do agree that Wymondham is a suitable location for a contingency site and in our response to Document 2: Sites Plan we have set out suggestions for potentially accommodating a part of this contingency.

I think that to protect the countryside it would be best to develop sites already allocated in the Joint Core Strategy before any further sites allocated in the GNLP are built on. A phased approach will mean that developments are more sustainable, making use of new infrastructure already identified in the JCS.

Please see attachments for full representation

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

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

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

Please see attachment

General Objections

The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.

The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.

I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.

One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.

Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.

Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.

Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.

GNLP3003
I object to GNLP3003:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
• The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
• The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

I make no apology for echoing other residents concerns as detailed below.

General objections:
The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.
The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.
I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.
One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.
The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.
Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.
Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.
Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
Outside the development boundary for the village.
Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.
GNLP3003
I object to GNLP3003:-
Outside the development boundary for the village.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

The standard method is used in emerging GNLP to determine the minimum number of houses needed during the plan period. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Firstly, Paragraph 010 identifies the circumstances where increases to housing need might be appropriate, including where there is a growth strategy, strategic infrastructure improvements are proposed, and to meet unmet needs from a neighbouring area. The consultation document for emerging GNLP refers to employment growth and infrastructure. It is requested that the draft version of GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a have been taken into account for the housing requirement. Secondly, Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. It is not clear whether the housing requirement for emerging GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.

The standard method is used in emerging GNLP to determine the minimum number of houses needed during the plan period. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Firstly, Paragraph 010 identifies the circumstances where increases to housing need might be appropriate, including where there is a growth strategy, strategic infrastructure improvements are proposed, and to meet unmet needs from a neighbouring area. The consultation document for emerging GNLP refers to employment growth and infrastructure. It is requested that the draft version of GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a have been taken into account for the housing requirement. Secondly, Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. It is not clear whether the housing requirement for emerging GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

CPRE Norfolk also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable (or as CPRE Norfolk would argue, unsustainable) sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 68 Parish and Town Councils in Broadland and South Norfolk (over 37%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

COMMENT - Response to Greater Norwich Local Plan consultation:

Norfolk is a rural area, and tourism is an important business. It is the unspoilt rural nature and the preponderance of wildlife, and, to a certain extent the remoteness that makes it so attractive to many. Increased housing and roads will detract from that, and make life less tolerable for residents.
The incredibly-long documents submitted as part of this local plan (which very few people will ever read) include a statement of intent to improve public transport and promote cycling and walking. How can new roads be part of this plan? Yet the Norwich Western Link and the Long Stratton by-pass both figure in the plan. These expensive schemes should not be included, as some sensible revamping of junctions, and introduction of good public transport will ease congestion and make these new roads unnecessary, as well as improving connectivity for those many people who are unable to drive or do not own a car.
Similarly, the huge increase in housing build will only detract from the general ambience of Norfolk, including Norwich, as an historic city. It is time that local authorities encouraged the government to introduce schemes to make better use of existing housing stock, flats over shops, large houses used only by one or two people; and of course, to reduce immigration and the birth rate. It is local authorities who are landed with the responsibility of catering for this increase in population, and the problems it causes

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

Hempnall Parish Council also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has only occasionally exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.

Hempnall Parish Council wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. New site allocations for housing should be treated as phased development and these sites should not be built out until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. Hempnall together with a total of 68 Parish and Town Councils in Broadland and South Norfolk (over 37%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

GENERAL OBJECTIONS

The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.

The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.

I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.

One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.

OBJECTIONS SPECIFIC TO REEDHAM

Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.

The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.

Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.

There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.

Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.

Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.

Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.

Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.

SITE SPECIFIC OBJECTIONS

GNLP1001

I object to GNLP1001:-

•Outside the development boundary for the village.

•Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.

•Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.

GNLP3003

I object to GNLP3003:-

•Outside the development boundary for the village.

•Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.

•The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.

•The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

See comments made in relation to Question 13 on behalf of Welbeck Strategic Land III LLP

The Key Service Centres include Loddon which has, in the last few years, had 82 units built on the Beccles Road, 200 units under construction on George Lane, and 'preferred sites in the GNLP' on Beccles Road for a further 180 units with 20 units in Chedgrave. This will increase the population by 40+ % over the last census figures with little or no improvement in local facilities, and increase the local carbon footprint with a large increase in the number of cars.

The housing numbers suggested are excessive. There is also a case (made out in the CPRE representation) for a scheduling of site allocation over the period of the plan since the oversupply suggested in the draft will result in developers merely cherry-picking the most financially attractive sites.

The Policy 1 approach to windfall housing growth is supported as it provides flexibility to respond to higher economic growth and opportunities for self and custom build housing in accordance with the NPPF’s recognition of the important contribution of small sites (NPPF Paragraph 68) and those wishing to build or commission their own homes (NPPF Paragraph 61).

Policy 1 sets out three scenarios where additional windfall housing growth will be considered acceptable in principle where they would not have an unacceptable impact on the character and scale of the settlement and subject to other Local Plan policies:

1. Within settlement boundaries in accordance with the above settlement hierarchy. This should be amended to say “within and adjacent to settlement boundaries” with reference to Policies 7.4 and 7.5.

2. Elsewhere in village clusters, subject to the requirements of Policy 7.4. Please refer to separate representations made to Policy 7.4 under Q45 and Q46.

3. On sites of up to 3 dwellings in all parishes, subject to Policy 7.5. Please refer to representation made to Policy 7.5, which seeks to clarity that this should be a maximum of 3 dwellings per site in all parishes, not a total of 3 dwellings per parish.

See response to q13

We have already commented on our concerns regarding the deliverability of the large housing commitment which makes up 82% of the housing requirement that has been set out to 2038. There is no evidence to assess regarding this at the present time and this should be provided prior to the Regulation 19 stage.

Lanpro also believe that the overall housing requirement figure should be larger than the 44,343 homes set out in the draft plan. It is accepted that the updated NPPF now requires the new Standard Methodology to be used to assess housing need. However, the City Deal numbers have not been added to the need figure generated through the Standard Methodology. It is recognised that the Standard Methodology includes an uplift for affordability, but the NPPG clearly states that:

“The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area.”

The NPPG recognises that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the Standard Method indicates. It states that circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of factors such as:

“growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals).”

The agreed City Deal included the delivery of 3000 additional homes on top of JCS targets and an additional 13000 jobs. It is considered that these housing numbers should be added to the overall housing requirement figure.

Paragraph 162 refers to building in flexibility to support higher than trend economic growth incorporating the City Deal through contingency and windfalls only, rather than making it a key part of the strategy and identified housing requirement. If the Greater Norwich Authorities are serious about supporting the Vision set out in the plan for above target economic growth including within the Cambridge-Norwich Tech corridor and are serious about supporting the strategic initiatives of the LEP and Norfolk and Suffolk Economic Plan for jobs growth, then these additional housing numbers should be added to the standard methodology housing need figures to form part of the housing requirement figure. Furthermore, additional employment land should be allocated within the Hi-Tech corridor at Hethel as part of a new Garden Village settlement.

As set out above, we consider that a new settlement at Hethel should be allocated now. We support paragraph 167, which recognises the potential for a longer-term new settlement, provided this is located within the Cambridge Norwich Tech corridor.

We consider that greater clarity should be provided under Policy 1 regarding the housing numbers allocated to Norwich City itself and its fringe parishes to correspond with the preferred allocations document. Greater clarity is also needed regarding the proposed uplift figures. At the moment the table in policy 1 includes uplift as a commitment which is confusing when compared to the preferred new allocations tables which also include uplift. This needs to be properly and clearly explained.

By not including predicted windfall development in the calculation of housing numbers there will be an over-supply of houses.
Why are the sites allocated in the JCS not required to be built out before any new sites developed?
There is little evidence supplied to show that increasing the amount of land available for development actually increases the rate at which they are built.
Why is there no insistence on phasing of development?

We have already commented on our concerns regarding the deliverability of the large housing commitment which makes up 82% of the housing requirement that has been set out to 2038. There is no evidence to assess regarding this at the present time and this should be provided prior to the Regulation 19 stage.

Glavenhill Ltd also believe that the overall housing requirement figure should be larger than the 44,343 homes set out in the draft plan. It is accepted that the updated NPPF now requires the new Standard Methodology to be used to assess housing need. However, the City Deal numbers have not been added to the need figure generated through the Standard Methodology. It is recognised that the Standard Methodology includes an uplift for affordability, but the NPPG clearly states that:

“The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area.”

The NPPG recognises that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the Standard Method indicates. It states that circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of factors such as:

“growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals).”

The agreed City Deal included the delivery of 3000 additional homes on top of JCS targets and an additional 13000 jobs. It is considered that these housing numbers should be added to the overall housing requirement figure.

Paragraph 162 refers to building in flexibility to support higher than trend economic growth incorporating the City Deal through contingency and windfalls only, rather than making it a key part of the strategy and identified housing requirement. If the Greater Norwich Authorities are serious about supporting the Vision set out in the plan for above target economic growth including within the Cambridge-Norwich Tech corridor and are serious about supporting the strategic initiatives of the LEP and Norfolk and Suffolk Economic Plan for jobs growth, then these additional housing numbers should be added to the standard methodology housing need figures to form part of the housing requirement figure. Furthermore, additional employment land should be allocated within the Hi-Tech corridor at Hethel as part of a new Garden Village settlement.

As set out above, we consider that a new settlement at Hethel should be allocated now. We support paragraph 167, which recognises the potential for a longer-term new settlement, provided this is located within the Cambridge Norwich Tech corridor.

We consider that greater clarity should be provided under Policy 1 regarding the housing numbers allocated to Norwich City itself and its fringe parishes to correspond with the preferred allocations document. Greater clarity is also needed regarding the proposed uplift figures. At the moment the table in policy 1 includes uplift as a commitment which is confusing when compared to the preferred new allocations tables which also include uplift. This needs to be properly and clearly explained.

Please see attached for consultation response from Hempnall Parish Council.

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

The housing commitment numbers reflect the proposed growth distribution of the Settlement Hierarcy, which is supported. The approach to housing numbers appears to be sound, but we note that the draft plan proposes to allocate sites that already have the benefit of having been granted planning consent. There is a need to ensure that the deliverable housing commitment figure does not double count those sites proposed for allocation and those sites that already benefit from an extant planning permission, which will ensure that the housing commitment is sufficient to meet the identified need.

The approach to providing allocations in village clusters in South Norfolk within a separate plan is questioned and serves to add uncertainty regarding the ability of the plan to allocate sufficient sites to meet housing need across the Greater Norwich area over the plan period. A better approach would be to run consultation on all GNLP sites simultaneously.

We object to the approach for housing numbers and delivery. It is not considered that the proposed numbers or distribution of housing would provide sustainable development which meets the challenges of climate change or supports a post-carbon economy effectively.
The Greater Norwich area has a historic record of poor housing delivery which has only recently improved, largely as a result of large numbers of change of use conversions, and purpose-built student accommodation development. The Draft Plan relies upon 82% of the required housing being delivered on those sites which are currently allocated in the Greater Norwich area, which have not delivered in the current plan period.
Such an approach places the five-year housing supply in jeopardy and increases the opportunities for non-planned development, which can have detrimental impacts upon infrastructure, character and communities.
The proposed new settlement Honingham Thorpe would offer the opportunity to provide housing in a holistic and sustainable way in order to create a vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that new garden settlements can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares.
In order to meet housing need and meet climate change targets, more is required than delivering housing units. Rather, the focus is shifted to the creation of beautiful places and vibrant, resilient communities. A new settlement, based on The Garden City Principles, can deliver such communities together with a wide range of employment opportunities, mixed tenure housing, zero-carbon principles, sustainable transport, comprehensive green infrastructure and local food sourcing, together with comprehensive community governance and long-term stewardship.

Paragraph 144 places an emphasis is on providing for future human generations. There is a need to place the same value on nature which fulfils its own function, not just one for humans to enjoy and appreciate.

The map shows housing allocation in the Growth Triangle is proximate to Broads National Park. How will the impact of proposals within GNLP area be balanced and aligned with those in adjacent, separate (in terms of strategic planning oversight) areas?
There will likely be an increase in pressure on facilities within the Broads National Park as a result of residents from new developments, leading to increased disturbance on designated species (this disagrees with HRA findings), and increased wear and tear on infrastructure. How will the tariff system proposed be managed and funds allocated to provide for example vehicle charging points, repair of trails, gates etc within outside of the GNLP area. The Greater Norwich area can’t be viewed in isolation to surrounding areas managed by other authorities.
The RSPB is disappointed that HRA conclusions suggest the plan will be sound as there will not be any adverse effects on integrity of Natura 2000 and Ramsar sites, but in several areas this is due to reliance on plans that have not yet been completed such as the Norfolk RAMS and GI Strategy. Until such plans and approaches are finalised, they cannot be relied upon and cannot be taken to as a measure to demonstrate that the GNLP policies will be sound. The RSPB looks forward to seeing revised HRA recommendations based on an evidence base that is final and has certainty that it will be in place by the time the plan is adopted.

Please find attached representations, submitted on behalf of our Client – Berliet Limited.