Question 17: Do you support, object or wish to comment on the approach to Infrastructure?

Comment

Representation ID: 20100

Received: 25/02/2020

Respondent: RJ Baker & Sons

Agent: Cheffins

The approach set out in draft Policy 1 is somewhat vague in simply stating that the growth strategy will be supported by infrastructure improvements. We would suggest that more specific commitments are required in this policy or cross reference to other policy proposals.

Object

Representation ID: 20219

Received: 02/03/2020

Respondent: Nicola Harrison

No new roads should be built. All the money should be put into proving good electric bus services and trains where possible and building traffic free routes for cycling/walking. Air pollution is killing 40,000/yr in UK. Obesity is killing people (Storing up problems , Royal College of Physicians 2004).

Comment

Representation ID: 20847

Received: 13/03/2020

Respondent: Welbeck Strategic Land III LLP

Agent: Bidwells

The need to support sustainable growth through the provision of infrastructure improvements, such as schools and health centres, is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on a local need and not undermine delivery.

Consideration should be given to whether it is unviable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. schools and health centres, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan or whether site specific Section 106 obligations are appropriate.

Support

Representation ID: 21183

Received: 16/03/2020

Respondent: Hopkins Homes, Persimmon Homes and Taylor Wimpey

Agent: Bidwells

The need to support sustainable growth through the provision of infrastructure improvements, such as schools and health centres, is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, to mitigate the impacts of the specific development, based on a local need and must not undermine delivery.

Support

Representation ID: 21206

Received: 16/03/2020

Respondent: Kier Living Eastern Ltd

Agent: Bidwells

The need to support sustainable growth through the provision of infrastructure improvements, such as schools and health centres, is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, to mitigate the impacts of the specific development, based on a local need and must not undermine delivery.

Comment

Representation ID: 21288

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

The policy should say how the suggested improvements will be achieved e.g. through CIL, site specific policies, specific infrastructure policy.

Comment

Representation ID: 21396

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

The policy should say how the suggested improvements will be achieved e.g. through CIL, site specific policies, specific infrastructure policy.

Comment

Representation ID: 21522

Received: 16/03/2020

Respondent: Hingham Town Council

Whilst Hingham Town Council support the policy “the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services” – there is absolutely no evidence to show how this will be achieved in Hingham. Hingham is in need of improvements to its footways, roads, school, green infrastructure and public transport – HOW in this going to be improved in Hingham to support the growth of the town?

Support

Representation ID: 21736

Received: 16/03/2020

Respondent: Brown & Co

We support the approach to infrastructure.
The proposed new settlement Honingham Thorpe would provide on site infrastructure solutions from day one, including shops and a school, to support sustainability. The proposed development would allow for purpose built infrastructure to be provided, opposed to the retrofitting of existing overstretched infrastructure and the associated disruption for existing communities.
The Greater Norwich Local Plan Infrastructure Needs Report indicates that some local infrastructure is already over capacity, notably a number of substations. Additional information should be provided as to how carried forward and new allocations in these areas would overcome to ensure timely delivery.

Comment

Representation ID: 21832

Received: 16/03/2020

Respondent: Natural England

The current wording of the policy needs to be strengthened with regard to the environment and the delivery of GI. Currently it is rather vague and weak with regard to the essential role that quality GI must play if sustainable development is to be delivered under the Plan and meet the needs and aims as set out in the accompanying text under (144). The policy needs to cross reference Policy 3 in order to provide a strong and clear steer of what will be required to deliver the growth strategy whilst protecting and enhancing the area’s natural environmental assets, and to make the Plan sound. We recommend that the wording of the policy needs to be amended as follows (or a similar form of wording used):

“Sustainable development and inclusive growth are supported by…

 supporting infrastructure will be provided in line with policies 2, 3 and 4;
 environmental protection and enhancement measures including further improvements to the green infrastructure network will be delivered in line with policy 3.”
and:
“INFRASTRUCTURE
Page 4 of 11
The sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Improvements to existing green infrastructure and the creation of new green infrastructure will be delivered in line with policy 3.”
Whist we welcome recognition that new development must be supported by additional infrastructure of all kinds, in terms of GI, the reference to Appendix 1 is disappointing, given the complete absence of GI being mentioned in Appendix 1. The appendix is based on the findings of the undated Greater Norwich Local Plan Infrastructure Needs Report (GNLPINR). The GNLPINR make very limited reference to the provision of GI via a large scale map which shows strategic GI corridors and contains two sentences.
We strongly recommend that references to GI throughout the Plan should be made instead to the Greater Norwich Infrastructure Plan (dated July 2019). This document refers to GI in many sections, and in Appendix A – Infrastructure Frameworks includes a detailed list of the GI projects that will be delivered under the current Joint Core Strategy (JCS), and presumably rolled forward into the new Plan. Clearly, it will need to be updated due to the new development being proposed under this consultation. However, more detailed information about the quality and quantity of GI together with where on the ground it will be delivered needs to be included in the Plan.

Support

Representation ID: 21944

Received: 13/03/2020

Respondent: UEA Estates & Buildings

Agent: Bidwells

The need to support sustainable growth through the provision of infrastructure improvements is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development.

Comment

Representation ID: 22331

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: 22368

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.

Comment

Representation ID: 22481

Received: 16/03/2020

Respondent: Norwich Green Party

Energy: a number of City Council car parks have electrical load restrictions which limit the provision of additional chargers for electric vehicles especially rapid chargers. UK Power Networks might require grid improvements for the city centre area to enable new chargers to be connected to the network.

Green Infrastructure: Policy 1 Infrastructure refers to green infrastructure. We would like to see a step change in the provision of green infrastructure. The latter should be in addition to and not a replacement for the ongoing loss of informal green spaces such as sports grounds and playing fields to housing and other development. Green infrastructure relating to active travel has in several instances involved the removal of greenery to the detriment of urban heating and biodiversity; for example grass verges have been removed in order to widen shared pedestrian/cycle paths. All green infrastructure should involve the enhancement or new addition of green soft landscaping

Object

Representation ID: 22482

Received: 16/03/2020

Respondent: Norwich Green Party

We object to the GNLP reliance on individual private car use for accessing essential infrastructure, notably:

Health Care Requirements (ref Appendix 1): Parking is referred to in relation to 'Additional need resulting from growth' for the categories of 'Hospital' (NNUH) and Mental Health' (Julian Hospital). The expansion of car parking at NNUH is a major concern which needs addressing. Firstly, additional car parking facilitates the growth in car travel to the hospital and leads to an increase in carbon emissions and in air pollution. The NNUH has the largest car park in Norfolk which is more a policy failure than a proud record. The climate change emergency and the air pollution crisis have major public health implications and yet the NNUH and GNDP reliance on car travel is making public health worse. Secondly, there is a social equity problem because public transport provision serving the NNUH is unaffordable and second rate for many low income households and those without a car. Catering for car access to the NNUH has been a higher priority for policy makers whilst the provision of public transport to the NNUH has largely been left to the market. Money will need to be found for improving public transport infrastructure for serving the NNUH (such as re-organising the rather chaotic dropping off/picking up public transport arrangements outside the main entrance) in view of the smaller than anticipated Transforming Cities grant.

Waste Management (ref Appendix 1) we are concerned about the out-of-town locations of the planned recycling centres which will increase reliance on car-borne access. The increase in carbon emissions from additional car mileage could potentially negate any energy savings benefits from recycling. It would be helpful to calculate the net environmental costs and benefits of this recycling model (users take by car and van a range of materials to central location for recycling) to inform decision making, otherwise the local authorities could end up creating a net disbenefit and increasing the use of energy and carbon emissions.

High quality public transport infrastructure is referred to in Section 5 Policy 1 (para 168) and the Key Diagram shows eight Strategic Bus Corridors. We wish to reiterate our point that the GNDP authorities' Transforming Cities application was unsuccessful and Norwich, Portsmouth and Stoke will have to share a £117m pot.
As a consequence, the draft plan is not deliverable due to uncertainty around the ability to develop a city-wide public transport system for serving growth (including the level of growth to 2026 envisaged by the JCS). There are no other large sources of funding on the horizon which can make up for the deficiency. A lack of funding means that the draft GNLP fails the NPPF 'Effectiveness' test.

Support

Representation ID: 22632

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Support, with comments
The need to support sustainable growth through the provision of infrastructure improvements, such as schools and health centres, is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on a local need and not undermine delivery.
When considering infrastructure, consideration should be given to whether it is viable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. the requirement to provide schools and health centres on land which otherwise would be land developable for alternative uses, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan.
The potential for infrastructure costs which are specific to larger strategic sites to be secured by appropriate and negotiable Section 106 planning obligations, in order to ensure that such sites are deliverable and,
Greater Norwich Local Plan, Regulation 18 (c ), GNLP033
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QUESTION RESPONSE
importantly, that there is certainty regarding the timely delivery of the infrastructure on site, should be fully explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).

Comment

Representation ID: 22647

Received: 16/03/2020

Respondent: Sport England

Number of people: 2

Infrastructure requirements should be widened to include social infrastructure such as schools and outdoor/indoor spaces for sport and physical activity

Support

Representation ID: 22675

Received: 16/03/2020

Respondent: Mrs Nicole Wright

INFRASTRUCTURE

The social objectives of the plan are lacking. There is a need for this policy to address current and future health, social and cultural needs.

There is a strong focus on housing growth at the neglect of social and community needs and priorities. (It is not consistent with Paragraph 15 of the NPPF).

Support

Representation ID: 22698

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
32. Further to the response provided above in respect of Question 11, we support the approach to infrastructure that has been set out within Policy 1 – The Sustainable Growth Strategy in that the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Adequate infrastructure provision is key to supporting the development of the Plan area and enabling development to come forward. The statement provided within Policy 1 is vague and needs a greater explanation as to how the Greater Norwich Local Plan will ensure sustainable growth is supported by improvements to infrastructure.

Comment

Representation ID: 22727

Received: 16/03/2020

Respondent: Pegasus Group

Our client agrees with the broad sustainable growth strategy to support improvements to the transport system, green infrastructure and services. In particular, Policies 1 and 4, along with appendix 1, set out the infrastructure requirements to serve the growth in Greater Norwich based on evidence in the Greater Norwich Local Plan Infrastructure Needs Report. Appendix 1 includes proposed junction improvements to the A47/A146 Loddon Road. In the context of Land off Norton Road, our client would be supportive of these proposed works.
The GNLP should promote sustainable growth by allocating housing sites in sustainable locations in established settlements which possess high-quality public transport links and good range of services. A direct bus link serves Loddon to Norwich city centre and its public transport hubs (including Norwich train station). These excellent connections offer sustainable travel options to major employment hubs and recreation/leisure destinations in Norwich and further afield. Loddon also possesses a wide range of shops, services including a high school, medical centre, library, public houses and employment opportunities, including at the Loddon Industrial Estate. On this basis, the allocation of Land off Norton Road, Loddon site would be in accordance with paragraph 102 of the NPPF and encourage modal shift away from the private car. This, in turn, would assist the Councils in delivering their sustainable growth strategy.

Comment

Representation ID: 22789

Received: 16/03/2020

Respondent: Strutt & Parker LLP

we support the approach to infrastructure that has been set out within Policy 1 – The Sustainable Growth Strategy in that the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Adequate infrastructure provision is key to supporting the development of the Plan area and enabling development to come forward. The statement provided within Policy 1 is vague and needs a greater explanation as to how the Greater Norwich Local Plan will ensure sustainable growth is supported by improvements to infrastructure.

Comment

Representation ID: 22817

Received: 16/03/2020

Respondent: Norwich Green Party

Energy: a number of City Council car parks have electrical load restrictions which limit the provision of additional chargers for electric vehicles especially rapid chargers. UK Power Networks might require grid improvements for the city centre area to enable new chargers to be connected to the network.
Green Infrastructure: Policy 1 Infrastructure refers to green infrastructure. We would like to see a step change in the provision of green infrastructure. The latter should be in addition to and not a replacement for the ongoing loss of informal green spaces such as sports grounds and playing fields to housing and other development. Green infrastructure relating to active travel has in several instances involved the removal of greenery to the detriment of urban heating and biodiversity; for example grass verges have been removed in order to widen shared pedestrian/cycle paths. All green infrastructure should involve the enhancement or new addition of green soft landscaping,
We object to the GNLP reliance on individual private car use for accessing essential infrastructure, notably:
Health Care Requirements (ref Appendix 1): Parking is referred to in relation to 'Additional need resulting from growth' for the categories of 'Hospital' (NNUH) and Mental Health' (Julian Hospital). The expansion of car parking at NNUH is a major concern which needs addressing. Firstly, additional car parking facilitates the growth in car travel to the hospital and leads to an increase in carbon emissions and in air pollution. The NNUH has the largest car park in Norfolk which is more a policy failure than a proud record. The climate change emergency and the air pollution crisis have major public health implications and yet the NNUH and GNDP reliance on car travel is making public health worse. Secondly, there is a social equity problem because public transport provision serving the NNUH is unaffordable and second rate for many low income households and those without a car. Catering for car access to the NNUH has been a higher priority for policy makers whilst the provision of public transport to the NNUH has largely been left to the market. Money will need to be found for improving public transport infrastructure for serving the NNUH (such as re-organising the rather chaotic dropping off/picking up public transport arrangements outside the main entrance) in view of the smaller than anticipated Transforming Cities grant.
Waste Management (ref Appendix 1) we are concerned about the out-of-town locations of the planned recycling centres which will increase reliance on car-borne access. The increase in carbon emissions from additional car mileage could potentially negate any energy savings benefits from recycling. It would be helpful to calculate the net environmental costs and benefits of this recycling model (users take by car and van a range of materials to central location for recycling) to inform decision making, otherwise the local authorities could end up creating a net disbenefit and increasing the use of energy and carbon emissions.
High quality public transport infrastructure is referred to in Section 5 Policy 1 (para 168) and the Key Diagram shows eight Strategic Bus Corridors. We wish to reiterate our point that the GNDP authorities' Transforming Cities application was unsuccessful and Norwich, Portsmouth and Stoke will have to share a £117m pot.
As a consequence, the draft plan is not deliverable due to uncertainty around the ability to develop a city-wide public transport system for serving growth (including the level of growth to 2026 envisaged by the JCS). There are no other large sources of funding on the horizon which can make up for the deficiency. A lack of funding means that the draft GNLP fails the NPPF 'Effectiveness' test.

Support

Representation ID: 22852

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

We welcome the support for improvements to the transport system, but these need to be clarified. We are promoting the Loddon P&R site as a means by which the GNLP can improve P&R provision on the last remaining main route into the city.

We welcome the support for improvements to green infrastructure. We consider that the additional land at WCP should be safeguarded for such improvements, to promote confidence that the proposed allocations for developments in the vicinity will be able to rely on support for investment therein.

Support

Representation ID: 22880

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements is, such as schools and health centres, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on local needs, alongside not undermining the viability of housing delivery.

Support

Representation ID: 22906

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development.

Support

Representation ID: 22938

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development.

Support

Representation ID: 22958

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development.

Support

Representation ID: 22993

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development.

Comment

Representation ID: 23014

Received: 16/03/2020

Respondent: Hingham Town Council

Whilst Hingham Town Council support the policy “the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services” – there is absolutely no evidence to show how this will be achieved in Hingham. Hingham is in need of improvements to its footways, roads, school, green infrastructure and public transport – HOW in this going to be improved in Hingham to support the growth of the town?

Support

Representation ID: 23020

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements is, such as schools and health centres, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on local needs, alongside not undermining the viability of housing delivery.