Question 18: Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

There are only two mentions of air quality in the policy, one of which says that air quality should be protected. If that is to be achieved, then we must ensure that future development does not impact it negatively. One way to do this would be to adopt the principle, explicitly set out in the GNLP, that all new developments need to demonstrate that they will not reduce air quality in the long term. Air quality in Norwich is bad enough as it is, and the consequences to our health are becoming clearer on a daily basis.

In relation to multiple GNLP Sustainable Communities policies there is no mention of the food system. Increasing the opportunity for urban agriculture (allotment space, designated community gardens, space for small food enterprises) could help strengthen food security, reduce food poverty, increase health (mental and physical) and create stronger community bonds through inclusive activities and educational workshops. The benefits of including food on planning agendas has been outlined in many papers and an explicit food strategy for Norwich that allows food (production, distribution, consumption, and waste) to be included alongside other development staples could reap multiple rewards for the City.

There is talk of "Greater Norwich of having strong landscape protection policies". Most developments are very intrusive into the local landscape and not enough is done to both protect trees and require substantial new planting.
AWA talks of it's major strategy being to conserve water. This is all well and good as long as new housing drainage is laid to sufficient fall to ensure self cleansing.
The GP's, hospital (N&N) and dentists are not providing an adequate service at the moment through excessive demand, additional housing will merely exacerbate this. This is a failure of the planning system.

Q18: We have one comment on Policy 2 in respect of the preferred approach to sustainable communities. This relates to Item iii of the policy which sets out means of assisting the broad-based approach of the policy.
Item iii states that ‘delivery plans are required with planning applications for 100 dwellings plus ….’. It is far from clear what is meant by a ‘delivery plan’ and the requirement ignores the fact that planning applications are frequently promoted by individuals, landowners, institutions or promotional companies rather than housebuilders. Such applicants sell their land on to housebuilders following the granting of permission and therefore have no control over the timing or actual delivery of development. In addition, planning applications for sites of 100+ dwellings will generally take some time to be determined and will require S106 Agreements, so it is somewhat unrealistic to require detailed delivery plans (such as timetables) at the time of an application submission.

Our concern is that the aspirations in this policy, whilst laudable, are little more than aspirations. The actions suggested are not options - they are essential. The Village Cluster policy does not meet your aspirations. Our concern is reinforced by the SNDC view that Building Regulations can only be tightened to the extent that builders will accept that.

Some of the proposals set out, such as the need to retain landscape gaps between communities and water neutrality are commendable. Housing density should be higher, particularly in Norwich. The design and layout of victorian terraced housing might well be a model for our future low carbon world. This policy reads as a gloss to cover the shortcomings of the overall vision, it should be the main item on the menu with far greater emphasis on the location of new housing. Any Sustainability Statement should be carried out before allowing any site to be included in the Local Plan.

Commenting on Policy 2 – Sustainable Communities, CPRE Norfolk questions the use of the words “as appropriate” in the policy’s introduction, as this means the requirements would be far too open to interpretation as to what is “appropriate” and therefore opportunities to ensure that ‘mitigating and adapting to climate change, [and] assisting in meeting national greenhouse gas emissions targets’ will be missed.

This concern is particularly relevant when considering how new housing development in the “village clusters” will fulfil the first requirement to ‘ensure safe, convenient and sustainable access to on-site and local services and facilities including schools, health care, shops, leisure/community/faith facilities and libraries.’ The rationale behind these “village clusters” appears to be mainly based on the availability and accessibility of a primary school. However, safe, convenient and sustainable access to the other features on this list are equally important. Adequate health care and shops simply are not available in these ways to many of the preferred new sites for housing in the “village clusters”, therefore giving further reasons why such sites should not be included in the GNLP.

There is a worrying disconnect between the aspirations in point 6 with the need to ‘manage travel demand and promote public transport and active travel within a clearly legible public realm’, and the imposition of additional new housing in “village clusters”. It is difficult if not impossible to see how residents of the majority of this new housing will be able to use active travel or public transport, due to the likely distances from workplaces and the lack of suitable public transport.

If additional new housing is developed in “village clusters” most of the working residents will not have ‘good access to services and local job opportunities’. Instead there will be an unsustainable increase in the number of journeys to and from work using private vehicles, which will not be electric-powered certainly for the majority of the plan period. It is very doubtful if additional housed will provide enough business to keep a village shop open, but they will definitely increase the number of journeys made for delivery and service vehicles, making this housing even more unsustainable.

If communities are to ‘minimise pollution’ as required to do so by point 8, it is imperative that no additional new housing is allocated to “village clusters”, as this would lead to an increase in petrol and diesel-powered vehicle journeys to and from such housing. This, along with the resultant increase in congestion, makes this additional housing highly undesirable.

Commenting on Policy 2 – Sustainable Communities, Hempnall Parish Council questions the use of the words “as appropriate” in the policy’s introduction, as this means the requirements would be far too open to interpretation as to what is “appropriate” and therefore opportunities to ensure that ‘mitigating and adapting to climate change, [and] assisting in meeting national greenhouse gas emissions targets’ will be missed.

This concern is particularly relevant when considering how new housing development in the “village clusters” will fulfil the first requirement to ‘ensure safe, convenient and sustainable access to on-site and local services and facilities including schools, health care, shops, leisure/community/faith facilities and libraries.’ The rationale behind these “village clusters” appears to be mainly based on the availability and accessibility of a primary school. However, safe, convenient and sustainable access to the other features on this list are equally important. Adequate health care and shops simply are not available in these ways to many of the preferred new sites for housing in the “village clusters”, therefore giving further reasons why such sites should not be included in the GNLP.

There is a worrying disconnect between the aspirations in point 6 with the need to ‘manage travel demand and promote public transport and active travel within a clearly legible public realm’, and the imposition of additional new housing in “village clusters”. It is difficult if not impossible to see how residents of the majority of this new housing will be able to use active travel or public transport, due to the likely distances from workplaces and the lack of suitable public transport. Public transport links between Hempnall and nearby Key Service Centres are non existent and links to Norwich are inadequate.

If additional new housing is developed in “village clusters” most of the working residents will not have ‘good access to services and local job opportunities’. Instead there will be an unsustainable increase in the number of journeys to and from work using private vehicles, which will not be electric-powered certainly for the majority of the plan period. It is very doubtful if additional housing will provide enough business to keep a village shop open, but it will definitely increase the number of journeys made for delivery and service vehicles, making this housing even more unsustainable.

If communities are to ‘minimise pollution’ as required to do so by point 8, it is imperative that no additional new housing is allocated to “village clusters”, as this would lead to an increase in petrol and diesel-powered vehicle journeys to and from such housing. This, along with the resultant increase in congestion, makes this additional housing highly undesirable.

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change. To demonstrate the ability to secure these objectives, the preparation of a Sustainability Statement as part of an application for a major development is supported. The use of master planning for the delivery of larger strategic sites, in conjunction with community engagement, and provision of Delivery plans is also supported.
Whilst the requirement to ensure the efficient use of land by, amongst other things, providing an indicative minimum density of 25 dwellings per hectare, is supported, the policy, or supporting text, should make it clear that, as well as giving consideration to on site characteristics, consideration will be given to a range of other site / scheme specific issues, such as housing mix, design considerations and the densities of the surrounding area.

The TCPA is very pleased to see that Policy 2 has a strong focus on mitigating and adapting to climate change which is a national priority. However, the policy wording could be strengthened regarding healthier communities by including reference to ensuring new developments are designed to promote active lifestyles through physical activity such as walkable communities and connected pedestrian and cycle routes (please see Sport England and Public Health England’s Active Design principles: https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design). A commitment to reducing health inequalities would also be highly beneficial in addressing the health and wellbeing needs of the local population.

Sustainability statements Clause 175 should be required for all forms of development including alterations and conversions, not "Major" or "Minor". A simple 1 page of thought on the subject is not disproportionate to climate change needs.
Policy 2 Clause 3 why the weasel word "contribute" rather than "provide" and enhance bio-diversity.
Policy 2 Clause 10. Absolutely support the requirement for enhanced energy uplift above Building Control old standard

In principle this section makes sense. However, the is a heavy reliance on the requirements for statements by developers at the time of submitting a planning application. There is no statements regarding a macro approach to community planning or strong community involvement in planning prior to the submission of plans. It would make sense to engage communities at a much earlier stage in the approach suggested. We also wish to record our support for the coments made on this question by CPRE

The current predicament for Horsford is that due to increased development the B1149 becomes heavily congested with vehicles at peak travel times. Further development in the village would exacerbate vehicle movement and increase environmental pollution which is in conflict with GNLP Policy 2 regarding meeting greenhouse gas emission targets.
The Primary School cannot take further increased numbers of children and the doctors practice is also at capacity.

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change, is supported.
The requirement for major developments to submit a Sustainability Statement is also supported, as is the requirement for Delivery plans to be provided.

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change, is supported.

The requirement for major developments to submit a Sustainability Statement is also supported, as is the requirement for Delivery plans to be provided.

Lanpro generally supports this policy but without knowing where the small rural village cluster allocations will be made in South Norfolk and whether they are sustainable, we are concerned that they may not be able to meet some of these requirements. Lanpro offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, but are concerned about the scale of growth to be directed to such sites and particularly the amount that could be directed to locations outside the old NPA, as set out in our response to question 13.

How does housing development in "Village Cluster" ensure 'safe, convenient and sustainable access to local services and facilities' which are lacking in most villages?
There is no joined up thinking between the "Village Cluster" concept and the aspiration to 'manage travel demands and promote public transport'. Most villages have limited or no public transport.
"Village Clusters" are not where the jobs and services are which will therefore increase the car journeys required to access these. This does not correlate to 'minimising pollution'.

Glavenhill Ltd generally supports this policy but without knowing where the small rural village cluster allocations will be made in South Norfolk and whether they are sustainable, we are concerned that they may not be able to meet some of these requirements. Glavenhill Ltd offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth, but are concerned about the scale of growth to be directed to such sites and particularly the amount that could be directed to locations outside the old NPA, as set out in our response to question 13.

There are some excellent recommendations in the TCPA's State of the Union - reuniting health with planning in promoting healthy communities that will amplify the Policy 2 commitments. https://www.tcpa.org.uk/Handlers/Download.ashx?IDMF=cb4a5270-475e-42d3-bc72-d912563d4084. Particularly Page 35 diagram - an integrated approach to planning for health and wellbeing.
A commitment to work jointly with healthcare partners to ensure the commitments within Policy 2 contribute to addressing local health needs in a targeted, insight led approach. The use of Active Design principles to guide the implementation of Policy 2 would be appropriate.

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.

Bergh Apton is a rural village, at its nearest point, 7 miles from Norwich city centre. Bergh Apton has been grouped with Alpington and Yelverton as a village cluster for development. There is no school in the village, the nearest being at Alpington. There is no footpath from Bergh Apton to Alpington.
Of the 9 sites put forward in Bergh Apton, only the former blockworks on Church Road would have reasonable access to the school in Alpington, if a permissive path was provided.
Also, the road could be widened if it was felt that part of it was too narrow.

Hingham Town Council supports the policy with regard to Sustainable Communities, but again question it’s deliverability, with specific reference to Hingham. It is disappointing that the GNLP housing development site assessment has concluded that a Preferred option – GNLP0520 is contrary to this policy on several counts. The development would not be able to provide safe and convenient access to existing facilities in the town (ref policy 2.1) , it would not respect, protect and enhance the landscape character (ref policy 2.5) and would unlikely to be able to manage travel (ref policy 2.6) demand due to Hingham’s limited public transport. The preferred option site GNLP0520 certainly would not “minimise flood risk or reduce the cause and impacts of flooding” (ref policy 2.8).
Whilst the policy theory for Sustainable Communities on paper is very desirable, HOW is this going to be achieved when preferred sites for housing development are allocated that are contrary to this policy.
The GNLP team and Planning Authorities thereafter should actively seek information from residents affected by or potentially affected by flooding in the vicinity of a proposed site allocation or development, rather than accepting the submittance from the developers that flooding has been / can be mitigated.

With reference to policy point 2 i (page 62) “ ….using a recognised community engagement process will be encouraged on larger sites……..200 dwellings” this is not far reaching enough. Community engagement should be mandatory for any development that would have a significant impact on a community – for example – with specific reference to Hingham – a development of 80 houses would have a significant impact on the town, in terms of integrating into the community, burden on local facilities such as Drs surgery and school and associated parking issues, as well as the visual and character impact a development would have on a small historic town such as Hingham.

Linking references should be made to the newly commissioned review of the GNGB Sport and Facilities strategies which were last published in 2014. The work is being implemented through the Greater Norwich Sports Strategy Implementation Group and will develop a new collaborative and insight led approach to planning and delivering strategic outcomes for sport and physical activity using Sport England's Strategic Outcome Planning Guidance.
https://sportengland-production-files.s3.eu-west-2.amazonaws.com/s3fs-public/sopg-full-document.pdf?6LHbT31bSjHLqpLB944hucyPTAWiU0wi

The requirement for major developments to provide a Sustainability Statement is supported. However, the requirement for specific types of development to include a Health Impact Assessment is questioned.

Any requirements for new health care or sports facilities to support the scale of new development in Greater Norwich should be identified strategically in the preparation of the Local Plan and allocation of sites, in consultation with the NHS. Where large scale development (100+ homes) is proposed on unallocated sites then there would be greater justification to require applications to be supported by a bespoke Health Impact Assessment, but further guidance must be provided to understand the level of detail that would be required under such circumstances.

Where a need for health care infrastructure has been identified, whether through the Local Plan process or submission of HIAs on unallocated sites, funding should be delivered through the Community Infrastructure Levy.

Appropriate development management policies on design, open space and access can achieve the aim of ensuring schemes give new communities the best opportunity to live healthy and active lifestyles. These policies can be addressed generally within the Design and Access Statement rather than a separate Health Impact Assessment.

Terminology needs to be more carefully worded, particularly 'The NPPF also requires a positive approach to large scale renewable energy generation except for onshore wind energy development.' Without amendment the policy is unreasonable and restrictive. The 'preferred approach' implies footnote 49 of the NPPF which does not need to be repeated in local policy. A positive approach can be taken to onshore wind if the stipulations of NPPF Footnote 49 are met. The NPPF promotes sustainable development and therefore excluding onshore wind from the positive approach to planning is a policy conflict.

We support the preferred approach to sustainable communities, including the need for a Sustainability Statement. It is considered that adherence with all of the provisions of Policy 2 as proposed should be the norm for all future development in order to deliver sustainable development.
The proposed new settlement Honingham Thorpe would align with The Garden City Principles, and offer a unique opportunity for all elements to be provided in a holistic and mutually supportive manner. The Government has recognised the role of garden settlements in creating sustainable communities, whilst Policy Exchange and the Town and Country Planning Association have supported this approach and the unique opportunity it provides to encourage the emergence of more sustainable lifestyles.

Good to see a more rigorous approach being applied to water management and adopting more demanding standards. Although the GNLP focuses on new build (as mentioned in comment 13 above related to paragraph 107) what additional benefits could be gained from improvements to existing residential and commercial buildings?
Given water is such a vital resource and comments have been made regarding the serious water stress status of the area, how successful has Anglian Water’s ‘love every drop’ campaign been and do they propose continuance and escalation of this approach?
A fully updated and signed off water cycle study will be required to inform decisions about what is appropriate. This will be necessary to inform HRA conclusions and ensure that adverse effects on integrity will be avoided.
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.

Please see attached for full submission

Please see attached for full submission