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?
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21833
Received: 16/03/2020
Respondent: Natural England
We welcome the production of Table 8 – Key Issues addressed by policy 2 and agree with the issues covered.
In relation to issue 3.Green infrastructure it is appropriate for developments to be required to deliver GI off-site, or to financially contribute to this, where it is not possible to deliver quality GI which meets the needs of the inhabitants within that site. It would be useful to state here that development is expected to avoid loss or severance of existing GI networks, and to contribute to the enhancement and extension of existing GI on-site in order to strengthen these networks.
With regard to issue 9. Water the findings of the draft WCS should be referred to, and used to update the table text. A clear intention to adopt the higher standard for water of 110 litres per person per day needs to be stated in the policy. Mention is made of the need to retrofit existing housing and employment stock with water efficiency measures, which we support, and recommend that the Plan should contain a policy which supports this measure.
We support the production of a Sustainability Statement for major developments.
Q19. Do you support, object or have any comments relating to the specific requirements of the policy?
We warmly welcome and support this policy.
Under (3) we consider the provision of accessible GI for recreational uses should be included within the policy. This is necessary to help mitigate the impacts of additional recreational pressure from new housing development on designated sites.
Under (9) we endorse the adoption of the higher standard for water efficiency under the Building Regulations, which is also supported by evidence in the WCS. Reference to retrofitting existing buildings with water efficiency measures has also been as identified as essential in the WCS in terms of managing water demand. We suggest it would be appropriate to include some wording in this policy which recognises this need, and supports its implementation should Government adopt this approach in future.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21850
Received: 12/03/2020
Respondent: Hempnall Parish Council
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.
Please see attached for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21907
Received: 12/03/2020
Respondent: Home Builders Federation
The housebuilding industry, through the HBF, recognises that there is a need to move towards stronger measures to improve the environmental performance of new residential development. This is in terms of reducing carbon emissions in new homes, providing gains in biodiversity on all developments, green infrastructure and improving the environment around new developments.
However, the HBF, and our members, consider a national and standardised approach to improving such issues as the energy efficiency of buildings, the provision of renewable energy and the delivery of electric vehicle charging points to be the most effective approach that balances improvements with continued deliver of housing and infrastructure. It is the industry’s preference for a national approach to improving the environmental performance of residential developments, rather than local authorities setting their own standards. We consider this is necessary to allow research and development and supply chains to focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these new requirements. It is fundamentally inefficient to create a plurality of standards.
The industry will clearly need to take into account the Government’s measures on the Future Homes Standard and Bio-Diversity Gain – both of which will be mandatory for new residential developments in future. In terms of these new regulatory targets applying to new development from 2025 onwards – to deliver the objectives of the Future Homes Standard – the industry, with the leadership of the HBF, will be commissioning work to consider what the industry can do, taking into account developments in research and product development within that time-frame, and what new standards can feasibly be adopted and implemented by the industry.
Therefore, when considering their approach to such matters the councils should ensure that they are working within the current policy and legislative framework and not seeking to deliver a different range of standards that will work against the collective drive on this matter. The importance of a collective approach will also balance the cost of delivering the energy efficiency improvements required alongside other planning obligations and development aspirations that the Councils are seeking to deliver through the GNLP, such as meeting housing needs in full and improving the affordability of homes in this area. The Councils will therefore need consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer or leave some sites undeliverable.
Prior to the future standards the Councils must take account of current guidance which sets out the approach that Councils should take with regard to technical standards relating to energy efficiency with paragraph 50 of the NPPF stating that:
“Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.”
The Planning Practice Guidance (PPG) expands on this provision outlining that policies requiring higher energy performance standards than building regulations should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes. As such the aspirations of this plan with regard to improving the energy efficiency of new homes must be made within the context of this guidance if the plan is to be consistent with national policy and found sound.
It will also be important for the Council to ensure that the impact of this policy is fully tested within its viability study. We note that the second bullet point states that development will need to allow for new and changing technologies such as fibre optic networks and electric vehicles. Whilst the HBF is supportive of such infrastructure it is important that the costs of delivering this infrastructure is considered within he Councils’ viability assessment. These are not included as policy costs within the interim viability study and if specific policies are to be produced requiring such infrastructure they should be included as a specific cost.
For example, the installation of electric vehicle charging points (ECVP) is estimated to add on an additional cost of approximately £976 per unit. The introduction of EVCPs
in new buildings will also impact on the electricity demand from these buildings especially for multi-dwelling buildings. A requirement for large numbers of EVCPs will require a larger connection to the development and will introduce a power supply requirement, which may otherwise not be needed. The level of upgrade needed is dependent on the capacity available in the local network resulting in additional costs in relation to charge point instalment. The costs of installing the cables and the EVCP hardware will also vary considerably based on site-specific conditions in relation to the local grid. It is therefore essential that all costs are taken into account to ensure that their cumulative impact does not render the plan undeliverable.
Please find attached the HBF’s comments on the GNLP.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21925
Received: 24/03/2020
Respondent: Horsford Parish Council
Horsford Parish Council note that GNLP POLICY 2 – SUSTAINABLE COMMUNITIES states, “Development must be high quality, contributing to delivering inclusive growth in mixed, resilient and sustainable communities and to mitigating and adapting to climate change, assisting in meeting national greenhouse gas emissions targets.
To achieve this, development proposals are required as appropriate to: 1. 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 current predicament for Horsford is that the B1149 cannot cope with the amount of traffic now passing through and funnelled back and forth to the Broadland Northway. There are tailbacks and heavy congestion at peak times going out of the village from Brewery Lane Roundabout as far back into the village as Gordon Godfrey Way on Holt Road (approx. 3 miles) and equally in the evening traffic along Reepham Road from Hellesdon to Horsford. Whereas there was once a choice of four roads in and out of the village - Holt Road, Holly Lane, Drayton Lane and Church Street, there are now only two - Brewery Lane and Church Street. Further development would increase numbers of vehicles, exacerbate vehicle movements and increase environmental pollution, which conflicts with your statement GNLP Policy 2 regarding meeting national greenhouse gas emissions targets. Any additional housing developments should be located in or closer to Norwich, where there are far more realistic opportunities for people to walk or cycle to work.
This is also in conflict with Paragraph 6 in the introduction to the GNLP “The GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets”.
Horsford Parish Council also have concerns about the access road from Green Lane/Flag Cutters Way on to the Holt Road. The roundabout is not fit for purpose because it is offset and traffic coming out of Flag Cutters Way is obscured from traffic travelling South towards the roundabout. There have been occasions when HGV traffic has ignored the roundabout and continued straight on avoiding the roundabout altogether. Damaged kerbstones and central grassed area of the roundabout, where vehicles have driven over the roundabout when negotiating it, confirms poor design. This needs to be rectified. Norfolk Highways Department have accepted there is a problem and have put in a temporary 20 mph speed limit in the area either side of the roundabout. Horsford Parish Council believe this roundabout should be at the centre line of the B1149 and want to see a proposal to move the roundabout to that central position.
Furthermore, there are only two pedestrian crossings in the village, one co-located with Mill Lane, which has a lollipop lady controlling it during the twice daily school runs, and the other co-located with the Primary School. The speed limit within the village is 30 mph but the residents feel strongly that this is often exceeded, which, coupled with the amount of large HGV traffic, makes the road more dangerous.
Another indicator, which Horsford Parish Council believe should definitely be considered a constraint on further development, is the lack of school places in the Primary school. This is supported in the Horsford Assessment Booklet Page 1, “current capacity at Horsford Church of England VA Primary School is rated as ‘amber’, consequently it is considered that the Horsford cluster could accommodate development in the region of 20-50 dwellings. Without expansion school capacity could be a possible constraint on further development”.
It should be noted that within the last 12 months, Horsford Medical Practice has also written to Broadland District Council in regard to increased population following further development numbers and the inability to register any more patients as they are at capacity, which is also in conflict with GNLP Policy 2 to ensure safe and convenient health care. Horsford Parish council believes that increased housing has already and will continue to put a strain on the services that exist in order to sustain the village.
For the sake of accuracy Horsford Parish Council would like to point out that the first paragraph in the Horsford Assessment Booklet refers to both a library and a public house in the village. However, there are no public houses in the village now and there has only ever been a mobile Library.
Please see attachment for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21985
Received: 16/03/2020
Respondent: Ms Carol Sharp
The use of the words ‘as appropriate’, in the policy’s introduction, mean the requirements would be far too open to interpretation as to what is ‘appropriate’
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’ when these are simply not available in most villages.
Please see attached for full submission
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21996
Received: 13/03/2020
Respondent: Redenhall with Harleston Town Council
The Town Council supports the requirements for Developments set out in Policy 2 (Sustainable Communities). We also feel that developments should provide on-site green infrastructure with access to electric car and electric bicycle charging points.
please find attached the report which was agreed by resolution by Harleston Town Council on March 11th 2020.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22021
Received: 15/03/2020
Respondent: Mulbarton Parish Council
MPC believes that the words “as appropriate” in the policy’s introduction would mean that the requirements are far too open to interpretation as to what is “appropriate”
MPC see “village clusters”, being detrimental as they would lead to an increase in petrol and diesel-powered vehicle journeys to and from Mulbarton to work places and with internet based deliveries.
Please see attached for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22065
Received: 16/03/2020
Respondent: Norfolk Wildlife Trust
Policy 2 – Sustainable Communities
Q18 – Whilst we support the drive to increase energy efficiency and on site renewable energy provision in order to help mitigation the impacts of climate change, in line with best practice advice, the recent adoption of an even more ambitious zero carbon target for major housing development by Reading Borough Council (RBC Local Plan policy H5) shows that even greater gains can be delivered through the GNLP. We strongly recommend, in order to reduce future impacts of climate change on wildlife as far as possible, that the GNLP adopts a zero carbon target for all new housing.
We support the measures in point 5 to protect and enhance the landscape, as this will provide vital space for wildlife to move through the landscape in adaptation to climate change. Given the vital role of nature-based solutions to climate change mitigation and adaptation, we see the need to safeguard and restore our natural environment as a vital part of progress to a carbon neutral future. In addition, in order to maintain this connectivity through the natural landscape, which overlaps with the incoming need in the Environment Bill to develop Nature Recovery Networks, we also strongly recommend that policy measures are added to the GNLP to ensure that new development includes green natural features wherever possible to ensure living space and movement corridors for wildlife in the built environment. We recommend that a policy requiring minimum standards for provision of green infrastructure such as green roofs, walls and sustainable drainage are required for new development. In addition to benefits for wildlife, this can contribute to improved climate resilience and adaptation through improving energy efficiency in buildings, reducing the urban heat island effect, and reducing rain run-off rates, as well as improving quality of life through providing more wildlife rich public space. Such policies have been successfully adopted in many cities across the world, including in the UK Southampton (Southampton City Centre Action Plan policy AP12, Green Space Factor) and the Urban Greening Factor in policy G5 of the draft London Plan.
Thank you for consulting Norfolk Wildlife Trust on the draft Greater Norwich Local Plan. We have attempted to comment wherever possible in response to the questions set out in the consultation, but have a number of comments which cover multiple policies or supporting documents and so have compiled our comments in this letter.
See attached for full submission
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22089
Received: 13/03/2020
Respondent: Watkin Jones Group
WJG support these objectives for creating a vibrant and inclusive area that is enhanced by new homes, infrastructure
and environment.
See attached for full submission by Clare Droog on behalf of WJG
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22132
Received: 16/03/2020
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
The preferred approach to sustainable communities is the requirement for sustainability assessments to accompany planning applications for major developments. This approach is supported and is considered to be in line with the National Planning Policy Framework.
Please see attached for full submission
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22284
Received: 16/03/2020
Respondent: Hugh Crane Ltd
Agent: Savills
For full representation, please refer to the attached documents.
The requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations is not supported by the evidence that the policy relies upon.
There is no justification for the lack of any alternative approaches.
Consideration could be given to wording which ‘encourages a 20% reduction against Part L of the 2013 Building Regulations’.
For full submission, please refer to attached documents
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22332
Received: 16/03/2020
Respondent: Pigeon Investment Management Ltd
Agent: Pegasus Group
4. POLICY 2 – SUSTAINABLE COMMUNITIES
4.1 While we broadly support the overall aims and objectives of the GNLP to facilitate the growth and delivery of sustainable communities the following representations are made in response to Policy 2 and its associated reasoned justification.
Criteria 3
4.2 This Criteria requires new development to;
“Contribute to multi-functional green infrastructure links, including through landscaping, to make best use of site characteristics and integrate into the surroundings;”
4.3 This is supported as it provides for the environmental objective of sustainable development. Pigeon’s site proposals at Hethersett includes new green infrastructure linkages thereby supporting the environmental objectives of Criteria 3. These linkages will provide for biodiversity enhancement and new wildlife corridors as well as providing new footpath connectivity integrating with the existing public right of way network for the benefit of both existing and new residents.
Criteria 4
4.4 This Criteria requires new development to;
“Make efficient use of land with densities dependent on-site characteristics, with higher densities and car free housing in the most sustainably accessible locations in Norwich. Indicative minimum densities are 25 dwellings per hectare across the plan area and 40 in Norwich.”
4.5 The density of residential development at any site is dependent on other community infrastructure or site-specific requirements that may arise as a result of emerging GNLP planning policy. It may transpire that a site promoted to the plan can provide educational or health facilities in association with residential development. The need for highway infrastructure and sustainable drainage features to be provided at a site also should be taken into consideration. To that end the policy should be amended to state that; “...the indicative minimum net density of the residential element of a site allocation should be 25 dwellings per hectare.”
4.6 The Policy identifies that these minimum density standards are indicative. This is supported as it allows for flexibility to ensure that each parcel of land is used effectively, taking account of the type of development proposed, the site context and appropriate design characteristics.
Criteria 5
4.7 This Criteria identifies that the strategic gap policies will be used to ensure that landscape character is protected, and the supporting text in Table 8 suggests that this is the appropriate way to do this in the absence of a Green Belt in Greater Norwich.
4.8 It should be noted that Green Belt and the strategic gaps are not landscape designations and so the criteria does not actually fulfil the objective of the Policy. The criteria should therefore be amended to provide clarity as to whether the objective is to respect landscape characters or to provide a place-shaping tool as would be provided through the designation of Green Belt or whether both of these separate policy objectives are sought.
4.9 Paragraphs 331 and 337 of the GNLP suggests that the role of the strategic gaps is to prevent coalescence which is a place-shaping rather than landscaping policy. Therefore, it appears that the strategic gaps are being used as a replacement for Green Belt given that the GNLP acknowledges in Table 8 that there are no exceptional circumstances to justify the designation of Green Belt. The role of the strategic gaps must therefore be less restrictive than that which would be provided by a Green Belt. This is especially so where, as is the case with Land off Station Road, the designated area does not make any contribution to the separation of Hethersett and Norwich.
4.10 Even if it was appropriate to designate a proxy-Green Belt through the use of strategic gaps, paragraph 145 of the NPPF identifies that some development within a Green Belt can be appropriate and the same approach should be adopted in relation to strategic gaps. For example, where outdoor sports and outdoor recreation developments are proposed such as at Land off Burnthouse Lane, these would not be inappropriate in the Green Belt and so they would clearly not be inappropriate in a strategic gap. 4.11 However, the objective to respect landscape character is supported and this can be provided through landscape-led development at both Land off Station Road and Land off Burnthouse Lane, both of which contain generous areas of strategic landscaping and robust tree/shrub belts to ensure that these can be appropriately integrated into the surrounding landscape.
4.12 In respect of Land off Burnthouse Lane, it should also be noted that Colney Lane, which forms the eastern boundary of this parcel, forms a clearly defined boundary with an existing planting belt (approximately 20-25m wide) running along the eastern edge of Colney Lane. The existing planting belt and Colney Lane itself provide a more appropriate boundary to the strategic gap, with the agricultural fields to the east of Colney Lane providing separation between Hethersett and the A47 to the east (and Cringleford beyond).
Criteria 10
4.13 This Criteria contains the following bullet point;
“All new development will provide a 20% reduction against Part L of the 2013 Building Regulations (amended 2016);”
4.14 The Planning Practice Guidance states that;
“The National Planning Policy Framework expects local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy and adopt nationally described standards. Local requirements should form part of a Local Plan following engagement with appropriate partners and will need to be based on robust and credible evidence and pay careful attention to viability.” PPG Climate Change – Paragraph: 009 Reference ID: 6-009-20150327 Last revised 27th March 2015
4.15 PPG Paragraph: 012 Reference ID: 6-012-20190315, last revised 15th March 2019, states that Local Plans can set energy efficiency standards that exceed the energy efficiency requirements of the Building Regs, it also states that such policies should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the code for Sustainable Homes – which is identified as approximately 20% above current Building Regs across the build mix. The PPG also requires such policy requirements to be viable. 4.16 The Code for Sustainable Homes was withdrawn in 2015 and replaced by technical housing standards. The GNLP Reg 18 has chosen to continue to pursue the ‘20% above Building Regs’ approach at criteria 10 of Policy 2.
4.17 The Alternative approaches section states that this target is a ‘challenging but achievable requirement’ and that to go beyond 20% would be unviable.
4.18 What is not clear however is the Councils’ evidence to require energy savings of ‘at least 20%’ above Building Regs when the PPG states ‘approximately 20% across the build mix’.
4.19 It is not clear either whether this policy requirement has been appraised across a range of site typologies in the viability appraisal and whether it has been tested in conjunction with the other policy requirements of the plan, including those of emerging Policy H5 which seeks:
i. 33% affordable housing, (except in Norwich City Centre);
ii. all new housing development to meet the Governments Nationally Described Space Standards; and
iii. 20% of major housing developments to provide ‘at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor’.
4.20 Whilst the objectives behind these are supported, taken together these emerging policy requirements of the plan could prejudice the delivery of some sites within the emerging plan.
Master planning
4.21 Community engagement prior to submitting an application is supported. However, Policy 2 identifies master planning using a recognised community engagement process for schemes of more than 200 dwellings will be encouraged. It is not clear what is meant by such a master planning process and clarity would be welcomed.
4.22 It is considered likely that such a master planning process would exceed the requirements of each of the joint authorities existing adopted Statements of Community Invo4.23 Furthermore, there is no guarantee that the masterplan outcomes of such a community engagement process will be considered appropriate or acceptable by the local authority as there is no mechanism for validating the outcomes of the process pre-submission. This could result in difficulties for all parties at the application stage should masterplan amendments be required as a result of statutory and internal local authority consultations post submission. lvement and also goes beyond the requirements of paragraphs 39 to 41 of the NPPF and the PPG (20-010).4.23 Furthermore, there is no guarantee that the masterplan outcomes of such a community engagement process will be considered appropriate or acceptable by the local authority as there is no mechanism for validating the outcomes of the process pre-submission. This could result in difficulties for all parties at the application stage should masterplan amendments be required as a result of statutory and internal local authority consultations post submission.
Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Hethersett. Please find attached the response form, the representations and a Delivery Statement
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22369
Received: 16/03/2020
Respondent: Pigeon Investment Management Ltd
Agent: Pegasus Group
4. POLICY 2 – SUSTAINABLE COMMUNITIES
4.1 While we broadly support the overall aims and objectives of the GNLP to facilitate the growth and delivery of sustainable communities the following representations are made in response to Policy 2 and its associated reasoned justification.
Criteria 3
4.2 This Criteria requires new development to;
“Contribute to multi-functional green infrastructure links, including through landscaping, to make best use of site characteristics and integrate into the surroundings;”
4.3 This is supported as it provides for the environmental objective of sustainable development. Pigeon’s site proposals at Diss includes new green infrastructure linkages thereby supporting the environmental objectives of Criteria 3. These linkages will provide for biodiversity enhancement and new wildlife corridors as well as providing new footpath connectivity integrating with the existing public right of way network for the benefit of both existing and new residents.
Criteria 4
4.4 This Criteria requires new development to;
“Make efficient use of land with densities dependent on site characteristics, with higher densities and car free housing in the most sustainably accessible locations in Norwich. Indicative minimum densities are 25 dwellings per hectare across the plan area and 40 in Norwich.”
4.5 The density of residential development at any site is dependent on other community infrastructure or site-specific requirements that may arise as a result of emerging GNLP planning policy. It may transpire that a site promoted to the plan can provide educational or health facilities in association with residential development. The need for highway infrastructure and sustainable drainage features to be provided at a site also should be taken into consideration. To that end the policy should be amended to state that;
“...the indicative minimum net density of the residential element of a site allocation should be 25 dwellings per hectare.” 4.6 The Policy identifies that these minimum density standards are indicative. This is supported as it allows for flexibility to ensure that each parcel of land is used effectively, taking account of the type of development proposed, the site context and appropriate design characteristics.
Criteria 10
4.7 This Criteria contains the following bullet point;
“All new development will provide a 20% reduction against Part L of the 2013 Building Regulations (amended 2016);”
4.8 The Planning Practice Guidance states that;
“The National Planning Policy Framework expects local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy and adopt nationally described standards. Local requirements should form part of a Local Plan following engagement with appropriate partners, and will need to be based on robust and credible evidence and pay careful attention to viability.” PPG Climate Change – Paragraph: 009 Reference ID: 6-009-20150327 Last revised 27th March 2015
4.9 PPG Paragraph: 012 Reference ID: 6-012-20190315, last revised 15th March 2019, states that Local Plans can set energy efficiency standards that exceed the energy efficiency requirements of the Building Regs, it also states that such policies should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the code for Sustainable Homes – which is identified as approximately 20% above current Building Regs across the build mix. The PPG also requires such policy requirements to be viable.
4.10 The Code for Sustainable Homes was withdrawn in 2015 and replaced by technical housing standards. The GNLP Reg 18 has chosen to continue to pursue the ‘20% above Building Regs’ approach at criteria 10 of Policy 2.
4.11 The Alternative approaches section states that this target is a ‘challenging but achievable requirement’ and that to go beyond 20% would be unviable. 4.12 What is not clear however is the Councils’ evidence to require energy savings of ‘at least 20%’ above Building Regs when the PPG states ‘approximately 20% across the build mix’.
4.13 It is not clear either whether this policy requirement has been appraised across a range of site typologies in the viability appraisal and whether it has been tested in conjunction with the other policy requirements of the plan, including those of emerging Policy H5 which seeks:
i. 33% affordable housing, (except in Norwich City Centre);
ii. all new housing development to meet the Governments Nationally Described Space Standards; and
iii. 20% of major housing developments to provide ‘at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor’.
4.14 Whilst the objectives behind these are supported, taken together these emerging policy requirements of the plan could prejudice the delivery of some sites within the emerging plan.
Master planning
4.15 Community engagement prior to submitting an application is supported. However, Policy 2 identifies master planning using a recognised community engagement process for schemes of more than 200 dwellings will be encouraged. It is not clear what is meant by such a master planning process and clarity would be welcomed.
4.16 It is considered likely that such a master planning process would exceed the requirements of each of the joint authorities existing adopted Statements of Community Involvement and also goes beyond the requirements of paragraphs 39 to 41 of the NPPF and the PPG (20-010).
Furthermore, there is no guarantee that the masterplan outcomes of such a community engagement process will be considered appropriate or acceptable by the local authority as there is no mechanism for validating the outcomes of the process pre-submission. This could result in difficulties for all parties at the application stage should masterplan amendments be required as a result of statutory and internal local authority consultations post submission.
Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Walcot Green Lane, Diss.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22403
Received: 16/03/2020
Respondent: Norwich Green Party
We support the requirement for a sustainability statement.
Green infrastructure: essential to incorporate some element in all but minor developments ('Net Biodiversity Gain'). Green infrastructure should be defined to include a range of features including, trees, hedges, green roofs, green walls, verges, small biodiversity features etc. Removal of verges and trees to construct local active travel initiatives is unacceptable.
Densities: housing densities should not be under-mined by parking standards. Use of land for parking to boost developer profits is unsustainable.
Travel: levels of parking help to determine the level of private car use. Lower ratios of parking to numbers of dwellings are required to make efficient use of land; encourage modal switch and reduce carbon emissions (a switch to electric vehicles will not solve emissions from road transport). Parking standards in new developments should be lowered across Greater Norwich.
Energy: see response to Q19. Meanwhile, MHCLG has indicated an intention to publish a Future Homes Standard which will require up to 80% lower carbon emissions for all new homes from 2025.
For full representation and additional information submitted, please refer to the attached documents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22471
Received: 16/03/2020
Respondent: Breckland District Council
The Plan needs a clear monitoring framework setting out how this will be monitored
see full response attached.
See attachment for officer level response from Breckland Council
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22531
Received: 16/03/2020
Respondent: Historic England
There is no mention of the historic environment in this policy on sustainable communities. Paragraph 8 of the NPPF makes it clear that achieving sustainable development means that the planning system has three overarching objectives, the third of which is an environmental objective to contribute to protecting and enhancing our natural built and historic environment. To that end we would expect to see reference to the historic environment in the policy on page 61 and also in the key issues addressed by the policy as set out in Table 2.
Suggested change: Include reference to the historic environment in the policy as required by para 8 of the NPPF.
For full representation, please refer to attached documents
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22633
Received: 13/03/2020
Respondent: M Scott Properties Ltd
Number of people: 2
Agent: Bidwells
Support, with comments
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. To demonstrate the ability to secure these objectives, we support the preparation of a Sustainability Statement as part of an application for a major development. The use of master planning, 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 and design considerations. For example, the inclusion of bungalows within a development to meet an identified need is likely to result in a lower density development, although a density of 25 dwellings per hectare should still be achievable on a net basis.
On behalf of M Scott Properties Ltd we are instructed to submit representations to the Greater Norwich Local Plan Regulation 18 (c) consultation. The representations are split into two, reflecting the two parts of the Greater Norwich Local Plan; the Strategy Document and the Sites Plan, in respect of GNLP0337.
The attached document provides a complete record of the representations made on behalf of M Scott Properties Ltd.
The various technical studies referred to in the Representation and the Delivery Statement can be accessed in the attachments also.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22648
Received: 16/03/2020
Respondent: Sport England
Number of people: 2
Sport England supports this policy, which seeks to increase opportunities for healthy and active lifestyles.
Sport England, in conjunction with Public Health England, has produced ‘Active Design’ (October 2015), a guide to planning new developments that create the right environment to help people get more active, more often in the interests of health and wellbeing. The guidance sets out ten key principles for ensuring new developments incorporate opportunities for people to take part in sport and physical activity. The Active Design principles are aimed at contributing towards the Government’s desire for the planning system to promote healthy communities through good urban design. Sport England would commend the use of the guidance in the master planning process for new residential developments. The document can be downloaded via the following link: https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design
Sport England would support referencing Active Design in the supporting text for this policy, as the guidance will assist in the development of sustainable communities to make increased opportunities for sport and physical activity.
Q17 – Sustainable Growth Strategy
Infrastructure requirements should be widened to include social infrastructure such as schools and outdoor/indoor spaces for sport and physical activity
Q18 – Sustainable Communities
Sport England supports this policy, which seeks to increase opportunities for healthy and active lifestyles.
Sport England, in conjunction with Public Health England, has produced ‘Active Design’ (October 2015), a guide to planning new developments that create the right environment to help people get more active, more often in the interests of health and wellbeing. The guidance sets out ten key principles for ensuring new developments incorporate opportunities for people to take part in sport and physical activity. The Active Design principles are aimed at contributing towards the Government’s desire for the planning system to promote healthy communities through good urban design. Sport England would commend the use of the guidance in the master planning process for new residential developments. The document can be downloaded via the following link: https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design
Sport England would support referencing Active Design in the supporting text for this policy, as the guidance will assist in the development of sustainable communities to make increased opportunities for sport and physical activity.
Q23 – Strategic Infrastructure
Sport England supports this policy as it seeks to make significant improvements to the cycling and walking network, to encourage more people to cycle and walk to work, or for leisure, and the development of a multi-functional green infrastructure network.
With regard to increase in school capacity, this should not be at the expense of existing outdoor spaces for sport (e.g. playing fields, games courts). Sport England have a statutory remit to protect existing playing fields and we will object to schemes that result in a loss of playing fields without meeting any of the exceptions identified in our adopted policy of Para 97 of the NPPF.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22661
Received: 16/03/2020
Respondent: Saxlingham Nethergate Parish Council
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.
Saxlingham Nethergate Parish Council met last week and considered their response to the current consultation.
They noted, considered and decided to fully endorse the response produced by CPRE in full (attached).
Q1 Please comment on or highlight any inaccuracies within the introduction
Please see our more detailed responses to the questions below, which make our concerns clear. In particular we have a major concern with the Draft Strategy as it makes no mention of using phasing for the delivery of new housing. We consider that any new sites allocated in the GNLP should be phased by being placed on a reserve list, and under phased development only built out when most of the existing JCS sites have been used. Inclusion of all the sites for immediate development will lead to developers “cherry-picking” the most profitable sites and newly allocated green field sites in less sustainable locations will be developed first, with even more land banking of currently allocated sites. In short, deliver the already allocated 82% of the 44,500 new homes, before giving permissions on the remaining 18%.
The current Local Plan, the Joint Core Strategy (JCS) was adopted in March 2011 with amendments adopted in January 2014: it has been in place for just over 6 years. When adopted, it was considered to be the blueprint for development in Norwich, Broadland and South Norfolk until 2026, and in doing so provided clear signals about where growth should and should not take place. In the introduction to the current consultation document it is stated that housing, jobs, services and infrastructure needs to be provided at the right time ‘and in the right places’. CPRE Norfolk questions how the response to this has changed so markedly since adoption of the JCS and well before that Local Plan was due to expire. In particular, the construction of the Broadland Northway (NDR) (noted in paragraph 7 of the introduction) was largely intended to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle. Moreover, there was a clear focus for housing and other growth to be in and close to Norwich, with minimal new development to be permitted in the rural policy areas of Broadland and South Norfolk. The GNLP strategy seems to be contradicting the direction of travel envisaged in the JCS and appears to undermine the planning process. A great strength of the JCS is the protection it gave to the rural areas: this seems to be sacrificed in the GNLP Draft Plan.
Paragraph 6 of the Introduction is clear that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’ It will be difficult if not impossible to meet these targets if new housing to the scale proposed in the draft strategy is dispersed across the rural areas of Broadland and South Norfolk. The main justification for this appears to be the availability of primary school places in the “village clusters”, whereas there are more important measures for sustainability which should be taken into account, including the number of car journeys and journeys by delivery vehicles to new housing, along with the associated congestion such vehicles will result in.
The introduction mentions in paragraph 25 that South Norfolk District Council will draw up its own South Norfolk Village Clusters Housing Site Allocations document. CPRE Norfolk is very concerned that by adopting such an approach this allocations document will not receive the same level of scrutiny as the main draft strategy document. We are also very concerned that the number of additional dwellings on top of the existing commitment of 1,349 houses is given as ‘a minimum of 1,200’. The use of the word ‘minimum’ is unnecessary and potentially very alarming, as in effect this gives no limit to the maximum number of houses which could be allocated in those “village clusters”. Given the draft plan provides enough committed sites ‘to accommodate 9% more homes than “need”, along with two “contingency” locations for growth’ (page 37) and does not include windfall developments in its housing totals, the word “minimum” should be replaced with “maximum” or “up to” as is the case with the figures for Broadland’s “village clusters”. Why is there this discrepancy in language between two authorities which are part of the same Local Plan: it appears to be inconsistent and illogical.
Q3 Please comment on or highlight any inaccuracies within the spatial profile.
Paragraph 41 states that ‘this GNLP needs to plan for additional housing needs above and beyond existing commitments based on the most up-to date evidence’. However, the calculations of housing need are based on the 2014 National Household Projections, which are not the most up-to date statistics, nor are they sufficiently robust to be used for such an important and far-reaching strategy. CPRE Norfolk admits that the 2014 figures are those which central Government expects to be used. However, several Local Planning Authorities, including North Norfolk District Council, are challenging the use of the 2014 figures, instead suggesting that the more up-to date 2016 National Household Projections should be used. CPRE Norfolk agrees that the GNLP needs to be based on the most up-to date evidence, and therefore requests the GNDP insists on using the 2016 National Household Projections. If the most recent ONS statistics had been used, current commitments are sufficient to cover housing needs to 2038.
Q6 Do you support or object to the vision and objectives for Greater Norwich?
A major concern is that the draft plan largely consists of a wish list, but lacks real targets or actions, particularly on the environment and climate change. For example, our environment is lauded but the draft plan notes in paragraph 37 that life expectancy for men in Norwich is 10.9 years lower in the most deprived areas compared to the least deprived. We cannot see any specifics within the draft plan as to how this shocking fact is to be addressed.
Paragraph 120 stresses the need for ‘good access to services and facilities’ for ‘our suburbs, towns and villages’. While this is provided in the first two categories of settlement there is insufficient provision or access to services in many of the settlements within the “village clusters”. The decision to allocate additional new housing beyond what is already allocated within the JCS is based almost solely on the existence of a primary school with available places or potential for expansion within the “cluster”. This does not amount to the provision of ‘good access to services and facilities’ and therefore this level of new housing in “village clusters” should not be permitted within the GNLP.
Paragraph 125 is perhaps the strongest argument for not allocating additional housing to “village clusters” within the GNLP. Clearly, there will be a major need for journeys from and to work for many of those living in any such new housing, in addition to additional journeys by delivery vehicles to this new housing. This paragraph states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ For the majority of the plan period it is highly wishful thinking to think that ‘electric vehicles will predominate throughout Greater Norwich’. These additional journeys will not only add to the “carbon footprint” but will also add to congestion on the road network, affecting air quality and the wellbeing of residents. If the intention of the GNLP is to locate housing close to jobs, which we agree should be a major aim, then any additional allocations of housing should be located in or close to Norwich, where there are realistic opportunities to walk or cycle to work and to services, or to use public transport to do so. The existing allocations of housing within the JCS and to be carried forward to the GNLP will provide sufficient new accommodation close to other places of work in main towns and key service centres.
Paragraph 129 states: ‘greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ We strongly feel that it is imperative that Per Capita Consumption (PCC) of water is further reduced to below the Government’s prescribed 110 litres per person per day in order to deliver this statement in paragraph 129. East Anglia is the driest region in the UK: our aquifers, rivers and wetlands are already at breaking point, as are many of the region’s farmers, who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PCC water consumption are not set as part of the GNLP, this will further adversely impact upon the environment, impacting on the Broads and wetlands, which in turn will impact the region’s aspirational growth for tourism and will severely impact the regional agricultural economy. To ensure that the water-supply to existing users is not compromised it is sensible to restrict the number of new houses to a level that realistically covers actual need, and this fact reinforces our case for phasing of housing and our questioning of the need for a higher than necessary buffer.
Paragraph 132 makes the claim that new quality development will be located to minimise the loss of green-field land. CPRE Norfolk strongly suggests that the best way to achieve this is not to allocate additional sites for housing in “village clusters”. Indeed, there are already sufficient allocated sites for housing in the JCS being proposed to be carried forward to the GNLP in the Norwich fringe parishes, main towns and key service centres to keep pace with the likely build rates of development. The exception to this should be any brownfield sites, particularly those within Norwich, which should be prioritised into a “brownfield first” policy. This should form part of a phased approach to new housing, so that existing allocations from the JCS and any brownfield sites should be developed before permitting any additional allocated sites to be built-out.
One effective way to prevent the unnecessary loss of much greenfield land would be to institute a green belt on the “green wedges” model around Norwich, as requested by 84 respondents and 1,912 petition signatories (currently at 2,200 signatures) calling for this according to the draft statement of consultation, September 2018, for the Stage A Regulation 18 Site Proposals and Growth Options consultation. CPRE Norfolk is very concerned that this proposal or option has been removed from the current consultation.
In conclusion for this question, we find that the vision and objectives contain serious flaws, especially in regard to the way in which they conflict with policies within the current Local Plan, which withstood the rigorous inspection process.
Q9 Do you support, object, or have any comments relating to the approach to Housing set out in the Delivery Statement?
This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ CPRE Norfolk disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.
It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.
Q12 Do you support, object, or have any comments relating to the Climate Change Statement?
Given the stated measures in the Climate Change Statement, it is impossible to see how the proposed additional allocation of sites for housing in “village clusters” can be justified. Furthermore, it is stated that ‘growth in villages is located where there is good access to services to support their retention’, when this is rarely the case beyond providing a primary school with sufficient places or room for expansion. Many services are simply not located within the “village clusters” with many additional vehicle journeys being an inevitable consequence of such housing allocations. Therefore, these would be contrary to measures 2 and 3 of the Climate Change Statement.
By locating additional housing in “village clusters” there would be an increased need to travel, particularly by private car, due to the lack of viable and clean public transport. If Climate Change is seriously going to be addressed then it is unacceptable to allocate additional sites for housing in rural areas which are not at all, or poorly served by public transport. New housing must be located where jobs and a wide range of services are or can be provided.
In addition CPRE Norfolk is concerned by the lack of any detailed policy on the design of new housing in the draft Plan document, other than a brief mention in the ‘Design of development’ in the Climate Change Statement. Detailed requirements to insist that new houses are built to the highest possible environmental standards beyond the Government’s minimum standards are needed, if serious steps are to be taken towards addressing Climate Change issues.
Q13 Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?
We supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the concept of “village clusters” has been introduced into the planning process. For many reasons they appear to be a flawed unsustainable concept. A real strength of the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore we are very disappointed that this distinction has been abolished. The Rural Policy Areas gave real protection to the countryside: this is threatened by the introduction of the village cluster approach. This is another example of how the Draft GNLP contradicts the existing agreed Local Plan.
As noted above in our response to Q1 CPRE Norfolk has serious misgivings about the separation of the sites and allocations for new housing in the South Norfolk Village Clusters from the rest of the GNLP and its current consultation. In addition, we strongly object to the use of the open-ended statement that these South Norfolk “village clusters” will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number as is the case for the Broadland “village clusters”. If the reason for this separation is, as was given at the recent GNDP meeting of 6th January 2020, the lack of suitable sites coming forward in these South Norfolk “village clusters”, then this gives another good reason why the delivery of housing should be phased. Clearly the sites included in the JCS have undergone rigorous assessment and their inclusion in the Local Plan is an acknowledgement of their suitability for development. It makes absolute sense that these suitable sites should be developed first especially given the fact that any new sites coming forward are deemed to be unsuitable.
Paragraph 163d states that the strategy for location of growth ‘focusses reasonable levels of growth in the main towns, key service centres and village clusters to support a vibrant rural economy’, before suggesting that the approach to “village clusters” is ‘innovative’. The claim that providing new housing in such locations will support services is, we contend, largely illusory. Instead, additional new housing will lead to more car and delivery vehicle journeys, with residents travelling longer journeys to access the services they require such as health services and a supermarket. Given that the majority of any such new houses will be larger “family” homes, with children just or more likely to be of secondary or tertiary school or college age than of primary school age. This will have further impacts on carbon reduction due to the additional journeys needed to secondary schools or colleges.
It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable option for the distribution of housing in terms of the environment (e.g. minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; ensuring that everyone has good quality housing of the right size; maintaining and improving the quality of life; reducing deprivation; promoting access to health facilities and healthy lifestyles; reducing crime and the fear of crime; promoting access to education and skills; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes; conserving and enhancing the historic environment and heritage assets; minimising waste generation; promoting recycling; minimising the use of the best agricultural land; maintaining and enhancing water quality and its efficient use) is Option 1: urban concentration close to Norwich. In terms of all these factors taken together the least desirable option as shown on this chart is Option 4: dispersal. We therefore strongly support urban concentration in and close to Norwich as the way forward, because it is best for the environment, minimising climate change and the well-being of residents.
There is very little economic evidence to suggest that cementing new housing estates on the edges of villages will bring any boost to local services, but rather they will put a strain on these services, where they exist.
We cannot understand why the table showing the same set of factors in the Interim Sustainability Appraisal for the GNLP on page 42 shows some different results from the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option.
Given the clear benefits and advantages from these documents for the environment, climate change and other areas, as well as other reservations around lack of sustainability and issues of delivery, we strongly urge the GNDP to remove the requirement for additional new sites for housing in the “village clusters” from the GNLP.
Q14 Do you support, object, or wish to comment on the approach for housing numbers and delivery?
Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.
CPRE Norfolk also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.
CPRE Norfolk wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.
There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable (or as CPRE Norfolk would argue, unsustainable) sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.
It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.
Q18 Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?
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.
Q19 Do you support, object or have any comments relating to the specific requirements of the policy?
We comment on various aspects of Table 8 relating to Policy 2.
Point 3, Green Infrastructure. The opening statement is: ‘Developments are required to provide on-site green infrastructure appropriate to their scale and location’. The three main benefits listed are biodiversity gain, promotion of active travel and the reduction of flood risk, which are key NPPF priorities.
The NPPF is also supportive of biodiversity on a more strategic scale, and the importance of ecological networks and Nature Recovery Networks. While Green Infrastructure is useful, and can play a role in these, it clearly has limitations in a wider role across the wider countryside, and in linking high designated nature conservation sites.
Point 5, Landscape, should recognise that valued landscapes often sit with good wildlife habitats. This is particularly the case for river valleys and the Broads. A strong message from the Environment Plan and the recommendations from the recent Landscapes Review is to make links between landscapes and wildlife, and not consider them in isolation. This is covered more fully in our response to Q21.
Point 9, Water. In our view it needs to be recognised that SUDS is not a silver bullet when dealing with flood risk. Areas of low-lying land with a high water-table can present a problem in ‘getting the water way’, and if it does manage to do that existing settlements can be put at risk.
A high level of growth puts a greater pressure on the capacity of Waste Water Treatment Works, both on the discharge of effluent into river systems, and on flood risk with foul water. This will be exacerbated by under or lagging investment in WWTW. Although not the responsibility of the Greater Norwich Authorities, their Annual Monitoring Reports (AMRs) should record and monitor incidents.
The statement in Point 9, Water - Key issues addressed by policy 2 states that: ‘Government policy expects local planning authorities to adopt proactive strategies to adapt to climate change, taking into account water supply and demand considerations. It allows local plans to set a higher standard of water efficiency than the Building Regulations where evidence justifies it. For housing development, only the higher Building Regulations standard for water prescribed by Government (110 litres per person per day) can [be] applied through local plans and more demanding standards cannot be set. If the potential to set more demanding standards locally is established by the Government in the future, these will be applied in Greater Norwich.’ The closing note at the bottom of the wording states: ‘Implementation of the standards for water efficiency will be supported by an updated advice note.’
We comment that it is imperative that Per Capita Consumption (PCC) of water is further reduced below the Government's prescribed 110 litres per person per day in order to deliver the statement made in Section 3, paragraph 129 which states: ‘Greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable local energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ East Anglia is the driest region of the UK, our aquifers, rivers and wetlands are already at breaking point, as are many of the regions farmers who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PPC water consumption are not set as part of the local plan, this will further adversely impact upon the environment, impacting upon the Broads and wetlands, which in turn will impact the regions aspirational growth for tourism and will severely impact the regional agricultural economy.
These pressures are further evidence as to why the amount of new housing should be tightly controlled.
Q21 Do you support, object or have any comments relating to the approach to the natural environment?
CPRE Norfolk supports further ‘development of a multi-functional green infrastructure network’. However, we have major concerns about how biodiversity net gain will be evaluated, assessed and measured, although it is recognised that at this point it is unclear as to what the legal requirements of this policy will be given the current progress of the Environment Bill.
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt on a ‘green wedges’ model would go some way to addressing this.
This draft Plan takes a very narrow view on the NPPF and 25-Year Plan on policies for the natural environment, namely that strategy, aims and policies are restricted to considering only gain as seen through the prism of development. There is a duty to cooperate between Councils, and that should automatically happen. While implementation may be less direct, there should be a wider strategic vision that does support policies of the NNPF. CPRE Norfolk has a proposal for a Nature Recovery Network from the North Norfolk Coast to the east coast (including parts of the Broadland DC area), by the enhancement of the ecological network provided by our river systems, and supported by the environmental land management scheme. This includes a detailed planning and land management document for landscapes and wildlife relating to a Nature Recovery Network, which also include an AONB extension to the Norfolk Coast AONB into the full catchments of the twin North Norfolk rivers Glaven and Stiffkey.
Q22 Are there any topics which have not been covered that you believe should have been?
Yes, the decision to remove a possible green belt for Norwich on the green wedges (or other) model from the draft Local Plan is, in the opinion of CPRE Norfolk, unjustified, particularly bearing in mind the large degree of support it received in the earlier Stage A Regulation 18 Site Proposals and Growth Options consultation.
Q23 Do you support, object or have any comments relating to [the] approach to transport?
CPRE Norfolk supports the provision of new railway stations at Rackheath and especially Dussindale as outlined in paragraph 206.
We note the contradiction in the Transport for Norwich Strategy as reflected in Policy 4 – Strategic Infrastructure, when it aims ‘to promote modal shift’ by having ‘significant improvements to the bus, cycling and walking network’ on the one hand, but promotes ‘delivery of the Norwich Western Link road’ on the other. CPRE Norfolk fully supports the former set of aims while opposing the latter.
CPRE Norfolk supports ‘protection of the function of strategic transport routes (corridors of movement)’, and as part of this strongly suggests that no industrial development should be permitted on unallocated sites along such corridors of movement.
The desire to support ‘the growth and regional significance of Norwich Airport for both leisure and business travel to destinations across the UK and beyond’ surely contradicts the aspirations for addressing climate change stated within Section 4 of the draft GNLP?
Public transport provision needs to be improved and made affordable, not only between main towns and key service centres, but to and from smaller settlements. This is essential even without any further growth of these settlements, as many areas of rural Norfolk have become public transport deserts.
Q27 Do you support, object or have any comments to [the] approach to affordable homes?
CPRE Norfolk supports the affordable housing policy within Policy 5 – Homes. It is essential that the requirements of this policy are followed when progressing applications for housing on sites of 10 dwellings or more. Any policy which encourages the building of a greater proportion of affordable homes should be adopted. It is to be hoped that government policy will change further regarding viability tests so they become more transparent, so that it would be less easy for developers to evade their responsibilities to deliver affordable homes. More central government intervention is required if these needed homes are to be built. Ideally, affordable and social housing should be provided where needed as a stand-alone provision, and not be connected to private developers’ housing targets. Lessons must be learned from the history of poor delivery of affordable homes, to ensure that the policy to provide 28% or 33% affordable houses must be enforced. We support rural exception sites as a means of supplying needed local affordable and social housing. An approach based on the provision of stand-alone sites such as these, in our opinion is a far better method for addressing affordable and social housing needs.
Q34 Do you support, object or have any comments relating to the approach to employment land?
CPRE Norfolk while not agreeing with the allocation of so much green-field land for employment/economic use, it is essential that any such allocated sites are adhered to. This means that no exceptions should be made, particularly for larger businesses, to develop sites outside these allocated areas. If any such un-planned growth were to be permitted this would lead to further erosion of the area’s landscape and environment, along with issues regarding the sustainability of any such sites. A large amount of the land allocated in the JCS for employment use remains for use. The development of these sites should be prioritised before any new sites are added.
Q45 Do you support or object or wish to comment on the overall approach for the village clusters? Please identify particular issues.
“Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside. It is difficult to understand the justification for changing the current settlement hierarchy within the JCS to that proposed in this draft plan, in particular by eliminating the JCS categories of Service Villages, Other Villages, smaller rural communities and the countryside, which provided opportunities for a more nuanced approach to housing allocation, appropriate to each category of community/settlement within their own setting, landscape and context. The “village cluster” approach is a relatively crude one, with much more of a ‘one size fits all’ approach. CPRE Norfolk is particularly disappointed to see that the current JCS settlement hierarchy is not even offered as an ‘alternative approach’ in the draft GNLP, and wishes to see this rectified.
Even if the “village clusters” are adopted it would still be important to limit these to the area within their settlement boundaries and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.
The different approach for “village clusters” in Broadland compared to those in South Norfolk is not acceptable given the emphasis on the GNLP being a strategic plan for the whole of Greater Norwich. The “village clusters” in Broadland and South Norfolk should be treated in the same way if they are to be included in the final GNLP. This means that a maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’. We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.
CPRE Norfolk is concerned by the use of primary school catchments acting as ‘a proxy for social sustainability’, with apparently no other sustainability measures being taken into account when decided on the amount and location of housing within “village clusters”. This does not make the proposed allocated housing within “village clusters” sustainable as required by the NPPF. Other measures should be taken into account within the social, economic and environmental spheres.
Q46 Do you support or object or wish to comment on the approach for specific village clusters? Please identify particular issues.
We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.
Q47 Do you support or object or wish to comment on the overall approach for Small Scale Windfall Housing Development? Please identify particular issues.
CPRE Norfolk feels that windfall development should be restricted to sites within settlement boundaries. Housing need is already catered for by other policies in the Plan. Windfall developments should also count towards overall housing targets.
Q48 Do you support or object or wish to comment [on] any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.
CPRE Norfolk does not understand why there has been a major change in direction and policy as to where new development should be allocated in the GNLP compared to the current JCS. The JCS was only finally fully adopted in January 2014, just over 6 years ago. In the JCS housing concentrated in and close to Norwich was agreed and supported by hugely expensive infrastructure projects, in particular the Northern Distributor Road (now known as the Broadland Northway), which was primarily constructed to distribute traffic form and to new housing developments on the northern fringes of Norwich and in the North-east Growth Triangle. It would be a massive and costly folly to change that policy to one which allowed for the dispersal of much housing across the rural areas of Broadland and South Norfolk, where there is insufficient infrastructure, services and public transport, which would mean such development would be unsustainable. This would only lead to more congestion and pollution, leading to problems in meeting carbon-reduction targets.
CPRE Norfolk wants to see sites allocated for housing in the existing plan (the JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up.
There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites.
It is very disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.
We question the relevance of a plan whose horizon is 2038, which is likely to be reviewed and replaced on at least three occasions before its end-date, and we fear that on each of these occasions more unsustainable housing will be crammed in at the expense of the countryside. What is perhaps most disturbing is that so many people living in the area are not aware of the current JCS let alone the emerging GNLP, and that where citizens are engaged in the process seem to have their views discounted. For example, this is clear where the views of over 38% of the Broadland and South Norfolk Parish and Town Councils regarding the phasing of housing development are apparently ignored. Current consultation processes are not reaching the majority of people: perhaps a Citizens’ Assembly approach would be a means which would enable more people to be involved.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22699
Received: 16/03/2020
Respondent: Strutt & Parker LLP
[On behalf of Scott Properties Ltd]
33. The preferred approach to sustainable communities is the requirement for sustainability assessments to accompany planning applications for major developments. This approach is supported and is considered to be in line with the National Planning Policy Framework.
Please find attached the following documentation forming a consultation representation for the Greater Norwich Local Plan: Stage C Regulation 18 Draft Strategy and Site Allocations on behalf of my colleague, Adam Davies.
- Completed document for the following documents and questions:
- Draft Greater Norwich Local Plan – Part 1 The Strategy
- Question 6
- Question 9
- Question 11
- Question 12
- Question 13
- Question 14
- Question 16
- Question 17
- Question 18
- Question 25
- Question 29
- Question 32
- Question 41
- Question 42
- Question 48
- Draft Local Plan – Part 2 Site Allocations
- Policy GNLP2136
- Greater Norwich Local Plan Interim Viability Study (November 2019)
- Proving Layout
- Parameter Plan
- Pedestrian Access Plan
- Highways Technical Note
- Vehicular Access Proposals
- Barley Close Pedestrian Link
- Utilities Assessment
- Flood Risk Technical Note
- Infiltration Testing
- Preliminary Surface Water Attenuation Calculations
- Bat Scoping and Activity Survey
- Great Crested Newt and Amphibian Survey
- Reptile Survey
- Arboricultural Survey
- Archaeological and Heritage Assessment
- Noise Assessment
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22728
Received: 16/03/2020
Respondent: Pegasus Group
Policy 2 – Sustainable Communities is a broad strategic policy covering a range of economic, environmental, and social imperatives for development with the ultimate objective of reducing emissions. The policy, therefore, details the importance of high quality development, contributing to inclusive growth in mixed, resilient and sustainable communities and mitigating and adapting to climate change.
6
Our client supports the Council’s approach to sustainable communities and the requirement for housing developments of 100 dwellings or more to submit a Delivery Statement such that the key objectives of Policy 2 are implemented which reflect the overarching aims of the NPPF. They also believe that their site at Land off Norton Road, Loddon would align with these objectives in the delivery of a sustainable community.
Land off Norton Road is considered to be located in a sustainable location as it is easily accessible to Loddon’s High Street (less than 10 minutes walk from the site), which has an excellent range of shops, services, employment opportunities and bus stops with a frequent bus service to Norwich city centre (one bus every 30 minutes). Furthermore, there are employment opportunities available at Loddon Industrial Estate (less than 10 minutes walk from the site). By affording sustainable levels of growth to areas such as this it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.
Our client is actively developing sites across Greater Norwich, which have delivered well-designed and high quality developments which are long lasting and make the best use of the land available through appropriate housing densities. The proposed development at Land off Norton Road would similarly align with this with indicative minimum densities of 25 dwellings per hectare across the plan area. It would be designed in such a way that actively encourages walking and cycling.
See summaries for responses
- GNLP Regulatory 18 Consultation Questions- Land off Norton Road, Loddon
- GNLP Regulatory 18 Consultation Questions- Dairy Farm, Thorpe End
Introduction
These representations are submitted on behalf of our client Halsbury Homes Ltd in response to the Greater Norwich Local Plan (GNLP) Regulation 18 Consultation.
Our client is promoting Land off Norton Road, for residential development in the GNLP.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22790
Received: 16/03/2020
Respondent: Strutt & Parker LLP
The preferred approach to sustainable communities is the requirement for sustainability assessments to accompany planning applications for major developments. This approach is supported and is considered to be in line with the National Planning Policy Framework.
For full representation, please refer to the attached documents.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22881
Received: 13/03/2020
Respondent: Bidwells
Number of people: 2
Support, with comments.
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. 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.
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.
Please find attached a Regulation 18 Stage C Consultation Representation in relation to GNLP0125, Land West of West Lane, Horsham St Faith.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22923
Received: 16/03/2020
Respondent: Barratt David Wilson Homes
Agent: Savills
The requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations is not supported by the evidence that the policy relies upon.
There is no justification for the lack of any alternative approaches.
For full representation, please refer to attached suite of documents.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22969
Received: 16/03/2020
Respondent: Barratt David Wilson Homes
Agent: Pegasus Planning Group
Our client supports the Councils placing greater emphasis on climate change and believes that the most appropriate way to meet these objectives is by locating new development in sustainable locations. Cringleford, which is identified as a fringe parish of the Norwich urban area, meets the criteria for delivering a sustainable community as the village has good access to services and facilities. Moreover, sites already consented in the village are already providing green infrastructure and promoting walking and cycling for new residents, which will create a more inclusive and social community. The delivery of sites where people can walk and cycle to meet their daily needs also helps residents to establish lifestyles that benefit their physical and social health.
With growth already being successfully accommodated at Cringleford there are improvements to sustainable travel routes that will ensure that future and existing residents’ reliance on the use of the private car will be reduced. This reduction in car dependency will also help reduce the negative impacts that unsustainable modes of travel have on climate change through increased greenhouse gas emissions. Moreover, through the promotion of walking, cycling and public transport residents will experience more positive interactions with each other and other residents of Cringleford and beyond than if they were reliant on private cars to meet their daily needs. Therefore, Cringleford is clearly a village where available sites should be developed to accommodate the maximum number of new homes whilst still respecting the semi-rural character of the village.
In order to meet the ambitious delivery programme for the Local Plan our client supports the requirement for housing developments of 100 dwellings or more to submit a Delivery Statement. Our client’s commitment to the delivery of new homes in the Greater Norwich area means that they will be well placed to demonstrate further delivery of much needed new homes at their site in Cringleford.
For full representation, please refer to the attached documents.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22970
Received: 16/03/2020
Respondent: Barratt David Wilson Homes
Agent: Pegasus Planning Group
Policy 2 includes the requirement to ‘ensure the effective use of land’ by requiring indicative minimum densities of 25dph across the plan area and 40dph in Norwich. However, neither the Policy nor the supporting text clarify whether these figures are gross or net. Our client believes that the Policy should clarify that these are net figures. The proposed uplift in housing numbers for Cringleford would deliver approximately 360 homes across two sites with a combined net developable area of approximately 13.5ha. This would result in an average density of only 26dph across both the sites. As Cringleford is a fringe parish of the Norwich urban area it is identified as being at the top of the hierarchy for locating new growth. Therefore, this low density, only 1dph above the indicative minimum for the wider local plan area and 15dph below the indicative minimum for Norwich would not accord with the requirement of Policy 2 to ‘ensure the effective use of land’.
On Cringleford the use of 44dph means that the most effective use of the land will be to accommodate approximately 500 dwellings on site GNLP0307 alone. However, the proposed uplift in the allocation would result in our client’s site and site GNLP0327 delivering the 360 additional homes at a density nearer to 25dph rather than the 40dph identified for sites in the Norwich urban area. This is not in accordance with the requirements of the NPPF, draft Policy 2 or the approach that has been accepted for other development sites in Cringleford.
For full representation, please refer to the attached documents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22971
Received: 16/03/2020
Respondent: Barratt David Wilson Homes
Agent: Pegasus Planning Group
Our client recognises the importance of delivering the infrastructure for the charging of electric vehicles but is concerned about the impact of the widespread use of residential charging points, which would require additional infrastructure to accommodate the power needed. Moreover, costs of installing the cables and associated hardware will vary considerably based on site conditions and the connections to and capacity of the local grid. It is essential that all associated costs related to electric charging infrastructure are taken into account to ensure that their cumulative impact do not render the sites undeliverable without reducing the percentage of affordable housing that they deliver. Our client believes that the best approach is for developers to ensure that the necessary ducting and cabling is installed to allow residents to fit their own electric charging points as and when required.
For full representation, please refer to the attached documents.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23021
Received: 13/03/2020
Respondent: Bidwells
Support, with comments.
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. 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.
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.
Please find attached a Regulation 18 Stage C Consultation Representation in relation to GNLP0520, Land South of Norwich Road, Hingham.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23029
Received: 16/03/2020
Respondent: Hingham Town Council
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.
For full representation response, please refer to the attached document.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23080
Received: 16/03/2020
Respondent: Orbit Homes
Agent: David Lock Associates
We wholly support the sustainable communities policy. This should underpin the spatial growth strategy and sites that are best able to perform against these sustainability requirements should be the ones selected for allocation.
However, we consider that the Plan does not effectively translate its aims and objectives in relation to delivering sustainable communities into its spatial strategy. It fails to acknowledge the ability of larger strategic scale developments to achieve these policy requirements, many of which are inherent in the design of new settlement scale developments.
The opportunity at SGV truly stands apart from other strategic growth opportunities in its sustainability and energy offer. One of the central features of SGV, as demonstrated in the Prospectus, is its ability to be aligned with the delivery of a solar farm on adjacent land under the control of the same landowner.
In this context, Orbit have explored the measures necessary to achieve a NetZero development from the outset and put forward SGV on this basis. The detail of how the scheme could achieve NetZero is set out in Sustainability, Energy and Climate Change Strategy as part of the technical assessment in Appendix 4. To inform this Strategy estimates of possible construction and operational stage carbon emissions and costs estimates to address these emissions to net zero through on-site renewable energy, tree planting and carbon offsetting have been undertaken.
SGV as a prospective allocation would establish an important precedent for the GNLP area in demonstrating how requirements of Policy 2 can be met. It is vital that in preparing Local Plans, policy-makers are proactive in establishing policies to tackle climate change.
It is imperative that GDNP realise their ambitions as set out in Policy 2 in light of the growing global climate change challenge. Without such commitments the GDNP will fall short of making a meaningful contribution in the fight against global climate change.
The use of zero-carbon and energy-positive technology is one of the integral Town and Country Planning Association Garden Village principles which have been used to shape the SGV proposal since its inception. We contend that the use of the Town and Country Planning Association Garden Village principle framework ensures that GV proposals, in particular SGV, are better placed to respond to climate change issues than small – medium scale development as sustainability principles are embedded within the design of such schemes.
For full representation, please refer to the attached documents.