Question 19: Do you support, object or have any comments relating to the specific requirements of the policy?

References to energy generation require it to be renewable and low carbon but do not mention that it should be clean in terms of air pollution. There is no point in having a renewable source of energy that pollutes the air we breathe. Wood, straw and other biomass fuels, whilst renewable, are not clean and can cause severe damage to the environments from which they are obtained. The GNLP should contain a clear indication that only clean renewable energy technologies should be used, e.g. not entirely based on government subsidies that can be withdrawn at any time.

Representing Norfolk Constabulary:

As a Designing Out Crime Officer for Norfolk Police, I support the intended key issue #7 (within Table 8) for the establishment and maintenance of resilient, safe and inclusive communities and also, key issue #1 to provide convenient, safe and sustainable access to facilities. I would suggest when these issues advance for further development that ‘safe’ is also to be interpreted as secure and that the principles of Secure By Design (SBD) - the police initiative which promotes the adoption of crime prevention measures, are further incorporated to improve the security of buildings and their immediate surroundings to provide safe places to live, as in line with Govt directive. Both the National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG) set out guidance in creating safe and accessible communities and I would draw your attention to section 8 of the NPPF. It recommends that local planning authorities ensure their policies and decisions aim to create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion (paragraph 91). Paragraph 164 advises that when preparing their Local Plan, local authorities should work with local advisors and others to ensure that they have taken into account the most up-to-date information about higher risk sites in their area for malicious threats and natural hazards, including steps that can be taken to reduce vulnerability and increase resilience. The Design section of the PPG includes crime prevention and security measures. I look forward to engaging further as the Local Plan progresses.

Please see attached

Please find my submission on the "Stage C Regulation 18 Draft Strategy and Site Allocations" consultation. This document comprise part of the Norwich Green Party submission, and submitted early as I am going away. I understand other sections of the Norwich Green Party submissions will follow later.

Policy 2: Sustainable Communities identifies a number of criteria to ensure the delivery of high quality development.

Criteria 5 seeks to respect, protect and enhance landscape character, including maintaining strategic gaps and landscape setting. However, these principles have not been applied to the selection of reasonable alternative housing sites for Wymondham. As set out in the representations to the GNLP Site Allocations document, it is noted that the strategic extensions located to the north east of Wymondham, and identified as reasonable alternatives, are located within the strategic gap between Wymondham and Hethersett. This outcome would be inconsistent with the approach in Criteria 5 of Policy 2 in terms of whether development to the north east of Wymondham would respect and protect landscape character in this location. As set out in the representations to the GNLP Site Allocations document for the Wymondham sites, it is requested that those strategic sites located on the north east of Wymondham should score ‘red’ for impacts on landscape. In contrast, the promoted development at land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320) would include new areas of green infrastructure and open space to mitigate the impact on landscape character.

Policy 2 includes a requirement for delivery statements to be prepared for developments of 100 dwellings or more, setting out a timetable for housing delivery at the site. The requirement for a delivery statement is appropriate, but the information provided in the statement needs to be robust, and a statement is no substitute for the allocation of deliverable sites in emerging GNLP. It is considered that a detailed assessment of housing delivery should be undertaken before sites are allocated for development or identified as reasonable alternatives, because discussions with developers on its own represents a limited and inadequate approach. A detailed assessment of housing delivery would have highlighted that the strategic extensions and garden villages identified as reasonable alternatives and contingencies for Wymondham are not deliverable in the short term and would not offset non-delivery at housing allocations and commitments. As set out in the representations to the Site Allocations document, land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320) is deliverable and should be allocated for development or identified as a reasonable alternative.

The setting of minimum densities is good practice – but what about maximum densities? There are some allocated sites proposing a density of around 200 dwellings per hectare, which is without precedent in Norwich and is well above the London average for new housing approvals, which was 154 dph in 2015/16. Either a policy on maximum density, or a requirement for developments above a certain density to be subject to greater scrutiny, would help to ensure that new housing is compatible with a good quality of life for residents.


It is regrettable that higher water efficiency standards cannot be set, and I hope the Greater Norwich councils will continue to lobby government for an update to the regulations. I welcome the provision for higher standards to be adopted when this becomes possible. An explicit commitment to lobby for this change would be a welcome addition.

I welcome the increased ambition on sustainable energy compared to the Growth Options consultation. There could still be room for more ambition.
The plan claims that moving towards carbon neutral buildings is ‘unviable’ - but not doing so will render the buildings themselves unviable by the end of the plan’s lifetime, requiring a massive retrofitting programme at far greater expense than if the buildings were future-proofed at the outset. We should not be allowing new builds with little renewable energy provision and poor energy efficiency. More exploration is needed of how Greater Norwich can do better on this.
While the NPPF is not supportive of onshore wind, local authorities should be doing their best within these constraints to enable this cheap and popular form of energy to thrive. Could a framework be developed for areas working on a neighbourhood plan, encouraging them to explore the potential for onshore wind and guiding them on how to ensure proposals are acceptable to the community? Cornwall Council produced a renewable energy planning advice document in 2016 which is a useful reference point for this.
Salford’s local plan provides a good example of how renewable energy can be more explicitly supported within the constraints of government policy.

I would like to see the addition of a policy on supporting local food growing, which can contribute to climate change objectives, access to green spaces, health and wellbeing, community cohesion and the local economy.
While there are well-established local and national policies on allotments, these do not cover other forms of community food growing. Additional allotment space can be difficult to provide in densely developed urban areas; and it is important to note that allotment waiting lists do not tell the whole story about demand for growing space. They reflect only the demand from people already interested in food growing, whereas community growing often brings in new people. Community food growing spaces are located very close to where people live, and offer a more significant social element. Many people who might be interested in growing are unable to take on the significant commitment of running an allotment. Finally, projected increases in the number of households are likely to mean housing is built at higher densities and fewer houses will have private gardens, meaning that more people will potentially be looking for access to growing space.
There are a number of local authorities which have successfully supported community food growing through the use of planning policy, including Bristol, Lambeth, and Brighton & Hove. A policy could, for example:
require new developments of five or more dwellings to make provision for food growing on site, with the level of provision commensurate with the scale of development. This could include facilities for rainwater harvesting and composting of food waste;
include a question on food growing provision in pre-planning application questionnaires;
encourage schools, healthcare facilities and office developments to consider providing space for food growing;
encourage the innovative use of space for food growing, such as structurally suitable green roofs and green walls;
seek the inclusion of productive plants such as fruit trees in all new landscaping proposals, as an additional source of easily available healthy food.

Policy 2: Sustainable Communities identifies a number of criteria to ensure the delivery of high-quality development.

Criteria 4 seeks to make efficient use of land. However, this principle has not been applied to the selection of the preferred housing allocation in Marsham. In this case, a greenfield site at land south of Le Neve Road, Marsham (Ref. GNLP2143) is identified as a preferred housing allocation, when a site containing vacant and unused buildings/hardstanding associated with a former poultry unit at Fengate Farm, Marsham (Ref. GNLP3035) is available for development but is only identified as an unreasonable alternative. This outcome would be inconsistent with Criteria 4 of Policy 2 and would not make efficient use of land. As set out in the representations to the GNLP Site Allocations document for the Marsham sites, it is requested that land at Fengate Farm site should be identified as a housing allocation in emerging GNLP in preference to a greenfield site.

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 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 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.

Norfolk Constabulary have the responsibility for policing and making Norfolk a safe place where people want to live, work, travel and invest in.

Central Government place great emphasis on the role of the Police. Furthermore, National Planning Policy Framework (NPPF) gives significant weight to promoting safe communities (in section 8 of the NPPF). This is highlighted by the provision of paragraph 91, which states

Planning policies and decisions should aim to achieve healthy, inclusive and safe places which…….

b) are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion ….

Therefore the inclusion within criteria 1, 6 and 7 of the importance of creating safe, inclusive, resilient communities is welcomed.

Within the policy however, specific reference should be made to require developers of major developments (of 500+ dwellings) to detail the measures that will be taken to deliver safe, resilient and inclusive communities including how they will fund the necessary infra-structure. Therefore, criteria (i) of this policy should include reference to the specific objective to create and maintain a safer community and reduce crime and disorder.

10 ii Masterplanning. A requirement for 200 houses needing masterplanning will lead to lots of 190 house developments meaning non integrated planning for larger sites e.g. GT7 Salhouse Road developments. Similarly there should not be a specific number before delivery plans are required.
Can this not be at Officer (Authority) discretion with a condition requirement?

As the GNLP produces further iterations of this plan there must be inclusion of specific targets to community involvement and pre planning application consultation.

We endorse and fully support the comments made by CPRE in relation to Green Infrastructure, landscape, water

We support and endorse the comments made by CPRE

This policy approach is supported, and accords with the NPPF.

Policy 2 refers to residential developments being required to mininise water consumption by meeting the optional requirement of 110 litres/per person/per day and that the highest possible standard with be applied over the plan period.

Anglian Water and the Environment Agency has issued advice to local planning authorities (copy attached) stating that there is evidence to demonstrate a need for optional water efficiency standard to be applied in the Anglian Water supply area. As such we fully support the inclusion of this standard in the policy.

We fully support the intention that development proposals will be expected to meet the current standard water efficiency rather than be limited to the existing standard. This is particularly important given Defra’s recent consultation on personal consumption of water which included reference to potential changes to existing building regulations on water efficiency.

Anglian Water is keen to promote the development of ‘Water smart communities’ including as part of the Local Plan. They use a more holistic and integrated approach to water management with the aim to:

• Enhance liveability by contributing to green streetspaces and high quality open space
• Promote the sustainable use of water resources and infrastructure to enable growth
• Build resilience against the impacts of climate change and extreme weather events
• Contribute to natural capital and biodiversity through multi functional water features
• Deliver water efficient homes to reduce household bills and support affordability

Opportunities for a more holistic and integrated approach to water management should form part of the plan, to encourage multi-functional water management assets which support other community objectives. This approach combines different elements of water management (e.g. combining SuDS with a water re-use system to both manage runoff and provide an alternative non-potable water supply) together with town planning and design (e.g. integrating the planted SuDS features throughout a development to contribute to ‘greener’ streetscapes).

In our previous comments on the Local Plan we had made detailed comments relating to text to be included in Policy FR1 in relation to surface water management, foul drainage and sewage treatment. This wording doesn’t appear in the Draft Local Plan and there is also no specific policy relating to flood risk which would apply to development proposals.

It is therefore proposed that Policy 2 is amended as follows:

‘Minimise flood risk, including reducing the causes and impacts of flooding, supporting a through [catchment] [text to be deleted] [an integrated] [new text] approach to water management [and] [text to be deleted] including the us[e][new text][ing] [text to be deleted] of sustainable drainage [systems and water efficiency and re-use measures.] [new text]

[Applicants are to demonstrate they have followed the surface water hierarchy for all proposals as follows:
a) Water re-use at point of run-off;
b) Discharge by infiltration to the ground;
c) Discharge to an open surface water body;
d) Discharge to a surface water sewer;
e) Discharge to a combined sewer;
No surface water connections are made to the foul sewer system and connections to the combined or surface water system is only made in exceptional circumstances where it can be demonstrated that there are no feasible alternatives (this applies to new developments and redevelopments); ] [new text]

Development must also protect water quality and be water efficient. To achieve the [latter] [deleted text] [this] [new text]:

That adequate sewage treatment capacity and foul drainage already exists or can be provided in time to serve the development; ] [new text]

Housing development will meet the Building Regulations part G (amended 2016) water efficiency higher optional standard;

Non-housing development will meet the BREEAM "Very Good" water efficiency standard, or any equivalent successor;
If the potential to set more demanding standards locally is established by the Government up to 2038, the highest potential standard will be applied in Greater Norwich.
[Development proposals should include water re-use measures, including grey water recycling, surface water or rainwater harvesting, where practicable;

Suitable access is to be safeguarded for the maintenance of existing water supply and drainage infrastructure following development.] [new text]

Reference is made a high standard of amenity in connection with transport impacts but not in terms of existing uses.It is suggested that applicants should also demonstrate that proposed developments would not be adversely affected by the normal operation of Anglian Water’s existing assets e.g. water recycling centres (formerly sewage treatment works).

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.


It is therefore recommended that Policy 2 or another policy should include the following wording:
‘Proposals for development adjacent to, or in the vicinity of, existing uses will need to demonstrate that both the ongoing use of the neighbouring site is not compromised, and that the amenity of occupiers of the new development will be satisfactory with the ongoing normal use of the neighbouring site’

Lanpro consider a national and standardised approach to improving issues such 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 delivery of housing and infrastructure. It is our 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.

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. Reedham already has many complaints about the sewerage facilities in the village, before trying to cope with the additional housing proposed.

Glavenhill Ltd consider a national and standardised approach to improving issues such 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 delivery of housing and infrastructure. It is our 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.

As the Council have declared a climate emergency we believe that any new housing should be as energy efficient as possible and this is beyond the present building regs it should still be required. The use of community battery schemes would be useful in taking excess power generated during the day and making it available at night. If we are going to be required to drive electric cars then there will be a need for a much enhanced grid and the large power stations could be supplemented by local generation. On a historic note Hingham did at one time have it’s own gas works and similar small scale electrical generation should be welcomed

The policy on flooding (item 9) could be strengthened by actually encouraging no additional hard surfaces outside the highway within a distance of one mile into a flood plain. Recent issues have shown the devastation excessive rain can have when rivers fill and although this has not been an issue for Norfolk the situation is only likely to get worse.

Point 2: Persimmon Homes (Anglia) recognise the importance of delivering new and changing technologies in terms of supporting a healthy economy, satisfying modern business needs and for social well-being.

With respect to electric vehicles, Persimmon Homes (Anglia) acknowledge the environmental importance of ensuring that all new cars are effectively zero emissions by 2040 and share the Government’s ambition to achieve this target. We also recognise that the transition to electric vehicles is still at a relatively early stage of development and, as such, the existing electricity network may be limited in terms of accommodating electric vehicle charging with respect to the associated increase in domestic energy demand that such provision is likely to generate.

Policy 2 must therefore be informed through consultation with UKPN to ensure that the associated requirements are deliverable without creating any unsustainable pressure upon the network.

Whilst the delivery of new and changing technologies is supported, these must be factored into the Council’s Viability Report as they will undoubtedly carry cost implications for new development.

Point 4: The approach to encouraging higher densities in more sustainable locations is supported, but it is considered that indicative minimum densities across the plan area should be higher, especially if the policy objective of making efficient use of land is to be realised. It is considered that a minimum indicative density of 30 dwellings per hectare would be more appropriate in this respect, but that the Policy should acknowledge the suitability for higher densities more generally, for example in town centres where sustainable transport links and good access to jobs/services are more likely to be available.

Persimmon Homes (Anglia) does not consider that additional Strategic Gaps need to be designated. Since the existing Strategic Gaps were designated based on high level landscape assessment, policies should include sufficient flexibility to enable development in the Strategic Gaps where site specific LVIAs demonstrate there would not be a significant adverse impact.

Points 9 & 10: In terms of water efficiency and energy demand, Persimmon Homes (Anglia) would support a policy approach that delivers consistency with the most up-to-date Building Regulation standards. In this respect, the Policy must be updated to take account of Part L of the Building Regs (future homes standard) once this has been formally implemented. The update to Part L of the Building Regulation may include a requirement for 31% reduction in carbon emissions compared to the current standard. It is imperative that the Council’s Viability Report makes an assessment of the potential cost implications of the amended Building Regulations (Part L).

Moving forward, between now and adoption, there needs to be a mechanism enabling continual review of any further change to national regulations that might carry implications for development viability so that these can be captured in the plan making process.

Persimmon Homes (Anglia) recognise the contribution that battery storage can make in terms of enhancing energy resilience. However, at present, the costs of providing such infrastructure are high and the industry is hampered by a skills/knowledge gap. An opportunity exists for local government to work collaboratively with developers to help research and fund energy storage schemes through pilot projects. Such an approach should be adopted before this aspect of the policy is taken forward.

Without amendment the policy is unreasonable and restrictive. Wind energy should not be an exception from the policy support. Part of Footnote 49 of the NPPF is implied but this does not need to be repeated in local policy. Wind energy developments which have the backing of the affected local community should be supported. Public opinion is consistently supportive of onshore wind (see attached). It is suggested that the final paragraph of part 10 of the policy is removed and wind is not excluded from support subject to acceptable wider impacts, as given in the penultimate paragraph of part 10.

We support the requirements of the policy as proposed, it would be a missed opportunity if these were to be diluted. In order to meet the objectives and vision of this Plan, and to meet the national target of being carbon neutral by 2050 it is essential that all future development should deliver all elements, it is not considered that there should be any justification for this not being the norm.
We would support more demanding standards, in particular in relation to water consumption and energy efficiency, should Government change its policy approach.

We support the requirements of the policy as proposed, it would be a missed opportunity if these were to be diluted. In order to meet the objectives and vision of this Plan, and to meet the national target of being carbon neutral by 2050 it is essential that all future development should deliver all elements, it is not considered that there should be any justification for this not being the norm.
We would support more demanding standards, in particular in relation to water consumption and energy efficiency, should Government change its policy approach.
Consultation responses are welcomed on the likely cost of implementing the proposed energy policy approach locally.
It is the intention for the proposed new settlement Honingham Thorpe to be carbon neutral. Clarion believe that whilst the up-front cost may be higher, the investment is necessary in order to create healthy, resilient, and vibrant communities, to meet the challenges of climate change, and to create a positive change for future generations.

The consideration and safeguards that are being put into the environment, landscapes, types of home, green spaces, leisure, access to cycle routes and for electric cars etc. etc. are impressive.

I have concern, however, about the attitude to Climate Change (141) and Renewable Energy (174) Table 8 item 10. With regard to Policies 2 & 4 the current requirement of the NPPF regarding land-based wind farms is absolutely appropriate. Land-based wind farms should only occur after consultation; where, when and if There is strong local support.

Please see attached for full submission

The Council would like to take the opportunity to express its support for the Greater Norwich Local Plan Draft Strategy.

Section 1 – Introduction
Paragraph 15 refers to a plan period to 2036. This needs amending to 2038, as noted elsewhere in the document.

Section 2- Greater Norwich Spatial Profile
Paragraph 70 notes that the A146 forms part of the Government’s Major Road Network (MRN) of local non-trunk roads of national importance. East Suffolk is pleased that the importance of the A146 has been recognised as it is a key link between Lowestoft, Beccles and Norwich. The Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report (March 2018) notes that the A146 Norwich Road/Loddon Road and the A146 Norwich Road/A143 Yarmouth Road are two junctions that will reach 90-99% capacity by end of the Waveney Local Plan period, 2036. The two junctions are close to Beccles but fall within the South Norfolk Council/Greater Norwich area. Measures to address traffic issues on the A146 near Beccles are likely to be necessary in future reviews of Local Plans. (See page 36 of The Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report (March 2018) https://www.eastsuffolk.gov.uk/assets/Planning/Waveney-Local-Plan/Background-Studies/Suffolk-County-Council-Forecast-Highway-Modelling.pdf)

It may be of interest to the Greater Norwich Planning Policy Team to know that the Barnby Bends bypass Major Route Network improvement proposal has progressed to the next stage with funding to prepare an outline business case. Improvements to the section of the A146 near Barnby, commonly known as the Barnby Bends, would benefit the whole A146 route between Lowestoft and Norwich, and the A143 link to Diss and Bury St Edmunds.

Paragraph 73. The Norwich rail service provides direct access to Lowestoft. Please update the text to include Lowestoft in the list of rail destinations accessible from Norwich.

Section 3 – The Vision and Objective for Greater Norwich
Paragraph 108. The Council supports the overall vision and objectives of the Greater Norwich Local Plan.

Paragraph 111 would benefit from explaining what the term ‘clean growth’ means. The terms ‘clean growth’, ‘clean transport’, ‘clean pubic transport’, ‘clean energy’ and ‘clean water’ are used through the document without explanation. It should not be assumed the audience is already familiar with specific terms and jargon. The terms should be explained in the text or included in the glossary in Appendix 2.

Policy 1 – The Sustainable Growth Strategy
We support the Greater Norwich Local Plan’s preferred option to support growth, including the use of the Government’s standard methodology for assessing housing numbers and delivery, use of a settlement hierarchy, and approach to the economy. We are pleased the strategy for growth can meet the area’s need for housing, including a buffer, and need for employment land.

Policy 2 – Sustainable Communities
Issue No.2 in Table 8 would benefit from more specific and detailed information to facilitate electric and low-emission vehicles and their ancillary infrastructure needs. Developers should be encouraged to provide electric charging points for dwellings with on-plot parking spaces, and to provide ducting and electricity supply to communal and public parking spaces to enable future installation of charging points. This would complement policies for East Suffolk (contained in the adopted Waveney Local Plan and the emerging Suffolk Coastal Local Plan) on facilities for electric charging points, by enhancing provision in the wider network.

A Housing Design Audit for England by Place Alliance (see http://placealliance.org.uk/research/national-housing-audit/) found that lower building densities on projects away from the urban core scored poorly in design and there were clear benefits to designing at higher densities with the best schemes averaging 56 dwellings per hectare. This research may be of interest regarding the minimum densities specified in point 4 of the policy.

The Royal Town Planning Institute has produced detailed guidance on how developments can be designed to support people with dementia by creating familiar, legible, distinctive, accessible, comfortable and safe environments. The application of dementia friendly design principles is considered to result in a higher quality environment for all users. Considering the aging population in the Greater Norwich area, and the surrounding area, and rise in dementia, it is advisable to incorporate dementia friendly design principle where appropriate, especially in larger housing developments. (See https://www.rtpi.org.uk/media/1312/dementiatownplanning-practiceadvice2017.pdf) Issue No.7 in Table 8 would benefit from specifically referencing dementia friendly design principles. This would complement the policies in the adopted Waveney Local Plan and the emerging Suffolk Coastal Local Plan.

Overall, we support the approach of the sustainable communities policy and requirement for a sustainability statement.

Policy 3 – Environmental Protection and Enhancement
We support the approach to the built and historic environment as it is in accordance with the NPPF.

Policy 4 – Strategic Infrastructure
We support the approach in the Strategic Infrastructure policy.

Policy 5 – Homes
We are pleased that the Greater Norwich area can meet the housing need, including a buffer, as identified using the Government’s standard methodology, and support the approach in the Homes policy.

Policy 6 – The Economy
We support the approach in The Economy policy.

Policy 7.1 – The Norwich Urban Area including the fringe parishes
We support the approach in The Norwich Urban Area policy.

Policy 7.2 – The Main Towns
We support the approach in The Main Towns policy.

Policy 7.3 – The Key Service Centres
We support the approach in The Key Service Centres policy.

Policy 7.4 – Village Clusters
The Waveney Local Plan identifies Beccles and Bungay as two of the five Market Towns for housing growth in the former Waveney area. The total growth from homes built, existing commitments and allocations in the Waveney Local Plan for 2014-2036 are 1,458 dwellings for Beccles and Worlingham and 557 dwellings for Bungay. Both Beccles and Bungay boarder the South Norfolk/Greater Norwich area. Any housing development in villages close to the former Waveney area is highly likely to impact high schools, medical centres, shops and other services and facilities in Beccles and Bungay. Housing development in the wider South Norfolk area is highly likely to impact traffic on the A146, which is an important link between Lowestoft and Norwich. Junctions on the A146 close to Beccles will be close to capacity by the end of the Waveney Local Plan period in 2036.

The future allocation of 1,200 new dwellings in village clusters in a South Norfolk Village Clusters Housing Allocations Document should take into consideration the impact on services and facilities in East Suffolk and the overall combined impact of proposed development in South Norfolk and the former Waveney areas on the A146. The Council would wish to be notified of progress on the South Norfolk Village Clusters Housing Allocations Document.

We support the overall approach of allocating housing growth in villages to promote their social sustainability and support rural life and services.

Policy 7.5 – Small Scale Windfall Housing Development
We support the approach in the Small Scale Windfall Housing Development policy

Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowner in support of the proposed development of the site at Land at Rightup Lane, Wymondham.

See attached for full submission

Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowner in support of the proposed development of the site at Land at Rightup Lane, Wymondham.

See attached for full submission

Please see attached for full submission

Please see attached for full submission