Question 24: Do you support, object or have any comments relating to the approach to other strategic infrastructure (energy, water, health care, schools and green infrastructure)?

essentially I only have one comment and as that applies to the entire Greater Norwich Local Plan in its entirity rather than specific items, I would be very grateful if you could make this known at the review stage for me.

My comment is:

Whilst the Plan seems to take account of and address micro infrastructure issues, such as school and local medical provision, it does not in my opinion focus enough on Hospital provision or Mental healthcare overall.

Local GPs refer patients to the NNUH, QE or JPH NHS Trusts which have limited capacity and already some of the worst A&E waiting times in the UK. The Plan will lead to a growth in population, yet there appears to be no account for the need to expand hospital bed capacity within the county. That means existing waiting times both in A&E and for surgery etc. will get considerably worse.

Far greater weight needs to be placed on suitable Acute hospital bed provision within the plan as acceptable healthcare for Norfolk's growing population will be dependant on the number of Acute Hospital beds etc. The Plan will I hope be referred to the relevant local NHS Trusts for their views as to what the effect the population growth will be on them and if they will cope.

Thank you for giving me the opportunity to make my point and hope it's can be taken into account.

I am concerned about the lack of provision of additional healthcare in Sprowston which is already seriously under strain. A new school has been built for children in the new Manor Park estate that has one class this year & will be several years before it is full & I am sure it will be needed, but while not every new house will have school age children, the occupants of every new house, whatever their ages, will need a doctor. At the presentation in Sprowston & in this report healthcare provision seems to have very little information.

I have spent many hours going through the plans for the future and it it obvious that a lot of time has been spent, and no doubt, a lot of consultancy fees in drawing these plans up.
I'm sure it will be of little surprise that you will not get many positive responses to the plans.
For my part, I do believe that planning for the future is essential and I have no wish to live in the past, but I think it is totally irresponsible to continue issuing these plans and to continue building developments willy nilly before there is a plan to complete the infrastructure to serve and support the expansions already underway. I deliberately did not use the phrase "already completed" because it cannot be claimed that any of the developments that have been started over the past 20 years can be regarded as complete until all services needed to serve these developments are in place, i.e. doctors and dentist surgeries, schools, social services, roads and street lights completed, a doubling of the size of the N & N hospital and a plan to bring into the region more industry. There will be many more items to add to this list and until these are completed it is totally irresponsible and lacking in intelligence to continue with any further developments.
This is not meant to be taken as an insult but asking for more thought to be put into the legacy that we are leaving our children.

We can't keep building new housing without sufficient infrastructure, notably doctors, schools and recreational spaces. I feel the track record in Broadland isn't good. I recognise the Central Government is not always helpful but Councils need to look out for residents and check large developers, who seem to only be interested in maximising profit.

You need to be more seriously investing in green tech and infrastructure. This is obviously way forward and without serious direct towards this you will fail to meet climate targets.. progress is way off currently and unless you take it seriously will will miss the chance to be a leading county. We have the perfect place to demonstrate best practice- why can’t you do it?

Comments
Clarification is required as to the extent of education contributions likely to be required.
Paragraph 229 states that “if a new development is likely to generate enough children to fill a new school, Norfolk County Council asks developers for the full cost of building that school.” However, the paragraph goes onto state that “with the current CIL approach locally, only land can be secured through a S106 agreement and the build cost of the new school is claimed through CIL.”
From discussions with NCC Education and the GNLP it is understood that when a new School is required the situation will remain as existing i.e. the developer will be expected to provide the land for the School, with the construction being funded through CIL. If this position has changed, it will have significant implications for viability.
The flexibility provided in relation to provision of new schools (para 231), ensuring that they are only provided as and when they are required is fully supported.
As detailed in comments made to Question 17, when considering infrastructure, consideration should be given to whether it is unviable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. schools and health centres, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan. The potential for infrastructure costs which are specific to larger strategic sites to be secured by Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the delivery of the infrastructure, should be explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).

The extent of the upgrades to infrastructure required both for this local Plan and the County, with the level of proposed growth is evident in the works required by Power Networks and Anglian Water. As for Health and Schools, it is irresponsible to imagine that the existing health services, (missing large numbers of staff under the conservative process of demoralise, destabilise, privatise) and schools, (missing staff under the conservative process of demoralise, destabilise, privatise) will be able to respond to the "growth" levels predicted. Our hospitals and ambulance services are continually struggling and schools are failing from cost pressures.

The emphasis on policies that reduce the number of car journeys is commendable, but we view the proposals as too generalistic and lack a clear focus on action.

The proposal for continued lobbying of statutory providers for the timely delivery of improvements to strategic infrastructure, such as the energy supply network, is welcomed and supported. This will be critical to ensuring the timely delivery of the planned growth.

In relation to education provision, the Consortium are committed to continued engagement with Norfolk County Council in relation to the potential to accommodate a secondary school on site GNLP0132. Further clarification is required in relation to funding mechanisms, and the inter-relationship with the CIL regime, to ensure that implications for viability are fully understood and mitigated at Plan-making stage. This is essential to ensure that the policy framework is drafted to appropriately reflect these considerations, and ensure that strategic sites are not over-burdened with the delivery of strategic infrastructure beyond that directly required by the development.

The proposal for continued lobbying of statutory providers for the timely delivery of improvements to strategic infrastructure, such as the energy supply network, is welcomed and supported. This will be critical to ensuring the timely delivery of the planned growth.

Policy 4 – Strategic Infrastructure – supporting text

Para 222 – Reference is made to no additional spending being required for water supply infrastructure. However the WRMP includes new potable water transfers to be funded by Anglian Water through customer bills. We would also expect developers to pay appropriate charges for the required connections to the water supply network.

Both of the documents produced by Anglian Water as referenced in para 222 have been published. Anglian Water’s Water Resource Management Plan (WRMP) was approved by Defra in December 2019 and the Water Recycling Long Term Plan was published in September 2018.

We review our Water Resource Management Plan on a continuous basis and will be preparing a new plan for 2024 which will align with the regional plan being led Water Resources East.

Anglian Water is also to prepare a Drainage and Wastewater Management Plan in partnership with stakeholders including the Greater Norwich authorities, the Broads Authority and the EA. This will be used to inform our next business plan for 2024.

The text should be updated to this effect.

Para 225 – Anglian Water promotes the use of Sustainable Drainage Systems as these have benefits both in terms of surface water and sewer flooding as well as wider environmental and community benefits including water quality enhancement.

The text should be updated to this effect.

Para 226 – reference is made to improved monitoring as outlined in Anglian Water’s Water Recycling Long Term Plan. This relates to the monitoring of foul flows within the network rather than existing Water Recycling Centres as stated.

The text should be updated to this effect.

Para 227 – reference is made to standard charges for ensuring water is supplied to development sites and are drained effectively.

Anglian Water applies developer charges directly for connections to water supply network and foul sewerage networks. The charges for 2020-21 do not include standard charges which were included previously. There is also investment made by Anglian Water as part of our business planning process.

The text should be updated to this effect.

Para 228 – reference is made to the preparation of the Greater Norwich Water Cycle Study. Anglian Water has made detailed comments on the content on the draft study which is to be finalised including addressing comments made by relevant organisations.

We are supportive of a number of policy recommendations as set out in the Draft Study including applicants demonstrating that capacity both within the foul sewerage network and at the receiving Water Recycling Centre (in consultation with Anglian Water) is available to serve development proposals and separation of surface and foul flows wherever possible.

These policy recommendations have not been carried forward into the wording of Policy 2 unlike the reference to increased water efficiency in residential development. Please see suggested changes to Policy 2 of the Local Plan.

Policy 4 – Strategic Infrastructure

Policy 4 as drafted appears to refer to Greater Norwich Authorities and partners lobbying Anglian Water as an infrastructure provider for the timely delivery of improvements including wastewater network, Whtilingham Water Recycling Centre and at Yare Valley Sewer.
Water and sewerage companies including Anglian Water prepare business plans on a 5 year investment cycle. Customer charges will be set following submissions from Anglian Water about what it will cost to deliver the business plan. Anglian Water’s business plan for the next Asset Management Plan period (2020 to 2025) was submitted to our economic regulator Ofwat in 2019.
It is therefore suggested that policy 4 is amended as follows:

‘The Greater Norwich Local Authorities and partners [including utility companies will work together in relation to] [new text] [lobby for] [text to be deleted] the timely delivery of improvements to infrastructure…and to’

In addition the policy as drafted refers to Whitlingham Water Recycling Centres and Yare Valley sewer but not to water supply and sewerage network improvements more generally.

Lanpro support the delivery of strategic infrastructure in a timely manner. This is essential to support delivery of proposed housing and employment growth. Delivery of necessary infrastructure to support dispersal of housing growth to small rural village clusters will, however, be difficult and expensive. The ability of small schemes to fund the provision of on-site services and facilities and to support local infrastructure capacity improvements through land provision and developer contributions is limited. Therefore, significant dispersal of housing growth to small rural clusters should not form part of the growth strategy (see our answer to Question 13).

Glavenhill Ltd support the delivery of strategic infrastructure in a timely manner. This is essential to support delivery of proposed housing and employment growth. Delivery of necessary infrastructure to support dispersal of housing growth to small rural village clusters will, however, be difficult and expensive. The ability of small schemes to fund the provision of on-site services and facilities and to support local infrastructure capacity improvements through land provision and developer contributions is limited. Therefore, significant dispersal of housing growth to small rural clusters should not form part of the growth strategy (see our answer to Question 13).

Policy 4 sates “School capacity will be increased to provide for growth by improvements to existing schools”
With specific reference to Hingham – there is widespread concern within the community of the pressure that more housing will have on the primary school and Drs surgery. Current plans for Hingham Primary School are to replace old worn out mobile classrooms with new structures, however this will not increase the capacity of the school. With development taking place in Watton, Carbrooke and Great Ellingham, parents from Breckland are looking to enrol children in Hingham Primary School, increasing the pressure on the school’s ability to accommodate additional numbers of children (the Drs Surgery also has a wide catchment area within Breckland). There is also concern regarding the lack of sufficient local child care places to assist working parents.
It should also be noted that Hingham does not have a high school.
With regard to green infrastructure. Being that there is no public car park and businesses in the Market Place and Fairland have no dedicated parking for staff or customers, it would be unlikely to achieve provision for green travel (outside of that of providing private charging points within a development) such as provision of publicly available vehicle charging points.

We note the Interim Viability Study does not include a typology of schemes in excess of 600 dwellings. This creates a gap in terms of taking account of the site-specific infrastructure costs of larger, strategic level housing schemes and the associated viability implications.

A lower level CIL tariff, applied to larger scale developments, should be considered in order to address this issue and support the delivery of strategic sites. Further representation will be submitted on this point in response to Question 48 of the current Regulation 18 consultation.

We support the approach to other strategic infrastructure.
The proposed new settlement Honingham Thorpe would deliver strategic infrastructure from the start, to facilitate the creation of a sustainable community from the first occupation of any dwelling.

11. Policy 4 – Strategic Infrastructure sets out the context for school place planning, and identifies that both expansions of existing and new schools will be required to meet the growth needs.

12. We would advise some slight policy wording amendments to ensure that the policy is sufficiently flexible and can endure throughout the plan period, where need and demand for education places may change.

School capacity will be increased to provide for growth by improvements and expansions to existing schools and the provision of new schools as required, including primary schools on strategic development sites and growth areas as identified in the most up to date evidence base.

13. It is considered that this change will ensure that the changing growth needs are capable of being met in future years, and will be underpinned by the latest evidence base, in accordance with the supporting policy text at paragraph 232 (setting out that the information will be updated annually in line with the Greater Norwich Infrastructure Plan ‘GNIP’). DfE also notes specifically that education infrastructure requirements for the plan period should be included within an Infrastructure Funding Statement . Where additional need for school places will be generated by housing growth, the statement should identify the anticipated CIL and Section 106 funding towards this infrastructure. The statement should be reviewed annually to report on the amount of funding received via developer contributions and how it has been used, providing transparency to all stakeholders.
14. DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability assessment or other evidence relevant to education which may be used to inform local planning policies and CIL charging schedules. As such, please add DfE to the database for future consultations on relevant plans and proposals.
15. The supporting text to the policy, at paragraph 230, sets out the requirement for developer contributions and CIL in the delivery of schools.

16. Local authorities have sometimes experienced challenges in funding schools via Section 106 planning obligations due to limitations on the pooling of developer contributions for the same item or type of infrastructure. However, the revised CIL Regulations remove this constraint, allowing unlimited pooling of developer contributions from planning obligations and the use of both Section 106 funding and CIL for the same item of infrastructure. The advantage of using Section 106 relative to CIL for funding schools is that it is clear and transparent to all stakeholders what value of contribution is being allocated by which development to which schools, thereby increasing certainty that developer contributions will be used to fund the new school places that are needed. DfE supports the use of planning obligations to secure developer contributions for education wherever there is a need to mitigate the direct impacts of development, consistent with Regulation 122 of the CIL Regulations.
17. As drafted currently, we consider that paragraph 230 does not accord with our guidance on developer contributions (as referenced in paragraph 2) and therefore we would propose the following amendments:
If a new development is likely to generate enough children to fill a new school, developers are expected to contribute both the land and for the full construction cost of that school. A pro rata contribution is requested if pupil yield is calculated to be less than a full new school and the school places are to be provided elsewhere through expansions or on other development sites. Land must be secured through S106 Agreements, and contributions towards both on-site and off-site education can be secured through both S106 Agreements and CIL where applicable locally.

18. We also request a reference within the Local Plan’s policies or supporting text to explain that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This helps to demonstrate that the plan is positively prepared and deliverable over its period.

Paragraph 220. When will Anglian Water’s strategic plans for water supply and disposal be completed and made public? In order to comment fully on the GNLP we need to understand what these strategic proposals are. Without them our comments are incomplete, and our input into the GNLP will not be maximised.

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

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.

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

Please see attached for full submission

Please see attached for full submission

Full representations (with appendices) submitted in response to the current Regulation 18 consultation of the Greater Norwich Local Plan on behalf of Landstock Estates Ltd and Landowners Group Ltd.

Thank you for inviting Highways England to comment on the Regulation 18 Draft Review of the Greater Norwich Local Plan (GNLP), which is prepared jointly by three local authorities - Broadland District Council, Norwich City Council and South Norfolk Council through the Greater Norwich Development Partnership (GNDP). This document expresses our views on the Draft Strategy and Site Allocations for future development as mentioned in this GNLP.
Highways England is responsible for the operation, maintenance and improvement of the Strategic Road Network (SRN) in England on behalf of the Secretary of the State. In the area within and surrounding Norfolk, this relates to the A11 and A47 trunk roads.
Consequently, our comments on the draft Local Plan which are set out below are limited to those aspects/strategies which may have impacts related to these two trunk roads.

See attached

I attach the feedback from Broadland Green Party members on the GNLP Consultation.

Each section is identified but not all questions have been answered. However, all questions are included to maintain the numbering.

See attached

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.

General
I support the general approach the team has adopted for the GNLP 2026-38. They are to be commended for all the detailed work that they have put into this exercise.
Infrastructure (Introduction and Draft Strategy Appendix 1 pages 116-7, Q24)
In any future text could the team give greater emphasis to the work that is going on with respective partner organisations to ensure that planning for healthcare and education and transport links is taking place. I appreciate these areas are not in your gift and you are reliant on these partners being broadly in sync with your timescales. However, I note that, when confronted particularly with housing growth in their area, the complaint is often raised that “they” are doing nothing to increase access to GPs or to school places. From a presentational perspective at least, more updates and greater prominence in the report and any press releases, to these aspects, to allay fears, might help to make subsequent housing/ employment development more acceptable. Cecilia Riccardi 12 Abbey Road Wymondham NR18 9BY 3 March 2020 GNLP 1st
Options: Draft Strategy on Growth Options and Main Towns Policy 7.2. p103 onwards, paragraph 329, Q41 and 42)
Option 1: support. Option 2: support.
Garden Village Proposal: Support
I know this is not generally a favoured approach, not least because of the long lead times involved. However, it provides an ideal opportunity to develop something truly ground breaking, visionary and fit for the second half of the 21st century. Any area that can back the RIBA Stirling Prize winner for 2019 surely already has a head-start in the quest for the eco-friendly design that will be required. There must be national grants available to ensure that future communities can be built e.g.to meet climate change targets. It could have a share in the wind-farm bounty Norfolk provides. And simultaneously make a virtue of and preserve sympathetically existing environmental, historical and heritage features. Local authorities must be able to share best practise nationally. Creation of such a village should be standalone, with appropriate infrastructure - roads, healthcare, education - developed and not impinging upon already stretched local towns. Silfield Village, (GNLP2168) if chosen, could be built with all necessary facilities and access onto the A11 growth corridor and not via the Wymondham railway bridge. Such a strategy might also obviate the need for Wymondham to provide for the 1000 homes contingency should e.g. Carrow Road not be available, and thus remove the burden on Wymondham.

Policy 7.2: The Main Towns - Wymondham – preferred sites
GNLP0354 Land at Johnson’s Farm: preferred site for Wymondham
Position: Oppose access proposals.
The good news is that, subject to a 1000 homes contingency, Wymondham is initially only being required to take 100 new homes in the period up to 2038. This is surely in recognition that it took a disproportionate share in the planning period to 2026.
The 50 (of the 100) homes planned under GNLP0354 are neither here nor there given that we are already taking 335 homes on the B1172 Gonville site opposite. (These 335 are additional to the 2200 originally allocated to Wymondham to 2026). However, as the accompanying explanation makes clear, this is likely to lead to an unacceptable expansion (from 50) of up to 400 homes over time. Given that Johnson’s Farm has for some years been keen for development this is surely likely to be sooner rather than later. I am less than confident that the “protecting heritage aspects”, including any covenants currently in place, arguments, will hold much sway given the Gonville Hall experience.
A Request
Would planners, and especially highways, please reconsider the requirement for access/exit for the 50 homes to be through Abbey Road. There is one narrow entrance/exit to Abbey Road for the currently situated 77 homes. Abbey Road leads directly from the B1172 roundabout and at entry has a crossing point with a light which further restricts access. This estate road bends round to the left past the children’s park and then curves right to a left turn with a narrow access point (two cars width) on to Johnson’s field behind. Unless the plan is to remove the entry, crossing point and install double yellow lines all along this narrow road to prevent parking, further development is NOT feasible by this route. More worrying is the 18 months to 2-year building phase when this narrow road could not take all the JCBs, construction lorries, heavy machinery and low-loaders etc. safely. Surely new developments should not be designing in traffic chaos? I ask for a rethink and on- the- ground inspection. I enclose a map which shows the roundabout and unsuitability of this road for access/exit.

For full representation, please refer to the attached documents.