Question 33: Are there any topics which have not been covered that you believe should have been?

Showing comments and forms 1 to 11 of 11

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20083

Received: 24/02/2020

Respondent: Mr Norman Castleton

Representation:

There should be stipulation herein providing for new housing to be built to a low impact environmental standard including low carbon energy systems, efficient insulation and double/triple glazed windows and doors plus solar panels or other low impact lighting, heating & energy systems.

Full text:

There should be stipulation herein providing for new housing to be built to a low impact environmental standard including low carbon energy systems, efficient insulation and double/triple glazed windows and doors plus solar panels or other low impact lighting, heating & energy systems.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20979

Received: 14/03/2020

Respondent: Mr Andrew Cawdron

Representation:

There should be more comment about the sustainable nature of materials to be used for construction as part of the planning process.

Full text:

There should be more comment about the sustainable nature of materials to be used for construction as part of the planning process.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21587

Received: 16/03/2020

Respondent: Hingham Parish Council

Representation:

Provision of accommodation for the homeless via a relevant charity

Full text:

Provision of accommodation for the homeless via a relevant charity

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22001

Received: 13/03/2020

Respondent: Redenhall with Harleston Town Council

Representation:

The Town Council supports Policy 5 (Homes) and the stated requirements with regard to affordable homes, space standards and accessible housing

Full text:

please find attached the report which was agreed by resolution by Harleston Town Council on March 11th 2020.

Attachments:

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22039

Received: 13/03/2020

Respondent: East Suffolk Council

Representation:

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.

Full text:

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

Attachments:

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22090

Received: 13/03/2020

Respondent: Watkin Jones Group

Representation:

WJG support these objectives for creating a vibrant and inclusive area that is enhanced by new homes, infrastructure
and environment.

Full text:

See attached for full submission by Clare Droog on behalf of WJG

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22376

Received: 16/03/2020

Respondent: Pigeon Investement Management Ltd

Agent: Pegasus Group

Representation:

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure.
5.14 The Policy requires proposals for major housing development to provide; “..at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.15 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.16 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.17 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.18 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.19 Pigeon are supportive of providing self-build plots and their proposals at Diss allow for such development. Indeed, the Diss site allows for a discrete area of 10 self-build plots allowing for mutual support amongst the self-build community and bespoke design solutions to come forward.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed. 5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. As such, provision for approximately 10 self-build plots is made as part of the proposal on land to the east of Walcot Green Lane. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Full text:

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.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22492

Received: 16/03/2020

Respondent: Highways England

Representation:

With the move to more sustainable transport, consideration should be given to how cycles and other non car modes of traffic can be stored, and how electric cars can be charged when not in use.

Full text:

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

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22524

Received: 16/03/2020

Respondent: Broadland Green Party

Representation:

In the policy on homes there is no reference to quality of homes, energy efficiency and climate change. These are critical issues to the future build of homes in Norfolk given the general poor quality of homes adhering to just the basic standards of house building, if that, in some extreme cases.
On the issue of build quality, there appears to be a woeful lack of building control inspections to ensure at least the minimum of standards adhering to the Building Regulations. We suspect this is in part due to a combination of the privatisation of Building Control (CNC) and the reduction in funding to local authorities to carry out statutory responsibilities adequately, in this case that of building control inspections. This dire situation needs to be urgently rectified.
Back in 2008 the Climate Change Strategy for Norfolk signed by all seven district councils and the county council stated: ““Most of the houses and infrastructure that we build now will still be standing in 2080, when the impacts of climate change will be much greater. The considerable level of growth planned for the county by 2026 provides an immediate strategic opportunity to plan housing and infrastructure that will be much more resilient to the impacts of climate change. This will reduce long term risks to Norfolk residents and help avoid the potentially major expense of addressing problems at a later stage, after the impacts of climate change have been felt.”
All new housing must be carbon neutral or at least built to Passivhaus standards.

Full text:

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

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 23048

Received: 16/03/2020

Respondent: Hingham Parish Council

Representation:

Provision of accommodation for the homeless via a relevant charity .

Full text:

For full representation response, please refer to the attached document.

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 23198

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

Representation:

The policy does not contain any guidance on the required housing size mix. We would expect this to be included and Orbit Homes favours a flexible approach in this regard that requires broad accordance with the latest SHMA evidence.

Full text:

On behalf of our client Orbit Homes (2020) Limited we wish to make representations to the Greater Norwich Local Plan (GNLP) Regulation 18 Draft Plan Consultation.

These representations comprise Orbit Homes’ comments on the policies contained in the Draft Strategy document and on the Draft Sites document for Long Stratton.

Please see attached document comprising a cover letter, response from and separate enclosures providing comments on the following policies / sites:

• Enclosure 1. Response Form
• Enclosure 2. Policy 1 – Growth Strategy
• Enclosure 3. Policy 2 – Sustainable Communities
• Enclosure 4. Policy 5 – Homes
• Enclosure 5. Policy 7.2 – The Main Towns
• Enclosure 6. GNLP0509 – Land south of St Mary’s Road, Long Stratton
• Enclosure 7. Policy 7.4 – Village Clusters, including:
• Land to the north of Ransome Avenue, Scole; and
• Land north of Church Road, Tasburgh

We trust that these comments will be given due consideration and look forward to participating further as the Greater Norwich Local Plan progresses. If you require any further information in respect of our client’s site then please do not hesitate to contact me or my director Geoff Armstrong whose details provided in the attached letter.

Attachments: