Question 37: Are there any topics which have not been covered that you believe should have been?
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21609
Received: 16/03/2020
Respondent: Hingham Town Council
Use/regeneration of of existing empty retail premises within high street/communities
Use/regeneration of of existing empty retail premises within high street/communities
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22041
Received: 13/03/2020
Respondent: East Suffolk Council
We support the approach in The Economy policy.
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
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22408
Received: 16/03/2020
Respondent: Horsham Properties Ltd
Agent: Mrs Georgina Brotherton
Draft Policy 6 ‘The Economy’
3.1 The draft GNLP states that it seeks to support small and medium sized businesses within both urban and rural areas by allocating sufficient employment land and allowing for windfall sites to come forward. However, Policy 6 ‘The Economy’, as drafted does not provide a flexible policy basis to accommodate the needs not anticipated by the Local Plan or to enable the expansion of existing small and medium size employment sites across of the GNLP area. Policy 6, as drafted therefore does not align with the NPPF or adopted Joint Core Strategy Policy 5 ‘The Economy’ and it is requested that the policy is amended to allow for the expansion of existing small and medium sized employment sites, such as the Abbey Farm Commercial Park site.
3.2 Paragraph 116 of the GNLP explains that the role of smaller scale employment sites in the urban area, market towns and villages will help to deliver good access to jobs for all. To promote the delivery of jobs, Section 4 of the GNLP explains that the draft plan provides choice and flexibility by providing for a wide range of type and size of employment sites. In terms of smaller scale and rural employment sites, Section 4 explains that such sites will be supported in accessible and sustainable locations.
3.3 Policy 1 outlines the Local Plans sustainable growth strategy and the supporting text to this policy explains at paragraph 151 that the plan allocates employment sites totalling around 360 hectares. Paragraph 155 explains that the Plan also allocates land and allows for additional windfall delivery of smaller scale sites to provide for jobs growth elsewhere in the urban area, towns and villages, providing local job opportunities and supporting small-scale businesses and a vibrant rural economy.
3.4 Whilst Policy 6 as drafted recognises the needs of small, medium and start-up businesses and explains that this will be addressed through the allocation and retention of smaller scale employment sites across the area, the policy as drafted does not allow for the expansion of existing small and medium sized sites.
3.5 Policy 5 ‘The Economy’ of the Joint Core Strategy specifically addressed the needs of small and medium sized businesses within the policy by allowing for the expansion of existing small and medium sized employment sites. We consider that this part of Policy 5 should be carried forward into draft Policy 6 of the GNLP.
3.6 By allowing existing employment sites to expand, this would enable existing businesses to grow and meet their evolving requirements on site rather than relocate, potentially out of the GNLP area. Paragraph 80 of the NPPF states planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Paragraph 81 goes on to state that policies should be flexible enough to accommodate needs not anticipated in the plan and to enable a rapid response to changes in economic circumstances.
3.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows: 2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.
On behalf of our client, Horsham Properties Ltd and owner of Abbey Farm Commercial Park at Horsham St Faith, we write in respect of the Greater Norwich Local Plan, Regulation 18 - Part 1, The Strategy and Part 2 Site Allocations Consultation, published January 2020.
Please find attached LPP’s statement that sets out our representations regarding Site Reference HNF3 – Land at Abbey Farm Commercial Park, Horsham St Faith, that is allocated for employment uses within the Broadland District Council Site Allocations Development Plan Document (2016) and is identified as ‘Carried Forward Employment Allocation’ within the draft Greater Norwich Local Plan (GNLP) (2020).
This statement also considers the policies contained within Part 1 The Strategy set out within the draft GNLP and provides representations in respect of Policy 6 ‘The Economy’, Policy 7.4 ‘Village Clusters’ and responses to questions 6, 10, 15, 34 and 46. A response to each question has also been submitted via the GNLP online consultation portal.
This statement additionally identifies and seeks the allocation of land north of Abbey Farm Commercial Park (0.9 hectares), as a further modest extension to the Commercial Park for employment use.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22683
Received: 16/03/2020
Respondent: Mrs Nicole Wright
Policy 6:
The Economy
Comment
The draft policy does a good job at defining the allocated sites.
However, it needs to provide a clear framework for assessing future proposals that may come forward, in a flexible way that will respond to changing needs in both rural and urban contexts.
Although it states what provision has been made, it does not offer criteria for assessing development proposals that are not currently in the frame.
The site is ideally situated at the Thickthorn Junction
Gateway Zone on a Green Infrastructure Corridor and the Cambridge Norwich tech corridor. It is adjacent to the
proposed park and ride extension and the planned
Highways England A47/A11 Thickthorn Junction
improvement works.
This proposed allocation was originally put forward for a
larger scale allocation. This is proposed to be reduced in
scale as per the attached plan.
The Stage 2 HELAA Comparison Table identifies the
following potential issues with the site:
Flood Risk and Heritage
However, a recent feasibility study found that there were no insurmountable constraints to development in relation to the above or the following:
Compatibility with neighbouring issues
Site access and transport
Access to services
Utilities infrastructure
Contamination
Ground stability / contamination
Landscape
Townscape
Biodiversity/ Geodiversity
The trustees of the land commissioned a Strategic Gap
Appraisal to assess whether the recent and planned
interventions in the Strategic Gap in any way undermined its function and purpose and whether as a result, there is a need to modify its boundaries or progress a strategy to mitigate the harm and enhance its function and purpose.
The site is ideally located to mitigate the impact of the
neighbouring strategic growth allocations through provision of additional community infrastructure in providing a small number of accessible homes for older people, new permissive footpaths and cycleways to encourage outdoor recreation, and a community hub.
A copy of the Sustainability Appraisal, Revised Site Plans and Strategic Gap Appraisal are enclosed.
The proposals have been modified to ensure that they do not conflict in any way with proposed allocations at
Colney, Cringleford or Hethersett. They will instead serve to mitigate their impact in providing additional community and social infrastructure to address the additional need generated.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22859
Received: 16/03/2020
Respondent: Crown Point Estate
Agent: Miss Kate Wood
As noted under question 36 above, independent retail uses are not clarified or accommodated in the Town Centres element of Policy 6. It should be acknowledged that independent businesses have a vital role to play in the vitality and viability of the rural community, and should be accommodated at or close to the edge of villages from which they can draw employees and customers. Such businesses can become destinations for the wider community, but at low numbers, and tend to be relatively localised. We are promoting the allocation of Octagon Farm on the edge of Poringland (a high order settlement), where the present uses of the converted barn can be built upon with additional development that will support that business through linked trips.
For full representation, please refer to the attached documents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23053
Received: 16/03/2020
Respondent: Hingham Town Council
Use/regeneration of of existing empty retail premises within high street/communities
For full representation response, please refer to the attached document.