Question 39. Do you support or object or wish to comment on the approach for East Norwich? Please identify particular issues.

Comment

Representation ID: 19824

Received: 03/02/2020

Respondent: Mrs Suzanne Jones

The development of the Utilities site is still designated, in part, for energy generation. The collapse of the proposed Generation Park project on this site demonstrates the dangers of infrastructure projects of this size, based on unproven technologies and wholly dependent on government subsidies that can be withdrawn at any time. Norwich almost ended up with an outdated, polluting and uneconomic white elephant on its eastern fringe. Any future energy producing developments should be of a manageable scale, using proven technology and be truly green, i.e. not adding further emissions to Norwich's already sub-standard air quality.

Object

Representation ID: 20300

Received: 04/03/2020

Respondent: Mr ALAN EARTHROWL

Increasing population will exhaust what little facilities we have,The roads generally lanes are not large enough for extra traffic and there are very few footpaths.Where the narrow lanes wear away Pot holes will become a major problem.Pedestrians will be put at greater risk and maybe street lights might have to be considered.Light pollution?.I understand that the council has many more possible sites available that should be considered.

Support

Representation ID: 21332

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

The approach to East Norwich is supported. This is a key area of the City Centre that will benefit from regeneration and can support an attractive new community area for the city. The inclusion of sustainable energy generation is only supported if the type and scale of generation is compatible with achieving a healthy and attractive environment for the proposed new residential community and does not compromise air quality or amenity standards for residents.

Support

Representation ID: 21412

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

The approach to East Norwich is supported. This is a key area of the City Centre that will benefit from regeneration and can support an attractive new community area for the city. The inclusion of sustainable energy generation is only supported if the type and scale of generation is compatible with achieving a healthy and attractive environment for the proposed new residential community and does not compromise air quality or amenity standards for residents.

Comment

Representation ID: 21765

Received: 16/03/2020

Respondent: Brown & Co

We would raise concern regarding the proposed approach for East Norwich. This area is subject to significant flood risk, contamination, infrastructure constraints, and is located adjacent to The Broads and a number of heritage assets. These constraints, together with the significant investment required to deliver development in this location has seen no scheme progress despite previous allocations and approved planning applications.

Comment

Representation ID: 21778

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Due to scale and lack of contour lines it is hard to determine but the map on page 95 seems to show the proposed development areas 1+2 sit within the floodplain. This would seem to contradict advice regarding development in the floodplain.
Given the comment within the draft document describing biodiversity buffers, are there opportunities with the 4 proposed developments in East Norwich to bring nature close to or within these development areas?

Comment

Representation ID: 22068

Received: 16/03/2020

Respondent: Norfolk Wildlife Trust

Policy 7.1 - The Norwich Urban Area including the fringe parishes
We note the inclusion of an allocation for development in the East Norwich strategic growth area, which overlaps with the Carrow Abbey County Wildlife Site. The outline permission granted several years ago highlights the clear need to safeguard this site in perpetuity as part of the wider site design and we recommend that specific reference to these requirements is made in the policy text for clarity.

Comment

Representation ID: 22290

Received: 16/03/2020

Respondent: Barton Willmore

Q38 - 40) Consultation Questions for Policy 7.1 – The Norwich Urban area including the fringe parishes

2.56 The introduction to the draft Sites Allocation Document (SAD) confirms the document identifies the preferred sites for new allocation, the allocations to be carried forward from the current Local Plans, reasonable alternative sites (where appropriate) and unreasonable housing sites. The SAD is split into 50no. Settlement Papers which summarises the settlement characteristics and the existing and/or proposed allocations. 2.57 In the main, these provide a brief summary of existing allocations, and review whether these remain deliverable within the new Plan Period, and the sites submitted through previous call for sites, providing a rationale for why the sites should or should not be allocated.

2.58 One exception to the above are the existing allocations within the Growth Triangle, allocated through the Growth Triangle Area Action Plan (2016), which the Settlement Papers conclude to be carried forward:

High amounts of existing development commitment remains, as the allocations identified in the Growth Triangle Area Action Plan will not be superseded by the new local plan

2.59 No justification for this approach is provided within the Draft Strategy or the SAD.

2.60 As acknowledged in Table 2.1 and 2.2, the JCS has delivered poorly against its housing requirement since the start of the Plan period. A significant failing of the JCS has been the under delivery of allocations within the Growth Triangle. In particular allocations GT6, GT11, GT12, GT13, GT14 and GT16.

2.61 Policy 7.1 (The Norwich Urban Area including fringe parishes) identifies 12,019 dwellings as the ‘existing deliverable commitment’ for The Growth Triangle with 1,415 additional dwellings proposed through the GNLP.

2.62 Of the 12,019 committed dwellings, Appendix B1 (Broadland Sites Forecast) of Annual Monitoring Report 2018 – 19 (AMR, Appendix 4) identifies the Growth Triangle area is expected to deliver 4,485 dwellings between 2019/20 – 2025/26 (i.e. the remainder of the Joint Core Strategy Plan Period).

2.63 The AMR identifies the remaining 7,623 dwellings will be delivered in ‘2026 and beyond’. No updated trajectory is provided within the AMR or as part of the current GNLP consultation to demonstrate when these 7,623 dwellings (circa. 23% of the existing commitments) will be delivered i.e. by 2038 or beyond.
2.64 Table 2.3 below summarises 4no. allocated Growth Triangle sites which account for circa. 6,350 dwellings of the supply to be delivered ‘2026 and beyond’, not account for additional dwellings identified to be delivered in 2024/25 – 2025/26 (for which no evidence is provided).
Table 2.3: Growth Triangle Area Action Plan allocations [see attached document] 2.65 Sites GT12 and GT16 are anticipated to deliver 3,500 and 3,000 dwellings respectively in the Plan period. To date neither have commenced – despite being anticipated to deliver from 2019/2020 and 2016/2017 respectively. In the case of GT12, the latter phases are dependent on Infrastructure Forward Funding. Neither sites have secured detailed permission for any phase. Even if permission was to be granted now, accounting for NLP lead in times, they would not commence before 2021. This is ambitious, and even then would have to deliver housing at a rate of 220 dwellings per annum in the case of GT12, and 227 dwellings per annum in the case of GT16 (as set out in the AMR which anticipates no housing on site until 2024). NLP 2016, highlights average build out rates of 171 dwellings per annum on greenfield sites of this size, reducing to 148 dwellings per annum for brownfield sites. Based on these averages and the anticipated delivery rates in the 2018/2019 AMR, it would result in a housing shortfall of over 1,200 homes in itself. Accordingly, these allocations should be reduced to 2,927 (GT12) and 2,388 (GT16) respectively. The shortfall must be accounted for elsewhere.

2.66 The GNLP needs to provide a clear evidence-based justification for carrying over allocations identified in the Growth Triangle Area Action Plan. No such evidence is currently provided and as such the Plan risks being found unsound on account of being unjustified, not effective and not positively prepared on this basis. At the very least, we highlight for valid reasons the allocations GT12 and Gt16 cannot deliver the numbers anticipated, which should result in a reduction of 1,200 homes.
2.67 Furthermore, the Growth Strategy seeks to allocate additional land within the Growth Triangle with a proposed allocation for 1,200 dwellings in Sprowston. This site is under the control of the developers of the adjoining GT20 allocation (White House Farm) which is subject to an Outline application for 516 dwellings submitted August 2019 pending determination (application ref. 20191370). The AMR identifies an expectation for GT20 to commence in 2021/22 and complete in 2025, however given Outline consent has not yet been granted (and subsequent Reserved Matters prepared and submitted), this may be optimistic. The proposed allocation in Sprowston is identified to be built out after GT20 has completed. It is therefore unlikely the proposed allocation, for 1,200 dwellings, will be delivered within the Plan period. Policy 7.1 and Policy 1 should be updated to reflect this site is unlikely to deliver its full allocation within the Plan period.

2.68 To ensure the Plan delivers its housing growth requirement over the Plan Period, there is clearly a need to reduce the reliance on the Growth Triangle allocations which have not delivered as anticipated and allocate additional sites which are developable within the Plan Period, including in other locations outside the Growth Triangle. 2.69 Furthermore, Page 94 of the GNLP highlights that there is uncertainty over the Unilever/Carrow Works site. The NPPF requires clear evidence of delivery, and as such this allocation should be removed. As detailed in Section 3, Wymondham is such a location to accommodate at least some of this growth.

2.70 Accounting for the above, 1,200 homes as a minimum should be removed from the Growth Triangle, with further justification provided for all homes to be delivered in this location. Based on delivery to date in the Growth Triangle, we also strongly object to the addition of a further 1,415 homes in this location. To continue to rely on housing delivery in the Growth triangle undermines confidence in the GNLP to deliver on its needs. As such a minimum of 2,615 homes should be removed from the Growth triangle and re-allocated. As detailed in Section 3, Wymondham is such a location to accommodate at least some of this growth.

2.71 Within Wymondham, the Promoters have successfully secured consents resulting in circa. 900 dwellings being completed in the past 14 years from unidentified sites. This reflects not only the suitability of Wymondham as an appropriate location (i.e. people want to live there) but also represents a proven and trusted track record for the Promoters in bringing forward suitable sites.

Comment

Representation ID: 22344

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail; main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 We reserve the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.

Comment

Representation ID: 22379

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

7. POLICIES 7.1-7.5 – THE SPATIAL STRATEGY
Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail, main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 Our client reserves the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.
Policy 7.2 - Main Towns
7.17 Policy 7.2 sets out the level of growth to be delivered in the plan period for the Main Towns of Aylsham, Diss, Harleston, Long Stratton and Wymondham. Collectively these towns will provide 6,342 homes, approximately 14% of housing growth for the plan period.
7.18 Paragraph 308 of the GNLP states that these towns play ’a vital role on the rural economy’ as they ‘provide employment opportunities and services for rural hinterlands’. It goes on to say that the settlements are ‘the engines of rural growth’.
7.19 Accordingly, it is necessary to make appropriate provision at these highly sustainable settlements to ensure that the rural economy is supported and that local housing needs are addressed including at Diss.
7.20 The GNLP states that Diss is ‘strategically located’ with the ‘widest range of shops and services of the main towns’ plus a ‘broad range of employment opportunities’. It is identified at paragraph 317 as having ‘potential for economic growth as an enhanced centre serving a large rural hinterland in South Norfolk and northern Suffolk’. Paragraph 322 identifies Diss as having ‘potential for jobs growth on existing undeveloped allocated employment land particularly for manufacturing, including high value activities.’ (emphasis added)
7.21 Given the above statements about Diss taken from the introduction to Policy 7.2 it is concerning that it ranks third out of the five main towns for proposed housing delivery in the plan period with 743 new homes proposed, 343 from existing commitments and 400 from new allocations, representing just 12% of new housing development to come forward at main towns.
7.22 It would seem appropriate given the status Diss is given in the GNLP that it would provide a greater percentage of new housing growth especially as it is the only main town that is a net importer of workers as described in the spatial strategy representation above.
7.23 It is of particular importance if the plan is to balance the delivery of homes to jobs that Diss is allocated more housing growth to address the current shortfall of workers. Additional housing over and above that required to address the current shortfall will be required to provide for workers at new employment development coming forward on the allocated 10.8ha site at Diss. There are therefore strong arguments to increase the level of new housing proposed at this main town. 7.24 Proposed housing allocations at Diss, as set out in the draft GNLP, include a new green field site to the north of the town, and a large brownfield site to the east of the town immediately adjacent to the train station.
7.25 Concern is raised over the deliverability of the brownfield site (GNLP0102 Frontier Agriculture Ltd) as this is an existing employment site in active use by the UK’s leading crop production and grain marketing business. The site provides one of the company’s nationwide network of grain storage and processing facilities each of which are located in strategically placed locations to provide optimum accessibility for producers across the local area. The loss of the facility from Diss would be disadvantageous to the local agricultural sector.
7.26 The delivery of new residential development at the site would also be almost entirely surrounded by employment land meaning that it would be largely disconnected from neighbouring residential uses which provide for natural surveillance and reduce the potential for crime. There may be issues with residential amenity given the presence of businesses immediately on virtually all sides, each of which is likely to be served by heavy goods vehicles potentially operating throughout the day and night, with the potential for noise and air quality issues.
7.27 Moreover, the Diss Sites Evidence Base document states that the use of the site for residential purposes is not supported by the local community who consider the allocation of the site to be prejudicial to the delivery of the Diss Neighbourhood Plan. (A previous outline application for demolition of existing buildings at the site and the erection of 90 dwellings was withdrawn (2015/2816) on 17th October 2016.)
7.28 The Stage 6 detailed site assessment states that no additional documents have been submitted to support the site.
7.29 Therefore, in terms of residential amenity and delivery, this residential allocation is considered to be inappropriate when other deliverable alternatives are available such as land at Walcot Green Lane (GLNP1044) which will provide new green infrastructure linkages including circular footpath routes, market and affordable homes and self-build plots plus new highway improvements to Walcot Green Lane, all of which will provide benefits to existing and new residents alike. 7.30 The land at Walcot Green Lane is deliverable and additional technical work that has been carried out in support of promoting the site evidences that highway constraints identified by the Council’s evidence base can be overcome through the provision of a high quality pedestrian and cycle link via Orchard Croft to the south. The site is not otherwise constrained and can contribute to the authorities five-year housing land supply.
7.31 In conclusion Diss should be providing additional housing through allocations in the GNLP in order to balance jobs with homes at the Main Towns. The quantum of housing currently proposed in the GNLP is inadequate to achieve a jobs/homes balance and additional employment land is proposed through the GNLP. The argument for additional and alternative housing allocations at Diss is compelling, especially given the proposed brownfield allocation at the town which is not appropriate in terms of place making or delivery. The land at Walcot Green (GNLP1044) is an appropriate alternative which should be allocated to help address the emerging unmet housing needs at Diss.

Support

Representation ID: 22425

Received: 16/03/2020

Respondent: Norwich Green Party

We broadly support the proposals in principle. There is a need to reference the requirement to protect the Carrow Abbey County Wildlife Site in the policy wording.

Comment

Representation ID: 22426

Received: 16/03/2020

Respondent: Norwich Green Party

Ref. the interim sustainability appraisal which assesses policy options against the 15 sustainability objectives established by the scoping report. We are very concerned that the interim sustainability appraisal undermines its whole purpose by also considering ‘delivery’ as a factor to weigh against the objectives. This is summed up by p52 of the appraisal: after a table presenting the six options for distribution of housing allocations (p42), in which it is absolutely clear that options 1, 2 and 3 perform better than the dispersal options (4, 5 and 6), the “summary of significant effects” starts: “Options 1, 2 and 3 may be harder to deliver”, goes on to observe that 1,2 and 3 perform better on everything else, then concludes “in sustainability terms the choice between alternatives appears finely balanced, with no alternative clearly better than another in SA terms”.
This is dishonest. The only objective on which 4, 5 and 6 are deemed to perform better is SA5, “Ensure that everyone has good quality housing of the right size and tenure to meet their needs”. In the ‘analysis’ of this objective on p45, there is no mention of meeting need (which surely relates to providing affordable housing in places where there are jobs and where people therefore want to live); instead, this becomes “diversity, choice and competition in the market for land” and “least risk of delay”, and judges dispersal the best option – ignoring the fact that this will result in unaffordable housing in unsustainable non-communities with no employment, so not actually meeting need at all. SA5, therefore, is first twisted to have a completely different meaning in order to support dispersal, then considered to outweigh all the other objectives put together (there’s no hierarchy of objectives in the SA) to the extent that the dispersal options become equally sustainable to options that would concentrate growth where infrastructure and services are.
“Delivery” is not an objective in the Sustainability Assessment and should be disregarded for the purpose of weighing up policies on sustainability grounds.

Object

Representation ID: 22541

Received: 16/03/2020

Respondent: Historic England

We recognise the opportunities provided in East Norwich for brownfield regeneration.
One of our key concerns in this area relates to Carrow Works (Abbey/Priory). We have set out in more detail our concerns in Appendix B in relation to this site but in summary, we question the capacity of the site and suggest that a more detailed Heritage Impact Assessment be undertaken before the next draft of the Plan to inform the suitability or otherwise of the site, the likely impact of development upon the significance of heritage assets, the extent of the developable area and hence capacity of the site, any necessary mitigation or enhancements that could be made and then any changes required to policy wording.

Suggested Change: Undertake detailed HIA for Carrow Works site.

Object

Representation ID: 22545

Received: 16/03/2020

Respondent: Historic England

P101 Bullet point 4
We welcome bullet point 4 in relation to heritage assets. We suggest the use of the word including before Carrow as there are other heritage assets besides those listed.

Support

Representation ID: 22861

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

We support the allocation of East Norwich and note the intention for sustainable accessibility and traffic restraint, and for links between the city centre and Whitlingham Country Park. The addition of 2,000 additional homes in this location, as well as other uses, will result in significant additional population living and working on the site. This makes it even more important that Park & Ride facilities are located in close proximity, to ensure sustainable access. The pressure from additional population within a high density development, where land is at a premium, may need to be met by SANGS. The additional land at WCP should be safeguarded for this purpose within the Plan.

Object

Representation ID: 23084

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

In responding to Policy 7.1 we refer back to our comments in respect of Policy 1. In summary we consider there to be serious flaws arising from:
i. the continued overreliance on East Norwich given past under-delivery;
ii. the failure to distribute new growth within other parts of the GNLP area to more closely align with local housing needs where they arise and thus avoid market saturation in areas of more marginal viability;
iii. misalignment between the spatial strategy and the economic priorities of the Plan related to the Tech Corridor; and
iv. the assumptions over the scale of housing delivery arising from a key regeneration site in the centre of Norwich (Carrow Road) which is subject to considerable and acknowledged uncertainty above).

Comment

Representation ID: 23174

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site
- land in front of ATB Laurence Scott
8.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
8.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
8.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
8.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
8.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.