Question 40. Do you support or object or wish to comment on the approach for elsewhere in the urban area including the fringe parishes? Please identify particular issues.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 19834
Received: 03/02/2020
Respondent: Miss Philippa Thomas
The current provision of Doctor's surgeries and schools in the Taverham/Drayton area is already overstretched. Before more housing is built, which would stretch services even further, I would like to see a larger health centre (like the one at Hoveton and Wroxham) up and running and larger school premises, thereby providing better services for the existing population before we consider introducing more housing. Our priority should be services to provide for the current community not adding more stress to the overstretched services.
The current provision of Doctor's surgeries and schools in the Taverham/Drayton area is already overstretched. Before more housing is built, which would stretch services even further, I would like to see a larger health centre (like the one at Hoveton and Wroxham) up and running and larger school premises, thereby providing better services for the existing population before we consider introducing more housing. Our priority should be services to provide for the current community not adding more stress to the overstretched services.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 19865
Received: 07/02/2020
Respondent: Dr Matthew Tomlinson
Please carefully consider the environmental and social impact of any further UEA expansion in the sensitive yare valley area. There is a risk that a continually squeeze on this area will see a shrinkage and consequent devaluing of this vitally important area.
Please carefully consider the environmental and social impact of any further UEA expansion in the sensitive yare valley area. There is a risk that a continually squeeze on this area will see a shrinkage and consequent devaluing of this vitally important area.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 19871
Received: 07/02/2020
Respondent: Mr Graham Everett
I support the proposed site for 1400 dwellings subject to adequate infrastructure being provided in the early stages of the development. These requirements are for a new doctors surgery and junior school as all others in the area are already at full capacity. A new footpath from the site entrance on Reepham Road to the NDR roundabout is already required.
I support the proposed site for 1400 dwellings subject to adequate infrastructure being provided in the early stages of the development. These requirements are for a new doctors surgery and junior school as all others in the area are already at full capacity. A new footpath from the site entrance on Reepham Road to the NDR roundabout is already required.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 19873
Received: 07/02/2020
Respondent: Mr Graham Everett
I am pleased that no additional sites have been proposed in the parish of Drayton. There are already approved planning permissions for up to 400 new dwellings, and the infrastructure cannot support any more. Drayton is in a critical drainage area as identified in the Norwich Urban Water Management plan and is at risk of surface water flooding.
I also agree that no new sites should be proposed in the parishes of Horsford and Hellesdon.
I am pleased that no additional sites have been proposed in the parish of Drayton. There are already approved planning permissions for up to 400 new dwellings, and the infrastructure cannot support any more. Drayton is in a critical drainage area as identified in the Norwich Urban Water Management plan and is at risk of surface water flooding.
I also agree that no new sites should be proposed in the parishes of Horsford and Hellesdon.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20000
Received: 19/02/2020
Respondent: Michael Olesen
Today I attended the GNLP consultation in Sprowston. I appreciate the need for a long term strategy but, as a resident, find it difficult to make a meaningful decision on its proposals when there is no detail on resolving current issues and future identifiable concerns. There is no link to show improvements to local infrastructure nor proposals to cope with all the issues associated with building an additional 4,700 properties and managing the increase in population and road usage. You draft identifies certain infrastructure areas yet I could only find mention to schools. What about medical facilities, police/fire stations, community facilities, cycle routes, increases in buses, improvements to existing roads and junctions, and green spaces. For example, the draft mentions using current P&R site for a High School yet the access roads are already inadequate for the level of current traffic and the roundabouts (both off wroxham road and at junction with P&R) are already choke points at busy times. Another example is the lack of cycle ways, the Salhouse and North Walsham Road are currently not suitable for use by cyclists as there are no cycle tracks, the roads are narrow and the level of traffic high.
Finally, an area long overlooked, bus routes into Norwich City. Why are there no bus lanes going North out of the City? Why do buses use the narrow stretch of Sprowston Road; when to pass vehicles they have to mount the public footpath. I am of the opinion that whilst identifying sites for development little or no consideration has been given to the infrastructure and maintaining/improving the quality of life for current and new residents.
Today I attended the GNLP consultation in Sprowston. I appreciate the need for a long term strategy but, as a resident, find it difficult to make a meaningful decision on its proposals when there is no detail on resolving current issues and future identifiable concerns. There is no link to show improvements to local infrastructure nor proposals to cope with all the issues associated with building an additional 4,700 properties and managing the increase in population and road usage. You draft identifies certain infrastructure areas yet I could only find mention to schools. What about medical facilities, police/fire stations, community facilities, cycle routes, increases in buses, improvements to existing roads and junctions, and green spaces. For example, the draft mentions using current P&R site for a High School yet the access roads are already inadequate for the level of current traffic and the roundabouts (both off wroxham road and at junction with P&R) are already choke points at busy times. Another example is the lack of cycle ways, the Salhouse and North Walsham Road are currently not suitable for use by cyclists as there are no cycle tracks, the roads are narrow and the level of traffic high.
Finally, an area long overlooked, bus routes into Norwich City. Why are there no bus lanes going North out of the City? Why do buses use the narrow stretch of Sprowston Road; when to pass vehicles they have to mount the public footpath. I am of the opinion that whilst identifying sites for development little or no consideration has been given to the infrastructure and maintaining/improving the quality of life for current and new residents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20151
Received: 26/02/2020
Respondent: Yvonne Todd
Ref:- Taverham and District areas.
Whichever site/s are chosen by Council, I do hope the following comments are considered first.
When Thorpe Marriott was first approved for development , the local communities of Taverham,Drayton. Etc, were lead to believe that there would be new schools and doctors surgeries. THIS never happened.
Therefore in my opinion if permission (wherever that maybe) is granted, BEFORE the start of house building, YOU AS COUNCIL, should insist that the Schools, Doctors Surgery and any other public services, be built first. This way guaranteeing that they are In place for all new comers to the area.
We are all well aware of the existing Doctors and Schools are already chock-a-block, no way, will they be able to cope with the proposed 1400 houses, resulting in 3000 plus, extra people. Neither Drayton or Taverham Doctors have land available around the exsisting surgeries , if they had, maybe those could have been enlarged .
We can all promise things, words mean nothing unless carried out, that then makes the promise right.
Ref:- Taverham and District areas.
Whichever site/s are chosen by Council, I do hope the following comments are considered first.
When Thorpe Marriott was first approved for development , the local communities of Taverham,Drayton. Etc, were lead to believe that there would be new schools and doctors surgeries. THIS never happened.
Therefore in my opinion if permission (wherever that maybe) is granted, BEFORE the start of house building, YOU AS COUNCIL, should insist that the Schools, Doctors Surgery and any other public services, be built first. This way guaranteeing that they are In place for all new comers to the area.
We are all well aware of the existing Doctors and Schools are already chock-a-block, no way, will they be able to cope with the proposed 1400 houses, resulting in 3000 plus, extra people. Neither Drayton or Taverham Doctors have land available around the exsisting surgeries , if they had, maybe those could have been enlarged .
We can all promise things, words mean nothing unless carried out, that then makes the promise right.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20257
Received: 29/02/2020
Respondent: Amanda Mitchell
I understand you are doing alot of building around Thorpe Marriott and Drayton..when they built Thorpe Marriott they did not put any bridle ways in for horses..so we have to do road work to get to Marriotts way..please consider putting bridle ways into your new plans
I understand you are doing alot of building around Thorpe Marriott and Drayton..when they built Thorpe Marriott they did not put any bridle ways in for horses..so we have to do road work to get to Marriotts way..please consider putting bridle ways into your new plans
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20356
Received: 24/02/2020
Respondent: Mr R Craggs
A Basic Appraisal of Flood Risk in Sprowston and the need for Existing Homes to be assured Protection
(By Robert Craggs a member of the Sprowston T.C. Flood Risk Working Party)
Summary & Purpose
The dramatic increase in development in Sprowston has progressively raised concern about the increased propensity for flooding to existing homes and fundamentally because it is in e in a flood plain. New homes and buildings can be sited and constructed to avoid flooding but not existing homes. Hence the focus on preventative action and assurance.
Climate change is blamed for the flooding generally in the UK but in reality it is more attributable to building on flood plains where one can expect the ground to saturated
A Basic Appraisal of Flood Risk in Sprowston and the need for Existing Homes to be assured Protection
(By Robert Craggs a member of the Sprowston T.C. Flood Risk Working Party)
Summary & Purpose
The dramatic increase in development in Sprowston has progressively raised concern about the increased propensity for flooding to existing homes and fundamentally because it is in e in a flood plain. New homes and buildings can be sited and constructed to avoid flooding but not existing homes. Hence the focus on preventative action and assurance.
Climate change is blamed for the flooding generally in the UK but in reality it is more attributable to building on flood plains where one can expect the ground to saturated
Introduction:
The purpose of this description is to remind residents of the difficult situation we have been put in by the failure of authorities to ensure proper protection of existing homes, and
worthy though the work now being done by the Greater Norwich Local Plan Team, this should have preceded the approval of the massive developments approved for Sprowston.
It is very apparent now that the initiative taken by Sprowston Parish Council in 2011 in forming their Flood Risk Working Party should have been adopted years ago by both Broadland DC and Norfolk CC because consultation and input of local knowledge is vital to such a strategy
You will see the Interactive Mapping System displayed on the Greater Norwich Local Plan Regulation 18 Draft Plan and it will be very worthwhile to explore this in detail at the forthcoming Roadshow. To make sense of these maps one needs computer facilities to navigate, zoom in and try and understand the interaction of the dynamics in play.
Trying to superimpose massive developments on a map of a flood plain where the presence of groundwater is unknown - in order to understand flood risk - is not easy. Understandably, many will not be up to the task and given the complexity, I tend to put myself in that category. However, the anecdotal evidence of residents is crucial to compiling an authentic map despite the reluctance they may have to disclosing information that might affect the value of their homes.
By way of my own contribution to understanding the propensity of flood risk in this area, I am submitting this basic description of the dynamics of surface water and groundwater in this area, because of the importance but hidden nature of the latter. This description is but of one part of Sprowston but hopefully it may assist residents in identifying key factors contributing to flooding. This description therefore is a microcosm of a wider problem but the principles are the same.
My concerns about flood risk to existing homes spans over two decades where I have been very critical of the failure of Developers, Planning Authorities and the Environment Agency because of their failure to consult on such a critical issue and where due diligence has not been exercised. Consequently, when appeals become complaints and these are still ignored, residents need to exercise their own due diligence to get proper assurances.
Description of drainage systems and propensity of flood risk to some areas of Sprowston.
What follows is a brief description showing how water can travel above and below ground and backing-up to cause flooding.
I do not know when the drainage culverts in Sprowston were created, but it is over thirty years since ‘old timers’ informed me that these had ‘always been there’. It is possible that they preceded the days when clay was extracted for brick-making. Then, drainage channels would have been dug to get access to further deposits but adding to the difficulty now, in understanding where water is coming from and where it is going.
This could explain the dilemma admitted by Peter Brett Associates when they could not understand the flooding dynamics around the Sprowston P&R site when they carried out the FRA in 2012 for the consortium of Developers represented by Beyond Green’s Planning Application 20121516. The old-fashioned drainage pipes I observed appeared to suggest this
The previous FRA carried out before this re-sited P&R was approved, was a disaster when the site was designated as having a 1 in a 100 -year risk of flooding when local residents told them that it was a regular occurrence, just as it was on Home Farm before the area adjacent Wroxham Road was developed.
Water falling on or draining into Sprowston, drains in a northerly direction towards the River Bure, except in the south where it drains into the Wensum and the Yare
Reference to an Ordance Survey map will help to follow this description. GNDP SFRA Index Grid map GN 35, can also be consulted but the area discussed is slightly off this map – in fact this GN35 map fails to show what is described here what in effect is a drainage path:
1. There is a drainage lagoon with boreholes off Roundtree Way which I assume links with:
2. The Drainage Lagoon with 16 boreholes adjacent the UCP/Crown Cork Factory off Salhouse Road. Which has overflowed several times causing flooding
3. This lagoon in turn drains via 3 x 300mm pipes situated under Blue Boar Lane adjacent Wyevale Garden Centre. Also there is another 300mm pipe /drain under the the junction of Blue Boar Lane and Wroxham Road this delivers into the culvert between Wroxham Road and the Tesco Fuel Station
4. These three 300mm pipes deliver into the main drainage culvert on Home Farm that has a 1 in 600 drop running past Tesco Supermarket. When the height of this water increases it obviously starts to back-up and if it meets saturated ground it will back-up much faster which is known to be the case causing the lagoon in 2 above to spill over
5. This main culvert runs past Tesco en-route to the golf course. A water table one metre below ground level was ‘discovered when Tesco re-sited their car park, and where:
6. Frequent overspills have been experienced near Tesco Fuel Station in the vicinity of the bridge over the other drainage culvert that runs parallel with Wroxham Road. Described in 4. above
7. Even before this very large area was asphalted to extend the Tesco Car Park and construct the Fuel Station water drained into this area of Home Farm that left it waterlogged for several months of the year and even evidenced by an abandoned tractor on more than one occasion, besides flooding the sewer pipe
8. This area described in para 7 is now developed with houses that stand on significantly elevated footings to avoid flooding. And under the road system on this development large diameter concrete pipes are installed forming an underground reservoir in conjunction with a large collection chamber on the Blue Boar Lane side of the bridge. This water collection system operates a controlled release into the culvert. This has been overwhelmed in the past
9. This culvert drains into the lagoon created at the junction of Wroxham Road and Marriott Way. This makes three lagoons at this juncture, with the two at the Park & Ride with boreholes that drain into a culvert on that western side of Wroxham Road en-route to the Springs at Rackheath. The other lagoon drains into the series of lagoons off Marriott way
10. Similar drainage facilities on the Sprowston Golf Course will be well known to golfers.
11. There has been a significant increase in the number of drainage lagoons/SuDs systems created in the past few years and it is noticeable how rapidly these fill up as will be observed by drivers along Mallards way.
12. And drainage carries on en-route to Rackheath Industrial Estate that has experienced flooding (as has Rackheath Hall in the past).
13. What is not fully known is the presence and extent of groundwater. It is there under the Sprowston Park & Ride and has even been evident after a drought. Groundwater was not only not plotted or monitored by the Environment Agency, but they never even kept files on what was reported to them about groundwater. Indeed, they did not even monitor flooding unless it occurred near rivers or the sea.
The drainage system or series of systems described above, constitutes but one ‘drainage path’ so to speak, within Sprowston and where flooding has been reported in recent years. To what extent these incidents can be linked to the drainage path described above is a matter of conjecture. For certain, part of this flow of water is linked and most likely this linkage is continuous This can mean that water trying to drain can be impeded and back up, this is not just a possibility but a likelihood, irrespective of the distance involved.
The attenuation of water upstream is a classic means of preventing flooding, but the attenuation of water downstream can do the opposite.
The biggest threat to flooding as we know is saturated ground and this entire area is low lying in a flood plain where groundwater will present a barrier to drainage; while simultaneously surface water run -off, accelerated by ever more hard surfacing, with less land for water to percolate - is a fair description of Sprowston
There are now considerably more drainage lagoons/ SuDs systems between us and the Broads and the sea generally but this does not constitute a safeguard for water backing up, and surface run-off will back up when it meets saturated ground. And it needs to be borne in mind that the Wensum is tidal in Norwich which is an indicator in itself.
Also, water from Old Catton and Spixworth where developments are also planned increase the vulnerability for flooding to existing homes which makes the careful mapping of surface and groundwater behaviour in Sprowston all the more critical.
That the wider area can be designated arid from an agricultural point of view does not detract from the propensity of flooding, on the contrary these environmental conditions are well known bed-fellows.
The Greater Norwich Strategic Flood Risk Assessment is the right approach that we all need to contribute to, but I am dismayed that so little has been achieved in getting to grips with the actual details of drainage within Sprowston and which iI expected to now see mapped, for example on Index Grid GN 35 map having dedicated a meeting in August 2017 discussing this at some length.
What cannot be ignored is the flawed approach to approving Planning Applications.
The Greater Norwich Strategic Flood Risk Assessment acknowledged that previous FRA’s and SFRA’s were flawed and this were critical to planning applications. The GNLP SFRA lists only 5 incidents of flooding in the Sprowston Area but this cannot be a true representation of the situation and facts such as those described above which were well reported but were not analysed to ascertain their potential effect.
Arbitrary but erroneous assessments of ‘once in a hundred-year event’ of risk of flooding occurring have been wrongly stated: For example, the Sprowston P&R site and the Home Farm Development were negligently given such assessments when evidence to the contrary was presented and scrutiny of FRA’s denied despite protest.
This SFRA is assembled by Norfolk County Council as the Lead Local Flood Authority (LLFA), and it is drawn from information from District Councils and the City Council; but Broadland DC Planners stated categorically that they ‘know next to nothing about flood risk’. This may explain why there is an absence of the information about flood risk in Sprowston described above?
The situation was always complex as the river system shows, however, it is now considerably more complicated as a result of very large developments being approved what is disappointing about the JBA Consulting Report for the Greater Norwich Area Strategic Flood Risk Assessment Final Report: Level 1 November 2017 – viz
https://gnlp.oc2.uk/docfiles/46/2017s5962_greater_norwich_area_sfra_final_v2.0.pdf
is that instead of providing actual and progressive analyses of potential flood risk, it largely restates what we called for years ago. Even Planning Policy Statement 25 Development & Flood Risk Dec 2006 served the purpose in stating what should be done before planning applications were approved. This was best done by listening to local anecdotal evidence and scrutinising Developer’s FRA’s and SFRA’s but for reasons yet to be explained this is precisely what was not done.
Statements in this Final report Nov 2017.
Such as, quote: “ ---how interacting sources of water can have a profound effect on the extent of flood risk.” end quote: These were the very grounds of our concerns, especially where there are contiguous developments. Isn’t this precisely what we stressed years ago when the preferred solution was to export water or change the dynamics of drainage.
Major flooding in the Norwich area is a fact of history, and the primary factor in predicting where flooding will occur in the future is where it has occurred in the past. However, minor areas of flooding become much more important where developments are planned and it is imperative to examine these in relation to FRA’s. That only 5 instances of flooding have been reported in the Sprowston area cannot be a true representation.
Site-specific Flood Risk Assessments
Page 11/152 of the above link states that quote: “Developers should, where required, undertake more detailed hydrological and hydraulic assessments of water courses to verify flood extent” end quote. This identifies the biggest single failure because local residents have ‘site-specific’ knowledge, therefore an important source of information and they are best placed to scrutinise FRA’s; but there has been a conspicuous failure here.
Surface water management and SuDS
Page 12/152 of the above link states quote: “Planners should be aware of the conditions and local requirements set by Norfolk County Council, the Lead Local Flood Authority (LLFA), for surface water management for major and minor developments and ensure development proposals and applications are compliant with LLFA’s policy” end quote
Yet the presiding Planning Officer for the Beyond Green Consortium Planning Application 20121516 that includes land owned by Norfolk County Council publicly stated in the Planning Committee Meetings in May 2013 when this application was approved that he ‘knew next to nothing about flood risk’ and did not believe anyone else in Planning did either and stressed this by stating that he did not even know what SuDS were. Despite this creating considerable dismay and complaint, he repeated this virtually verbatim at the Reconsideration Planning Committee Meeting on 11 March 2015. And this despite personal protest about not being allowed to see the Peter Brett Associates FRA before this meeting because I had previously seen a draft that was patently flawed.
Impact of additional development on flood risk. Page 48/152 - also shown as is page 24 of the JBA Consortium of Norfolk Authorities Strategic Flood Risk Assessments) states, quote
“When allocating land for development, consideration must be given to the potential cumulative impact of development on flood risk. The increase in impermeable surfaces and resulting increase in runoff increases the chances of surface water flooding if suitable mitigation measures, such as SuDS, are not put in place. Additionally, the increase in runoff may result in more flow entering watercourses, increasing the risk of fluvial flooding downstream” – end quote. This reinforces the need to have scrutinied the FRS’s and the then respective SFRA’s
Conclusions:
The exhortations in this JBA Consulting Report for this GNLP SFRA Final Reports November 2017 are exactly the same sentiments that turned into warnings years ago. Knowing the impact of development on flood risk, the obvious question is why has Sprowston with its massive planned and approved developments not received priority treatment in mapping and understanding the factors that have dramatically increased the propensity for flood risk?
R Craggs 17 Feb 2020
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20834
Received: 13/03/2020
Respondent: Mr Jim Elliott
paras 299 and 300
Being near to the countryside in Hellesdon generally means going there by car, that is not environmentally friendly. We need open spaces accessible by foot or disability chair or by mums and toddlers with pushchairs. Hellesdon is already planned to have 1330 more houses on the Golf Course site. We need light industries not heavily polluting ones like at the airport.
paras 299 and 300
Being near to the countryside in Hellesdon generally means going there by car, that is not environmentally friendly. We need open spaces accessible by foot or disability chair or by mums and toddlers with pushchairs. Hellesdon is already planned to have 1330 more houses on the Golf Course site. We need light industries not heavily polluting ones like at the airport.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20991
Received: 14/03/2020
Respondent: Honingham Parish Council
Honingham Parish Council object to Honingham being grouped together with Easton and as such being classified as part of the Urban Fringe. Honingham is a small rural parish with extremely limited services and there should remain a clear distinction between it and surrounding villages
Honingham Parish Council object to Honingham being grouped together with Easton and as such being classified as part of the Urban Fringe. Honingham is a small rural parish with extremely limited services and there should remain a clear distinction between it and surrounding villages. There is no shop, school, doctors or regular bus service in the village. It is not sustainable to consider the village capable of supporting the proposed increase in houses, alongside this the potential for further future development which this classification as Urban Fringe would lead to. Honingham should be considered separately from Easton, having only been grouped with Easton due to school catchments. Many of the school aged children in the village do not attend school at Easton, and travel to other destinations, therefore this grouping is not reflective of the real situation. This grouping also does not take into account the other locations residents have to travel to to utilise services such as shops or doctors which covers a far wider area, thus demonstrating further the unsustainable nature of development larger than 2-3 homes in the village.
By grouping Honingham with Easton this provides the opportunity to further build upon the countryside in the area, destroying the green space west of Norwich and the clear distinction between urban and rural.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21048
Received: 15/03/2020
Respondent: Mr Richard KIRKHAM
I strongly object to Honingham being classified as urban fringe with Easton. Honingham is a rural village in open countryside which should be retained. Indeed the classification based on school catchments is itself not relevant when most school children attend schools elsewhere. Development of Honingham would require car journeys for schools, jobs and shops which is unacceptable in environmental sustainability terms. Honingham has no infrastructure to support development - not even a functioning bus stop. It is unacceptable to allow the Norfolk countryside to be invaded by unnecessary urban sprawl, especially in what is a flood prone area.
I strongly object to Honingham being classified as urban fringe with Easton. Honingham is a rural village in open countryside which should be retained. Indeed the classification based on school catchments is itself not relevant when most school children attend schools elsewhere. Development of Honingham would require car journeys for schools, jobs and shops which is unacceptable in environmental sustainability terms. Honingham has no infrastructure to support development - not even a functioning bus stop. It is unacceptable to allow the Norfolk countryside to be invaded by unnecessary urban sprawl, especially in what is a flood prone area.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21154
Received: 15/03/2020
Respondent: Yare Valley Society
The Yare Valley Society strongly supports the commitment in Policy 7.1 to enhancements to the green infrastructure which will include links to and within the Wensum, Yare, Tud and Tas Valleys, Marriott’s Way and beyond. The strengthening our green infrastructure network is key to meeting the challenges of declining biodiversity, combating climate change, and promoting the mental well-being of our communities.
The Yare Valley Society strongly supports the commitment in Policy 7.1 to enhancements to the green infrastructure which will include links to and within the Wensum, Yare, Tud and Tas Valleys, Marriott’s Way and beyond. The strengthening our green infrastructure network is key to meeting the challenges of declining biodiversity, combating climate change, and promoting the mental well-being of our communities.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21158
Received: 15/03/2020
Respondent: Mr Neil Saunders
GNLP0337 Land between Fir Covert Road and Reepham Road
Increase in the current tree line to allow a path similar to the Greenway Path to be included to allow dog walkers and people to use the current permissive paths
Maintain & increase depth of tree line to maintain wildlife corridors
No link road between the two plots due to risk to current users & wildlife of Marriott Way.
A link road could become a rat run o get to the high school, garden centre and the proposed new supermarket near the garden centre
GNLP0337 Land between Fir Covert Road and Reepham Road
I’m not surprised this land is allocated for housing. I have expected this to happen for the last 15 years.
The allocated land is shown as two separate parcel with no linkage between the two and I hope it stays that way.
The position to the roundabout on the Reepham Road needs to be carefully considered so there is no tail back to the Broadland Northway nor towards Drewray Drive.
Both parcels of land currently have permissive paths around them that dog walkers and people use to exercise. I would like to see an increase in the current tree line to allow a path similar to the Greenway Path to be included to allow dog walkers and people to use it.
There is a line of trees across the field nearest to the Reepham Road. This is used by wildlife as a corridor to connect to the hedges on Breck Farm Lane and the embarkments of the Broadland Northway. I regularly see bats and birds flying along the tree line and foxes and deer in the area. I would like to see this tree-line remain and another row to trees planted to maintain this corridor and provide more protection from the new houses.
When Thorpe Marriott was being built there was discussion of a school and doctors. Neither were built.
At the exhibition for the plan in Taverham there was a proposed layout of the site. I noticed there was a link road between the two plots. I would like this link to be removed on the following ground.
The link road would cross Marriotts Way. There is a crossing on Pendlesham Rise and there has been a number of near misses caused by driver ignoring the Give Way signs.
Marriott Way is used regularly by families and individuals for exercise, runners, walkers cyclists and horse riders. The provision of a cross will increase the risk of injury to these users.
The road could become a rat run as people use the road to get to the high school, garden centre and the proposed new supermarket near the garden centre or to avoid the Broadland Northway due to the accident rate and increased traffic when the Wensum link is built.
The provision of a link road would disrupt the wildlife corridor of Marriotts Way and increase the amount of wildlife deaths due to the traffic as the wildlife will not adapt quickly.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21191
Received: 16/03/2020
Respondent: Hopkins Homes, Persimmon Homes and Taylor Wimpey
Agent: Bidwells
We strongly support the proposed allocation of an additional 1200 dwellings (minimum) at White House Farm, Sprowston. The site has previously been demonstrated, through earlier Representations and a Delivery Statement, to be suitable, available and viable for up to 1350 dwellings, and the Consortium have an excellent track-record of delivery in the immediate area. The site is highly sustainable and a logical location for further growth, being well-related to services and employment opportunities. This allocation will provide continuity in delivery for the three housebuilders, and assist in providing an appropriate buffer to safeguard against any potential under-delivery of other sites.
We strongly support the proposed allocation of an additional 1200 dwellings (minimum) at White House Farm, Sprowston. The site has previously been demonstrated, through earlier Representations and a Delivery Statement, to be suitable, available and viable for up to 1350 dwellings, and the Consortium have an excellent track-record of delivery in the immediate area. The site is highly sustainable and a logical location for further growth, being well-related to services and employment opportunities. This allocation will provide continuity in delivery for the three housebuilders, and assist in providing an appropriate buffer to safeguard against any potential under-delivery of other sites.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21215
Received: 16/03/2020
Respondent: Kier Living Eastern Ltd
Agent: Bidwells
The Growth Triangle continues to be a key focus of housing growth, and the retention of the Growth Triangle Area Action Plan and the allocations contained therein is strongly supported. The area is highly sustainable, and will deliver a significant proportion of new economic growth over the Plan period. Sites such as GT13: Norwich Rugby Club, have already been shown, through their allocation in the Area Action Plan to be sustainable and suitable locations for housing growth, and this remains the case.
The Growth Triangle continues to be a key focus of housing growth, and the retention of the Growth Triangle Area Action Plan and the allocations contained therein is strongly supported. The area is highly sustainable, and will deliver a significant proportion of new economic growth over the Plan period. Sites such as GT13: Norwich Rugby Club, have already been shown, through their allocation in the Area Action Plan to be sustainable and suitable locations for housing growth, and this remains the case.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21333
Received: 16/03/2020
Respondent: Lanpro Services
Agent: Stephen Flynn
In the absence of any evidence regarding delivery to support existing commitments, Lanpro are concerned about the reliance in the draft plan on the delivery of 13,430 homes in the Growth Triangle to 2038. Delivery of homes on key parts of the Growth Triangle has been very slow to progress since planning permission was granted.
In the absence of any evidence regarding delivery to support existing commitments, Lanpro are concerned about the reliance in the draft plan on the delivery of 13,430 homes in the Growth Triangle to 2038. Delivery of homes on key parts of the Growth Triangle has been very slow to progress since planning permission was granted.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21413
Received: 16/03/2020
Respondent: Glavenhill Ltd
Agent: Stephen Flynn
In the absence of any evidence regarding delivery to support existing commitments, Glavenhill Ltd are concerned about the reliance in the draft plan on the delivery of 13,430 homes in the Growth Triangle to 2038. Delivery of homes on key parts of the Growth Triangle has been very slow to progress since planning permission was granted.
In the absence of any evidence regarding delivery to support existing commitments, Glavenhill Ltd are concerned about the reliance in the draft plan on the delivery of 13,430 homes in the Growth Triangle to 2038. Delivery of homes on key parts of the Growth Triangle has been very slow to progress since planning permission was granted.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21704
Received: 16/03/2020
Respondent: Brown & Co
We wish to submit an additional site for consideration to deliver circa. 30 dwellings. The site is well related to the main built form of Costessey and would provide the opportunity to deliver a sensitive development together with open space and an extension to the adjacent County Wildlife Site.
We wish to submit an additional site for consideration to deliver circa. 30 dwellings. The site is well related to the main built form of Costessey and would provide the opportunity to deliver a sensitive development together with open space and an extension to the adjacent County Wildlife Site.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21769
Received: 16/03/2020
Respondent: Brown & Co
We would raise concern over the ability to, and sustainability of, continuing to ‘bolt-on’ significant housing development to existing settlements. Such continuing urban sprawl is not considered to represent truly sustainable development, can often result in the creation of non-walkable neighbourhoods separated from services and facilities, places increased pressure on local infrastructure, and often comprise identikit housing which fails to adequately respect local character and create community cohesion. In recent years, development within the urban fringe has failed to deliver attractive development with its own character, or meaningful open space to provide the ‘green lungs’ of the city.
We would raise concern over the ability to, and sustainability of, continuing to ‘bolt-on’ significant housing development to existing settlements. Such continuing urban sprawl is not considered to represent truly sustainable development, can often result in the creation of non-walkable neighbourhoods separated from services and facilities, places increased pressure on local infrastructure, and often comprise identikit housing which fails to adequately respect local character and create community cohesion. In recent years, development within the urban fringe has failed to deliver attractive development with its own character, or meaningful open space to provide the ‘green lungs’ of the city.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21799
Received: 16/03/2020
Respondent: Quantum Land
Please see attached for full submission
Policy 7.1 – The Norwich Urban Area including the fringe parishes – we object to this policy on the grounds that there are no new allocations, including those proposed at GNLP2170 and GNLP2171, within the Thorpe St Andrew area. We will deal with the Site Allocations further (in the attached), and this objection should therefore be read in the context of the objections and comments (in the attached);
Please find attached representations, submitted on behalf of our Client – Berliet Limited.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21808
Received: 15/03/2020
Respondent: Mr R Craggs
This submission follows sequentially from my submission for GNLP Reg 18 Consultation 22 March 2018, which in turn followed my submission to NCC Local Flood Risk Management Strategy 23 May 2015. For well over a decade my focus has been on flood risk to existing homes from the extensive developments planned and taking place in Sprowston.
It is crucial that residents be provided with the information they seek in order to engage in a meaningful way in important consultations such as this. Interactive flood maps are an excellent innovation but these have not been updated for the Sprowston area for some years now. The sparseness of flood risk information available for this area conceals a potential problem, and yet key information has been communicated to the relevant authorities, but there is no indication of this on maps or in the narrative in your Consultation documentation for Sprowston.
This information provided previously was made available because it was acknowledged how little the Environment Agency (EA) knew about the presence of surface water and groundwater in this area, given that the EA was only created in 1995 and when their remit only covered flood risk in the vicinity of rivers and large bodies of water; and groundwater was not even considered until relatively recently, despite being reported to them years previously. You do not need to be near a river or a large body of water if large areas are to be covered by hard surface that reduces the amount of land area available for percolation, especially when there is a lot of groundwater present.
The Index Map GN35 does not show any added information over the last 2 years, not even the Marriott’s Way Link Road between Wroxham Road A1151 and Salhouse Road that has seen considerable in-filling of houses and SuDs lagoons. Even the NDR is not shown. It is appreciated that updating such maps, even though they are insertable will not be a cheap exercise, but a progressive narrative keeping roughly in pace with development surely is essential and this has to focus on hot spots where considerable development is under way, it would be reassuring to know if the well-designed SuDs system adjacent the NDR at the junction of the A1151 is performing well. However, that the situation further ‘upstream’ in Sprowston has been underestimated.
What is very disturbing is not being able to find out what is going on opposite the Wyevale Garden Centre on Blue Boar Lane which is part of the 20080367 Planning Application for the Consortium of developers Persimmon Home, Hopkins Homes and Taylor Wimpey and where the Millard Consulting FRA and SFRA proved so controversial because it was considered flawed. (this was viewed in the context that Millard Consulting also drew up the SFRA for the area) The FRA for Sprowston Park & Ride was flawed as was the FRA done for Home Farm where assessments of 1 in 100 - year risk of flooding were absurdly wrong.
The outfall of drainage passing under Blue Boar Lane at this point is critical and it is worrying that the various attempts to find out what is going on, to establish what design and construction work is taking place to ensure effective drainage is not getting any response. Why is this when such reluctance to share crucial information just fuels suspicion?
In relation to this Blue Boar Lane Development, for which the agents Bidwells produced the Sustainability Appraisal Report in 2006, it refers to Planning Policy Guidance 25 Development & Flood Risk but which is now reinforced with much more specific practical guidance as this GNLP 2020 Consultation Document itself describes. It is to be hoped that this improved guidance has been complied with – can we be assured of this?
This is because the old existing drainage system in Sprowston was never fully understood, and of course the subsequent impact of contiguous developments and the relationship and effectiveness of drainage from these adjacent developments is crucial. And especially considering that the FRA’s and SFRA for this 20080367 evaded the scrutiny Sprowston residents since it was done under Reserved Matters, and this is a worry area regarding propensity to the flooding of existing homes.
It is therefore very timely for a detailed feedback on the effectiveness of measures taken to ensure effective drainage and especially now when there is the added justifiable concerns about climate change that this 2020 Consultation gives more credence to.
Please see attached for full submission
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21878
Received: 12/03/2020
Respondent: Drayton Parish Council
Drayton Parish Council agree with the GNLP findings that there are no further sites considered suitable or a reasonable alternative for development in the parish of Drayton for the reasons given.
Drayton Parish Council agree with the GNLP findings that there are no further sites considered suitable or a reasonable alternative for development in the parish of Drayton for the reasons given.
Taverham GNLP 0337.
Drayton Parish Council does not object to the proposal but wishes to raise concerns on the impact on Drayton. There is no spare capacity in the schools or the doctors surgery in Drayton. Whilst accepting a new school and surgery will be provided as part of any planning approval these facilities will not be provided until the site is substantially developed. The concern is on the detrimental impact on Drayton until these facilities are provided. The Parish Council would like to ensure more robust provision is included within the development so that these facilities are available before 25% of the development is built. The Parish Council would also like to ensure that no vehicular access is granted into the new development area from Felsham Way.
Drayton Parish Council has concerns with the increase in traffic numbers on Reepham Road towards Drayton and Hellesdon from the proposed vehicular access point from the new development. Drayton Parish Council would seek for a left turn only exist to encourage the use of Broadland Northway, the Norwich Western Link and the soon to be delivered dualled A47. Traffic that needed to travel directly into Drayton or Hellesdon wil still be able to do so via the Broadland Northway / Reepham Road roundabout.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22043
Received: 13/03/2020
Respondent: East Suffolk Council
We support the approach in The Norwich Urban Area 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: 22189
Received: 16/03/2020
Respondent: Environment Agency (Eastern Region)
Section 5 of this policy specifically refers to ‘the Natural and Build Environment’. This policy should be strengthened and refer to the environmental policies within the River Wensum Strategy. It should also expand the section to broaden the scope for environmental improvements within the urban area, such as integration of SuDS with biodiversity features, providing swales with diverse flora, tree pits and green driveways for example.
This will help reduce runoff thereby protecting rivers from urban pollution as well as providing steppingstones connecting river habitats.
The River Wensum Restoration strategy (upstream from Hellesdon), where we are working to restore the whole of the River Wensum SSSI SAC, is relevant to development in the fringe parishes in that area e,g. Taverham, Drayton and Costessey.
Please see attached for full submission
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22261
Received: 16/03/2020
Respondent: Carter Jonas LLP
Number of people: 2
Land off Townhouse Road, Costessey
Policy 7.1 contains the development strategy for the Norwich Urban Area and the fringe parishes. We object to the strategy for Costessey, in respect of the decision to make no allocations in the village and the sites identified as reasonable alternatives. A number sites have been identified as a reasonable alternative housing allocation at Costessey, including a strategic extension for +1,200 dwellings at land off Bawburgh Lane and New Road (Ref. GNLP0581) and land north of New Road and east of A47 (Ref. GNLP2043). The land off Townhouse Road in Costessey (Ref. GNLP0284R) is promoted for residential development, but it is considered that this site has been incorrectly identified as an unreasonable site in the GNLP Site Assessment document.
It is very unlikely that the strategic extension sites in Costessey identified as reasonable alternative would be delivered quickly enough to address a housing land supply shortfall in Costessey in the short term. The lead-in times for these types of developments are typically more than 5 years, largely because they are complex and require significant levels of primary infrastructure to be provided e.g. roads and drainage in advance of housing. On this basis, it is considered that the strategic extension sites in Costessey are not reasonable because they would not meet the purpose of a contingency site i.e. to meet non-delivery elsewhere. In addition, as set out in the representations to the Site Allocations document, there are identified constraints and uncertainties to development at the strategic extension sites in Costessey (Ref. GNLP0581 and GNLP2043), including access arrangements and proximity to the Norwich Southern Bypass. It has not yet been confirmed that these strategic extension sites are available or suitable for development, and as such they should not be identified as reasonable alternatives. Furthermore, the other identified reasonable alternative site in Costessey, at Roundwell Works (Ref. GNLP0593) would lead to the loss of employment land and the access arrangements have not been confirmed, and as such it may also not be a reasonable alternative site.
As set out in the representations to the Site Allocations document for Costessey sites, the promoted development at land off Townhouse Road in Costessey (Ref. GNLP0284R) is smaller than the strategic extension site, it is controlled by a housebuilder, and is available for development, and as such it could meet the requirements for a contingency site to meet non-delivery elsewhere. A number of technical reports and studies have been prepared for the site which demonstrate that there are no constraints to development and significant impacts can be mitigated, and concept plans have been prepared to identify different development options for the site i.e. 100, 130 and 200 dwelling options. The technical evidence demonstrates that landscape impacts can be mitigated by retaining existing trees and hedges, providing new areas of woodland and landscaping, and creating new areas of open space. The site is not affected by flood risk, and a drainage strategy would be prepared for the promoted development to manage surface water drainage. An area of open space would be created at the site frontage along Townhouse Road. Therefore, it is considered that land off Townhouse Road in Costessey (Ref. GNLP0284R) should be allocated in emerging GNLP or identified as a reasonable alternative site to meet future needs.
On behalf of my client, Taylor Wimpey Strategic Land, please find attached representations relating to Land South of Townhouse Road, Costessey, and Green Lane West, Rackheath.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22291
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.
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.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22345
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.
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 Hethersett. Please find attached the response form, the representations and a Delivery Statement
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22380
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.
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.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22427
Received: 16/03/2020
Respondent: Norwich Green Party
We object to the proposal for a new urban extension at Taverham (1,400). A new strategic community in this location would be reliant on car use and therefore increase carbon emissions, air pollution and traffic pressures in the Wensum Valley area and increase different types of run-off including silt to the River Wensum SAC. Major development on land between the NDR and city edge would see further loss of countryside. As indicated, we believe that existing allocations should be developed before any new allocations.
The SA/SEA (Jan 2020) for Taverham and Ringland (B.47) confirms that the proposed Taverham and Ringland development cluster would have a major negative impact on Air Quality and Noise, Climate Change Mitigation and Adaptation, Education and Natural Resources and Waste. By way of mitigation, the SA/SEA recommends that focus on improving public transport, walking and cycling would be likely to help reduce carbon emissions emitted within Norwich.
However, the likelihood that high quality public transport can be provided from the outset of the development is unclear because the Transforming Cities bid has not been successful. In any case, the Fakenham Road and Reepham Road were not identified as among the six radial road corridors for upgrades to public transport infrastructure by the joint application. Therefore, unless alternative sources of funding can be obtained for developing a high quality public transport system for Norwich, a strategic development at Taverham is likely yo be car-dependent in much the same way that Thorpe Marriott has evolved.
Overall, we are concerned by the extent of car-based urban sprawl of Norwich as development has spread out into the open countryside, facilitated by road building. . Norwich is now strangled and its unique rural setting has been eroded by the Southern Bypass and NDR and a string of business parks, retail parks and other major developments clustering around land hungry junctions.
For full representation and additional information submitted, please refer to the attached documents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22436
Received: 16/03/2020
Respondent: Gladman Developments
7.1 Question 40: Further Urban Area 7.1.1 Gladman supports the recognised need for housing delivery to be achieved on the edge of the main urban area of Norwich, with surrounding parishes within South Norfolk and Broadland accommodating this growth.
7.1.2 Policy 7.1 outlines the suggested housing growth directed to the urban area with large numbers attributed to strategic urban extensions at Taverham and within the growth triangle. Gladman would argue that the location identified as a contingency site at Costessey would also provide a logical location for residential growth within the plan period and should also be allocated for development through the GNLP and is actively promoting the site on behalf of the landowners
7.1.3 Furthermore, when taking the uncertainty surrounding some of the other location within the plan, namely the Carrow Works and well as the significant reliance placed on growth at the Growth Triangle, it seems logical that this alternative should be included in the Norwich urban area to ensure that the defined housing needs of the plan area are met at the most sustainable locations, and maintain a housing land supply throughout the plan period, given its deliverable nature.
7
Please find attached the headline representations of Gladman made in response to the Reg 18 version of the Greater Norwich Local Plan.