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: 22459
Received: 16/03/2020
Respondent: Gladman Developments
2.3 Policy 7.1 The Norwich Urban Area including the fringe parishes
(Question 40)
2.3.1 Gladman welcomes the proposals made under Policy 7.1 for the Norwich Urban Area and the fringe
parishes to continue being the area’s major focus for jobs, homes and services development and
welcomes the further allocations proposed in the city in addition to the existing commitments.
2.3.2 The policy identifies the delivery of a total of 30,560 new homes over the plan period 2018-2038
within the Norwich Urban Area, of which 85% consists of already committed development.
2.3.3 Gladman notes the proposals to include the site GNLP0581, in addition to site GNLP2043, as a
contingency site with a capacity of 1,000 homes, with associated amenity land, woodland and green
area, to be brought forward if the delivery of the GNLP housing allocations does not meet the Local
Plan targets.
2.3.4 It is however considered that this additional 1,000 dwellings should be planned for now, in the form
of a further allocation in the Plan, rather than being identified as a contingency. Such an approach
would increase the flexibility of the Local Plan and heighten its durability against unpredicted
changes which might occur over the remaining years of the plan. The plan making process provides
a good opportunity for the infrastructure requirements of Costessey and any future development
to be understood with a solution planned for. Planning for this upfront would reduce any delay in
meeting housing needs, which may not be possible through the planning application process.
Please find attached the representations of Gladman made specifically in relation to our land interest in Costessey
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22475
Received: 16/03/2020
Respondent: Breckland District Council
For information, Breckland District Council also is concentrating growth in this area at Attleborough, Snetterton Heath, Thetford, Dereham and Swaffham.
For information, Breckland District Council has employment growth planned for Cambridge Norwich Corridor and at Dereham
See attachment for officer level response from Breckland Council
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22495
Received: 16/03/2020
Respondent: Highways England
The proposed sites within the Colney Strategic Employment Zone is likely to have a significant impact on the B1108/A47 Watton Road junction, and it is suggested early assessment on the junction and the A47 at this location is required to ensure that these sites are deliverable.
Thank you for inviting Highways England to comment on the Regulation 18 Draft Review of the Greater Norwich Local Plan (GNLP), which is prepared jointly by three local authorities - Broadland District Council, Norwich City Council and South Norfolk Council through the Greater Norwich Development Partnership (GNDP). This document expresses our views on the Draft Strategy and Site Allocations for future development as mentioned in this GNLP.
Highways England is responsible for the operation, maintenance and improvement of the Strategic Road Network (SRN) in England on behalf of the Secretary of the State. In the area within and surrounding Norfolk, this relates to the A11 and A47 trunk roads.
Consequently, our comments on the draft Local Plan which are set out below are limited to those aspects/strategies which may have impacts related to these two trunk roads.
See attached
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22496
Received: 16/03/2020
Respondent: Highways England
The existing A47 Longwater junction suffers significant congestion at peak times and the proposed sites in and around Costessey will likely to have a substantial impact on its performance. It is suggested early assessment on the junction and the A47 at this location is required to ensure that these sites are deliverable, together with its connections to the proposed Western bypass.
Thank you for inviting Highways England to comment on the Regulation 18 Draft Review of the Greater Norwich Local Plan (GNLP), which is prepared jointly by three local authorities - Broadland District Council, Norwich City Council and South Norfolk Council through the Greater Norwich Development Partnership (GNDP). This document expresses our views on the Draft Strategy and Site Allocations for future development as mentioned in this GNLP.
Highways England is responsible for the operation, maintenance and improvement of the Strategic Road Network (SRN) in England on behalf of the Secretary of the State. In the area within and surrounding Norfolk, this relates to the A11 and A47 trunk roads.
Consequently, our comments on the draft Local Plan which are set out below are limited to those aspects/strategies which may have impacts related to these two trunk roads.
See attached
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22498
Received: 16/03/2020
Respondent: Highways England
With regard to Easton and Honingham Highways England agrees with the statements that there could be significant constraint to the proposed development with the existing highway infrastructure and further assessment is required. We welcome the provision of a Road Bus Rapid Transit (BRT) to create sustainable transport opportunities.
Thank you for inviting Highways England to comment on the Regulation 18 Draft Review of the Greater Norwich Local Plan (GNLP), which is prepared jointly by three local authorities - Broadland District Council, Norwich City Council and South Norfolk Council through the Greater Norwich Development Partnership (GNDP). This document expresses our views on the Draft Strategy and Site Allocations for future development as mentioned in this GNLP.
Highways England is responsible for the operation, maintenance and improvement of the Strategic Road Network (SRN) in England on behalf of the Secretary of the State. In the area within and surrounding Norfolk, this relates to the A11 and A47 trunk roads.
Consequently, our comments on the draft Local Plan which are set out below are limited to those aspects/strategies which may have impacts related to these two trunk roads.
See attached
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22540
Received: 16/03/2020
Respondent: Historic England
The Northern City Centre
Historic England recognise that this area contains a number of key brownfield sites and understand the importance of regeneration in the area for the city as a whole.
The allocation proposes the redevelopment of Anglia Square at a density similar to that proposed in the planning application currently before the Secretary of State. We consider that any development of the scale envisaged would cause a high degree of harm to the character and appearance of the City Centre conservation area, as well as harm of varying degrees to many designated heritage assets, including some of the city’s most important.
Evidence prepared by Historic England for the Inquiry suggested that 600 dwellings, rather than 1200 would be a more appropriate scale. Historic England has also expressed fundamental concern regarding the proposed landmark building and in particular its height. The Norwich skyline is important to the character of the town as a whole and in particular the City Centre Conservation Area. For a number of years we have stated that development should not break the skyline in the City.
There are clearly differences of opinion in relation to this site in particular but a number of key principles can be drawn from this case and applied to other redevelopment sites in the City.
They are as follows:
Development should be of a scale and massing in keeping with the surrounding area;
Development should respect and reinterpret the historic grain, street layouts, burgage plots and morphology of the City;
Development should avoid breaking the skyline or competing with historic landmark buildings across the City;
Development should use materials in keeping with the historic fabric of the City.
It will be necessary to review the policy in the light of the Inspectors findings in relation to Anglia Square.
Suggested Change:
Include key principles for development within the Plan.
Review policy in light of Inspectors findings.
For full representation, please refer to attached documents
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22640
Received: 13/03/2020
Respondent: M Scott Properties Ltd
Number of people: 2
Agent: Bidwells
Strongly support.
As detailed in comments provided in respect of Question 13, the proposed Settlement Hierarchy and the identification of Norwich and the Norwich Fringe as the location to accommodate 69% of the housing growth during the period to 2038 is strongly supported.
Norwich and the Norwich Fringe is the catalyst for economic growth in the area and provides a range of amenities, services and infrastructure to support sustainable housing.
The fringe parishes will play a significant role in providing sustainable growth, given their proximity to employment opportunities, services and strategic infrastructure, such as Broadland Northway. In addition, by virtue of its location, the fringe parishes are in close proximity of the countryside providing ease of access to the leisure and recreation opportunities it provides.
The fringe parishes provide opportunities for strategic growth i.e. over 1,000 units. Developments of this scale are capable of providing a wide range of infrastructure improvements, such as schools, employment, health centres and green infrastructure, which will provide benefits to both existing and future residents.
This approach is entirely consistent with paragraph 72 of the NPPF, which advises that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided that are well located and designed and supported by the necessary infrastructure and facilities.”
The identification of Taverham as a location to accommodate a minimum of 1,400 dwellings by way of a strategic urban extension is fully supported.
Taverham provides an excellent location to provide a strategic urban extension of a minimum of 1,400 units. It represents a highly sustainable location with good access to Norwich, that has been significantly enhanced by the recent delivery of the Broadland Northway. The buffer created by the Broadland Northway presents an opportunity for a logical strategic urban extension to the settlement of Taverham at a size and scale that can, whilst being proportionate to the scale of the settlement, accommodate a significant quantum of the infrastructure and housing required in the Greater Norwich Area over the next two decades.
Taverham already benefits from a variety of amenities including a pub, a supermarket, takeaways, petrol filling station and a garden centre. In addition, the area is within close proximity of the amenities provided within Thorpe Marriott and Drayton. Nightingale and Ghost Hill Infant schools are located in close proximity of the site, as are Taverham Junior and High Schools. A private school (Langley Preparatory School at Taverham Hall) is located nearby. These will be sustained and enhanced by the increased population proposed.
The proposals to enhance the green infrastructure with the fringe parishes network through, amongst other things, improved links to Marriott’s Way is supported.
On behalf of M Scott Properties Ltd we are instructed to submit representations to the Greater Norwich Local Plan Regulation 18 (c) consultation. The representations are split into two, reflecting the two parts of the Greater Norwich Local Plan; the Strategy Document and the Sites Plan, in respect of GNLP0337.
The attached document provides a complete record of the representations made on behalf of M Scott Properties Ltd.
The various technical studies referred to in the Representation and the Delivery Statement can be accessed in the attachments also.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22978
Received: 16/03/2020
Respondent: Barratt David Wilson Homes
Agent: Pegasus Planning Group
Our client supports the delivery of new homes in the fringe parishes and believes that these are one of the most sustainable locations for new homes to be delivered in the Greater Norwich area. Therefore, it is crucial that the Councils maximise the use of sites in the fringe parishes that have already been identified to accommodate new homes. The use of higher densities on these sites, in accordance with the approach on sites already consented for development, will also maximise the use of new infrastructure that has already been, or is in the process of being delivered.
Our earlier comments in this document and the evidence submitted to the Sites Allocations element of the GNLP is of relevance here as it explains why we think more housing could be delivered at Cringleford. This should be reflected in the strategy for the fringe parishes.
For full representation, please refer to the attached documents.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23085
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).
For full representation, please refer to the attached documents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23176
Received: 16/03/2020
Respondent: Pigeon Investment Management Ltd
Agent: Pegasus Group
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.
8.12 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.
8.13 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.
8.14 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.
8.15 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.
8.16 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 Dereham Road, Reepham. Please find attached the response form, the representations and a Delivery Statement.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23182
Received: 14/03/2020
Respondent: Cornerstone Planning Ltd
Number of people: 2
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant of the current application of the site off Green Lane West, Rackheath (ref. 20171464).
Whilst acknowledging that the site in question does not as yet having planning permission,
Broadland Council has resolvd to do so (Planning Committee - 10 April 2019). We therefore suggest that - in the interests of completeness, and given that by the time of the next iteration of the Local Plan there will be an extant planning permission for 322 no. dwellings and associated development on the land - an appropriate note should be added to the Plan's supporting text (Notes).
Please let me know if you require any further information or clarification.
Full Representations makes comments on BRU2, TROW1, Question 27 and Rackheath as well as Aylsham. Check Summaries for submission on these other sites/location or question.
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.
Aylsham
Norfolk Homes Ltd supports the classification of Aylsham as a Main Town in its settlement hierarchy, the Sustainable Growth Strategy in relation thereto and the identification of the town as a sustainable community able to accommodate additional, significant housing (and related) growth.
In promoting the allocation of our site on Norwich Road, Aylsham, we also wish to highlight that Aylsham is a highly sustainable location capable of accommodating greater, planned growth. The town has all the requisite services, facilities and employment, together with good transport links, sufficient to support sustained housing and associated growth (as set out in the HELAA and related Local Plan evidence).
The merits of further growth in Aylsham are self-evident and indeed referenced in the supporting evidence, namely:
• Aylsham has a vibrant town centre which supports a sizable number of retail and service businesses;
• Access to most of the remainder of the Greater Norwich area and beyond has been improved with the opening of the NDR;
• Local employment opportunities are provided in the town centre and the Dunkirk Industrial Estate to the north-east of Aylsham;
• There exists a good range of services and facilities within the town, including primary and secondary education;
• There are two GP surgeries and a dental surgery in Aylsham, all of which are still accepting patients;
There are a number of recreational opportunities in or near the town including a recreation ground on Sir Williams Lane, a new football facility at Woodgate Farm, the Bure Valley Way, The Marriott's Way and facilities at Blickling Hall.
Indeed, the town has seen continuous and planned housing growth since the early 1990s; it is capable of continuing to accommodate sustainable growth through at least the new Plan period and thereby make an important contribution to the provision of new housing in
a Greater Norwich, above existing commitments and the 300 houses indicated in the draft Local Plan.
Norwich Road, Aylsham (GNLP0596)
We reiterate/clarify the proposed allocation of this site for circa 300 dwellings, access, land for community use (2-hectare primary school site), public open space and associated infrastructure.
We note that in the draft Greater Norwich Local Plan the Norwich Road site is identified as a "Reasonable Alternative", indicating that:
''This site is considered to be a reasonable alternative if additional growth is needed in the towns, subject to mitigation measures. For highways reasons, requirements would include a maximum of 100 dwellings with access from Norwich Road and a2-metre-wide footpath across the site frontage. 250 dwellings would require two points of access, but this would require further investigation as it would not be possible from either Copeman Road or Buxton Road. This site is therefore of secondary preference for allocation in the town."
It is noted that another site is identified as the proposed allocation
GNLP0311, 0595 and 2060: There are a number of similarly performing sites put forward in Aylsham but this combination of sites is favoured for allocation as it is preferred in highway terms as long as two points of access are provided. The site allocation includes a requirement/or a new primary school in Aylsham required to meet growth needs."
In subsequent discussion with officers we have been advised that - in reality - they feel that there is very little between the three sites in question (that identified as the 'Proposed Allocation' and the two sites identified as 'Reasonable Alternatives').
We believe that the summaries above - both the reason for identifying site ref. GNLP0311, 0595 and 2060 ahead of the Norwich Road (0596) site, and for not proposing the allocation of the latter - are based on incorrect information. Specifically:
• Contrary to the above statements, there is no highway constraint to the safe accessing of the Norwich Road site. We have subsequently been advised by Norfolk County Council Highways that the arrangement set out in the attached Indicative Masterplan would make the site's allocation/development acceptable in principle (see attached correspondence). The masterplan shows two points of access via Norwich Road, with a potential emergency access and/or cycle/footpath link only via Buxton Road [Please note that Norfolk Homes Ltd. also has control over the adjacent former motel site (for a primary/secondary access point), and the entirety of the Norwich Road frontage from the just north of the roundabout to the northern extent of the motel site (to accommodate the requisite footpath and other off-site highway improvement works)].
• Contrary to the published HELAA Comparison Table, the site should be identified as
green not amber against the issues of Access to Service, Uilities Capacity/Utilities Infrastructure (see below) and Compatability with Neighbouring Uses.
In particular it should be noted that in meeting and correspondence with Anglian Water it advised us (specifically with reference to the Norwich Road site) that ''Anglian Water can confinn that there is currently capaci.ty at Aylsham Water Recycling Centre to accommodate the 300 dwellings proposed. We closely monitor housing and economic growth in our region to align investment and the operation of our infrastructure to additional demand for used water." In effect, that Anglian Water is able to meet - through infrastructure investment- any additional housing and related demand, and environmental impacts arising therefrom. Water management ought not therefore to be viewed as a constraint to additional housing allocations in Aylsham, and this is acknowledged in the emerging Plan.
With regard to Compatibility with Neighbouring Uses, please note the accompanying Air Quality Assessment and Noise Assessment. The former concludes that air quality impacts are considered to be not significant, in accordance with the IAQM guidance, and that air quality issues are not a constraint to approving development of the site as proposed. The latter - which is of necessity high level, pending assessment of a detailed layout - concludes that some acoustic mitigation would be needed closest to the A140 but that noise levels at the site are generally low enough that non-acoustic glazing and trickle vents can be used across the majority of the site.
The attached plans illustrate in more detail how access is to be achieved, together with related off-site highway improvement works. The plans have been seen by Norfolk County Council and confirmed as acceptable in principle (see attached correspondence).
Furthermore, we are advised by NCC
Education/Children's services that there is a requirement for a 2ha site to allow the building of a new 2FE/ 420 place school. We confirm that we are willing and able to make provision for such on the proposed (Norwich Road, 0596) site, as indicated on the attached Indicative Masterplan, and at any stage of the development required by the County Council.
Our view - therefore - is that the Greater Norwich Development Partnership has made an incorrect assessment of the sustainability/merits/deliverability of the sites considered, in particular those of the Norwich Road site (GNLP0596).
Norfolk Homes has undertaken considerable work with a view to being able to make an early planning application and ensure early delivery of the requisite primary school and housing. To that end I attach copies of the work undertaken to date and which demonstrate that there are no constraints to said development:
• Indicative Masterplan;
• Access Plans (including off-site highway works);
• Tree Survey;
• Air Quality Assessment;
• Noise Assessment;
• Landscape and Visual Impact Assessment;
• Ecology (Habitat Survey completed; species surveys scheduled for March-May 2020 )
Furthermore, Norfolk Homes Ltd. is content to explore - as part of the development proposals for the site - the Town Council's Cittaslow objectives (concerning park and ride) as set out in its 'Aylsham - Shaping the Future' document.
It is clear from the above and attached that the Norwich Road site (GNLP0596) is the best and most sustainable site to meet the growth/housing needs of Aylsham. The evidence hereby submitted demonstrates that the site should therefore be a proposed new allocation rather than a reasonable alternative. It is important to note that this is a view shared by Aylsham Town Council (see below).
In conclusion, Norfolk Hornes has a legal control over all the land in question, and has
undertaken significant work to date to demonstrate the suitability, deliverability and sustainability of the site's development as proposed. The site is available and deliverable in the short term - via a detailed planning application - to assist in meeting the Greater Norwich Local Plan's objective of delivering a sufficient supply of homes in the right locations.
Community Support
Please also note that Aylsham Town Council resolved to respond to the GNLP Local Plan consultation as follows (Minutes of Aylsham Town Council meeting of 19 February 2020):
'The town accepted that one site would need to be accommodated but this must include a primary school and this must be commissioned in the first phase of the project. The affordable housing element must be strictly adhered to. The Town Council would like a transport hub included in the development. The Town Council rejected Burgh Road as the most favourable site and instead would only agree to Norwich Road."
This representation demonstrates not only that the site is available, deliverable and sustainable, but has the support of the local community, a significant consideraion we suggest in determining the most appropriate sites for allocation.
BRU2
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant/developer of the site at Yarmouth Road, Brundall (20180935 and 20190604), identified - in part - under Policy BRU2 of the Draft Local Plan.
The Draft Plan proposes no new allocations in Brundall but to carry forward - from the current Local Plan - sites BRU and BRU3. The former corresponds with Norfolk Homes' outline planning permission (ref. 20180935) and current Reserved Matters submission (ref. 20190604), together with the Parish Council's adjacent formal recreation site south of Yarmouth Road (ref. 20191377). The draft Plan notes:
'The site was allocated in the previous local plan and it is intended to carry this allocation forward, recognising the public benefit in providing informal open space. However, it is likely that the allocation of BRU2 will need further revision given the recent planning permission on the site for 155 dwellings which includes alternative provision for recreation (reference: 20161483). The site was also promoted through the local plan process as GNLP0325. The recreational allocation under BRU2 remains appropriate pending the residential development taking place."
The plan appears to attempt to keep options open - pending what happens on site - but it is our view that the identification/proposed allocation of the entire site for recreational open space - albeit at draft Plan stage - is potentially confusing and contradictory. A large portion of the site has planning permission for 15 5 dwellings ( with Reserved Matters approval pending ) and development will have commenced - anticipated late 2020 - well before the Plan is adopted, thus rendering it immediately out-of-date. We see no difficulty in allocating the formal recreation part of the site with a corresponding permission, but not the permitted housing part.
The Councils might also consider extending the settlement boundary to include that part of the site with permission for housing, again given that its implementation/commencement will pre-date the adoption of the Plan.
TROW1
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the developer of the site at Phase 1, White Horse Lane, Trowse (ref. 2016/0803 and 2016/0805) and the applicant/developer of Phase 2, White Horse Lane, Trowse (ref. 2019/2318), cumulatively identified under Policy TROW1 of the Draft Local Plan.
TROW1 is proposed to be carried forward as a housing allocation but it is noticeable that the wording of TROW1 (between adopted Local Plan and as now proposed) is different in the following way:
The Introduction to the policy is briefer now, but the main change is "approximately 173 dwellings"in lieu of "150 to 160 dwellings".
In the Notes to the policy, it states that the allocated site benefits from planning permission for 173 dwellings. It references Norfolk Homes' Phase 1 permission for 98 dwellings and an undetermined Reserved Matters for 75 dwellings. The latter has been superseded by Norfolk Homes' current full application for 83 dwellings, which is not referenced in the text
Given that Norfolk Homes' current application would increase the cumulative development of the site to 181 dwellings, we would request that:
• The current planning application is acknowledged in supporting text (Notes);
• The policy title refers to "at least 173 dwellings"
Question 27
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.
It is noted that at paragraph 240 of the Draft Local Plan, it states:
"240. The policy sets a general requirement for on-site affordable housing provision of 33% on sites that show better viability based on local evidence, with a lower requirement in Norwich City Centre. This is based on:
o The Strategic Housing Market Assessment 2017 which identifies a need for 11,030 affordable homes in Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point;
o Under national policy, small sites under 10 dwellings are not required to provide affordable housing. Larger sites will therefore have to ensure that overall affordable housing need is delivered;
o The most recent viability study.findings which conclude that centrally located brownfield sites which have higher development costs which affect viability are generally able to provide 28% affordable housing;
o Some specific sites have very high costs associated with development. These are allocated with lower affordable housing requirements."
Within 'Policy 5 -Homes' is included:
"Affordable Housing"
Major residential development proposals and purpose-built student accommodation will provide:
• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a different percentage of affordable housing;
• affordable housing on-site except where exceptional circumstances justify off-site provision;
• a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking account of the most up-to-date local evidence of housing need. This will include 10% of the affordable homes being available for affordable home ownership where this meets local needs;
• affordable housing of at least equivalent quality to the market homes on-site.
The sub-division of a site to avoid affordable housing provision will not be permitted."
This begs the question: if the most up-to-date SHMA identifies a need for 28% affordable housing, why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication -although somewhat disingenuous -is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived 'shortfall' through major housing schemes (10 or more units).
We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the Joint Core Strategy is carried forward into the new Local Plan: 'The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area." (Draft policy 5 only says that "a mix of affordable housing sizes, types, and tenures ... " should reflect the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period - notably since the publication of the 2017 SHMA -and has been reflected in Councils' approaches to decision making thereafter. There now appears to be a marked change in the Councils' approach to an evidentially-based and up-to date proportion of affordable housing, without justification.
The GNDP may feel it has a case to make -other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments -but we cannot find any proper rationalisation in the Draft Local Plan, nor in its supporting evidence, including the Interim Viability Study (November 2019). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period.
Rackheath
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant of the current application of the site off Green Lane West, Rackheath (ref. 20171464).
Whilst acknowledging that the site in question does not as yet having planning permission,
Broadland Council has resolvd to do so (Planning Committee - 10 April 2019). We therefore suggest that - in the interests of completeness, and given that by the time of the next iteration of the Local Plan there will be an extant planning permission for 322 no. dwellings and associated development on the land - an appropriate note should be added to the Plan's supporting text (Notes).
Please let me know if you require any further information or clarification.