Question 41. Do you support or object or wish to comment on the approach for the main towns overall? Please identify particular issues.

Comment

Representation ID: 20104

Received: 25/02/2020

Respondent: RJ Baker & Sons

Agent: Cheffins

See main text

(Summary - entered by GNLP team:
- Broad support for the overall approach to housing in main towns
- Agree that Wymondham should accommodate the greatest proportion of housing across the 5 main towns
- Wymondham is capable of further growth
- Support the employment allocation in Wymondham - maybe a long term case for additional employment land)

Comment

Representation ID: 20118

Received: 26/02/2020

Respondent: William Harrison

Agent: Smallfish

We strongly urge the GNDP to reconsider allocating small sites of less than 0.5ha and fewer than 12 dwellings, in accordance with Paragraph 68 of the NPPF.

We also ask that the existing recreation/amenity land protection status on Site GNLP 3026 is removed. The site previously formed part of the school playing fields until sold in 2018 by NCC. It is now in private ownership and has no public access. It remains adjacent to a large amount of recreation space at the school. It can provide much-needed housing in an extremely sustainable location.

Comment

Representation ID: 20853

Received: 13/03/2020

Respondent: Welbeck Strategic Land III LLP

Agent: Bidwells

The Main Towns, such as Wymondham, provide a range of services and amenities and are, therefore, a sustainable and suitable location for the majority of growth. Development in these locations is key to ensuring the sustainability of the rural economy. More specifically, Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth in accordance with the identified settlement hierarchy.

Object

Representation ID: 21335

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

Despite the plan’s emphasis in its vision (page 31) and delivery statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes are allocated within the Tech Corridor itself. Growth in other main towns should not take precedent over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Cambridge Norwich Tech corridor.

Object

Representation ID: 21414

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Despite the plan's emphasis in its vision (page 31) and delivery statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes are allocated within the Tech Corridor itself. Growth in other main towns should not take precedent over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Cambridge Norwich Tech corridor.

Comment

Representation ID: 21771

Received: 16/03/2020

Respondent: Brown & Co

As with the approach to the urban fringe parishes, we would raise concern regarding the deliverability, and sustainability of additional ‘bolt-on’ developments in these locations. 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 fail to adequately respect local character and create community cohesion.

Support

Representation ID: 22044

Received: 13/03/2020

Respondent: East Suffolk Council

We support the approach in The Main Towns policy.

Support

Representation ID: 22135

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Policy 7.2 – The Main Towns outlines that the settlements in the Plan Area of Aylsham, Diss (with part of Roydon), Harleston, Long Stratton and Wymondham will provide for substantial development of around 6,300 homes. We support this approach, although given the dispersed nature of the settlements consider that a more ambitious level of growth should be deliverable and would provide greater support to enable these rural communities to prosper and thrive. Such an approach would provide the plan with a greater degree of flexibility in the event the larger allocations in the Norwich fringe deliver more slowly than anticipated.

The Main Towns are considered to be sustainable locations that are suitable to accommodate additional growth to contribute to the overall Plan area’s housing need. This approach is supported by paragraph 72 of the NPPF which identifies that the supply of a large number of new homes can often best be achieved through planning for larger scale development, including extensions to existing villages and towns, where they are well located and supported by the necessary infrastructure and facilities. The draft plan identifies sites for approximately 14% of new housing in the main towns. It acknowledges that much of the proposed development has planning permission and there are significant commitments in the main towns, especially in Long Stratton and Wymondham. More capacity for new allocations is available in Aylsham, Diss (with part of Roydon), Harleston and with Wymondham. The 14% proportion of new housing could be increased as a large number of reasonable alternative sites have been proposed in the main towns.

Our clients would strongly encourage the Greater Norwich Local Plan to increase the number of new allocations in these towns. The NPPF challenges local authorities to support the Government’s objective of significantly boosting the supply of new homes and ensure there is a sufficient amount and variety of land which can come forward where it is needed. This also applies to the needs of groups with specific housing requirements such as the elderly. We would therefore encourage the GNLP to review the reasonable alternative sites which have been proposed and bring forward a greater number of new allocations. Our client’s site, Land between Shelfanger and Mount Street, Diss, is one such reasonable alternative which could deliver, albeit a modest number, 24 retirement units in a central location along with other significant community benefits.

Comment

Representation ID: 22158

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.2 - Main Towns
6.17 Policy 7.2 sets out the level of growth to be delivered in the plan period for the Main Towns of Aylsham, Diss, Harleston, Long Stratton and Wymondham.Collectively these towns will provide 6,342 homes, approximately 14% of housing growth for the plan period.
6.18 Paragraph 308 of the GNLP states that these towns play ’a vital role on the rural economy’ as they ‘provide employment opportunities and services for rural hinterlands’. It goes on to say that the settlements are ‘the engines of rural growth’.
6.19 Accordingly, it is necessary to make appropriate provision at these highly sustainable settlements to ensure that the rural economy is supported and that local housing needs are addressed including at Wymondham.

Comment

Representation ID: 22190

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Paragraph 330 states that “Anglian Water plans to increase capacity at the local water recycling centre at Wymondham to serve growth”. There needs to be a clear policy added to this document, specifically regarding ‘Foul Infrastructure’. This policy should include a clause to ensure that foul drainage infrastructure and treatment is provided in a timely manner ahead of occupation of new properties. In order to protect the local water environment and existing households/residents from issues with foul flooding, planning permission should be granted once delivery of infrastructure within appropriate timescales has been secured.
For several of the "Main Towns" listed there is a statement similar to: "Anglian Water plans to increase capacity at the local water recycling centres at ..."
It is good to see that Anglian Water are being consulted at this early stage on development. However, there are several WRCs where this statement has been added despite there being no scheduled upgrades to WRC treatment capacity in AMP7. Beyond AMP7, it is difficult for Anglian Water Services to commit to upgrades due to uncertainty surrounding funding availability for upgrades to treatment which is assessed through their Asset Management Plan process. We would suggest a caveat surrounding funding availability is added to this sentence.
Several of these WRCs are also close to their existing permit - so to accommodate the growth Anglian Water will need to apply for a new discharge permit. Given the sensitivity of a number of watercourses within the Greater Norwich area, there could be constraints on the permit due to very tight permit standards/permit standards not being achievable with conventional treatment. Therefore, it is essential that contingency options are assessed and the outputs and recommendations from the Water Cycle Study are used to direct growth within the districts. At this stage it should not be taken as a given that those WRCs will be able to accommodate all the growth until full capacity and impact assessments results are available and funding secured.
These points reaffirm exactly why a separate foul infrastructure policy needs to be included in the local plan.
It would be useful to include a requirement: to demonstrate that there is, or will be, sufficient wastewater infrastructure capacity to accommodate each individual development. This would likely take the form of a Pre-Development Enquiry response from Anglian Water submitted in support of each new planning application.

Comment

Representation ID: 22226

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

To reiterate our response to Question 13 we have concerns in respect of the comparatively low level of growth that is to be directed towards the Main Towns, a tier of the settlement hierarchy that historically yields sites that benefit from ease of delivery whilst lying in demonstrably sustainable locations. It must be remembered that the five main towns form the second highest tier in the settlement hierarchy and represent the most sustainable locations for new homes away from the Norwich urban area yet are allocated just 14.5% of total proposed growth over the plan period. It is a concern that the current strategy appears to somewhat arbitrarily constrain growth at these settlements and fails to take full advantage of the combination of deliverable sites, high levels of service provision and strong infrastructure connections present at each town.

Officers will note that our responses towards the earlier stages of the GNLP concluded that the Main Towns should realistically be expected to accommodate a far greater level of growth than currently, approximately 2,750 new dwellings across the tier. This results in an average figure of 550 homes per settlement, albeit it is acknowledged that some of the towns have a greater capacity to grow than others. In respect of Aylsham specifically our response to the Growth Options Consultation in March 2018 concluded that, due to the high levels of sustainability and accessibility it offers allied with the availability of suitable and deliverable housing sites, it would not be unreasonable to direct approximately 750-1,000 new homes towards the town. Our views in this respect remain unaltered. However, it is apparent from the ‘Housing’ table included as part of Policy 7.2 of the ‘Draft Strategy’ document that the total proposed housing to be allocated at Aylsham over the plan period falls well below this figure at only 300. In terms of cumulative growth (including existing commitments) the level of delivery at Aylsham would be the lowest of the five settlements comprising the Main Town tier. This is despite Aylsham comprising the fourth largest settlement in the plan area allied with a range of demonstrably deliverable and highly accessible sites at the town. It is also set to receive a lower level of allocated growth than both Diss and Harleston.

Indeed, Aylsham is described at paragraph 312 of the GNLP as having a good range of shops and services as well as strong transport links to Norwich. Meanwhile, Harleston (which is to receive a greater level of growth both by way of allocation and cumulatively over the plan period) is characterised as having shops and transport links designed to meet a localised catchment only. To this end the level of growth now proposed at Aylsham appears disproportionately low when the sustainability of the town and its capacity to meet the wider needs of the Greater Norwich area are both considered.

It is also noted that Anglian Water now has plans to increase capacity at the Aylsham water recycling centre, an infrastructure constraint that has held back the town’s ability to grow in recent times. Indeed, the January 2018 consultation document identified the capacity of the local water treatment capacity as the only real brake limiting the growth of the town. Otherwise the same document describes Aylsham as a town benefitting from strong market interest, thus demonstrably enhancing the case that sites at the town are attractive and deliverable. It is therefore our view that there is no good reason to arbitrarily limit the growth of Aylsham in the event that sustainable and deliverable sites at the town can be identified.

On this basis we are pleased to reiterate, and indeed reinforce, the availability of our client Westmere Homes’ land at North East Aylsham (site reference GNLP0336). This represents one of three sites that we understand officers consider to comprise suitable locations for the delivery of approximately 300 dwellings at the town. In fact, it is our clear view that our client’s site – currently identified within the evidence base of the GNLP as a reasonable alternative – represents by far the most suitable site for the delivery of meaningful growth at Aylsham. Additional evidence describing the deliverability, suitability and overall sustainability of the site is included at Annex 1 of this letter.

Regardless, on the basis of our analysis set out above we consider that there is a compelling case for more than one site to come forward at the town with a view to delivering far in excess of the 300 dwellings currently proposed by the GNLP.

Comment

Representation ID: 22292

Received: 16/03/2020

Respondent: Barton Willmore

Q41 - 42) Consultation Questions for Policy 7.2 – The Main Towns

2.72 The Main Towns consist of the settlements of Wymondham, Aylsham, Diss and Harleston. Policy 1 of the Draft Strategy also identifies Long Stratton as a Main Town. Clearly Wymondham is a settlement at least twice the size of any subsequent settlement, and given the services available, it should be identified as a ‘Large Main Town’ in a means that separates it from the other towns. An audit of facilities and services should be undertaken to support this assertion and create a hierarchy of settlements for which Wymondham should be singled out as the largest town and the most suitable to accommodate growth. This would support the basis for the additional 1,000 homes identified for Wymondham as a ‘contingency’ location, and also support the case for it to accommodate a portion of the additional growth we have identified as (a) needing to be identified to accommodate additional homes linked to the Growth Deal; and a buffer of 20%; and (b) needing to be re-allocated as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46). 2.73 We do not object to the identification of Long Stratton given the existing growth committed for the town and its location within the Norwich Policy Area, but as set out in response to Question 13, we do believe the allocation needs scrutinising as based on NLP 2016 evidence, we believe it is unlikely that 1,800 homes can be delivered in Long Stratton before 2038.

2.74 As acknowledged at paragraph 308 of the Draft Strategy the Main Towns play a vital role in the rural economy, providing employment opportunities and services for wider hinterlands. We agree with this description but consider Wymondham to have additional roles and services which elevates it above the other Main Towns. Furthermore, Wymondham is located within the Norwich Policy Area (and SHMA ‘Core Area’) and within the Cambridge Norwich Tech Corridor.

2.75 Given the emphasis of the GNLP to focus housing, employment and infrastructure growth within a ‘Strategic Growth Area’ (illustrated on the Key Diagram of the Draft Strategy) which broadly reflects the Cambridge Norwich Tech Corridor, it is unclear why Wymondham is not a key location for growth within the Plan, and separated out as such within a settlement hierarchy.

2.76 Policy 7.2 identifies Wymondham to have an existing deliverable commitment of 2,463 dwellings (including delivery 2018/19). The AMR identifies 1,140 dwellings to be delivered in the next 5-years (2019/20 to 2023/24) with a further 328 dwellings to be delivered in the remainder of the JCS Plan Period. 2.77 For 2026 and beyond the AMR identifies a supply of only 502 dwellings for the latter phases of South Wymondham (477 dwellings) and for London Road/Sutton Lane (35 dwelling). This level should be significantly increased given its previous success in delivering homes, to accommodate at least a portion of the homes we have identified as (a) needed to accommodate additional homes linked to the Growth Deal and a buffer of 20%; and (b) needed for re-allocation as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46).

2.78 The Draft Strategy proposes to allocate an additional 100 dwellings only in Wymondham, across 2no. sites (50 dwellings each). Across the extended Plan Period (2026 – 2038) there is only likely to be circa. 600 dwellings delivered in Wymondham, despite the key location of the settlement within the Cambridge Norwich Growth Corridor and past strong housing delivery. This simply does not represent sustainable planning, and by raising its position within the settlement hierarchy the case can be made to support additional growth that needs to be re-allocated.

2.79 The GNLP does give some recognition to Wymondham, by acknowledging it as a settlement that could accommodate a contingency of 1,000 dwellings. This was based on whether “the GNLP area does not meet its local plan targets”. We have highlighted for reasons above, that the GNLP does not (a) plan for enough housing growth to meet need, particularly as a result of the Growth Deal; and (b) needs to re-allocate land that cannot deliver the anticipated level of housing – i.e. in the Growth Triangle; Carrow Works; Long Stratton and the Village Clusters. Accordingly the ‘contingency’ for Wymondham should be enacted into this Local Plan now, and additional growth beyond the 1,000 dwelling contingency should be allocated to Wymondham given its sustainable location within the A11 and Cambridge to Norwich tech corridor.

2.80 The supporting assessment of Wymondham identifies that there are 7 ‘reasonable’ sites that could accommodate additional growth. Park Farm (Site GNLP2168) and Stanfield Road (Site GNLP1055) are identified as new settlements, for which there is no need identified. However, Sites GNLP2155, GNLP2150 and principally GNLP0525R, were identified as ‘reasonable’ sites that together could knit circa 1,730 new dwellings into the housing that has already been delivered at the former Rugby Club; planned at Elm Farm, and located to the north of Tuttles Lane and Norwich Road. As set out in Chapter 3, our client has land that is available, nonconstrained and deliverable, that can provide a new sustainable community heart to the existing housing that has been delivered to date, that is permitted at Elm Farm, in addition to a further 600 homes, supported by a new primary school and a Local Centre. This land can also deliver a new Country Park and land for a new Sixth Form College. 2.81 The land offers the opportunity to create a new sustainable community that delivers infrastructure to the immediate community and has wider benefits to the town in respect of open space and education provision. This is a well located site within the A11 and Cambridge – Norwich Tech corridor, with good access to trains, bus facilities and dedicated cycle routes. It should form at least part of additional land allocations to Wymondham, necessary to deliver the growth required, and in need of being re-allocated for the reasons set out in responses to previous questions.

2.82 As detailed in Section 3 there is an existing education capacity constraint in Wymondham which was not addressed at the time of adoption of the Wymondham Area Action Plan but confirmed by the Examining Inspector as a matter which justified an early review of the Plan and needing a solution. A solution to this is achievable, through the re-location of Wymondham High Sixth Form, and supported by Norfolk County Council Education. However, this is not currently being addressed by the adopted Development Plan, nor would it be addressed by the emerging GNLP in its current form.

2.83 Only through the allocation of sufficient growth to Wymondham will the GNLP resolve the ongoing education capacity constraint. The education ‘issue’ therefore must be dealt with through this plan-making process, and our client’s land offers the opportunity to address that constraint through the provision of sustainable new community that will also bring local shops and services, a new Primary School and a new public park.

2.84 In order to achieve the Vision and Objectives set by the Growth Strategy, including realising the full potential of the Cambridge Norwich Growth Corridor and meeting existing infrastructure requirements, it is necessary for the Plan to support Wymondham as a key location for growth, beyond current commitments.

2.85 In addition to the above, whilst we have no objection to the Main Towns receiving additional growth to ensure they continue to successfully achieve their roles as providers of employment and services to serve rural areas, but it is clear, for the reasons we have established Wymondham, should be set apart as a new settlement hierarchy to accommodate a higher portion of the additional growth.

2.86 Notwithstanding the above comments, we do question why Harleston, as the smallest Main Town, is identified for allocations totalling 450 dwellings in addition to the existing commitments (173 dwellings). Harleston is the least accessible Main Town, not being located on the rail network or on an A road which connects to Norwich and is not located within the Norwich Policy Area or the SHMA Core Area.

2.87 The Draft Strategy is therefore not considered to be justified or effective in line with the requirements of the Framework. As such, the proposed strategy is considered unsound.

Comment

Representation ID: 22383

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.2 - Main Towns
7.17 Policy 7.2 sets out the level of growth to be delivered in the plan period for the Main Towns of Aylsham, Diss, Harleston, Long Stratton and Wymondham. Collectively these towns will provide 6,342 homes, approximately 14% of housing growth for the plan period.
7.18 Paragraph 308 of the GNLP states that these towns play ’a vital role on the rural economy’ as they ‘provide employment opportunities and services for rural hinterlands’. It goes on to say that the settlements are ‘the engines of rural growth’.
7.19 Accordingly, it is necessary to make appropriate provision at these highly sustainable settlements to ensure that the rural economy is supported and that local housing needs are addressed including at Diss.
7.20 The GNLP states that Diss is ‘strategically located’ with the ‘widest range of shops and services of the main towns’ plus a ‘broad range of employment opportunities’. It is identified at paragraph 317 as having ‘potential for economic growth as an enhanced centre serving a large rural hinterland in South Norfolk and northern Suffolk’. Paragraph 322 identifies Diss as having ‘potential for jobs growth on existing undeveloped allocated employment land particularly for manufacturing, including high value activities.’ (emphasis added)
7.21 Given the above statements about Diss taken from the introduction to Policy 7.2 it is concerning that it ranks third out of the five main towns for proposed housing delivery in the plan period with 743 new homes proposed, 343 from existing commitments and 400 from new allocations, representing just 12% of new housing development to come forward at main towns.
7.22 It would seem appropriate given the status Diss is given in the GNLP that it would provide a greater percentage of new housing growth especially as it is the only main town that is a net importer of workers as described in the spatial strategy representation above.
7.23 It is of particular importance if the plan is to balance the delivery of homes to jobs that Diss is allocated more housing growth to address the current shortfall of workers. Additional housing over and above that required to address the current shortfall will be required to provide for workers at new employment development coming forward on the allocated 10.8ha site at Diss. There are therefore strong arguments to increase the level of new housing proposed at this main town. 7.24 Proposed housing allocations at Diss, as set out in the draft GNLP, include a new green field site to the north of the town, and a large brownfield site to the east of the town immediately adjacent to the train station.
7.25 Concern is raised over the deliverability of the brownfield site (GNLP0102 Frontier Agriculture Ltd) as this is an existing employment site in active use by the UK’s leading crop production and grain marketing business. The site provides one of the company’s nationwide network of grain storage and processing facilities each of which are located in strategically placed locations to provide optimum accessibility for producers across the local area. The loss of the facility from Diss would be disadvantageous to the local agricultural sector.
7.26 The delivery of new residential development at the site would also be almost entirely surrounded by employment land meaning that it would be largely disconnected from neighbouring residential uses which provide for natural surveillance and reduce the potential for crime. There may be issues with residential amenity given the presence of businesses immediately on virtually all sides, each of which is likely to be served by heavy goods vehicles potentially operating throughout the day and night, with the potential for noise and air quality issues.
7.27 Moreover, the Diss Sites Evidence Base document states that the use of the site for residential purposes is not supported by the local community who consider the allocation of the site to be prejudicial to the delivery of the Diss Neighbourhood Plan. (A previous outline application for demolition of existing buildings at the site and the erection of 90 dwellings was withdrawn (2015/2816) on 17th October 2016.)
7.28 The Stage 6 detailed site assessment states that no additional documents have been submitted to support the site.
7.29 Therefore, in terms of residential amenity and delivery, this residential allocation is considered to be inappropriate when other deliverable alternatives are available such as land at Walcot Green Lane (GLNP1044) which will provide new green infrastructure linkages including circular footpath routes, market and affordable homes and self-build plots plus new highway improvements to Walcot Green Lane, all of which will provide benefits to existing and new residents alike. 7.30 The land at Walcot Green Lane is deliverable and additional technical work that has been carried out in support of promoting the site evidences that highway constraints identified by the Council’s evidence base can be overcome through the provision of a high quality pedestrian and cycle link via Orchard Croft to the south. The site is not otherwise constrained and can contribute to the authorities five-year housing land supply.
7.31 In conclusion Diss should be providing additional housing through allocations in the GNLP in order to balance jobs with homes at the Main Towns. The quantum of housing currently proposed in the GNLP is inadequate to achieve a jobs/homes balance and additional employment land is proposed through the GNLP. The argument for additional and alternative housing allocations at Diss is compelling, especially given the proposed brownfield allocation at the town which is not appropriate in terms of place making or delivery. The land at Walcot Green (GNLP1044) is an appropriate alternative which should be allocated to help address the emerging unmet housing needs at Diss.

Comment

Representation ID: 22437

Received: 16/03/2020

Respondent: Gladman Developments

Question 41: Main Towns 7.2.1 Gladman supports the allocation of additional land at identified Main Towns. This recognises the suitability and sustainability of these areas as suitable locations for development over the plan period. However, for the reasons set out in Paragraphs 5.1.3 and 5.1.6 to 5.1.11 Gladman do not consider that sufficient opportunities for new development, in addition to commitments, is identified particularly in Diss and Wymondham. In response, Gladman consider further allocations should be identified at both settlements, with the proposed contingency for Wymondham, formally allocated as a site for housing.
7.2.2 Gladman considers that strategic gaps should be reviewed and revised through the plan making process of the Greater Norwich Plan. Since defined and last reviewed the context for each strategic gap is likely to have altered taking into account more recent development, with the role of strategic gaps as a development management tool altered given the spatial strategy outlined within the draft Plan. A thorough evidenced based assessment of all affected land parcels together with wider related land is necessary to consider whether strategic gaps remain a relevant and necessary designation to prevent the coalescence of settlements within the plan area.

Comment

Representation ID: 22455

Received: 16/03/2020

Respondent: Gladman Developments

2.2 Policy 7.2 Main Towns
Allocations at Diss
2.2.1 Gladman welcome proposals made under Policy 7.2 for further growth to be allocated at Diss in
addition to existing commitments. It is however considered that the additional 400 dwellings
planned for through the Draft GNLP at Diss is not enough to meet housing and employment needs
(see main representations) and does not provide sufficient flexibility within the housing land supply
to ensure the deliverability of planned requirements. Gladman submit that the level of new growth
to be directed to the settlement could and should be increased.
2.2.2 Notwithstanding that Gladman think growth should be increased at Diss, we raise question marks
around the proposed allocations to the north of the Cemetery, west of Shelfanger Road and East of
Heywood Road. It is unclear what benefits the link road would provide when considered against the
potential landscape impact of the site. There does not currently appear to be certainty that the link
would alleviate the existing traffic problems, and this appears to be a ‘best guess’. Gladman suggest
further evidence will be needed to support this proposed allocation.

Comment

Representation ID: 22465

Received: 16/03/2020

Respondent: Gladman Developments

2.3 Policy 7.2 Main Towns
Allocations at Wymondham
2.3.1 Gladman welcome proposals made under Policy 7.2 for further growth to be allocated at Wymondham in addition to existing commitments. It is however considered that the 100 dwellings planned for through the Draft GNLP at Wymondham is not enough to meet housing and employment needs (see main representations) and does not provide sufficient flexibility within the housing land supply to ensure the deliverability of planned requirements. The level of new growth to be directed to the settlement should be substantially increased.
2.3.2 In Wymondham, committed development accounts for 96% of the total growth requirements of the Local Plan over the period 2018-2038. The emerging GNLP therefore does very little to influence the strategy of the town, with policies to have limited effect in directing where, how and in what form development takes place in the town.
2.3.3 The effects of this are twofold. Firstly, growth in the town will not respond to the latest evidence base of need. For example, as drafted, the Plan will fail to respond to the housing needs of the elderly with no allocations for elderly accommodation, and little scope provided for elderly appropriate accommodation through the 100 dwellings allocated in Wymondham through the draft GNLP. Secondly, the GNLP does nothing to respond to the town’s location within the A11 tech corridor, and therefore fails to make the most of this opportunity, rendering it ineffective in this regard, and potentially harming the achievement of planned economic growth in the wider plan area.
2.3.4 Gladman notes the proposal to identify 1,000 dwellings worth of contingency in Wymondham to respond to unmet housing need. Noting the size of the Wymondham, its sustainability, and location as part of the Tech Corridor, Gladman consider that Wymondham forms one of the most appropriate locations within the plan area at which to address any housing shortfall and/or provide additional flexibility to respond to plan targets.
2.3.5 It is however considered that this additional growth should be planned for now, in the form further housing allocations in the Plan, rather than offset to a later date. Such an approach would increase the flexibility of housing land supply provided within the GNLP and heighten its durability against unpredicted changes which might occur over the plan period. Allocating land for a further 1,000 dwellings in the Plan would also address comments made above regarding the effectiveness of the GNLP in addressing the needs of Wymondham itself, as well as broader housing need. The plan making process provides a good opportunity for the infrastructure requirements of Wymondham 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.
Strategic Gaps
2.3.6 Gladman consider that strategic gaps should be reviewed and revised through the plan making process of the Greater Norwich Plan. As currently defined, the extent of the strategic gaps potentially forms an unnecessary constraint to development within the plan area, preventing the development of otherwise sustainable sites for development through the GNLP. Since defined and last reviewed the context for each strategic gap is likely to have altered considering more recent development changing the nature of the strategic gap and changing the need to retain land within this designation to fulfil its purpose.
2.3.7 Evidence of this is clear in the case of the strategic gap currently defined between Wymondham and Hethersett. In recent years the character of land at the north eastern edge of Wymondham along Norwich Common has significantly altered with new housing and employment development along the north of this road which has served to urbanise this area.
2.3.8 In response to this, Gladman commissioned FPCR to undertake an assessment of the Strategic Gap to consider how land included within this designation functions as an important part of the identified gap. This evidence (provided in Appendix 2) concludes:
 The gateway into Wymondham from the East is formed by Elm Farm Business Park. This is the most eastern extent of Wymondham;
 The B1172 (Norwich Common) represents the only visual receptor for the gap, given general absence of public footpaths and obscured views on the A11;
 Inter-visibility along the B1172 is however limited given intervening vegetation and built development;
 The settlement pattern in Wymondham has recently altered from a nucleated settlement following recent development in the north east of the town; and  There is a limited degree of openness within the strategic gap between Wymondham and Hethersett owing to existing intervening vegetation and built development.
2.3.9 Taking the above into account FPCR conclude that by maintaining the current minimum width of the Strategic Gap it is unlikely that further development will compromise inter-visibility, physical separation or perceived openness, with opportunities available to mitigate adverse effects on openness.
2.3.10 On account of this evidence, Gladman believe there is clear justification to revise the extent of the Strategic Gap defined at the edge of Wyondham to exclude land south of Norwich Common from within the gap to provide a new boundary defined at the entrance of the town provided at Elm Farm Business Park. Further commentary is provided within section 3 of this representation about how the land being promoted by Gladman at Norwich Common, Wymondham could be developed whilst safeguarding the integrity of the wider strategic gap.

Object

Representation ID: 22546

Received: 16/03/2020

Respondent: Historic England

Policy 7.2: We recommend including something on the individual characters of the main settlements in this section.

Comment

Representation ID: 22703

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
50. Policy 7.2 – The Main Towns outlines that the settlements in the Plan area of Aylsham, Diss (with part of Roydon), Harleston, Long Stratton and Wymondham will provide for substantial development of around 6,300 homes. We support this approach although given the dispersed nature of the settlements consider that a more ambitious level of growth would be deliverable and would provide greater support to enable these rural communities to prosper and thrive. Such an approach would provide the Plan with a greater degree of flexibility in the event the larger allocations in the Norwich fringe deliver more slowly than anticipated.
51. The Main Towns are sustainable locations that are suitable to accommodate additional growth to contribute to the overall Plan area’s housing need. This approach is supported by paragraph 72 of the NPPF which identifies that the supply of a large number of new homes can often best be achieved through planning for larger scale development, including extensions to existing villages and towns, where they are well located and supported by the necessary infrastructure and facilities.

Comment

Representation ID: 22793

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Policy 7.2 – The Main Towns outlines that the settlements in the Plan area of Aylsham, Diss (with part of Roydon), Harleston, Long Stratton and Wymondham will provide for substantial development of around 6,300 homes. We support this although given the dispersed nature of the settlements consider that a more ambitious level of growth would be deliverable and would provide greater support to enable these rural communities to prosper and thrive. Such an approach would provide the Plan with a greater degree of flexibility in the event the larger allocations in the Norwich fringe deliver more slowly than anticipated. The Main Towns are sustainable locations that are suitable to accommodate additional growth to contribute to the overall Plan area’s housing need. In particular, we support the approach to allocate development of the combined sites to the north of Diss which form the subject of Policy GNLP0250/0342/0119/0291 which are included as preferred options and provide a suitable amount of growth in relation to the settlement hierarchy, infrastructure and local constraints. This approach is supported by paragraph 72 of the NPPF which identifies that the supply of a large number of new homes can often best be achieved through planning for larger scale development, including extensions to existing villages and towns, where they are well located and supported by the necessary infrastructure and facilities.

Object

Representation ID: 22810

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

Comment/object - We note that the housing figures identified for the main town are expressed as 'around' and that the individual towns have fixed figures. This is despite the overall housing requirement of the Plan being identified as a minimum figure. We therefore recommend that the word 'minimum' be carried through into the policy wording for the main towns, including the individual targets for each town.

Support

Representation ID: 22838

Received: 15/03/2020

Respondent: Ms Cecilia Riccardi

I know this is not generally a favoured approach, not least because of the long lead times involved. However, it provides an ideal opportunity to develop something truly ground breaking, visionary and fit for the second half of the 21st century. Any area that can back the RIBA Stirling Prize winner for 2019 surely already has a head-start in the quest for the eco-friendly design that will be required. There must be national grants available to ensure that future communities can be built e.g.to meet climate change targets. It could have a share in the wind-farm bounty Norfolk provides. And simultaneously make a virtue of and preserve sympathetically existing environmental, historical and heritage features. Local authorities must be able to share best practise nationally. Creation of such a village should be standalone, with appropriate infrastructure - roads, healthcare, education - developed and not impinging upon already stretched local towns. Silfield Village, (GNLP2168) if chosen, could be built with all necessary facilities and access onto the A11 growth corridor and not via the Wymondham railway bridge. Such a strategy might also obviate the need for Wymondham to provide for the 1000 homes contingency should e.g. Carrow Road not be available, and thus remove the burden on Wymondham.

Support

Representation ID: 23146

Received: 16/03/2020

Respondent: Hopkins Homes

Agent: Bidwells

As detailed in comments provided in respect of Question 13, the proposed Settlement Hierarchy and the
identification of the Main Towns to accommodate approximately 14% of housing growth during the period
to 2038 is supported.
As detailed in the draft Local Plan, the Main Towns, such as Aylsham, provide a range of services and
amenities and are, therefore, the most sustainable and suitable locations for the majority of growth.
Development in these locations is key to ensuring the sustainability of the rural economy.
More specifically, Aylsham is recognised in the draft Local Plan as a sustainable location, with a good
range of shops and services, as well as local employment opportunities. It also benefits from good public transport links to Norwich and beyond. Consequently, it is a suitable location for additional growth, in accordance with the settlement hierarchy.

Comment

Representation ID: 23199

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

As set out in Orbit Homes’ representations to Policy 1, the proposed spatial strategy for allocating additional growth in the GNLP focusses a significantly higher proportion of total growth to the proposed village clusters and a lower proportion of growth to the Norwich urban area compared to existing commitments, while the strategy for the Main Towns and Key Services Centres remains broadly similar. In particular, the Main Towns continue to be allocated a comparatively low level of growth. These settlements form the second tier in the settlement hierarchy and are the most sustainable options for growth outside Norwich and yet are allocated just 14.5% of total growth during the plan period. This strategy fails to take full advantage of the potential of these settlements to sustainably grow and meet the housing needs of their catchment areas.

In addition to the current spatial strategy not recognising the potential of the main towns to sustainably accommodate higher levels of growth, Orbit Homes’ representations to Policy 1 also identifies a need to allocate an additional 4,000 to 6,300 dwellings above those currently proposed to be allocated in the GNLP. In order to meet this requirement, it would clearly be unsustainable to allocate additional high levels of growth to smaller rural settlements and Orbit Homes’ are concerned that due to significant existing commitments, any significant additional growth in the urban area may suffer from deliverability issues. We therefore consider that a higher proportion of the increased housing requirement should be directed to deliverable sites in the Main Towns.