Question 42. Do you support or object or wish to comment on the approach for specific towns (Aylsham, Diss (with part of Roydon), Harleston, Long Stratton and Wymondham)? Please identify particular issues.

Showing comments and forms 1 to 30 of 37

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 19929

Received: 13/02/2020

Respondent: Mr Alan Franks

Representation:

Comments on small site in Roydon-better related to Diss (GNLP0104)

Site Features and Constraints
I seek to draw attention to facts that are undisclosed on the call for sites submission form GNLP0104.
And would ask you to take the following into consideration before considering the site as suitable for development.
The only significant prehistoric site in Roydon dates to the Iron Age and is found to the north of Sand Stone Way (The site presented for development). Here, the cropmark of a ring ditch was noted on an aerial photograph in 1977. Partial excavation of the feature in 1981 recovered Neolithic flint tools and fragments of Iron Age pottery, and the site was interpreted as an Iron Age defended settlement.
The owner of this land undertook the partial excavation in 1981 and has made a further partial excavation in recent years. It is believed that important artefact’s remain in the ground.
Before any development is approved it would be in the interest of the community for a full and independent archaeological excavation to be undertaken.
In addition to the above I have observed several errors and omissions on the application document:
5d. Contradicts statement made in 4a, the land has been used in the past as agricultural land. Its current appearance may give the impression that it is not suitable. However this is due to the partial excavations carried out by the owner in connection with my comments about it being an historical site. It is possible that this is a deliberate attempt to influence planners.
7a. The applicant has failed to disclose that there is a public right of way crossing the access to the site (The Angles way)
7a. Sandstone way is currently a small quiet residential cull-de- sac; access to the site is very restricted. The proposed development would fundamentally change the character of the area. On completion the residents would be subject to considerable nuisance from traffic flow. During the period of construction (Possibly 2 years) the disruption would be intolerable.
7g. See statement above in blue.
7h. Neighbouring Uses: Once again the application fails to present the full picture. The land to the west of the proposed development is agricultural. Cultivated as arable. The land to the south is a public footpath (The Angles way) The land to the north is the A1066. The close proximity of the development to the A1066 would subject the proposed properties to a high level of noise & vibration. The road is a main thoroughfare for HGV’s who pass in large numbers from 4am. Vibration is a particular problem and already affects properties in the vicinity. This has resulted in complaints in the past. Permitting this development with this knowledge could render the local authority with further complaint and costly remedial action may be required.
7j. The access to the site from the west is from Tottington lane onto Sandstone way. This route is unsuitable; Tottington lane is a narrow country lane with no passing places. The access from the east is via Denmark lane,Tottington lane and Sandstone way. The junction of Denmark lane with the A1066 is of particular concern and already presents a potential danger. Visibility when turning out of Denmark lane is restricted if subjected to increased traffic, accidents would be anticipated.

I also notice that the site in question is in fact two sites A & B. only site B is within the settlement boundary Also the site to the north Site C (believed to be in different ownership) is indicating that 42 dwellings could be constructed. The 3 sites will put further strain on the already dangerous junction previously referred to.
In addition development of this area will encroach upon the green divide between Diss & Roydon. This divide is precious to residents of Roydon who are determined to remain independent. (Please refer to the recent keep Roydon whole campaign)

Full text:

Comments on small site in Roydon-better related to Diss (GNLP0104)

Site Features and Constraints
I seek to draw attention to facts that are undisclosed on the call for sites submission form GNLP0104.
And would ask you to take the following into consideration before considering the site as suitable for development.
The only significant prehistoric site in Roydon dates to the Iron Age and is found to the north of Sand Stone Way (The site presented for development). Here, the cropmark of a ring ditch was noted on an aerial photograph in 1977. Partial excavation of the feature in 1981 recovered Neolithic flint tools and fragments of Iron Age pottery, and the site was interpreted as an Iron Age defended settlement.
The owner of this land undertook the partial excavation in 1981 and has made a further partial excavation in recent years. It is believed that important artefact’s remain in the ground.
Before any development is approved it would be in the interest of the community for a full and independent archaeological excavation to be undertaken.
In addition to the above I have observed several errors and omissions on the application document:
5d. Contradicts statement made in 4a, the land has been used in the past as agricultural land. Its current appearance may give the impression that it is not suitable. However this is due to the partial excavations carried out by the owner in connection with my comments about it being an historical site. It is possible that this is a deliberate attempt to influence planners.
7a. The applicant has failed to disclose that there is a public right of way crossing the access to the site (The Angles way)
7a. Sandstone way is currently a small quiet residential cull-de- sac; access to the site is very restricted. The proposed development would fundamentally change the character of the area. On completion the residents would be subject to considerable nuisance from traffic flow. During the period of construction (Possibly 2 years) the disruption would be intolerable.
7g. See statement above in blue.
7h. Neighbouring Uses: Once again the application fails to present the full picture. The land to the west of the proposed development is agricultural. Cultivated as arable. The land to the south is a public footpath (The Angles way) The land to the north is the A1066. The close proximity of the development to the A1066 would subject the proposed properties to a high level of noise & vibration. The road is a main thoroughfare for HGV’s who pass in large numbers from 4am. Vibration is a particular problem and already affects properties in the vicinity. This has resulted in complaints in the past. Permitting this development with this knowledge could render the local authority with further complaint and costly remedial action may be required.
7j. The access to the site from the west is from Tottington lane onto Sandstone way. This route is unsuitable; Tottington lane is a narrow country lane with no passing places. The access from the east is via Denmark lane,Tottington lane and Sandstone way. The junction of Denmark lane with the A1066 is of particular concern and already presents a potential danger. Visibility when turning out of Denmark lane is restricted if subjected to increased traffic, accidents would be anticipated.

I also notice that the site in question is in fact two sites A & B. only site B is within the settlement boundary Also the site to the north Site C (believed to be in different ownership) is indicating that 42 dwellings could be constructed. The 3 sites will put further strain on the already dangerous junction previously referred to.
In addition development of this area will encroach upon the green divide between Diss & Roydon. This divide is precious to residents of Roydon who are determined to remain independent. (Please refer to the recent keep Roydon whole campaign)

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 19931

Received: 30/10/2019

Respondent: Rebecca, E, T and Hayley Crockford

Number of people: 4

Representation:

I am writing to let you know, the greater norwich local plan for Harleston to build new homes will not go ahead if I have anything to do with it. Have you even thought of the impact it will have on the wildlife, the hare's I have seen in the early mornings on the way to work, which I will not see anymore. Dentists, Doctors, Schools, Jobs? are we having more of these (non) I don't think so do you? There are many empty houses in this area. So don't lie about we need more homes, young people should learn to save and not get things they shouldn't afford. Thanks for taking my happiness away. It's to do with money, and how much can you get, you people are selfish, taking away our towns and villages it will soon be a city.

Full text:

I am writing to let you know, the greater norwich local plan for Harleston to build new homes will not go ahead if I have anything to do with it. Have you even thought of the impact it will have on the wildlife, the hare's I have seen in the early mornings on the way to work, which I will not see anymore. Dentists, Doctors, Schools, Jobs? are we having more of these (non) I don't think so do you? There are many empty houses in this area. So don't lie about we need more homes, young people should learn to save and not get things they shouldn't afford. Thanks for taking my happiness away. It's to do with money, and how much can you get, you people are selfish, taking away our towns and villages it will soon be a city.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 19932

Received: 30/10/2019

Respondent: Rebecca, E, T and Hayley Crockford

Number of people: 4

Representation:

We have just received your letter. Which was a surprise, as you already have our letter of our views. We do not want any more houses built and a lot of people in Harleston agree with us. Including former Town Council Barry woods which has set up a group called action for Harleston. People's views should be took into account.

Full text:

I am writing to let you know, the greater norwich local plan for Harleston to build new homes will not go ahead if I have anything to do with it. Have you even thought of the impact it will have on the wildlife, the hare's I have seen in the early mornings on the way to work, which I will not see anymore. Dentists, Doctors, Schools, Jobs? are we having more of these (non) I don't think so do you? There are many empty houses in this area. So don't lie about we need more homes, young people should learn to save and not get things they shouldn't afford. Thanks for taking my happiness away. It's to do with money, and how much can you get, you people are selfish, taking away our towns and villages it will soon be a city.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20090

Received: 25/02/2020

Respondent: Wymondham Town Council

Representation:

The Council is pleased that there is only a minimal additional proposed allocation of 100 homes in view of the significant number that already have approval and have not yet been built. Concern was however expressed that there could be a possible contingency of 1000 new dwellings and this seems excessive. The Council wishes to reserve the right to comment on any sites that are recommend(sic) if this contingency, or part thereof, is proposed in the final plan.

Full text:

The Town Councils Planning Lighting & Highways Committee has now considered the proposals relating to Wymondham and the plan for an additional 100 dwellings to be added to the existing allocation resulting in an overall commitment of 2563.
The proposed sites reference GNLP0354 at Johnson's Farm and GNLP3013 Land North of Tuttles Lane, each with an allocation of 50 dwellings are considered acceptable.
The Council is pleased that there is only a minimal additional proposed allocation of 100 homes in view of the significant number that already have approval and have not yet been built. Concern was however expressed that there could be a possible contingency of 1000 new dwellings and this seems excessive. The Council wishes to reserve the right to comment on any sites that are recommend(sic) if this contingency, or part thereof, is proposed in the final plan.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20105

Received: 25/02/2020

Respondent: RJ Baker & Sons

Agent: Cheffins

Representation:

Further clarification and justification is required for the Wymondham contingency of 1,000 dwellings - further land can easily be allocated now.

Full text:

Q42: Elsewhere (Q13 under Policy 1) we have queried the basis of the 1,000 dwelling contingency identified for Wymondham. Three comments arise:
• The fact that Wymondham has been identified for this possible contingency suggests that there is an acceptance that this settlement is capable of accommodating further growth. We support that view;
• We do believe that there is scope for accommodating some further housing development at Wymondham within this plan which would reduce the contingency figure and therefore provide a greater degree of certainty for all parties through increased land allocations; and
• It is unclear how the Local Planning Authority will monitor or measure whether ‘delivery of housing in the GNLP area does not meet local plan targets ‘. In addition, if the contingency is triggered by low delivery rates in the GNLP area – how might the allocation of suitable land be achieved i.e. what is the statutory mechanism for facilitating such a contingency? The approach set out for this contingency provides little certainty for residents, landowners, service organisations or statutory undertakers planning future service provision.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20411

Received: 04/03/2020

Respondent: Great Melton Parish Council

Representation:

Great Melton has already experienced a surge in traffic volume through the village within the last eighteen months or so.
This was bound to happen with the amount of development that has taken place in the last few years, on the edge of Wymondham and Hethersett.
Infra structure additions and repairs will have to be undertaken, but it is hoped that any such work will be done in a sympathetic way with regard to the Parish of Great Melton.

Full text:

Great Melton has already experienced a surge in traffic volume through the village within the last eighteen months or so.
This was bound to happen with the amount of development that has taken place in the last few years, on the edge of Wymondham and Hethersett.
Infra structure additions and repairs will have to be undertaken, but it is hoped that any such work will be done in a sympathetic way with regard to the Parish of Great Melton.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20590

Received: 10/03/2020

Respondent: David Hastings

Agent: Smallfish

Representation:

We feel the method excluding small sites is not in line with the spirit and intention of Paragraph 68 of the NPPF and ask GNDP to reconsider its position on small sites.

We put forward a new site of approximately 0.5 hectares for consideration as an allocation for new small-scale housing development for up to eight dwellings. This site already lies within the adopted Wymondham development boundary. The main issue the landowners are trying to rectify through the site allocations process is the removal of the site from the Policies Map as protected recreation/amenity land and its allocation for housing.

Full text:

We write in response to your latest consultation (Regulation 18) on the Greater Norwich Local Plan. We note that the Partnership has decided not to allocate any sites smaller than 0.5 ha and understand that these small sites will only be considered now as extensions to the development boundary, rather than as site allocations.

However, we do not feel that this method reflects Paragraph 68 of the NPPF, which seeks to allocate at least 10% of the housing requirements on small and medium sites under one hectare. Rather, it ensures that only medium and large sites between 0.5+ ha are allocated.

The draft plan only allocates sites for 12 or more dwellings with a minimum target density of 25 dwellings per hectare and at least 0.5ha. This will ensure that allocated sites will only deliver major development. It also limits the overall mix of sites, meaning that small sites are likely to only be considered acceptable if immediately adjacent to the existing adopted development boundary, whereas medium and large sites could potentially be allocated some distance apart from the development boundary.

Taken together, this proposed method would inadvertently ensure that all small sites and minor residential developments are excluded from the allocation process entirely, despite the fact that it is well known that smaller sites both support smaller builders and are built out more quickly, having a large impact on ensuring a consistent and adequate housing supply is maintained.

We feel this method is not in line with the spirit and intention of Paragraph 68 of the NPPF and seek for the GNDP to reconsider its position on small sites and consider providing them with allocation status.

As a result, we would like to put forward a new site of approximately 0.5 hectares shown on the attached site plan for consideration as an allocation for new small-scale housing development for up to eight dwellings. A Greater Norwich Call for Sites form and location plan is attached.

We draw your attention to the fact that this site already lies entirely within the adopted Wymondham development boundary. As a result, the main issue the landowners are trying to rectify through the site allocations process is the removal of the site from the Policies Map as protected recreation/amenity land.

The site has been in the same family since 1981. Until 2005, the site was overgrown with trees and brambles. In 2005, the land was cleared and a fence erected. It is unknown how or why the northern part of the site (shown in green on the attached plan), was shown as protected recreation/amenity land on the current local plan Policies Maps. To the landowner’s knowledge, the site has never been open for public access, nor has it ever been used for recreation or amenity purposes.

The loss of this narrow strip of land from the wider recreation/amenity land designation will make little material difference to the area, given that it is not open for recreation or amenity use and the landowners has no plans to allow the public to use it for such purposes. The public has access to much more substantial recreation and amenity facilities very close by at Kett’s Park Community & Recreation Centre, which is only 230 metres to the south, or Ashleigh Primary School only 230 metres to the north. The continued protection of this site for recreation or amenity purposes provides no benefit to or the wider public or the landowners.

When coupled with the remainder of the landowners’ landholding, the site could provide much-needed housing in an extremely sustainable location in one of the Council’s major growth areas.

Therefore, the landowners respectfully request that the recreation/amenity land designation on this site is reconsidered and that the new local plan considers allocating the site for residential development.


Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20626

Received: 11/03/2020

Respondent: Mrs Janet Skidmore

Agent: Carter Jonas LLP

Representation:

No summary provided.

Full text:

Policy 7.2 contains the development strategy for the main towns, including Wymondham. We object to the strategy for Wymondham, in respect of the decision to make only a limited number of allocations in this settlement and because the sites identified as reasonable alternatives are not suitable. A number of strategic extensions (for 1,500 dwellings) and garden villages (for 6,500 dwellings) have been identified as reasonable alternative housing allocations at Wymondham, but these sites clearly exceed the contingency requirement for the town and cannot be delivered quickly. The land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320) is promoted for residential development, but has been incorrectly identified as an unreasonable site in the GNLP Site Assessment document.

It is very unlikely that strategic extensions or garden villages would be delivered quickly enough to address a housing land supply shortfall in Wymondham 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 extensions and garden villages in Wymondham are not reasonable because they would not meet the purpose of a contingency site i.e. to meet non-delivery elsewhere. It is very unlikely that the strategic extensions and garden villages identified as reasonable alternatives for Wymondham will provide policy compliant levels of affordable housing during the initial phases of development because of the costs of providing primary infrastructure e.g. roads, drainage, strategic landscaping, and community uses in advance of housing development. In addition, as set out in the representations to the Site Allocations document for Wymondham sites, there are identified constraints to development at these sites. For example, the land to the north east of Wymondham is within the strategic gap between Wymondham and Hethersett, and development in this location would reduce that gap and have an impact on the landscape setting of the town. Therefore, it is considered that the strategic gaps and garden village identified as reasonable alternatives for Wymondham are not suitable for the developments proposed at these sites.

As set out in the representations to the Site Allocations document for Wymondham sites, the promoted development at land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320) is smaller than the strategic extension sites and garden villages and it available for development, and as such it could meet the requirements for a contingency site to meet non-delivery elsewhere. The development at land to the north of Gonville Hall Farm is currently under construction, and therefore the promoted development at land south of Gonville Hall Farm would in due course be adjacent to the built-up area of the town, which was the reason why the site was assessed as an unreasonable site. There are no constraints to development at this site. A number of site specific technical reports have been prepared for the promoted development: Concept Masterplan; Heritage Desk Based Assessment; Preliminary Ecological Appraisal; Landscape & Visual Overview; Flood Risk & Drainage Appraisal; and Access and Movement Strategy. In summary, there are no constraints to development at the site, and the promoted development includes significant areas of green infrastructure, a buffer around Gonville Hall, and the heritage setting corridors remain free of built development. Therefore, it is considered that land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320) should be allocated in emerging GNLP or identified as a reasonable alternative site to meet future needs.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20654

Received: 09/03/2020

Respondent: Mr Brian Falk

Representation:

The GREATER NORWICH Regulation 18 Consultation 2020
PROPOSALS FOR DISS
Whatever the merits of the Greater Norwich Local Plan for Norwich there are few for Diss. The clue is in the
name. It may stretch credulity to include Long Stratton in Greater Norwich, but the reasons for doing so cannot
include Diss, and do not try. The local plan provisions for Diss are in no way recognisable as a creative and
workable plan. They are a recipe for the decline of Diss’s role and regional centre as a historic market town.
Consultation 18 divorces Diss from its essential support settlements and, despite the gnlp political introduction,
there are no housing-matching specific plan proposals for new jobs, supporting infrastructure, schools, roads,
health care, Proposals and consultation are limited to a bureaucratic scatter of housing sites without context,
an exercise in allocating housing numbers simply to achieve a total, leading to added settlement girth within
restricted boundaries, a kind of planning obesity, creeping encroachment on agricultural land and a lottery
allocation of added wealth for selected peripheral land owners.
WHY DOES THE GNLP (particularly Regulation 18 proposals) FAIL TO LIVE UP TO THE TITLE
OF A LOCAL PLAN?
It fails to link Diss to its surrounding support villages. It specifically severs proposals for those settlements
from its proposals for Diss, which as a market town relies on its surrounding villages as they rely on Diss. No
plan for Diss as a market town commercial and social centre can be relevant if it limits its consideration to its
parish boundary and treats surrounding settlements in separate categories of ‘Service and ‘Other’. These
settlements need planning as an essential element of a Greater Diss.
It fails to grant Diss the same growth zone considerations applied for Norwich. Diss may be far smaller than
the County capital, but it has its own integral support and growth zone and no Local Plan should ignore that
context. Diss parish of some 7,500 has a population hinterland of 50-70,000 dependant on the commercial or
social attraction. A simple mid-distance hinterland virtually fills a ten mile circumference, a weighted
gravitational assessment on population (2012) in competing centres reduces that hinterland to the north, west
and south of Diss to five miles circumference. The audience support for Diss Corn Hall (2015) shows the
‘reach’ of Diss into the myriad of its surrounding Villages and Hundreds beyond the ten mile circumference.
A local plan needs to take this hinterland into consideration and treat it as an integral element of Diss’ future.
Hinterland assessments
By travel, at settlement mid-points By population gravitational weighting By Corn Hall Audience 2015
It fails to acknowledge that Diss, the sole centre in the County other than Norwich, has a rail station providing
a swift link direct to the heart of London’s financial centre. This already attracts significant commuter traffic.
For 30 years this pattern of home/work commuting has greatly increased, will continue to be a potent urban
generator, but has not been built into the parameters guiding the plan.
It claims to relate a confetti allocation of dwelling consents to primary school access, with a child’s pedestrian
link to a primary schools set as the criterion for a new housing site. But it fails to assess the need and thus
location for new Primary Schools. The plan accepts existing catchment areas and assumes the existing schools
can accommodate all children from new housing. Or, indeed for any new social services. It is not a plan, it is
a housing numbers game.
It mentions but fails to resolve the traffic difficulties of Park Road and Victoria Road Diss, ignoring the need
and potential for a hinterland bypass link between the A143 and A1066. There are no proposals for
infrastructure to support the allocated housing sites, nor analysis that road, water, drainage and communication
capacity will be available.
It fails to provide any Action plan or proposals for Diss Town Centre. It has no proposals for the linkage of the
Diss Park to the proposed Waveney riverine parkland. It fails to mention the town centre and the increasing
number of empty commercial properties let alone attempting to adopt plan policies that will help the centre to
survive.
Empty properties in the Diss Heritage Triangle and Market
Place. There are further significant vacancies down Mere Street
It still continues retail use amongst those approved for Sites DIS 6 & 7, (Committed Sites up to 2018) despite
the rejection of retail warehousing use on appeal for Diss 7 and the accepted deleterious impacts retail
development that it would have had have on existing traders and Diss’ historic town centre. The Development
Management Committee in refusing consent may have hid behind the fact the site was on the periphery of a
conservation area, but the inspector recognised the adverse economic impacts it would have had. This review
of the plan should take the opportunity to change the approved uses for committed sites.
It continues the cult of ‘borderism’ that has plagued all plans in the past, accepting that plan responsibility
ceases at the County boundary and thus fails to acknowledge the Diss Town Council and Mid-Suffolk’s efforts
to establish a Neighbourhood plan that includes those zones that form part of Diss’ hinterland south of the
River Waveney. For planning purposes a ‘Greater Diss Growth Zone’ paralleling the Norwich approach should
include the core parishes of the emerging Neighbourhood plan … Diss, Roydon, Burston & Shrimpling, Scole,
Palgrave, Stutson and Brome and Oakley. This, at least, would provide some logical context for a
comprehensive plan that includes housing as but one of its elements.
A POSSIBLE DIFFERENT APPROACH FOR THE DISS AND EYE SPATIAL REGION.
These two diagrams compare the planning base for Greater Norwich as set out in the 2010 Key Diagram from
the Joint Core Strategy with that for the south of the District and north Mid-Suffolk. That for Greater Norwich
seeks to take into account a broad range of plan elements. That for the south of South Norfolk is a collection
of parishes each treated separately and has no planning relevance whatsoever.
Rather than using this parish patchwork as a series of boxes within which to allocate peripheral housing
additions to each settlement an extension of the JCS Strategy approach for the Norwich Growth Area would
be to attempt a similar consideration of the needs of a planned axis between Diss and Eye. This would entail
the establishment of a joint South Norfolk-Mid-Suffolk development and implementation unit, difficult but
possible, and would provide for a matching basis of plan consideration across the county boundary. It would
also permit a more imaginative and attractive solution to housing provision to include, perhaps, a new highdensity
yet garden village community.
SUMMARY
The GNLP may or may not deliver a sufficient supply of homes for the next plan period. But it fails to do more
than generally acknowledge primary criteria under the JCS for future economic, social or environmental
objectives and their impacts on Diss and its surrounds. It fails to identify how the proposed number and location
of new homes will relate to the Diss of the future. There are no plan specifics to ensure the vitality of the town
centre, nor any consideration of how such housing will promote a healthy and safe community. No proposals
deal with the need and provision of sustainable transport or high quality communication. There is no
recognition of the importance of the rail link, or proposals for better linkage between station and town. The
housing provision, site by site, may have associated provisions affecting their layout (no mention is made of
design quality) but these remain subsidiary and ancillary to each housing designation, rather than satisfying
broader policies. The Local Plan Consultation 18 restricts itself to sites for new housing, lacks a full and
realistic context, is devoid of policies to ensure well-designed places or conservation of natural and historic
assets and environment and without these fails to meet the requirements set out in the National Planning Policy
Framework.

Full text:

Please see attached

The GREATER NORWICH Regulation 18 Consultation 2020
PROPOSALS FOR DISS

Whatever the merits of the Greater Norwich Local Plan for Norwich there are few for Diss. The clue is in the name. It may stretch credulity to include Long Stratton in Greater Norwich, but the reasons for doing so cannot include Diss, and do not try. The local plan provisions for Diss are in no way recognisable as a creative and workable plan. They are a recipe for the decline of Diss’s role and regional centre as a historic market town. Consultation 18 divorces Diss from its essential support settlements and, despite the gnlp political introduction, there are no housing-matching specific plan proposals for new jobs, supporting infrastructure, schools, roads, health care, Proposals and consultation are limited to a bureaucratic scatter of housing sites without context, an exercise in allocating housing numbers simply to achieve a total, leading to added settlement girth within restricted boundaries, a kind of planning obesity, creeping encroachment on agricultural land and a lottery allocation of added wealth for selected peripheral land owners.

WHY DOES THE GNLP (particularly Regulation 18 proposals) FAIL TO LIVE UP TO THE TITLE OF A LOCAL PLAN?
It fails to link Diss to its surrounding support villages. It specifically severs proposals for those settlements from its proposals for Diss, which as a market town relies on its surrounding villages as they rely on Diss. No plan for Diss as a market town commercial and social centre can be relevant if it limits its consideration to its parish boundary and treats surrounding settlements in separate categories of ‘Service and ‘Other’. These settlements need planning as an essential element of a Greater Diss.

It fails to grant Diss the same growth zone considerations applied for Norwich. Diss may be far smaller than the County capital, but it has its own integral support and growth zone and no Local Plan should ignore that context. Diss parish of some 7,500 has a population hinterland of 50-70,000 dependant on the commercial or social attraction. A simple mid-distance hinterland virtually fills a ten mile circumference, a weighted gravitational assessment on population (2012) in competing centres reduces that hinterland to the north, west and south of Diss to five miles circumference. The audience support for Diss Corn Hall (2015) shows the ‘reach’ of Diss into the myriad of its surrounding Villages and Hundreds beyond the ten mile circumference. A local plan needs to take this hinterland into consideration and treat it as an integral element of Diss’ future.













Hinterland assessments
By travel, at settlement mid-points By population gravitational weighting By Corn Hall Audience 2015

It fails to acknowledge that Diss, the sole centre in the County other than Norwich, has a rail station providing a swift link direct to the heart of London’s financial centre. This already attracts significant commuter traffic. For 30 years this pattern of home/work commuting has greatly increased, will continue to be a potent urban generator, but has not been built into the parameters guiding the plan.

It claims to relate a confetti allocation of dwelling consents to primary school access, with a child’s pedestrian link to a primary schools set as the criterion for a new housing site. But it fails to assess the need and thus location for new Primary Schools. The plan accepts existing catchment areas and assumes the existing schools can accommodate all children from new housing. Or, indeed for any new social services. It is not a plan, it is a housing numbers game.
It mentions but fails to resolve the traffic difficulties of Park Road and Victoria Road Diss, ignoring the need and potential for a hinterland bypass link between the A143 and A1066. There are no proposals for infrastructure to support the allocated housing sites, nor analysis that road, water, drainage and communication capacity will be available.

It fails to provide any Action plan or proposals for Diss Town Centre. It has no proposals for the linkage of the Diss Park to the proposed Waveney riverine parkland. It fails to mention the town centre and the increasing number of empty commercial properties let alone attempting to adopt plan policies that will help the centre to survive.







Empty properties in the Diss Heritage Triangle and Market
Place. There are further significant vacancies down Mere Street


It still continues retail use amongst those approved for Sites DIS 6 & 7, (Committed Sites up to 2018) despite the rejection of retail warehousing use on appeal for Diss 7 and the accepted deleterious impacts retail development that it would have had have on existing traders and Diss’ historic town centre. The Development Management Committee in refusing consent may have hid behind the fact the site was on the periphery of a conservation area, but the inspector recognised the adverse economic impacts it would have had. This review of the plan should take the opportunity to change the approved uses for committed sites.
















It continues the cult of ‘borderism’ that has plagued all plans in the past, accepting that plan responsibility ceases at the County boundary and thus fails to acknowledge the Diss Town Council and Mid-Suffolk’s efforts to establish a Neighbourhood plan that includes those zones that form part of Diss’ hinterland south of the River Waveney. For planning purposes a ‘Greater Diss Growth Zone’ paralleling the Norwich approach should include the core parishes of the emerging Neighbourhood plan … Diss, Roydon, Burston & Shrimpling, Scole, Palgrave, Stutson and Brome and Oakley. This, at least, would provide some logical context for a comprehensive plan that includes housing as but one of its elements.








A POSSIBLE DIFFERENT APPROACH FOR THE DISS AND EYE SPATIAL REGION.



















These two diagrams compare the planning base for Greater Norwich as set out in the 2010 Key Diagram from the Joint Core Strategy with that for the south of the District and north Mid-Suffolk. That for Greater Norwich seeks to take into account a broad range of plan elements. That for the south of South Norfolk is a collection of parishes each treated separately and has no planning relevance whatsoever.















Rather than using this parish patchwork as a series of boxes within which to allocate peripheral housing additions to each settlement an extension of the JCS Strategy approach for the Norwich Growth Area would be to attempt a similar consideration of the needs of a planned axis between Diss and Eye. This would entail the establishment of a joint South Norfolk-Mid-Suffolk development and implementation unit, difficult but possible, and would provide for a matching basis of plan consideration across the county boundary. It would also permit a more imaginative and attractive solution to housing provision to include, perhaps, a new high-density yet garden village community.

COMMENTS ON REGULATION 18 ‘PROMOTED SITES’
Housing Sites:
GNLP0342 and 0250
Specific provision should made at the outset to restrict the housing site area so as to identify, allocate and gift adequate extra land for Diss cemetery and the link road, not leaving these needs contingent on planning conditions.
GNLP0102, 0185 and 1054
It is inappropriate to squeeze housing into the middle of an employment site and adjacent to a railway. The site should remain in employment use. Diss needs more land designated for employment use and a policy to generate new work opportunities.
GNLP0341 (Parish Fields)
A strictly limited number of dwellings might be permitted provided they were designed specially for the site and, as public benefit for the use of land designated as ‘Important Local Open Space to be retained’, the remainder of Parish Fields were deeded over to Diss Town Council and developed as a public park.
GNLP0599, 1044, 1003
None are currently designated for the next plan period, but should they be considered they need to be designed and built as part of a special Walcot Green village design with its own open surrounds, not treated as added Diss girth.

Site Commitments up to 2018
DIS 3
This critical, if small, site on the edge of the A1066 has high visual impact. It may look convenient on a map to complete zoned residential to a straight line, but this is desk-planning with little regard to the actual look and feel of the land. The site needs to revert back to open space so as to emphasise and not diminish the value of the landscape gap between Diss and Roydon and to avoid allotments butting up against housing. A planted woodland strip along the this edge of housing land would be beneficial to the look and character of the town.
DIS 6
Retail use should be deleted from the sui generis approved uses for this site and compulsory purchase made of the ‘ransom’ strip on the ‘Morrison’s internal roundabout so as to allow traffic to access DIS 6 (and the bus station) from the internal Morrison road approach. Provision should be made for a landscape walk connection from the bus station south to DIS 2, to include a walkway strip alongside the electricity sub-station.
DIS 2 & 7
Retail use should be deleted from the sui generis approved uses for DIS 7 and effort made to help relocate the feather factory and to create a landscape connection between the Diss Town Park and DIS 2.

SUMMARY
The GNLP may or may not deliver a sufficient supply of homes for the next plan period. But it fails to do more than generally acknowledge primary criteria under the JCS for future economic, social or environmental objectives and their impacts on Diss and its surrounds. It fails to identify how the proposed number and location of new homes will relate to the Diss of the future. There are no plan specifics to ensure the vitality of the town centre, nor any consideration of how such housing will promote a healthy and safe community. No proposals deal with the need and provision of sustainable transport or high quality communication. There is no recognition of the importance of the rail link, or proposals for better linkage between station and town. The housing provision, site by site, may have associated provisions affecting their layout (no mention is made of design quality) but these remain subsidiary and ancillary to each housing designation, rather than satisfying broader policies. The Local Plan Consultation 18 restricts itself to sites for new housing, lacks a full and realistic context, is devoid of policies to ensure well-designed places or conservation of natural and historic assets and environment and without these fails to meet the requirements set out in the National Planning Policy Framework.

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20995

Received: 14/03/2020

Respondent: Mr Keith Benjafield

Representation:

Currently Wymondham is increasing its housing significantly, but to date no new schools are being provided.Health services are unable to cope /take on new patients. If development is to continue then the council need to ensure that the infrastructures are in place to accommodate the new developments. From my background this all to common a failure. I have worked in Construction for 45yrs both as a contractor and in local authorities , and have seen money wasted. Planning should ensure that a flow of infrastructure is in place as the developments proceed.

Full text:

Currently Wymondham is increasing its housing significantly, but to date no new schools are being provided.Health services are unable to cope /take on new patients. If development is to continue then the council need to ensure that the infrastructures are in place to accommodate the new developments. From my background this all to common a failure. I have worked in Construction for 45yrs both as a contractor and in local authorities , and have seen money wasted. Planning should ensure that a flow of infrastructure is in place as the developments proceed.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21336

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

Representation:

See our answer to question 41.

Full text:

See our answer to question 41.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21415

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Representation:

See our answer to question 41.

Full text:

See our answer to question 41.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21643

Received: 16/03/2020

Respondent: Aylsham TC

Representation:

AylshamWhilst it is true that Aylsham has good transport links there is an issue with transport through the town itself. TThe Town Council would like to address this through the provision of a transport hub to look at solutions for both the bus situation and the long-term parking issues experienced by the town.
The town requires a safe crossing of the A140.
Clarification on the school - is this a replacement or third school?

Full text:

Aylsham
Whilst it is true that Aylsham has good transport links both North and South via the A140, there is an issue with transport through the town itself. The roads in the historic centre were not built for cars let alone the large buses that now regularly cross the town. The Town Council would like to address this through the provision of a transport hub to look at solutions for both the bus situation and the long-term parking issues experienced by the town. The Town Council does not agree with the chosen site – the full details of which are provided in the response to sites consultation.
The town is fortunate to have the long distance trails of the Weavers Way and Marriots/Bure Valley Way. However, both these paths necessitate crossing the extremely busy A140 with no assistance to the pedestrian – this will need to be addressed.
Although the Town Council welcomes the addition of the school the policy does not specifically include this. The notes to the policy claim a new primary school which would indicate a third school will be built but the Town Council have been informed that it is more likely that an existing school will be moved and extended on a new site. This is not clear in the policy and is not the wished for expansion of primary education in the town

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21773

Received: 16/03/2020

Respondent: Brown & Co

Representation:

A number of these areas are subject to significant landscape and infrastructure constraints, which place delivery at jeopardy and could result in significant adverse impacts on local character and biodiversity. These issues have already impacted upon the delivery of a large proportion of the ‘existing deliverable commitment’. Additional consideration should be given to the individual characteristics of each town and their suitability for additional development, and the scale of this.

Full text:

A number of these areas are subject to significant landscape and infrastructure constraints, which place delivery at jeopardy and could result in significant adverse impacts on local character and biodiversity. These issues have already impacted upon the delivery of a large proportion of the ‘existing deliverable commitment’. Additional consideration should be given to the individual characteristics of each town and their suitability for additional development, and the scale of this.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21793

Received: 16/03/2020

Respondent: Miss Jean Kershaw

Representation:

Comments on small site GNLP0104

my concerns.
1) I live (in the area) (for over twenty years). Applications have been raised for the development of the land - never having been developed due to access to any homes being built
2) Sandstone Way is a cul-de-sac & at times can be congested by cars parked on the roadside.
I just do not think it feasible to contemplate developing the site unless other entry & exit to the site can be developed. I know other residents share these concerns.
Also there is a Public Footpath at the top of Sandstone Way (used by school children & dog walkers) which presumably would no longer exist. But to me the biggest problem would be car parking in Sandstone Way & possible entry to any proposed new property at Sandstone Way.

Full text:

Re: Greater Norwich local Plan What it meas to Roydon Mtg held Diss Corn Hall - 3 March.
As I was unable to attend the above meeting I am sending you details of my concerns.
1) I live (in the area) (for over twenty years). Applications have been raised for the development of the land - never having been developed due to access to any homes being built
2) Sandstone Way is a cul-de-sac & at times can be conjested (sic) by cars parked on the roadside.
I just do not think it feasible to contemplate developing the site unless other entry & exit to the site can be developed. I know other residents share these concerns.
Also there is a Public Footpath at the top of Sandstone Way (used by school children & dog walkers) which presumably would no longer exist. But to me the biggest problem would be car parking in Sandstone Way & possible entry to any proposed new property at Sandstone Way.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21794

Received: 17/03/2020

Respondent: Zai Gooderham

Representation:

Ref small site GNLP0104
there is a footpath between the land to be developed, and Sandstone Way cul-de-sac. I see the plan is to bring the traffic off the A1066 down Denmark Lane, and then through Sandstone Way, on to this site.
There are many reasons I could give to make you see how ridiculous this is. The road is not suitable for this traffic, not only the width but the design, and the structure is not suitable even you council refuse lorry has to go on the pavement next to (resident's houses), it goes over (there) water meters, and the pavement has sunk, some what, and it has cracked the pavement, this road, and the pavement has not received any attention, since these houses have been built about 31 years.
The speed, and parking on Denmark Lane, and Tottington Lane, leaves much to think about, (locals) often come out of Sandstone Way, and have to risk coming out unable to see, because vehicles park almost on the junction.
I think these places need serious consideration

Full text:

I write this letter to send my concern, about the plans to develop the land near (the) cul-de-sac of Sandstone Way, and the A1066. May I remind you, there is a footpath between the land to be developed, and Sandstone Way cul-de-sac. I see the plan is to bring the traffic off the A1066 down Denmark Lane, and then through Sandstone Way, on to this site.
There are many reasons I could give to make you see how rediculous this is. The road is not suitable for this traffic, not only the width but the design, and the structure is not suitable even you council refuse lorry has to go on the pavement next to (resident's houses), it goes over (there) water meters, and the pavement has sunck(sic), some what, and it has cracked the pavement, this road, and the pavement has not received any attention, since these houses have been built about 31 years.
The speed, and parking on Denmark Lane, and Tottington Lane, leaves much to think about, (locals) often come out of Sandstone Way, and have to risk coming out unable to see, because vehicles park almost on the junction.
I think these places need serious consideration

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21960

Received: 15/03/2020

Respondent: Norman Hart

Representation:

Harleston has been allocated a disproportionately large number of houses c.f. Aylsham and Diss Aylsham 25% more people than Harleston 20% fewer houses Diss 80+% more people than Harleston 16% more houses Long Stratton andWymondham not comparable because of their proximity to Norwich.

If one allows 10% growth in population per decade, the increase in population will be Aylsham 1250 Harleston 950 Diss 1750. GNLP proposals do not reflect this. The new allocations are Diss 50 houses less than Harleston and Aylsham 150 less.

INFRASTRUCTURE.
Harleston’s primary and secondary schools have few if any vacancies available ( Diss certainly has spaces available at secondary level ). The small(3 partner) doctor’s surgery is under pressure.
Surface drainage and sewerage are under pressure according to Anglian Water who have talked of considerable investment needed even for the development of land already allocated. Harleston lacks a community hall ( preferably community owned ) for functions and large meetings.

PUBLIC TRANSPORT.
Diss is a public transport hub of some size. 13 bus routes + a main line railway station ( 35+ services per day to Norwich, Ipswich, Colchester and London. Harleston has 3 bus routes ( one has just one bus per day). Commuting for ‘normal’ working hours is only available to Diss, Long Stratton and Norwich. There are no evening or Sunday services.

OTHER COMMENTS. Proposed new sites are only walkable into town centre by fit people 15 minutes ( we have a high proportion of elderly people ). Harleston has low unemployment BUT the vacancies are predominately in low pay and low status jobs.

I am not against development as a bred and born Harlestonian I have seen Harleston grow from just under 2000 to present size but I fail to see how we have been treated fairly cf Diss and Aylsham.

Full text:

Housing allocation for main towns( page 106) I understand that ‘existing deliverable commitment’ ( but not yet built) are included in the figures. It is the total figure to which I address my comments initially.
Harleston has been allocated a disproportionately large number of houses c.f. Aylsham and Diss Aylsham 25% more people than Harleston 20% fewer houses Diss 80+% more people than Harleston 16% more houses Long Stratton andWymondham not comparable because of their proximity to Norwich.
If one allows 10% growth in population per decade, the increase in population will be Aylsham 1250 Harleston 950 Diss 1750. GNLP proposals do not reflect this. The new allocations are Diss 50 houses less than Harleston and Aylsham 150 less. INFRASTRUCTURE. Harleston’s primary and secondary schools have few if any vacancies available ( Diss certainly has spaces available at secondary level ). The small(3 partner) doctor’s surgery is under pressure. As a member of the PPG, I often hear this. Surface drainage and sewerage are under pressure according to Anglian Water who have talked of considerable investment needed even for the development of land already allocated. Harleston lacks a community hall ( preferably community owned ) for functions and large meetings. PUBLIC TRANSPORT. Diss is a public transport hub of some size. 13 bus routes + a main line railway station ( 35+ services per day to Norwich, Ipswich, Colchester and London. Harleston has 3 bus routes ( one has just one bus per day). Commuting for ‘normal’ working hours is only available to Diss, Long Stratton and Norwich. There are no evening or Sunday services. OTHER COMMENTS. Proposed new sites are only walkable into town centre by fit people 15 minutes ( we have a high proportion of elderly people ). Harleston has low unemployment BUT the vacancies are predominately in low pay and low status jobs. I I hope the above may be of some use. I am not against development as a bred and born Harlestonian I have seen Harleston grow from just under 2000 to present size but I fail to see how we have been treated fairly cf Diss and Aylsham.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21965

Received: 13/03/2020

Respondent: Welbeck Strategic Land III LLP

Agent: Bidwells

Representation:

Object, with comments
We object to the proposed approach to accommodating housing growth in Wymondham.
As detailed in comments made in relation to Question 41, Wymondham, as the second largest settlement in the Greater Norwich
area, is located in a highly sustainable location. This is recognised by the identification of Wymondham in the draft Local Plan as
a ‘contingency’ location that can accommodate 1,000 additional dwellings, if delivery of housing elsewhere in the GNLP area
does not meet local plan targets.
The principle of identifying contingency locations to accommodate additional growth should locations elsewhere in the GNLP
area fail to deliver, is supported. Particularly as it is, as detailed in comments made in relation to Question 13, considered
questionable if the scale of growth forecast in both the Norwich Urban area and fringe parishes, as well as the South Norfolk
Village Clusters, can be considered deliverable in accordance with the NPPF i.e. clear evidence has not been provided to
demonstrate that housing completions will begin on site within 5 years.
Therefore, it is, in our view, highly likely that a contingency site will be required in Wymondham in in order to ensure that local
plan targets in relation to housing delivery are met.
In order to ensure that the policies of the Local Plan are unambiguous in terms of how forecast growth will be met, it is
recommended that rather than identify a contingency site, land in Wymondham should be allocated for housing development.
This will provide certainty for a range of stakeholders, not least the public, and ensure that development, including infrastructure,
can be delivered in a planned and coordinated manner.
However, in the event that the decision to identify contingency sites remains, it is, as per the approach adopted in relation to
Costessey, recommended that a specific site is identified in Wymondham. As well as ensuring a consistent approach between
the policies of the Local Plan it provides certainty, ensuring there is not ambiguity in terms of where growth could be located.
More specifically, the chapter of the draft Site Allocations document relating to Wymondham identifies five Reasonable
Alternatives (assuming the proposed garden villages are excluded). These sites occupy a variety of locations around Wymondham and range in size from 150 to 1,500 units, providing a significant amount of ambiguity as to where future growth will be accommodated.

Full text:

On behalf of Welbeck Strategic Land III LLP, we are instructed to submit representations to the draft 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.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21991

Received: 13/03/2020

Respondent: Redenhall with Harleston Town Council

Representation:

The Town Council agrees with the planners that the other sites on the "List of sites to be considered for residential/mixed use allocation" should be categorised as "Not reasonable alternatives".

Full text:

please find attached the report which was agreed by resolution by Harleston Town Council on March 11th 2020.

Attachments:

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22003

Received: 13/03/2020

Respondent: Redenhall with Harleston Town Council

Representation:

Regarding Policy 7 .2 (The Main Towns), our detailed comments as to new developments were made in the attached. The Town Council feel that drainage, school capacity, healthcare provision and public transport should all be improved to an acceptable level before further development takes place.

Full text:

please find attached the report which was agreed by resolution by Harleston Town Council on March 11th 2020.

Attachments:

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22136

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

In respect of Aylsham, Diss and Harleston, these settlements are more dispersed lying on the peripheries of the local plan area and support wider rural communities in adjoining districts. They have been identified for lower levels of growth than Long Stratton and Wymondham. As such we strongly support the proposed new allocations in these towns which will help these rural communities to prosper and thrive. To this extent, in addition to the preferred allocations, we recommend that further consideration should be given to those sites identified as reasonable alternative allocations to further boost housing supply and support a prosperous rural economy. In particular, as set out in our response to question 41 above, we would encourage the Greater Norwich Local Plan to revisit 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 community benefits.

Full text:

Please see attached for full submission

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22227

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

Representation:

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.

Full text:

Please find attached a full set of representations as follows:

On behalf of Westmere Homes Ltd:

Representations in respect of land at North East Aylsham (Site GNLP0336) comprising:

• Letter L0013: Comments on general policies, prepared by ARP
• Annex 1: Land at North East Aylsham, prepared by ARP
• Enclosure A1: Access Strategy, prepared by Vectos
• Enclosure A2: Landscape and Visual Appraisal, prepared by Aspect Landscape Planning
• Enclosure A3: Heritage Assessment, prepared by Asset Heritage
• Enclosure A4: Landscape Strategy and Site Masterplans, prepared by Aspect Landscape Planning

On behalf of Westmere Homes Ltd and Saltcarr Farms Ltd:

Representations in respect of land at Harvest Close, Hainford (Site GNLP2162) comprising:

• Letter L0013: Comments on general policies, prepared by ARP
• Annex 2: Land at Harvest Close, Hainford, prepared by ARP
• Enclosure H1: Access Strategy, prepared by Vectos
• Enclosure H2: Development Framework Plan, prepared by Aspect Landscape Planning

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22293

Received: 16/03/2020

Respondent: Barton Willmore

Representation:

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.

Full text:

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: 22385

Received: 16/03/2020

Respondent: Pigeon Investement Management Ltd

Agent: Pegasus Group

Representation:

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.

Full text:

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.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22453

Received: 16/03/2020

Respondent: Gladman Developments

Representation:

3.2.1 If allocated, the development of Land at Burston Road, Diss could deliver significant benefits to the
local area and wider community, this includes:
• Development of an appropriate scale for its location, providing for a wide range of tenure,
size and types of new homes;
• The delivery of policy compliant affordable homes;
• Land available for education uses to be discussed with relevant parties;
• Child play provision inclusive of a LEAP;
• A Country Park for the enjoyment of new and existing residents; and
• Potential highways improvements along with pedestrian and cycling links/improvements.

Full text:

Please find attached the representations of Gladman made specifically in relation to our land interest in Diss.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22476

Received: 16/03/2020

Respondent: Breckland District Council

Representation:

Re: Para 328 and 329 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

Full text:

See attachment for officer level response from Breckland Council

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22478

Received: 13/03/2020

Respondent: Mr Eric Hall

Representation:

(Representation on behalf of Marstons Estates Ltd)

Please see attached for full comments
We support the overall growth strategy of the Plan and consider that Diss is appropriately identified as a main town to which significant additional development can be directed.

The site allocations plan does not include any allocation for the subject site and the writer therefore infers that the DIS 6 allocation is effectively removed, leaving the site as unallocated land albeit within a defined settlement boundary; moreover as noted above Diss is considered a suitable location for significant development. If the site were to come forward subsequent to the plan it would be considered a windfall; under Policy 1 this would be acceptable in principle at appropriate scales and locations where they would not have a negative impact on the character and scale of the settlement and subject to other local plan policies.

On this basis we support Policy 1 and do not oppose the removal of DIS 6.

Full text:

Please find attached representations on behalf of Marston’s Estates Ltd.
INTRODUCTION
We act on behalf of Marston Estates Ltd, owners of land to the rear of the Thatcher's Needle public house, Park Road, Diss. Marsyons Estates welcomes the opportunity to comment on the draft strategy and site allocation plan.

BACKGROUND
The site comprises the residue of undeveloped land mainly to the rear of the Thatcher's Needle public house, which was built and is now operated by Marstons. The site is currently part of site allocation DIS 6 in the Site Specific Allocations and Policies DPD adopted in 2015. For convenience the policy is reproduced below
Land amounting to some 1.76 hectares is allocated for retail (non-food goods), leisure,
offices (class A2 only), and housing, with any housing only constituting a small (no more
than 25% by area) proportion of the site.

The developers of the site will be required to ensure:

1. Retail use is limited to non-food goods;
2. Residential use is an integral part of a commercial development (with offices
limited to Class A2);
3. Provision of landscaping to screen the adjacent electricity sub-station;
4. Impacts on TPO trees on Park Road are taken into account;
5. Scheme design takes into account adjacent Conservation Area;
6. Potential for contamination on the site is assessed (and managed appropriately if
any contamination found);
7. Contribution made towards green infrastructure provision at DIS 2 (including
habitat creation along the river)
8. Wastewater infrastructure capacity must be confirmed prior to development taking
place;
9. Norfolk Minerals and Waste Core Strategy Policy CS16 applies, as this site is
underlain by safeguarded mineral resources

PLANNING HISTORY

Outline permission was granted in 2011 for the erection of a 60 bed hotel, a restaurant/public house and associated parking on the site. Detailed consent was granted in 2012 for the restaurant/public house element and this has now been constructed and opened for use.

Permission was refused in 2016 for the erection of 4 No. non food retail units and the refusal supported on appeal on grounds relating to the impact on the conservation area, affect on trees and insufficient evidence being provided on retail policy issues.

A further application was made in 2017 (ref 2017/2053) proposing 3 retail units of 3164 sq m and a 27 bed hotel/lodge of some 745 sq m. The application was subject to long negotiation over the form and appearance of the proposal and its retail impact. Officers recommended refusal and it was refused on grounds of impact on the conservation area and retail impact.

The refusals of these schemes, which are acceptable in principle under the site allocation policy, have led to the owners considering that the adopted policy is moribund and accordingly welcome the opportunity to re-examine future uses for this site. A number of potential uses are being examined from both a planning and commercial perspective.

CONSULTATION PROPOSALS

We support the overall growth strategy of the Plan and consider that Diss is appropriately identified as a main town to which significant additional development can be directed.

The site allocations plan does not include any allocation for the subject site and the writer therefore infers that the DIS 6 allocation is effectively removed, leaving the site as unallocated land albeit within a defined settlement boundary; moreover as noted above Diss is considered a suitable location for significant development. If the site were to come forward subsequent to the plan it would be considered a windfall; under Policy 1 this would be acceptable in principle at appropriate scales and locations where they would not have a negative impact on the character and scale of the settlement and subject to other local plan policies.

On this basis we support Policy 1 and do not oppose the removal of DIS 6.

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22502

Received: 16/03/2020

Respondent: Highways England

Representation:

With regard to Wymondham the proposed reasonable alternative site (contingency) will require a new junction onto the A11. Whilst this is agreeable in principle it will need further investigation.

Full text:

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: 22704

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation:

[On behalf of Scott Properties Ltd]
52. In respect of Aylsham, Diss and Harleston, these settlements are more dispersed lying on the peripheries of the Local Plan area and support wider rural communities in adjoining districts. They have been identified for lower levels of growth than Long Stratton and Wymondham. As such we strongly support the proposed allocations in these towns which will help these rural communities to prosper and thrive. To this extent, in addition to the preferred allocations, we recommend that further consideration should be given to those sites identified as reasonable alternative allocations to further boost housing supply and support a prosperous rural economy. In particular, we strongly support the proposed allocation of sites such as the land at Briar Farm, Harleston (GNLP2136) which are included as preferred options and provide for positive growth in relation to the settlement hierarchy, infrastructure and local constraints. In respect of our clients site, Land at Briar Farm, Harleston it will not only provide much needed housing, but also specialist homes C3 care accommodation, along with a retail area, and extensive open space and recreational facilities. The site is available now and developable, it can come forward and start to deliver significant numbers of new homes in the first five years of the Plan period and because of the mix of residential units there will be a wider range of market demand so that delivery is not restricted due to concerns about market saturation.
53. In summary, the site is immediately available for development and delivery could be completed within a short term period.

Full text:

Please find attached the following documentation forming a consultation representation for the Greater Norwich Local Plan: Stage C Regulation 18 Draft Strategy and Site Allocations on behalf of my colleague, Adam Davies.

- Completed document for the following documents and questions:
- Draft Greater Norwich Local Plan – Part 1 The Strategy
- Question 6
- Question 9
- Question 11
- Question 12
- Question 13
- Question 14
- Question 16
- Question 17
- Question 18
- Question 25
- Question 29
- Question 32
- Question 41
- Question 42
- Question 48
- Draft Local Plan – Part 2 Site Allocations
- Policy GNLP2136
- Greater Norwich Local Plan Interim Viability Study (November 2019)
- Proving Layout
- Parameter Plan
- Pedestrian Access Plan
- Highways Technical Note
- Vehicular Access Proposals
- Barley Close Pedestrian Link
- Utilities Assessment
- Flood Risk Technical Note
- Infiltration Testing
- Preliminary Surface Water Attenuation Calculations
- Bat Scoping and Activity Survey
- Great Crested Newt and Amphibian Survey
- Reptile Survey
- Arboricultural Survey
- Archaeological and Heritage Assessment
- Noise Assessment

Attachments:

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22745

Received: 16/03/2020

Respondent: Rosconn Group

Representation:

RSL wish to comment on Policy 7.2 and the associated text with specific reference to Long Stratton. At paragraph 326, it is stated that due to the scale of existing commitments in the settlement, the Plan does not make any further allocations in addition to Long Stratton’s Action Area Plan. It then goes on to state that evidence shows that the scale of commitments means that parts of the site allocated in the AAP will not be delivered until after 2038. We cannot locate the evidence referred to at footnote 104 ‘Analysis of Commitments’ and the Councils have been unable to confirm where this is located.

In reviewing the circumstances, it is clear that the allocation of land to the east of Long Stratton in the AAP (2016) for approximately 1,800 dwellings was in order to aid the delivery of the Long Stratton bypass. The AAP seeks the delivery of at least 1,800 dwellings by 2026, with no more than 250 dwellings to be occupied until such time as the bypass is completed. Funding for the bypass, as detailed within the AAP, is to be from a number of sources including developer contributions (S106/CIL). Clearly the development itself is unable to fully fund the cost of the bypass, particularly as it is to be completed in advance of the majority of housing being completed. Of the total budget of £29m, it is understood that £10m has already been secured via the City Deal, but the remaining £19m has yet to be secured. The construction of the bypass had originally intended to start in 2020 with completion by 2022. More recent evidence suggests construction will now start in 2020.

In terms of the delivery of the 1,800 dwellings and associated bypass, two planning applications were made in January 2018 for the two principal elements of the overall development and the bypass. These applications however remain undetermined as they are the subject of a holding objection from the Highways Agency in view of the potential implications of the wider development on the operation of the A47 trunk road and in particular its junction with the A140. As such, it appears unlikely that the bypass will commence construction during 2020.

As such, it is apparent that the strategic allocation at Long Stratton has been severely delayed, as has progress on delivering the bypass. It is therefore unlikely that any meaningful housing numbers will be delivered from these sites within the next 5 years and it is difficult to see more than 100 dwellings being delivered by 2026 compared with the 1,800 envisaged in the 2016 AAP. Furthermore, there is serious doubt about whether any meaningful development will be delivered from this site by 2038 and probably significantly less than has been assumed when determining commitments from this particular allocation. However, the AMR 2018/19 does not provide sufficient detail to determine what has been assumed to contribute towards the overall housing commitment identified within Policy 1 and the ‘Analysis of Commitments’ referred to at paragraph 326 cannot be provided by the Councils at this time.

The implications of a failure to bring forward the strategic allocation at Long Stratton, alongside the delivery of the bypass have serious consequences for the settlement and the wider area in a number of ways which have serious social, economic and environmental consequences. In such circumstances, RSL consider that scope to bring forward a further housing site within the settlement should be given serious consideration. This would have potential benefits in helping to address short term local housing needs, provides scope to provide additional funding to address the funding gap for the bypass, whilst making a meaningful contribution to the wider delivery of housing within the Greater Norwich area in a highly sustainable location that aligns with the overall spatial strategy of the emerging Local Plan.

RSL are promoting land to the south of Flowerpot Lane, Long Stratton and further details of this site are provided in the separate Call for Sites submission in view of the fact the land has not been promoted previously. This is an unconstrained site which is well-related to the south western edge of the settlement and is available, deliverable and suitable. It offers scope for a smaller site for approximately 150 dwellings, or a larger scheme in the region of 700 dwellings. RSL would welcome the opportunity of discussing the site’s potential in greater detail with the authorities.

Full text:

Re: Greater Norwich Local Plan – Regulation 18 Draft Plan Consultation

We write in response to the consultation of the above document.

Rosconn Strategic Land (RSL) welcome the opportunity to comment on the Draft GNLP and having reviewed the document and its supporting evidence, provide comments below. RSL represent the owners of land to the south of Flowerpot Lane, Long Stratton who we have entered into a promotion agreement with in order to promote their land for residential development. The site has not previously been considered for development by the Councils and as such, a completed Site Submission Form also accompanies these representations which demonstrates it is suitable, available and deliverable.

Part 1 – The Strategy

Question 9

RSL fully support the overall purpose of the Delivery Statement which recognises the importance of inclusive growth and sustainable development, and more specifically the acknowledgment of the interrelationship between the delivery of housing, jobs and infrastructure.

In terms of Housing, again we generally support a pro-active approach of only allocating housing sites where there is a reasonable prospect that their delivery, taking account of policy requirements in the Plan, can be evidenced. However, it is notable that approximately 83% of the minimum Local Housing Need figure is to be delivered through existing commitments, some of which are from sites already allocated in existing development plans. These existing development plans include the 2011 Joint Core Strategy, alongside subsequent Site Allocations and Area Action Plans dating from 2014-2016.

It is not clear from the evidence provided to date what proportion of the commitments are on sites for which no planning permission has yet been secured despite being allocated for several years, but there is certainly some indication that not all historic allocations are likely to remain deliverable, particularly in the context of a more stringent national planning policy framework. Furthermore, in reviewing the latest Annual Monitoring Report 2018-19, it is stated at paragraph 3.21 that despite recent successes, housing delivery overall within the Greater Norwich area has fallen 4,255 homes below the JCS target since the start of the plan period, with the under delivery resulting in housing shortfalls in the NPA that total 6,076 homes, with shortfalls particularly acute in the Broadland part of the NPA. It concludes by stating that it remains a significant challenge to achieve and sustain a level of delivery that would enable the JCS housing target to be met by 2026.

It is also notable that footnote 45 of the Delivery Statement in respect of Housing, states that housing allocations in the Draft Plan will only be carried forward to the Submission Version of the Plan if evidence is presented to show that they will be delivered by 2038. Whilst we would support this approach, we would encourage the authorities to rigorously review the deliverability of long-standing allocated housing sites which have not progressed to date. Similarly, those sites with outline planning permissions where reserved matters have not followed in a reasonable period of time should also be carefully scrutinised to determine whether they remain deliverable during the plan period.

Question 11

Again, RSL generally support the overarching approach with respect to prioritising the benefits and delivery of infrastructure in order to benefit existing communities, support growth and improve connectivity. However, alongside the other providers mentioned, recognition should also be given to the development industry’s role in bringing forward key infrastructure. They are often central to the funding and delivery of infrastructure alongside new housing and economic development, which benefits the wider community.

Question 13

Whilst RSL generally agree with the proposed settlement hierarchy, there appears to be no explanation within Policy 1 or elsewhere, as to what the purpose of the hierarchy is other than to confirm that this has been used to inform the distribution of growth. Whilst paragraph 166 confirms which settlements fall into which level of the hierarchy, there appears to be no explanation as to what the role and function of each tier in the hierarchy is. It is therefore difficult to comment on whether the proposed distribution of growth within the hierarchy is appropriate or not. It would therefore assist the reader if the role and function for each tier in the hierarchy could be clearly set out within the policy or otherwise within the explanatory text.

Notwithstanding the above, further explanation is required as to the role and function of the Stratgeic Growth Area (SGA). Whilst Policy 1 and paragraph 166 state that it is the settlement hierarchy that has guided the distribution of growth, this appears to then be contradicted by the statement at paragraph 169 which suggests that the strategy is to direct 78% of the growth to the SGA. It is therefore unclear whether it is the settlement hierarchy or the SGA that have influenced the distribution of growth and this should be clarified.

In terms of the distribution of growth, Policy 1 states that growth has been distributed in line with the settlement hierarchy to provide good access to services, employment and infrastructure. However, in reality, the majority of growth (83% of the minimum Local Housing Need) is already committed through historic allocations and existing permissions, 72% of which are within the Norwich Urban Area. Considering the overall geographical scale of the 3 authorities, this is a significant amount of development committed to a relatively small area. Whilst it is agreed that a large proportion of growth should be located in and around the principal settlement within the Plan area, directing further growth through new allocations to an area which is already well-catered for in terms of future growth is questionable, particularly from a deliverability perspective. Is it realistic to expect that the scale of growth already committed, alongside an additional 4,395 homes through new allocations is likely to be deliverable within the Plan period? The evidence referred to earlier has highlighted the real challenge to achieving the levels of growth identified for the NPA through the current JCS. Directing further growth to this area must therefore raise concerns about whether this is a justified and effective strategy. Furthermore, will this achieve the objectives set out at paragraph 164, particularly (4) focussing a reasonable level of growth in the main towns, key service centres and village clusters to support a vibrant rural economy, and (6) allocating a significant number of medium and smaller scale sites in towns and villages to provide a balanced range of site types to allow choice, assist delivery and allow smaller scale developers and builders into the market?

In summary, RSL object on the basis that further consideration should be given to directing a greater proportion of the residual housing requirement through new allocations towards the Main Towns and Key Service Centres, particularly those that are located outside the SGA in order to enable the sustainability benefits of housing growth to be distributed more widely and fairly. Settlements such as Long Stratton and Aylsham for instance play a wider role in serving a principally rural hinterland and growth can assist in maintaining and enhancing services and facilities that these wider rural communities are reliant on. This approach would remain aligned with the preferred growth option of directing the majority of growth around the Norwich Urban Area and within the SGA, whilst allowing a greater level of dispersal to support thriving rural communities. Such an approach is also likely to be more deliverable than the current “all the eggs in one basket” approach where almost all of the growth is directed to the Norwich Urban Area / SGA with very little being directed to the rural communities elsewhere within the plan area. This is not considered to be consistent with the objectives of paragraph 78 of the NPPF.

Question 14

Policy 1 states that there is a need for ‘around 40,550 new homes’ during the plan period 2018-2038. Table 6 confirms that the Local Housing Need figure, being the minimum local housing need figure as calculated using the Government’s standard methodology is 40,541 dwellings. The PPG ‘Housing and economic needs assessment’ states at paragraph 2 that the standard method identifies a minimum annual housing need figure but does not produce a housing requirement figure. Paragraph 10 then explains when it may be appropriate to plan for a higher housing need figure than the standard method indicates. It also reiterates the Government’s commitment to more homes being built and support for ambitious authorities who want to plan for growth. In also confirming that the local housing need figure provides only a minimum starting point in determining the number of homes needed in an area, it acknowledges that it does not attempt to predict the impact of future government policies, changing economic circumstances or other factors that might have an impact on demographic behaviour. As such, it then outlines some of the circumstances where it may be appropriate to plan for a higher number of houses. This includes where growth strategies are proposed (e.g. Housing Deals), strategic infrastructure is planned or where an authority agree to take on unmet need from a neighbouring authority.

RSL consider that the housing requirement set out in the Plan should be described as a minimum and not be seen as a ceiling on a greater level of housing coming forward during the Plan period, so that it is consistent with the NPPF’s focus on significantly boosting the supply of housing. It is also considered that the housing requirement within the Draft Plan does not reflect government guidance in that it only proposes to meet the minimum starting point figure and no evidence has been provided to support why this decision has been made or why it is considered to be appropriate. It is notable that the Draft Plan also sets an objective to deliver around 33,000 new jobs by 2038, this target being derived from an analysis of ‘enhanced growth’.

The Strategy Advice document of December 2017 highlights that the detailed assessment of the Greater Norwich sub-region set out within the Employment Land Assessment confirms the considerable potential of the area in the future to achieve significant levels of economic growth based on an assessment of the key economic assets and drivers within the Greater Norwich economy. It continues that these strengths suggest that the growth potential of Greater Norwich extends beyond ‘business as usual’ base growth, leading to GVA’s assessment which identifies an ‘enhanced’ growth scenario that maximise the area’s economic growth potential. This is due to the area having a strong foundation of academic and commercial research, an increasingly entrepreneurial economy, a base of internationally recognised businesses and a diverse property portfolio which suggest Greater Norwich is well positioned nationally and internationally to compete for future business investment as well as continuing to grow its own business base. The document does however highlight at paragraph 2.7 that the base model used to develop the future employment growth does include an assumed level of population growth to balance jobs growth with labour supply and migration, albeit recognising this does not necessarily align with objectively assessed housing needs.

Policy 6 later on in the Draft Plan further elaborates on the proposed economic growth strategy for the area which makes reference to supporting and delivering the ambitions of a series of other related strategies such as the LEP’s Economic Strategy and Local Industrial Strategy, the Cambridge Norwich Tech Corridor initiative and the enhanced growth outlined in the Greater Norwich City Deal, as well as acknowledging the wider benefits of linkages to the Oxford Cambridge Arc and the London Stansted Cambridge corridor.

In such circumstances, RSL object and consider that the authorities should consider a meaningful uplift to the minimum Local Housing Need figure to help support and deliver the ambitious, above-trend economic growth strategy that the Draft Plan is seeking to deliver.

In other respects, reference is made at paragraph 159 to the fact that the housing figures within Policy 1 make provision for a 9% buffer over and above the minimum Local Housing Need figure. Notwithstanding comments above regarding the need to uplift the housing requirement to reflect economic growth aspirations, 9% is not considered to be sufficient when considered in the context of the overall scale of housing need within the 3 authorities and the fact the majority of this is being met by long-standing housing allocations many of which have failed to come forward as planned. In such circumstances, RSL object and consider a much larger buffer of 20% would be more appropriate to ensure there is flexibility in the housing supply to respond to rapid changes, as required by paragraph 11 of the NPPF.

It is acknowledged that some additional flexibility is offered, as detailed at paragraph 162 with reference to a proposed contingency site for 1,000 dwellings at Costessey and potentially a further 1,000 dwellings contingency site at Wymondham, albeit no specific site has been identified at present. Whilst RSL are supportive of the principle of identifying contingency sites, we do object to the approach to allocating such large strategic sites and the decision on where such sites should be located. Contingency sites should, by their very nature, be ‘oven-ready’ sites that could be delivered quickly in order to meet a shortfall in the housing land supply until such time as allocated sites are able to deliver. Allocating one or two strategic sites of 1,000 dwellings are likely to face similar difficulties to the sites they are seeking to supplement in view of longer lead-in times compared to smaller sites. A more credible solution would be to identify a greater number of smaller sites in a variety of locations that could collectively bring forward housing quickly to address short term shortfalls in housing supply. Geographically, as highlighted earlier in our representations, identifying contingency sites in the same location as the majority of allocated housing sites is more than likely to result in a similar fate. A much more credible approach would be to identify contingency sites in a range of locations across the Plan area to maximise their ability to address a rapid change in circumstances and avoid any potential localised issues that may arise in the housing market, such as absorption rates in the Norwich Urban Area as a result of multiple housing sites competing against each other in a very small geographical area. Therefore, distribution of some or all of the contingency sites outside the Norwich Urban Area may be a more effective and justified approach than the one currently proposed.

Question 15

In connection with our response to Question 14 above, it is not clear whether the economic growth ambitions of Policy 6 are fully consistent with the housing requirement set out within the Plan. Moreover, is there any evidence to indicate that 40,541 dwellings in the period to 2038 is sufficient to support the economic aspirations of the emerging Plan to 2038? Until such time as this is clarified, we wish to maintain an objection that the economic objectives are not deliverable, justified or effective due to a lack of suitable housing for the employees required to service future jobs growth or otherwise, there is likely to be an increase in in-commuting to the area from outside in order to service these newly arising jobs which would not be a sustainable approach to adopt.

Question 16

RSL support the intention that the five-year housing land supply should be calculated on the basis of the whole of the Greater Norwich area.

Question 42

RSL wish to comment on Policy 7.2 and the associated text with specific reference to Long Stratton. At paragraph 326, it is stated that due to the scale of existing commitments in the settlement, the Plan does not make any further allocations in addition to Long Stratton’s Action Area Plan. It then goes on to state that evidence shows that the scale of commitments means that parts of the site allocated in the AAP will not be delivered until after 2038. We cannot locate the evidence referred to at footnote 104 ‘Analysis of Commitments’ and the Councils have been unable to confirm where this is located.

In reviewing the circumstances, it is clear that the allocation of land to the east of Long Stratton in the AAP (2016) for approximately 1,800 dwellings was in order to aid the delivery of the Long Stratton bypass. The AAP seeks the delivery of at least 1,800 dwellings by 2026, with no more than 250 dwellings to be occupied until such time as the bypass is completed. Funding for the bypass, as detailed within the AAP, is to be from a number of sources including developer contributions (S106/CIL). Clearly the development itself is unable to fully fund the cost of the bypass, particularly as it is to be completed in advance of the majority of housing being completed. Of the total budget of £29m, it is understood that £10m has already been secured via the City Deal, but the remaining £19m has yet to be secured. The construction of the bypass had originally intended to start in 2020 with completion by 2022. More recent evidence suggests construction will now start in 2020.

In terms of the delivery of the 1,800 dwellings and associated bypass, two planning applications were made in January 2018 for the two principal elements of the overall development and the bypass. These applications however remain undetermined as they are the subject of a holding objection from the Highways Agency in view of the potential implications of the wider development on the operation of the A47 trunk road and in particular its junction with the A140. As such, it appears unlikely that the bypass will commence construction during 2020.

As such, it is apparent that the strategic allocation at Long Stratton has been severely delayed, as has progress on delivering the bypass. It is therefore unlikely that any meaningful housing numbers will be delivered from these sites within the next 5 years and it is difficult to see more than 100 dwellings being delivered by 2026 compared with the 1,800 envisaged in the 2016 AAP. Furthermore, there is serious doubt about whether any meaningful development will be delivered from this site by 2038 and probably significantly less than has been assumed when determining commitments from this particular allocation. However, the AMR 2018/19 does not provide sufficient detail to determine what has been assumed to contribute towards the overall housing commitment identified within Policy 1 and the ‘Analysis of Commitments’ referred to at paragraph 326 cannot be provided by the Councils at this time.

The implications of a failure to bring forward the strategic allocation at Long Stratton, alongside the delivery of the bypass have serious consequences for the settlement and the wider area in a number of ways which have serious social, economic and environmental consequences. In such circumstances, RSL consider that scope to bring forward a further housing site within the settlement should be given serious consideration. This would have potential benefits in helping to address short term local housing needs, provides scope to provide additional funding to address the funding gap for the bypass, whilst making a meaningful contribution to the wider delivery of housing within the Greater Norwich area in a highly sustainable location that aligns with the overall spatial strategy of the emerging Local Plan.

RSL are promoting land to the south of Flowerpot Lane, Long Stratton and further details of this site are provided in the separate Call for Sites submission in view of the fact the land has not been promoted previously. This is an unconstrained site which is well-related to the south western edge of the settlement and is available, deliverable and suitable. It offers scope for a smaller site for approximately 150 dwellings, or a larger scheme in the region of 700 dwellings. RSL would welcome the opportunity of discussing the site’s potential in greater detail with the authorities.

Part 2 – Site Allocations

In respect of Long Stratton, RSL wish to object to the fact that no allocations are proposed within the Part 2 Draft Plan. The reasoning for the Councils approach on this matter is that, despite the settlement being identified as a Main Town, there is already a total deliverable housing commitment for Long Stratton of 1,892 homes between 2018-2038.

As highlighted in our comments to Part 1, there are no deliverable planning permissions in respect of the sites allocated at Long Stratton within the Action Area Plan (2 planning applications are pending since January 2018). Paragraph 326 of Part 1 of the Draft Plan also confirms that evidence (which is not available) shows that the scale of the commitments means that part of the site allocated in the AAP will not be delivered until after 2038. It also confirms there may be additional capacity within the existing allocations but these are unlikely to be delivered until late in the plan period or beyond. Finally, it is also apparent that the bypass that is required to help deliver the existing commitments has been delayed and is not fully funded, which calls into question whether this is likely to further undermine the timely delivery of these existing sites unless the funding gap of circa £19m can be found. In the circumstances, RSL are concerned that the approach adopted is not sound, both in respect of the fact that the overall housing requirement for the authorities may not be achievable and that housing growth and the associated benefits within Long Stratton, one of the plan area’s most sustainable settlements, may not be achieved.

In considering ‘Reasonable Alternatives’, it is noted that the Part 2 document states “No Reasonable Alternative Sites”. However, the accompanying ‘Main Towns Assessment Booklet’ for Long Stratton concludes that following detailed assessment, 3 sites were identified as reasonable alternatives, but later in the document it states that in order to allow permitted housing sites in Long Stratton to be developed and existing service capacity to be clarified, there will be no new allocations in the GNLP. As such, it concludes that it considers there are no reasonable alternatives to this approach.

In light of the circumstances, in that the delivery of the allocated (but not permitted) sites is unlikely to occur fully during the Plan period, considering reasonable alternatives is clearly an alternative approach that should have been considered as part of the Plan-making process. This is particularly important if such alternatives are able to assist in helping to contribute towards addressing the current funding gap that exists in respect of the bypass, critical to facilitating planned growth and the associated benefits for existing residents and other road users.

In considering reasonable alternatives, RSL request that the land south of Flowerpot Lane, Long Stratton should also be considered in these terms. Whilst the site has not been previously considered through the HELAA, we enclose a copy of a completed Call for Sites submission form and OS Plan which provide further details of the site. These demonstrate the suitability, availability and deliverability of the site which is well-related to the urban area and capable of being brough forward in full during the Plan period. Importantly, it can also make a meaningful contribution towards funding the Long Stratton bypass, thereby helping to facilitate the delivery of wider strategic growth in the area.
We trust the above comments are of assistance and we welcome the opportunity to engage further during the preparation of the Greater Norwich Local Plan and/or to discuss our site in further detail with you. If in the meantime there are any queries or further information is required, please do not hesitate to contact me.