Question 43. Do you support or object or wish to comment on the approach for the key service centres overall? Please identify particular issues.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20998
Received: 14/03/2020
Respondent: Mr Keith Benjafield
The green belt between Wymondham and Hethersett should not be encroached any more than it currently is .
The green belt between Wymondham and Hethersett should not be encroached any more than it currently is .
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21284
Received: 16/03/2020
Respondent: Hannah Guy
We support the continued inclusion of Loddon within the settlement hierarchy of a Key Service Center. The village is highly sustainable, has good road access network and accessibility to the wider Norfolk area, it provides facilities such as education, employment and tertiary services for the community.
We support the continued inclusion of Loddon within the settlement hierarchy of a Key Service Center. The village is highly sustainable, has good road access network and accessibility to the wider Norfolk area, it provides facilities such as education, employment and tertiary services for the community.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21329
Received: 16/03/2020
Respondent: Hardingham Farms Ltd
Agent: Lanpro Services Ltd
More new housing allocations should be apportioned to key service centres than to village clusters in recognition of their higher tier within the growth heirarchy.
Key Service Centres are identified under draft Policy 1 of the Regulation 18 Stage C Consultation Document as a third-tier settlement, with growth proposed to these areas after the ‘Norwich Urban Area’, and the ‘Main Towns’.
Despite their position in the hierarchy, only 515 new homes are proposed to come forward through new allocations within all nine Key Service Centres. This compares to a minimum of 1,680 homes that are proposed to come forward in the lower (fourth) tier, ‘Village Clusters’.
Whilst Hardingham Farms Ltd recognise the benefits to be delivered to the vitality of rural areas through allocating some new sites and thus increasing footfall within small village locations, it is considered both unsustainable and inappropriate to apportion a greater amount of growth to these areas than to the higher order Key Service Centres which it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.
More new housing allocations should, therefore, be apportioned to key service centres than to village clusters in recognition of their higher tier within the growth heirarchy.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21339
Received: 16/03/2020
Respondent: Lanpro Services
Agent: Stephen Flynn
Lanpro consider it both unsustainable and inappropriate to apportion a greater amount of growth to small village locations than to the higher order Key Service Centres which, it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.
Key Service Centres are identified under draft Policy 1 of the Regulation 18 Stage C Consultation Document as a third-tier settlement, with growth proposed to these areas after the ‘Norwich Urban Area’, and the ‘Main Towns’.
Despite their position in the hierarchy, only 515 new homes are proposed to come forward through new allocations within all nine Key Service Centres. This compares to a minimum of 1,680 homes that are proposed to come forward in the lower (fourth) tier, ‘Village Clusters’.
Whilst Lanpro recognise the benefits to be delivered to the vitality of rural areas through allocating some new sites and thus increasing footfall within small village locations, it is considered both unsustainable and inappropriate to apportion a greater amount of growth to these areas than to the higher order Key Service Centres which it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.
With specific reference to draft Policy 7.3 of the Regulation 18, Stage C Consultation Document, Lanpro object to the Council’s decision not to allocate any additional sites for residential development within the Poringland / Framinghams area, which is sustainably located within the old NPA. This decision appears to be neither justified or positively prepared, nor to have been sufficiently tested and is therefore considered ‘unsound’.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21417
Received: 16/03/2020
Respondent: Glavenhill Ltd
Agent: Stephen Flynn
Glavenhill Ltd consider it both unsustainable and inappropriate to apportion a greater amount of growth to small village locations than to the higher order Key Service Centres which, it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.
Key Service Centres are identified under draft Policy 1 of the Regulation 18 Stage C Consultation Document as a third-tier settlement, with growth proposed to these areas after the ‘Norwich Urban Area’, and the ‘Main Towns’.
Despite their position in the hierarchy, only 515 new homes are proposed to come forward through new allocations within all nine Key Service Centres. This compares to a minimum of 1,680 homes that are proposed to come forward in the lower (fourth) tier, ‘Village Clusters’.
Whilst Glavenhill Ltd recognise the benefits to be delivered to the vitality of rural areas through allocating some new sites and thus increasing footfall within small village locations, it is considered both unsustainable and inappropriate to apportion a greater amount of growth to these areas than to the higher order Key Service Centres which it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.
With specific reference to draft Policy 7.3 of the Regulation 18, Stage C Consultation Document, Glavenhill Ltd object to the Council’s decision not to allocate any additional sites for residential development within the Poringland / Framinghams area, which is sustainably located within the old NPA. This decision appears to be neither justified or positively prepared, nor to have been sufficiently tested and is therefore considered ‘unsound’.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21617
Received: 16/03/2020
Respondent: Hingham Town Council
Hingham has been designated as a Key Service Centres, at no point in the document is there a definition for a “Key Service Centre”. The lack of concrete criteria for a “Key Service Centre” renders the designation of such an entity meaningless.
Hingham has been designated as a Key Service Centres, at no point in the document is there a definition for a “Key Service Centre”. The lack of concrete criteria for a “Key Service Centre” renders the designation of such an entity meaningless.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21777
Received: 16/03/2020
Respondent: Brown & Co
As with the approach to the urban fringe parishes and the main towns, we would raise concerns regarding the deliverability, and sustainability of additional ‘bolt-on’ developments in these locations. Such continuing urban sprawl is not considered to represent truly sustainable development, can often result in the creation of non-walkable neighbourhoods separated from services and facilities, places increased pressure on local infrastructure, and often comprise identikit housing which fail to adequately respect local character and create community cohesion.
As with the approach to the urban fringe parishes and the main towns, we would raise concerns regarding the deliverability, and sustainability of additional ‘bolt-on’ developments in these locations. Such continuing urban sprawl is not considered to represent truly sustainable development, can often result in the creation of non-walkable neighbourhoods separated from services and facilities, places increased pressure on local infrastructure, and often comprise identikit housing which fail to adequately respect local character and create community cohesion.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22045
Received: 13/03/2020
Respondent: East Suffolk Council
We support the approach in The Key Service Centres policy.
The Council would like to take the opportunity to express its support for the Greater Norwich Local Plan Draft Strategy.
Section 1 – Introduction
Paragraph 15 refers to a plan period to 2036. This needs amending to 2038, as noted elsewhere in the document.
Section 2- Greater Norwich Spatial Profile
Paragraph 70 notes that the A146 forms part of the Government’s Major Road Network (MRN) of local non-trunk roads of national importance. East Suffolk is pleased that the importance of the A146 has been recognised as it is a key link between Lowestoft, Beccles and Norwich. The Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report (March 2018) notes that the A146 Norwich Road/Loddon Road and the A146 Norwich Road/A143 Yarmouth Road are two junctions that will reach 90-99% capacity by end of the Waveney Local Plan period, 2036. The two junctions are close to Beccles but fall within the South Norfolk Council/Greater Norwich area. Measures to address traffic issues on the A146 near Beccles are likely to be necessary in future reviews of Local Plans. (See page 36 of The Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report (March 2018) https://www.eastsuffolk.gov.uk/assets/Planning/Waveney-Local-Plan/Background-Studies/Suffolk-County-Council-Forecast-Highway-Modelling.pdf)
It may be of interest to the Greater Norwich Planning Policy Team to know that the Barnby Bends bypass Major Route Network improvement proposal has progressed to the next stage with funding to prepare an outline business case. Improvements to the section of the A146 near Barnby, commonly known as the Barnby Bends, would benefit the whole A146 route between Lowestoft and Norwich, and the A143 link to Diss and Bury St Edmunds.
Paragraph 73. The Norwich rail service provides direct access to Lowestoft. Please update the text to include Lowestoft in the list of rail destinations accessible from Norwich.
Section 3 – The Vision and Objective for Greater Norwich
Paragraph 108. The Council supports the overall vision and objectives of the Greater Norwich Local Plan.
Paragraph 111 would benefit from explaining what the term ‘clean growth’ means. The terms ‘clean growth’, ‘clean transport’, ‘clean pubic transport’, ‘clean energy’ and ‘clean water’ are used through the document without explanation. It should not be assumed the audience is already familiar with specific terms and jargon. The terms should be explained in the text or included in the glossary in Appendix 2.
Policy 1 – The Sustainable Growth Strategy
We support the Greater Norwich Local Plan’s preferred option to support growth, including the use of the Government’s standard methodology for assessing housing numbers and delivery, use of a settlement hierarchy, and approach to the economy. We are pleased the strategy for growth can meet the area’s need for housing, including a buffer, and need for employment land.
Policy 2 – Sustainable Communities
Issue No.2 in Table 8 would benefit from more specific and detailed information to facilitate electric and low-emission vehicles and their ancillary infrastructure needs. Developers should be encouraged to provide electric charging points for dwellings with on-plot parking spaces, and to provide ducting and electricity supply to communal and public parking spaces to enable future installation of charging points. This would complement policies for East Suffolk (contained in the adopted Waveney Local Plan and the emerging Suffolk Coastal Local Plan) on facilities for electric charging points, by enhancing provision in the wider network.
A Housing Design Audit for England by Place Alliance (see http://placealliance.org.uk/research/national-housing-audit/) found that lower building densities on projects away from the urban core scored poorly in design and there were clear benefits to designing at higher densities with the best schemes averaging 56 dwellings per hectare. This research may be of interest regarding the minimum densities specified in point 4 of the policy.
The Royal Town Planning Institute has produced detailed guidance on how developments can be designed to support people with dementia by creating familiar, legible, distinctive, accessible, comfortable and safe environments. The application of dementia friendly design principles is considered to result in a higher quality environment for all users. Considering the aging population in the Greater Norwich area, and the surrounding area, and rise in dementia, it is advisable to incorporate dementia friendly design principle where appropriate, especially in larger housing developments. (See https://www.rtpi.org.uk/media/1312/dementiatownplanning-practiceadvice2017.pdf) Issue No.7 in Table 8 would benefit from specifically referencing dementia friendly design principles. This would complement the policies in the adopted Waveney Local Plan and the emerging Suffolk Coastal Local Plan.
Overall, we support the approach of the sustainable communities policy and requirement for a sustainability statement.
Policy 3 – Environmental Protection and Enhancement
We support the approach to the built and historic environment as it is in accordance with the NPPF.
Policy 4 – Strategic Infrastructure
We support the approach in the Strategic Infrastructure policy.
Policy 5 – Homes
We are pleased that the Greater Norwich area can meet the housing need, including a buffer, as identified using the Government’s standard methodology, and support the approach in the Homes policy.
Policy 6 – The Economy
We support the approach in The Economy policy.
Policy 7.1 – The Norwich Urban Area including the fringe parishes
We support the approach in The Norwich Urban Area policy.
Policy 7.2 – The Main Towns
We support the approach in The Main Towns policy.
Policy 7.3 – The Key Service Centres
We support the approach in The Key Service Centres policy.
Policy 7.4 – Village Clusters
The Waveney Local Plan identifies Beccles and Bungay as two of the five Market Towns for housing growth in the former Waveney area. The total growth from homes built, existing commitments and allocations in the Waveney Local Plan for 2014-2036 are 1,458 dwellings for Beccles and Worlingham and 557 dwellings for Bungay. Both Beccles and Bungay boarder the South Norfolk/Greater Norwich area. Any housing development in villages close to the former Waveney area is highly likely to impact high schools, medical centres, shops and other services and facilities in Beccles and Bungay. Housing development in the wider South Norfolk area is highly likely to impact traffic on the A146, which is an important link between Lowestoft and Norwich. Junctions on the A146 close to Beccles will be close to capacity by the end of the Waveney Local Plan period in 2036.
The future allocation of 1,200 new dwellings in village clusters in a South Norfolk Village Clusters Housing Allocations Document should take into consideration the impact on services and facilities in East Suffolk and the overall combined impact of proposed development in South Norfolk and the former Waveney areas on the A146. The Council would wish to be notified of progress on the South Norfolk Village Clusters Housing Allocations Document.
We support the overall approach of allocating housing growth in villages to promote their social sustainability and support rural life and services.
Policy 7.5 – Small Scale Windfall Housing Development
We support the approach in the Small Scale Windfall Housing Development policy
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22191
Received: 16/03/2020
Respondent: Environment Agency (Eastern Region)
The definition of green infrastructure in the Glossary seems to imply that the plan is not taking the broader definition to include natural habitats into account. The plan must specifically address mitigation and compensation for loss of natural habitats (this is also relevant to Policy 7.2). We would like to see a target % of green infrastructure to be provided within a development.
Site Allocations
The quality of the water from new developments is our primary concern about those near chalk streams. Chalk streams are naturally low in nutrients and have good water quality. There are risks due to car washing, use of herbicides in gardens, run off from roads contaminated with salt and chemicals from cars. The plan needs to ensure that the provision of SuDS is appropriate and follows design guidance. New developments must undertake a WFD compliance assessment to ensure that they do not cause and deterioration and do not compromise our ability to meet Good WFD status.
The plan should also identify areas (outside of land allocations) where small developments would need to rely of de-minimus abstraction 20m3 per day (where there is no potable water supply). This kind of development would have negative impacts on an area already under water stress so these areas should be identified and development restricted.
Please see attached for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22294
Received: 16/03/2020
Respondent: Barton Willmore
Q43 - 44) Consultation Questions for Policy 7.3 – The Key Service Centres
2.88 We support the identification of the Key Services Centres as locations which have an important role to play within the overall settlement hierarchy, providing facilities and services to serve the settlement and its hinterland.
2.89 Of these, the Draft Strategy only seeks to allocation additional land in Acle, Blofield, Hingham and Loddon/Chedgrave for housing, totalling 515 dwellings. 2.90 With the exception of Hethersett, which has a significant existing deliverable commitment, none of the Key Service Centres are located within the Cambridge Norwich Growth Corridor. However, Poringland, Hethersett, Brundall and Blofield are located within the Norwich Policy Area and, additional to these, Acle is located within the SHMA Core Area.
2.91 Whilst we do not object to the approach to allocating a limited level of development to the Key Service Centre, in line with our comments in respect of the Main Towns, the strategy needs to be justified, including ensuring it aligns with the Plan’s Vision and Aims. As currently drafted, it is unclear why settlements outside of the NPA/Core Area (the area with the strongest functional connection to Norwich) have been chosen in place of those within it. Q45 - 46) Consultation Questions for Policy 7.4 – The Village Clusters
2.92 We object to the approach advocated for the village clusters. Whilst it is acknowledged that these can make a vital contribution towards meeting housing and other growth requirements across the Plan Period, to arbitrarily allocate 1,200 additional homes is not justified or supported by clear evidence. We would argue it conflicts with the principles of sustainable development, and that growth should be focused on larger settlements, particularly those in more sustainable locations, such as the A11 corridor, served by rail and within the Cambridge – Norwich Tech Corridor.
2.93 Paragraph 25 of the Draft Strategy acknowledges that whilst the GNLP promotes housing choice and supports economic activity within the rural parishes, South Norfolk has decided to progress a separate development plan document to meet the overall housing numbers for its village clusters set out in the plan.
2.94 The decision to delay allocation of these sites until a further Development Plan document has been drafted, consulted on, and Examined separately risks serious impeding delivery of a substantial element of housing growth to be delivered by the Plan. Further, the current approach would support up to 80 separate small allocations if it is based on sites of no more than a hectare in size.
2.95 To ensure the Plan is positively prepared, effective and consistent with national policy, the GNLP should be seeking to allocate all housing to achieve its total growth needs in the GNLP, and distributed in a clearly evidenced manner that reflects the principles of sustainable development.
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: 22346
Received: 16/03/2020
Respondent: Pigeon Investment Management Ltd
Agent: Pegasus Group
Policy 7.3 Key Service Centres
7.17 According to the GNLP, the Key Service Centres have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving the rural areas. It also identifies that these roles are intended to continue to be supported by appropriate levels of development.
7.18 Policy 7.3 identifies the growth to come forward at Key Service Centres in the plan period up to 2038. The Reg 18 GNLP identifies 3,253 homes and 11.79 hectares of employment land to come forward in the plan period across the Nine Key Service Centres.
7.19 Of the 3,253 homes to be allocated only 515 are new allocations with all other homes being derived from existing allocations or commitments.
7.20 Of particular concern is the fact that Hethersett is not identified for any additional allocations in the GNLP, other than an uplift at HET1 (which will not increase the rate of delivery but will simply elongate the development phase owing to be controlled by two housebuilders), despite being a Key Service Centre that provides a sustainable location where growth has previously been considered to be appropriate.
7.21 In failing to consider additional growth at such locations the Councils are missing opportunities provided by the Land at Hethersett to provide the required additional community facilities and a better range of uses at the Key Service Centres.
7.22 Land is proposed for a new educational campus at Land off Burnthouse Lane, Hethersett to provide a new primary school, thereby future proofing primary education in the village, and accommodation for Key Stage 3 students of Hethersett Academy, alleviating pressure on the existing school campus. This new campus will include a range of new recreation and sports facilities as well as providing the opportunity for new green infrastructure linkages for the benefit of existing and new residents alike. It is also proposed that a care home/care village will be provided to respond to the significant need for such accommodation across the GNLP area at Land off Station Road in close proximity to local services and with regular bus services to Norwich. The proposed provision of employment land will also be of significant benefit to the residents of Hethersett as it will enhance the opportunity for residents to be employed within the settlement and thereby reduce the need to travel.
7.23 In not providing an appropriate mix of uses through allocations at these locations the GNLP fails to provide flexibility and choice in the GNLP and risks the sustainability of the Key Service Centres as well as the timely delivery of market and affordable homes if allocated sites stall. Land at Hethersett is available and deliverable and provides not only for market and affordable homes but also for specialist accommodation to meet identified requirements.
7.24 The GNLP states that Hethersett is close to Norwich and within the Cambridge Norwich Tech Corridor. Paragraph 337 of the GNLP states the services and facilities that the settlement provides and the fact that it has good access to employment opportunities at a range of strategic and more local sites.
7.25 Land at Hethersett can provide for new market and affordable homes, new employment land, a new educational and sports campus and a new care home/care village. The attached Delivery Statement is based on technical evidence and clearly illustrates the sites and uses now promoted. We would welcome the opportunity to come and discuss these matters further with the Councils.
7.26 Whilst there is an existing allocation for the provision of 40 extra care units in Hethersett, this is insufficient given the identified need for 3,257 such homes across South Norfolk alone. Furthermore, following the allocation of this site in 2015, no planning application has been submitted in the subsequent 4 years which provides an indication that this site may not be attractive to the market or that there is a site-specific constraint which is acting as a barrier to development given the significant need for such accommodation.
7.27 The GNLP has not taken the opportunity that plan making provides to balance the delivery of new homes across the Key Service Centres and to consider how the delivery of new homes can also release land to provide new social and community infrastructure that the evidence base states is required at each settlement.
Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Hethersett. Please find attached the response form, the representations and a Delivery Statement
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22439
Received: 16/03/2020
Respondent: Gladman Developments
Question 43: Key Service Centres 7.3.1 Gladman supports the identification of settlements within this tier of the hierarchy and recognises the need for these locations to take growth in order to meet the local need for housing and encourage growth within the community.
7.3.2 However, it is felt that additional new allocations to some of the locations which do not receive any within the local plan review would be beneficial for both the settlements and the wider plan’s effectiveness. Namely, Poringland/Framingham Earl as the second largest Key Service Centre can accommodate additional levels of growth to boost the housing numbers in this tier and within the settlement. Given its location relative to Norwich and the facilities which are provided for within its confines, Poringland is an excellent candidate for additional growth through this plan despite the number which has already been attributed to it and could help bolster land supply with smaller sites that can demonstrate delivery now.
Please find attached the headline representations of Gladman made in response to the Reg 18 version of the Greater Norwich Local Plan.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22450
Received: 16/03/2020
Respondent: Gladman Developments
2.2 Policy: 7.3 Key Service Centres
Growth directed to Poringland
2.2.1 Gladman welcomes the acknowledgement that Key Service Centres will continue to be developed
to enhance their function as places to live and work, and be providers of services to the settlement
and the hinterland. Whilst the level of growth directed to this tier is a minimum, the number of
houses committed to sustainable settlements falls short of the levels needed to meet housing need
and employment needs within the local areas, and the District as a whole.
2.2.2 Though Poringland has taken some growth, providing no new allocations is counterintuitive to the
role Poringland plays in the District. As explained previously, Poringland is a sustainable settlement
with sites readily available and deliverable now, that could provide extensive benefits to the
community and help boost significantly the supply of housing as emphasised through national
policy.
2.2.3 Gladman consider that allocating no new development through the Draft GNLP to a sustainable
settlement such as Poringland will not provide the flexibility needed to ensure land supply is met
over the plan period. The level of new growth to be directed to the settlement should be
substantially increased. 2.2.4 New allocations identified in ‘Key Service Centres’ would increase the flexibility of the Local Plan
and heighten its durability against unpredicted changes which might occur, especially with the
reliance on large strategic sites to deliver. Allocating land for sites at an appropriate scale to the
settlement through the Plan would address the current and future housing needs. Planning for
these sites now would increase deliverability soon after the plan is adopted.
Please find attached the representations of Gladman made specifically in relation to our land interest in Poringland.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22494
Received: 16/03/2020
Respondent: Highways England
Where the proposed growth is located near or close to the Strategic Road Newtork, appropriate transport assessments will be required to understand the need for essential highway and other infrastructure to support delivery.
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: 22732
Received: 16/03/2020
Respondent: Pegasus Group
According to the GNLP, the ‘Key Service Centres’ have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving the rural areas. It also identifies that these roles are intended to continue to be supported by appropriate levels of development. The Draft GNLP Strategy states that the Key Service Centres of Acle, Blofield, Brundall, Hethersett, Hingham, Loddon / Chedgrave, Poringland / Framingham Earl, Reepham and Wroxham, will deliver 3,417 homes over the plan period (approximately 8% of the proposed housing growth). Our client agrees with the broad approach to increasing the levels of development within the Key Service Centres which will assist in safeguarding existing services, public transport links and infrastructure. In addition to this, delivering growth in villages will diversify the local community and allow others to benefit from village life should they wish to do so, which is consistent with paragraph 78 of the NPPF.
The GNLP Draft Strategy outlines that the Councils would consider an increase in the number of allocated sites in ‘Key Service Centres’ and it is noted that there are many reasonable alternative sites in these locations. In particular, our client suggests that the Councils should consider additional small and medium sized sites, across these sustainable locations, which are well related to the form and character of the settlement and are capable of accommodating housing growth within the plan period.
The GNLP Draft Strategy identifies that Loddon / Chedgrave has a good range of services, good public transport links and is well located between Norwich and Lowestoft to benefit from employment growth, including in the offshore energy sector. As a result, designated Key Service Centres, such as Loddon, should be a focus for sustainable levels of housing growth.
See summaries for responses
- GNLP Regulatory 18 Consultation Questions- Land off Norton Road, Loddon
- GNLP Regulatory 18 Consultation Questions- Dairy Farm, Thorpe End
Introduction
These representations are submitted on behalf of our client Halsbury Homes Ltd in response to the Greater Norwich Local Plan (GNLP) Regulation 18 Consultation.
Our client is promoting Land off Norton Road, for residential development in the GNLP.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22862
Received: 16/03/2020
Respondent: Crown Point Estate
Agent: Miss Kate Wood
We object to the reference in paragraph 340 to an arbitrary limit of 3 dwellings for windfall sites outside settlement boundaries. This suggests that 4 dwellings would be unacceptable, yet would clearly not undermine the settlement hierarchy or be out of character with a village edge, and neither would 5 houses or 10. The policy should relate to character and appearance, with sites referring to natural boundaries on the ground rather than contrived sites or sites that do not make the best use of land. We comment more fully on this point under question 47 below.
For full representation, please refer to the attached documents.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23028
Received: 13/03/2020
Respondent: Bidwells
Support, with comments
As recognised in Question 1, the overall approach for Key Service Centres is fully supported. The identification of Hingham as a Key Service Centre is fully supportive of the approach for Key Service Centres, as Hingham is a location which has a range of services and amenities to support day to day life, including a primary school, Co-op Food, White Hart Pub, library, a doctor’s surgery, alongside a range of employment uses. Accordingly, the identification of Hingham as a Key Service Centre supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.
In addition, the suitability and sustainability of Hingham for growth has been demonstrated through The Hops, a development of 88 dwellings. The Hops, which was allocated under Policy HIN 1 of the Adopted Development Plan, which had a delivery rate of three and a half years (from submission of planning application to completion).
Therefore, we support the identification of a 21% increase in growth for Key Service Centres, which will result in them occupying 8% of total housing growth.
Please find attached a Regulation 18 Stage C Consultation Representation in relation to GNLP0520, Land South of Norwich Road, Hingham.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23054
Received: 16/03/2020
Respondent: Hingham Town Council
Hingham has been designated as a Key Service Centres, at no point in the document is there a definition for a “Key Service Centre”. The lack of concrete criteria for a “Key Service Centre” renders the designation of such an entity meaningless.
For full representation response, please refer to the attached document.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23177
Received: 16/03/2020
Respondent: Pigeon Investment Management Ltd
Agent: Pegasus Group
Policy 7.3 Key Service Centres
8.17 According to the GNLP, the Key Service Centres have a relatively good range of services, access to public transport and employment opportunities and play a
vital role in serving the rural areas. It also identifies that these roles are intended to continue supported by appropriate levels of development.
8.18 However, many are planned to receive disproportionately low levels of development owing to a range of factors. Such constrained rates of growth are likely to compromise the role that these settlements play. In order to support such an unsustainable strategy, it would need to be demonstrated that the constraints identified by the Councils cannot be satisfactorily addressed rather than allowing the sustainability of these settlements to be compromised.
8.19 Policy 7.3 identifies the growth to come forward at Key Service Centres in the plan period up to 2038. The Reg 18 GNLP identifies 3,253 homes and 11.79 hectares of employment land to come forward in the plan period across the Nine Key Service Centres.
8.20 Of the 3,253 homes to be allocated only 515 are new allocations with all other homes being derived from existing allocations or commitments.
Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Dereham Road, Reepham. Please find attached the response form, the representations and a Delivery Statement.