Question 46. Do you support or object or wish to comment on the approach for specific village clusters?

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

Bergh Apton is a rural village, 7 or 8 miles from Norwich city centre. Bergh Apton has been grouped with Alpington and Yelverton as a village cluster for development. There is no school in the village, the nearest being at Alpington. There is no footpath from Bergh Apton to Alpington.
Of the 9 sites put forward in Bergh Apton, only the former blockworks on Church Road would have reasonable access to the school in Alpington, if a permissive path was provided. Also, the road could potentially be widened if it was felt that part of it was too narrow.

Whilst the overall strategy for village clusters contained in Policy 7.4 is supported, we believe
that the sites subject of these Representations should be included as part of the delivery of growth
in this part of Greater Norwich. The sites offer a good opportunity, with minimal constraints/impact
on the character of the village. Furthermore, the sites are not within a sensitive area, being within
a relatively dense residential area, and would ‘read’ as part of the residential area for this part of
the village.

Hemblington is normally classified as a rural village and is a distinct unit from Blofield Heath, part of a service village. They should therefore be treated separately not as a cluster which does not conform to existing administrative units.
It is not clear that Hemblington School does have a defined catchment area, and this is therefore a questionable planning criterion.

South Norfolk going it alone, outside of the GNLP is perplexing. This expensive decision is worrying and suggests that they wish to continue to make large villages into small towns and small 'other villages' into large villages allowing unfettered development. The developments that have been created are more of the same with similar houses crammed in to the available space with minute gardens and insufficient parking leading to pavement parking. The Dutch barn end on a couple of edging houses is the only nod to East Anglia. No mention of passive houses with communal heating through groundsource or creative self-building.

Please see attached for full submission

Please find attached representations.
These representations are made on behalf of KCS Developments in respect of the Greater Norwich Local Plan to 2036.
Our Client is promoting five sites within Spooner Row which can deliver between 173 and 246 dwellings along with community facilities. Spooner Row is proposed to fall within the lowest tier of the settlement hierarchy within the GNLP – the “village clusters” – despite previously being identified as a service village within the Core Strategy. These representations demonstrate that this approach is flawed and underplays the significance of settlements such as Spooner Row.

Re: POLICY GNLP2019, Land at Rectory Road and south of the Bure Valley Railway, Coltishall (approx. 1.43 ha) is allocated for residential development.
We object strongly to the Proposal to bring Greenfield site GNLP2019 as the preferred option for a housing estate.
We question the accuracy and validity of the GNLP background documents concerning Coltishall as they hold many misconceptions. Firstly, we do not have good transport links as stated. We have a skeleton bus service of one-hour intervals between North Walsham and Norwich only. This service ends just after 6pm from Norwich and is rarely used by commuters due to practical considerations. We have no public transport provision to our nearest Town, Supermarket and Rail Station in Hoveton and Wroxham. Recently a parishioner enquired about a hop on bus service but this does not exist. Our School has reached its capacity intake, a similar situation applies to the Health Practice, both will struggle with a large rise in residents as no plans have been developed to further fund these institutions.
The proposed sites as you have mentioned yourselves will cause chaos in Rectory Road. This is a small residential road which is already problematic at peak time due to vehicles attending the School and Health Practice. We fail to see how this can be addressed without a huge alteration to the streetscape damaging the feel and safety aspect of the village in this designated conservation area.
We have questions too about how Crocus Homes seemed to have prior knowledge of your intentions regarding showing The Parish Council detailed drawings of development on this site. We can see that without Crocus Homes cooperation the proposed site would be landlocked.
On a wider Issue, in the light of the landmark ruling regarding Heathrow Airport expansion, ruling it illegal as it failed to consider Climate changing issues and adherence to CO2 emission as agreed in the Paris agreement, this has thus been proved a legally binding commitment. No such assessment has been made for the Village Clusters and until this is drawn up and considered against sites nearer employment and public transport, we call for these proposals to be dropped.
Our final question at this stage; numerous letters of complaint have been sent to the Monitoring Officer at Broadlands District Council demanding the Chair of the Greater Norwich Development Partnership Board (consultants for the GNLP), Cllr Shaun Vincent, step down immediately given his conflict of interests as a developer himself and having his own consultancy company advising on planning matters. I have read S28 and 29 of the Localism Act 2011 and my understanding is that Cllr Vincent should have no involvement in the selection process. How is this situation being managed and does it not now put a question mark on why certain sites have been preferred over others and more widely the validity of the whole GNLP.

Please consider the following objections to the GNLP

Reedham

Although the proposed sites are not currently predicted to be at risk from flooding, large parts of Reedham are within the “Land projected to be below annual flood level in 2050” including the sewerage plant, roads, railway, pubs and other businesses, meaning that well within the lifespan of any new development the village may no longer be viable, I suggest this reason alone makes additional large developments in Reedham unsuitable. It is very surprising that the “Lead Local Flood Authority” has entered a response of “No comments”

The “village clusters” approach does not make sense when the Climate Change Statement is taken into account, the entire principle is flawed, the approach used for the Joint Core Strategy was much more sustainable.

The consultation document states;

“Reedham is not clustered with other settlements as the school catchment does not extend to adjoining villages. The school currently has spare capacity.”

How can Reedham be a “cluster” of one village? The school currently has pupils from Freethorpe, Cantley and Brundall, how does this indicate a catchment of Reedham only? Any reliance on school places as a justification for development should be questioned, there are no guarantees that housing will bring children to the village, the recent 24 dwelling development of a JCS site (Red 1) in the village has so far only resulted in one additional pupil at Reedham school. Parents have a choice of schools in the area. Any benefit is lost in any case after a few years as children grow up and leave the primary school.

The consultation states;

“there is a total of 28 additional dwellings with planning permission on small sites”

For a small rural village developing these dwellings alone would give a sustainable amount of growth, further large developments are not required and indeed risk changing the character of this historic village.
There is an emerging neighbourhood plan which may provide a more suitable proposal for Reedham, no sites should be allocated until the neighbourhood plan has been adopted.

The sewerage system in the village already requires tankers to remove material, sometimes daily.

The narrow roads to and around the village are not suitable for a permanent increase in traffic.


GNLP1001

The farmland to the east of this site will be accessed for large machinery through any residential development on this site.
The site is outside the development boundary.
Contrary to GNLP Policy 2 issue 1
Contrary to GNLP Policy 7.4 347

GNLP3003

The only possible vehicle access to this site is not wide enough with no scope to widen without purchase of private garden land, there is absolutely no reason to believe that this would be possible. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
The site is outside the development boundary.
Contrary to GNLP Policy 2 issue 1
Contrary to GNLP Policy 7.4 347

At a recent meeting of Halvergate Parish Council on 4th March, it was agreed that the Parish Council had no issue with the linking of Halvergate with neighbouring villages as a ‘cluster’, given that no land within the Parish has been designated as suitable for a development consisting of 10 or more dwellings. We also understand that this new status is in no way intended to transcend or undermine the provisions of the Halvergate Conservation area.

Councillors also agreed that our overriding concern continues to be that any planning permissions granted, should be slanted heavily towards providing dwellings for the existing community, with an emphasis on affordable dwellings for younger people and opportunities for older residents to develop in-fill plots on a piecemeal basis.

However, we feel, nevertheless, that one unfortunate consequence of village clustering across the area covered by the GNLP is that larger developments could end up being permitted in villages with little or no infrastructure, and, crucially, no substantial transport links. Where this is the case there will inevitably be a much greater use of private cars at a time when the country is seeking to drastically reduce its carbon footprint. We are concerned by the consequent pressure on rural roads by any amount of development, especially given that most households have at least 2 cars and also the pressure on medical facilities and schools. The infrastructure should already be in place to support any building.

The Parish Council also wishes to draw attention to the possible effects on the sewage treatment plant off the Wickhampton road that serves not only Halvergate but also the neighbouring village of Freethorpe. If substantial further development is allowed in Freethorpe we fear that this plant could be placed under strain. (Residents are already complaining about the frequency of lorries negotiating the tiny road to service the plant.) At a site meeting back in 2013, Anglian Water maintained that it remained confident that this plant was fit for purpose, though in the follow-up letter to this meeting the representative admitted that the plant was ‘operating beyond its design capacity’. With the all-pervading stench from the Whitlingham plant that greets drivers on the Norwich Southern Bypass which serves as a reminder of what ensues if such a plant is not fit for purpose, we very much hope that any large developments ensuing from the new cluster status do not condemn Halvergate residents to the same daily misery.

Please see attached for full submission

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

Please see attached for full submission and amended site proposal

On behalf of Carl Palmer & Wellington
Please find attached a full Statement (and appendices including a Connectivity Assessment –Canhams Consulting Ltd.) in response to the exclusion of the above site (GNLP 0283) as a preferred site, for your consideration ; and covering individual policies as considered necessary with reference to Policies 7.3 & 7.4 in particular.

As the Chair of Governors (and on behalf of the governors) for Coltishall Primary School I would like to submit the following response to the draft GNLP in regard to the sites in Coltishall.

We support the decision that the majority of the sites put forward in Coltishall and Horstead have been assessed to be unreasonable as we had significant concerns about the impact of capacity within the school and traffic in the vicinity of the school. We also acknowledge that the impact of traffic has been a deciding factor for some of these sites.

We are disappointed to see that there is a plan to include additional housing to the site at the end of Rectory Road. The governors are currently very concerned about capacity at the school. The school is typically oversubscribed and we are approaching levels where children who are resident within the catchment area will be unable to be accepted into the school. This is before any further development has been completed, so proposing to extend this development could result in a significant problem for the school. In addition to capacity, we also have significant concerns regarding traffic on Rectory Road. During school drop off and pick up times, Rectory Road is severely congested and already hazardous for children. Putting more development at the end of the road is only going to result in increased traffic and more difficulties on a narrow, unsuitable road.

As well as the site specific development, there is a general reference to there being sufficient land to expand the school. The governors do not support this position and are strongly opposed to any expansion of the school. There are no acceptable ways to expand the school on a small scale to support the size of developments proposed. Additionally, large scale development would be detrimental to the school ethos and environment, and not in the interests of the children meaning that governors would not support any such proposal.

I write to express my concerns regarding the proposed new Developments in the village of Reedham. Having seen the impact of the recent development of Barn Owl Close, I am most concerned that further developments within the village need careful consideration if they are to add to the village without inflicting an unsafe and unsustainable burden on the community

Reedham is a remote village, with a minimalist and ancient infrastructure. It is miles from a main road, with access via narrow country lanes
The roads within Reedham village do not have safe two-way traffic width; passing another car requires care and consideration
Access by the emergency services cannot be measure in terms of a few minutes, - it is usually at least half an hour
There is a very limited train service, which has, recently, been subject to much disruption and cancellation of trains, reliance upon such a service is risky at the moment
The bus service is extremely limited, to the point that trying to use that service for everyday purposes is almost impossible
The Sewerage system for the village is already well over-stretched, - evidenced by the number of tanker visits to pump out, - daily and sometimes more.
The water supply is also overstretched, - evidenced by the lack of water pressure at key times, and by the lack of available water at a recent fire within the village
Electricity supply to the village area appears to be stretched, evidenced by not infrequent flickering of lights at peak usage times
One of the proposed sites has no vehicle access - why is it even proposed?
That same site is on a site that the school would like to use as it’s playing field, being almost adjacent to the school rather than half way across the village as is the current school playing field
The school, I understand, now has very limited capacity for more children, (updated February 2020) and also has very limited playing field facilities, see above comment. Hence it appears that it is also near it’s capacity

It is my suggestion that whilst Reedham might be seen as a suitable target recipient for more homes, in terms of Trains, pubs, etc, the character of the village is struggling with the current occupancy, and the infrastructure is woefully inadequate to cope, let alone have more people, cars, sewerage, and demand for water and electricity.

Please consider the infrastructure before adding random developments that significantly add to the population of a village, potentially taking to dangerous levels the demands for all necessary facilities, as well as detracting from the character of a village that depends on just that character for it’s survival

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

Please see attached for full submission

Hopkins Homes are providing this consultation response in reply to the Regulation 18 Draft Local Plan Consultation by the requested submission deadline of 16th March 2020.

Hopkins Homes Ltd is the largest independent house building company in East Anglia with a reputation for delivering well designed, high quality residential and mixed-use development harmonising with its local context. In the past decade the company has succeeded in delivering sustainable developments which improve neighbourhoods, improve local infrastructure and add to local distinctiveness throughout the Greater Norwich area.

In respect of the content of the Draft Plan, Hopkins Homes wish to make the following comments:-

SECTION 5 – THE STRATEGY POLICY 1 THE SUSTAINABLE GROWTH STRATEGY

Consultation Questions for Policy 1 – The Sustainable Growth Strategy

13. Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

Whilst Hopkins Homes agrees with the broad strategy outlined, we do consider that a number of the existing villages within the wider Greater Norwich Area, both within and beyond the defined ‘Norwich Policy Area’ benefit from sufficient sustainability credentials so as to be able to accommodate greater levels of housing growth than are currently proposed.

Notably, Hopkins Homes have proposed sites on the periphery of the villages of Mulbarton and Scole within South Norfolk, both of which settlements benefit from facilities and good connections with nearby higher-order market towns which enable them to accommodate higher levels of growth than are currently envisaged through the proposed Strategy.

In respect of Mulbarton, the existing population in excess of 3,500 is higher than that of over half of the designated Key Service Centres, as confirmed by the data contained in Table 1 on Page 11 of the Draft Plan, which therefore further confirms the appropriateness of higher levels of proportionate housing growth than currently proposed within the Draft Plan.

POLICY 5 – HOMES

Consultation Questions for Policy 5 – Homes

32. Do you support, object or have any comments relating to the approach to Self/Custom-Build ?

Whilst Hopkins Homes understands the Government’s desire to promote the development of housing via Self and Custom-Build, it is common knowledge that the vast majority of demand for such housing is upon smaller and individual development sites in predominantly rural locations, rather than as a small portion of a larger development site.

To this end, it is suggested that specific smaller sites in rural locations should be allocated for such uses, rather than seeking to require such provision as a portion of larger sites.

POLICY 7.3 – THE KEY SERVICE CENTRES

Consultation Questions for Policy 7.3 – The Key Service Centres

43. Do you support or object or wish to comment on the approach for the key service centres overall? Please identify particular issues.

44. Do you support or object or wish to comment on the approach for specific key service centres: (Acle, Blofield, Brundall, Hethersett, Hingham, Loddon / Chedgrave, Poringland / Framingham Earl, Reepham, Wroxham)? Please identify particular issues.

As previously outlined under Question 13, Hopkins Homes considers that the village of Mulbarton should be formally identified as a Key Service Centre, Mulbarton, given the existing population in excess of 3,500 is higher than that of over half of the designated Key Service Centres, as confirmed by the data contained in Table 1 on Page 11 of the Draft Plan, whilst the village also benefits from a proportionately good range of services and facilities.

POLICY 7.4 - VILLAGE CLUSTERS

Consultation Questions for Policy 7.4 – The Village Clusters

45. Do you support or object or wish to comment on the overall approach for the village clusters? Please identify particular issues.

46. Do you support or object or wish to comment on the approach for specific village clusters? Please identify particular issues.

Whilst Hopkins Homes support the identification of village clusters to accommodate additional residential development to support the sustainable growth of rural areas, there should be no defined numerical restraint upon the size of site area or the number of dwellings proposed for allocation in this way. Instead, any such allocations should be made so as to be proportionate to the size of settlement cluster within which they are located and the range of facilities available, in order that they successfully meet local housing needs.

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

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.

On behalf of our client, Horsham Properties Ltd and owner of Abbey Farm Commercial Park at Horsham St Faith, we write in respect of the Greater Norwich Local Plan, Regulation 18 - Part 1, The Strategy and Part 2 Site Allocations Consultation, published January 2020.

Please find attached LPP’s statement that sets out our representations regarding Site Reference HNF3 – Land at Abbey Farm Commercial Park, Horsham St Faith, that is allocated for employment uses within the Broadland District Council Site Allocations Development Plan Document (2016) and is identified as ‘Carried Forward Employment Allocation’ within the draft Greater Norwich Local Plan (GNLP) (2020).

This statement also considers the policies contained within Part 1 The Strategy set out within the draft GNLP and provides representations in respect of Policy 6 ‘The Economy’, Policy 7.4 ‘Village Clusters’ and responses to questions 6, 10, 15, 34 and 46. A response to each question has also been submitted via the GNLP online consultation portal.

This statement additionally identifies and seeks the allocation of land north of Abbey Farm Commercial Park (0.9 hectares), as a further modest extension to the Commercial Park for employment use.

For full representation, please refer to the attached document.

POLICY 1 – SUSTAINABLE GROWTH
Q13 Do you agree with the proposed settlement hierarchy?
NO - Becoming part of a cluster will result in inevitable exposure to wider and unnecessary development and the ultimate loss of existing settlement boundaries and village identity.
Q14 Do you support the approach to housing numbers?
NO - the 9 /10% extra allocations as well as additional windfall sites is excessive given that there are sufficient sites allocated to meet predicted demand.

POLICY 7- 4 VILLAGE CLUSTERS

Q45. Do you support or wish to comment on the overall approach for the village clusters? Please identify particular issues.

Most villages are able to continue to access services as they do already without the need to cluster. The policy is intended to enable wider development which will result in the ultimate loss of existing settlement boundaries and the risk of unnecessary development.

Q46. Do you support or wish to comment on the approach for specific village clusters?
We strongly object to the proposed cluster of Hainford with Stratton Strawless or any other village and firmly believe that Hainford should retain its stand alone village status as are other nearby villages. The residents of Hainford value their rural aspect and independence and the reasons for linking Stratton Strawless to Hainford are weak.
a) The majority of family size accommodation in Stratton Strawless is situated west of the A140 where there are other nearby schools which are closer and more accessible than Hainford without the requirement to cross the busy A140 at peak times, Hevingham school is 0.4 miles, Marsham Primary School 1.4 miles and Horsford (with supermarket, Doctors surgery, Post Office,social club, leisure facilities, take away food outlet, library, excellent public transport links etc.) is also closer.
b) The largest concentration of homes on the eastern side of the A140 are on the mobile home park which we understand is for residents over the age of 55. For the residents who may live on the eastern side of the A140 and require primary school facilities there is also nearby Buxton school.
In addition to the above we object to the proposal that there is the potential for the development of 50/60 dwellings because there is insufficient capacity to sustain that level of development due to lack of facilities and infrastructure to support this.
The Officers have already stated that there is no capacity for Hainford school to expand and all 9 proposed sites for Hainford were discounted by planners mainly due to there being no safe pedestrian access to the school ( a crucial underlying criteria for development in the policy) and no feasible way to address this. There were Highways concerns, widespread flooding issues, and visual impact and break out into the country side. Added to which the public transport service is very limited with the last daily service from the city at 18.15 .We understand that the Policy requirements are to avoid development where there is a reliance on the private motor vehicle.
Therefore I support Hainford Parish council's objections to the proposal to become part of a cluster and to the ultimate redefinition of our settlement boundary in order to facilitate wider development and to the proposal that there is the capacity to support a further 50/60 dwellings

POLICY 7- 4 VILLAGE CLUSTERS
Q45. Do you support or wish to comment on the overall approach for the village clusters? Please identify particular issues.
I do not support the proposed policy for village clusters.
Most villages are able to continue to access services as they do already without the need to cluster. The policy is intended to enable wider development which will result in the ultimate loss of existing settlement boundaries and the risk of unnecessary development. We are aware that the redefinition of settlement boundaries is to be considered at a later stage in the plan.
Q46. Do you support or wish to comment on the approach for specific village clusters?
iI object to the proposed cluster of Hainford with Stratton Strawless or any other village and firmly believe that Hainford should retain its stand alone village status as are other nearby villages. The residents of Hainford value their rural aspect and independence and the reasons for linking Stratton Strawless to Hainford are weak.
1. The majority of family size accommodation in Stratton Strawless is situated west of the A140 where there are other nearby schools which are closer and more accessible than Hainford without the requirement to cross the busy A140 at peak times, Hevingham school is 0.4 miles, Marsham Primary School 1.4 miles and Horsford (with supermarket, Doctors surgery, Post Office,social club, leisure facilities, take away food outlet, library, excellent public transport links etc.) is also closer.
55. The largest concentration of homes on the eastern side of the A140 are on the mobile home park which we understand is for residents over the age of 55. For the residents who may live on the eastern side of the A140 and require primary school facilities there is also nearby Buxton school.
In addition to the above I object to the proposal that there is the potential for the development of 50/60 dwellings because there is insufficient capacity to sustain that level of development due to lack of facilities and infrastructure to support this.
The Officers have already stated that there is no capacity for Hainford school to expand and all 9 proposed sites for Hainford were discounted by planners mainly due to there being no safe pedestrian access to the school ( a crucial underlying criteria for development in the policy) and no feasible way to address this. There were Highways concerns, widespread flooding issues, and visual impact and break out into the country side. Added to which the public transport service is very limited with the last daily service from the city at 18.15 .I understand that the Policy requirements are to avoid development where there is a reliance on the private motor vehicle.
Therefore I object to the proposal to become part of a cluster and to the ultimate redefinition of our settlement boundary in order to facilitate wider development and to the proposal that there is the capacity to support a further 50/60 dwellings.

Saxlingham Nethergate Parish Council met last week and considered their response to the current consultation.

They noted, considered and decided to fully endorse the response produced by CPRE in full (attached).

Q1 Please comment on or highlight any inaccuracies within the introduction

Please see our more detailed responses to the questions below, which make our concerns clear. In particular we have a major concern with the Draft Strategy as it makes no mention of using phasing for the delivery of new housing. We consider that any new sites allocated in the GNLP should be phased by being placed on a reserve list, and under phased development only built out when most of the existing JCS sites have been used. Inclusion of all the sites for immediate development will lead to developers “cherry-picking” the most profitable sites and newly allocated green field sites in less sustainable locations will be developed first, with even more land banking of currently allocated sites. In short, deliver the already allocated 82% of the 44,500 new homes, before giving permissions on the remaining 18%.

The current Local Plan, the Joint Core Strategy (JCS) was adopted in March 2011 with amendments adopted in January 2014: it has been in place for just over 6 years. When adopted, it was considered to be the blueprint for development in Norwich, Broadland and South Norfolk until 2026, and in doing so provided clear signals about where growth should and should not take place. In the introduction to the current consultation document it is stated that housing, jobs, services and infrastructure needs to be provided at the right time ‘and in the right places’. CPRE Norfolk questions how the response to this has changed so markedly since adoption of the JCS and well before that Local Plan was due to expire. In particular, the construction of the Broadland Northway (NDR) (noted in paragraph 7 of the introduction) was largely intended to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle. Moreover, there was a clear focus for housing and other growth to be in and close to Norwich, with minimal new development to be permitted in the rural policy areas of Broadland and South Norfolk. The GNLP strategy seems to be contradicting the direction of travel envisaged in the JCS and appears to undermine the planning process. A great strength of the JCS is the protection it gave to the rural areas: this seems to be sacrificed in the GNLP Draft Plan.

Paragraph 6 of the Introduction is clear that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’ It will be difficult if not impossible to meet these targets if new housing to the scale proposed in the draft strategy is dispersed across the rural areas of Broadland and South Norfolk. The main justification for this appears to be the availability of primary school places in the “village clusters”, whereas there are more important measures for sustainability which should be taken into account, including the number of car journeys and journeys by delivery vehicles to new housing, along with the associated congestion such vehicles will result in.

The introduction mentions in paragraph 25 that South Norfolk District Council will draw up its own South Norfolk Village Clusters Housing Site Allocations document. CPRE Norfolk is very concerned that by adopting such an approach this allocations document will not receive the same level of scrutiny as the main draft strategy document. We are also very concerned that the number of additional dwellings on top of the existing commitment of 1,349 houses is given as ‘a minimum of 1,200’. The use of the word ‘minimum’ is unnecessary and potentially very alarming, as in effect this gives no limit to the maximum number of houses which could be allocated in those “village clusters”. Given the draft plan provides enough committed sites ‘to accommodate 9% more homes than “need”, along with two “contingency” locations for growth’ (page 37) and does not include windfall developments in its housing totals, the word “minimum” should be replaced with “maximum” or “up to” as is the case with the figures for Broadland’s “village clusters”. Why is there this discrepancy in language between two authorities which are part of the same Local Plan: it appears to be inconsistent and illogical.

Q3 Please comment on or highlight any inaccuracies within the spatial profile.

Paragraph 41 states that ‘this GNLP needs to plan for additional housing needs above and beyond existing commitments based on the most up-to date evidence’. However, the calculations of housing need are based on the 2014 National Household Projections, which are not the most up-to date statistics, nor are they sufficiently robust to be used for such an important and far-reaching strategy. CPRE Norfolk admits that the 2014 figures are those which central Government expects to be used. However, several Local Planning Authorities, including North Norfolk District Council, are challenging the use of the 2014 figures, instead suggesting that the more up-to date 2016 National Household Projections should be used. CPRE Norfolk agrees that the GNLP needs to be based on the most up-to date evidence, and therefore requests the GNDP insists on using the 2016 National Household Projections. If the most recent ONS statistics had been used, current commitments are sufficient to cover housing needs to 2038.

Q6 Do you support or object to the vision and objectives for Greater Norwich?

A major concern is that the draft plan largely consists of a wish list, but lacks real targets or actions, particularly on the environment and climate change. For example, our environment is lauded but the draft plan notes in paragraph 37 that life expectancy for men in Norwich is 10.9 years lower in the most deprived areas compared to the least deprived. We cannot see any specifics within the draft plan as to how this shocking fact is to be addressed.

Paragraph 120 stresses the need for ‘good access to services and facilities’ for ‘our suburbs, towns and villages’. While this is provided in the first two categories of settlement there is insufficient provision or access to services in many of the settlements within the “village clusters”. The decision to allocate additional new housing beyond what is already allocated within the JCS is based almost solely on the existence of a primary school with available places or potential for expansion within the “cluster”. This does not amount to the provision of ‘good access to services and facilities’ and therefore this level of new housing in “village clusters” should not be permitted within the GNLP.

Paragraph 125 is perhaps the strongest argument for not allocating additional housing to “village clusters” within the GNLP. Clearly, there will be a major need for journeys from and to work for many of those living in any such new housing, in addition to additional journeys by delivery vehicles to this new housing. This paragraph states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ For the majority of the plan period it is highly wishful thinking to think that ‘electric vehicles will predominate throughout Greater Norwich’. These additional journeys will not only add to the “carbon footprint” but will also add to congestion on the road network, affecting air quality and the wellbeing of residents. If the intention of the GNLP is to locate housing close to jobs, which we agree should be a major aim, then any additional allocations of housing should be located in or close to Norwich, where there are realistic opportunities to walk or cycle to work and to services, or to use public transport to do so. The existing allocations of housing within the JCS and to be carried forward to the GNLP will provide sufficient new accommodation close to other places of work in main towns and key service centres.

Paragraph 129 states: ‘greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ We strongly feel that it is imperative that Per Capita Consumption (PCC) of water is further reduced to below the Government’s prescribed 110 litres per person per day in order to deliver this statement in paragraph 129. East Anglia is the driest region in the UK: our aquifers, rivers and wetlands are already at breaking point, as are many of the region’s farmers, who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PCC water consumption are not set as part of the GNLP, this will further adversely impact upon the environment, impacting on the Broads and wetlands, which in turn will impact the region’s aspirational growth for tourism and will severely impact the regional agricultural economy. To ensure that the water-supply to existing users is not compromised it is sensible to restrict the number of new houses to a level that realistically covers actual need, and this fact reinforces our case for phasing of housing and our questioning of the need for a higher than necessary buffer.

Paragraph 132 makes the claim that new quality development will be located to minimise the loss of green-field land. CPRE Norfolk strongly suggests that the best way to achieve this is not to allocate additional sites for housing in “village clusters”. Indeed, there are already sufficient allocated sites for housing in the JCS being proposed to be carried forward to the GNLP in the Norwich fringe parishes, main towns and key service centres to keep pace with the likely build rates of development. The exception to this should be any brownfield sites, particularly those within Norwich, which should be prioritised into a “brownfield first” policy. This should form part of a phased approach to new housing, so that existing allocations from the JCS and any brownfield sites should be developed before permitting any additional allocated sites to be built-out.
One effective way to prevent the unnecessary loss of much greenfield land would be to institute a green belt on the “green wedges” model around Norwich, as requested by 84 respondents and 1,912 petition signatories (currently at 2,200 signatures) calling for this according to the draft statement of consultation, September 2018, for the Stage A Regulation 18 Site Proposals and Growth Options consultation. CPRE Norfolk is very concerned that this proposal or option has been removed from the current consultation.

In conclusion for this question, we find that the vision and objectives contain serious flaws, especially in regard to the way in which they conflict with policies within the current Local Plan, which withstood the rigorous inspection process.

Q9 Do you support, object, or have any comments relating to the approach to Housing set out in the Delivery Statement?

This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ CPRE Norfolk disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.

It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

Q12 Do you support, object, or have any comments relating to the Climate Change Statement?

Given the stated measures in the Climate Change Statement, it is impossible to see how the proposed additional allocation of sites for housing in “village clusters” can be justified. Furthermore, it is stated that ‘growth in villages is located where there is good access to services to support their retention’, when this is rarely the case beyond providing a primary school with sufficient places or room for expansion. Many services are simply not located within the “village clusters” with many additional vehicle journeys being an inevitable consequence of such housing allocations. Therefore, these would be contrary to measures 2 and 3 of the Climate Change Statement.

By locating additional housing in “village clusters” there would be an increased need to travel, particularly by private car, due to the lack of viable and clean public transport. If Climate Change is seriously going to be addressed then it is unacceptable to allocate additional sites for housing in rural areas which are not at all, or poorly served by public transport. New housing must be located where jobs and a wide range of services are or can be provided.

In addition CPRE Norfolk is concerned by the lack of any detailed policy on the design of new housing in the draft Plan document, other than a brief mention in the ‘Design of development’ in the Climate Change Statement. Detailed requirements to insist that new houses are built to the highest possible environmental standards beyond the Government’s minimum standards are needed, if serious steps are to be taken towards addressing Climate Change issues.

Q13 Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

We supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the concept of “village clusters” has been introduced into the planning process. For many reasons they appear to be a flawed unsustainable concept. A real strength of the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore we are very disappointed that this distinction has been abolished. The Rural Policy Areas gave real protection to the countryside: this is threatened by the introduction of the village cluster approach. This is another example of how the Draft GNLP contradicts the existing agreed Local Plan.

As noted above in our response to Q1 CPRE Norfolk has serious misgivings about the separation of the sites and allocations for new housing in the South Norfolk Village Clusters from the rest of the GNLP and its current consultation. In addition, we strongly object to the use of the open-ended statement that these South Norfolk “village clusters” will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number as is the case for the Broadland “village clusters”. If the reason for this separation is, as was given at the recent GNDP meeting of 6th January 2020, the lack of suitable sites coming forward in these South Norfolk “village clusters”, then this gives another good reason why the delivery of housing should be phased. Clearly the sites included in the JCS have undergone rigorous assessment and their inclusion in the Local Plan is an acknowledgement of their suitability for development. It makes absolute sense that these suitable sites should be developed first especially given the fact that any new sites coming forward are deemed to be unsuitable.

Paragraph 163d states that the strategy for location of growth ‘focusses reasonable levels of growth in the main towns, key service centres and village clusters to support a vibrant rural economy’, before suggesting that the approach to “village clusters” is ‘innovative’. The claim that providing new housing in such locations will support services is, we contend, largely illusory. Instead, additional new housing will lead to more car and delivery vehicle journeys, with residents travelling longer journeys to access the services they require such as health services and a supermarket. Given that the majority of any such new houses will be larger “family” homes, with children just or more likely to be of secondary or tertiary school or college age than of primary school age. This will have further impacts on carbon reduction due to the additional journeys needed to secondary schools or colleges.

It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable option for the distribution of housing in terms of the environment (e.g. minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; ensuring that everyone has good quality housing of the right size; maintaining and improving the quality of life; reducing deprivation; promoting access to health facilities and healthy lifestyles; reducing crime and the fear of crime; promoting access to education and skills; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes; conserving and enhancing the historic environment and heritage assets; minimising waste generation; promoting recycling; minimising the use of the best agricultural land; maintaining and enhancing water quality and its efficient use) is Option 1: urban concentration close to Norwich. In terms of all these factors taken together the least desirable option as shown on this chart is Option 4: dispersal. We therefore strongly support urban concentration in and close to Norwich as the way forward, because it is best for the environment, minimising climate change and the well-being of residents.

There is very little economic evidence to suggest that cementing new housing estates on the edges of villages will bring any boost to local services, but rather they will put a strain on these services, where they exist.

We cannot understand why the table showing the same set of factors in the Interim Sustainability Appraisal for the GNLP on page 42 shows some different results from the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option.

Given the clear benefits and advantages from these documents for the environment, climate change and other areas, as well as other reservations around lack of sustainability and issues of delivery, we strongly urge the GNDP to remove the requirement for additional new sites for housing in the “village clusters” from the GNLP.

Q14 Do you support, object, or wish to comment on the approach for housing numbers and delivery?

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

CPRE Norfolk also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable (or as CPRE Norfolk would argue, unsustainable) sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

Q18 Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

Commenting on Policy 2 – Sustainable Communities, CPRE Norfolk questions the use of the words “as appropriate” in the policy’s introduction, as this means the requirements would be far too open to interpretation as to what is “appropriate” and therefore opportunities to ensure that ‘mitigating and adapting to climate change, [and] assisting in meeting national greenhouse gas emissions targets’ will be missed.

This concern is particularly relevant when considering how new housing development in the “village clusters” will fulfil the first requirement to ‘ensure safe, convenient and sustainable access to on-site and local services and facilities including schools, health care, shops, leisure/community/faith facilities and libraries.’ The rationale behind these “village clusters” appears to be mainly based on the availability and accessibility of a primary school. However, safe, convenient and sustainable access to the other features on this list are equally important. Adequate health care and shops simply are not available in these ways to many of the preferred new sites for housing in the “village clusters”, therefore giving further reasons why such sites should not be included in the GNLP.

There is a worrying disconnect between the aspirations in point 6 with the need to ‘manage travel demand and promote public transport and active travel within a clearly legible public realm’, and the imposition of additional new housing in “village clusters”. It is difficult if not impossible to see how residents of the majority of this new housing will be able to use active travel or public transport, due to the likely distances from workplaces and the lack of suitable public transport.

If additional new housing is developed in “village clusters” most of the working residents will not have ‘good access to services and local job opportunities’. Instead there will be an unsustainable increase in the number of journeys to and from work using private vehicles, which will not be electric-powered certainly for the majority of the plan period. It is very doubtful if additional housed will provide enough business to keep a village shop open, but they will definitely increase the number of journeys made for delivery and service vehicles, making this housing even more unsustainable.

If communities are to ‘minimise pollution’ as required to do so by point 8, it is imperative that no additional new housing is allocated to “village clusters”, as this would lead to an increase in petrol and diesel-powered vehicle journeys to and from such housing. This, along with the resultant increase in congestion, makes this additional housing highly undesirable.

Q19 Do you support, object or have any comments relating to the specific requirements of the policy?

We comment on various aspects of Table 8 relating to Policy 2.


Point 3, Green Infrastructure. The opening statement is: ‘Developments are required to provide on-site green infrastructure appropriate to their scale and location’. The three main benefits listed are biodiversity gain, promotion of active travel and the reduction of flood risk, which are key NPPF priorities.
The NPPF is also supportive of biodiversity on a more strategic scale, and the importance of ecological networks and Nature Recovery Networks. While Green Infrastructure is useful, and can play a role in these, it clearly has limitations in a wider role across the wider countryside, and in linking high designated nature conservation sites.
Point 5, Landscape, should recognise that valued landscapes often sit with good wildlife habitats. This is particularly the case for river valleys and the Broads. A strong message from the Environment Plan and the recommendations from the recent Landscapes Review is to make links between landscapes and wildlife, and not consider them in isolation. This is covered more fully in our response to Q21.
Point 9, Water. In our view it needs to be recognised that SUDS is not a silver bullet when dealing with flood risk. Areas of low-lying land with a high water-table can present a problem in ‘getting the water way’, and if it does manage to do that existing settlements can be put at risk.
A high level of growth puts a greater pressure on the capacity of Waste Water Treatment Works, both on the discharge of effluent into river systems, and on flood risk with foul water. This will be exacerbated by under or lagging investment in WWTW. Although not the responsibility of the Greater Norwich Authorities, their Annual Monitoring Reports (AMRs) should record and monitor incidents.

The statement in Point 9, Water - Key issues addressed by policy 2 states that: ‘Government policy expects local planning authorities to adopt proactive strategies to adapt to climate change, taking into account water supply and demand considerations. It allows local plans to set a higher standard of water efficiency than the Building Regulations where evidence justifies it. For housing development, only the higher Building Regulations standard for water prescribed by Government (110 litres per person per day) can [be] applied through local plans and more demanding standards cannot be set. If the potential to set more demanding standards locally is established by the Government in the future, these will be applied in Greater Norwich.’ The closing note at the bottom of the wording states: ‘Implementation of the standards for water efficiency will be supported by an updated advice note.’

We comment that it is imperative that Per Capita Consumption (PCC) of water is further reduced below the Government's prescribed 110 litres per person per day in order to deliver the statement made in Section 3, paragraph 129 which states: ‘Greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable local energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ East Anglia is the driest region of the UK, our aquifers, rivers and wetlands are already at breaking point, as are many of the regions farmers who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PPC water consumption are not set as part of the local plan, this will further adversely impact upon the environment, impacting upon the Broads and wetlands, which in turn will impact the regions aspirational growth for tourism and will severely impact the regional agricultural economy.

These pressures are further evidence as to why the amount of new housing should be tightly controlled.

Q21 Do you support, object or have any comments relating to the approach to the natural environment?

CPRE Norfolk supports further ‘development of a multi-functional green infrastructure network’. However, we have major concerns about how biodiversity net gain will be evaluated, assessed and measured, although it is recognised that at this point it is unclear as to what the legal requirements of this policy will be given the current progress of the Environment Bill.

Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt on a ‘green wedges’ model would go some way to addressing this.

This draft Plan takes a very narrow view on the NPPF and 25-Year Plan on policies for the natural environment, namely that strategy, aims and policies are restricted to considering only gain as seen through the prism of development. There is a duty to cooperate between Councils, and that should automatically happen. While implementation may be less direct, there should be a wider strategic vision that does support policies of the NNPF. CPRE Norfolk has a proposal for a Nature Recovery Network from the North Norfolk Coast to the east coast (including parts of the Broadland DC area), by the enhancement of the ecological network provided by our river systems, and supported by the environmental land management scheme. This includes a detailed planning and land management document for landscapes and wildlife relating to a Nature Recovery Network, which also include an AONB extension to the Norfolk Coast AONB into the full catchments of the twin North Norfolk rivers Glaven and Stiffkey.

Q22 Are there any topics which have not been covered that you believe should have been?

Yes, the decision to remove a possible green belt for Norwich on the green wedges (or other) model from the draft Local Plan is, in the opinion of CPRE Norfolk, unjustified, particularly bearing in mind the large degree of support it received in the earlier Stage A Regulation 18 Site Proposals and Growth Options consultation.

Q23 Do you support, object or have any comments relating to [the] approach to transport?

CPRE Norfolk supports the provision of new railway stations at Rackheath and especially Dussindale as outlined in paragraph 206.

We note the contradiction in the Transport for Norwich Strategy as reflected in Policy 4 – Strategic Infrastructure, when it aims ‘to promote modal shift’ by having ‘significant improvements to the bus, cycling and walking network’ on the one hand, but promotes ‘delivery of the Norwich Western Link road’ on the other. CPRE Norfolk fully supports the former set of aims while opposing the latter.

CPRE Norfolk supports ‘protection of the function of strategic transport routes (corridors of movement)’, and as part of this strongly suggests that no industrial development should be permitted on unallocated sites along such corridors of movement.

The desire to support ‘the growth and regional significance of Norwich Airport for both leisure and business travel to destinations across the UK and beyond’ surely contradicts the aspirations for addressing climate change stated within Section 4 of the draft GNLP?

Public transport provision needs to be improved and made affordable, not only between main towns and key service centres, but to and from smaller settlements. This is essential even without any further growth of these settlements, as many areas of rural Norfolk have become public transport deserts.

Q27 Do you support, object or have any comments to [the] approach to affordable homes?

CPRE Norfolk supports the affordable housing policy within Policy 5 – Homes. It is essential that the requirements of this policy are followed when progressing applications for housing on sites of 10 dwellings or more. Any policy which encourages the building of a greater proportion of affordable homes should be adopted. It is to be hoped that government policy will change further regarding viability tests so they become more transparent, so that it would be less easy for developers to evade their responsibilities to deliver affordable homes. More central government intervention is required if these needed homes are to be built. Ideally, affordable and social housing should be provided where needed as a stand-alone provision, and not be connected to private developers’ housing targets. Lessons must be learned from the history of poor delivery of affordable homes, to ensure that the policy to provide 28% or 33% affordable houses must be enforced. We support rural exception sites as a means of supplying needed local affordable and social housing. An approach based on the provision of stand-alone sites such as these, in our opinion is a far better method for addressing affordable and social housing needs.

Q34 Do you support, object or have any comments relating to the approach to employment land?

CPRE Norfolk while not agreeing with the allocation of so much green-field land for employment/economic use, it is essential that any such allocated sites are adhered to. This means that no exceptions should be made, particularly for larger businesses, to develop sites outside these allocated areas. If any such un-planned growth were to be permitted this would lead to further erosion of the area’s landscape and environment, along with issues regarding the sustainability of any such sites. A large amount of the land allocated in the JCS for employment use remains for use. The development of these sites should be prioritised before any new sites are added.

Q45 Do you support or object or wish to comment on the overall approach for the village clusters? Please identify particular issues.

“Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside. It is difficult to understand the justification for changing the current settlement hierarchy within the JCS to that proposed in this draft plan, in particular by eliminating the JCS categories of Service Villages, Other Villages, smaller rural communities and the countryside, which provided opportunities for a more nuanced approach to housing allocation, appropriate to each category of community/settlement within their own setting, landscape and context. The “village cluster” approach is a relatively crude one, with much more of a ‘one size fits all’ approach. CPRE Norfolk is particularly disappointed to see that the current JCS settlement hierarchy is not even offered as an ‘alternative approach’ in the draft GNLP, and wishes to see this rectified.

Even if the “village clusters” are adopted it would still be important to limit these to the area within their settlement boundaries and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.

The different approach for “village clusters” in Broadland compared to those in South Norfolk is not acceptable given the emphasis on the GNLP being a strategic plan for the whole of Greater Norwich. The “village clusters” in Broadland and South Norfolk should be treated in the same way if they are to be included in the final GNLP. This means that a maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’. We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

CPRE Norfolk is concerned by the use of primary school catchments acting as ‘a proxy for social sustainability’, with apparently no other sustainability measures being taken into account when decided on the amount and location of housing within “village clusters”. This does not make the proposed allocated housing within “village clusters” sustainable as required by the NPPF. Other measures should be taken into account within the social, economic and environmental spheres.

Q46 Do you support or object or wish to comment on the approach for specific village clusters? Please identify particular issues.

We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

Q47 Do you support or object or wish to comment on the overall approach for Small Scale Windfall Housing Development? Please identify particular issues.

CPRE Norfolk feels that windfall development should be restricted to sites within settlement boundaries. Housing need is already catered for by other policies in the Plan. Windfall developments should also count towards overall housing targets.

Q48 Do you support or object or wish to comment [on] any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

CPRE Norfolk does not understand why there has been a major change in direction and policy as to where new development should be allocated in the GNLP compared to the current JCS. The JCS was only finally fully adopted in January 2014, just over 6 years ago. In the JCS housing concentrated in and close to Norwich was agreed and supported by hugely expensive infrastructure projects, in particular the Northern Distributor Road (now known as the Broadland Northway), which was primarily constructed to distribute traffic form and to new housing developments on the northern fringes of Norwich and in the North-east Growth Triangle. It would be a massive and costly folly to change that policy to one which allowed for the dispersal of much housing across the rural areas of Broadland and South Norfolk, where there is insufficient infrastructure, services and public transport, which would mean such development would be unsustainable. This would only lead to more congestion and pollution, leading to problems in meeting carbon-reduction targets.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (the JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites.

It is very disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

We question the relevance of a plan whose horizon is 2038, which is likely to be reviewed and replaced on at least three occasions before its end-date, and we fear that on each of these occasions more unsustainable housing will be crammed in at the expense of the countryside. What is perhaps most disturbing is that so many people living in the area are not aware of the current JCS let alone the emerging GNLP, and that where citizens are engaged in the process seem to have their views discounted. For example, this is clear where the views of over 38% of the Broadland and South Norfolk Parish and Town Councils regarding the phasing of housing development are apparently ignored. Current consultation processes are not reaching the majority of people: perhaps a Citizens’ Assembly approach would be a means which would enable more people to be involved.

Re: Strumpshaw Settlement Boundary
Thank you for sending details of the Greater Norwich Local Plan. The existing settlement boundaries map which I requested from you does not appear to include the end part of my garden. I have enclosed a copy of the map and high-lighted the full extent of my property. Would you please amend your details and confirm that these have been corrected.

REEDHAM - GNLP2175, 1001, 3003, 2151
I have a number of concerns regarding the proposed sites in Reedham.
GNLP2175 - WITTON GREEN
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Specifically about this site - Sewage problems - In the last two years alone I have had to help my neighbour deal with the results of the completely inadequate sewage system in this area. The sewer at the end of the road adjoining Pottles lane regularly gets blocked and my neigbour's entire garden gets covered in raw sewage. All the sewage from 30 or 40 houses ends up on my neigbours lawn. When Anglian Water come they say the sewer was not originally designed for all the extra houses that have gone up over the last 20 years or so and the system can't cope. Anglian Water have had to do major bio-hazard clean up and the lawn has been returfed twice recently.
When I spoke to you about this you have said that Anglian Water have said there isn't a problem! - I don't feel you are getting accurate information about this area from Anglian Water.
The sewage system cannot deal with any more dwellings on this road and the new dwellings on GNLP2175 would be upstream of this problem just making it a lot worse.
WATER PRESSURE - I understand that on one occasion a fire engine was unable to get adequate water pressure to deal with a fire. On Witton Green (where I live) the water pressure often drops to well below an acceptable level and you just get a trickle. The problem has reached the point where many of us have switched back to old style storage tanks to ensure a constant supply and pressure.
OTHER PROPOSED SITES - GNLP2175, 1001, 3003, 2151
ROADS TO REEDHAM - The only Access to Reedham is from the A47 - it is locked in by the River. The main road from the A47 is tiny, winds a lot and goes through various other villages to get to the A47. It's about 8 miles that takes about 15 minutes to just get to the A47 at Acle. The roads are very narrow and very bad.
When we get snow we get locked in - last time (2 yeasr ago) for over a week it was completely unpassable. My partner tried to get home from work and ended up staying in Acle for 5 nights. (This has happened several times since I have lived here).
Recently (4 or 5 times in the last year) we have not been able to get in or out of the village due to roads flooding from rain. On two occasions in the last year the road has been blocked for 12 hours or more and we have been stranded.
A part of the road in Freethorpe (on the way to the A47) floods almost everytime it rains and has done so for years. It floods a nearby house and often remains unpassable.... And this is the main road in and out! It was like this about 10 days ago with only a relatively small amount of rain and has only just soaked away! (The solutiuon this time was to put temporary traffic lights up to make sure drivers didn't drive through the puddle - they have only just removed the lights).
My understanding is the the Highways Authority have told you that the roads are fine and there isn't a problem! - I don't think they are giving you reliable information.
The roads between Reedham and the A47 are no where near good enough to take anymore traffic associated with more development in this area.
OPEN SPACE - I notice in Norwich that the tendency is to leave some open spaces alongside new developments (and/or in between houses) leaving an open airy feel for people to enjoy. So it seems odd that in the villages there is a push to fill every gap with new houses which completely changes the character and feel of the village.
SCHOOL - You can't take into account capacity at the school because many of us choose not to send our children to Reedham School. Reedham School is a very small site, with 2 1/2 teachers - the size of the site means it can't get much bigger. Freethorpe School is much larger, has 6 or 7 teachers along with a wider variety of classrooms, teachers and pupils and so a lot of parents will prefer to send their children there as opposed to Reedham. So if you put more families in Reedham they probably won't use the local School.
Reedham School has always pushed for more children (and the funding that comes with them) but that doesn't mean it makes sense for Reedham parents to send their children there.
FINALLY - If over the coming decades there is going to be an ever increasing need for more housing then we will very quickly reach a point where no more houses can fit in the available boundary of a village. Ultimately the village boundary will have to moved further out.
Rather than ruin the feel and character of the village now perhaps it makes more sense to develop outside the Village (i.e. move the outer boundary) leaving the existing Village as it is.
However, any more development must also come with massive improvement of sewage systems, road drainage and widening and improvements of the road system to the A47 - All these are already not fit for purpose.

Please find attached a Regulation 18 Stage C Consultation Representation in relation to GNLP0125, Land West of West Lane, Horsham St Faith.