Question 48. Do you support or object or wish to comment any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

Comment

Representation ID: 22795

Received: 16/03/2020

Respondent: Strutt & Parker LLP

In response to Question 48, the below comments have been made in respect of the Greater Norwich Local Plan Interim Viability Study (November 2019) We are generally supportive to the approach taken but have some observations in respect of the detail which we hope are helpful:

Density (Table 4)
- Net areas are only used on Typologies 6-9, but are also applicable to Typology 4, where sites will also be required to provide on-site public open space, green infrastructure and SUDS, as well as often needing to gift land for community uses.
- The density figures are presumably based on the indicative mixes in Table 5, but these do not have any allowance for housing for older people (single-storey), which will again reduce density. This will mean that the proposed density of 25 dwelling per hectare (gross) will be difficult to achieve where large proportions of bungalows are to be included.
- The net: gross ratios are likely to be circa 66% on these sites, meaning a net density of circa 38 dph will be needed.

Housing Mix (Table 5)
- As mentioned above, there is nothing for single-storey accommodation, for example housing for older people and accessible housing, despite the strong demographic arguments which demonstrate the need to provide accommodation for an ageing population.
- While housing need may suggest the proportion of 3 bedroom homes should be high in the Main Towns, demand for market properties is likely to be higher for larger family properties. Such a high percentage of two bed houses seems high at the expense of 3 and 4+ bed family housing in the Main Towns. In particular, 8% of 4+ seems very low. Market demand is likely to be circa 20% of the private dwellings with 4+ bedrooms (13% aggregated).
- The 20% for flats also seems high, the market for private flats is limited in rural locations, so we would expect this to be closer to 10% overall.
- Again no information has been provided for single-storey properties
- The 3-bedroom house size (102 sq. m) is for a 6-person property, so comes out large at 1,100 sq. ft.

Affordable Housing (Table 7 & Table 15)
- Typology 4 (Main Town) is assessed at 28% Affordable Housing but 33% is sought by policy.
- At 28% (and with current assumptions) it is the 2nd least viable (£115,872 surplus) and as such, on the Sensitivity Testing it fails across all scenarios.
- Affordable Rent – 60% is very ambitious as a return, it is recognised in the report that the range is 45% to 65%, so 50% would be a better assumption to use.
- Affordable Ownership – again it is recognised that the range can be 60% to 80%, so 70% would be a better assumption than 75%.
- As mentioned in the caveats, no account has been taken of the 5% custom build policy requirement.

Access
- For specialist housing developments, all (not just 20%) of homes will meet at least the M4(2) access requirement, which adds up at £940 per dwelling. It is our consideration that a new house type is required for the Study.

RAMS
- A justification is required in relation to the recommendation for £200 per dwelling. This was recently revised down to £122 in neighbouring Suffolk.

Market Revenue
- The values do not correlate with what is currently on the market, especially for the 4 bedroom properties, for which the values are overstated by as much as 43%. The below tables show all of the new build (estate) houses on Rightmove as of the 18th February 2020.
(see attached document for additional figures (para 39)

Build Costs
- The costs for Bungalows will be higher than £1,221 per square metre and it is suggested that consideration of bungalows is included within the Study.
- The costs for Garages have been contained within the site and infrastructure costs. CIL will also be payable on the garages which will increased the cost.
- No allowance is made for ground conditions / ground water protection / flood risk. It is important that these are factored in.

Sites and Infrastructure Costs (Table 10)
- 15% seems low for site and infrastructure costs, it is considered that these costs will rise over the Plan period with increased electricity requirements etc.

CIL/S106 (Table 11)
- As mentioned above, Garages have been excluded but will be chargeable.
- For Typology 4 – the majority of the Main Towns are in Zone B so it would make sense to use the appropriate figure.
- The 2020 figures are now available and as such should be used (£70.46 per sq. metre).
- No allowance has been made for site-specific Section 106 works such as Public Rights of Way improvements etc.

Benchmark Land Value (Table 12a)
- The figure for Typology 4 is £432,432 / ha = £175k / acre (gross). This does not reflect that most land is purchased at a discount to reflect the planning and promotion risks / cost time. It also doesn’t consider sales agent and legal fees.
- Taking the example in the report shown below, the figure should be revised accordingly and checked against actual transactions to show that the transaction levels (and therefore expectations) are still far higher at circa £300,000 gross per acre.
- 7.5 acres @ £175k per acre = £1.312m
• minus Agent’s Fees @ 1.5% = £1.292m
• minus Sales Legal Fees @ £10k = £1.282m
• minus Recoverable Promotion Costs @ £150k =
£1.132m
• minus Promoter’s Share @ 20% = £906k
• = £121k per acre (= EUV x 12, not 17.5)

Comment

Representation ID: 22818

Received: 03/03/2020

Respondent: Marine Management Organisation

Please find attached our response letter. The first page contains general marine planning information and legal responsibilities. Pages two and three briefly details specific consideration for the Greater Norwich Local Plan.

In addition to this, if you would like further information on the East Marine Plans, I would be happy to provide a meeting covering general information on marine planning, monitoring and implementation of the east marine plans, tools for implementation and an update on the development of marine plans in England.

Comment

Representation ID: 22866

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Appendix 1 Infrastructure Requirements (and by extension Greater Norwich Local Plan Infrastructure Needs Report).

It is disappointing that there is no discussion on the Park and Ride system, or infrastructure for buses in general. There is also no discussion of public charging infrastructure for electric vehicles. We note that the review of Park & Ride sites has yet to be published, but would point out that the allocation of the proposed Loddon P&R site will provide the opportunity to complete the ring of P&R sites to serve each radial road route towards the city, and will be able to facilitate electric vehicle charging points at construction stage rather than by retro-fitting.

Comment

Representation ID: 22867

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Greater Norwich Local Plan Infrastructure Needs Report

There is no discussion of Park and Ride facilities, or of plans for buses in general – whilst the contents page states section 5.2 Bus and Rail, the section itself only discusses rail. If Greater Norwich is to achieve its vision of sifting towards sustainable transport methods, the requirement for additional bus capabilities and the infrastructure to serve them is a key requirement which must be planned for. The exclusion of bus infrastructure, including P&R facilities, is therefore an oversight which requires addressing. It is our opinion that there is a clear need for an additional P&R along the A146 corridor, and the GNLPINR should therefore include an assessment of further P&R requirements to ensure the appropriate infrastructure can be brought forward.

Comment

Representation ID: 22868

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Loddon P&R
It is considered that the Sustainability Appraisal's (SA) assessment of the Loddon P&R site has been undertaken in an overly broad manner, resulting in negative impacts being stated for categories where this is not justified. The matters will be discussed here in the order taken by the SA.

Objective 1 'Air Quality', the SA states air and noise pollution concerns occur because of its location adjacent to the A146. Any minor negative impact on air and noise quality at the site fails to take account of the circumstances of the site’s proposed use and the bigger picture. A Park and Ride will by nature have users which are transitory – being on the site no more than 15 – 30 minutes, and more importantly, the provision of P&R facilities improves air quality within the city centre, by removing cars that would otherwise drive in. Air quality and noise pollution should therefore not be counted as negatives against the proposal.

Under Objective 2 'Climate Change Mitigation and Adaption', the location of the site in Flood Zone 1 should be a major positive impact (rather than minor positive) as the proposal will locate end users on a site with the least possible risk of fluvial and surface water flooding.

Under Objective 3 'Biodiversity', a minor negative impact is stated because of the site being located within 5km of The Broads SAC and Broadlands SPA and Ramsar, and within the IRZ of the Yare Broads and Marshes SSSI. The provision of a P&R site in this location will not add to direct pressure on those sites, and ecological impacts can be mitigated within the design. Impact should therefore be neutral at worst.

The section on Objective 4 'Landscape' states development of the site would have a minor negative impact on the local landscape character. While it is accepted that the introduction of a P&R would invariably alter the character of the site itself, it is considered that impact on the wider countryside character could be appropriately mitigated through careful, landscaping-led masterplanning of the site. A full Landscape and Visual Impact Assessment will be submitted at a later stage to demonstrate the landscape effects of the proposed P&R scheme.

It is unclear how the proposed development could have a negative impact on access to local services, as stated under Objective 6 'Population'. A P&R would actually have the opposite effect, allowing a greater range of users easier access to services via public transport.

In a similar vein, under Objective 8 'Health' it appears the site has been assessed for health purposes as if the proposal is for housing. The proposal would not restrict access to the Norfolk and Norwich University Hospital. The site being located outside of the target distance of the nearest GP surgery, hospital and leisure centre is not of relevance to the proposed use as a P&R and should therefore not be recorded as a major negative impact.

The major positive impact on the local economy stated under Objective 11 'Economy' is agreed with. As well as creating jobs through the construction and operation of the P&R itself, there will also be a positive impact on the Norwich economy as the P&R will make it easier and more convenient for workers and visitors to travel into the city centre.

Under Objective 12 'Transport', the SA has recorded minor negative impacts in terms of access to bus and rail services. This conclusion is entirely contradictory to the purpose of a Park and Ride which will improve access to bus services for a range of people, allowing access into the city centre in a more convenient and sustainable manner. This should therefore instead be recorded as a major positive impact.

Objective 13 'Historic Environment' states potential impacts to designated heritage assets identified as the setting of the Grade II Listed Bixley Mill, Crown Point Registered Park and Garden, and the Scheduled Remains of Medieval Settlement 380m south of Park Farm. As only a minor negative impact has been identified by the Council, the development of the P&R site is not considered to result in substantial harm to the heritage assets. However, to ensure that development of the site appropriately takes into account the setting of the identified heritage assets, a detailed assessment of the potential impacts will be undertaken to inform the masterplanning of the site. With these measures, it is considered that heritage impact is not an onerous constraint to the allocation of the site.

Under Objective 15 'Water', it is stated that the site is within the catchment (Zone III) of a groundwater SPZ, and minor negative impacts are recorded due to a risk of groundwater contamination. It is considered that this risk can be effectively mitigated through the implementation of a robust drainage strategy tied in with the use of appropriate hard surfacing across the site, and there would therefore be no negative impacts.

Comment

Representation ID: 22869

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Park Farm

Park Farm has not been assessed in the Sustainability Appraisal. However, we make the following points:

Objective 11 – Economy. Development proposals which would result in a net increase in employment floorspace would be expected to have a major positive impact on the local economy.

Objective 14 – Natural Resources, Waste and Contaminated Land. In accordance with the core planning principles of the NPPF, development on previously developed land will be recognised as an efficient use of land. Development of previously undeveloped land and greenfield sites is not considered to be an efficient use of land, but there are wider considerations as to the appropriate use of greenfield sites. Development of an existing brownfield site would be expected to contribute positively to safeguarding greenfield land in Greater Norwich and have a minor positive impact on this objective.

Comment

Representation ID: 22870

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

WCP

SA Objective 1 – Air Quality and Noise notes that development at WCP could potentially expose site end users to higher levels of transport associated air and noise pollution. Traffic using the A47 and A146 would be expected to have a minor negative impact on air quality and noise at these sites. We propose that WCP is safeguarded for future country park-related development.

Railway Line: The north of Site GNLP3052 is located adjacent to a railway line. The proposed development at this site could potentially expose site end users to higher levels of noise pollution and vibrations associated with this railway. A minor negative impact would therefore be expected.

Air Pollution: The SA nots that WCP is proposed for non-residential end use and comprises 220.3ha. The proposed development at this site could potentially result in a significant increase in local air pollution; therefore, a major negative impact would be expected. However, this seems to assume that some form of high density commercial development is proposed, whereas we are proposing to safeguard the site for open space and leisure uses. The masterplanning for the site could achieve benefits in air pollution terms and the SA should therefore record a positive impact.

SA Objective 2 – Climate Change Mitigation and Adaptation. In terms of Fluvial Flooding, the SA notes that the north of the site is adjacent to Whitlingham Great Broad and located within Flood Zones 2, 3a and 3b, such that proposed development could potentially locate some site end users in areas at risk of fluvial flooding; therefore, a major negative impact would be expected. However, the extensive nature of the site means that any proposed leisure development can be located such that users are kept away from areas at risk of fluvial flooding. Therefore the SA should record a positive impact in relation to site GNLP3052.

Surface Water Flooding: Small areas within the site coincide with areas determined to be at low, medium and high risk of surface water flooding. Development would be expected to have a major negative impact on pluvial flood risk, as development would be likely to locate site end users in areas at high risk of surface water flooding, as well as exacerbate pluvial flood risk in surrounding locations. However, this assumes significant built development and significant ground coverage which is not the case. The appropriate design and management of the extensive green space will facilitate on-site flood attenuation, with knock-on reduction in risk to surrounding locations as a result of controlled run-off, such that the SA should record a major positive impact.

SA Objective 3 – Biodiversity, Geodiversity and Green Infrastructure. SSSI IRZ: This section of ‘The Broads’ SAC and ‘Broadland’ SPA and Ramsar is also designated as ‘Yare Broads and Marshes’ SSSI. The site is located within an IRZ which states that “all planning applications (except householder) outside or extending outside existing settlements/urban areas affecting greenspace, farmland, semi natural habitats” should be consulted on. The SA assumes a minor negative impact on the features for which these SSSIs have been designated would be expected, due to development on natural greenspace. However, our proposal is to safeguard the additional WCP land for country park use, which can only benefit biodiversity, both by providing / protecting it on site, and by providing space for leisure use, thus reducing human pressure on designated habitats elsewhere.

LNR: Site GNLP3052 coincides with ‘Whitlingham’ Local Nature Reserve. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park, which is coincident with this LNR. As this site is proposed for tourism and a Country Park, it is assumed that the developable area of the site will exclude the LNR itself, and therefore, a negligible impact on this LNR would be expected. We agree with this assessment.

CWS: Site GNLP3052 coincides with ‘Old Wood’, ‘Trowse Wood’ and ‘Trowse Meadows’ CWSs. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park, which is coincident with these CWSs. As this site is proposed for tourism use and a Country Park, it is assumed that the developable area of the site will exclude these CWSs, and therefore, a negligible impact on these CWSs would be expected. We agree with this assessment.

Priority Habitats: Site GNLP3052 coincides with deciduous woodland, coastal floodplain grazing marsh, and good quality semi-improved grassland priority habitats. The proposed development is considered by the SA to be likely to result in the partial loss of these habitats, and therefore, have a minor negative impact on the overall presence of priority habitats in the Plan area. However, the safeguarding of this site for additional country park usage means that habitats can both be safeguarded and created, leading to net gain.

SA Objective 4 – Landscape. National Park/Country Park: The majority of Site GNLP3052 coincides with The Broads National Park. A proportion of this area also coincides with Whitlingham Country Park. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park. The nature and exact location of the proposed development is unknown at this stage and therefore the impact on this National Park and Country Park is uncertain. Our proposal is to safeguard the site for country park usage, which can only benefit the country park as a whole.

Landscape Character: The majority of Site GNLP3052 is located within the LCA ‘Yare Valley Urban Fringe’. Some key characteristics of this LCA include the wide, flat floodplain, recreational landscape and green buffer between the river valley and Norwich City. Site GNLP3052 is proposed for recreation and tourism end use, and therefore, the proposed development at this site would be unlikely to be discordant with these key characteristics. We agree with this assessment.

Views from the PRoW Network: Site GNLP3052 coincides with a PRoW. Development could potentially alter the views experienced by users of the PRoW network; therefore, a minor negative impact on the local landscape would be expected by the SA. However, altered views are not necessarily altered in a negative way, and the impact should be recorded as neutral.

Views for Local Residents: Site GNLP3052 is located adjacent to the settlement of Trowse Newton. The SA considers that development would be likely to alter the views experienced by residents of surrounding dwellings to some extent, and therefore, a minor negative impact on the local landscape would be expected. However, as noted above, altered views are not necessarily altered in a negative way, and the impact should be recorded as neutral.

SA Objective 6 – Population and Communities. Local Services: The nearest local services WCP are Trowse Village Store in Trowse Newton, or Morrisons supermarket within Norwich City. The site is located outside the target distance to these services. The proposed development at these two sites could potentially have a minor negative impact on the access of site end users to local services. However, residential development is not proposed at this site, which is intended to be safeguarded for country park related development, thus a neutral impact should be recorded.

SA Objective 8 – Health. Main Road: the site is located adjacent to the A47, where development could potentially expose site end users to higher levels of traffic associated emissions, which would be likely to have a minor negative impact on the health of site end users. However, this assumes residential development, whereas we propose that the site is safeguarded for country park uses, and should therefore expected to have a minor positive impact on health.

GP Surgery: The closest GP surgery to the site is Lakenham Surgery, located approximately 1.5km to the north west, outside the target distance such that the SA assumes development would be expected to have a minor negative impact on the access of site end users to GP surgeries. However, the site is proposed for country park related uses, not residential development.

As the site is located outside the target distance to an NHS hospital, GP surgery and leisure centre, development would be expected to have a major negative impact on the health and wellbeing of site end users. However, the site is proposed for country park related uses, not residential development, such that these services would not be required on a day to day basis, and country park usage would have a positive impact on health in itself.

SA Objective 11 – Economy. Employment Floorspace: the site is proposed for tourism end use. This would be expected to result in the provision of employment opportunities in the local area, and therefore, a major positive impact on the local economy would be expected as a result of development at these four sites. Site GNLP3052 currently coincides with ‘Kingsley Farrington Boatyard’ and ‘Norfolk Snowsports Club’. Site GNLP3052 is proposed for tourism end use and it is assumed that the development will incorporate these existing facilities, and therefore, would be expected to result in a net gain in employment floorspace overall. We agree with this assessment.

SA Objective 12 – Transport and Access to Services. Bus Stop: the site is outside the target distance to a bus stop providing regular services. Therefore, the proposed development at these three sites could potentially have a minor negative impact on site end users’ access to bus services. However, this could change with the significant amount of development proposed for this part of Norwich and with the development of the Loddon P&R site we are promoting.

Railway Station: The closest railway station to the site is Norwich Railway Station, located approximately 3km to the north west. A large proportion of the site is situated outside the target distance to this station. Therefore, the proposed development at these two sites would be likely to have a minor negative impact on site end users’ access to rail services. However, we anticipate that the country park usage would be mainly beneficial for local users.

Pedestrian Access: The site is well connected to the existing footpath network. Development would be expected to have a minor positive impact on site end users’ access to the PRoW network and opportunities to travel by foot. We agree with this assessment.

SA Objective 13 – Historic Environment. Grade I Listed Buildings: The site is located approximately 40m from the Grade I Listed Building ‘Church of St Andrew’. The proposed development at this site could potentially alter the setting of this Listed Building, and therefore, a minor negative impact on the local historic environment would be expected by the SA. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Grade II* Listed Buildings: The site is located adjacent to the Grade II* Listed Building ‘Whitlingham Hospital Blocks 04, 05, 06’ and within 200m from several Listed Buildings along Yarmouth Road including ‘Thorpe Hall’ and ‘Walpole House’, but is separated from these Listed Buildings by the River Yare and woodland. Development at this site could potentially alter the setting of ‘Whitlingham Hospital Blocks 04, 05, 06’ and therefore a minor negative impact on the local historic environment would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Grade II Listed Buildings: Site GNLP3052 coincides with the Grade II Listed Building ‘Ruins of Trowse Newton Hall’ and is located adjacent to ‘Whitlingham Hospital Service Buildings, Block 03’, ‘Boundary wall and gateway at Whitlingham Hospital’, ‘Sunnydale’ and ‘Trowse Old Hall’. The proposed development at this site could potentially result in direct impacts on ‘Ruins of Trowse Newton Hall’ and therefore a major negative impact on the local historic environment would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Conservation Area: A small proportion of Site GNLP3052 coincides with Trowse with Newton Conservation Area. Therefore, the SA suggests development at this site could potentially alter the setting of this Conservation Area, and as such have a minor negative impact on the local historic environment. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Registered Park and Garden: Site GNLP3052 coincides with ‘Crown Point’ RPG. Development at this site could potentially have a direct impact on this RPG and therefore a major negative impact would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the RPG.

SA Objective 14 – Natural Resources, Waste & Contaminated Land. Previously Developed Land: All sites in this cluster comprise previously undeveloped land. Site GNLP3052 comprises 220.3ha of previously undeveloped land. The scale of development at this site is unknown at present, however, the proposed development could potentially result in a major negative impact on natural resources due to the loss of 20ha or more of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils. We disagree with this assessment, since our proposal relates to country park usage not extensive tracts of built development.

ALC: Site GNLP3052 is situated on ALC Grades 3 and 4 land. ALC Grade 2 and 3 are considered to be some of Greater Norwich’s BMV land. Therefore, a minor negative impact would be expected as a result of the proposed development at these four sites, due to the loss of this important natural resource. This assumes that the land would be built over, or would be available for agriculture, whereas we are proposing to safeguard the land for country park related uses, which are essentially reversible, such that a neutral impact should be recorded.

SA Objective 15 – Water B.52.15.1 SPZ: Sites GNLP3051, GNLP2069 and GNLP3049 coincide with the catchment (Zone III) of a groundwater SPZ. Site GNLP3052 coincides with the inner zone (Zone I), outer zone (Zone II) and catchment of a groundwater SPZ. The proposed development at these four sites could potentially increase the risk of groundwater contamination within this SPZ, and therefore, result in a minor negative impact on local groundwater resources

Watercourse: Site GNLP3052 is located adjacent to the River Yare, with a proportion of the site located within 200m of this watercourse. Development could potentially increase the risk of contamination of this watercourse, and therefore, a minor negative impact would be expected. However, contamination is unlawful, and planning controls exist to ensure any surface water drainage is carried through stages of filtration before any outfall into rivers. Given the proposed country park related uses, the SA should therefore record a neutral impact.

Comment

Representation ID: 22878

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Octagon Farm

SA Objective 1 – Air Quality and Noise. Air Pollution: The sites are proposed for the development of dwellings. Development could potentially result in a significant increase in local air pollution and have a negative impact on air pollution in the local area.

We consider this to be inappropriate, since air quality issues depend upon the context of the site being proposed for development. In the case of Octagon Farm, the sites does not fall within an air quality management area, and is not proposed to be developed in a way that result in such designation.

SA Objective 2 – Climate Change Mitigation and Adaptation. Carbon Emissions: Development could potentially increase local carbon emissions, as a proportion of South Norfolk’s total, by more than 0.1%. Therefore, a minor negative impact on South Norfolk’s carbon emissions would be expected. In response we assert that the design of the development has yet to be finalised. There are opportunities through development management policies to ensure carbon emissions are minimised.

Surface Water Flooding: A proportion of the site coincides with areas determined to be at risk of surface water flooding which would have a major negative impact on pluvial flood risk, as development would be likely to locate site end users in areas at high risk of surface water flooding, as well as exacerbate pluvial flood risk in surrounding locations. However, the development of the Octagon Farm site (both site references) provides the opportunity to incorporate on-site surface water attenuation, which will not only ensure development can be protected from flood risk, but also protect the Listed Octagon Barn itself, and by reducing off-site flows will also control peaks of flooding beyond the site boundaries. This would therefore be recorded as a positive impact.

SA Objective 4 – Landscape. Landscape Character: All sites in this cluster are located within the LCA ‘Poringland Settled Plateau Farmland’. Some key characteristics of this LCA include large scale open arable fields, woodland, and densely settled core area. The sites comprise large areas of pasture and arable land and could potentially be discordant with these key characteristics and would be expected to have a minor negative impact on the local landscape character. In this case, the site is well enclosed by vegetation, especially woodland to the north, so any landscape impact would be very localised and should therefore be recorded as neutral.

SA Objective 5 – Housing. Net Gain: Development would be expected to result in a major positive impact on housing provision. We agree with this assessment.

SA Objective 6 – Population and Communities. Local Services: The nearest convenience stores to this cluster, including Premier Grocery Store, Budgens, and One Stop Shop, are located within Poringland. The site is located either partially or wholly outside the target distance to these shops. Development could potentially have a minor negative impact on the access of site end users to local services. However, the site is proposed for mixed use development, where there is the opportunity to incorporate some top-up provision, and there are also bus stops immediately adjacent to the site.

Local Landscape Designations: Poringland contains several local landscape designations including Poringland Community Woodland, All Saints Road Open Space, Poringland Village Green and Carol Close play area. The list of sites are located within 600m from one or more of these features. The proposed development at these 16 sites would be likely to provide site end users with good access to these local features, and as such, result in a minor positive impact on opportunities for integration with the local community. We agree with this assessment.

SA Objective 8 – Health. Green Network: The site is located partially or wholly over 600m from a PRoW or public greenspace, and therefore, the proposed development at these four sites could potentially have a minor negative impact on the access of some site end users to the local green network. However, the development site provides the opportunity to incorporate public open space and circular walks through the masterplanning process, resulting in a positive impact.

GP Surgery: Old Mill Surgery and Heathgate Surgery are both located within Poringland. The site is located outside the target distance to these GP surgeries, and therefore, the proposed development at these twelve sites would be expected to have a minor negative impact on the access of site end users to GP surgeries. However, there are bus stops immediately adjacent to the site, to enable access by public transport.

Leisure Centre: The closest leisure facility to Poringland, Framingham Earl and Framingham Pigot is Riverside Leisure Centre, located approximately 7.2km north of the cluster. All 21 sites in this cluster are located outside the target distance to this leisure facility, and therefore, a minor negative impact on the health and wellbeing of site end users would be expected. However, there are bus stops immediately adjacent to the site, such that access can be facilitated by public transport, thus resulting in a neutral or positive impact.

SA Objective 10 – Education. Primary School: Poringland Primary School and Nursery is located in the centre of Poringland. The site is situated partially or wholly outside the target distance to this school. Development could potentially result in a minor negative impact on some site end users’ access to primary education. However, bus stops immediately adjacent to the site would facilitate a choice of accessibility.

Secondary School: Framingham Earl High School is located in the north of Poringland. The site is located within the target distance to this school, and therefore, development would be likely to result in a minor positive impact on site end users’ access to secondary education. We agree with this assessment.

SA Objective 11 – Economy. Primary Employment Location: Poringland Town Centre is located in close proximity to the Poringland, Framingham Earl and Framingham Pigot cluster. Roseberry Business Park is also located within 3km from this cluster. These locations would be expected to provide a range of employment opportunities for site end users. Therefore, the proposed development at all 20 sites would be expected to have a minor positive impact on the local economy. Employment Floorspace: The site is proposed for mixed use development including employment, commercial and business end uses. This would be expected to result in the provision of employment opportunities in the local area, and therefore, a major positive impact on the local economy would be expected as a result of development at this site. We agree with these assessments.

SA Objective 12 – Transport and Access to Services. Bus Stop: The site is located within the target distance to bus stops providing regular services. Development would be likely to have a minor positive impact on site end users’ access to bus services. We agree with this assessment.

Pedestrian Access: Site GNLP0321 is well connected to the existing footpath network. Development would be expected to have a minor positive impact on site end users’ access to the PRoW network and opportunities to travel by foot. Site GNLP1032 currently has poor access to the surrounding footpath network. Development could potentially have a minor negative impact on local accessibility. However, we assert that the joint development of these 2 sites at Octagon Farm would mean both could benefit from and facilitate further access to the PROW network.

SA Objective 13 – Historic Environment. Scheduled Monument: GNLP1032 is located approximately 300m from ‘Remains of Bixley Hall and associated garden water features’ SM, and Site GNLP0321 is located approximately 520m from this SM. Development could potentially have a minor negative impact on the setting of these SMs. However, it is unlikely, given the intervening woodland to the north of the sites, and the ability to masterplan the development taking account of the significance of the heritage asset. Therefore, this impact should be recorded as neutral.

SA Objective 14 – Natural Resources, Waste & Contaminated Land. Waste: Development for dwellings would be expected to increase household waste production by more than 0.1% in comparison to current levels in South Norfolk and could potentially result in a minor negative impact on waste generation. However, all residential development results household waste irrespective of its location.

Previously Developed Land: All sites in this cluster comprise previously undeveloped land. Development would be likely to result in a minor negative impact on natural resources due to the loss of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils. The combined site (8.48ha), would indeed result in the loss of undeveloped land, as is the case for all sites that are not brownfield. Given the significant numbers of new dwellings required, this is inevitable, and must be balanced with the positive impacts of providing housing, including affordable housing, and supporting the local economy and community vitality.

ALC: All sites in this cluster are wholly or partially situated on ALC Grade 3 land. Sites GNLP1032 and GNLP0485 are also partially situated on ALC Grade 2 land. All sites are situated on some of Greater Norwich’s BMV land. Therefore, a minor negative impact would be expected as a result of the proposed development at these 21 sites, due to the loss of this important natural resource. We agree, but given the significant numbers of new dwellings required, this is inevitable, and must be balanced with the positive impacts of providing housing, including affordable housing, and supporting the local economy and community vitality.

SA Objective 15 – Water. All sites in this cluster coincide with the catchment (Zone III) of a groundwater SPZ. The proposed development at these 21 sites could potentially increase the risk of groundwater contamination within this SPZ, and therefore, result in a minor negative impact on local groundwater resources. We assert that the planning process prevents contamination from occurring, since the design and construction of the development will be required to ensure staged filtration of surface water prior to reaching the groundwater. Proposed uses would not include heavy industry.

Watercourse: Site GNLP1032 is located adjacent to The Beck, with the majority of the site located within 200m of this watercourse. The proposed development at this site could potentially increase the risk of contamination of this watercourse, and therefore, a minor negative impact would be expected. We assert that the planning process prevents contamination from occurring, since the design and construction of the development will be required to ensure staged filtration of surface water prior to discharge to local watercourses. Proposed uses would not include heavy industry.

Comment

Representation ID: 22890

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

The following comments relate to the Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November, 19).

Whilst there is general support for the approach adopted and the collaborative approach that the GNLP Team are seeking to adopt, there is concern that the assumptions made within the Viability Study in relation to, amongst other things, sales values, build costs and benchmark land values are too generic and not backed up by comparable evidence. Further evidence on this is provided below.

● The assumed land values are too low and not representative of market values. Comparable evidence needs to be provided to justify the figures used.
● The assumption that 54% of dwellings are 3 bedroom is considered high. In addition, the number of 1 bedroom units will vary Norwich and the market towns, with the latter being lower.
● There appears to be no consideration of demographics. In our view, the identified housing mix should include a significant number of bungalows as the greatest rise within the age groups occurs in the 65 plus band. This will influence build cost, densities and sales values and is fundamental on any strategic site.
● Garages should be added into the build cost calculation.
● No allowance has been made for Abnormals. This should be included or, alternatively, the contingency should be increased accordingly.
● No allowance is made for planning or promotion costs.
● An allowance should be made for Services. These are becoming increasingly expensive particularly given the increased requirements anticipated through the Future Homes Standards Consultation.
● There is a concern that the £5,000 allowance for energy efficiency measures is too low.

Comment

Representation ID: 22914

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

The Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November 2019), only covers mainstream residential development, and not UEA related academic development or purpose-built student accommodation.

Notwithstanding this, the UEA are confident that the delivery of GNLP0133-B, GNLP0133-C, GNLP0133-D, GNLP0133-ER and GNLP0140-C are viable having regards to the policy requirements of the draft GNLP, alongside no factors that UEA are aware of, at this moment in time, which could prevent delivery of these sites. However, given the duration of the plan period, it is
important that there is sufficient flexibility within the plan to re-visit the viability of development projects/sites as they come forward and to reflect any changes in circumstances which could question the viability of fulfilling all policy requirements set out within the plan.

Comment

Representation ID: 22946

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

The Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November 2019), only covers mainstream residential development, and not UEA related academic development or purpose-built student accommodation.

Notwithstanding this, the UEA are confident that the delivery of GNLP0133-B, GNLP0133-C, GNLP0133-D, GNLP0133-ER and GNLP0140-C are viable, having regards to the policy requirements of the draft GNLP, alongside no factors that UEA are aware of, at this moment in time, which could prevent delivery of these sites. However, given the duration of the plan period, it is important that there is sufficient flexibility within the plan to re-visit the viability of development projects/sites as they come forward and to reflect any changes in circumstances which could question the viability of fulfilling all policy requirements set out within the plan.

Comment

Representation ID: 22966

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

The Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November 2019), only covers mainstream residential development, and not UEA related academic development or purpose-built student accommodation.

Notwithstanding this, the UEA are confident that the delivery of GNLP0133-B, GNLP0133-C, GNLP0133-D, GNLP0133-ER and GNLP0140-C are viable,having regards to the policy requirements of the draft GNLP, alongside no factors that UEA are aware of, at this moment in time, which could prevent delivery of these sites. However, given the duration of the plan period, it is important that there is sufficient flexibility within the plan to re-visit the viability of development projects/sites as they come forward and to reflect any changes in circumstances which could question the viability of fulfilling all policy requirements set out within the plan.

Comment

Representation ID: 23003

Received: 13/03/2020

Respondent: Bidwells

The Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November 2019), only covers mainstream residential development, and not UEA related academic development or purpose-built student accommodation.

Notwithstanding this, the UEA are confident that the delivery of GNLP0133-B, GNLP0133-C, GNLP0133-D, GNLP0133-ER and GNLP0140-C are viable, having regards to the policy requirements of the draft GNLP, alongside no factors that UEA are aware of, at this moment in time, which could prevent delivery of these sites. However, given the duration of the plan period, it is important that there is sufficient flexibility within the plan to re-visit the viability of development projects/sites as they come forward and to reflect any changes in circumstances which could question the viability of fulfilling all policy requirements set out within the plan.

Comment

Representation ID: 23031

Received: 13/03/2020

Respondent: Bidwells

The following comments relate to the Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November, 19).

Whilst there is general support for the approach adopted and the collaborative approach that the GNLP Team are seeking to adopt, there is concern that the assumptions made within the Viability Study in relation to, amongst other things, sales values, build costs and benchmark land values are too generic and not backed up by comparable evidence. Further evidence on this is provided below.

● The assumed land values are too low and not representative of market values. Comparable evidence needs to be provided to justify the figures used.
● The assumption that 54% of dwellings are 3 bedroom is considered high. In addition, the number of 1 bedroom units will vary between Norwich and the market towns, with the latter being lower.
● There appears to be no consideration of demographics. In our view, the identified housing mix should include a significant number of bungalows as the greatest rise within the age groups occurs in the 65 plus band. This will influence build cost, densities and sales values and is fundamental on any strategic site.
● Garages should be added into the build cost calculation.
● No allowance has been made for Abnormals. This should be included or, alternatively, the contingency should be increased accordingly.
● No allowance is made for planning or promotion costs.
● An allowance should be made for Services. These are becoming increasingly expensive particularly given the increased requirements anticipated through the Future Homes Standards Consultation.
● There is a concern that the £5,000 allowance for energy efficiency measures is too low.

Comment

Representation ID: 23091

Received: 16/03/2020

Respondent: Norfolk Wildlife Trust

Thank you for consulting Norfolk Wildlife Trust on the draft Greater Norwich Local Plan. We have attempted to comment wherever possible in response to the questions set out in the consultation, but have a number of comments which cover multiple policies or supporting documents and so have compiled our comments in this letter.

Our key overarching comments are given below, followed by specific responses to policy questions and supporting documents.

Future Impacts of Climate Change on Wildlife and Zero Carbon targets
Evidence is clear that the effects of climate change on Norfolk’s wildlife will be significant, in addition to the pressures it already faces from habitat loss, fragmentation, disturbance and invasive species. A recent paper highlighted the many species likely to be lost from Norfolk in response to a 2 degree temperature rise. Therefore, to avoid committing Norfolk to further unnecessary wildlife losses, and to safeguard natural areas critical to the storage and sequestration of carbon in the future, we strongly recommend that the plan takes every opportunity possible to help reach national carbon neutrality goals as soon as possible, locking in gains for climate change mitigation and adaptation in all new development. This should include zero carbon targets for new housing, in line with the examples set by Reading Borough Council in policy H5 of their recently adopted Local Plan.

Urban Greening
We strongly recommend the inclusion of a mandatory requirement for development to include green design features such as green roofs, walls and sustainable drainage. Such measures will contribute to a wide range of targets set out in Policy 2, improving the resilience of the built environment to climate change, improving building energy efficiency through improved insultation, reducing the urban heat island effect and reducing rates of rain run-off that contribute to flooding, in addition to the benefits to wildlife that this will provide by enhancing the ability of the urban environment to provide habitats and stepping stones for wildlife to move in response to climate change. Southampton City Council City Centre Action Plan and the London Plan show examples of successful inclusion of such policies in other city plans. For further information on the benefits or urban greening policies, see reports produced for the London Plan and by the Town & Country Planning Association on the benefits of urban greening policies.

Wildlife Site Safeguarding Consistency
We have not been able to identify any allocations which would result in the direct loss of County Wildlife Sites (CWS), although a few have CWS within their site boundaries with draft policies to safeguard them and manage them as green infrastructure. We note that for the remainder of the proposed allocations in proximity to wildlife sites (SAC, SPA, Ramsar, SSSI, CWS, Ancient Woodland, Local Nature Reserves, Protected Road Verges), some make reference to adjacent CWS and support safeguarding from indirect impacts and buffering with new green infrastructure, but not all. We recommend that all allocations should be reviewed against these criteria in order to ensure that appropriate policy wording can be included to safeguard them from damaging development. This will help ensure compliance with targets in the plan to ensure no losses and net gains for wildlife from development.

Biodiversity Net Gain and Nature Recovery Networks
The Environment Bill currently progressing through Parliament includes provisions for mandatory Biodiversity Net Gain (BNG) for all new development and the creation of Nature Recovery Networks (NRNs). A metric for the measuring of BNG has been consulted on extensively by DEFRA and is already available for use. Natural England have recently released advice on the establishment of NRNs, which clearly highlights the important role the planning system (and in particular the delivery of BNG) needs to play in the successful creation and maintenance of NRNs. Whilst we recognise that the Environment Bill has not yet been passed, it is highly likely that it will be passed before the next consultation stage of the GNLP. Therefore we recommend that detailed consideration is given to how the GNLP will help deliver measurable biodiversity net gain in all new development and ensure that the development and green infrastructure it promotes will help towards the delivery of an effective NRN for Norfolk. Given our expertise with landscape scale nature conservation projects, the Trust would be happy to discuss this in further detail with the GNLP team once the Environment Bill has passed and the requirements are clearer.

Comment

Representation ID: 23120

Received: 31/03/2020

Respondent: Salhouse Parish Council

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.

Comment

Representation ID: 23148

Received: 16/03/2020

Respondent: Hopkins Homes

Agent: Bidwells

The following comments relate to the Greater Norwich Local Plan, Interim Viability Study, prepared by
NPS Group (November, 19).
Whilst there is general support for the approach adopted and the collaborative approach that the GNLP
Team are seeking to adopt, there is concern that the assumptions made within the Viability Study in
relation to, amongst other things, sales values, build costs and benchmark land values are too generic
and not backed up by comparable evidence. A few specific comments are provided below:
• The assumed land values are too low and not representative of market values. Comparable
evidence needs to be provided to justify the figures used.
• Garages should be added into the build cost calculation.
• No allowance has been made for Abnormals. This should be included or, alternatively, the
contingency should be increased accordingly.
• No allowance is made for planning or promotion costs.
• An allowance should be made for Services. These are becoming increasingly expensive
particularly given the increased requirements anticipated through the Future Homes Standards
Consultation.
• There is a concern that the £5,000 allowance for energy efficiency measures is too low.
• The affordable rent values are included at 60% of Open Market Values. Based on recent
evidence we would suggest that this figure should be between 45%/50% of open market value.
• The intermediate units (Affordable Homes Ownership) are included at 75% of OMV. Based on
recent evidence we would suggest that assuming a shared ownership model, the figure should
be between 65% of open market value.

Comment

Representation ID: 23151

Received: 16/03/2020

Respondent: Gladman Developments

Duty to Cooperate
3.1.1 The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the
Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The
DtC requires local planning authorities to engage constructively, actively and on an ongoing basis
with neighbouring authorities on cross-boundary strategic issues through the process of ongoing
engagement and collaboration.1
3.1.2 The revised Framework (2019) has introduced a number of significant changes to how local
planning authorities are expected to cooperate including the preparation of Statement(s) of
Common Ground (SOCG) which are required to demonstrate that a plan is based on effective
cooperation and has been based on agreements made by neighbouring authorities where crossboundary
strategic issues are likely to exist. The revised Framework (2019) sets out that local
planning authorities should produce, maintain, and update one or more Statement(s) of Common
Ground (SOCG), throughout the plan making process2. The SOCG(s) should provide a written record
of the progress made by the strategic planning authorities during the process of planning for
strategic cross-boundary matters and will need to demonstrate the measures local authorities have
taken to ensure cross-boundary matters have been considered and what actions are required to
ensure issues are proactively dealt with e.g. unmet housing needs.
3.1.3 As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans
Local Plan examinations, if a Council fails to satisfactorily discharge its DtC, a Planning Inspector
must recommend non-adoption of the Plan. This cannot be rectified through modifications.
3.1.4 It is noted that in Norfolk there is a strong history of cross-boundary cooperation and engagement.
This exists locally with the production of the joint Core Strategy and now GNLP, the Norfolk Spatial
Planning Framework, and work associated with the Anglia LEP. It will be important, in order to meet
legal requirements and the tests of soundness, that this cross-boundary engagement continues
through remaining stages of plan preparation, with evidence of ongoing working and mechanisms
for this to continue beyond adoption of the GNLP.

Comment

Representation ID: 23188

Received: 27/04/2020

Respondent: Persimmon Homes (Anglia)

Number of people: 4

Agent: Bidwells

Viability Inputs
127. Revenues are overstated and unsubstantiated.
128. Discounts to affordable rent tenure are too low and do not reflect registered provider bids in the current market.
129. Build costs adopted are below BCIS median rates. No explanation or rationale is provided for this.
130. Build costs make no allowance for Part L of the 2020 Building Regulations nor for
regulations M49”) and M4(3).
131. The allowance for Site and Infrastructure works is likely to prove inadequate for most schemes. This allowance should not include the cost of garages which are a build cost.
132. Benchmark land values have been reduced by 30% from the 2017 Hamson report without any reference to data, reasoning or justification. The levels adopted are likely to prevent land coming forward for development.
133. The outcome of using the inputs chosen in the interim study produces appraisals that
very significantly over-state viability.

Typologies
134. We have focussed only on Typology 9 in this report. We make no comment about any other typologies.
135. A Typology for large (1,000 unit plus) schemes should be provided accounting for the specific infrastructure and community facilities these sites are expected to provide.
136. Without this typology, the study cannot be considered complete.

Appraisals
137. Based on our review of Typology 9 only, we consider the methodology adopted in the preparation of the appraisals to be sound.
138. We cannot calculate the interest charges to match those used in the interim study, but this is not unusual when comparing viabilities.

General
139. We are concerned that the instructions to the consultant that prepared the interim study are not made clear in the report. We are also concerned that there may be a conflict of interest that has not been declared.
140. Both issues undermine the veracity of the report and its conclusions, especially when combined with the consistent adoption of inputs that improve viability.
141. We are especially concerned at the lack of background data, reasoning and justification for many of the inputs to the interim study.

142. We therefore conclude that the NPS Interim Viability Study does not provide a reliable, robust or accurate assessment of viability for the purposes of the emerging GNLP.