Policy 1 - The Sustainable Growth Strategy

Inclusion of site GNLP4058 within the GNLP as an allocation. Please see accompanying Reg. 19 Consultation Statement for further information.

Please find details in the accompanying Reg. 19 Consultation Response Statement. My client's site ought to be included in the GNLP as an allocation.

No modifications proposed at this stage.

We support the soundness of the allocation of my clients site reference GNLP 3003 within the GNLP. Please see accompanying Reg. 19 Consultation Statement for further details.
No modifications proposed at this stage.

Housing Delivery

The GNLP aims to deliver 49,492 new dwellings to 2038: CPRE Norfolk contests this number for being unnecessarily high as it will not enable the delivery of sustainable development which should prioritise the use of brownfield over greenfield sites. It is worth noting that the Government in its response to the recent Changes to the Planning System consultation appears to indicate more room for divergence from the housing needs figure derived from the standard method. Aside from stating that the current standard method will be retained with additional tweaks, this response also specifies that the standard method should not be interpreted as a "target in plan making", but rather as a "starting point" which should be considered "alongside what constraints areas face, such as the Green Belt, and the land that is actually available for development" before making "the decision on how many homes should be planned for". The response goes on to insist on the fact that the standard method "does not override other planning policies, including the protections set out in Paragraph 11b of the NPPF (which specifically allows for a divergence from the standard method in cases where the scale of development would cause harm) or our strong protections for the Green Belt. It is for local authorities to determine precisely how many homes to plan for and where those homes are most appropriately located. In doing this they should take into account their local circumstances and constraints". This suggests that there is no need to increase the number of houses to be built way beyond the number required by the standard methodology, and instead it could be used to set lower targets due to local circumstances and constraints.

Delivery of such a large number of houses would make it difficult or even impossible to meet climate change targets, including the legally binding commitment to reach net zero by 2050, particularly as these are likely to be made more stringent during the life of the plan. If climate change is going to be the priority it should be, then the number of new houses in the plan should be kept to the legally required minimum rather than inflated to the proposed levels which are far above the legal requirement or “need”. Moreover, the location of any new housing should be reviewed in light of climate change targets and legislation, so that sites are allocated in the most sustainable locations, bearing in mind the importance of environmental factors in ensuring development is sustainable in the NPPF (paragraph 8), and a plan sound.

The GNLP proposes to have ‘enough committed sites to accommodate 22% more homes than “need”, along with a “contingency” location for growth, should they be required to offset any non-delivery. Additional opportunities will be



provided, particularly small scale growth at villages and on small brownfield sites across Greater Norwich, through additional windfall development’ (Reg. 19 GNLP Delivery Statement.) Having such a high buffer of 22% makes the GNLP unsound due to this almost certain to result in failure to meet necessary climate change targets, legislation and aspirations. The Reg. 19 GNLP at para. 53 notes that a 5% buffer is required by the NPPF, and yet a 22% buffer is being proposed.

It is important that prioritisation is given to the delivery of brownfield sites, in line with the Government’s stated intentions and the need to help to address climate change. If more new allocations and windfalls outside rural settlement boundaries are permitted then it is highly likely that development will take place there rather than on urban brownfield sites, where development may not be so streamlined or cost-effective for the developer.

There is clear and compelling evidence from historic completions that windfalls are highly likely to come forward for development, with the Reg. 19 GNLP forecasting that an estimated 4,450 resulting from windfall development will come forward during the plan period, and yet only 1,296 dwellings have been included as a windfall allowance. ‘As windfall delivery is likely to remain robustly high’, it would be sound to include a much higher number within this allowance, thus meaning that fewer new housing allocations would be required on less sustainable greenfield rural sites. This is also further evidence that a 22% buffer is unnecessarily high.

We note the inaccuracy in Reg. 19 GNLP para. 180 which states that 1,200 new houses in the South Norfolk Village Clusters Housing Allocations Local Plan (SNVCHAHA) plus 250 in the Diss and area Neighbourhood Plan totals 1,400, instead of 1,450.

We question the inclusion of a “contingency” site or sites, such as that at Costessey (Reg. 19 para. 181) for ‘around 800 homes’, but which we believe should also include those identified ‘to provide the opportunity and flexibility to accommodate around 5,000 additional homes to recognise that the 2018-based household projections indicate that growth may be higher than in the 2014-based projections which are used in the plan’ (page 15, GNDP agenda and papers, 7 December 2020.) These include 2,000 dwellings in East Norwich and 840 from sites in Colney, Cringleford, Harleston, Wymondham, Aylsham and Acle. These additional numbers of dwellings should only be included if there is a legal need to do so, otherwise the GNLP will include even more unnecessary and “unneeded” houses. We argue that a sound way to deal with this issue would be to introduce prioritisation or phasing of delivery for these numbers of houses which are beyond what is “needed”, whereby the additional or “extra” numbers are only included if actually “needed” following any revisions to that effect in the standard methodology. However, to address climate change issues more effectively, it would make more sense to include these additional sites given their more sustainable locations, particularly those in East Norwich for example, within the core GNLP, and then only add the additional numbers, consisting of housing sites in less sustainable locations if they become absolutely necessary. Given the already inflated buffer, this would mean that all new allocated sites for housing in the GNLP in village clusters in both Broadland and South Norfolk could be removed from the core plan, and only introduced if required once other more sustainable sites have been delivered. This would still allow existing allocations from the JCS to be included in the GNLP, but new sites in village clusters should be removed, along with those included to be delivered under policy 7.5, until or if such a time as a revised standard methodology requires these greater numbers.

It is important that the GNLP does not over-promise by allocating large numbers of sites for housing above and beyond what is “needed”. It is clear from the current JCS that the targets set were too high, as with five years left of the JCS 31,452 commitments remain. To reach the GNLP target of 49,492 houses an average annual delivery rate of 2,458 would be required over the period 2020 – 2038. The average annual delivery rate for 2011 - 2020 was 1,841, which is significantly below what would be required as an annual average delivery-rate for the GNLP. It would be more sound to



set a more realistic target figure, which would be more likely to be met: this would be easier and more likely to be achieved if the target is as low as can be permitted.

Building regulations are not currently stringent enough to ensure that new buildings are carbon neutral. This issue is meant to be addressed for 2025, but there is no guarantee this will happen, and it is therefore highly likely that a significant number of the planned new dwellings would be constructed to standards that contribute to climate change. To address this, the number of new allocations, particularly in less sustainable locations such as in most of the village clusters, should be kept to the legal minimum, rather than inflated to the current proposed level. Legal challenges such as that being pursued in South Oxfordshire by Bioabundance make it clear that the soundness and legal compliance of Local Plans can be challenged on climate change grounds. Central to this challenge is the contention that South Oxfordshire District Council’s Local Plan fails to comply with the Climate Change Act 2008 because of the amount of homes planned for the district.

GNLP Regulation 19 Consultation Response

CPRE Norfolk bases its submission on the following parts of paragraph 35 of the NPPF relating to the examination and soundness of local plans: that to be justified a plan must be based on proportionate evidence, and that a plan must be consistent with national policy, by enabling the delivery of sustainable development. In addition, there are some comments below which raise issues of legal compliance.

Climate Change

Section 19 (1A) of the Planning and Compulsory Purchase Act 2004 requires that: ‘development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority’s area contribute to the mitigation of, and adaptation to, climate change.’ Whilst the GNLP’s Climate Change Statement states that it will ‘have an effective monitoring regime to ensure evidence on reducing carbon dioxide emissions, recorded against the Climate Change Act and other key national statutory and policy frameworks’, it does not include clear evidence-based carbon reduction targets, which are needed for the GNLP to demonstrate how it will meet its legal obligations. This means that throughout the GNLP, policies should have carbon reduction at their core, which will be of great importance when considering location of development, transport planning, environmental policies, and others where sustainability is a key. Instead, the GNLP prioritises economic growth and development without putting the legal requirements of climate change front and centre. This is demonstrated by the statement at para. 158 that ‘the document meets the NPPF’s primary purpose for a local plan by providing the planning strategy for the pattern and scale of development to meet growth needs in Greater Norwich from 2018 to 2038’, whereas it should be stating that it meets the NPPF’s primary purpose for a local plan to provide for “sustainable development”.

The need to address Climate Change in line with national policies has not been fully met by the GNLP, despite the claim at para. 93 of the Reg. 19 GNLP that ‘mitigating the effects of climate change within the greater Norwich area is a cornerstone of the GNLP’. On reading various historic papers of the GNDP it is clear that Climate Change is consistently put second to the apparently more important growth. For example, at 2.2 of the GNDP Papers for 6 January 2020, it is stated that further work had been undertaken ‘reviewing the key messages and current thinking on climate change’. This illustrates the concern is for the message being delivered, rather than any real desire to ensure that policies within the GNLP put climate change to the fore. This is further supported by the minutes of the GNDP meeting of 26 September 2019 when it was noted that ‘some key messages (such as those in respect of climate change) had failed to keep up with current thinking and needed updating’, showing that it was accepted that the message on addressing climate change had to be improved, and yet there was no stated intention to see this translated into more robust policies.

It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable alternative for the location 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; reducing the need to travel and promoting the use of sustainable transport modes; 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 and other factors taken together the least desirable option as shown on this chart is Option 4: dispersal of development. However, this opportunity to start to address climate change and other sustainability measures was not taken, with a combination of development location options being chosen instead.



Para. 97 of the Reg. 19 GNLP states that ‘policies in the GNLP will need to contribute to national targets to reduce emissions, plan for transition to a post-carbon economy and ensure new development is adapted to a changed climate’. To achieve the latter in particular, excessive amounts of new housing in unsustainable locations not built to carbon neutral standards will fail to meet this requirement. The Reg. 19 GNLP Climate Change Statement when addressing the location of development states: ‘the policies covering the location of development ensure that new housing will be close to every- day services and jobs’ and ‘growth in villages is located where there is good access to services to support their retention.’ This is not always the case, with many rural housing site allocations and anticipated “windfalls” not being close to jobs or where there is good access to services, given the location of the majority of new allocated sites at the edge of settlements. Unfortunately, it is impossible to make comments about new allocation sites in South Norfolk’s village clusters due to the decoupling of the policy for these from the GNLP (See below.)

To make this sound, the total number of dwellings beyond the required amount should be reduced to the necessary minimum, and the locations of much of the new development changed to reflect the needs resulting from climate change. This should result in inclusion of the “additional” brownfield urban sites, such as those in East Norwich, and the withdrawal of many of the proposed sites in unsustainable rural locations, where there is poor access to public transport and local jobs, but instead a reliance on private cars, as well as delivery vehicles to support these new dwellings.

Housing Delivery

The GNLP aims to deliver 49,492 new dwellings to 2038: CPRE Norfolk contests this number for being unnecessarily high as it will not enable the delivery of sustainable development which should prioritise the use of brownfield over greenfield sites. It is worth noting that the Government in its response to the recent Changes to the Planning System consultation appears to indicate more room for divergence from the housing needs figure derived from the standard method. Aside from stating that the current standard method will be retained with additional tweaks, this response also specifies that the standard method should not be interpreted as a "target in plan making", but rather as a "starting point" which should be considered "alongside what constraints areas face, such as the Green Belt, and the land that is actually available for development" before making "the decision on how many homes should be planned for". The response goes on to insist on the fact that the standard method "does not override other planning policies, including the protections set out in Paragraph 11b of the NPPF (which specifically allows for a divergence from the standard method in cases where the scale of development would cause harm) or our strong protections for the Green Belt. It is for local authorities to determine precisely how many homes to plan for and where those homes are most appropriately located. In doing this they should take into account their local circumstances and constraints". This suggests that there is no need to increase the number of houses to be built way beyond the number required by the standard methodology, and instead it could be used to set lower targets due to local circumstances and constraints.

Delivery of such a large number of houses would make it difficult or even impossible to meet climate change targets, including the legally binding commitment to reach net zero by 2050, particularly as these are likely to be made more stringent during the life of the plan. If climate change is going to be the priority it should be, then the number of new houses in the plan should be kept to the legally required minimum rather than inflated to the proposed levels which are far above the legal requirement or “need”. Moreover, the location of any new housing should be reviewed in light of climate change targets and legislation, so that sites are allocated in the most sustainable locations, bearing in mind the importance of environmental factors in ensuring development is sustainable in the NPPF (paragraph 8), and a plan sound.

The GNLP proposes to have ‘enough committed sites to accommodate 22% more homes than “need”, along with a “contingency” location for growth, should they be required to offset any non-delivery. Additional opportunities will be provided, particularly small scale growth at villages and on small brownfield sites across Greater Norwich, through additional windfall development’ (Reg. 19 GNLP Delivery Statement.) Having such a high buffer of 22% makes the GNLP unsound due to this almost certain to result in failure to meet necessary climate change targets, legislation and aspirations. The Reg. 19 GNLP at para. 53 notes that a 5% buffer is required by the NPPF, and yet a 22% buffer is being proposed.

It is important that prioritisation is given to the delivery of brownfield sites, in line with the Government’s stated intentions and the need to help to address climate change. If more new allocations and windfalls outside rural settlement boundaries are permitted then it is highly likely that development will take place there rather than on urban brownfield sites, where development may not be so streamlined or cost-effective for the developer.

There is clear and compelling evidence from historic completions that windfalls are highly likely to come forward for development, with the Reg. 19 GNLP forecasting that an estimated 4,450 resulting from windfall development will come forward during the plan period, and yet only 1,296 dwellings have been included as a windfall allowance. ‘As windfall delivery is likely to remain robustly high’, it would be sound to include a much higher number within this allowance, thus meaning that fewer new housing allocations would be required on less sustainable greenfield rural sites. This is also further evidence that a 22% buffer is unnecessarily high.

We note the inaccuracy in Reg. 19 GNLP para. 180 which states that 1,200 new houses in the South Norfolk Village Clusters Housing Allocations Local Plan (SNVCHAHA) plus 250 in the Diss and area Neighbourhood Plan totals 1,400, instead of 1,450.

We question the inclusion of a “contingency” site or sites, such as that at Costessey (Reg. 19 para. 181) for ‘around 800 homes’, but which we believe should also include those identified ‘to provide the opportunity and flexibility to accommodate around 5,000 additional homes to recognise that the 2018-based household projections indicate that growth may be higher than in the 2014-based projections which are used in the plan’ (page 15, GNDP agenda and papers, 7 December 2020.) These include 2,000 dwellings in East Norwich and 840 from sites in Colney, Cringleford, Harleston, Wymondham, Aylsham and Acle. These additional numbers of dwellings should only be included if there is a legal need to do so, otherwise the GNLP will include even more unnecessary and “unneeded” houses. We argue that a sound way to deal with this issue would be to introduce prioritisation or phasing of delivery for these numbers of houses which are beyond what is “needed”, whereby the additional or “extra” numbers are only included if actually “needed” following any revisions to that effect in the standard methodology. However, to address climate change issues more effectively, it would make more sense to include these additional sites given their more sustainable locations, particularly those in East Norwich for example, within the core GNLP, and then only add the additional numbers, consisting of housing sites in less sustainable locations if they become absolutely necessary. Given the already inflated buffer, this would mean that all new allocated sites for housing in the GNLP in village clusters in both Broadland and South Norfolk could be removed from the core plan, and only introduced if required once other more sustainable sites have been delivered. This would still allow existing allocations from the JCS to be included in the GNLP, but new sites in village clusters should be removed, along with those included to be delivered under policy 7.5, until or if such a time as a revised standard methodology requires these greater numbers.

It is important that the GNLP does not over-promise by allocating large numbers of sites for housing above and beyond what is “needed”. It is clear from the current JCS that the targets set were too high, as with five years left of the JCS 31,452 commitments remain. To reach the GNLP target of 49,492 houses an average annual delivery rate of 2,458 would be required over the period 2020 – 2038. The average annual delivery rate for 2011 - 2020 was 1,841, which is significantly below what would be required as an annual average delivery-rate for the GNLP. It would be more sound to set a more realistic target figure, which would be more likely to be met: this would be easier and more likely to be achieved if the target is as low as can be permitted.

Building regulations are not currently stringent enough to ensure that new buildings are carbon neutral. This issue is meant to be addressed for 2025, but there is no guarantee this will happen, and it is therefore highly likely that a significant number of the planned new dwellings would be constructed to standards that contribute to climate change. To address this, the number of new allocations, particularly in less sustainable locations such as in most of the village clusters, should be kept to the legal minimum, rather than inflated to the current proposed level. Legal challenges such as that being pursued in South Oxfordshire by Bioabundance make it clear that the soundness and legal compliance of Local Plans can be challenged on climate change grounds. Central to this challenge is the contention that South Oxfordshire District Council’s Local Plan fails to comply with the Climate Change Act 2008 because of the amount of homes planned for the district.

The GNLP and South Norfolk Village Clusters

CPRE Norfolk challenges the decoupling of the housing allocations for the South Norfolk Village Clusters and its associated policy from the rest of the GNLP as being unsound. The GNLP Regulation 19 consultation has commenced before the South Norfolk Village Clusters Housing Allocations document (SNVCHA) has been published for its Regulation 18 consultation. This is despite the South Norfolk Local Development Scheme (accessed 18 February 2021 when it was labelled as “final”) stating that the SNVCHA will be consulted on in February/March 2021. While it is reasonable for a Local Plan to comprise several separate documents, the GNLP and the SNVCHA to be sound should follow the same, or at least a very similar timetable, otherwise it is impossible to judge whether the two (or more) documents are based on proportionate evidence. This clear link is demonstrated by the GNLP setting the overall numbers of new houses to be included in the SNVCHA, and by the GNDP meeting of 10 July 2020 noting that the GNDP would ‘consider whether the “minimum” reference can be amended in the Reg. 19 version of the GNLP as the SNVCHA plan progresses’ (page 20, GNDP papers, 10 July 2020.) Given that the SNVCHA Regulation 18 consultation had not started when the GNLP Regulation 19 consultation had done so makes the latter unsound, as the SNVCHA had not progressed sufficiently for a potential change to the “minimum” reference be considered, nor has ‘evidence been provided for the Regulation 19 version to show the sites to meet the minimum 1,200 housing requirement in SNVCHAs’ (page 20, GNDP papers, 10 July 2020.) By including the “minimum” term, it is possible that the SNVCHA could include new housing allocations of a far greater number than 1,200, as that would still fall within the definition of a “minimum” number. This potential change in housing numbers within the GNLP would further increase the housing numbers beyond an already inflated number. We note that the Reg. 19 GNLP Table 6 states there will be 1,200 houses in the SNVCHA not a “minimum” of 1,200.

Moreover, the Reg. 19 GNLP states in para. 136 that: ‘homes here [in our suburbs, market towns and villages] will be built at appropriate densities to respect and enhance local character and to meet the needs of all in mixed communities.’ CPRE Norfolk contends that it is impossible to ensure this will take place given the independence of the SNVCHA to make its own conclusions regarding densities of new housing and its location within the village clusters. This is supported further by the Reg. 19 GNLP Climate Change Statement which states that ‘growth in villages is located where there is good access to services to support their retention’ It is impossible for this statement to be accurate given the decoupling of the SNVCHA from the GNLP regarding the location of housing in village clusters in South Norfolk.

It is also worth commenting on South Norfolk District Council’s Statement of Community Involvement (amended version September 2020, accessed on 18 February 2021.) Here, the emerging Local Plan is described as the GNLP (para. 39) with no reference to the SNVCHA, which is misleading and inaccurate. Also, the GNLP is described as covering the period to 2036 (para. 41), whereas it should be until 2038.



Policy 7.5 Small Scale Windfall Housing Development

As explained above CPRE Norfolk contends that as there is no “need” for the high numbers of additional new housing, and given the generally unsustainable locations of any new housing under this policy, the policy should be considered to be unsound. Existing allocations in the JCS to be carried forward to the GNLP will allow for support of local services and the maintaining of rural vitality, without needing additional new sites within village settlement boundaries, but especially without the need for the provision of new market housing outside settlement boundaries as would be permitted under this policy. Furthermore, the very high level of current commitments, in excess of 31,000, provides developers with the flexibility that is necessary to address housing need. There can be no justification for adding in additional site options on the grounds that further flexibility is required to ensure delivery.

If, despite these concerns, the policy is included in the GNLP we feel that its wording needs to be amended to remove ambiguity and help ensure communities with greater certainty as to where new development could be permitted. This should include a clearer definition of how a proposal should “respect” the form and character of the settlement. We also suggest that developments under this policy should not be permitted where there is a made Neighbourhood Plan.

The Norwich Western Link Road

The inclusion of this proposed road is incompatible with the climate change statement and various other statements in the Reg. 19 GNLP e.g. in para. 141: ‘for journeys that are still needed there will be a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ Policy 4 – Strategic Infrastructure suggests that ‘a virtuous circle where clean transport is prioritised, less use is made of cars’ will partially be achieved by delivery of the Norwich Western Link road. This is unsound as the creation of this new road would lead to an increase in car and other motor vehicle use, as shown in ‘the end of the road? Challenging the road-building consensus’ (CPRE, 2017.)

Consultation

The GNDP papers and minutes for their meeting of 10 July 2020 make it very clear that more time was required to ensure soundness of the plan, as well as laying out and agreeing on the need for a further six weeks focused Reg. 18 consultation to take place from 2 November 2020 – 14 December 2020. The papers for the meeting explain that ‘this means it will be possible to undertake further focused consultation on possible changes to the plan without introducing further delay to the timetable. This is considered advantageous in reducing risks to soundness and allowing improvements to the plan’ (para. 2.2. GNDP Board papers, 10 July 2020.) However, at the subsequent GNDP meeting it was agreed not to hold this Reg. 18d consultation but instead to push on to the Reg. 19 consultation, thereby denying the opportunity for people, organisations and other stakeholders to comment on what was to be included in the Reg. 18d consultation. In particular, there has been no opportunity to comment in a consultation on the suitability or otherwise of new sites which were brought forward during and around the Reg. 18c consultation, nor to comment on any amendments to policies made since publication of the Reg. 18c consultation documentation. It is clear that this consultation was considered to be necessary in July 2020 and yet this consultation has not taken place, making the Reg. 19 GNLP unsound.

This lack of consultation in the form of an invitation to make representations about what the local plan ought to contain with regard to these new sites and policy amendments is in the view of CPRE Norfolk contrary to provision 18 of The Town and Country Planning (Local Planning) (England) Regulations 2012, and therefore is not legally compliant. This view is further supported by the failure of the three local authorities, Broadland District Council, South Norfolk District Council and Norwich City Council to comply with their respective Statements of Community Involvement with regard to



consultation on Local Plans, by not consulting on these significant additions and amendments to the GNLP, particularly as, unlike the current JCS, the GNLP will include policies and proposals for individual sites instead of having separate Site Allocation plans for the individual districts.

Green Belt

CPRE Norfolk contends that insufficient baseline evidence has been collected and evidence gathered to keep this under review. There has not been an examination of comprehensive and proportionate evidence for the establishment of a Green Belt for Norwich.

Para. 118 of the Reg. 19 GNLP merely states that ‘Greater Norwich does not have a nationally designated Green Belt. National Policy is clear that new Green Belts should very rarely be established. Therefore this plan will need to carry forward policies for protecting our valued landscapes.’ Instead, CPRE Norfolk argues that a thorough examination of the evidence for a Green Belt should have been carried out and published as, although rare, the NPPF does allow for the creation of new green belts in the right circumstances.

This is in part shown by the answer to a question from CPRE Norfolk to the GNDP for their meeting of 16 December 2020. The question was:
CPRE Norfolk notes that the GNLP Reg 19 v1.4 at paragraph 117 states that: "Greater Norwich does not have a nationally designated Green Belt. National policy is clear that new Green Belts should very rarely be established. Therefore, this plan will need to carry forward policies for protecting our valued landscapes."

We are concerned that the GNLP has reached this stage without a more thorough and detailed (at least one that is available publicly) consideration of the provision of a Green Belt for Norwich, preferably on the "green wedges" model. CPRE Norfolk would like an explanation as to why the exceptional circumstances for creation of a Green Belt for Norwich as required by the NPPF do not exist.

The wholly exceptional circumstances around the current Covid-19 crisis are just one example which demonstrates not only how essential it is to maintain and protect green spaces, but also how circumstances have changed since earlier drafts of the GNLP. Moreover, the Government’s proposed changes to the planning system and housing requirements suggest that more robust protection of valued green spaces is now more pressing than ever, along with the long-term need for climate change mitigation which the provision of a Green Belt would help to guarantee.

The GNLP Officer response was:

The Green Belt issue was thoroughly addressed in the Regulation 18A consultation Growth Options document. This clearly set out the national policy requirement to demonstrate exceptional circumstances to establish a new Green Belt. All responses to the consultation are included in the Draft Statement of Consultation published in September 2018. No evidence has been provided at any stage through the Regulation 18 period that demonstrates such exceptional circumstances. The GNLP provides strong polices to protect green spaces and enhance green infrastructure.

Covid-19 is an exceptional circumstance nationally, it is not exceptional to the local plan area. The CPRE are correct to point out that the pandemic has reinforced the importance of green spaces, but in this respect the most significant need is for green space to be accessible. The function of Green Belts is not to provide accessible



green space; this is best provided through a green infrastructure strategy. Similarly, the function of a Green Belt is not to address climate change. Indeed, because development may need to leap-frog Green Belts, they can be detrimental to climate change by extending commutes and other travel needs. The issue may need to be reconsidered in the next local plan to address any relevant requirements of the proposed new planning system and to take account of any new settlement proposals.

The response makes clear that ‘no evidence has been provided at any stage through the Regulation 18 period that demonstrates such exceptional circumstances’, which implies that such evidence has not been sought, and that therefore the Green Belt issue has not been thoroughly addressed by the GNDP. For the potential of a Green Belt to have been ‘thoroughly addressed’ as is claimed in the response, then such evidence should have been gathered for the Local Plan’s body of evidence, to be considered both comprehensive and proportionate. CPRE Norfolk provides such evidence in the following section of its submission to demonstrate in part that the necessary exceptional circumstances required for an establishment of a Green Belt for Norwich, on the ‘green wedges’ model, do exist. It is our belief that a decision not to pursue a Green Belt for Norwich through inclusion within the draft GNLP was taken without a full assessment of the evidence having taken place, which therefore raises questions about both the legal compliance and soundness of the Plan. To address this, the evidence for a Green Belt for Norwich needs to be fully assessed and, CPRE Norfolk suggests, a Green Belt on the ‘green wedges’ model should be incorporated into the GNLP. This evidence is presented below in A Green Belt for Norwich? A paper by CPRE Norfolk.



A Green Belt for Norwich? A paper by CPRE Norfolk

1. Summary

1.1 Unlike many major cities Norwich does not have a Green Belt, and at present the draft GNLP does not have provision for one. This is explained on the GNLP website:

• Green Belts do not stop development but move that pressure from the edges of a city to surrounding ‘satellite’ towns;

• under Government policy, new Green Belts can only be set up in exceptional circumstances;

• in Greater Norwich, the control of development in the countryside is done through the use of countryside protection policies – backed by Government policy, known as the National Planning Policy Framework (NPPF), the use of countryside protection policies will continue in the new local plan.

1.2 This paper sets out the reasons why a Green Belt could and should instead be considered as a key planning tool for Greater Norwich, and be introduced in the next draft of the GNLP. It will show how establishing a Green Belt in Greater Norwich would meet the tests set out in the NPPF 2019.

1.3 Part of the context for this paper is the response given to a question asked by CPRE Norfolk to the GNDP at their meeting on 16 December 20210, which in part explained that “the Green Belt issue was thoroughly addressed in
the Regulation 18A consultation Growth Options document”, and that “no evidence has been provided at any stage through the Regulation 18 period that demonstrates such exceptional [as required by the NPPF] circumstances”. If the Green Belt issue has been thoroughly addressed then CPRE Norfolk suggests that this process should have included an evidential assessment. This paper seeks to address this issue.



1.4 Greater Norwich has experienced a substantial amount of development over the last 70 years, with further growth a key part of central and local government policy in the future. This pressure to provide large amounts of new housing and other development means that the countryside around Norwich, which is one of its greatest assets and which helps define the identity of the towns and villages across the area, is at risk from urban sprawl. The current coronavirus crisis has highlighted the importance of our countryside and green spaces, and the GNLP provides an opportunity for ensuring this remains available to all citizens in the years ahead, through implementation of a Green Belt to more securely check the sprawl of Norwich than is possible with the currently proposed GNLP draft policies.

2. National Context

National Planning Policy Framework (NPPF) 2019

2.1 The NPPF sets out the Government’s policy direction on planning which has at its core the aim to promote sustainable development.

2.2 The Government’s position on Green Belts is set out in Chapter 13, Protecting Green Belt Land. It has retained much of the advice of the previous version of the NPPF.

2.3 The fundamental aim of Green Belts is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence (NPPF 133.)

2.4 The NPPF identifies five purposes of Green Belts (NPPF 134):

• check the unrestricted sprawl of large built-up areas;

• present neighbouring towns merging into one another;

• assist in safeguarding the countryside from encroachment;

• preserve the setting and special character of historic towns; and

• assist in urban regeneration by encouraging the recycling of derelict land and other urban land.

2.5 New Green Belts should only be established in exceptional circumstances e.g. planning for larger-scale development such as new settlements or major urban extensions. In proposing a new Green Belt local planning authorities are advised to (NPPF 135):

• demonstrate why normal planning and development management policies would not be adequate;

• whether any major changes in circumstances have made the adoption of this exceptional measure necessary;

• show what the consequences of the proposal would be for sustainable development;

• demonstrate necessity for the Green Belt and its consistency with local plans for adjoining areas; and

• show how the Green Belt would meet other objectives of the Framework.

2.6 When drawing up Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences of channeling development towards



urban areas inside the boundary, towards towns and villages within the Green Belt or towards locations beyond the outer boundary (NPPF 138.)

2.7 When defining boundaries plans should satisfy six criteria (NPPF 139):

• ensure consistency with the development plan’s strategy for meeting the identified requirements for sustainable development;

• not include land which it is unnecessary to keep permanently open;

• where necessary identify areas of safeguarded land between the urban area and the Green Belt in order to meet longer-term development needs stretching beyond the plan period;

• make clear that the safeguarded land is not allocated for development at the present time and permission should only be granted following an update to a plan;

• demonstrate that the boundaries will not need to be altered at the end of the plan period; and

• define boundaries clearly using physical features that are readily recognizable and likely to be permanent.

2.8 Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use: such as looking for opportunities to provide access, to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity or to improve damaged and derelict land (NPPF 141.)

3. Greater Norwich Context

3.1 Development in Greater Norwich over the last 70 years has been significant with further substantial development proposed by 2038, currently consisting of a GNLP target (Total Housing Potential) for 49,492 houses to be built during the period 2018-2038.

3.2 The location and scale of development that has already taken place has produced considerable negative impacts on the countryside around Norwich. Existing settlements such as Wymondham, Aylsham, Acle, Loddon and Wroxham have experienced substantial growth in addition to large-scale development on the edges of Norwich. In effect, new communities have been developed including those within the north-east Growth Triangle. The areas of countryside between the settlements which play such an important part in framing their character and identity have been significantly diminished.

3.3 To accommodate future development in Greater Norwich the local planning authorities are having to consider land in sensitive locations which is likely to have further significant impacts on the existing settlement pattern. For example, major site allocations are proposed at Easton, Hethersett, Cringleford, Thorpe Marriot and Hellesdon.

3.4 With high levels of further growth being planned there is a strong risk of urban sprawl and excessive encroachment into the countryside.
4. The Planning Case for a Green Belt for Norwich

4.1 The NPPF is very clear in setting out the approach to the establishment of new Green Belts. It identifies five purposes for Green Belts and five tests to be satisfied for designation in strategic plans (see 2.4 and 2.5 above.) This section of the



paper sets out how in CPRE Norfolk’s view these tests can be met and that the GNDP authorities can and should support the principle of establishing a Green Belt and develop a detailed programme for defining a boundary.

Why normal planning and development management policies are not adequate.

4.2 In Greater Norwich the policy approach to protecting the settlement pattern and character of the area has been based on the designation of strategic gaps and landscape protection zones around the Norwich southern bypass, the protection of river valleys and other countryside protection policies such as the Joint Core Strategy’s Policy 1: addressing climate change and protecting environmental assets. Whilst these policies recognise the importance of maintaining the separation of settlements, they have not been sufficiently robust in preventing the loss of land between settlements resulting in the planned virtual coalescence of for example, Hethersett and Wymondham, Hellesdon and Drayton, and Colney
and Cringleford. The GNLP currently looks to continue and expand upon these policies e.g. by enhancing green infrastructure.

4.3 In the decision-making process, particularly when there has been a shortfall in the supply of housing land, the weight of decision favours the use of land for development. Where there is a shortfall in housing land supply, Inspectors at Section 78 appeals have granted permission for development on land within these ‘protected’ areas (e.g. Planning Inspectorate references: APP/L2630/W/15/3007004; APP/L2630/W/16/3145810; APP/L2630/W/16/3145810.)

4.4 This suggests that the current and proposed draft GNLP policies which seek to protect the gaps between settlements are failing in their objective to prevent coalescence and sprawl.

4.5 Planning policies which seek to retain settlement character and the setting of settlements and promote green infrastructure do not carry the same status or weight as a Green Belt designation, i.e. very special circumstances do not have to be demonstrated. The designation of a Green Belt would introduce that test to protect against ‘inappropriate development’.

Major changes in circumstances have made the adoption of this exceptional measure necessary

4.6 The recent months of the Coronavirus crisis have shown the importance of our green spaces, as has been demonstrated by various reports and surveys e.g. a CPRE and Women’s Institute commissioned poll on attitudes to green spaces and community spirit during the lockdown (results at https://bit.ly/3c6Yc1U ;) the Wildlife Trusts’ five-year review of ‘30 Days Wild’; a YouGov survey commissioned by CPRE and the HomeOwners Alliance (results
at https://bit.ly/36Gm1Md .) The importance of wildlife, nature and the countryside are widely acknowledged as being beneficial to mental and even physical health, with access to green spaces being important to all. Therefore, the need to retain green spaces around Norwich and to maintain gaps between various settlements is clear, whilst acknowledging that Green Belts per se are not intended to provide better access to green spaces.

4.7 England’s Green Belts were largely established in the aftermath of the Second World War when the need to stop urban sprawl and the merging of settlements was recognised, along with the need to preserve the character of historic towns and to encourage development to be within existing built-up areas. The current crisis, combined with the pressing demands of climate change are an exceptional set of circumstances that should lead to a re-calibration of priorities, with the GNLP providing the opportunity for maintaining a green setting for the historic city of Norwich and protection of important green corridors from harmful development, whilst enabling necessary development and economic growth to take place, as well as providing the opportunity for securing better access to countryside.



4.8 The pressure for development is significant. The Greater Norwich authorities are planning for 49,492 new homes by 2038 (GNLP Reg. 19), along with similarly ambitious plans to grow the economy, jobs and infrastructure. Such growth is at a historically exceptional level. The fact that 49,492 homes are being proposed for inclusion in the GNLP shows exceptionality, due to the fact that this number is 22% above the figure for housing need: if this figure was kept to the legal requirement of 40,541 plus a 5% buffer, giving a total of 42,568, this particular exceptional factor would be removed.

The consequences of the proposal for sustainable development

4.9 A Green Belt would be central to the development of a robust strategy for delivering sustainable development in Greater Norwich. The NPPF identifies three elements/objectives of sustainable development.

Economic objective

4.10 Planning should help build a strong, responsive and competitive economy. A Green Belt would form part of a strategic approach which would provide for new development opportunities. It would support the economic development of Greater Norwich by supporting the retention and enhancement of its natural environment and landscape.

Social objective

4.11 Planning should support strong and vibrant communities by providing homes in a well-designed and safe environment with accessible open spaces that promote their health, social and cultural well-being. A Green Belt would retain areas of countryside close to Norwich and other settlements, providing opportunities for recreation and promoting access to it. It would retain the identity of settlements that are highly valued by residents and support the continued regeneration of existing urban areas.

4.12 The countryside around cities and towns has a particular role to play in encouraging healthy lifestyles and wellbeing. Green Belts provide a breath of fresh air for at least 30 million people who currently live in areas surrounded by Green Belts. The particularly strong planning controls provided by Green Belt policy provide a clear visual distinction between city/town and country on the edge of England’s largest and most historic cities, and contribute to a good quality of life within them.

Environmental objective

4.13 Planning should protect and enhance the natural environment to help improve biodiversity and mitigate and adapt to climate change. A Green Belt designation would complement initiatives such as the Green Infrastructure Plan and Corridors.
4.14 Current planning policies exercise very little control over the management of land leading to a poor quality of environment. A Green Belt designation would provide a robust and long-term framework for developing proposals for a proactive approach to land management which could enhance the quality of the environment around Greater Norwich for the benefit of residents.

Necessity for the Green Belt and its consistency with the strategic local plans for adjoining areas

4.15 The case for the Green Belt has been outlined in the paragraphs above. Its designation around Norwich would be consistent with the planning policies of surrounding planning authorities as they seek to manage the impact of development adjoining their boundaries in line with their own plans.



4.16 The NPPF identifies three geographic issues in respect of achieving sustainable development.

4.17 In drawing up a boundary the consequences of channelling development towards urban areas inside the boundary needs to be considered. A Green Belt could act as a positive stimulus to investment in such areas and support the delivery of brownfield sites and the regeneration of existing residential development.

4.18 The impact on towns and villages within a defined boundary should also be considered. A Green Belt would first of all maintain a distinction between settlements. It would also not preclude some additional development to meet local housing needs but would inform decisions as to the most appropriate locations in terms of avoiding coalescence rather than as a result of ad hoc decisions.

4.19 The third issue is the impact on locations beyond the outer boundary, often referred to as leap-frogging. The nature of the proposed Green Belt on a ‘green wedges’ model would prevent the majority of concerns regarding leap-frogging, whilst designation would inform any discussions on which locations might be appropriate for consideration and those which would not. If the total housing potential was set at the legal requirement of 40,541 plus a 5% buffer, given the delivery already achieved 2018-20 (5,240 dwellings) and the current commitment of 31,452, the balance of 5,876 houses could be provided by a combination of windfalls and through the development of Brownfield sites in Norwich. The leapfrogging of development outwards over the green belt would not be a problem in these circumstances in fact the opposite trend would be evident with development leapfrogging in to Norwich aided by the increasing availability of redundant office and retail space in the city centre together with the availability of other large-scale sites in East Norwich and Anglia Square. Concentrating development in Norwich minimises climate change impacts and will help revitalise the city centre – an issue that will be increasingly significant over the coming years.

4.20 In the event that a Green Belt was designated for Greater Norwich and there was a need to release land to meet housing needs one would anticipate an assessment based on seeking to achieve sustainable development. In that context rather than identify sites further away from where the need arose which would generate journeys of potentially considerable length, a sequential approach would be applied i.e. by first developing existing identified brownfield sites in Norwich as suggested in 4.19 and by making use of redundant office and retail space for residential use.

How the Green Belt would meet other objectives of the Framework

4.21 The focus of the NPPF is the delivery of sustainable development. It comprises economic, social and environmental objectives that have been addressed in the paragraphs above.

5. Practical Considerations

5.1 CPRE Norfolk recognises that designating a Green Belt for Greater Norwich will be challenging in terms of the time and resources required to assess where its boundaries should be and the formal process of designation through the review of the area’s local plan.

5.2 The designation of a Green Belt will need to be undertaken in the context of addressing the scale and location of development to support the economy of Greater Norwich and meeting the housing needs of the area. CPRE
Norfolk recognises the need to make provision for new development in bringing forward a Green Belt.

5.3 To achieve a Green Belt boundary that performs its intended functions and purposes and has the confidence and support of the public, it will be important to ensure that it is robust and can stand the test of time. How land within the Green Belt is managed will also be important. This could be achieved by making the best use of land within the existing



built-up areas, identifying and safeguarding greenfield sites for development in the future and having a positive approach to the use of land within the Green Belt.

5.4 The ‘green wedges’ model is an important tool in providing the benefits of a Green Belt, but without restricting the required level of growth. The boundaries of such ‘wedges’ could be tailored: to check the unrestricted sprawl of the margins of Norwich and its connected villages; to prevent neighbouring settlements merging into one another, such
as Wymondham and Hethersett; to assist in safeguarding the countryside from encroachment, leaving it available in part as a green resource for the population; to preserve the setting and special character of historic settlements; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban, brownfield land within Norwich.

6. Conclusion

CPRE Norfolk’s view, having considered the requirements set out in the current NPPF, is that there is a strong planning justification for the designation of a new Green Belt on the ‘green wedges’ model in Greater Norwich and that the practical considerations of delivering it can and should be addressed. The intention of such a Green Belt would not be to prevent development, but to ensure the location of such development also enables protection and enhancement of green spaces and countryside for the benefit of all. A thorough assessment of the evidence for a Green Belt should have been included as part of the production of the GNLP: as the Officer reply to the CPRE Norfolk question above makes clear, this evaluation of the evidence has not been carried out.



Future-proofing the GNLP

The GNLP is planning for the period up to 2038 and as such should be making greater attempts to plan for the likely more demanding laws and regulations regarding climate change, which will be introduced during the life of the plan. These may come as a result of COP26 being held in November 2021, as well as the Government’s increasingly loudly stated commitments around the environment and climate change, as well as a focus on utilising brownfield land as in Robert Jenrick’s statement on the ‘right to regenerate’ made on 16 January 2021. In addition, the NPPF is due to be revised, with an interim revision already being consulted on to end on 27 March 2021. This interim revision looks to implement policy changes in response to the ‘Building Better Building Beautiful Commission “Living with Beauty” report’, and will also take the opportunity to make a number of environment-related changes including amendments on flood risk and climate change. The direction of travel is clear from this and to future-proof the GNLP we urge the GNDP to take this into account to ensure the soundness of the plan. While the Reg. 19 GNLP states at para. 165 that ‘this local plan also provides a “direction of travel”’, this is concerned with how to identify further opportunities for growth, rather than identifying opportunities for meeting current and future demands resulting from climate change targets.

This emphasis on the environment is made clear from the suggested revision to para. 8c) of the NPPF, where instead of the current descriptor for the environmental objective as being ‘to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy’, the suggested revision is ‘to protect and enhance our natural built and historic environment; including making effective use of land, improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy’. This is worth quoting in full as it illustrates the subtle yet clear way the Government intends and expects planning to prioritise environmental protection and enhancement. This is carried through in the suggested revision to para. 11a) where instead of positively seeking ‘opportunities to meet the development needs of their area’, plan-making will be expected to ‘promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects’, if the proposed revisions are adopted. This should be taken into account in the GNLP, particularly regarding the number of new housing allocations, the location of new housing and the benefits from a Green Belt.

It is noted that the Reg. 19 GNLP states that: ‘While the GNLP sets out plans for the additional growth needed to 2038 and identifies the best ways for establishing long-term growth, we also need to take account of the Government’s commitment to simplified rules based local plans and increasing housing supply, particularly in areas with high affordability pressures, which will assist in increasing home ownership and providing for affordable rents. The GNLP does this by setting a strategy that can be sustainably added to, providing locations that can be zoned for growth, renewal and protection in the longer term, and by providing for sufficient growth to both meet currently established needs and to set us on the path to meeting the higher long-term housing needs Government aims to provide for’ (para. 26.) This appears to have been added in response to the Government’s proposed changes to the planning system and the recent Planning White Paper, which assumes that the required housing numbers will be increased by the new “housing algorithm”, when in fact they may be reduced from the numbers required by the initial forecasts. We feel it would be more sound to wait to see what the legally required minimum in terms of housing numbers will be, rather than adding large numbers of what are currently unneeded houses in an attempt to satisfy future unknowns.

Instead, CPRE Norfolk argues that the GNLP would be better future-proofed by more clearly recognising the need to tackle climate change throughout the life of the plan through a reduction in the total number of houses to the minimum required, along with more serious consideration on environmental grounds as to the best location for this housing. This would be a more sound and responsible approach than that currently suggested in the Reg. 19 GNLP, which is to go far beyond what is “needed”, by allocating sites for anticipated additional housing which may not be necessary.

In summary a sound ‘future proofed’ sustainable way forward that best protects the environment (nature and the landscape) and mitigates the impact of Climate Change should involve:

• Setting the total housing potential at the minimum level required through the application of the government’s standard methodology plus a 5% buffer – i.e. 40,541 + 2,027 = 42,568

• Planning for the provision of the additional 5,876 houses that would be required if the minimum level was applied
i.e. 42,568 - 36,692 (31,452 current commitments plus 5,240 already built) through concentration of development in Norwich using Brownfield sites and by converting redundant city centre retail and office space into residential usage, thereby aiding city centre regeneration. Windfalls could also make a greater contribution than currently allowed for in the draft plan (the NPPF allows for evidence-based windfalls to be included)

• Dropping policies 7.4 Village Clusters and 7.5 Small Scale Windfall Housing Development and plans to disperse development widely over large areas of countryside from the GNLP – none of these climate threatening options are needed if the minimum housing requirement is chosen, and removing them would secure the integrity of existing settlement development boundaries, whilst still allowing for some growth where there are existing JCS allocated sites.
• Providing a Green Belt on the Green Wedges model to protect the countryside around Norwich from urban sprawl.



• Prioritising the provision of affordable social housing – this can best be achieved in rural areas via the use of exemption sites allocated where local housing association surveys identify a need, and should be provided by those housing associations working together with parish and town councils

• Accepting that the phasing of development is the best way to offer the opportunity for a further 5,000 houses in the GNLP; housing that would only be needed if the 2018-based ONS household projections (which indicate that growth may be higher than predicted by the standard methodology 2014-based projections) prove to be correct. The phasing of sites is the sensible and sound way forward – sites would be made available if needed but otherwise remain undeveloped. If historic build rates are a reliable indicator of future trends it seems highly unlikely that these extra sites will be required.
• Prioritising sites for development as part of a phased delivery plan. The use of current allocations and urban Brownfield sites, together with the conversion of redundant office and retail space for residential purposes should take precedence over development on Greenfield sites. As part of this phased delivery Brownfield sites, identified in the list of sites to accommodate the extra 5,000 houses, such as sites for 2,000 houses in East Norwich, should be scheduled for development before sites in village clusters and elsewhere in the countryside. There is no sound reason why the composition of the sites allocated to accommodate the potential for an additional 5,000 houses cannot be altered with Greenfield sites (e.g. all the new village cluster sites) being moved in to the phased 5,000 list (to be developed only if needed) with their place in the plan taken by identified Brownfield sites.
There is no need for all sites to be made available for development at the start of the plan. The 31,452 current allocations already provide plenty of flexibility and developer choice and there is little evidence to suggest that increasing the level of allocations leads to an increase in the delivery of new housing – it is far more likely to lead to an escalation in the number of land-banked sites and would encourage developers to “cherry pick” more attractive, cheaper to develop rural sites ahead of the more sustainable, climate-friendly urban Brownfield options.


David Hook (Chair, Vision for Norfolk Committee, CPRE Norfolk) Michael Rayner (Planning Campaigns Consultant, CPRE Norfolk)

We support the identification of Wymondham as one of the main towns and Wymondham is by far the largest of the five main towns (and twice the size of the next largest Town – Diss). Given the geography of the areas in which the five main towns are located then there is an argument for a greater proportion of the total housing growth to be steered to those five towns. Policy 1 refers to Hethersett (which is not a main town but a key service centre) and Wymondham alongside the Norwich urban area which highlights the importance of these two settlements within the Strategic Growth Area.
At present, the growth strategy is very strongly based on the majority of housing growth (65%) taking place in the Norwich Urban Area. There may be a question as to whether the housing market can support such a high proportion of new housing being concentrated in this area. We note and agree with the total housing provision being a minimum figure of about 49,000 new homes (our emphasis).

It is requested that Policy 1 includes confirmation that the circumstances identified in Paragraphs 010 and 024 of Id.2a of the Planning Practice Guidance are included in the housing target for Draft GNLP e.g. adjustments for economic growth, strategic infrastructure and to meet affordable housing needs. It is also requested that an additional contingency site is identified at Wymondham to address low housing delivery rates if that occurs in the future.

Policy 1 sets out the proposed housing target for the period between 2018 and 2038 and defines the settlement hierarchy and distribution strategy for Draft GNLP.
It is acknowledged that the proposed housing target in Policy 1 is derived from the standard method for calculating local housing needs, as required by Paragraph 60 of the NPPF. The proposed housing target includes a 22% buffer above the figure derived from the standard method. However, what is not certain is whether how the buffer has been calculated is consistent with national guidance.
Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows:
• Where there is a growth strategy in place to promote and facilitate additional growth;
• Where strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and
• Where an authority has agreed to accommodate unmet housing needs from a neighbouring area.
Greater Norwich is within the Cambridge Norwich Tech Corridor and there is a Greater Norwich City Deal, which indicates that that two of the circumstances – growth strategy and infrastructure improvements – apply to the housing target for Draft GNLP, and adjustments should have been considered and assessed. It is not clear that these factors have been taken into account for the housing target in Policy 1. It is requested that Draft GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a are included in the housing target in Policy 1.
Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. The latest published Annual Monitoring Report (January 202) includes data on the delivery of affordable housing. The affordable housing completions data shows that delivery is below targets in both percentage and absolute terms overall. The data shows that across Greater Norwich there is a shortfall in the delivery of affordable housing of 449 dwellings. Paragraph 3.26 in the AMR notes some of the challenges of delivering affordable housing, including that affordable housing is not required from non-major developments and the redevelopment of vacant buildings or prior approval of office buildings, and it also notes that viability is an issue for some sites. It is not clear whether the housing requirement for Draft GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.
The supporting text to Policy 1 also refers to a proposed contingency site, for 800 dwellings at land off Bawburgh Lane and New Road in Costessey (Site Ref. GNLP GNLP0581). As set out in the representations to the Delivery Statement, there a number of constraints to development at this site including transport impacts and it is considered that a single large contingency site in one settlement will not be effective in addressing a housing land supply shortfall in the short term. There are a number of actions that will need to be completed before the contingency site delivers any housing. It is unlikely that housing would be delivered at the proposed contingency site to make a meaningful contribution to the housing supply to address low housing delivery rates. It is considered that a number of contingency sites should be identified in a variety of locations, and that the trigger mechanism for the contingency approach is activated earlier than three years.

Draft policy 1 refers to settlement boundaries in the Norwich Urban Area (which includes Thorpe St Andrew) and states that housing growth will be considered acceptable within settlement boundaries. An amendment to the policy map is proposed to include Oasis Sport and Leisure Centre GNLP0540 within the settlement boundary. This is on the basis that planning permission for housing development (ref: 20151132 and 20190016) has been approved and the inclusion of this land outside of the settlement boundary will weaken the interpretation of draft policy 1 as it will not be clear what is built form of a settlement and where the countryside policies should apply.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 1 is clearly written and unambiguous.

It is requested that Policy 1 includes confirmation that the circumstances identified in Paragraphs 010 and 024 of Id.2a of the Planning Practice Guidance are included in the housing target for Draft GNLP e.g. adjustments for economic growth, strategic infrastructure and to meet affordable housing needs.
No modifications are required to the settlement hierarchy in respect of Marsham.

Policy 1 sets out the proposed housing target for the period between 2018 and 2038 and defines the settlement hierarchy and distribution strategy for Draft GNLP.
It is acknowledged that the proposed housing target in Policy 1 is derived from the standard method for calculating local housing needs, as required by Paragraph 60 of the NPPF. The proposed housing target includes a 22% buffer above the figure derived from the standard method. However, what is not certain is whether how the buffer has been calculated is consistent with national guidance.
Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows:
• Where there is a growth strategy in place to promote and facilitate additional growth;
• Where strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and
• Where an authority has agreed to accommodate unmet housing needs from a neighbouring area.
Greater Norwich is within the Cambridge Norwich Tech Corridor and there is a Greater Norwich City Deal, which indicates that that two of the circumstances – growth strategy and infrastructure improvements – apply to the housing target for Draft GNLP, and adjustments should have been considered and assessed. It is not clear that these factors have been considered for the housing target in Policy 1. It is requested that Draft GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a are included in the housing target in Policy 1.
Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. The latest published Annual Monitoring Report (January 202) includes data on the delivery of affordable housing. The affordable housing completions data shows that delivery is below targets in both percentage and absolute terms overall. The data shows that across Greater Norwich there is a shortfall in the delivery of affordable housing of 449 dwellings. Paragraph 3.26 in the AMR notes some of the challenges of delivering affordable housing, including that affordable housing is not required from non-major developments and the redevelopment of vacant buildings or prior approval of office buildings, and it also notes that viability is an issue for some sites. The representations to Policies 7.4 and 7.5 highlight that infill development sites and small scale development at villages are unlikely to deliver any affordable housing. It is not clear whether the housing requirement for Draft GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.
Marsham contains a primary school, church, village hall and public house. There are businesses within the village that provide employment opportunities for local residents. The village is on a bus route providing frequent bus services to Norwich, Sheringham, Reepham and Cromer. Marsham is located approximately 2km to the south of Aylsham. In these circumstances, it is appropriate for Marsham to be defined as a village cluster in the settlement hierarchy.

Policy 1 sets out the proposed housing target for the period between 2018 and 2038, and defines the settlement hierarchy and distribution strategy for Draft GNLP.
Rackheath is located within the Norwich Urban Area and Fringe Parishes area, which is identified as the main focus for growth in Draft GNLP. The settlement hierarchy and the strategy directing growth to the Norwich Urban Area and Fringe Parishes area including Rackheath is supported.
It is acknowledged that the proposed housing target in Policy 1 is derived from the standard method for calculating local housing needs, as required by Paragraph 60 of the NPPF. The proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) would contribute towards the housing target and the delivery of housing in the short term to maintain a sufficient land supply. No other comments are made on the housing target in respect of the proposed allocation.
No changes are requested to Policy 1.

It is thought that sites GNLP0415A-G, collectively known as Honingham Thorpe, offer an appropriate opportunity to deliver growth differently, creating a truly sustainable community which paves the way for the region to become the UK leader in clean growth whilst raising the standards for design and placemaking.

It is considered that the proposed strategy is not appropriate and is incompatible with the overall purpose of the plan, in particular, the delivery of sustainable development which meets the challenges of climate change, and supports ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy, and the emergence of the region as the UK leader in clean growth. Furthermore, the proposed strategy is not considered suitable to deliver beautiful places or spaces.

It is considered that the spatial strategy of the GNLP would be better suited to following a more traditional and sustainable approach to the distribution of growth through the agreed settlement hierarchy.

In the case of South Norfolk, Welbeck Land strongly suggest the site on land north of Tuttles Lane East, Wymondham (GNLP00006), should become an allocated site.

The site on land north of Tuttles Lane East, Wymondham (GNLP00006), has the ability to deliver more suitable and sustainable growth, whilst addressing the identified infrastructure issues and requirements of one of the GNLP's largest settlements.

Please see the full representations made by James Bailey Planning Ltd. on behalf of Welbeck Land in the accompanying document.

1. EXECUTIVE SUMMARY

1.1 These representations have been prepared by James Bailey Planning Ltd. on behalf of Welbeck Strategic Land III Limited (Welbeck Land), with input from BasfordPowers, Sterling Transport Consultancy Ltd, Waterman Group, and Cannon Consulting Engineers. James Bailey Planning Ltd. are now instructed to represent Welbeck Land in this matter having inherited the instruction from Bidwells.

1.2 Welbeck Land have substantial interests in Wymondham in which they seek to promote large
scale development on the basis that the land represents a highly sustainable and suitable site for development.

1.3 These representations relate to the Greater Norwich Local Plan (GNLP), Regulation 19 PreSubmission Draft Plan document, February 2021.

1.4 They relate to the two parts of the plan, together with submissions on the legal compliance and soundness of the GNLP, both in terms of how it has been prepared and if it meets the prescribed tests of soundness.

1.5 While these representations consider all aspects of the GNLP, there is a specific focus on Section 5 – The Strategy, and particularly Policy 7 – Strategy for areas of growth. The representations concentrate specifically on the proposed growth for the Main Town of Wymondham.

1.6 In essence, the spatial growth strategy as currently being proposed by the GNLP Reg 19 is seriously questioned.

1.7 There are long standing sites that continue to be allocated that have failed to deliver over a number of years, and there is an unjustified growth being proposed towards ‘Village Clusters’.

1.8 The distribution of housing associated with the approach being taken in the GNLP Reg 19 document does not seem proportional or well considered or compatible with the requirement to promote a sustainable spatial strategy.

1.9 In essence, Welbeck Land consider that rather than solving any problems, this policy change creates additional new ones, notwithstanding the obvious difficulty of trying to judge whether the new “Cluster” allocations will be successful or not, when there is no indication where a significant proportion of them will actually be located.

1.10 Welbeck Land have continued to promote land to the north of Tuttles Lane East in the town of Wymondham (ref: GNLP0006) over a number of years, through the ‘Call for Sites’ requests, and then through previous stages of the emerging Local Plan.

1.11 It is suggested that the previous representations and submissions made to the earlier stages of the emerging GNLP, notably those at Reg. 18(c) stage previously submitted by Bidwells, remain relevant and should therefore still be considered as the document moves forward towards Examination by an Independent Inspector.

1.12 The Wymondham Area Action Plan (WAAP) was adopted by South Norfolk Council in October 2015. It identified a series of sites for the growth of housing, employment, and infrastructure. Delivery of some of the allocated housing sites remains a problem.

1.13 In March 2020, Wymondham Town Council submitted a Neighbourhood Area application,
designating the whole civil parish, which South Norfolk Council has confirmed. Progress on the Neighbourhood Plan remains unclear at the time of preparing these representations.

1.14 In summary, it is considered there is insufficient growth being proposed by the GNLP for Wymondham during the plan Period up to 2038. As an identified ‘Main Town’, there is also a weight of expectation that an appropriate level of growth will be ascribed to Wymondham, which has failed to materialise through the GNLP Reg 19 document.

1.15 It is believed that there are also mixed messages coming from the GNLP process. During the Reg 18(c) stage, Wymondham had a contingency identified for 1,000 new homes, however this has now been removed at the current Reg 19 stage. Conversely, Costessey (without comparable linkages or connections to Wymondham) had a contingency site identified at Reg 18(c) stage, which has carried through to an 800-unit contingency site in the Reg 19 document. This approach appears wholly unjustified and inconsistent.

1.16 There is also a large reliance on existing strategic sites being retained as allocations within the latest GNLP Reg 19 document, which have failed to be delivered over a number of years, such as the site at North Rackheath. This casts serious doubt not only of the delivery of these sites, but on the growth over the plan period. If allocated sites are not brought forward, then it will not be long before ‘hostile applications’ are made.

1.17 What is clear is that GNLP Reg 19 document appears to place an overreliance on delivery coming
forward through ‘windfall sites’, with a significantly disproportionate amount of housing growth being directed to the ‘Village Clusters’.

1.18 However, the South Norfolk Village Clusters Housing Site Allocations Local Plan is yet to be produced. Therefore, it is surely unjustified to place a reliance on a document that itself has yet to be tested.

1.19 The impact of Covid-19, and the knock-on effect of change in people’s habits, such as working arrangements and commuting patterns, is also considered within these representations. It is suggested that the current global pandemic is likely to have an impact on future housing growth, which the GNLP still has time to properly consider.

1.20 It is therefore believed that, although being positively prepared, the approach being taken to the spatial growth strategy across the Greater Norwich area is fundamentally flawed, and on this basis is therefore ‘unsound’ as it is neither justified nor effective.

1.21 To modify part of this deficiency, Welbeck Lane request that the land north of Tuttles Lane East, previously identified as a “reasonable alternative” in the Reg 18(c) document, be recognised as a formal allocation at Wymondham for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wymondham High School.

1.22 It is considered that identifying sites, such as land north of Tuttles Lane East at Wymondham, will help to provide a robust and proper planning approach to spatial growth. Allocating sites that prove their suitability; availability; and deliverability, in the most sustainable locations, will also enable the necessary infrastructure to be properly costed, programmed, and implemented.

1.23 In summary, the GNLP:-
• Over relies on long standing strategic site proposals, despite the knowledge from past history that some of them are unlikely to come to fruition within the Plan period;
• Introduces a change in policy direction to significantly increase reliance on development of small Village Cluster sites;
• Reduces the clear benefit to be gained from developing sustainable and available Main Town sites;
• Actually reduces proposals for certain Main Towns despite there being a clear expectation of new development;
• Is inconsistent in proposing certain Main Town sites to the detriment of other clearly more sustainable Main Town sites; and
• Proposes a spatial growth strategy that is fatally flawed, and therefore “unsound”.

1.24 Welbeck Land asks the Inspector to propose allocation of land to the north of Tuttles Lane
East for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wyndham High School. This action would go a long way to clarifying the clear deficiencies of the Plan as currently proposed and could easily be achieved without any need to delete other
current proposals.

1.25 The latest version of the Illustrative Masterplan for the site has been included as Appendix One.

1.26 A draft Statement of Common Ground has also been prepared to accompany these
representations and is attached as Appendix Two.

1.27 A Transport Working Note has been prepared to support these representations and is included
as Appendix Three.

THE NEXT SECTION OF THIS SUBMISSION IS SET OUT IN CHRONOLOGICAL ORDER AGAINST
THE GREATER NORWICH LOCAL PLAN (GNLP) REGULATION 19 PRE-SUBMISSION DRAFT PLAN
DOCUMENT FEBRUARY 2021.

See full representation attached.

Recommendation
7. We would recommend that the Council submits the more detailed evidence on supply alongside the Local Plan and as such we reserve the right to comment at the examination in public on land supply once the relevant evidence has been published.

For full submission view attachment.

A Sound Way Forward

1) Set the Total Housing Potential at the minimum local housing need figure of 40,541. This satisfies the Government’s Standard Methodology requirement.

2) Realise that by setting the housing target at 40,541 this number of new houses could be met by a combination of: 31,452 existing commitments; 5240 completions (2018 – 20); with the balance of 3,849 houses supplied by windfall developments and Brownfield sites in Norwich. In this scenario no new allocations for housing involving Greenfield sites need be made and therefore it would not be necessary to include any village cluster sites in the plan or utilise sites that might come forward as a result of policy 7.5. The negative aspects of dispersal would be avoided.

3) Accept that there is no need to introduce additional sites on the grounds that developers require more choice. The 31,452 existing commitments already provide an adequate supply of development land for many years to come and give developers all the flexibility they need in regard to site choices. Developers only build to market demand and if there is a surplus of sites they will simply “cherry pick” attractive rural sites and leave more sustainable sites land banked.

4) Learn from past mistakes. Clearly the JCS included a housing target that was far too large – hence 31,452 un-built commitments remain with only 5 years left on the plan. This time the GNLP should set a realistic target – 40,541 is probably already too large.

5) Concentrate development in and around Norwich. This is the best way to reduce greenhouse gas emissions. Setting a lower total housing potential makes this locational approach feasible.

6) Future proof the plan - Post Covid and Post Brexit things will be very different. Trends towards home working and internet shopping are leading to a reduction in the need for office and retail space in the city centre. In order to revitalise the city centre incorporate in to the GNLP the ever increasing potential for converting redundant office and retail space in to residential use. This is a sound approach NPPF paragraph 148 encourages: “the reuse of existing resources, including the conversion of existing buildings”. This kind of conversion could provide a large number of new dwellings in a sustainable location and take pressure of development in the countryside. The GNLP is possibly un-sound because it has not fully explored the potential for this kind of conversion.

7) Realise that the 5,000 houses included in the Total Housing Potential to provide an opportunity for extra capacity should the 2018 ONS household projection figures become reality could be treated as phased development i.e. even if sites for these houses are allocated they need only be brought forward for development if required. In this phased approach Brownfield sites should be prioritised. This way the GNLP will have soundly demonstrated that it is aware that the ONS 2018 projections may require this additional provision but also that it acknowledges the fact that this provision will only need to be brought on stream if the projections prove to be accurate.

8) Listen to parish councils who know what their residents want. For example in Hempnall the Parish Council considers the amount of new housing currently projected for the village, resulting from the JCS site south of Bungay Road, the affordable housing scheme that the parish council seeks to implement in conjunction with Saffron Housing at Millfields and from likely windfalls – totalling approximately 45 to 50 houses - is the right amount for the village (a 10% increase over current housing numbers). Therefore we do not want any of the sites put forward by landowners for inclusion in the GNLP to be allocated in the plan. We would also like our policy that all development be restricted to inside the current development boundary to be honoured except in regard to the provision of a rural exception site for affordable housing.

9) Provide affordable housing in villages via Rural Exception Sites. The Parish Council in conjunction with Saffron has plans to build affordable housing near Millfields. The site is owned by South Norfolk Council and they have asked for its inclusion in the GNLP as an allocated site. If their request is granted it will prevent its classification as an exception site and our affordable housing scheme will be lost. We ask that SNC complies with NPPF 77 which says: “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs”. Rural exception sites enable local affordable housing requirements to be fully met. Reliance on market schemes fails to achieve this objective. For example the 23 house JCS development south of Bungay Road was originally intended to include 7 affordable houses. Through the use of viability studies the developer has managed to reduce this in stages to just one (7 then 5 then 3 now 1).

10) Lobby central government to insist on carbon zero building standards at the earliest opportunity. As things stand currently the GNLP, for much of its 20 year plan period, will not operate in an environment where the highest standards are required.

Hempnall Parish Council considers that the Housing Growth Needs as set out in paragraphs 176 to 187 of the Draft GNLP Regulation 19 Publication (under Policy 1 – The Sustainable Growth Strategy in Section 5 of the document ‘The Strategy’) are unsound (and possibly not legally compliant) both in regard to the magnitude of the Total Housing Potential and in respect of the spatial distribution of development.

In particular we consider that both the total number of houses (Total Housing Potential) and the distribution of development conflict with Climate Change objectives and potentially contradict objectives set in regard to environmental protection and enhancement including protection of the landscape.

Relevant NPPF paragraphs and Climate Change Act targets relating to concerns over the magnitude of the Total Housing Potential

The NPPF requires that: “Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures” – paragraph 149

The Oxford English dictionary defines mitigating as: “having the effect of making something bad less severe, serious, or painful.” Therefore the NPPF says that local plans should take a proactive approach in making something bad (i.e. climate change) less severe, serious or painful.

NPPF paragraph 148 states that the planning system: “should help to shape places in ways that contribute to radical reductions in greenhouse gas emissions”



Climate Change Act 2008 has set a legally binding target for the UK to reduce its Greenhouse Gas emissions from 1990 levels by at least 80% by 2050.

The Climate Change Act 2008 (2050 Target Amendment) Order 2019
The UK has recently legislated to end its contribution to global warming by 2050, with a target that will require the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050, compared with the previous target of at least 80% reduction from 1990 levels.

Given that the carbon foot print resulting from the pre-construction and construction work necessary to build each new house is in the region of 100 tonnes of CO2 * then fulfilling the Total Housing Potential of 49,492 houses could generate 4,949,200 tonnes of CO2 and this is just the amount of CO2 resulting from building the houses. If the operational greenhouse gas emissions over the lifecycle of the properties is factored in the emissions total leaps to astronomical levels as the building phase is only responsible for about a quarter of total lifecycle emissions. Of course building methods could improve during the plan period, thus reducing both construction and operational emissions, but with the government constantly “kicking the can” down the road on introducing stricter building regulations this may well take many years to be realised and even with better standards total emissions resulting from the building and operation of 49,492 additional houses will still be very high.

There is a choice that can be made between retaining the policy draft figure of 49,492 or setting a lower total housing number in accordance with NPPF paragraph 60 which says that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach”

Hempnall Parish Council contends that adherence to climate change policy should require local authorities to choose the minimum number of houses needed in order to comply with the local housing need assessment resulting from the appliance of the standard method in national planning guidance and to not set a housing target or housing potential at a higher level.

Therefore Hempnall Parish Council considers that the GNLP should reduce the Total Housing Potential to the level required to address local housing need as assessed by the standard method i.e. 40,541 dwellings as it is unsound to proceed with a Total Housing Potential for 49,492 extra houses by 2038 because the higher figure is not compatible with Government Climate Change Objectives.

In making a choice to proceed with the lower housing figure the GNLP would be demonstrating that:

• The plan has taken a proactive approach to mitigating climate change impacts (as required by NPPF paragraph 149) because it will have chosen the least damaging option in terms of greenhouse gas emissions (the huge CO2 emissions that would have resulted from building nearly 50,000 houses would be made less severe or serious) while still complying with NPPF paragraph 60. Of course the construction and operation of 40,541 houses will still generate enormous greenhouse gas emissions but the total will at least be around 20% less than if 49,492 were built.


• The plan has attempted to comply with NPPF paragraph 148, as best possible given the requirements of NPPF paragraph 60, by endeavouring to “shape places in ways that contribute to radical reductions in greenhouse gas emissions”. While choosing to build 40,541 extra houses is not going to lead to a radical reduction in greenhouse gas emissions making this choice radically lowers emission levels below those which would occur if 49,492 houses were built.

• The plan has attempted to comply, as best possible given the requirements of NPPF paragraph 60, with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050.


If the choice is made for the GNLP to proceed with the higher housing potential figure of 49,492 the plan will not have demonstrated that it has:

• Pursued a proactive approach to mitigate climate change impacts because it will have chosen an option that makes something bad (i.e. climate change) more severe and serious than it otherwise would have been if the lower local housing need figure was chosen. The plan would not be compliant with NPPF paragraph 149.

• Attempted to comply with NPPF paragraph 148 because it will have chosen not to take advantage of the opportunity to achieve the radically lower emission levels that would result from the adoption of the lower local housing need figure

• Complied, as best possible given the requirements of NPPF paragraph 60, with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050 because in not choosing the lower local housing need figure it will have facilitated the generation of considerably higher level of greenhouse gas emissions.



*(source: Climate Change section of the Environmental Statement for Chalgrove Airfield in Oxfordshire - this is 3000 home development. If you look to page 15, it says: “The total GHG emissions from pre-construction and construction are estimated to be in the order of 313,370 tCO2e” i.e. around 100 tonnes per house)


Furthermore Hempnall Parish Council considers that the GNLP should reduce the Total Housing Potential to the level required to address local housing need in order to provide a greater level of environmental and landscape protection

Clearly the land take to build 49,492 houses is considerably greater than that required to construct 40,541. Choosing the lower figure saves many Greenfields from the threat of development and in so doing makes it easier to protect countryside, habitats, landscape, flora and fauna.


Hempnall Parish Council’s concerns over the distribution of Housing

Allocating new sites in villages as part of a dispersal policy is unsound as it conflicts with the objective of the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050. Concentrating development in and around Norwich is the best way to reduce greenhouse gas emissions as such development can more easily be based on the usage of public transport. There is increasing potential for more residential space to be provided in Norwich as a result of trends towards home working and internet shopping which are leading to a reduction in the need for office and retail space in the city centre.

Vehicle use is often the main contributor to operational emissions resulting from new housing * *. Therefore development that is dispersed will create a greater level of greenhouse gas emissions than development that is concentrated in or close to Norwich. Eventually private cars will all be electric or hydrogen powered but for the “shelf life” of the GNLP (to 2038) the transition will not have been completed and for the first 12 years (and probably more) of the plan the majority of vehicles will remain as petrol or diesel powered.

The table on page 80 of the GNDP papers from June 23rd, 2017 clearly showed that the best spatial option for new housing in order to minimise negative environmental consequences was Option 1: Urban Concentration close to Norwich. This option was the one which was best for: minimising, air, light and noise pollution; improving well-being; reducing CO2 emissions; mitigating the effects of climate change; protecting and enhancing bio-diversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; reducing the need to travel and promoting the use of sustainable transport modes; minimising the use of the best agricultural land and maintaining and enhancing water quality and its efficient use. In terms of all these and other factors taken together the least desirable option was Option 4: Dispersal of Development.





Unfortunately the obvious conclusion that should have followed on from the publication of this table, i.e. for the GNLP to be based on Option 1, was not pursued. Instead the distribution pattern for new housing envisaged in the draft plan, while it includes a degree of urban concentration, still promotes dispersal of development through proposals to make new allocations in Village Clusters and via policy 7.5. These allocations are in addition to the rural housing sites already included in current commitments carried over from the JCS and are additional to estimates for windfall developments in villages.

If the GNLP proposals for the location of new housing are not changed a sizeable chunk of development will end up being dispersed and the plan will not have:

• Taken a proactive approach to mitigating climate change impacts (as required by NPPF paragraph 149) because the plan would be facilitating a distribution pattern of development that produces greater greenhouse gas emissions than would be the case if a better option (Option 1) had been chosen

• Complied with NPPF paragraph 148 which seeks to “shape places in ways that contribute to radical reductions in greenhouse gas emissions” because it clearly does not shape the development of places in a way that enables there to be a radical reduction in greenhouse gas emissions – far from it in fact. The shape of development in locational terms, because it includes a sizeable element of dispersal, would lead to an increase in greenhouse gas emissions. Concentrating development in and near Norwich is a much sounder spatial option if the requirements of paragraph 148 are to be met.

• Made the best attempt to comply with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050. Obviously by choosing to disperse a large amount of new housing greenhouse gas emissions will rise more rapidly than if development was all concentrated near Norwich - pursuing dispersal makes it less likely that emissions will reach net zero by 2050.

• Complied with paragraph 150 of the NPPF which states that “new development should be planned for in ways that can help to reduce greenhouse gas emissions, such as through its location, orientation and design.” Clearly dispersing a sizeable quantity of development is not locating housing in the right place to help reduce greenhouse gas emissions.

• Followed National Planning Practice Guidance (PPG) (2019) which states that: “effective spatial planning is an important part of a successful response to climate change as it can influence the emission of greenhouse gases” and “Planning can also help increase resilience to climate change impact through the location, mix and design of development.” In addition, the PPG provides examples of mitigating climate change by reducing greenhouse gas emissions and adapting to climate change through “Reducing the need to travel and providing for sustainable transport”. Dispersing development is not locating new housing in the best place to reduce climate change impacts nor is it reducing the need to travel or making it easy to provide sustainable public transport.




* * Source: Climate Change section of the Environmental Statement for Chalgrove Airfield in Oxfordshire – in this 3000 home development “total GHG emissions from operational phase (over 60 year design life) contribute 80% to the overall emissions of the Proposed Development.” Estimated operational emissions are summarised in Table 15-13 of the ES. Of these operational emissions four fifths (1,021,260 tonnes of CO2) will result from vehicle use.



Furthermore Hempnall Parish Council considers that the GNLP should remove plans to disperse housing in to village clusters and via policy 7.5 because this dispersal of development has a greater negative impact on the environment and landscape than that which would result from concentrating development in or near Norwich

It is clear from the table on page 80 of the GNDP papers from June 23rd, 2017 that dispersing development has far greater negative impacts on the environment and landscape than concentrating development in and close to Norwich.

Dispersal:

• Increases air, light and noise pollution

• Increases CO2 emissions

• Causes more Greenfield sites to be built on

• Robs us of valuable agricultural land

• Threatens habitats and bio-diversity

• Suburbanises the countryside


Conclusions

• Hempnall Parish Council considers that the GNLP in its present form is un-sound (and quite possibly not legally compliant) because it has set the total housing potential number unnecessarily high - this is not compatible with NPPF paragraphs 148 and 149 nor does it comply with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050

• Furthermore we consider the GNLP to be un-sound because it chooses to disperse a significant amount of development, a policy which also does not “chime” with the requirements of NPPF paragraphs 148, 149 and 150 and the objective of the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050. Nor does it follow the guidance provided by National Planning Practice Guidance (PPG) (2019)

• Setting the housing number so high and dispersing some development in the way the GNLP suggests also has a number of very negative consequences in regard to the landscape and the environment.


A Sound Way Forward

1) Set the Total Housing Potential at the minimum local housing need figure of 40,541. This satisfies the Government’s Standard Methodology requirement.

2) Realise that by setting the housing target at 40,541 this number of new houses could be met by a combination of: 31,452 existing commitments; 5240 completions (2018 – 20); with the balance of 3,849 houses supplied by windfall developments and Brownfield sites in Norwich. In this scenario no new allocations for housing involving Greenfield sites need be made and therefore it would not be necessary to include any village cluster sites in the plan or utilise sites that might come forward as a result of policy 7.5. The negative aspects of dispersal would be avoided.

3) Accept that there is no need to introduce additional sites on the grounds that developers require more choice. The 31,452 existing commitments already provide an adequate supply of development land for many years to come and give developers all the flexibility they need in regard to site choices. Developers only build to market demand and if there is a surplus of sites they will simply “cherry pick” attractive rural sites and leave more sustainable sites land banked.

4) Learn from past mistakes. Clearly the JCS included a housing target that was far too large – hence 31,452 un-built commitments remain with only 5 years left on the plan. This time the GNLP should set a realistic target – 40,541 is probably already too large.

5) Concentrate development in and around Norwich. This is the best way to reduce greenhouse gas emissions. Setting a lower total housing potential makes this locational approach feasible.

6) Future proof the plan - Post Covid and Post Brexit things will be very different. Trends towards home working and internet shopping are leading to a reduction in the need for office and retail space in the city centre. In order to revitalise the city centre incorporate in to the GNLP the ever increasing potential for converting redundant office and retail space in to residential use. This is a sound approach NPPF paragraph 148 encourages: “the reuse of existing resources, including the conversion of existing buildings”. This kind of conversion could provide a large number of new dwellings in a sustainable location and take pressure of development in the countryside. The GNLP is possibly un-sound because it has not fully explored the potential for this kind of conversion.

7) Realise that the 5,000 houses included in the Total Housing Potential to provide an opportunity for extra capacity should the 2018 ONS household projection figures become reality could be treated as phased development i.e. even if sites for these houses are allocated they need only be brought forward for development if required. In this phased approach Brownfield sites should be prioritised. This way the GNLP will have soundly demonstrated that it is aware that the ONS 2018 projections may require this additional provision but also that it acknowledges the fact that this provision will only need to be brought on stream if the projections prove to be accurate.

8) Listen to parish councils who know what their residents want. For example in Hempnall the Parish Council considers the amount of new housing currently projected for the village, resulting from the JCS site south of Bungay Road, the affordable housing scheme that the parish council seeks to implement in conjunction with Saffron Housing at Millfields and from likely windfalls – totalling approximately 45 to 50 houses - is the right amount for the village (a 10% increase over current housing numbers). Therefore we do not want any of the sites put forward by landowners for inclusion in the GNLP to be allocated in the plan. We would also like our policy that all development be restricted to inside the current development boundary to be honoured except in regard to the provision of a rural exception site for affordable housing.

9) Provide affordable housing in villages via Rural Exception Sites. The Parish Council in conjunction with Saffron has plans to build affordable housing near Millfields. The site is owned by South Norfolk Council and they have asked for its inclusion in the GNLP as an allocated site. If their request is granted it will prevent its classification as an exception site and our affordable housing scheme will be lost. We ask that SNC complies with NPPF 77 which says: “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs”. Rural exception sites enable local affordable housing requirements to be fully met. Reliance on market schemes fails to achieve this objective. For example the 23 house JCS development south of Bungay Road was originally intended to include 7 affordable houses. Through the use of viability studies the developer has managed to reduce this in stages to just one (7 then 5 then 3 now 1).

10) Lobby central government to insist on carbon zero building standards at the earliest opportunity. As things stand currently the GNLP, for much of its 20 year plan period, will not operate in an environment where the highest standards are required.

The value of the countryside and green spaces to the well being of all has been revealed throughout the Covid-19 pandemic. The Countryside deserves stronger protection in the GNLP than is currently on offer.

If changes are to be made to the housing allocations then one would expect that consideration would be given to potential changes to the planning situation in surrounding parts of the County and beyond as, clearly, the plan area does not exist in isolation.

I consider that the housing proposals are not sustainable in their totality or in their distribution for the reasons given in my responses to 162,176,179 and 192.

Housing numbers should be redirected from Diss, Harleston and the South Norfolk rural cluster villages to a new settlement at Hethel. The policy should include the identification of a new settlement at Hethel. This approach would clearly support the ambition to provide most new homes in and around Norwich and within the Tech corridor and would provide land and homes to expand and support the opportunity for hi-tech engineering jobs within the Tech corridor.

Our previously submitted comments in relation to the proposed growth strategy still stand. Too great an emphasis is placed upon dispersal of growth to as yet unidentified sites in rural cluster villages in South Norfolk and to towns like Diss and Harleston, outside of the Cambridge-Norwich Tech Corridor and the Strategic Growth Area.

Although it is recognised that these more rural locations should accommodate some additional housing growth, this should not take precedence over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Strategic Growth Area and Cambridge -Norwich Tech corridor.

Housing numbers should be redirected from Diss, Harleston and the South Norfolk rural cluster villages to a new settlement at Hethel. This approach would clearly support the ambition to provide most new homes in and around Norwich and within the Tech corridor and would provide land and homes to expand and support the opportunity for hi-tech engineering jobs within the Tech corridor. Such an approach would help provide a ‘Sustainable Growth Strategy’ and a development hierarchy that focusses growth on the most sustainable locations within the Strategic Growth Area. The current over emphasis on potential rural allocations in the bottom tier of the settlement hierarchy and overly large allocations in Diss and Harleston makes the strategy unsound in its current form.

Our previously submitted Vision and Delivery Document has provided detailed information regarding the availability and deliverability of the Stanfield Garden Village site together with the opportunities and benefits that would arise through its allocation.

Inclusion of site GNLP4013 within the GNLP as an allocation. Please see accompanying Reg. 19 Consultation Statement for further information.

Please find details in the accompanying Reg. 19 Consultation Response Statement. My client's site ought to be included in the GNLP as an allocation. At the very least, my client's site ought to have been considered as a 'reasonable' alternative and assessed as such within the context of the SA/SEA processes as it is demonstrably 'suitable' as evidenced via the HELAA.

Inclusion of site GNLP4013 within the GNLP as an allocation. Please see accompanying Reg. 19 Consultation Statement for further information.

See attachment for full representation

Summary of issues and commentary

The plan is not carbon audited. It is not in line with the Climate Change Act (2008) as required by national policy and guidance, and is unsound in relation to the duties around the mitigation of climate change, descending from the Climate Change Act and the Planning Acts.

The plan does not contain adequately detailed climate adaptation policies and its mitigation policies could go much further to reduce emissions from buildings. The GNDP councils are significantly behind many leading authorities who have developed binding policies requiring new development to be net zero carbon.

Much of the housing stock is historic, with relatively low levels of energy efficiency. Planning policies should be incorporated to support the appropriate retrofitting of this housing stock whilst minimising harm to historic fabric and significance.

Renewable energy policies are reactive and passive and there is no evidence of a proactive strategy to maximise renewable energy as required in national policy. The approach to onshore wind, to leave the identification of suitable areas to neighbourhood plans, is unlikely to boost the pipeline of projects coming forward, unless communities are given proactive support to identify such areas, and there is no evidence of such support being given.

Transport policies should be more robust in requiring new development to incorporate sustainable transport infrastructure.

Overall, the approach throughout the plan appears to be largely to leave carbon emission reductions to central government. Whilst central government is doing much to reduce carbon emission reductions, the UK is not on track to achieve an 80% reduction in carbon emissions by 2050, still less the new commitment to bring emissions down by 68% by 2030, and down to net zero by 2050. Local authorities have a vital role to play in adding to what central government is doing.

The IPPC report on global warming of 1.5°C, the Climate Change Act and the legal duties on local planning authorities around climate change mitigation and adaptation mean that climate change needs to take a more central role within Local Plans. Local Plans need to take a more rigorous approach to bringing forward development which is consistent with and moves very quickly towards a zero carbon world, with radical changes set in motion well within the lifetime of your plan. The gradualist approach set out in the plan is not equal to the scale and rate of change required.

Point 3 should be amended to read “...of up to 3 or 5 dwellings in all parishes, OR MORE WHERE JUSTIFIED subject to the requirements of policy 7.5” for the reasons explained in our representation to Policy 7.5.

Please find attached the following Representation Forms for Policy 1, Policy 7.4, Policy 7.5 and Paragraph 301 of the above consultation document. I have also reattached our Reg 18 Supplement Statement and appendices for reference in support of our representation to Policy 7.4. Please do not hesitate to contact me if you require any further information.

Salhouse Parish Council has no objections to this regulation 19 publication, however has some comments below:

Summary:

It would appear that this regulation will not really affect Salhouse Parish. As Salhouse comes under what is known as village clusters, growth will not substantially affect Salhouse. As the Salhouse Neighbourhood Plan is already in place it really just reinforces what has already been adopted.

Supporting Evidence:

Under Policy 1 - The Sustainable Growth Strategy, the housing growth over the 20 years is split across 4 key areas, with the fourth, "Village Clusters" where Salhouse sits, itself split into two parts (being "Broadland" and "South Norfolk").

In the "Village Clusters" group they are looking for 4220 homes in the 20 years from 2018; the "Broadland" split accounting for approx. 38% of those (1628no.). Of that, 1146 are already identified as a "deliverable commitment" - which is taken to mean they have approved sites to develop. So that leaves just 482 homes across 20 years spread across all of the Broadland "village clusters" – although the analysis does not give a clear indication of the number of these clusters.

As stated, Salhouse already has the Neighbourhood Plan adopted and in use as a planning tool, so the Parish Council has the means at its disposal to do what it can to control the size of development to ensure its appropriateness for the village - Salhouse should/may take its "fair share" of those 482 future homes, but that fair share should be proportional to the village's current size, so one's and two's, possibly 5; certainly not 10's to a hundred of new homes within the village.

Please see the sections addressing Procedural Issues and Policy 1 in the attached representations submitted on behalf of R Mason in support of the allocation of Land at Rightup Lane, Wymondham (site GNLP0355)

Pigeon Investment Management Ltd (‘Pigeon’) welcome the opportunity to submit representations on the Greater Norwich Local Plan Pre-Submission Draft Strategy Regulation 19 Publication Stage (‘the GNLP’) on behalf of R Mason (‘the Landowner’) in support of the allocation of Land at Rightup Lane, Wymondham (GNLP0355).

Please find attached full representation and an Illustrative Site Layout Plan.

Submitted by Bidwells on behalf of Scott Properties

The GNLP’s approach to providing choice and flexibility in terms of housing growth by accommodating 22% more homes than are needed+ is supported.

The buffer will help maintain the supply and delivery of housing in accordance with the NPPF and specifically the Government’s objective of encouraging authorities to consider more growth than required to meet local housing need, particularly where there is potential for significant economic growth.

The proposed Settlement Hierarchy is fully supported. Norwich and the Urban Fringe, which includes Taverham, is the most sustainable location within the Greater Norwich area and is the focus for significant economic growth. Norwich is the catalyst for economic growth in the area and provides a range of amenities, services and infrastructure to support sustainable housing. Accordingly, it is wholly appropriate and consistent with Government Guidance that it should be identified as the preferred location to accommodate 66% of the housing growth during the period to 2038.

On this basis, the proposed the Policy is considered to be sound.

Submitted by Bidwells on behalf of Abel Homes

The GNLP’s approach to providing choice and flexibility in terms of housing growth by accommodating 22% more homes than are needed, is supported.

The buffer will help maintain the supply and delivery of housing in accordance with the NPPF and specifically the Government’s objective of encouraging authorities to consider more growth than required to meet local housing need, particularly where there is potential for significant economic growth.

The proposed Settlement Hierarchy is fully supported. The identification of Village Clusters as a location for development ensures that a proportion of forecast growth is distributed to sustainable locations in rural areas; an approach that ensures the provision of choice and will assist in enhancing and maintaining the vitality of rural communities. Accordingly, it is wholly appropriate and consistent with Government Guidance that Village Clusters should be identified as the preferred location to accommodate 9% of the housing growth during the period to 2038.

On this basis, the proposed Policy is considered to be sound.

Please see the sections addressing Procedural Issues and Policy 1 in the attached representations submitted on behalf of the Trustees of the WJ Gowing 1985 Settlement and the Trustees of the Howard Trust and Pigeon Capital Management 2 in support of the allocation of Land north of Brecklands Road, Brundall.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land north of Brecklands Road, Brundall (site GNLP0352). Please find attached response forms, the representations and a Delivery Statement.

1. Introduction
1.1. Comments have been invited under Reg. 19 of the Town and Country Planning Act(Local Planning) (England) Regulations 2012 on the soundness of the draft Greater Norwich Local Plan (GNLP) prior to submission to the Planning Inspectorate.
1.2. Soundness is defined as:
1.2.1. Positively prepared: The plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent which achieving sustainable development.
1.2.2. Justified: The plan should be the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence.
1.2.3. Effective: The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
1.2.4. Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies in the National Policy Framework.
1.3. There are several reasons why I consider the Draft Plan in Reg. 19 is unsound but initially question the legitimacy of the changes in the Reg. 19 draft which fundamentally change the principles of the Reg. 18 consultation and on which the public are being denied representation which is patently unfair.
2. Fairness
2.1. It is trite law that a public body must adopt a fair procedure to decision-making to ensure that members of the public are given a fair and informed say before the decision comes into effect.
2.2. The draft Reg. 19 v 1.7 documents have significantly increased by 15% the housing provision over the life of the plan above the proposals in the Reg. 18 consultations initially citing Government proposals in the ‘Planning for the future’ consultation but later changing this to the fact that the 2018-based Government projections for Greater Norwich are higher than the 2014-based projections, as justification for going back on the intention for a further stage 18D consultation.
2.3. This approach of planning for the higher numbers in the 2018-based projections goes against the Government statement that the 2014-based projections should continue to be used in Local Plans.

For full representation view attachment.

We consider that the Plan’s total housing potential figure at Table 6 should exclude homes delivered through policy 7.5 under E and windfall allowance under F and should be made up as follows:

A Local Housing Need (2018 to 2038) - 40,541
B Delivery 2018/2019 and 2019/20 - 5,240
C Existing commitment to be delivered to 2038 – 31,452
D New Allocations – 11,957

Total Housing Potential – 48,649

The Explanation under D should be adjusted to read: ‘These are the homes to be provided on new sites allocated through the GNLP (9,871), the South Norfolk Village Clusters Housing Allocations Plan (1,836) and the Diss and area Neighbourhood Plan (250).’...

Please refer to continuation page.

We consider that the Plan’s approach to accommodating housing growth needs is unsound in respect of two areas:

1. The inclusion of homes delivered through policy 7.5 and windfall allowance within the buffer on housing need; and
2. The distribution of new housing allocations across the defined settlement hierarchy comprising the Norwich urban area, main towns, key service centres and village clusters.
We set out our reasoning below.
The inclusion of policy 7.5 and windfall allowance sites
We agree that a buffer should be applied to the identified minimum housing need figure based on the Government's standard methodology using 2014 based projections and that this should be at least 20%. This is important having regard in particular to the additional growth aspirations associated with the Greater Norwich City Deal; for the reasons set out at paragraph 178 of the draft Plan related to the Government’s housing growth aspirations; and to ensure that there is sufficient flexibility within the plan to cater for any non-delivery of sites and to ensure the Plan delivers on the established minimum housing need. Ensuring sufficient flexibility is particularly important in the context of a Plan where existing commitments and new allocations are focused on larger strategic sites within and around the Norwich Urban areas, which can take longer to come forward than expected.

Please refer to continuation page.

Please see the sections addressing Procedural Issues and Policy 1 in the attached representations submitted on behalf of Michael and Jackie Buxton and Pigeon Capital Management 2 Ltd in support of the allocation of Land at Dereham Road, Reepham.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Dereham Road, Reepham (Site GNLP0353R). Please find attached response forms, the representations and a Delivery Statement.

Comments on the failure to adequately address sustainability principles in the GNLP
The joint councils involved in the Greater Norwich Area are currently consulting on the revised local plan. This envisages significant growth in the population of around 16% between 2018 and 2038. The basis of the development plan has to be supported by ‘sustainability principles’. This is one of the key underlying fundamentals which are supposed to guide development policy, yet at the same time, the County Council and other partners such as Anglian Water etc. are only too aware that there are massive water shortage problems in Norfolk, and East Anglia in general and have established a project the Sustainable Water Management Plan for Norfolk. From this evidence and other sources it is apparent that both our surface and ground water resources are being depleted by abstraction and drought issues faster than they can be recharged, and are projected to worsen, and that this is causing us to experience ‘poor’ quality ground water / surface water due to pollution and increasing concentrations of this due to diminishing volumes.
Clearly, if water is being used faster than it is being replenished then we are going to run short – in fact we already are, seriously so. Technology is not the answer as there are clearly no mechanisms in place to help to reduce demand sufficiently to compensate, and this is not a new problem as this issue has been discussed and known about since the 1990s and nothing has been done which would actually have any meaningful impact on the issues - who would pay and how basically.
There is no indication in the GNLP as to how this situation will be addressed in a measured, quantified, monitored and responsible manner which would indicate that this situation will not worsen, that damage to our health and environment (particularly by the drying out of key wetland habitats due to abstraction and the damage to Protected habitats and species) will not occur as a direct result of the amounts of growth provided for in the GNLP. As such the GNLP does not meet sustainability criteria and would be in contradiction of the Habitats Regulations.
Paragraph 162 of the Sustainable Growth Strategy seeks to promote Norwich as a key growth area to support the development of the national economy. It goes on to say that this will be compatible with ‘protecting and enhancing the environment’. In preceding paragraphs it states that both greenfield and brownfield sites will be developed. The aims of the policy are fundamentally in conflict and cannot be reconciled. It is not possible to achieve large scale growth and protect and enhance the environment. The site allocations chosen and the development strategy proposed clearly will urbanise and pollute (air, water, light and noise) what are currently rural areas. It also removes the appeal and attractiveness of rural areas and replaces it with unattractive, unappealing urban sprawl. This is not consistent with protection of the environment and it is not correct to state that it is. The plan therefore fails to demonstrate that it is sustainable in this respect.
The fundamental tenant of sustainability is that it should not damage or harm the environment in a manner which will result in cumulative net adverse impacts. The choice of a largely un-developed rural county to be targeted for large scale development and growth in preference to other areas of the Country which are already developed / damaged, and in need of regeneration / already have unemployment figures which suggest an underemployed workforce is again contrary to sustainability principles.
Similarly the choice of an area of the Country with limited infrastructure and positioned poorly geographically, making transport costs and mileage greater than for other areas is again contrary to good sustainability principles. Other areas of the Country are much better connected, have better existing infrastructure and clearly will have significantly lower adverse environmental impacts from development than those proposed in the GNLP. No sequential test to compare or even consider these issues is contained in the Plan, and therefore it fails the test of sustainability on this account.
The sustainability references need to be considered further. Large scale development as proposed will require responses in the form of new hospitals, schools, medical facilities and personnel, social services, older person’s services etc. These needs are referenced but not quantified and planned for within the GNLP and there are no indications where or specifically how they will be provided for although broad references to various sources of funding (none specific) are referred to. To propose large scale migration and development without ensuring that the means to support it are present and will be adequate / appropriately located is again risking an unsustainable community development and contrary to sustainability principles.
Impact on protected Habitats – Habitats Regulations
Under the Habitats Regulations, there is a requirement that development should not harm habitats protected by the Regs. There are numbers of sites within a short distance of the GNLP area – the Broads and North Norfolk Coast – which will be significantly impacted by increased population growth. There is no detailed assessment in the GNLP of the impacts on Protected Habitats, supported by empirical evidence to assess the impacts, or the value of
proposed mitigation measures. Commuted sums from some developments within a close radius of a specific site may have some offset capability to address impacts but this will be large scale, large area impacts which cannot be offset by commuted sums. Therefore the population growth projected will adversely impact on Protected Species and Habitats. Population growth allowed for in the Plan therefore exceeds that which can be supplied without harm to Habitats and Species and is contrary to sustainability principles and legislative requirements
Specific comments on site proposals
Site allocation GNLP 0466R / HNF2. The policy in the Broadland District LP states that only those employment uses which have ‘significant specific benefit from a use being located near the airport’ shall be permitted.
Clearly this is intended as a sustainability reason for the location of and otherwise intrusive and inappropriately located industrial estate which extends the developed area of Norwich approx. 1m further north than currently exists into open and undeveloped greenfield countryside.
However it is noted that this condition is not continued in the GNLP policy for this site and this is clearly an omission which is contrary to sustainability principles as the location of such a development to the north eastern side of Norwich – adding transport miles to any communication to this location from more or less anywhere else in the County or Country is contrary to such principles.

SEE ENCLOSED NOTE 1

On behalf of our client, Orbit Homes, we are pleased to submit representations to the Regulation 19 Publication of the Greater Norwich Local Plan (GNLP). The attached letter contains a summary of our client’s representations, the detail of which is contained on the attached enclosures (including required forms).

1. INTRODUCTION

1.1 These representations are submitted on behalf of our client, Barratt David Wilson Homes (BDW) in response to the Greater Norwich Local Plan Regulation 19 consultation.

1.2 Our client has successfully worked with Cringleford Parish Council and officers from South Norfolk Council to secure detailed planning consent for 650 homes and a site for a new primary school at their Newfound Farm site in Cringleford (ref. 2013/1793). This site is currently being built out by Barratt Developments and will deliver a successful new community within one of the Greater Norwich area’s most sustainable settlements.

1.3 The Newfound Farm site falls within the allocation reference: GNLP0307. The land that is not the subject of the detailed consent is identified in Policy GNLP0307/GNLP0327 as accommodating part of the uplift of 410 homes for Cringleford. These representations are made in the context of the uplift area continuing the established design approach and densities of the consented development.

1.4 In accordance with requirements set out in the National Planning Policy Framework 2019 (NPPF) the Regulation 19 draft of the Local Plan has been considered against the following criteria:

Positively prepared – providing a strategy which, as a minimum seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring authorities is accommodated where it is practical to do so and is consistent with achieving sustainable development;

Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

Effective – deliverable over the plan period and based on effective joint working on cross boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the NPPF.

Barratt David Wilson Homes

1.5 Whilst our client supports the draft Local Plan they recommend that further changes be made to Policy GNLP0307/GNLP0327 to ensure that it is consistent with national policy and will enable the delivery of sustainable development.

Policy 1 - The Sustainable Growth Strategy – Comment

1.6 Policy 1 introduces flexibility to accommodate additional growth if the housing needs of the Local Plan area change. It is therefore essential that this flexibility extends to other policies of the Local Plan, specifically those that allocate sites for development. This will ensure that any changes to the growth predictions in the Local Plan can be accommodated by increasing development yields at sites that have already been identified as sustainable without the need to rely on sites in potentially less sustainable locations. It will also mean that the plan is positively prepared and accords with the requirement of the NPPF to boost the supply of new homes by making the most efficient use of land in the most sustainable locations.

Policy 2 (Sustainable Communities) - Not justified; not consistent with national policy

1.7 Policy 2 requires development to “make provision for delivery of new and changing technologies”. These include electric vehicle charging technologies. However, Policy 2 does not state the level of provision of charging points that will be required or identify the scale of development where this policy would be applicable. Instead, supplementary guidance is proposed to set out the details of future requirements.

1.8 A supplementary document cannot go beyond the requirements of planning policy. Therefore, as Policy 2 does not set a specific requirement for electric vehicle charging infrastructure it is not appropriate for a supplementary planning document to do so. Whilst other technologies are easier to install on sites the provision of electric vehicle charging infrastructure and the associated energy needs can have a direct impact upon the viability of development. Accordingly, any specific requirement for charging points that is proposed needs to have been assessed through the Viability Appraisal that accompanies the Local Plan. In this case, as Policy 2 does not require a specific percentage or number of charging points no such assessment has been carried out. Therefore, the impact on the viability of any future requirement has not been adequately assessed.

Barratt David Wilson Homes

1.9 This issue is particularly relevant to our client’s site at Cringleford. The need to increase the capacity of the energy supply network through a reinforcement of the primary substation at Cringleford is a factor that could constrain the delivery of new homes.

1.10 It is essential that all associated costs related to electric charging infrastructure are taken into account to ensure that their cumulative impacts do not render sites undeliverable. This point was raised in responses to the Interim Viability Appraisal and this matter has not been adequately addressed in the final Viability Appraisal. Our client believes that the best approach is for developers to ensure that the necessary ducting and cabling is installed to allow residents to fit their own electric charging points as and when required. Without any assessment of the impact of requiring electric vehicle charging points on viability, and therefore the deliverability of sites, Policy 2 is not justified and should be amended. In addition, all reference to a future standard being provided by a supplementary planning document should also be deleted.

1.11 Following criterion 9 of Policy 2 it states “If the potential to set more demanding standards locally is established by the Government, the highest potential standard will be applied in Greater Norwich”. It is not clear whether this statement relates to criterion 9, criterion 10 or all the criteria of Policy 2. Therefore, this text does not accord with paragraph 16 of the NPPF, which requires policies to be clearly written and unambiguous. Notwithstanding this, the statement is not justified and, as there is, any such standards that may subsequently be introduced have not been assessed through the Viability Appraisal. Therefore, their potential impact upon the viability and deliverability of sites is unknown.

1.12 It is not reasonable for Policy 2 to allow the decision maker to choose which standards can be applied if higher standards have not been adequately assessed through the Local Plan process. New standards should be introduced through a partial review of the Local Plan so that the implications can be properly tested and understood. New standards should not be introduced through supplementary planning documents or implementation notes as the supporting text of Policy 2 indicates. These documents cannot legally introduce standards over and above policies of the Local Plan.

1.13 At the time of the Regulation 18 consultation the emerging Local Plan sought a 20% reduction against Part L of the 2013 Building Regulations (amended 2016).

Representation to the Greater Norwich Local Plan Barratt David Wilson Homes

The interim viability appraisal that was consulted upon at that stage
that a higher percentage would not be viable. Policy 2 now proposes a reduction to 19% “except where a lower provision is justified because the requirement would make the development unviable.” Given the fact that the Council's own evidence indicates that 20% is unviable, it is reasonable to assume that the minor reduction to 19% will be unlikely to tip the balance in favour of viability. As the Viability Appraisal dated December 2020 does not clarify why the reduction from 20% to 19% is necessary it is difficult to understand how schemes will be more viable at this level.

1.14 The evidence base is similarly silent on the impact of the self-build requirement in this policy. The combination of these untested elements of the policy raises concerns about the implications of these requirements on deliverability.

1.15 Criterion ii encourages masterplanning using a recognised community engagement process on larger sites and particularly for proposed developments of 200 dwellings. There is no description of what this masterplanning process may constitute and therefore the use of such a process has the potential to delay delivery. There is no evidence that such delays have been acknowledged in the trajectory for homes that will be delivered on larger sites.

Recommendation

1.16 It is recommended that criterion 2 of Policy 2 be amended to remove reference to a requirement for the provision of electric vehicle charging infrastructure until an assessment of the impact on the viability of developments of any such requirement has been carried out.

1.17 Policy 2 should also be amended to delete the wording: “If the potential to set more demanding standards locally is established by the Government, the highest potential standard will be applied in Greater Norwich”.

1.18 Further evidence is required to demonstrate that the 19% reduction against Part L of the 2013 Building Regulations (amended 2016) is justified. This evidence is needed to demonstrate that it will not result in sites being undeliverable when taking into account those requirements of Policies 2 and 5 that will further impact upon viability and have not been adequately assessed in the Viability Appraisal.

1.19 Further clarification should be provided as to the masterplanning process that developers are expected to undertake for larger sites. In addition to this, an

Barratt David Wilson Homes

assessment should be carried out as to whether this process would delivery of sites above the 200 dwellings threshold.

Policy 5 (Homes) - Not justified or consistent with national policy Affordable housing
1.20 The wording of Policy 5 identifies that in some circumstances the percentage of affordable housing that a site can deliver is dependent on financial viability. However, it only allows this important material consideration to be applied to brownfield sites.

1.21 Whilst it is less common for greenfield sites to have abnormal development costs there can be costs associated with infrastructure delivery and made-up land that impact upon the viability of schemes. This is especially the case for sites that are built out to lower densities where there is less flexibility to offset higher development costs against the number of new homes that are delivered. The requirements for self-build plots, space standards and part M(2) dwellings also have the potential to further reduce the level of affordable housing sites can viably deliver. As the requirement for self-build plots in particular has not been included in the Viability Appraisal there is no evidence that it will not render sites unviable to develop if there is no flexibility to the percentage of affordable housing.

1.22 Policy 5 needs to allow the applicant for any site to demonstrate that site specific matters can justify the need for a viability assessment to determine the level of affordable housing that should be delivered. This should not just be limited to brownfield sites. Without this flexibility Policy 5 has the potential to prevent sites coming forward, contrary to the requirements of paragraph 59 of the NPPF to boost housing supply. It is therefore not consistent with national policy.

1.23 The 2017 SHMA provides the evidence base for the percentage of affordable housing across the Greater Norwich area, which at that time was calculated as 28% across the Local Plan area. However, once the numbers that have already been delivered (detailed in the Greater Norwich Authority Monitoring Report) and those that could potentially be delivered by Policy 5 have been taken into account, there are questions about whether supply would exceed demand. Notwithstanding the fact that the Norwich area will only be required to deliver 28%, with the ability for this to be reduced due to viability issues, the minimum requirement of ‘at least’ 33% across the rest of the Local Plan area has the

Barratt David Wilson Homes

potential to far exceed demand based on the number of major developments that are allocated.

1.24 It is essential that the affordable housing requirements of Policy 5 required are appropriately evidenced to ensure that they are proportionate to future need. A policy that seeks to deliver more than is required must also be fully tested in terms of its impact on the viability of allocated sites. A requirement to deliver more than is required will inevitably impact on the viability of development sites to deliver other benefits and policy requirements that have not been assessed in the Viability Appraisal.

1.25 If as a result of this further work it is demonstrated that Policy 5 would overdeliver on affordable housing then this raises further concerns about the appropriateness of the Councils' strategy of not allowing a more flexible approach to the requirements of Policy 5 for non-brownfield sites. Without being able to take into account other material planning considerations when assessing the level of affordable housing that individual sites can deliver Policy 5 could prejudice the deliverability of individual sites, thereby undermining the effectiveness of the Plan. If following a further review of the evidence it is confirmed that Policy 5 will overdeliver affordable housing, then the requirements of Policy 5 for the provision of affordable housing on sites outside the Norwich area should be reduced accordingly.

Recommendation

1.26 The percentage of affordable housing required by Policy 5 should be reviewed in light of past provision since the SHMA was produced and the numbers that could potentially be delivered by sites of more than ten units in the Local Plan area. If as a result of this further work the identified need for affordable housing is shown to be exceeded by the requirements of Policy 5 then the percentage of affordable housing for sites outside the Norwich City Centre area should be reduced accordingly.

1.27 Notwithstanding the above, the wording of Policy 5 should also be amended so that viability considerations can be taken into account for all sites and not just brownfield sites.

Barratt David Wilson Homes

Space standards

1.28 Policy 5 requires the provision of minimum space standards for all housing development proposals. This approach does not offer any flexibility for decision makers to consider applications for development that does not accord with the space standards but where other material planning considerations carry weight. For example, it may not be possible for the conversion of existing buildings to fully comply with the space standards, especially listed buildings where to accord with the policy the loss of historic fabric and layout may be needed.

1.29 Moreover, the introduction of space standards can have a negative impact upon the density and efficient use of smaller sites with a high percentage of smaller properties. The supporting text of Policy 5 encourages development proposals to consider the need for wheelchair adapted homes which meet the Building Regulation M4 (3) standard or any successor. However, this is not set as a policy requirement and is only encouraged “where viable”. Therefore, the Councils acknowledge that such standards can impact upon viability. Accordingly, Policy 5 needs to include the flexibility for developments that cannot comply with the space standards to be approved where other material planning considerations, such as viability and heritage constraints carry weight in the planning balance. The aspiration for new developments to meet space standards is a valid one. However, the blanket requirement of space standards does not allow for site- specific considerations to be taken into account and Policy 5 is not justified.

Recommendation

1.30 The wording of Policy 5 should be amended to allow greater flexibility for other material planning considerations to be taken into account. Please see suggested wording for Policy 5 below:

‘Unless other material planning considerations indicate otherwise, all housing development proposals must meet the Government’s Nationally Described Space Standard for internal space or any successor.’

Self-build

1.31 Policy 5 requires at least 5% of plots on residential proposals of 40 dwellings or more to provide serviced self/custom-build plots unless “a lack of need for such plots can be demonstrated; plots have been marketed for 12 months and have not been sold.” This requirement on larger sites will reduce the development yield

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of the proposed allocations thereby creating a situation where they do not deliver the number of units identified. This could then contribute to the failure of the plan to meet the identified housing requirement, which would conflict with national policy.

1.32 Policy 5 is not clear as to whether an applicant can only demonstrate a lack of need once plots have been marketed or whether an argument can be considered at the application stage based on a lack of need being demonstrated at that time. Moreover, the use of the Councils’ self-build registers, which only had 113 people on them in 2018/19, is not robust enough for the requirement of Policy 5 to be justified.

1.33 Given the number of allocations in the Local Plan it is evident that more than 113 plots would be delivered by Policy 5 alone. If it is the case that supply exceeds demand, then those bringing forward sites early on in the plan period will have to meet the requirement whereas those coming forward later on in the plan period would be able to demonstrate that the demand has been met. This may then discourage developers from coming forward early on in the plan period. As Policy
7.5 also encourages self-build developments on the edges of development boundaries this is another source of self-build plots that needs to be factored into any supply calculations to ensure that supply will not greatly exceed demand.

1.34 The Councils must demonstrate how many self-build plots Policies 5 and 7.5 are likely to deliver and whether the requirement of Policy 5 in particular is proportionate to the evidence. As part of this evidence base it is also necessary for the Councils to identify how many self-build homes have been granted permission since the requirement to maintain self-build registers was introduced. Alongside this the Councils should also survey people on their self-build registers to identify whether they would be likely to take a plot on a large-scale development.

1.35 The above point is particularly relevant as people can often put their names on the self-build registers of different Councils and only take a plot in their preferred location, which may not be part of a large-scale development. The Councils will need to consider the robustness of their self-build register as an evidence base and an accurate indicator for demand for self-build plots. This matter was raised in the examination of the Bedford Borough Council Local Plan 2030. In the Report on the Examination of the Local Plan 2030 of 20th December 2019 (extract below)

Barratt David Wilson Homes

the Council confirmed that the draft policy requirement for a percentage of self- build plots on developments of 100 dwellings or more was not justified.

“The Council has confirmed that Bedford Borough’s register of people interested in custom and self-build has been in place since April 2016 and shows 193 individuals and one association of two individuals registered. However, the register has not been reviewed since that date to ascertain whether all those on the list are still seeking a plot. It has therefore not been possible to determine whether the Council’s policy of 10% of all development on plots of 100 or more is reasonable or that it responds proportionately to need. Consequently, we cannot conclude that the policy is justified by the available evidence.”

1.36 The Councils also need to assess whether they can meet the existing and future need through their own housing strategies, land disposal and regeneration functions in accordance with paragraph 57-014 of the PPG.

1.37 All the aforementioned steps need to be gone through before the Councils seek to place additional burdens on house builders. Especially as paragraph 57-025 of the PPG confirms that Councils should only ‘encourage’ developers to consider self- build and custom housebuilding.

1.38 In many cases self-built plots can result in inefficiencies in the development of sites with the need for separate construction accesses and site compounds that may need to be in place long after the host development has been built out. They also generate less revenue for developers than finished homes. If plots are subsequently not sold then it is often not economically viable for volume housebuilders to return to a site to build out individual plots. Therefore, a requirement for self-build plots can impact negatively on the financial viability of a development. Accordingly, this matter should have been considered in the Viability Appraisal to demonstrate that requiring 5% of large sites to be self-build plots is justified and will not delay the delivery of new homes in the most sustainable locations.

1.39 If the only mechanism to demonstrate a lack of need for self-build plots is by marketing them for 12 months then this would delay the delivery of new homes more than if the same land were built out as part of a wider development. Our client has always been of the opinion that the limited numbers of self-builders on the Councils’ registers would be best accommodated as windfall sites on the edges of development boundaries as permitted by Policy 7.5. This would both accelerate the holistic delivery of larger sites and deliver plots in locations where

Barratt David Wilson Homes

self-builders are more likely to want to live. This approach will also deliver plots at a volume and pace that will address the existing and future needs.

Recommendation

1.40 The Councils should delete the requirement for 5% of homes on sites of 40 or more dwellings to be allocated to self-build or custom housebuilding. Alongside this, Policy 7.5 should be amended to allow self-built plots to be provided as exceptions to the thresholds for development outside development boundaries.

Policy 7.1 (The Norwich Urban Area including the fringe parishes) - Not consistent with national policy

1.41 Policy 7.1 lists the proposed allocations for the Norwich Urban Area including the fringe parishes. This Policy has a figure of 1,771 homes for Cringleford, which is identified as being the “Total deliverable housing commitment 2018 – 2038”. This figure is made up of the uplift in the allocation to 1,710 homes and an additional
61 homes that are already consented elsewhere in the village. Whilst Policy GNLP0307/GNLP0327 includes the word ‘approximate’ before the figure of 1,710 for the Cringleford allocation Policy 7.1 does not. Instead, it identifies the 1,771 figure as being a total. Without there being any clarification that the figures for allocations can be deviated from there is the danger that they may be seen as maximum figures. Especially as Policy 7.1 uses the term ‘total’, which is not consistent with the Cringleford allocation Policy that permits a more flexible approach to numbers with the use of ‘approximately’. Accordingly, the wording of Policy 7.1 would not be consistent with the requirement of paragraph 59 of the NPPF to boost the supply of new homes.

1.42 The use of ‘approximate’ allows for a deviation from the figure of 1,710 homes for Cringleford and therefore there must be a consistent approach to the figures in the Local Plan where they are not absolute figures. In Policy 1 all the figures are identified as minimum figures. Therefore, the same should apply to the figures for draft allocations. This will allow the final number of new homes to be delivered at each site to be based on a design-led approach that makes efficient use of land by delivering densities that are influenced by “on site characteristics”, as required by Policy 2.

Barratt David Wilson Homes

Recommendation

1.43 Policy 7.1 should be amended so that all the figures for the allocations are identified as minimums. Additional text should be added to confirm that developments will be required to make effective use of land with the final number of homes delivered on individual allocations being based on a design-led approach.

Policy 7.5 (Small Scale Windfall Housing Development) - Not effective

1.44 Paragraph 16 of the NPPF requires policies to be clearly written and unambiguous. The use of the term “Positive consideration will be given to self and custom build” does not provide sufficient clarity for the decision maker as to the weight that can be attached to proposals for self-built plots. For example, if the threshold for a parish were to be exceeded by two separate applications that were undetermined would one be approved over the other if it were to be self- build? Whilst it is positive that Policy 7.5 is seen as a mechanism for promoting self-built plots it will be ineffective once the thresholds for individual parishes have been reached.

1.45 It is recommended that self-build plots be specifically referenced in a criterion of Policy 7.5. Given the low numbers presently on the Councils’ registers the amendment of Policy 7.5 to positively promote self-build plots will be a more effective way of delivering them than requiring 5% on larger sites. This will speed up the delivery of the larger sites and provide a supply of self-build plots in locations where self-builders want to live.

1.46 Policy 7.5 should be the Councils’ primary tool for securing the delivery of self- build plots in order to meet their statutory requirement to promote self-build housing. However, the proposed cap in numbers for each parish would make it less effective in achieving this aim. The amendment of Policy 7.5 to positively provide for self-build plots would also remove the need for 5% of developments of 40 dwellings or more to provide 5% self-build plots as required by Policy 5.

1.47 Prioritising the delivery of self-build plots on the edges of development boundaries is more of a sound policy than relying on large development sites to deliver them. Especially as the approach proposed in Policy 5 has the potential to increase costs and reduce profits for developers, which could delay the delivery of new homes. Moreover, the removal of the obligation from larger developments

Barratt David Wilson Homes

would maximise the amount of affordable housing that they could deliver in cases where site specific issues may be affecting viability.

Recommendation

1.48 Policy 7.5 should be amended to positively provide plots for self-build over and above the thresholds or small and larger parishes. Please see suggested wording for Policy 7.5 below:

“Other than proposals for self-build, cumulative development permitted under this policy will be no more than 3 dwellings in small parishes or 5 dwellings in larger parishes (as defined in appendix 7) during the lifetime of the plan”

Part 2 - The Sites 3. Urban Fringe

Policy GNLP0307/GNLP0327 – Not effective or consistent with national policy

1.49 In our client’s response to the Regulation 18 consultation technical information was submitted to demonstrate that the balance of their site alone has the capacity to accommodate circa 500 new homes. The response included a Framework Plan and Vision Document for the site. Since submitting these details there has not been any discussion with officers about the capacity of the allocation or our client’s site. Instead, it appears that the proposed uplift of 410 homes for the Cringleford allocation, which has resulted in the figure of approximately 1,710 homes in the draft policy, has been estimated by officers. The only reference to the process that has led to this this estimate is the “further discussions with Development Management colleagues” that is referenced in the Norwich and Urban Fringe Assessment (Cringleford Booklet).

1.50 Whilst there have been addendums to the 2017 HELAA none of these have given further consideration to the Cringleford allocation. In light of the information submitted at the Regulation 18 stage a further assessment of the allocation should have been carried out to justify the proposed uplift. In the absence of this assessment Policy GNLP0307/GNLP0327 is not effective or consistent with the national policy. Therefore, a more flexible approach to numbers identified for the uplift in the allocation is needed to make the most efficient use of land and boost the supply of new homes in accordance with Policy 2 and paragraphs 59 and 117 of the NPPF.

Representation to the Greater Norwich Local Plan Barratt David Wilson Homes

1.51 There is a risk that without caveating that the figure of 1,710 new homes could be increased, which the use of ‘approximately’ clearly indicates, it may be regarded as a maximum figure. To ensure that the plan is positively prepared and is consistent with achieving sustainable development a design-led approach should be adopted to the uplift in the allocation with the figure of 1,710, or higher based on the evidence submitted at the Regulation 18 stage, being set as a minimum.

1.52 The Cringleford Policy acknowledges that there is flexibility to the education provision on site and that the 3 hectares may not be needed if an equivalent alternative provision can be agreed with the education authority. If the full 3 hectares of land was not required then that would allow for additional homes to be accommodated on the site. This change alone could result in a figure of more than 1,710 new homes being accommodated on the allocation.

1.53 The confirmation from Highways England that the proposed improvement of the A47 Thickthorn interchange can accommodate the proposed uplift is welcomed. Our client's initial transport work indicates that a higher uplift could also be accommodated and this should not therefore represent a constraint to the development potential of the site. In accordance with the wording of the Cringleford Policy this will be confirmed through the submission of a Transport Assessment as part of the planning application for the site.

1.54 The requirement for a vehicular route through the adjacent development site (reference: 2013/1494), capable of serving as a bus route is something that is outside our client’s control. Whilst they will work with the neighbouring developer to achieve a bus route, it is unreasonable for it to be a policy requirement as there are no guarantees it will be able to come forward. It is therefore suggested that flexibility is allowed for in the policy wording for a bus route to be provided if demonstrated to be achievable.

1.55 Criterion 7 requires “Provision of a drainage system (SUDs)”. It is not necessary for this to be expressly required by the policy as paragraph 165 of the NPPF and Policy HOU2 of the Cringleford Neighbourhood Plan both require that developments incorporate sustainable drainage systems. Similarly, paragraph 189 of the NPPF requires that the Historic Environment Record be consulted to determine any need for archaeological surveys prior to development (criterion 6). Both these criteria could be deleted from the policy.

Policy Map (below left), with the latter stating that the uplift of 410 homes will be “within settlement boundary”. Whilst this accords with the Proposal Map in the Cringleford Neighbourhood Plan (below right) the extended boundary of the housing allocation does not. If an amendment of the housing allocation boundary is considered acceptable then development should not be unduly constrained by the arbitrarily drawn settlement boundary. Reference to this should be removed from the Policy Map to allow the masterplanning of the site to be based on a design-led approach. This change will not result in a reduction in the buffer between new residential development and the Norwich Southern Bypass. Though it is considered necessary to allow greater flexibility for the layout of the site so that a more organic edge to the village can be created.


1.57 Our client controls 87% of the land identified to accommodate the uplift in the Cringleford allocation. If the uplift were restricted to only 410 homes then they could only deliver 357 of the homes on their land, which would result in a density of 17.68dph. This figure would be well below the average density of 44dph that has been approved on the Newfound Farm site. Clearly, such a low density would not accord with paragraphs 122 and 123 of the NPPF that require planning policies to ensure the efficient use of land and identify the importance of avoiding homes being built at low densities, especially in sustainable locations.

to demonstrate that the remainder of the BDW site at GNLP0307 has the capacity to deliver circa 500 homes. These homes can be delivered at a density of 44dph and the site will still deliver a minimum of 2 hectares of green infrastructure per 1,000 population as required be Policy 3. Therefore, even if the use of ‘approximately’ can be used to justify more than 410 homes across both sites it will fall well short of the 500 homes that can be delivered by continuing with the accepted design approach for Newfound Farm.

1.59 The ability to increase the number of new homes in the Cringleford allocation accords with GNLP objective 3 (Homes theme) “To enable delivery of high-quality homes of the right density, size, mix and tenure to meet people’s needs throughout their lives and to make efficient use of land.” It also accords with objective 5 (Housing) and 8 (Health) of the Sustainability Appraisal that identify that “Development proposals which would result in an increase of 100 dwellings or more would be likely to have a major positive impact on the local housing provision.” and “Development proposals which would locate site end users in close proximity to one of the listed NHS hospitals, a GP surgery and a leisure centre would be expected to have a major positive impact for this objective.”

1.60 Policy 2 seeks to make efficient use of land for development and requires that densities be “dependent on site characteristics”. This point is particularly relevant to the uplift in numbers proposed for Cringleford under Policy GNLP0307/GNLP0327. The estimated figure for the uplift would fall well below the density of 44dph that was approved for the Newfound Farm development and the density set out in the Framework Plan that was submitted. This higher density will be a material consideration in the determination of the application for the uplift area and the Cringleford allocation policy needs to acknowledge this.

1.61 Based on the 410 homes uplift being an estimate only it is of critical importance that the Local Plan seizes every opportunity to boost housing supply to be in full compliance with paragraph 59 of the NPPF.

Recommendation:

1.62 In the absence of a justification for the uplift to be restricted to 410 new homes Policy GNLP0307/GNLP0327 should be amended to substitute ‘approximately’ for ‘at least’ and the following text should be added:

based on a design-led approach taking into account the characteristics of the sites and the densities of surrounding development.”

1.63 Policy GNLP0307/GNLP0327 should also be amended to allow for flexibility in the requirement for a vehicular route through the adjacent development site (reference: 2013/1494) that is outside our client’s control. Please see suggested alternative wording for the Policy below:

“If achievable, the layout shall facilitate the future delivery of a vehicular route through the adjacent development site (reference: 2013/1494), capable of serving as a bus route;”

1.64 Finally, the Policy Map should be amended to delete the text “within settlement boundary”.

1.65 The suggested additional wording would make the Policy a more effective policy tool in the context of the NPPF’s test of soundness (paragraph 35) and make the Plan positively prepared.

Recommended modification: In combination with the subsequent considerations, it will therefore be necessary to modify the emerging housing.

Historic under-delivery
Recommended modification: It is, therefore, recommended that a proposed minimum contingency of 25% is retained as a minimum.

Policy 1- the Sustainable Growth Strategy

Policy 1 outlines the broad strategic approach for the plan period, which includes the proposed housing requirement and housing commitments.

Housing requirement

Paragraph 65 of the NPPF requires that a housing requirement is established within a Local Plan, which shows the extent to which their identified housing need can be met over the plan period.

The foreword to the Draft Local Plan identifies a "requirement" for about 49,500 homes over the period 2018-38. Paragraph 177 and Table 6 of the GNLP however identify a housing "target" for only 40,541 homes and Policy 1 identifies a "need" for around 40,550 homes.

The GNLP is therefore not only ambiguous such that it may not be effective, it also does not accord with national policy and therefore would benefit from a set housing requirement in strategic policies.

Recommended modification: to provide consistent references throughout the Local Plan to the 'housing requirement' as per Paragraph 65 of the NPPF.

The minimum housing need

The need for 40,541 homes is identified as having been calculated using the standard method. The standard method provides the minimum local housing need and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1. The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.

In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.92 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,388 homes.

Alternatively, the minimum local housing need from 2020 onwards can be calculated using the average household growth over the 10 consecutive years from 2020, namely 2020-30, with

1 As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book.


the affordability ratios of 2019 applied. The average household growth was 394, 505 and 680 respectively and the median workplace-based house price to earnings ratios were 9.01, 6.97 and 9.02 respectively. These figures produce a minimum local housing need of 2,008 homes per annum which equates to 36,148 homes over the period 2020-38. Table 6 of the GNLP identifies that 5,240 homes were completed in 2018-20. In addition to the minimum local housing need of 36,148 over the period 2020-38 this would again produce a minimum local housing need for 41,388 homes over the plan period.

It is therefore apparent that the standard method has been miscalculated within the GNLP and that the minimum local housing need is greater at 41,388 homes.

Recommended modification: In combination with the subsequent considerations, it will therefore be necessary to modify the emerging housing.

Historic under-delivery

In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 25,878 housing completions in the period 2008-20. However, only 20,924 homes have been delivered which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 23.7%. The overestimations of supply can be mainly attributed to the delivery rates of strategic infrastructure projects, and consequently, the ability of large scale SUE's to be delivered across Greater Norwich. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement which is 25% in excess of the minimum need for 40,541 homes. This would produce a housing requirement for 50,676 homes. Our client welcomes the Council's decision to include a substantial buffer of over 20% between its housing requirement and housing supply. This is essential to ensure the plan has sufficient flexibility to meet needs in full across the plan period.

Recommended modification: It is, therefore, recommended that a proposed minimum contingency of 25% is retained as a minimum.

POLICY 5 – HOMES

Policy 5 of the GNLP Draft Strategy sets out a requirement of 33% affordable housing on sites of 10 or more units, even though the 2017 Central Norfolk Strategic Housing Market Assessment (SHMA) identifies that there was a need for 39,486 homes, of which 11,030 represents 28% affordable housing. The affordable requirement should be based on up to date evidence and should be subject to detailed viability testing at a range of scenarios. Therefore, this aspect of Policy 5 will need to be amended.


Recommendation: In order to address this, it will be necessary to either recalculate the affordable housing needs based on the planned supply and then set affordable housing policies accordingly, or to reduce the affordable housing requirement within Policy 5 to 28%.

POLICY 7.3 – KEY SERVICE CENTRES

Paragraph 372 of the GNLP outlines that Key Service Centres have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving rural areas. It also identifies that these roles are intended to continue supported by appropriate levels of development.

The Draft GNLP Strategy states that the Key Service Centres of Acle, Blofield, Brundall, Hethersett, Hingham, Loddon / Chedgrave, Poringland / Framingham Earl, Reepham and Wroxham, will deliver 3,679 homes over the plan period (approximately 7% of the proposed housing growth).

Loddon has one new proposed housing allocation in the Draft GNLP Strategy, which is to the south-east of the settlement (Policy GNLP0312, Land to the east of Beccles Road) for the development of over 180 homes. Land to the north and south of Norton Road would adjoin onto the northwestern boundary of 'Land to the east of Beccles Road' (GNLP0312) and lead to the natural extension of the sustainable settlement of Loddon. The GNLP Loddon and Chedgrave Site Assessment Booklet assesses submitted sites in these settlements for consideration in the GNLP. It states that our client's site is "well related to services, is adjacent to a site which has been preferred for housing allocation, and offers the potential to increase permeability within this part of the town." As a result, the site was shortlisted for further assessment (Stage 6). The Stage 6 Assessment centred on the impacts on highways, flood risk, landscape visual and local services, as further set out in the paragraphs below.

Highways Impact

The initial Highways Authority comments from the Booklet state that Norton Road is not suitable for development traffic, but the southern section of the site may be accessed via the adjacent allocation Land to the east of Beccles (GNLP0312). As outlined with our client's Regulation 18 representations, they agree that suitable accesses can not only be achieved via the neighbouring allocation but also onto Norton Road.

Since the submission of Regulatory 18 representations, our client has commissioned technical transport assessments to evaluate the feasibility of creating two T-junctions on either side of Norton road, to serve both the site's northern and southern sections. At present, a through route via Land to the east of Beccles is not possible as this is a draft allocation (GNLP0312) and does not benefit from an extant consent. Therefore, the Transport Assessment (TA) solely assessed the highway's impact on two proposed Norton Road accesses. The Transport


Assessment recommended that a new footway is included on both sides of Norton Road and an extension of the existing 30mph towards the east. The TA concluded that such a proposal should be considered acceptable on transport-related grounds. Therefore, contrary to the initial Highways Authority comments, this detailed TA has found that it could be feasible to create safe vehicular access onto Norton Road.

Landscape Visual impact

Comments from Development Management raise concerns that the site would "cause harm to the landscape and the rural setting of the Broads." However, no further details are provided. A Landscape and Visual Impact Assessment (LVIA) instructed by our client, states that the views of the Site are considered to be well contained and highly localised within the context of the existing visual environment. The assessment concludes that the Site and receiving environment have the capacity to accommodate a strategic residential scheme. The allocation will not result in significant harm to the landscape character or visual environment and, as such, it is considered that a strategic housing proposal can be successfully integrated in this location.

Flood Risk impact

In terms of the other comments raised in the Loddon and Chedgrave Site Assessment Booklet, the Lead Local Flood Authority (LLFA) outlines that a complete geotechnical investigation will be needed to determine infiltration potential. Nevertheless, the LLFA outlines that "the site is at risk of surface water flooding, but this is not severe enough to prevent development of the site" and mitigation could be provided at the required planning stage." This is further supported in a Flood Risk Assessment (FRA) prepared by our client. The FRA concludes that with appropriate mitigation measures, the risk of flooding from all sources is generally low, and a development proposal can be operated safely and without significantly increasing flood risk elsewhere.

Sustainability

Land to the north and south of Norton Road is considered to be located in a sustainable location as it is easily accessible to Loddon's High Street (less than 10 minutes walk from the site), which has an excellent range of shops, services, employment opportunities and bus stops with a frequent bus service to Norwich city centre (one bus every 30 minutes). Furthermore, there are employment opportunities available at Loddon Industrial Estate (less than 10 minutes walk from the site). By affording sustainable levels of growth to areas such as this it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.


However, the Loddon and Chedgrave Site Assessment Booklet states that if this site was allocated in addition to the two other allocations in Loddon & Chedgrave, "development of this site may overwhelm public services." However, as previously stated in our clients' Regulatory 18 Representations, there is the potential to deliver new community facilities at Land off Norton Road, Loddon, for a range of uses, including public open space. Halsbury Homes Ltd will explore whether it may be possible to deliver additional facilities at the site. There is also the potential for off-site contributions to upgrade existing facilities. Halsbury Homes would welcome the opportunity to engage with the local community to understand what kind of facility will achieve the greatest benefit to the community.

Other Issues

Other technical reports commissioned by our client found there would be no adverse effects (subject to suitable mitigations) on nearby heritage assets, air quality, amenity and noise and trees.

Conclusion

The Loddon and Chedgrave Site Assessment Booklet concludes that the site is considered unsuitable for allocation. However, our client considers that the Councils should consider identifying additional available and deliverable small and medium sized sites from a range of locations capable of accommodating housing growth within the plan period. The site is available and deliverable within the plan period, with site access feasible to both the northern and southern sections of the site. The absence of additional allocations at Loddon is therefore not justified. The resultant disproportionately low level of growth will compromise the vitality of the settlement contrary to paragraph 78 of the NPPF

Recommendation: In order to provide greater certainty for the plan period, it will be necessary to increase the amount of housing in Key Service Centres, such as Loddon, which is capable of accommodating housing growth within the plan period. This provides the opportunity to allocate Land to the North and South of Norton Road, Loddon.

1 As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book.

Recommended modification: In combination with the subsequent considerations, it will, therefore, be necessary to modify the emerging housing requirements.

Historic under-delivery
Recommended modification: It is, therefore, recommended that a proposed minimum contingency of 25% is retained as a minimum.

Greater Norwich Local Plan Reg 19 Draft Plan Consultation

Land at Dairy Farm, Thorpe End

INTRODUCTION

These representations are submitted on behalf of our client Halsbury Homes Ltd in response to the Greater Norwich Local Plan (GNLP) Regulation 19 consultation.

Our client is promoting Land at Dairy Farm, Thorpe End for residential development through the GNLP and previously submitted Regulation 18 representations in March 2020.

Since the submission of Regulation 18 representations, our Client has submitted an Outline Planning Application on the parcel of land (7.46 ha) north of the Norwich Northern Distributed Road (NNDR) (Ref: 20200202 – Land at Green Lane East, Little Plumstead) which was previously included within the red line provided for the Site at Dairy Farm. This application for up to 130 market and affordable dwellings with land safeguarded for a 92 bed extra care independent living facility (use class C3) and for a medical centre (use class D1) was approved at Planning Committee on 24th February 2021.

These representations will address the following two questions from the GNLP Regulation 19 form:

• Question 5- Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to cooperate. Please be as precise as possible.

• Question 6- Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matter you have identified at 5 above. (Please note that non-compliance with the duty to co-operate is incapable of modification at examination). You will need to say why each modification will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Our Client considers that the Draft Local Plan in its current form is legally compliant, complies with the Duty to Cooperate and is legally sound. Nevertheless, certain Draft Strategy Policies (namely 1, 5 and 7.1) would benefit from amendments to provide greater certainty for the plan period (2018-2038). It is contended that the allocation of additional sites in sustainable locations, including Land at Dairy Farm, Thorpe End is required.


POLICY 1- THE SUSTAINABLE GROWTH STRATEGY

Policy 1 outlines the broad strategic approach for the plan period, which includes the proposed housing requirement and housing commitments.

Housing requirement

Paragraph 65 of the National Planning Policy Framework (NPPF) requires that a housing requirement is established within a Local Plan, which shows the extent to which their identified housing need can be met over the plan period.

The foreword to the Draft Local Plan identifies a "requirement" for approximately 49,500 homes over the period 2018-38. Paragraph 177 and Table 6 of the GNLP, however, identify a housing "target" for only 40,541 homes and Policy 1 identifies a "need" for approximately 40,550 homes.

The GNLP is, therefore, not only ambiguous such that it may not be effective, it also does not accord with national policy and, therefore, would benefit from a set housing requirement in strategic policies.

Recommended modification: To provide consistent references throughout the Local Plan to the 'housing requirement' as per Paragraph 65 of the NPPF.

The minimum housing need

The need for 40,541 homes is identified as having been calculated using the standard method. The standard method provides the minimum local housing need and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1. The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is, therefore, necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.

In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.92 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,388 homes.


1 As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book.


Alternatively, the minimum local housing need from 2020 onwards can be calculated using the average household growth over the 10 consecutive years from 2020, namely 2020-30, with the affordability ratios of 2019 applied. The average household growth was 394, 505 and 680 respectively and the median workplace-based house price to earnings ratios were 9.01, 6.97 and 9.02 respectively. These figures produce a minimum local housing need of 2,008 homes per annum which equates to 36,148 homes over the period 2020-38. Table 6 of the GNLP identifies that 5,240 homes were completed in 2018-20. In addition to the minimum local housing need of 36,148 over the period 2020-38, this would again produce a minimum local housing need for 41,388 homes over the plan period.

It is, therefore, apparent that the standard method has been miscalculated within the GNLP and that the minimum local housing need is greater at 41,388 homes.

Recommended modification: In combination with the subsequent considerations, it will, therefore, be necessary to modify the emerging housing requirements.

Historic under-delivery

In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 25,878 housing completions in the period 2008-20. However, only 20,924 homes have been delivered demonstrating that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 23.7%. The overestimations of supply can be mainly attributed to the delivery rates of strategic infrastructure projects, and consequently, the ability of large scale SUE's to be delivered across Greater Norwich. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement which is 25% in excess of the minimum need for 40,541 homes. This would produce a housing requirement for 50,676 homes. Our Client welcomes the Council’s decision to include a substantial buffer of over 20% between its housing requirement and housing supply. This is essential to ensure that the plan has sufficient flexibility to meet needs in full across the plan period.

Recommended modification: It is, therefore, recommended that a proposed minimum contingency of 25% is retained as a minimum.

POLICY 5 – HOMES

Policy 5 of the GNLP Draft Strategy sets out a requirement of 33% affordable housing on sites of 10 or more units, despite the 2017 Central Norfolk Strategic Housing Market Assessment (SHMA) identifing that there was a need for 39,486 homes, of which 28% or 11,030 homes represent affordable housing. The affordable requirement, should be based on up to date


evidence and should be subject to detailed viability testing under a range of scenarios. It is, therefore, considered that this aspect of Policy 5 will need to be amended.

Recommendation: In order to address this, it will be necessary to either recalculate the affordable housing needs based on the planned supply and then set affordable housing policies accordingly, or to reduce the affordable housing requirement within Policy 5 to 28%.

POLICY 7.1 – NORWICH URBAN AREA INCLUDING THE FRINGE PARISHES

The Draft GNLP Strategy states that the Norwich urban area including the fringe parishes2 will deliver 32,691 homes over the plan period (approximately 66% of the proposed housing growth). The site at Dairy Farm would, therefore, be a valuable contribution to this target which owing to the size of the site and the fact that our Client already owns the land would be deliverable within the first 5 years of the plan period, hence also contributing to the Councils five year housing land supply.

Land at Dairy Farm falls within the Thorpe St Andrew Growth Triangle an area identified for major growth. Situated in between the villages of Thorpe End and Rackheath the land at Dairy Farm would benefit from access to their village services as well as those within the Norwich urban area. Furthermore, there are an array of existing employment centres within the vicinity as well as a number proposed. Thereby the allocation of the small-scale housing site of Land at Dairy Farm would be in a sustainable location and would assist in providing the Councils’ with greater certainty over housing delivery during the next plan period.

The Village Cluster – Broadland Assessment Booklet for Great and Little Plumstead within the GNLP’s evidence base assesses submitted sites in these parishes for consideration in the GNLP. It states that the Site at Dairy Farm (ref: GNLP4030) is a “well located urban fringe site, with easy access onto the NDR” but following a Sustainability Appraisal (SA) it has not been proposed for allocation principally because it is considered that there is currently not a need for a development of that scale and there are other better urban fringe sites. Other concerns listed are set out in the paragraphs below:

Accessibility

The Great and Little Plumstead Assessment Booklet highlights concerns over the accessibility of existing services and facilities by walking or cycling to either Rackheath or Sprowston. The assessment does, however, go on to acknowledge that with development of the scale proposed at land at Dairy Farm (up to 1200 homes) that services and facilities as well as highway and


2 The Norwich fringe is the built-up parts of the fringe parishes of Colney, Costessey, Cringleford, Drayton, Easton, Hellesdon, Old Catton, Sprowston, Taverham, Thorpe St Andrew and Trowse and the remainder of the Growth Triangle.


pedestrian improvements would be secured through the planning process. Indeed, as stated in our Client’s Regulation 18 Representations there is the potential to deliver new community facilities at Land at Dairy Farm for a range of uses, including public open space. Halsbury Homes Ltd will explore further whether it may be possible to deliver some of these facilities at the Site and they would welcome the opportunity to engage with the local community to understand what kind of facility will be of greatest benefit to them. There is also the potential for off-site contributions to upgrade existing facilities. The settlements of Thorpe End and Rackheath in between which the site is located possess a range of facilities and services including a post office, village store, church, primary school and village hall.
In addition, as part of the Growth Triangle Area Action Plan (APP) proposals, there are enhancements planned for the local transport infrastructure. These include improving bus routes, and in particular, Bus Rapid Transit Corridors for which routes have been safeguarded, increasing the accessibility to the City centre. The Norwich Cycle Network is also proposed to be extended to serve the allocated sites north of the NNDR. As stated in the AAP “The new transport links, services and facilities delivered through the coordinated development of the Growth Triangle will support existing and new communities.” The adopted Broadland JCS (2014) establishes an effective implementation framework which will deliver this infrastructure in a timely manner. Hence, residential development located within this growth triangle will be supported by a multitude of infrastructure improvements that are proposed specifically to support such growth. It is, therefore, considered that services and facilities would be easily accessible from the Site via walking, cycling and other sustainable transport modes.
Landscape and Townscape

Comments surrounding the potential impact of the development on the landscape and townscape were raised in the site Assessment, owing to the Site’s size but also its proximity to the Thorpe End Garden Village Conservation Area which abuts the south western corner. Any future planning application would be supported by a Heritage Assessment as well as a Landscape and Visual Impact Assessment which would inform the proposed layout. It is possible for development to be set back from the south western edge and separated by public open space and sensitive landscaping to ensure that there are not any adverse effects on the setting of the Conservation Area. The use of perimeter landscaping would also be explored to soften the views of development.
In addition, it is considered that the existing built form of Thorpe End to the South, the consented development to the north (Land at Green Lane East, Rackheath – ref: 20200202) as well as the presence of transport infrastructure which transects the Site (NNDR, Broad Lane road and the Norwich to Sheringham railway line), have already had an urbanising impact upon the area reducing the value of the site as ‘open countryside.’


Biodiversity

Other comments raised relate to concerns over whether net biodiversity gain can be achieved through the development of the Site in line with National and Local policy. Our Client would ensure that any scheme on their Dairy Farm Site would be brought forward with the aim of achieving net gain in biodiversity through retention, protection and enhancement of any on- site habitats, provision of new public open space and high quality landscaped areas. They would also ensure that a green corridor would be maintained to the east of the site and again through sensitive design and positive enhancements would improve the ecological value of the site which in its present agricultural use is limited. Any future planning application would be accompanied by Ecological and Arboricultural Assessments to support the proposals.
Existing Buildings

Concerns were highlighted over the removal of existing agricultural buildings. A survey would be conducted to assess their current condition in the usual way. They are, however, in most other respects not appropriate for modern farming methods.
Noise

The Assessment notes concern over the impact of noise from the NNDR on potential residential development. A Noise Survey would be conducted to establish the potential effect of the NNDR and other surrounding transport infrastructure including Plumstead Road / Broad Lane and the Norwich to Sheringham railway line. The results of which would identify the requirement for potential noise mitigation measures which would then inform any potential scheme layout. Indeed, the aforementioned application at Land at Green Lane East, Little Plumstead (ref:20200202) which is subject to the same noise constraints was supported by a Noise Assessment which concluded that levels of noise recorded would not require any additional attenuation over and above standard building specifications.
Flooding

The Great and Little Plumstead Booklet notes that the Site is located within Flood Zone 1 in its entirety but identifies two main areas at risk of surface water flooding. Whilst the Booklet goes on to confirm that these would not be severe enough to prevent development, it states that they would require further consideration. Our Client would ensure that a Flood Risk Assessment would be submitted in support of any future planning application for the site which would be used to inform the subsequent drainage strategy and scheme layout.
Conclusion

The Great and Little Plumstead Assessment Booklet concludes that whilst the Site is not currently proposed for allocation “it may be more difficult to resist development there in the future if additional housing growth is needed.” As demonstrated by the response provided in


these representations, it is considered that the allocation of additional sustainable sites, which are available and deliverable, like Land at Dairy Farm, is required to provide greater security over the plan period.
Recommendation: In order to provide greater certainty for the plan period it is considered that additional sites in sustainable locations which are capable of delivering housing growth within the plan period should be allocated; providing the opportunity to allocate Land at Dairy Farm, Thorpe End.