Policy 1 - The Sustainable Growth Strategy

Please see attached letter

In summary: The settlement hierarchy in the Pre-Submission Plan should be based on an up-to-date assessment and reflect current circumstances. Horsford should be reclassified as a Key Service Centre, and an appropriate and increased level of growth assigned to it.

These representations comprise the following:

• Letter dated 22 March 2021 (Savills) (which includes the full representations on all 10 points and should thus be seen as accompanying / attached to all 10 representations)

The following enclosures to this letter (these are being sent by emails 2 and 3 of 3):

o Vision Document (Savills), March 2020
o Highway Capacity Assessment and Public Transport Provision Review for Phase 3 Development (Richard Jackson), 6 December 2018
o Education Report: Land at North Horsford (Phase 3) (EFM), December 2018
o Utilities and Drainage Review (BDW), 29 November 2018
o Ecological Report (TMA), December 2018
o Cultural Heritage Desk-Based Assessment (RPS), March 2020
o Landscape and Visual Appraisal (CSA), February 2020

Please see attached letter

In summary: The Pre-Submission Plan should demonstrate that it will be possible to demonstrate a 5YHLS on adoption of the Plan.

These representations comprise the following:

• Letter dated 22 March 2021 (Savills) (which includes the full representations on all 10 points and should thus be seen as accompanying / attached to all 10 representations)

The following enclosures to this letter (these are being sent by emails 2 and 3 of 3):

o Vision Document (Savills), March 2020
o Highway Capacity Assessment and Public Transport Provision Review for Phase 3 Development (Richard Jackson), 6 December 2018
o Education Report: Land at North Horsford (Phase 3) (EFM), December 2018
o Utilities and Drainage Review (BDW), 29 November 2018
o Ecological Report (TMA), December 2018
o Cultural Heritage Desk-Based Assessment (RPS), March 2020
o Landscape and Visual Appraisal (CSA), February 2020

Please see attached letter

In summary: The Pre-Submission Plan should identify a 'housing requirement' figure that takes into account evidence of higher levels of housing needs, and plans for a level of housing need that reflects other parts of the Plan, specifically drivers for economic growth.

These representations comprise the following:

• Letter dated 22 March 2021 (Savills) (which includes the full representations on all 10 points and should thus be seen as accompanying / attached to all 10 representations)

The following enclosures to this letter (these are being sent by emails 2 and 3 of 3):

o Vision Document (Savills), March 2020
o Highway Capacity Assessment and Public Transport Provision Review for Phase 3 Development (Richard Jackson), 6 December 2018
o Education Report: Land at North Horsford (Phase 3) (EFM), December 2018
o Utilities and Drainage Review (BDW), 29 November 2018
o Ecological Report (TMA), December 2018
o Cultural Heritage Desk-Based Assessment (RPS), March 2020
o Landscape and Visual Appraisal (CSA), February 2020

Please see attached letter

In summary: The Pre-Submission Plan should identify a 'housing requirement' figure.

These representations comprise the following:

• Letter dated 22 March 2021 (Savills) (which includes the full representations on all 10 points and should thus be seen as accompanying / attached to all 10 representations)

The following enclosures to this letter (these are being sent by emails 2 and 3 of 3):

o Vision Document (Savills), March 2020
o Highway Capacity Assessment and Public Transport Provision Review for Phase 3 Development (Richard Jackson), 6 December 2018
o Education Report: Land at North Horsford (Phase 3) (EFM), December 2018
o Utilities and Drainage Review (BDW), 29 November 2018
o Ecological Report (TMA), December 2018
o Cultural Heritage Desk-Based Assessment (RPS), March 2020
o Landscape and Visual Appraisal (CSA), February 2020

Breckland District Council has concerns over the Greater Norwich Local Plan and its growth plans. A large proportion of Breckland District Council’s growth plans are concentrated in the same area of the Norwich – Cambridge Corridor and the Council’s main concerns are the cumulative impact of the growth on infrastructure particularly power which has been identified as a constraint in this area in the Greater Norwich Energy Study April 2019. However, this study has failed to consider the cumulative growth of both Breckland and GNLP growth plans. Sufficient water resources both supply and waste management is also a concern as indicated in the Anglian Water Resources Management Study 2019. The Council does not consider the water efficiency policies proposed are going to adequately address the water requirements to support the growth from both Breckland and the Greater Norwich area. Under the Duty to Cooperate, Breckland District Council would welcome the earliest opportunity to engage with GNLP to explore a joint approach to any constraints which may arise as a result of the cumulative growth in both planned areas.
The Council is also particularly interested in any growth aspirations along the A47 at Honingham Thorpe; and A11 at Hethel and Silfield which would further put pressure on infrastructure in the area and under the Duty to Cooperate, Breckland District Council would welcome the earliest opportunity to engage with GNLP to explore the location and impact of any proposals in the Honingham Thorpe, Hethel and Silfield area on infrastructure including power and water as well as the impact on Breckland’s communities living nearby and to work jointly to minimise any adverse effects which may arise as a result.

See attachment.

Please find the consultation response from Climate Emergency Planning and Policy to the Reg 19 Pre-Publication Draft GNLP attached.

Please find the consultation response from Climate Emergency Planning and Policy to the Reg 19 Pre-Publication Draft GNLP attached.

See attachment for full representation and suggested changes to the plan

These representations are submitted on behalf of Landstock Estates Ltd and Landowners Group Ltd (the Promoters) in response to the Greater Norwich Development Partnership(GNDP) consultation on the February – March 2021 Greater Norwich Local Plan (GNLP) Regulation 19 Consultation. The promoters have land interests in North East Wymondham

See attachment for full representation.

Please see attachment for full representation (section 2)

For Rosconn Strategic Land, please find attached the following documents and information:

1. Duly completed representation form
2. Representations to relevant policies of the GNLP and relevant parts of the evidence base
3. Site delivery statements including high level transport review note for Land South of Flowerpot Lane, Long Stratton (HELAA Ref. 4033/34)

Please see the sections addressing Procedural Issues and Policy 1 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land west of Nelson Road, Diss.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Nelson Road, Diss. Please find attached response forms, the representations, a Concept Plan and Landownership Plan.

Please see the sections addressing Procedural Issues and Policy 1 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land at Walcot Green Lane, Diss.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Walcot Green Lane, Diss. Please find attached response forms, the representations and a Delivery Statement.

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation.

See section 4.2 for comments regarding Policy 1

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation.

See attached letter

Please find attached to this email planning representations on behalf of our client FCC Environmental to the Greater Norwich Local Plan Regulation 19 Consultation regarding their Pulham Market site.

I know that others have submitted very well-argued and detailed responses to the GNLP, viz. Bryan Robinson and Andrew Boswell. From reading them, and the GNLP documents, it seems that there are many aspects of planning which the GNLP has not addressed, or addressed incorrectly.

1) The latest plan has taken into account projected housing need figures produced in 2018, whereas it is stated clearly that those from 2014 should have been used.
2) The 2018 figures are higher, and do not take into account the already-stated ‘windfall’ house numbers which inevitably arise.
3) This is made worse by the fact that the later figures do not adequately reflect the fact that Britain has left the EU, and immigration figures are reducing. It simply does not make sense to plan to build houses which are unlikely to be lived in. Even now, there are plenty of permissions for houses which have not been taken up. These surely should be used before looking to increase dramatically the numbers of extra houses planned to be built.
4) The development of the area should be about more than simply building dwellings. Norfolk should be preserving its precious countryside, not planning to put it under bricks an
5) The numbers in the new proposals are not justified, and thus not consistent with the NPPF. It is doubtful whether the numbers proposed could ever be served adequately by local services as they stand. Also, the plans are not sustainable, in that they will negatively affect the freedom future generations will have to determine the development of the area.
6) Following the COVID pandemic, the whole plan should be looked at afresh, bearing in mind changed working practices. Transport, in particular, needs to be assessed now that the rush-hours appear to be less ‘peaky’ and the government’s stated aim of bringing about a modal shift to greener forms, mainly public transport, should mean that new and upgraded big roads are removed from the plan.

Please think again about making such a huge change to our rural county. We need a reasonble-length time of stability, consolidation and improvement of what we have.

Re: Greater Norwich Local Plan Regulation 19 Pre Submission Draft Consultation.
I refer to the above document and the consultation upon its contents. Please accept this letter as our response on behalf of our client Land Allocation Ltd to the above consultation.
We wish to make representations upon housing numbers, the spatial strategy, and rural housing, particularly focusing on policies 1, 7 and 7.2. We also wish to comment upon the proposed allocations at Diss a Main Town within the settlement hierarchy.
Housing Numbers: Policy 1 The Sustainable Growth Strategy
Policy 1 identifies that to meet the need for around 40,550 new homes, provision is made for a minimum of 49,492 new homes and sets the settlement hierarchy of Norwich urban area (Norwich and Norwich Fringe, Main towns, Key service centres and Village clusters.
It is centrally important to consider the Local Housing Need requirement in order for an appropriate and sustainable level of growth to be identified and provided for across the Great Norwich Area, delivering a sufficient amount of housing over the plan period. It is noted that this consultation includes a housing figure of 1,961 dwellings per annum, however, there is no real certainty within this Local Plan consultation in regards to the suitability of these figures. A key government objective is to ‘significantly boost’ housing supply, and it is felt a greater emphasis should be placed on the wording of the policy so that it is recognised as the minimum housing requirement.

Paragraph 60 of the NPPF states 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 which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
It is important to note that Paragraph 60 of the NPPF and the associated guidance within the PPG are clear that the standard method represents the “…minimum number of homes needed…” The plan must respond to the Governments key objective of boosting the supply of housing. It is important that there is flexibility in the number of housing allocations to ensure that a five-year housing land supply can be maintained over the plan period in order to meet the housing requirement. Therefore, the Council should be seeking to over-allocate housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance.
Any Local Plan currently being prepared will also have to consider the effect of the coronavirus pandemic on the housebuilding industry, and subsequently, the deliverability of the Council’s current five-year housing land supply. Whilst still relatively unknown, delays in the deliverability of housing are likely, and therefore, a subsequent undersupply may occur.
The Council have calculated the Local Housing Need, based upon the Standard Methodology resulting in 1,961 dwellings a year, but this calculation was carried out in June 2018. Further, the LHN, when calculated using the Standard Methodology, can fluctuate year to year based upon the housing projections, and the Standard Methodology doesn’t take account of economic growth. We therefore, recommend a Housing Requirement between the aggregated Local Housing Need for the three authorities calculated by the Standard Methodology and a requirement that takes account of the economic growth that the draft Local Plan identifies 33,000 additional jobs and allocates 360 hectares of employment land.
Just as the Local Housing Need can fluctuate, so can the buffer that is required in the context of 5-year housing land supply. The District Council may decide to confirm their 5-year housing land supply, in which case a 10% buffer would apply, and the rate of deliverable may also fall over the plan period, in which case a 20% would apply. We consider that a 20% buffer would ensure that the plan is future-proofed and provide flexibility, choice and competition in the housing market, reflecting government guidance.
We consider that the Council should be targeting a higher housing requirement than the Local Housing Need calculated using the Standard Methodology. It is notable that the proposed requirement does not provide an uplift for economic growth, even though the draft Local Plan identifies 33,000 additional jobs and allocates 360 hectares of employment land. We support the Local Plans ambition with respect to economic growth and believe that a housing requirement uplift is necessary to support this.
In addition, the PPG identifies other factors which need to be considered when determining the housing requirement. These include growth strategies, planned infrastructure, previous levels of delivery and recent assessments of need such as Strategic Housing Market Assessments (SHMA) where this suggests a higher need (PPG ID 2a-010). The Plan must be aspirational but deliverable to be positively prepared (NPPF, paragraph 16), and the target of new homes per annum is insufficient to realise job-led housing need across the plan area. In order to be found sound, the Local Plan should be targeting higher growth within the Local Plan in accordance with the above explanation.
Housing Distribution: Policy 7 Strategy for areas of growth
Policies 7.1 to 7.5 provide details on the housing distribution. The Main Towns of Aylsham, Diss (with part of Roydon), Harleston, Long Stratton and Wymondham provide just over 6,806 homes, approximately 14% of the proposed housing growth planned to 2038.
The GNLP identifies that the Main Towns ‘play a vital role in the rural economy, providing employment opportunities and services for wider hinterlands. As such, they are engines of rural growth and it is important that they are enabled to grow at appropriate scales, having regard to infrastructure and environmental issues, to enable them to thrive.’ Diss is identified as having ‘the widest range of shops and services of the main towns, as well as a broad range of employment opportunities mainly located to the east of the town centre close to the railway.’
Policy 7.2 distributes the 6,208 new homes between the Main Towns. Given that Diss the Main Town that the GNLP identified as having the widest range of services, then it is counter-intuitive that other Main Towns have higher growth, for example, Aylsham and Harleston are allocated 550 and 555 new homes whereas Diss is allocated 400 new homes.
In order for sustainable growth to be delivered across the Area at the level that is required, the local plan strategy should encompass a need for development within rural areas. Whilst a larger proportion of housing and employment growth should be focused on the urban or improved infrastructure areas, growth should also be located within the areas that the GNLP identifies as playing a vital role in the rural economy.
By permitting development in such settlements, it would help to assist in maintaining the vitality of these rural areas. Further a mix of smaller and medium scale sites can be delivered at a faster rate than the larger, allocated sites. Such sites form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow the Councils to continuously maintain a healthy and constant supply of deliverable sites.
In combination with the growth dispersed to the larger settlements, development in rural areas would ensure that there was a level of housing growth across the areas where those houses are needed. It would promote housing and would also ensure that rural areas received appropriate growth levels to maintain and enhance economic vitality, and the services and facilities required would be maintained. This approach would take account of paragraph 78 of the Framework sufficiently to promote housing growth in the rural settlements of the District’s. In such areas, more housing would assist in maintaining the vitality of rural areas, including the retention of services and facilities that depend on economic growth. Such an approach will promote greater and more sustainable developments.
Part 2: Allocations
To simply provide for the local housing need figure of 1,961 per year with an over-allocation of 22% would represent both a vulnerable overall strategy and would therefore be expressly contrary to the requirement to significantly boost the supply of housing embedded within the Framework. It would also lead to insufficient flexibility in the number of housing allocations to ensure that a five-year housing land supply can be maintained over the plan period to meet the housing requirement.
It is considered that this approach provides an overly vulnerable strategy, with little margin for error should there be even just a minor change in circumstances. It is therefore essential that the Council over-allocate housing land further to ensure flexibility, choice and competition in the housing market reflecting government guidance.
Policy 7.2 identifies that Diss as a Main Town and the preamble to the policy states that: ‘the town has a strong local employment base and supports three main supermarkets, a wide range of local shops and services in the town centre, and a full range of facilities (including secondary school, GPs, leisure centre, library, a variety of sports clubs etc.).’
The GNLP provides for at least 400 new homes for the town of Diss, which consists of the allocation of Frontier Agriculture for 150 homes and the Diss & District Neighbourhood Plan fulfilling the remaining overall housing requirement. There are also three carried forward allocations and commitments this provides for Diss (including part of Roydon) 754 homes between 2018-2038.

Given the status of Diss and the Towns access to services, it is therefore difficult to comprehend the new allocation of only 150 dwellings in the GNLP with the future allocation of 250 dwellings in the Diss and District Area Neighbourhood Plan.
Policy GNLP0102 allocates land at Frontier Agriculture Ltd, Sandy Lane, Diss (3.61 ha) for residential development to accommodate approximately 150 homes. This site is located to the east of the railway, so noise mitigation will be required and is in an area historically characterised by employment premises, and the site is likely to be contaminated also. The preamble to the policy also states that ‘the number of homes sought is set at 150 due to the highly sustainable town centre location, but the exact figure will be subject to detailed design and viability considerations.’ The site is unlikely to meet the definition of a deliverable site within the Framework.
Its allocation is even more difficult to comprehend when our clients site at land to the North of Walcot Rise, Diss is not constrained by such matters explained above. There is a willing landowner who has entered into a promotion agreement with our client Land Allocation Ltd who has submitted an outline planning application under reference 19/1555.
The Outline Planning Application was accompanied by substantial supporting documents such as Traffic Assessment, Heritage Impact Assessment, Flood Risk Assessment, Phase 1 Contamination Report, Landscape and Visual Impact Assessment and Ecological Surveys. None of which indicate that there are on-site issues that would prevent the sites allocation for residential development.
There are no significant abnormal or major infrastructure requirements. The Full Policy Requirements for Planning Obligations and CIL are expected to be made, as evidenced by the Outline Planning Application. There is no indication of any viability issues here.
The site forms a natural extension of the settlement, and there are no major constraints or viability matters to prejudice the development of the site for housing. There are no legal issues. The landowners are party to a promotion agreement with our client Land Allocation Ltd. Consequently, the site is deliverable, available and developable now.
Conclusion
We consider that the GNLP should be targeting a higher housing requirement than the Local Housing Need calculated using the Standard Methodology. It is notable that the proposed requirement does not provide an uplift for economic growth, even though the draft Local Plan identifies 33,000 additional jobs and allocates 360 hectares of employment land as a key priority for the Plan. We support the Local Plans ambition with respect to economic growth and believe that a housing requirement uplift is necessary to support this.

Just as the Local Housing Need can fluctuate, so can the buffer that is required in the context of 5-year housing land supply. District Councils may decide to confirm their 5-year housing land supply, in which case a 10% buffer would apply, and the rate of delivery on sites may also fall over the plan period, in which case a 20% buffer would apply. We consider that a 20% buffer above the uplift for economic growth would ensure that the plan is future-proofed and provide flexibility, choice and competition in the housing market reflecting government guidance.
As the Main Town that the GNLP identified as the Town with the widest range of services, the distribution of housing should reflect this by increasing the proportion of new homes to Diss. Overall, our clients site represents a deliverable, sustainable housing site and should be allocated in the emerging Local Plan for housing. Its inclusion within development limits and allocation will help to facilitate the future growth of Diss within the Greater Norwich area.
The site can deliver new housing within the short term and can make a significant and positive contribution towards addressing identified housing needs. The site adjoins the existing built-up and is seen in the context of the existing settlement. Through an appropriately designed scheme, an attractive residential development can be achieved, which will provide benefits to the local community as well as providing visual benefits.
If you need any further information or wish to discuss matters further, then please don’t hesitate to contact me at this office. We trust that our representations will be taken account of in the future stages of the preparation of the Local Plan.

Please see accompanying statement and supporting information. Site GNLP0341 in Diss should be allocated for older peoples housing

Please see accompanying statement and supporting information regarding Land between Shelfanger Road and Mount Street Diss (Reference GNLP0341).

I was trained as a biologist specialising in Ecology and Nature Conservation and lectured on these subjects at universities and colleges for 30 years
I was a member of the Colney Parish Meeting for 21 years and the Chairman of the committee for many years as the NNUH and the Research Park developed. In the early 1990s I produced an Environmental Assessment for then owners of Colney Hall.

Colney Parish has asked me to prepare a brief on local flood issues. This is because the property where I have lived for more than 30 years is beside the River Yare and I have examined flooding events in the area with great interest.

I feel that I have a sound knowledge base for commenting on major development proposals.

Great Norwich Local Plan proposals.
1. Colney
1. Policy GNLP0253
1a. Summary of Conclusions
Colney Hall is outside the approved 2015 Local Plan limit of development and development would have significant negative impacts on protected landscapes.
Colney parish objected to the inclusion of Colney Hall in 2018. Significant constraints have been identified under Housing and Economic Land Availability Assessment (HELAA). The proposal did not perform well scoring double negatives in a Sustainability Appraisal ( SA)
The facility proposed in the GNLP 0253 is not required to be located near the research park .
The 80 beds and 120 units of extra care housing is likely to add thousands more traffic movements on the B1108 an already congested road and would seriously impede through traffic to and from Norwich, UEA, the NNUH and the Research Park.

The Colney Hall 0253 proposal should be removed from the proposed GNLP 2021

1b Colney Hall Constraints
Colney a small village with more than 10% new homes, the site of Norwich Research Park, Norfolk and Norwich University Hospital, Spire Hospital, Global Clinic,GreenAcres burial site, two Anglian water substations , a large electricity substation and the Training Ground for Norwich City Football Club.

Parish Plans were announced in the 2000 White Paper and in 2009 a Parish Plan for Colney was produced. In 2015 the local Plan was approved setting the limit of development within the parish.
Colney Hall is outside the 2015 limit of development and development would have significant negative impacts on protected landscapes , the Yare Valley and Southern Bypass Landscape Protection Zone.

Recently, there have applications in Colney for an end of life hospice and the expansion of the GreenAcres site for a further 3600 burial plots. Despite concerns by the parish on flood related issues these applications have been approved subsequent to the GNLP proposals for Colney Hall.

The GNLP 0253 application proposes Colney Hall, (approx. 24.99 ha) is allocated for specialist housing for older people The site is to accommodate a dementia care unit of approximately 80 beds, approximately 120 units of extra care housing, and the conversion of Colney Hall. This application seems very similar in intent to the Priscilla Bacon Hospice (PBH) 2020/0578 application that has already been approved by South Norfolk Council in 2020.
Objections raised concerns regarding the extra amount of housing already planned for the area, removal of more protected green space and the impacts wildlife biodiversity. Norfolk Wildlife Trust stated constraints relating impacts on existing CWS 235 and impacts on floodplain may be significant and should be recognised as factors potentially making this allocation unsuitable for the proposed development.
Norwich Green Party comments on GNLP0253 and GNLP0158 (land within Yare Valley N of Watton Road) considered this land should be part of a Norwich Greenbelt and therefore protected from significant development so that it is retained as protected green space.

The Housing and Economic Land Availability Assessment (HELAA) for the site indicated a number of constraints relating to Access, Accessibility to Services, Utilities Capacity, Contamination and Ground Stability, Flood Risk, Market Attractiveness, Significant Landscapes, Townscapes, Biodiversity and Geodiversity, Historic Environment, Transport and Roads, Compatibility with Neighbouring Uses. A Sustainability Assessment was carried out and the proposal did not perform well scoring double negatives for air quality and noise, climate change mitigation and adaptation, Biodiversity, Geodiversity and GI, Education, Historic Environment and Natural resources, waste and contaminated land

However, although HELLA indicated that a suitable access may be possible, and that impact on local roads could be mitigated. I have found it difficult to find evidence in the GNLP 0253 proposal to support this conclusion. The nearest comparison site is the Priscilla Bacon Hospice 2020/0578 is smaller, 24 beds, and the application shows that the traffic generated would be some 851 movements a day. The GNLP0253 application for 80 beds and 120 units of extra care housing would seem likely to add thousands more traffic movements on the B1108, an already congested road and would seriously impede through traffic to and from Norwich, UEA, the NNUH and the Research Park.


2. POLICY BAW 2: Bawburgh and Colney Lakes
Bawburgh and Colney Lakes (approx. 73.5ha) is allocated for a water-based country park.
The 2009 Colney Parish Plan suggested a much less intrusive approach. Involving a network of circular walks linking the communities of Colney, Bowthorpe, Bawbugh, Hethesett, Little Melton, Earlham, UEA, NRP and the NNUH.

The BAW 2 land should be part of a Norwich Greenbelt involving the Yare Valley and protected from significant development so that it is retained as protected green space. Incorporated could be the existing County Wildlife Sites, Local Nature Reserve and possibly GreenAcres and Colney Hall.
This complex could form a important Wildlife Conservation Area with an information center for the wellbeing of local communities

Colney represents in microcosm the issues that face development in the Greater Norwich Area and throughout Norfolk.

3. Key Issues in the Area of Greater Norwich Local Plan.
3a Housing
Many residents will recall David Cameron on BBC’s Countryfile programme in 2012 stating,
“Our vision is one where we give communities much more say, much more control. The fear people have in villages is a great big housing estate being plonked down from above" .

Residents in towns and villages in the Greater Norwich Area and throughout Norfolk regularly learn of such new housing developments planned in their area. Who are these houses for? Certainly not for our local young people trying to own their own home as the so-called affordable homes in the development cost much more that most young people can afford. Developers frequently attempt to reduce the already low numbers of these "affordable homes " still further, arguing if they do not the scheme would not be profitable for the developer!!!!

It is puzzling why developers are still making applications for more development and getting approval by planners when there are some 31,452 un-built commitments in the GNDP area. Technically they are not all planning permissions - they are mainly site allocations in the JCS which will be rolled over into the GNLP)with a presumption therefore that planning permission will be granted.

An excuse often used by developers for new applications was the 5 year land bank requirement from local councils has not been achieved. However, throughout Norfolk the 5 year bank requirement has been achieved so why are some planners still approving new developer applications?

Norfolk is a very attractive county and it is understandable why people wish to live here. A reason suggested is that properties are cheaper in Norfolk. Why are they cheaper? This is because many developments are being built on greenfield sites where land is cheaper. Some developments like the Research Park and the Hospital are necessary but do we need more out of town retail parks and houses on greenfield sites?

A cornerstone of Norfolk's economy is agriculture. Nearly a quarter of the total of the national income comes from farming in the eastern region. Great swathes of productive farmland in Norfolk are going under construction projects. Satellite research showed East Anglian counties have had huge losses of farmland with Norfolk faring worst.

Unneeded and unwanted development is spreading like a cancer in the Greater Norwich Area and around our market towns and villages engulfing farmland when there are tens of thousands of unbuilt houses in approved housing allocations. Planners seem to be allow developers to "cherrypick" areas for new developments on greenfield sites

3.b Flooding
What has all this to do with flooding? The recent 2020 floods have been widespread including Norfolk and have raised awareness of flood issues and the risk of development. Around Norwich, for years there have been local and government action plans and flood assessment advising restricting development in most flood risk areas,
2011 Norwich Urban Area Surface Water Management Plan (SWMP); this includes groundwater susceptibility and covers most of Colney and shows the site has high susceptibility to groundwater flooding.
2018 Surface Water Management Action Plan (SWMAP). Department for Environment Food and Rural Affairs
2017 Greater Norwich Strategic Flood Risk Assessment (GNSFRA 2017).

The maps I have for the 1912,1968 and 1993 flood areas are incomplete and have probably been updated. Similarly with the groundwater susceptibility and surface water maps.
I have just read with interest the Greater Norwich level 2 Flood Risk Assessment but I have not been able to view Maps showing,
a. the extent of historic floods especially for the 1912, 1968 and 1993 events.
b. Groundwater flood susceptibility in GNLP area.
c. Surface Water flood areas.
The Level 2 assessment is extremely useful for examining specific sites. These give a series of pictures but a single map linking the all Groundwater flood susceptibility areas in GNLP and one for Surface Water flood areas would give a holistic picture for these matters in the GNLP area.
It is surprising that maps showing the extent of major floods have not been produced.

Unfortunately some planners and developers seem unaware of action plans and flood assessments and applications are approved in flood risk areas. Applications sometimes state flooding of a site once in a hundred years is a fairly unlikely flood event. However, the extent of historic flooding is not only important historically but has implications for development in the present day in river valleys. Around Norwich, for example, in the 1912 flood, houses in Wymondham were severely damaged along with the bridges at Bawburgh, Trowse and Lakenham. Records indicate major flood events occurred in river systems in the Norwich area in 1770, 1784, 1878, 1912, 1947, 1968,1993 , 2015, 2018 and 2020. This suggests that there is less than a 30 year interval between major floods and this interval is decreasing . Planning applications often do not mention this. Even a 30 year interval would make many developments unsustainable and the applications should be refused. Climate change is likely to increase the frequency of such flood events.
Unfortunately the Environment Agency flood map for three major flood events, only shows the extent of the floods in selected areas. Surely with modern mapping techniques almost all historic flood events such as the 1912 event can be mapped and made available to towns and parishes. This would give everyone an idea of the potential extent of flood areas. The groundwater susceptibility maps for the Norwich area is interesting because it indicates potential extent for flooding.

It would be informative if planners published information on the number and location of flooded properties in their area in the last 50 years and the dates when these properties were built.

3.c Norwich Western Link
For a year I worked for Bernard Matthews mainly at Weston Longville and have a fair appreciation of the area of the proposed NWL
If a Norwich Western Link ( NWL) is thought necessary it is not clear to many people why Option C was chosen by Norfolk County Councillors when a much cheaper and less environmentally damaging Option B(West) route is available.

1.Option B(west) and Option C both join the A47 at the same point, Wood Lane near Honingham. The economic benefits seem almost identical.
2. Option C involves a 720-metre-long viaduct over the Wensum and would cost £153 Million.
Option B(West) could utilise the existing bridge and needs no new crossing of the Wensum, no viaduct and costs £129 Million.

3. Environmental issues relating to NWL are extremely important.
Option C would destroy parts of important County Wildlife Sites (CWS) and permanently sever connections between other habitats along the route.
Option B(West) skirts past almost all CWS and important habitats and was identified by the Environment Agency as the least environmentally damaging route and would provide a bypass for Weston Longville

4. Another option that might be considered in view of controversy about an NWL is a single carriageway route for Option B(West) would have less environmental impact and at a cost of about £43 Million, the cheapest option of all.

See attachment.

On behalf of our client, Fuel Properties (Norwich) Ltd, we provide our comments on the Greater Norwich Plan Pre-Submission Draft Strategy (Regulation 19 Publication Stage), published for consultation in February 2021.

Fuel Properties (Norwich) Ltd are the developers of the Carrow Works site in east Norwich, which is identified in the emerging Greater Norwich Local Plan as being within the East Norwich Strategic Regeneration Area. The wider Regeneration Area has the potential to deliver some 4,000 new homes and 6,000 jobs, and will act as a catalyst for longer term regeneration of the wider area. The Carrow Works site comprises an important and substantial part of the East Norwich Strategic Regeneration Area and provides a significant opportunity to deliver growth for Norwich City the Greater Norwich
area.

Our client welcomes the opportunity to provide comments on the emerging Greater Norwich Local Plan and to work collaboratively with the authority and key stakeholders as the plan progresses.

See attachment for full representation.

An up-to-date evidence base in relation to the current and proposed open space and play space provision is required to inform the Strategy and proposed allocations.

This representation is submitted by Le Ronde Wright on behalf of the Trustees of site at Sprowston Sports and Social Club.

This submission relates to Policy 1, Policy 2 & 3, Policy 5 and paragraphs 275 to 277, and Policy 6. See summaries for detail.

A straightforward solution would be to revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

THE FOLLOWING IS AN OFFICER-CREATED SUMMARY OF MR CAWDRON’S REPRESENTATION. THE FULL TRANSCRIPTION IS ALSO ATTACHED

The changes between the Reg18C draft plan and the Reg 19 version include a significant increase in housing numbers, which has not been subject to public consultation. Furthermore, the latest Government advice from December 2020 is that the 2017 method of calculating housing requirement would continue, negating the need for the additional housing and buffer. Using the 2017 method, the projected need for 20 years for Greater Norwich is around 40,000 homes, closely aligning with the Reg18C draft plan. The Norwich Wensum Link should not be included as a legal assessment made in 2016, which is still current, found that the integrity of the SAC would be adversely affected and only relatively little weight would be attached to the need to relieve congestion in the Norwich area. The GNLP attempts to distance itself from the HRA obligations connected to the NWL, which is a project which overrides a legal opinion in 2016. There is no mention of the December 2020 Government carbon target emissions reduction of at least 68% by 2030.
To correct these issues, revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

Prepare a robust Housing and Economic Needs Assessment to comply with national guidance and clarify the number of homes likely to be needed in Greater Norwich where this appears likely to exceed the outcome of the standard method.

Policy 1 would benefit from the inclusion of a para under the Settlement Hierarchy to reference the commitment to a new settlement to meet additional housing needs within the Plan period.

Expanding Policy 1 to include within its spatial strategy more specificity about what a ‘sustainable community’ might constitute at a strategic scale would be helpful in guiding decisions about the criteria for new settlements, decisions for which will need to be taken in the next 2
years if the Councils delivery programme is to be met.

SEE FULL REP ATTACHED

Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.

The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.

The current wording of the policy needs to be strengthened with regard to the delivery of green infrastructure (GI). Currently it is rather vague and weak with regard to the essential role that quality GI must play if sustainable development is to be delivered under the Plan and meet the needs and aims as set out in the accompanying text under (161).

The policy needs to cross reference Policy 3 in order to provide a strong and clear steer of what will be required to deliver the growth strategy, whilst protecting and enhancing the area’s natural environmental assets, and to make the Plan sound. It refers to other relevant Plan policies in relation to housing, the economy, areas of growth and other strategic infrastructure, so links to Policy 3 should be included too.

We would like to see a greater reliance on windfalls on brownfield sites. It is highly likely that a generous number of windfall sites will come forward given the shake up of the economy, for example, loss of city centre retail and conversion of offices to dwellings. The GNLP states that evidence provides an estimated 4,450 homes from resulting from windfall development. Yet, only 1,296 dwellings have been allowed under windfalls, even though the GNLP acknowledges that ‘windfall development is likely to remain robustly high’.

Summary
We consider the GNLP to be unsound:
- Not positively prepared
- Not justified
- Not effective
- Not consistent with the NPPF

The GNLP Reg 19 would increase carbon emissions, contrary to the national legal target of net zero by 2050. The policy framework on climate change and local plans is addressed in the Centre for Sustainable Energy paper. Although climate change has been strengthened in the GNLP by the inclusion of a new climate change statement, it has been bolted onto to a previously prepared growth strategy and set of policies which are inconsistent with the statement and the evidence base on climate change. The GNDP is aware of this deficiency because they have agreed to review the Local Plan on climate change following its adoption.

The GNLP was not ready for the Regulation 19 stage. GNDP members had agreed to commission further work and undertake a Regulation 18C six week focussed consultation, but following the Planning White paper, they decided to proceed immediately to Regulation 19.

In our view, the Plan should not be accepted as sound but returned to the GNDP for further work to ensure soundness.

There are a number of matters which we consider to be unsound because they are
incompatible with the duty to proactively contribute to the mitigation of, and adaptation to, climate change under section 19 (1A) of the Planning and Compulsory Purchase Act 2004 which requires Local Plans to 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”
The matters include:
- Absence of an overall carbon budget for Greater Norwich to 2050 consistent with the Climate Change Act 2008, supported by a strategy and policies in line with the carbon budget trajectory.
- High housing number which will increase development pressures on greenfield sites;
- Growth that includes dispersal of development to small villages which lack services and the possibility of new garden city settlements in open countryside distant from railheads (Thorpe Honingham, Hethel and Silfield).
- Sub-optimal energy efficient standards and renewable renewable energy generation
- Lack of attention to retrofitting of historic development.
- A transport strategy which would increase carbon emissions by caterimng for traffic growth and modest modal shift to bus, walking and cycling.
- Inclusion of a Norwich Western Link.
- Support for improvements to strategic highways.

Several of these issues are addressed in the Reg 19 response by the Centre for Sustainable Energy which was commissioned by Norwich Green Party (on sustainable communities, zero carbon development, sustainable transport, renewable heating, renewable energy generation and retrofitting of traditional and historic buildings).

The CSE paper forms part of our representation on Regulation 19.

We also endorse responses submitted by other parties who share the same concerns on a range of matters: CPRE, Norfolk Wildlife Trust, Wensum Valley Alliance, Dr Andrew Boswell and Client Earth.
They cover soundness matters at considerable length:

- Climate change
- Housing numbers
- Growth Strategy
- Green Wedges
- Green Infrastructure

Norwich Green Party Group’s representation mainly covers Transport Policy 4 which we consider to be unsound. We also make comments on a number of individual development sites: East Norwich, Anglia Square and on the smaller King Street Stores site.

The changes to the Plan that we would like to see are those we have set out in our previous representations on Regulation 18. They include:

- An overall carbon budget for Greater Norwich to 2050 consistent with the Climate Change Act 2008, supported by a strategy and policies in line with the carbon budget trajectory.
- A lower housing number (42,568 dwellings plus a 5% buffer) resulting in lower development pressures on greenfield sites;
- Growth concentrated in high density low car developments close to sustainable transport hubs, with a high concentration of growth located around Norwich.
- No dispersal of development to small villages which lack services.
- No new garden city settlements in open countryside distant from railheads (Thorpe Honingham, Hethel and Silfield).
- Protection of Green Wedges around Norwich.
- Development build to zero carbon standards that include renewable heating based on renewable energy generation
- Retrofitting of historic development.
- A transport strategy based on traffic reduction and a high degree of modal shift to bus, walking and cycling.
- Abandonment of a Norwich Western Link.
- No further major increase in road capacity.

For full representation see attachment.

General response to Regulation 19 Plan from Lanpro Services

Lanpro Services wish to reiterate responses made to the Greater Norwich Local Plan Stage C Regulation 18 Consultation in March 2020.

The Stage C Regulation 18 submissions were made via the local plan portal under the following references / ID’s:

Agent: Stephen Flynn

Respondent: Lanpro Services

Representation IDs:
21244, 21246, 21253, 21258, 21261, 21263, 21265, 21266, 21267, 21269, 21272, 21277, 21283, 21287, 21288, 21298, 21301, 21304, 21312, 21314, 21318, 21320, 21322, 21325, 21331, 21332, 21333, 21335, 21336, 21339, 21352, 21355, 21358.

We conclude, in line with our previous representations that certain aspects of the plan are unsound.

General response to Regulation 19 Plan from Lanpro Services

Lanpro Services wish to reiterate responses made to the Greater Norwich Local Plan Stage C Regulation 18 Consultation in March 2020.

The Stage C Regulation 18 submissions were made via the local plan portal under the following references / ID’s:

Agent: Stephen Flynn

Respondent: Lanpro Services

Representation IDs:
21244, 21246, 21253, 21258, 21261, 21263, 21265, 21266, 21267, 21269, 21272, 21277, 21283, 21287, 21288, 21298, 21301, 21304, 21312, 21314, 21318, 21320, 21322, 21325, 21331, 21332, 21333, 21335, 21336, 21339, 21352, 21355, 21358.

We conclude, in line with our previous representations that certain aspects of the plan are unsound.

Please see the sections addressing Procedural Issues and Policy 1 in the attached representations on behalf of the Hethersett Consortium in support of the allocation of Land at Hethersett.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Hethersett. Please find attached response forms, the representations and a Delivery Statement .

To reflect our comments made upon the Settlement Hierarchy, in order for the growth strategy to be considered ‘sound’, Hopkins Homes suggests that the list of defined ‘Key Service Centres’ proposed within the Table under ‘Housing’ should be amended to add the settlements of Mulbarton and Scole.

As will also be outlined further below, sufficient levels of growth should be allocated to each of the defined ‘Key Service Centres’ to enable them to respectively fulfil their roles to provide for sufficient housing and economic growth over the Plan period.

Hopkins Homes are providing this consultation response in reply to the Regulation 19 Pre-Submission Draft Local Plan Consultation by the requested submission deadline of 22nd March 2021.

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

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

SECTION 5 – THE STRATEGY

THE SETTLEMENT HIERARCHY

Hopkins Homes have previously suggested that in order for the growth strategy to be considered ‘sound’ the defined ‘Key Service Centres’ identified in Paragraph 191 (iii) should include a number of other settlements throughout the Plan area which are of a size and functional role which can suitably accommodate additional residential growth in a sustainable way.

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

In respect of Mulbarton, the existing population in excess of 3,500 is higher than that of over half of the currently suggested designated Key Service Centres, which therefore further confirms the appropriateness of higher levels of proportionate housing growth than currently proposed within the Draft Plan.

Hopkins Homes would therefore suggest that for the Plan to be made ‘sound’, the settlements of Mulbarton and Scole should be added to the list of settlements defined as ‘Key Service Centres’ and the Key Diagram and Map 7 updated to reflect this.






POLICY 1 - THE SUSTAINABLE GROWTH STRATEGY


To reflect our comments made upon the Settlement Hierarchy, in order for the growth strategy to be considered ‘sound’, Hopkins Homes suggests that the list of defined ‘Key Service Centres’ proposed within the Table under ‘Housing’ should be amended to add the settlements of Mulbarton and Scole.

As will also be outlined further below, sufficient levels of growth should be allocated to each of the defined ‘Key Service Centres’ to enable them to respectively fulfil their roles to provide for sufficient housing and economic growth over the Plan period.



POLICY 5 – HOMES


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

To this end, in order for the Plan to be ‘Sound’, the wording in Paragraph 283 and in the final Paragraph of Policy 5 should be amended to indicate that proposals for self-build dwellings will be encouraged to come forward in sustainable locations and that specific smaller sites in rural locations will be Allocated for this purpose.




POLICY 7.3 – THE KEY SERVICE CENTRES


As previously outlined under the Settlement Strategy, Hopkins Homes considers that the villages of Mulbarton and Scole should be formally identified as a Key Service Centres. In particular, Mulbarton, with an existing population in excess of 3,500 is larger and more sustainable than over half of the currently designated Key Service Centres, whilst the village also benefits from a proportionately good range of services and facilities.

Whilst Wroxham has been identified as a ‘Key Service Centre’, no additional allocations are currently proposed to enable future housing growth. Hopkins Homes have previously made Representations to the GNLP that in order to suitably fulfil its role as a Key Service Centre, allocations for the proportionate further residential growth of Wroxham should be made. A copy of these previous Representations are now included as Appendices to these current Representations.

The suggested justification for not proposing any allocations for the growth of Wroxham appears to centre upon unsubstantiated claims of undue traffic and air quality impacts, together with perceived landscape impacts due to the proximity to The Broads. The available evidence does not support these claims.

In respect of traffic and air quality matters, Norfolk County Council’s ‘Wroxham and Hoveton Network Improvement Strategy’ of February 2020 highlighted the good level of available public transport in Wroxham, whilst also noted that existing air quality issues are focussed to the north of the Bridge between Wroxham and Hoveton, with the dominant direction of travel being south towards Norwich. As such, additional growth to the south of Wroxham would have no material impact upon these matters.

In respect of landscape impacts and proximity to The Broads, previous studies and evidence have concluded that additional growth to the south of Wroxham would have no direct visual relationship or impact upon The Broads, with significant resulting separation remaining in place.

Given the otherwise wholly sustainable location of the available land to enable the future growth of Wroxham, in order to suitably fulfil its intended role and function as a Key Service Centre, allocations for additional residential development should be made.



POLICY 7.4 - VILLAGE CLUSTERS


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

Coltishall Parish Council GNLP Regulation 19 Consultation Response March 2021

Contents
1.0 Objection
2.0 Sustainable development
3.0 Failure to meet sustainability requirement
4.0 Sustainable transport provision in the GNLP
5.0 Effect on Coltishall
6.0 Development needs

1.0 Objection

Coltishall Parish Council objects to the regulation 19 GNLP (henceforward the GNLP) on the grounds that it does not meet the requirement for soundness in the NPPF para 35:

a) it is not positively prepared as it is not consistent with achieving sustainable development
b) it is not justified as it is not an appropriate strategy, taking into account all reasonable alternatives
c) it is not effective, the goal of sustainable development will not be achieved by the plan
d) it is not consistent with national policy- it does not deliver sustainable development in accordance with the policies in the Framework or legal requirements

2.0 Sustainable development

2.1 Definition of sustainable development
Para 7 of the NPPF says:
‘At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.’

Para 8 of the NPPF states that the economic, social and environmental objectives of the planning system are interdependent and need to be pursued in mutually supportive ways so that there can be net gains across the objectives. The environmental objective is given as: ‘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’

2.3 NPPF guidance on conserving and enhancing the natural environment (section 15)
Para 170: ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other
benefits of the best and most versatile agricultural land, and of trees and woodland….’



Page 1 of 6

2.2 NPPF guidance on sustainable transport (section 9)
Para 102 states that transport issues should be considered from the earliest stage of plan making so that:
‘…the potential impacts of development on transport networks can be addressed…opportunities to promote walking, cycling and public transport use are identified and pursued…. the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains…’
Para 103 states that ‘The planning system should actively manage patterns of growth in support of these objectives[i.e. those in para102]. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes.’

2.4 Legal requirement to mitigate and adapt to 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’.
3.0 Failure to meet requirement for sustainability 3.1
Failure of the GNLP to meet the NPPF definition of Sustainable Development; the GNLP does not comply with 19 (1A) of the Planning and Compulsory Purchase Act 2004

The Jan 2021 Sustainability Appraisal and Strategic Environmental Assessment produced for GNDP lists 13 significant and/or cumulative adverse effects which will result from the GNLP and which are not mitigated by other aspects of the plan. The list summarising these effects (table N7) is copied below

1 Reduction in air quality.
Due to the volume of development proposed, an increase in traffic flows and subsequent reduction of air quality would be expected to have residual adverse effects on human health. In addition, many new residents could potentially be located within 200m of a main road. Cumulatively, this would be expected to result in a reduction of local air quality.

2 Increased pollutant emissions, including greenhouse gases
An increase in pollutants including greenhouse gases would be expected following the development proposed within the GNLP. The introduction of 110,367 residents would be expected to increase traffic volumes and energy demand, which would be expected to result in an increase of pollutant emissions.

3 Increased greenhouse gas emissions
The proposed development of 49,492 dwellings within the GNLP would be expected to increase carbon emissions in the Plan area by 565,079 tonnes (based on 2018 estimates). This increase would be expected to exacerbate the impacts of climate change within Greater Norwich.

4 Fragmentation of the ecological network.
The GNLP would be expected to result in the loss of approximately 1,019ha of previously undeveloped land. This loss of land would be expected to include habitats and ecological links

between designated biodiversity assets ultimately affecting the integrity of the wider ecological network.

5 Reduced access to healthcare facilities
A total of 103 site allocations are located over 5km from an NHS hospital. Residents in some of the rural settlements of Broadland and South Norfolk would be expected to have limited access to emergency healthcare, which could potentially have detrimental impacts on human health.

6 Increased risk of urbanisation of the open countryside and coalescence
A total of 85 allocated sites are located on previously undeveloped land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence. SA/SEA of the Greater Norwich Local Plan: Non-Technical Summary January 2021 LC-663_Vol_1of3_Non- Technical_Summary_8_250121LB.docx © Lepus Consulting for Greater Norwich Development Partnership N20 Residual adverse effects

7 Loss of tranquillity
The proposed development of 49,492 dwellings across Greater Norwich, with a number of developments located within rural Broadland and South Norfolk, would be likely to result in a loss of tranquillity of the rural landscape as a consequence of increases in noise and light pollution.

8 Reduced access to facilities and services
The majority of new residents would be located in areas with good access to services and facilities, including convenience stores and bus services. Nevertheless, large areas of Broadland and South Norfolk have limited access to rail services.

9 Increased household waste generation
The proposed development within the GNLP would be expected to increase household waste generation within the Plan area by approximately 31.5%. Although GNLP Policy 2 seeks to support sustainable waste management, there is little scope to reduce the quantity of waste generated per household.

10 Loss of soil resources, including BMV land
Approximately 1,019ha of development allocated within the GNLP is located on previously undeveloped land. This would be expected to result in the permanent and irreversible loss of ecologically, and potentially agriculturally, important soil resources.

11 Impact on soil ecosystem services
Soil provides a range of essential services to the local area, including nutrient cycling, abating flood risk, filtering water, filtering air, carbon storage and providing the basis for vegetation to flourish. The scale of development proposed within the GNLP would be expected to increase pressure on essential ecosystem services.

12 Reduction of water quality and ecosystem services
A total of 85 allocated sites are located on previously undeveloped land. The proposed development at these sites could potentially result in the contamination of nearby surface waterbodies or groundwater. The proposed development within the GNLP could also reduce the ability of the aquatic ecosystem to effectively filter water, provide the basis for vegetation to flourish, have benefits in regard to mental and physical wellbeing, and support biodiversity.

13 Increased demand for water
The introduction of 110,367 new residents would be expected to result in increased pressure on the local water resource.

3.1
Failure to follow NPPF guidance on conserving and enhancing the natural environment (section 15)
Much of the harm identified by the Sustainability Appraisal and Strategic Environmental Assessment is due to the use of greenfield sites. Large scale greenfield development in Greater Norwich is inherently unsustainable and runs contrary to the guidance in NPPF para 107. 78% of housing (38,600 houses) is on greenfield sites. In addition, over 300ha is allocated to commercial use. 1019 ha in total of previously undeveloped land will be used. The plan allocates 4,220 houses to ‘village
clusters’ and 6,800 to surrounding towns, plus windfall housing, and this is likely to be particularly harmful. Such development is contrary to good planning policy and is unnecessary. Large amounts of office and retail space in the city centre are likely to be redundant following the pandemic and to become available for redevelopment.

3.2
Failure to follow NPPF guidance on sustainable transport (section 9)
The policy of dispersion rather than concentration is contrary to guidance in para 103 of the NPPF.

Despite a stated commitment in the GNLP to sustainable transport and lowered emissions (paragraphs 93,97,152,157 and others) this is not backed by any specific proposals or commitments for public transport, cycling or walking (See 4.0 below), contrary to para 102 of the NPPF.

On the other hand environmentally damaging transport infrastructure development is at the heart of the plan ensuring that net environmental gain is impossible, contrary to guidance (NPPF paras 8 and 102).

The GNLP promotes large scale road building, including the Norwich western link road, ignoring the well-established fact that new road construction induces further road demand and is therefore unsustainable in terms of emissions as well as being directly destructive of the environment. It causes increased traffic in other parts of the road network.

While there is a requirement in the NPPF to maintain general aviation airfields, the GNLP commits to expanding this highly polluting and unsustainable industry. Policy 4 of the GNLP (strategic infrastructure) supports ‘the growth and regional significance of Norwich Airport for both leisure and business travel to destinations across the UK and beyond’. The area allocated for aviation and business linked to the airport is 85.5 hectares (allocated but undeveloped plus proposed), by far the largest allocation by primary employment use.

4.0
Sustainable transport provision in the GNLP
If sustainability is a genuine consideration in determining the nature of development, and if the plan is to meet the requirements of the NPPF, then proposals for sustainable transport should be part of decision making from the earliest stages (NPPF para 102) and should be included in the plan and should form part of the assessment for development sites. However there are no such proposals in the GNLP.

Examples of commitments the might partly mitigate the harms inherent in the GNLP:

A network of protected cycle lanes with routes specified; a detailed commitment to safe cycle and walking routes to schools.
Recommendations on road junctions, pavements and other infrastructure, to make walking safer and more attractive.
Policy on speed limits and enforcement, and traffic calming
Improvements to existing bus services. Reinstatement of bus services. New bus services. Proposals to link bus and rail services. More frequent rail services on the Wherry and Bittern lines

Moreover, existing infrastructure is described inaccurately, if at all:
Paragraph 88 refers to a ‘relatively good existing cycle network’. There is no network in the sense of a broad continuous system even in Norwich. Outside Norwich, nothing exists that could be described as a network. The Marriot way mentioned is not a link to anywhere except for tourism and leisure purposes.

Paras 89 and 238 reference the transforming cities programme which may provide additional funding for buses in the TfN area, but no attempt is made to describe the existing service or how this might be improved and how changes might serve the new development.

Outside the TfN area the reference is to the Market Town Network Improvement Strategies. These reports are focussed narrowly on each town and are not a source of significant policies for linking centres using sustainable transport. The Wroxham and Hoveton report (closest to Coltishall) makes recommendations for tiny improvements to cycling and walking within those settlements and none for public transport.

No assessment is made in the GNLP of current road traffic volumes, how these have been affected by recent development, particularly the NDR, and how they might be affected by further development.

The approval of site allocations under the GNLP gives permission in principle for development. However, transport impacts and mitigating strategies have not been assessed prior to site allocation. This is not consistent with the NPPF paras 102 and 103.

5.0 Effect on Coltishall

Coltishall is a historic village on the River Bure with about 1500 inhabitants.

The village is midway between Norwich and North Walsham on the B1150. The B1354 also runs through the village. 2018 data from speed cameras show that there were approximately 5.2 million vehicle movements per year through the village.

The level of traffic in Coltishall diminishes the quality of life of those living and working in the village and impacts their health. The High Street and Station Road are acutely affected.

Coltishall has experienced major traffic growth in recent years as a result widespread development outside Norwich and the construction of the NDR.

Coltishall has a single inadequate, expensive, and unreliable bus service connecting the village to Norwich and North Walsham. There is no bus to the nearest town Wroxham where there is a rail station.

There is no provision for cycling. Road junctions and pavement widths prioritise vehicle movement over pedestrians.

Coltishall will suffer further traffic growth due the Norwich Western Link Road and dispersed housing development. As noted above there are no proposals for sustainable transport that might partly mitigate this harm.

5.1 Site allocations within Coltishall
There are 3 site allocations in Coltishall:

Col1 and GNLP2019 form a continuous site on Rectory Rd. Coltishall Parish Council has objected to the development of this site on a number of grounds, the most important being:

a) It is a greenfield site with high levels of biodiversity.
b) The footpath in front of the site is the route for pedestrians going to the school, playground and other amenities on Rectory Rd from the Ling Way estate on the other side of the B1150. The proposed development introduces three new roadways to be crossed. In addition it will be necessary to cross traffic from the development at two further points: on Rectory Rd at the crossing to the east side of the B1150 and at the crossing of the B1150 itself.
c) There is an existing safety concern with the junction of Rectory Rd and the B1150. All traffic from the development will be routed to this junction. This is a potentially dangerous junction for all users, but particularly for pedestrians crossing the B1150. SAM speed camera data from Feb 2019 shows that in peak periods a vehicle passes every 4.3 seconds (northbound +southbound). 60% of vehicles break the speed limit

Col2 is a site on Station Rd. Station road carries very high levels of traffic. Coltishall Parish Council does not believe this is a healthy location for a residential development. There is no footpath on the east side of Station Road down to the high street and crossing the road to the west side would be perilous.

An objection to both developments is that they will be highly car dependent and add to the existing problem of heavy traffic. Significant sources of employment and education beyond primary level lie outside the village. The Coltishall Post Office has closed down- customers must now drive to Badersfield. Poor provision for walking and cycling generates vehicle traffic within the village.

It should be noted that the housing supply outlined for Coltishall by Broadland District Council previous local plan (37) and current local plan requirement (15-20) is already in surplus. Between 2004 and 2019; 57 houses have been given planning permission and built in Coltishall. This means
that the houses expected for Coltishall have already been built based on Broadland District Council’s
plans.

6.0 Development needs
Para 40 of the GNLP says that it follows the standard methodology required by the NPPF in assessing need.
The target for housing in the GNLP is 49,492 houses up to the year 2038 which includes an exceptionally large buffer of 22% above the perceived need.

A 5% buffer is required by the NPPF and there is good reason for the GNLP to use a 5% buffer given that 78% of housing is on greenfield sites and is unsustainable, see 3.0 above.
Setting aside the question of the reasonableness of using a purely trend based methodology for development needs, which is irrelevant here, it is nonetheless possible to take a cautious view of the

predicted household growth derived from the 2014 methodology (Household Projections:2014- 2039). Under that methodology population growth accounts for 95% of household growth of which 43% is due to immigration. The England and Wales Total Fertility Rate for 2020 was 1.6 (2019 1.65, 2014 1.85, 2012 1.93)- ie it is now well below the rate of replacement. The pandemic and Brexit may lead to falls in the non UK-born population, and this is suggested by data from the ONS labour force survey to sept 2020 https://www.escoe.ac.uk/estimating-the-uk-population-during-the-pandemic/

The minimum figure of 42,568 (40,541+ 5% buffer) should therefore be the housing target, both to reduce the harm of the proposed development, and to reflect recent demographic changes.