Policy 2 Sustainable Communities

The following points are not soundness issues, but the plan could easily be amended to include them. It seems logical to address these comments as additional modifications. They provide clarity and context and further useful information.
• Policy 2, bullet 5 – would welcome, perhaps in a footnote, reference to the landscape character assessment for the Broads, so it is clear that our LCA might be of relevance as well.

We have a number of comments and observations. We do not think they are soundness issues, but the changes are needed, in our opinion, to make the plan better, clearer and more consistent. We believe they can be addressed as additional modifications.

Comments on Strategy document
Main points
The following points are quite important, but are not soundness issues. They do not affect the soundness of the Local Plan. They can however be easily added to the Local Plan to provide context, especially given the stance in the Plan that the sites in East Norwich are seen as one, including the part in the Broads. Other comments would aid clarity. These comments could be addressed as additional modifications.
• Policy 3
o The Built and Historic Environment – first bullet point – it states developers should be ‘undertaking a heritage impact assessment if significant impacts might arise’ – government guidance states that this is required for any application that affects any heritage asset or their setting – including locally identified heritage assets. Is the wording therefore needed and if so does it need re-wording?
o Policy 3 second bullet point – ‘public benefits’ might be better wording than ‘benefits’. Should this be re-worded to put the emphasis on avoiding harm to Heritage assets?
o Policy 3 - The Built and Historic Environment – last sentence states ‘importance of the heritage asset’, for the sake of consistency of terminology would ‘significance of the heritage asset’, as per the NPPF, be better?
o Policy 3 – Natural Environment – first para – it states ‘ancient trees and woodland’ should be protected. Could this be broadened out to include other trees which contribute greatly to our settlements and green spaces?
• The map on page 100 needs to show the part of the utilities site in the Broads. The preceding text talks about looking at the area as a whole, yet misses the bit of the Utilities Site that is in the Broads.
• Policy 7.1, page 105, there needs to be some acknowledgement in this policy, even if it is a footnote, to say that part of the Utilities site is in the Broads and that the entire area is being considered together, regardless of local planning authority administration boundaries.
• Para 205 – ‘The strategic approach to heritage is first to consider the potential location of development, for example does the location itself “fit” well in relation to adjoining settlements’. We are not entirely clear what this means. Does it mean that new development should relate well to its historic context?
• Para 205 - goes on to state that development should avoid intruding into important views of historic assets. Historic England guidance on the Setting of Historic assets (The Setting of Heritage Assets (historicengland.org.uk)) and numerous appeal decisions make clear that the setting of a heritage asset is much greater than views and it is the setting of heritage assets that need to be considered not specific views.
• Para 205 - Also ‘historic assets’ is used – should the term be heritage assets to ensure it correlates with the terminology defined in the NPPF?
• Para 207 – should this state ‘public benefits’ not just benefits?
• Para 207 – This paragraph recognises that in certain circumstances a balance will need to be struck between development and protection and this recognition is useful. It might be helpful if this section was weighted more towards protection of the historic environment, taking a precautionary approach. The NPPF states that substantial harm to grade II listed HAs should be exceptional and to SAMs or grade II* / grade I HAS should be wholly exceptional (para 194). Equally para 195 of the NPPF states applications should be refused where a proposal will lead to substantial harm unless there are substantial public benefits that outweigh that loss or all of 4 tests can be met.
The reason for the following is not explained and is different to the NPPF. Depending on what is meant, it could affect the setting of the Broads. We would welcome some explanation around the wording used and also its justification.
• Policy 7.4, page 117 seems to imply that rural exception sites or entry level exception sites can be ‘well related’ to settlement boundaries. The NPPF says that such sites should be adjacent. Why is this approach being changed? It does not seem to be explained anywhere in the document. What is well related as well? How far from a settlement boundary can a development be? Depending on what is meant, this could affect the setting of the Broads and we may strengthen the status of our comment later in the examination process. Perhaps of relevance are the changes to the NPPF that are proposed to the current paragraph 172, proposed paragraph 175: ‘The scale and extent of development within these designated areas should be limited, while any development within their settings should be sensitively located and designed to avoid adverse impacts on the designated landscapes’.
The following points are not soundness issues, but the plan could easily be amended to include them. It seems logical to address these comments as additional modifications. They provide clarity and context and further useful information.
• Policy 2, bullet 5 – would welcome, perhaps in a footnote, reference to the landscape character assessment for the Broads, so it is clear that our LCA might be of relevance as well.
• Policy 7.1, page 106, last bullet point – you might want to have a footnote that refers to the local plan for the Broads and our policies on navigation.
Minor comments
Minor points for you to consider. These could aid clarity. They could be additional modifications.
• 10.3 – should this also refer to off shore wind’s on-shore infrastructure?
Typo and grammatical errors
Typos and grammatical errors for you to consider
• Page 105: Development of sites allocated in the East Norwich strategic regeneration area identified on the Key Diagram and defined on map 9 including Carrow Works, the Deal Ground and the Utilities Site will create a highly sustainable mixed-use gateway quarter accommodating substantial housing growth and optimising economic benefits. Development across the sites will provide in the region of 4,000 additional homes in the plan period and significant new employment opportunities for around 6,000 jobs. East Norwich also has the potential to act as a long-term catalyst for regeneration of the wider area, potentially including the following sites if they become available:
• Page 106: • creating an inclusive, resilient and safe community in which people of all ages have good access to high quality homes that meet housing needs, the provision of area-wide economic and social infrastructure and services, including (but not limited to) the creation of new employment opportunities, a new local centre, and a new primary school should need to be established’.
Comments on the sites document
The following points are quite important, but are not soundness issues. They do not affect the soundness of the Local Plan. They can however be easily added to the Local Plan to provide context. Other comments would aid clarity. These comments could be addressed as additional modifications.
• Throughout the various parts - as this is a planning document, no need to say ‘National Park’. Just say ‘the Broads’. There are many occurrences, so perhaps search for the term.
• It would be useful if all of the site allocation plans had street names on – the required standard for most planning applications is at least two street names.
• We note there is no mention of dark skies or limiting light pollution in the policies. The Broads has intrinsically dark skies, as can be seen at this map. We therefore recommend that wording could be added.
Norwich sites
The following comments are factual, observations, seek clarity, seek consistency or are typographical or grammatical. They are not soundness issues, but the comments could be addressed as additional modifications.

Observation:
As a matter of consistency. We note that para 2.198 says this ‘Given the site’s highly accessible location and the intention to provide new public transport links it is considered suitable to include car-free housing. In any event car parking levels should be kept low’. We note that other sites may say that the site is considered suitable for car free housing, but the wording in those instances does not go on to talk about the last part – car parking levels should be kept low. You may want to check to see if this wording is needed for other allocations.

0360/3053/R10
Main points
• Map page 15, this needs to show the part of the utilities site that is in the Broads. This does not affect the soundness of the Local Plan. It could, however, be easily added to the Local Plan to provide context, especially given the stance in the Plan that the sites in East Norwich are seen as one, including the part in the Broads.
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor points
• Page 12, point 6 of policy. Typographical/grammatical error: ‘heritage assets affected by the proposal on and off site including key views from and into the site’.
• Page 12, point 8 of policy – something to consider. You may wish consider biodiversity on this brownfield land that may establish or has been established over the years. Open mosaic habitat of intrinsic biodiversity value is a NERC Act habitat. Brownfield sites are listed as a Priority Habitat in Section 41 of the Natural Environment and Rural Communities Act 2006 (NERC Act), as ‘open mosaic habitat on previously developed land’. For more information go here www.buglife.org.uk/sites/default/files/Identifying%20open%20mosaic%20habitat.pdf and here jncc.defra.gov.uk/pdf/UKBAP_BAPHabitats-40-OMH-2010.pdf
0068
Main points
• As part of point 1, refer to the scheme making the most of its riverside location, as is stated in other policies. This is a matter of consistency. 0401 and GNLP0409AR for example have good wording in point 1 that can be used. It is not clear why this wording is in most, if not all other river side policies and not this one. This may simply be a drafting error. This would make the plan consistent.
• 2.30 – support the fact that early engagement with us is recommended, but not clear why the only reason is flood risk. Or does that part of the sentence only refer to AWS? It may need clarifying that in general, given its location, early engagement with the Broads Authority is recommended, rather than just saying to do with flood risk.
Minor points
• Typographical/grammatical error: ‘Missing full stop:(or if developed for student accommodation, a minimum of 125 student bedrooms). A small element of commercial, office, and/or educational use at ground floor level may also be acceptable’.
0401
Main point
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Typographical/grammatical error: 2.51: ‘The site is likely to accommodate at least 100 homes, or if the site is developed to include student accommodation (at least 250 bedrooms)’. Suggest removing brackets as the sentence is not really reading well or right as drafted.
Cc4b
Main point
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Typographical/grammatical error: 2.121: ‘Development of site CC4a should explore continued use/re-provision of the existing community garden facility’.
Cc7
Main point:
• 2.131: the trees seem to be in the Conservation Area and so have some protection. You might want to refer to that.

CC16
Main point
• 2.203 – we request that this is worded like 2.134 as follows: ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. At the moment, what is worded only refers to the EA. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Does not mention about making most of riverside location in supporting text like other policies. The actual policy does. You may wish to add something to the supporting text to be consistent.
Urban fringe
The following comment is factual. It is not a soundness issue, but it seems logical to address these comments as additional modifications.
Factual update
• Para 3.75 – last sentence, amend as follows ‘the Church of St Andrew and its ruins’ – as both the church and ruins are listed.
Key service centres
The following comment seeks to improve context. It is not a soundness issue, but it seems logical to address these comments as additional modifications.
Main point:
• GNLP0378R/GNLP2139R, GNLP0312 and para 5.42 – please also mention dark skies of the Broads. The Broads has intrinsically dark skies. You mention the setting of the Broads, which is welcomed, but please add reference to protecting the dark skies of the Broads.
Broadland villages
The following comments are factual, observations, seek clarity, seek consistency. They are not soundness issues, but it seems logical to address these comments as additional modifications.
Main points:
• Cantley map, page 15 – show the Broads for consistency and to show the context.
• Horstead and Coltishall map, page 25 – show the Broads for consistency and to show the context.
• GNLP1001 – please also mention dark skies of the Broads. The Broads has intrinsically dark skies. You mention the setting of the Broads, which is welcomed, but please add reference to protecting the dark skies of the Broads.
• Coltishall, Horstead and Belaugh – should the Conservation Areas that covers parts of all three of these villages be mentioned in the text?
• Salhouse – again should the Conservation Area be mentioned – potential for limited impact on the wider setting of the CA at the site allocated in Salhouse.

Additional explanation is required as to what the Council believes a 'delivery plan' to be and that definition needs to reflect that some applicants are not the actual provider of new dwellings and therefore cannot specify delivery dates or programmes.

Although we support the broad aims of this policy we object to Item iii.
Item iii states that ‘delivery plans are required with planning applications for 100 dwellings plus ….’. It is far from clear what is meant by a ‘delivery plan’ and the requirement ignores the fact that planning applications are sometimes promoted by individuals, landowners, institutions, charities or promotional companies rather than housebuilders. Such applicants sell their land on to housebuilders following the granting of permission and therefore have no control over the precise timing or actual delivery of development and no knowledge of that at the point of making a planning application. While a sequence of events can be defined, actual delivery dates will not be known in these circumstances. The policy wording needs to be reviewed in the light of these circumstances.

Policy 2 identifies some key principles to ensure the delivery of high quality development, and refers to accessibility, the efficient use of land, the delivery of green infrastructure, impacts on the environment including landscape and heritage, and the delivery of low carbon and resource efficient buildings. These principles are supported.
Mrs Janet Skidmore is promoting an additional allocation or contingency site at land south of Gonville Hall Farm in Wymondham (Site Ref. GNLP0320). The promoted development at this site would meet all of the key design principles set out in Policy 2. There are no constraints to development at this site. A number of site specific technical reports have been prepared for the promoted development including the following: Concept Masterplan; Heritage Desk Based Assessment; Preliminary Ecological Appraisal; Landscape & Visual Overview; Flood Risk & Drainage Appraisal; and Access and Movement Strategy.
The promoted development would also include a new vehicular access on to London Road, and no concerns are anticipated about highway safety or the function of the highway network. The site is accessible by walking and cycling, there are bus services on London Road and Wymondham Railway Station is reasonably accessible. The promoted development could enhance the walking and cycling network on London Road, support improvements to the existing bus services, and provide a new cycle route through the site. The promoted development would include new parkland areas, green corridors and green infrastructure to provide open space and wildlife habitats. The layout of the promoted development includes a buffer around Gonville Hall and the heritage setting corridors within the site remain free of built development. The site is not at risk of flooding, and the promoted development includes sustainable drainage basins to manage surface water. In addition, the promoted development would meet all design, low carbon, resource efficiency and water conservation standards.
No specific modifications are required to Policy 2.

No specific modifications are required to Policy 2. However, it is requested that modifications are made to the allocations in Marsham to ensure consistency with Policy 2 in terms of protecting landscape and heritage assets i.e. that Site Allocation GNLP2143: Land south of Le Neve Road in Marsham is deleted and land at Fengate Farm (Site Ref. GNLP3035) is identified as an alternative allocation for residential development.

Policy 2 identifies some key principles to ensure the delivery of high quality development, and refers to accessibility, the efficient use of land, the delivery of green infrastructure, impacts on the environment including landscape and heritage, and the delivery of low carbon and resource efficient buildings. These principles are supported.
However, it is considered that high quality development would not be delivered at Marsham, and in accordance with Policy 2, because of the proposed allocation at GNLP2143: Land south of Le Neve Road in Marsham on the basis that development in this location would have a significant impact on heritage assets and landscape character. The Noble Foods Ltd representation to Site Allocation GNLP2143 is accompanied by a heritage report and landscape appraisal. In summary, it is concluded in the heritage report that development at land south of Le Neve Road would adversely impact the setting and landmark qualities of the church tower at All Saints Church (Grade I Listed Building), and that even with landscape mitigation measures the proposed development would be perceived in key views of the church. It is concluded in the landscape appraisal that development at the site would have an unacceptable impact on the character and appearance of the open land that currently forms part of the setting of the village and the church, and it is unlikely that landscape mitigation would address the visual harm. Therefore, it is considered that the decision to allocate land south of Le Neve Road in Marsham for residential development would not comply with the requirements in Policy 2 for development to protect, preserve and enhance the landscape and historic environment.
Noble Foods Ltd is promoting an alternative site for a residential allocation in Marsham, at Fengate Farm (Site Ref. GNLP3035). The Fengate Farm site contains vacant and unused buildings and areas of hardstanding associated with a former poultry unit. The site is visible from the High Street and neighbouring properties. It would substantially enhance the townscape of Marsham if the fire damaged buildings at Fengate Farm were removed and replaced by residential development. There are no significant heritage, landscape, or ecological constraints to development at the Fengate Farm site. The transport and access assessment of the Fengate Farm site demonstrates that suitable vehicular and pedestrian accesses are available to support the proposed development, and that a safe and convenient walking route is available from the site to the primary school that avoid the High Street. In addition, the promoted development at Fengate Farm would meet design, low carbon, and resource efficiency standards. It is considered that the promoted development at Fengate Farm would be compliant with Policy 2, unlike the proposed allocation at land south of Le Neve Road.

Policy 2 identifies some key principles to ensure the delivery of high quality development, and refers to accessibility, the efficient use of land, the delivery of green infrastructure, impacts on the environment, and the delivery of low carbon and resource efficient buildings. These principles are supported.
A planning application has been submitted for the proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172). The proposed allocation, as promoted by Taylor Wimpey, would be consistent with the key principles for high quality development. The proposed allocation is accessible to the services and facilities and employment sites in Rackheath by sustainable modes of transport. The site area and quantum of development at the proposed allocation would deliver a suitable density of development, which is consistent with the characteristics of the site and surrounding area and would achieve an efficient use of land. The proposed allocation includes open space and areas of heathland on the western side of the Norwich Northern Distributor Road, in order to provide new green infrastructure for the area and to provide a habitat for protected species. The proposed development will be designed to meet low carbon, resource efficiency and water conservation standards. Therefore, it is considered that the proposed allocation at Site Ref. GNLP0172 would achieve the key principles of high quality development as identified in Policy 2.
No modifications are required to Policy 2.

Recommendation
16. We suggest that the requirement for EVCPs should not be included in the local plan because the Government’s proposed changes to Building Regulations will provide a more effective framework for the delivery of charging points for electric vehicles.

For full submission view attachment.

We are finding this policy sound but would raise the following comments on green infrastructure:

Green infrastructure is not always bio diverse and the plan has not mapped the habitats (just core areas in the GI study) or linked to the relevant partnerships (174). Green Infrastructure can vary in quality. For example, farming and playing fields would be of lower environmental quality than other forms. The plan should encourage multifunctional bio diverse green infrastructure links.

It is therefore suggested that point 9 of Policy 2 be amended to be effective and justified as follows:
‘Minimise flood risk, including Support [efficient] [text to be deleted] [integrated] [new word] water management. Flood risk should be minimised, including avoiding inappropriate development in areas at significant risk of flooding, reducing the causes and impacts of flooding, supporting a catchment approach to water management and using sustainable [drainage systems as part of all development proposals.] [new text] Development must also protect water quality, both surface and groundwater, and be water efficient [and make use of water-reuse measures wherever feasible.] [new text] To achieve the latter:

It is therefore suggested that point iv of Policy 2 be amended to be effective as follows:
‘Potential applicants for planning permission for major developments are advised to contact Anglian Water Services in the early stages of producing a development scheme in order to ensure that there is adequate capacity, or capacity can be made available, in the [wastewater] [word to be deleted] [sewerage] [new word] network [and at the receiving water recycling centre.] [new text]The provision of capacity could affect the timing of development. In locations where there are known to be capacity issues the local authority will expect this engagement to have taken place and for it to be demonstrated that adequate capacity will be available to serve the development (see Appendix 1 Infrastructure Requirements for currently known locations with capacity issues)’

Point 9: Policy 2 refers to residential developments being required to mininise water consumption by meeting the optional requirement of 110 litres/per person/per day.

Anglian Water, the Environment Agency and Natural England has issued advice to local planning authorities (copy attached) stating that there is evidence to demonstrate a need for optional water efficiency standard to be applied in the Anglian Water supply area. As such we fully support the inclusion of this standard in the policy.

We fully support the intention that development proposals will be expected to meet the current standard water efficiency rather than be limited to the existing standard. This is particularly important given Defra’s recent consultation on personal consumption of water which included reference to potential changes to existing building regulations on water efficiency.

Anglian Water is keen to promote the development of ‘Water smart communities’ including as part of the Local Plan. They use a more holistic and integrated approach to water management with the aim to:

• Enhance liveability by contributing to green streetspaces and high quality open space
• Promote the sustainable use of water resources and infrastructure to enable growth
• Build resilience against the impacts of climate change and extreme weather events
• Contribute to natural capital and biodiversity through multi functional water features
• Deliver water efficient homes to reduce household bills and support affordability

Opportunities for a more holistic and integrated approach to water management should form part of the plan, to encourage multi-functional water management assets which support other community objectives. This approach combines different elements of water management (e.g. combining SuDS with a water re-use system to both manage runoff and provide an alternative non-potable water supply) together with town planning and design (e.g. integrating the planted SuDS features throughout a development to contribute to ‘greener’ streetscapes). This would also be consistent with the justification given for provided for the requirements relating to water use which reference greywater recycling and rainwater capture (Table 8 of the plan).
We note that Policy 2 has been amended following the previous consultation but that our suggested changes relating to integrated water management including the use of SuDs (as the preferred method of surface water management) and water re-use measures is not included.

Point iv: in our previous comments we had also sought the inclusion of reference to foul drainage and sewage treatment which appeared in an earlier version of Local Plan (as part of Policy FR1). We are generally supportive of the wording as proposed but would make the point that the term ‘wastewater network’ is not defined and Appendix 1 refers to water recycling centres as well as the wastewater (sewerage) network .

In policy 2, criteria (i) of this policy should include reference to the specific objective 'to create and maintain a safer community and reduce crime and disorder'.

Norfolk Constabulary have the responsibility for policing making Norfolk a safe place where people want to live, work, travel and invest in.

Central Government place great emphasis on the role of the Police. Furthermore, National Planning Policy Framework (NPPF) gives significant weight to promoting safe communities (in section 8 of the NPPF). This is highlighted by the provision of paragraph 91, which states

'Planning policies and decisions should aim to achieve healthy, inclusive and safe places which ...

b) are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion'....

Therefore the inclusion within criteria 1, 6 and 7 of the importance of creating safe, inclusive, resilient communities is welcomed.

Within the policy however, specific reference should be made to require developers of major developments (of 500+ dwellings) to detail the measures that will be taken to deliver safe, resilient and inclusive communities including how they will fund the necessary infra-structure. Therefore, criteria (i) of this policy should include reference to the specific objective to create and maintain a safer community and reduce crime and disorder.

Norfolk Constabulary support the proposed Table 8 - Key issues addressed by Policy 2 (Issue 7) for the establishment and maintenance of resilient, safe and inclusive communities and also (Issue 1) to provide convenient, safe and sustainable access to facilities.

Norfolk Constabulary would support Local Plan policy and text that included reference to the principles of Secure By Design (SBD) (the police initiative which promotes the adoption of crime prevention measures) to improve the security of buildings and their immediate surroundings to provide safe places to live, as in line with Government directive . Both the National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG) set out guidance in creating safe and accessible communities and attention is highlighted to section 8 of the NPPF. This recommends that local planning authorities ensure their policies and decisions aim to create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion (paragraph 91). NPPF paragraph 164 advises that when preparing their Local Plan, local authorities should work with local advisors and others to ensure that they have taken into account the most up-to-date information about higher risk sites in their area for malicious threats and natural hazards, including steps that can be taken to reduce vulnerability and increase resilience. The Design section of the PPG includes crime prevention and security measures.

Further provisions that focus on these issues would be welcome to ensure conformity with the NPPF and secure soundness to the Plan.

Whilst paragraph 10 of policy 2 above is a good start, it could go much further to reduce carbon emissions from new development. We acknowledge that the planning White Paper proposes and Future Homes Standard proposes interim standards to be introduced in 2020 and stronger regulations which would come into force in 2025, requiring an 80% improvement over building regulations. We’re concerned that these proposed regulations will be weaker than policies already in place in some local authorities, would permit development to be built with lower fabric standards than the existing 2013 building regulations. Additionally the 2025 standards will not result in new development being fully de-carbonised, assuming instead that the remaining carbon emission reduction will be delivered by the de-carbonisation of grid electricity. There is no guarantee that electricity from the national grid will be fully decarbonised, or the period over which this will happen.

We would also point out that the future Homes Consultation11 proposes requiring interim carbon emission reductions of 31% beyond existing building regulations from 2020. This should be the baseline for policy formation.

We would encourage you to go further therefore and toughen your policy stance to require new development to be net zero carbon. The most ambitious and all-encompassing zero carbon policy of which we are aware is that from the draft London Plan, which has now gone through examination without major amendments.

View attachment for Example.

We strongly welcome the reference to maximising the use of “local energy networks and battery storage” however the policy is not clear how this statement relates to new developments, other than standalone projects. The wording should be clarified to be clearer whether and how new developments (for example significant housing developments) are expected to incorporate these technologies. The inclusion of battery storage within significant new housing and mixed use developments would be very helpful in alleviating constraints in the electricity distribution grid and enabling greater utilisation of renewably generated electricity.

See attachment 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.

Amend criterion 5 of policy 2 to read,

…taking account of landscape or historic character assessments including conservation area appraisals, design guides and codes

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

To make the Local Plan sound, criterion 4 of Policy 2 - Sustainable Communities should be revised as follows:


Make efficient use of land with densities dependent on site characteristics and scheme specific considerations, with higher densities and car free housing in the most sustainably accessible locations in Norwich. Indicative minimum net densities are 25 dwellings per hectare across the plan area and 40 in Norwich.

Submitted by Bidwells on behalf of Scott Properties.

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change is supported.

To demonstrate the ability to secure these objectives, we support the preparation of a Sustainability Statement as part of an application for a major development, and, where applicable, the provision of Delivery Statements.

However, whilst principle of the policy is considered sound, amendments are required to the detailed wording of the policy to ensure that, in accordance with the tests set out in paragraph 35 of the NPPF, it is sound. Therefore, minor alterations to Policy GNLP0132 are therefore sought, to ensure its soundness.

The requirement to ensure the efficient use of land by, amongst other things, providing an indicative minimum density of 25 dwellings per hectare is supported, however, the policy should make it clear that, as well as giving consideration to on site characteristics, consideration will be given to a range of other site / scheme specific issues, such as housing mix and design considerations? For example, the inclusion of bungalows within a development to meet an identified need is likely to result in a lower density development.

On this basis, it is considered that, as drafted, the policy is neither positively prepared or justified given that it falls to provide flexibility to enable the policy to respond to changing circumstances and meet identified need.

Submitted by Bidwells on behalf of Abel Homes.

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change is supported.

To demonstrate the ability to secure these objectives, we support the preparation of a Sustainability Statement as part of an application for a major development, and, if applicable, the provision of a Delivery Statement

Modify the plan to ensure that it is clear that the Key Issues do not work in isolation of each other and it will be important in decision making to ensure that any effect arising from one key issue is also cross referenced in any effect on one of more other Key Issue.

Please find representations on behalf of the Rackheath Hall Gardens Management Company Ltd in respect of the Reg 19 Local Plan.

SEE ENCLOSED NOTE 2

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).

1.16 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

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

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.

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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.

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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

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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

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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.

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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)

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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

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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

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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.

Please see attached letter

In summary: The requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations should be supported by evidence.

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.

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation. See section 4.3 for comments regarding Policy 2

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

See attachment for full representation

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.

Remove reference to the proposed requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations as it does not appear to be justified by the evidence base.

Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).

Representation submitted in relation to site GNLP3024 at Sprowston by Le Ronde Wright on behalf of Trustees

Policy 2
This policy addresses a number of key issues including the need for among other things, sustainable access to on-site services and facilities reducing the need to travel. The policy appears to be sound.

Policy 6

The policy states that small scale retail and leisure developments serving local needs are encouraged to serve new residential developments in existing residential areas promoting active travel. It discusses the importance of providing choice retaining and allocating smaller scale employment sites. The policy appears to be sound.

Policy 7.1

The policy states among other things, that elsewhere in the fringe parishes a range of sites will be provided for different types of employment and community uses and promote walking and cycling. This policy appears to be sound.

Although individually, the above policies appear be sound the overall Plan is not effective without allocations of smaller employment sites in key locations to address the impact of housing growth. Site GNLP3024 is a key allocation to be provided at Sprowston. The Plan would be unsound without it. In addition, a review of the settlement boundary of the town is necessary as it is incorrect as shown on the map regarding Sprowston.

Proposed Allocation GNLP3024

This proposed allocation of this business and community hub adjacent to allocation GNLP0132 would secure essential social and community infrastructure in close proximity to the new and existing homes in the locality, and better facilitate Sprowston's future planned growth and expansion. The SoCG (copy enclosed for ease of reference) and previous representations outline the mix of uses intended. There is extant planning consent for a mix of commercial and community uses. However, further flexibility is sought to complement the neighbouring developments. The allocation of this site would help to secure its future viability and deliverability and provide much needed extended services and amenities to serve the local growing population.

The evidence base needs to be brought up-to-date.

At Sprowston, a new site needs to be identified to provide a LEAP and more accessible public open space in the form of a local park and garden.

Proposed policies should actively support developments that would link existing areas of green infrastructure (GI) and require the provision of POS and GI where possible to link and interconnect with existing provision nearby. Additionally, it is considered that proposed allocations should set an exemplary way forward, aligning the policies for future developments to achieve this. As such, allocations should be promoted that contribute to the creation of new links between existing GI and contribute to an area-wide green infrastructure network. For example, the land at the Sprowston Sports and Social Club, surrounded by allocation GT5 in the Growth Triangle Area Action Plan would see the linking of an existing natural woodland, with a new proposed community park and garden, which could then link into the new playing fields/skate park being proposed in the south western edge of GT5. Such a proposal would exemplify the policy aspirations of linking existing Green Infrastructure into a more local network, whilst also providing new, much needed POS as highlighted by the Open Space Assessment for Sprowston.

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.

In preparing the submission version of the plan, we urge you to address fully all of the above issues, as well as those raised at the Regulation 18 stage, to ensure that the plan complies with the applicable statutory and policy requirements.

We regret that none of the issues raised in our response to the Regulation 18 consultation appears to have been addressed in the updated version of the plan. We therefore repeat our previous representations regarding non-compliance with section 19(1A) of the Planning and Compulsory Purchase Act 2004, with the SEA regulations including related requirements, and inconsistency with the NPPF, which we now supplement and update in respect o certain issues.

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.

Please clarify in the text which strategy is being referred to.



We recommend that the wording of point (3) of the policy needs to be amended as follows (or a similar form of wording used):

"3. Contribute to multi-functional green infrastructure links, including through landscaping, to make best use of site characteristics and integrate into the surroundings, having regard to relevant green infrastructure strategies and delivery plans, and in line with Policy 3."

The current policy states:

"Development must be high quality, contributing to delivering inclusive growth in mixed, resilient and sustainable communities, to enhancing the environment, and to mitigating and adapting to climate change, assisting in meeting national greenhouse gas emissions targets. To achieve this, development proposals are required, as appropriate, to:

3. Contribute to multi-functional green infrastructure links, including through landscaping, to make best use of site characteristics and integrate into the surroundings, having regard to relevant green infrastructure strategies and delivery plans; "

It is unclear what are the 'relevant green infrastructure strategies and delivery plans' and the policy should also 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.

Remove reference to the proposed requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations as it does not appear to be justified by the evidence base.

Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).

Please see the section addressing Policy 2 in the attached representations submitted 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 .