Policy 5 Homes

Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.

The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.

There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.

Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.

The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.

There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.

Either:

Delete the following:

"..... Irrespective of C2 or C3 use class classification, specialist older people’s housing will provide 33% affordable housing or 28% in the city centre."

or amend to include brackets:

"...Irrespective of C2 or C3 use class classification, specialist older people’s housing (excluding residential/nursing homes) will provide 33% affordable housing or 28% in the city centre."

The policy confirms that 'major residential developments' defined as over 10 dwellings will require affordable housing. However, the wording relating to care homes and extra care suggests this requirement will also apply to these uses. The Viability Report (2020) is clear that no account has been taken of care homes, nor extra care, in determining the viability of affordable housing. On this basis the last sentence should be deleted as it is not evidence based. If the case is made for extra care subsequently, the policy must still state it is not required for care homes. Unsound without this amendment.

Justification to be included and wording tidied up.

Although we support the idea of an element of self-build plots we object to the detail set out in Policy 5.
Firstly, we are unsure as to the basis of the stated threshold of 40 dwelling developments and request that the Plan provides a clear justification for this level.
Secondly, the wording seems confused. The policy objective is to secure, via applications, a proportion of self/custom build plots within planning permissions. The second bullet point refers to such plots not being sold after being marketed for 12 months. That situation is applicable when a developer seeks to change an existing permission (conditions or S106) and so it is not relevant to the policy aim (i.e. applications) and should be reworded.

Policy 5 deals with affordable housing and specifies that 33% of housing should be affordable from major residential sites. The affordable housing requirements are supported. It should be noted that the development currently under construction to the north of Gonville Hall Farm is delivering policy compliant levels of affordable housing. The promoted development at land south of Gonville Hall Farm in Wymondham (Site Ref. GNLP0320), would provide policy compliant levels of affordable housing if identified as an alternative allocation or contingency site if identified as an alternative allocation in Draft GNLP. The infill developments and small scale developments at villages are likely to fall below the threshold for providing affordable housing. A reduced level of affordable housing contribution is required from developments in Norwich. The most recent monitoring data demonstrates that there has been a shortfall in the delivery of affordable housing. In these circumstances, all opportunities should be taken to increase the delivery of affordable housing by identify suitable additional allocations and an additional contingency site, including at land south of Gonville Hall Farm in Wymondham (Site Ref. GNLP0320).

The draft plan states that an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as, inter alia, care homes (275, GNLP). Consequently, the draft plan makes a specific allocation for specialised housing for older people and site allocations with an element of specialist housing. This means that the plan should support the redevelopment of vacant or unviable care homes to other uses. We therefore propose amendments to draft policy 5, so that where existing older people's accommodation and others with support needs is either unviable, vacant or it does not have good access to local services then redevelopment to residential will be supported. Amended draft policy 5 below:

“Development proposals providing specialist housing options for older people’s accommodation and others with support needs, including sheltered housing, supported housing, extra care housing and residential/nursing care homes will be supported on sites with good access to local services including on sites allocated for residential use. Should it be demonstrated that existing older people's accommodation and others with support needs is either unviable, vacant or it does not have good access to local services then redevelopment to residential will be supported in principle. Irrespective of C2 or C3 use class classification, specialist older people’s housing will provide 33% affordable housing or 28% in the city.”

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

Policy 5 deals with affordable housing and specifies that 33% of housing should be affordable from major residential sites. The affordable housing requirements are supported. The promoted development at land at Fengate Farm in Marsham (Site Ref. GNLP3035) would provide policy compliant levels of affordable housing if it is identified as an alternative allocation in Draft GNLP. As set out in the representations to Policy 7.4: Village Clusters and Policy 7.5: Small Scale Windfall Housing Development, the policy approach of limited infill sites and small scale development sites only at villages is likely to fall below the threshold where affordable housing is required and means that none will be delivered at the smaller villages. No changes to Policy 5 are required.

Policy 5 deals with affordable housing and specifies that 33% of housing should be affordable from major residential sites. The affordable housing requirements are supported.
The latest published Annual Monitoring Report (January 2020) includes data on the delivery of affordable housing. The affordable housing completions data shows that delivery is below targets in both percentage and absolute terms overall, and across Greater Norwich there is a shortfall in the delivery of affordable housing of 449 dwellings. Paragraph 3.26 in the AMR notes some of the challenges of delivering affordable housing, including that affordable housing is not required from non-major developments and the redevelopment of vacant buildings or prior approval of office buildings, and it also notes that viability is an issue for some sites. Therefore, sites that are capable of delivering policy compliant levels of affordable housing need to be identified in Draft GNLP, to address the current shortfall in the delivery of affordable housing and to
As set out in the planning application for the proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) this development would deliver 33% affordable housing, which equates to 68 affordable dwellings. The fact that the proposed development would deliver affordable housing supports the decision to allocate this site in Draft GNLP.
No modifications are requested to Policy 5.

Recommendation
31. The Council should:
• Reduce the affordable housing requirement to reflect the evidence on the need for such homes;
• Without the required evidence the requirement for development to meet national described space standards must be deleted; and
• The requirement for 5% of homes on sites of 40 or more dwellings to be allocated to self-build or custom housebuilding should be deleted.

For full submission view attachment.

Please see the section addressing Policy 5 in the attached representations submitted on behalf of R Mason in support of the allocation of Land at Rightup Lane, Wymondham

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

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

Please see the separate sheet appended to this representation.

The policy’s objective of encouraging the delivery of Purpose-Built Student Accommodation (PBSA) to support the growth of the University is, in principle, supported.

Away from the UEA campus, the draft policy states that proposals for PBSA will be supported where the need for the development is justified by the current or proposed size of Norwich’s higher education institutions, and the proposals will adhere to a range of criterion.

One of these criterion requires off-campus PBSA to make provision for a policy-compliant proportion of affordable housing that would be expected if the site were developed for general needs housing.

This element of the policy is considered unsound, as PBSA should not be expected to contribute towards affordable housing provision. Paragraph 64 of the NPPF specifies that, where the provision of housing is proposed, at least 10% of the homes should be made available for affordable home ownership. Paragraph 64(b) of the NPPF states that PBSA is exempt from this 10% requirement.

On this basis, to ensure that the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to recognise that PBSA should not be expected to contribute towards affordable housing provision.

Affordable Housing

The policy should be revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.

Space Standards
In the apparent absence of the necessary robust evidence to justify it, the policy should, if this element is to be retained, provide some flexibility to recognise need and viability, where necessary.


The policy should clarify the type of specialist housing that will be required to provide affordable housing, as well as a definition of what is affordable care.

Self and Custom Build

The threshold should be increased, to better reflect the likely need. Clarity on the definition of self/custom build should be provided in the policy or supporting text.

Submitted by Bidwells on behalf of Scott Properties.

The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an aging population is also supported. However, there are a number of elements of the Policy that require alteration to ensure soundness.

Affordable Housing

As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.

On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.

Space Standards

Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.

This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms. At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.

Accordingly, we would suggest that if this element of the policy is to be retained that , as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.

Whilst the principal of specialist housing is generally supported, clarity is required on what type of specialist housing will be required to provide affordable housing. More specifically, it is not considered that residential and nursing care homes constitute dwellings that generate a requirement for affordable housing provision. In addition, it is considered that the policy should provide a definition as to what is affordable care. Without this information, the policy is not considered to be effective.

Self & Custom Build

The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.

The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own, deliver substantially more than the identified need.

Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is reduced to a level which better reflects need.

In addition, to provide clarity the policy, or supporting text, should provide further evidence on what is classified as a self / custom build unit. For example, if a developer provides a potential purchaser with a degree of choice in relation to the layout and design of their unit, such as the reconfiguration of layouts to suit individual requirements, or the provision of foundations, pipework to facilitate an extension at a later date, does this constitute a Custom Build unit for the purposes of the policy?

On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.

Affordable Housing

The policy should be revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.


Space Standards

In the apparent absence of the necessary robust evidence to justify it, the policy should, if this element is to be retained, provide some flexibility to recognise need and viability, where necessary.


Self and Custom Build

The threshold for on-site provision should be increased to better reflect the demonstrable need. Clarity on the definition of self/custom build should be provided in the policy or supporting text.

Submitted by Bidwells on behalf of Abel Homes

The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an aging population is also supported.

Affordble Housing

As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.

On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.


Space Standards

Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.

This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms. At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.

Accordingly, we would suggest that if this element of the policy is to be retained that , as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.

Self & Custom Build

The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.

The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own deliver substantially more than the identified need.

Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is reduced to a level which better reflects current demonstrable need.

In addition, to provide clarity the policy, or supporting text, should provide further evidence on what is classified as a self / custom build unit. For example, if a developer provides a potential purchaser with a degree of choice in relation to the layout and design of their unit, such as the reconfiguration of layouts to suit individual requirements, or the provision of foundations, pipework to facilitate an extension at a later date, does this constitute a Custom Build unit for the purposes of the policy?

On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.

Please see the sections addressing Procedural Issues and Policy 5 in the attached representations submitted on behalf of the Trustees of the WJ Gowing 1985 Settlement and the Trustees of the Howard Trust and Pigeon Capital Management 2 in support of the allocation of Land north of Brecklands Road, Brundall.

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

Please see the section addressing Policy 5 in the attached representations submitted on behalf of Michael and Jackie Buxton and Pigeon Capital Management 2 Ltd in support of the allocation of Land at Dereham Road, Reepham.

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

Please see enclosed letter for details of representations.

Please find attached representations to the GNLP Reg 19 Consultation on behalf of Frontier Agriculture Ltd.

Modify the plan to include the additional topic references above.

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

SEE ENCLOSED NOTE 5

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).

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

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

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

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

SECTION 5 – THE STRATEGY

THE SETTLEMENT HIERARCHY

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

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

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

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






POLICY 1 - THE SUSTAINABLE GROWTH STRATEGY


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

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



POLICY 5 – HOMES


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

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




POLICY 7.3 – THE KEY SERVICE CENTRES


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

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

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

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

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

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



POLICY 7.4 - VILLAGE CLUSTERS


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

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.

1. INTRODUCTION

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

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

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

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

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

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

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

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

Barratt David Wilson Homes

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

Policy 1 - The Sustainable Growth Strategy – Comment

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

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

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

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

Barratt David Wilson Homes

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

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

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

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

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

Representation to the Greater Norwich Local Plan Barratt David Wilson Homes

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

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

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

Recommendation

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

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

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

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

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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.

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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.

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

Policy 1- the Sustainable Growth Strategy

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

Housing requirement

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

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

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

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

The minimum housing need

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

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

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

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


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

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

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

Historic under-delivery

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

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

POLICY 5 – HOMES

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


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

POLICY 7.3 – KEY SERVICE CENTRES

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

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

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

Highways Impact

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

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


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

Landscape Visual impact

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

Flood Risk impact

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

Sustainability

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


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

Other Issues

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

Conclusion

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

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

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

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

Greater Norwich Local Plan Reg 19 Draft Plan Consultation

Land at Dairy Farm, Thorpe End

INTRODUCTION

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

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

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

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

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

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

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


POLICY 1- THE SUSTAINABLE GROWTH STRATEGY

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

Housing requirement

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

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

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

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

The minimum housing need

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

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


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


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

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

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

Historic under-delivery

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

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

POLICY 5 – HOMES

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


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

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

POLICY 7.1 – NORWICH URBAN AREA INCLUDING THE FRINGE PARISHES

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

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

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

Accessibility

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


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


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

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


Biodiversity

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

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

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

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

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


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

Please see attached letter

In summary: Evidence and justification should be provided for the proposed 33% requirement as set out in the Pre-Submission Plan; and the reference to ‘at least’ should be clarified.

These representations comprise the following:

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

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

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

Please see attached letter

In summary: The Pre-Submission Plan should demonstrate a 'need' for a policy requirement that development comply with the NDSS, and provide sufficient justification for this.

These representations comprise the following:

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

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

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

Please see the sections addressing Procedural Issues and Policy 5 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 .

Please see the sections addressing Procedural Issues and Policy 5 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land west of Nelson Road, Diss.

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

Please see the section addressing Policy 5 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land at Walcot Green Lane, Diss.

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

Acknowledgement in the Plan of the need for a more diverse, flexible and innovative approach to providing specialist 'retirement' housing is necessary to make the Plan sound, together with a specific identification/allocation of the site for specialist housing, in Part 2 of the Plan.

Representation relating Para 60, 275 and Policy 5

Increase in housing delivery in Wymondham (Main Town) beyond 2026.
Deallocation of Policy GNLP0354R: Land at Johnson's Farm, Wymondham
Allocation of GNLP4023, North of London Road, Wymondham

The Local Plan is unsound as it fails to provide for sufficient growth aspirations beyond 2026 in a Main Town and allocates a site which could result in substantial harm to Grade 1 Listed buildings, when there are better alternatives; including discounted site GNLP4023, North of London Road, Wymondham

Please find a representation attached.

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

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

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.