Policy 6 The Economy

The site owners support the additional wording included within bullet point 1 of Part 2, which states 'the allocation and retention of smaller scale employment sites across the area, with limited expansion where this can be justified' and consider that it provides sufficient flexibility for existing employment sites, such as Abbey Farm Commercial Park, to undertake future limited expansion if required.

Please see the LPP letter dated and submitted 9th March 2021 for full details.

We support the allocation of land at Browick Interchange, Wymondham as a strategic employment location.

Please see the section addressing Policy 6 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 6 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.

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

See attachment.

Please see the section addressing Policy 6 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 .

As noted above, the allocation of additional land at Keswick to the south of KES2 will support the plan in delivering on its employment objectives.

The land identified as GNLP3047 should be included in the plan.

In respect of emerging 'Policy 6 - The Economy' in the Reg 19 plan, it is notable that there is very little new land being allocated within the strategic employment sites with a lot of the older sites ‘rolled over’ into the employment land supply. In combination, KES/GNLP0497 and GNLP3047 would amount to circa 27 hectares of employment land in a sustainable location, with good access to the highway network, but also proximate to Norwich Ccentre (with associated and emerging sustainable transport links). Additionally, site specific infrastructure is coming forward. GNLP3047 provides the opportunity to contribute to delivering the employment objectives of the emerging GNLP and specifically Policy 6, and should be included in the plan.

See supporting letter and previous reps from March 2020 accompanying this form.

See attached letter

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

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

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

Policy 6

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

Policy 7.1

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

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

Proposed Allocation GNLP3024

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

See attachment for suggested modification to policy 6 to include the Ben Burgess site at Swainsthorpe.

4.3 On the basis of the above Ben Burgess contend that land west of Ipswich Road, Swainsthorpe should be allocated within the GNLP as an employment site failure to do so would render the plan unsound.

See attachments for full submission and supporting information.

4 Conclusion

4.1 Ben Burgess contends that as currently drafted the GNLP would fail when considered against the legal requirements and the tests of soundness in accordance with paragraph 35 of the NPPF. Previous representations have been submitted demonstrating that the proposal for a new Ben Burgess headquarters on land west of Ipswich Road, Swainsthorpe is deliverable and would constitute sustainable economic development. In the absence of an allocation in respect of land west of Ipswich Road, Swainsthorpe the GNLP does not explain how, in accordance with paragraph 82 of the NPPF, how the locational requirements of the particular sector within which Ben Burgess operates has been address. Ben Burgess wishes to engage with officers of the GNLP team ahead of the regulation 19 stage of the GNLP to identify reasonable alternatives.

4.2 These representations contend that an examination of the GNLP (Part 1: The Strategy and Part 2: The Sites) and supporting evidence base demonstrate that the GNLP does not fulfil the necessary requirements. The evidence base fails to consider the specific requirements associated with the industry in order to justify the claim “evidence suggests that currently committed land is more than sufficient in quantity and quality to meet the employment growth needs in Greater Norwich”. The decision to designate to development management contradicts the very foundation of a policy led planning system.

4.3 On the basis of the above Ben Burgess contend that land west of Ipswich Road, Swainsthorpe should be allocated within the GNLP as an employment site failure to do so would render the plan unsound.

Policy 6 needs to be adapted to provide a more flexible framework to encourage the sustainable change of use of existing land and businesses affected by the pandemic.
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For example, the site of the Sprowston Sports and Social Club is located in a sustainable location close to new housing allocations where it would be appropriate to provide a mix of publicly accessible open space alongside housing for older people with care and amenities shared with the wider community in line with the ambitions of paragraphs 46 and 47 of the Pre-Submission Draft Strategy.

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

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

Furthermore, the greater Norwich local plan allocates only 54.2 hectares of employment land for the next 17 years. It is considered that this is an exceptionally conservative estimate and that greater amounts of land may well be needed for future purposes. As already shown through the events of last year during the pandemic it is important to have a choice of places of employment within easy reach of new and existing homes. As such the GNLP needs to be more flexible providing opportunity for new creative industries and encouraging diversity in typology as much as possible to weather future crises. Through the allocation of more employment generating land of the type proposed at the Racecourse Community Park (site GNLP0177-B ) it is considered that the Greater Norwich Local Plan would be more robust as well as the local economy being more resilient through the provision and facilitation of greater choice of employment space and new opportunities close to existing homes and a Park and Ride.
The Greater Norwich Local Plan relies significantly upon undelivered previously allocated land. This land amounts to 229.9 hectares of land, as of April 2018, which will have been undeveloped for multiple reasons. It is fair to assume that not all of these reasons will have been overcome, and other issues impeding delivery have arisen. As such, further employment land, particularly smaller sites, need to be allocated to address existing and anticipated needs as a result of recent trends.
Policy 6 also states that development should seek to enhance the environment and economy of centers and villages with more dispersed services to protect their function and avoid the loss of commercial premises or local services.
As part of the Racecourse Community Park (GNLP0177-B ) a large area of public open space is to be provided. This land not only offers a wealth of biodiversity enhancements but usable public open space that would supplement and enhance the provision offered to both Hethersett and Cringleford. Furthermore, this site would result in more dispersed services within an easily accessible location to both residential areas. As such policy 6 would in theory be supportive of this development coming forward. The small parts of this site proposed for build development would perfectly supplement the employment provision proposed as part of the current draft Greater Norwich Local Plan.

The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.

Furthermore, the greater Norwich local plan allocates only 54.2 hectares of employment land for the next 17 years. It is considered that this is an exceptionally conservative estimate and that greater amounts of land may well be needed for future purposes. As already shown through the events of last year during the pandemic it is important to have a choice of places of employment within easy reach of new and existing homes. As such the GNLP needs to be more flexible providing opportunity for new creative industries and encouraging diversity in typology as much as possible to weather future crises. Through the allocation of more employment generating land of the type proposed at the Racecourse Community Park (site GNLP0177-B ) it is considered that the Greater Norwich Local Plan would be more robust as well as the local economy being more resilient through the provision and facilitation of greater choice of employment space and new opportunities close to existing homes and a Park and Ride.

The Greater Norwich Local Plan relies significantly upon undelivered previously allocated land. This land amounts to 229.9 hectares of land, as of April 2018, which will have been undeveloped for multiple reasons. It is fair to assume that not all of these reasons will have been overcome, and other issues impeding delivery have arisen. As such, further employment land, particularly smaller sites, need to be allocated to address existing and anticipated needs as a result of recent trends.

Policy 6 also states that development should seek to enhance the environment and economy of centers and villages with more dispersed services to protect their function and avoid the loss of commercial premises or local services.

As part of the Racecourse Community Park (GNLP0177-B ) a large area of public open space is to be provided. This land not only offers a wealth of biodiversity enhancements but usable public open space that would supplement and enhance the provision offered to both Hethersett and Cringleford. Furthermore, this site would result in more dispersed services within an easily accessible location to both residential areas. As such policy 6 would in theory be supportive of this development coming forward. The small parts of this site proposed for build development would perfectly supplement the employment provision proposed as part of the current draft Greater Norwich Local Plan.

Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.

This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.

It is considered that either policy 6 needs to be reworded, or a new policy dedicated towards employment generating uses in rural locations be provided. At present, the more rural settlements will miss out on the potential for windfall development which could serve to boost local economic vitality. It is considered the creation of employment generating uses in rural locations on a small scale would provide local people with local jobs, helping to reduce carbon emissions from commuting, whilst also reflecting the current trend of home working and the proliferation of new start-up businesses that have arisen over the last year during the pandemic.

For example, taking the sustainable settlement of Ashby St Mary and Thurston, it is considered that some small employment generating uses here would supplement the vitality of the settlement, in accordance with the aspirations of paragraphs 83 and 84 of the NPPF. If policies are not reworded to be more flexible, then dedicated allocations should be considered, such as those proposed between Norwich Road and Mill Road as part of the 4 hectare allocation. Furthermore, due to the more rural location, employment land here would be highly attractive for the more creative and tech industries, which would normally not want to be located on busy commercial parks. Instead the opportunity to create a small network of smaller scale employment sites would better reflect the economic composition of the locality where there is an abundance of entrepreneurial spirit and the surge in consumer demand for more bespoke and local produce.

It is considered that Policy 6 does not propose an effective or justified strategy for the economy of rural areas. Policy 6 states that the needs of small, medium and start-up businesses are addressed through the provision of small-scale business opportunities in all significant residential and commercial developments. Additionally, the policy goes on to state that the promotion of creative industries will be focused on the city center. It is considered that this policy approach is not appropriate for the rural hinterland that composes two of the three relevant districts. Paragraph 83 of the NPPF states that planning policies and decisions should enable the sustainable growth and expansion of all types of business in rural areas, both through the conversion of existing buildings and well-designed new buildings. Paragraph 84 of the NPPF goes on to state that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. Paragraph 84 also states that sites that are physically well related to existing settlements should be encouraged where suitable opportunities exist.

Policy 6, therefore is not consistent with national policy due to this inherent conflict with paragraphs 83 and 84 of the NPPF. Policy 6 directs employment generating uses to existing allocations and the city center, ignoring the needs of the rural communities resulting in an unjustified strategy for supporting rural vitality. As such the GNLP is considered to be unsound in relation to the provision of employment generating uses in rural communities.

Include CNTC in Policy 6. SEE FULL REP ATTACHED

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

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

We welcome the recognition given under (5) of Policy 6 to protect, enhance and expand the Green Infrastructure network.

See attachment for full representation (section 4.4.14)

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