Policy 7.2 The Main Towns

Return the figures for new homes to Reg.18. Not only should the second site in Aylsham be withdrawn, Reg.19 should be withdrawn until it has had proper consultation and discussion on the numerous errors within it.

This policy is not legally compliant as there has been no consultation with either the Town Council or other residents and associations as to the increase from Reg.18 of new homes from 300 to the 550 homes in Reg.19. In addition this policy is unsound as it has failed to take into account that within the last 5 years there have been two new large developments and other smaller ones that are only now meeting completion.

We support the overall approach to housing for the Main Towns as set out under Policy 7.2. Specifically, we agree that, of the 5 Main Towns, Wymondham should accommodate the greatest proportion of the overall housing growth being directed to the Main Towns. Although there is a considerable level of existing deliverable commitments at Wymondham, we do feel that the town is capable of further growth within this plan period given its location within the Cambridge-Norwich corridor, the available transport links, its existing service base and its growing employment sector. We also support the employment allocation in Wymondham although, over the longer term, there may well be a case for additional employment land.

It is requested that Policy 7.1 includes a development strategy for housing at Wymondham beyond 2026. It is requested that Draft GNLP includes a commitment and timetable to submit a review of the Wymondham AAP or Draft GNLP allocates additional housing sites or a contingency housing site in Wymondham to be delivered from 2030 onwards.

Mrs Janet Skidmore is promoting land at Wymondham, and as such the representations to Policy 7.2 are focussed on that settlement only.
Wymondham is classified as a Main Town in the settlement hierarchy. It contains a wide range of services and facilities, schools, and employment opportunities. There is a railway station in Wymondham, the town is served by buses, and there are shared pedestrian/cycle routes within the town. It is entirely appropriate for Wymondham to be classified as a Main Town and this is supported.
The development strategy for Wymondham is mainly focussed on the delivery of sites allocated in the Wymondham APP, which included a strategic allocation at Wymondham South and other smaller allocations. The Draft GNLP makes two small additional allocations delivering a total of 150 dwellings: at Site Refs. GNLP0354R and GNLP3013. It appears that Wymondham is expected to accommodate a significant amount of development through Draft GNLP. However, most of the development directed to Wymondham is derived from the AAP allocations, which has a plan period from 2008 to 2026; it is noted that the end date for the Stratton AAP is also 2026. The plan period for Draft GNLP extends until 2038. The latest published Annual Monitoring Report (January 202) includes data on predicted housing delivery from committed sites at Wymondham – see AMR Appendix B3: South Norfolk Sites Forecast at pg.24. It is predicted that most of the AAP allocations will be completed by 2026, with approximately 500 dwellings to be delivered beyond that date. It is very likely that all outstanding dwellings from the AAP allocations and the proposed new allocations in Draft GNLP (as Site Refs. GNLP0354R and GNLP3013) will be completed by 2030; the remainder of the developments at Wymondham South and London Road/Suton Lane would be under construction and the two new GNLP allocations are not subject to any phasing requirements. The development strategy for housing at Wymondham effectively ends by 2030, with no strategy for residential development beyond to 2038. There will be housing and affordable housing needs that arise in Wymondham between 2030 and 2038, but these are not taken into account in Draft GNLP. It is requested that Policy 7.2 needs to define a development strategy for housing at Wymondham for the period 2030 to 2038.
It is considered that there are a number of potential options to deliver housing development at Wymondham between 2030 and 2038. Firstly, for Draft GNLP to include a commitment and timetable to submit a review of the Wymondham AAP, so that there is an adopted strategy for the town after 2026. Secondly, for Draft GNLP to allocate additional housing sites or a contingency housing site in Wymondham, which could be delivered from 2030 onwards. There is a suitable and available site with no significant constraints at land south of Gonville Hall Farm in Wymondham (Site Ref. GNLP0320), which is promoted by Mrs Janet Skidmore.

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

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

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

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

1. EXECUTIVE SUMMARY

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

See full representation attached.

Changes to the allocations should be made in accordance with the representations referred to above.

The grounds of objection are the same as those made in response to Sections352, Policy 1, Sections 192 and 179.

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

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

Total Housing Potential – 48,649

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

Please refer to continuation page.

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

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

Please refer to continuation page.

SEE ENCLOSED NOTE 6

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).

See attachment for full representation (section 3)

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

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

Please see the section addressing Policy 7.2 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 7.2 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land at Walcot Green Lane, Diss.

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

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation in particular sections 4.5.9 - 4.5.26, section 5.2, section 6.1 - Land at Norwich Common, Wymondham and section 6.2 - Land at Burston Road, Diss

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

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

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

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

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

Please see accompanying statement and supporting information for site GNLP0341 in Diss and the request for it to 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).

The proposed Settlement Hierarchy and the identification of Aylsham as a Main Town that collectively with the other Main Towns (which are Diss (including part of Roydon), Long Stratton, Harleston and Wymondham) will accommodate 14% of the housing growth during the period to 2038 is strongly supported.

The Main Towns, including Aylsham, play a vital role in the rural economy, providing employment opportunities and services for wider hinterlands. They represent engines of rural growth and it is essential that they are able to grow at appropriate scales, having regard to infrastructure and environmental issues.

Aylsham has a good range of shops and services with local employment opportunities and to support the continued vitality of Aylsham, and reflect its sustainable nature, approximately 550 additional homes are proposed to be allocated across two sites.

Transport links to and from Aylsham via the A140 are also good, including regular bus services to Norwich and North Norfolk.

Development of this scale is capable of providing infrastructure improvements, such as land for a primary school, and green infrastructure, which will provide benefits to both existing and future residents.

This approach is entirely consistent with paragraph 72 of the NPPF, which advises that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided that they are well located and designed and supported by the necessary infrastructure and facilities.”

The critical mass of a new settlement closely related to a town can deliver the appropriate levels of infrastructure.
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.

Instead of the basic maps 8A and 8B, if reference could made in the policy to a specific GI strategy or similar document, which provides further details of what should be maintained and enhanced, it would assist in the delivery of a strategic GI and coherent ecological networks in accordance with para 170 (d) and 171 of the NPPF.

We welcome the reference to enhancing existing green infrastructure (GI) in the supporting text and in the final paragraph of the policy.

Instead of the basic maps 8A and 8B, if reference could made to a specific GI strategy or similar document, which provides further details of what should be maintained and enhanced, it would assist in the delivery of a strategic GI and coherent ecological networks in accordance with para 170 (d) and 171 of the NPPF.