Policy 7.3 The Key Service Centres

An official consultation period is needed. Little thought has been given to the number of houses proposed, the current infrastructure and what will be needed in the future.

At no point during the process have I (and Acle Parish Council) been made aware of ANY consultation. Communication has been very poor. It seems that decisions have been made without involving the local residents or the body representing them.

remove new allocations

hold a public consultation

ensure infrastructure such as schools and broadband are sufficiently upgraded before any further building commences.

Provide recourse where promises by the developers are not kept as has happened on other new estates in the area.

The consultation of the plan should have been carried out in accordance with the Statement of Community Involvement (2016) (Amended 2019). This was not done.

It is unclear if there is sufficient infrastructure available to support the increased number of houses in Acle.

It appears objections made by the local council have not been considered.

Land needs to be earmarked for future expansion of Acle Academy, and protected as such.
The development risks affecting the environmental importance of the track from Mill Lane in Acle to The Windle. Norfolk County Council's Environmental Policy states that there is a principle of an "environmental net gain" for any development. Currently this track goes across open fields, and is a popular walk for local residents. This would not been the same if the track crosses a housing estate!
In general, housing numbers need to be carefully planned, and villages supported to integrate new housing and new residents. Acle's sewerage system is recorded by Anglian Water as being above capacity already.
There is no access to the eastbound A47 from the west of the village so any new housing will result in a large increase in traffic along the narrow main street. A sliproad onto A47 is required to support larger housing numbers.
The proposal for Acle includes a link road from South Walsham Road to Norwich Road. This is welcomed and must be made a condition on any additional housing. However, without the sliproad onto A47, this will only help to remove some of the traffic from the village.

Broadland District Council's Statement of Community Involvement (2016) has not been complied with. Acle Parish Council and Acle residents were consulted on a proposal for an additional 200 homes. Despite many objections to this proposal for 200 new homes, the current Reg 19 document proposes 340 new homes, without having consulted on these additional 140 homes.
The proposal for the 340 homes on land to the west of the village was posted on the Reg 18 consultation as an attachment to a message of support from the landowner, so no one saw it...

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.

Glavenhill object to the lack of new sites being allocated for housing within Key Service Centres and the amount of dispersal to rural parts of the plan area. This is particularly the case within South Norfolk where 1,200 homes could all be allocated in small cluster villages in less sustainable rural parts of the District.

Glavenhill recommend that the quantum of allocations be redirected to support the stated ambitions for the Cambridge-Norwich Hi-Tech corridor and to reflect the sustainability of Key Service Centres such as Hethersett and Poringland / Framingham Earl.

Glavenhill object to the lack of new sites being allocated for housing within Key Service Centres and the amount of dispersal to rural parts of the plan area. This is particularly the case within South Norfolk where 1,200 homes could all be allocated in small cluster villages in less sustainable rural parts of the District.

Glavenhill recommend that the quantum of allocations be redirected to support the stated ambitions for the Cambridge-Norwich Hi-Tech corridor and to reflect the sustainability of Key Service Centres such as Hethersett and Poringland / Framingham Earl.

Please see the section addressing Policy 7.3 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.

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.

Please see the section addressing Policy 7.3 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.

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.

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.

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.

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.

On behalf of Abel Homes, we strongly support the allocation of GNLP0520, land South of Norwich
Road, Hingham. As demonstrated during the various Regulation 18 consultations, the site is entirely deliverable, and capable of making a significant contribution towards satisfying the Councils’ housing needs during the period to 2038.

The continued suitability of the site is detailed below. In considering the suitability of the site regard has been given to the specific requirements of Policy GNLP0520, as well as additional technical work, and discussions with key stakeholders, including the Lead Local Flood Authority and NCC (Highways), that have taken place since the Regulation 18 (c) consultation

On this basis, the allocation of land to the south of Norwich Road is considered to be sound based on the test of soundness set out in paragraph 35 of the NPPF, subject to minor alterations to the wording of Policy GNLP0520.

See attachment for full details

Please see attached letter

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

These representations comprise the following:

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

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

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

Please see the section addressing Policy 7.3 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 find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation particularly sections 4.5.27 - 4.5.34, section 5.3 and section 6.3 - Land south of Burgate Lane, Poringland.

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

Please see attachment for full representation

See attachments for full submission containing information regarding the strategy document and Horsford.

These representations are made in connection with site GNLP0283 and GNLP0283R - land at Holt Road, Horsford on behalf of Mr Carl Palmer.

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.