Policy 7.4 Village Clusters

The reason for the following is not explained and is different to the NPPF. Depending on what is meant, it could affect the setting of the Broads. We would welcome some explanation around the wording used and also its justification.
• Policy 7.4, page 117 seems to imply that rural exception sites or entry level exception sites can be ‘well related’ to settlement boundaries. The NPPF says that such sites should be adjacent. Why is this approach being changed? It does not seem to be explained anywhere in the document. What is well related as well? How far from a settlement boundary can a development be? Depending on what is meant, this could affect the setting of the Broads and we may strengthen the status of our comment later in the examination process. Perhaps of relevance are the changes to the NPPF that are proposed to the current paragraph 172, proposed paragraph 175: ‘The scale and extent of development within these designated areas should be limited, while any development within their settings should be sensitively located and designed to avoid adverse impacts on the designated landscapes’.

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

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

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

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

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

It is requested that two amendments are made to the table.

1. The land immediately to the west of the existing Commercial Park, which currently serves as a bund (approximately 0.65 hectares) and forms part of the proposed development area to extend the Commercial Park, is included.

2. The land to the northern section of the Commercial Park measuring 0.75 hectares, known as Block L approved under planning reference 20121385 and now built, is excluded to accurately reflect that these buildings form part of the existing Commercial Park and not part of proposed employment allocation GNLPSL2007/4061/HNF3.

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

We support the penultimate paragraph, which now allows for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. However, we object to the site areas contained within the employment areas table.

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

It is requested that land at Fengate Farm in Marsham (Site Ref. GNLP3035) is specifically allocated in Draft GNLP as an alternative to Site Allocation GNLP2143: Land south of Le Neve Road, or Fengate Farm should be incorporated into the village boundary to enable the delivery of housing at this vacant and unused site.

Policy 7.4 identifies the contribution that the village clusters in Broadland are expected to make to meeting the overall housing requirement. The housing requirement at village clusters would be met by site allocations, infill development and affordable housing-led development.
As set out in the representations to Site Allocation GNLP2143: Land south of Le Neve Road in Marsham, the findings of the landscape and heritage assessment for this site are not correct, the impacts would be more harmful and significant than predicted, and as such this allocation should be deleted. Noble Foods Ltd is promoting an alternative site for a residential allocation in Marsham, at Fengate Farm (Site Ref. GNLP3035), which has no significant constraints to development, and is a vacant and unused site adjacent to the village boundary. Therefore, the site allocations in village clusters will contribute towards meeting the housing requirement, but the most suitable sites within villages also need to be allocated e.g. Fengate Farm in Marsham.
The strategy for housing in the village clusters does not consider the circumstances that exist at particular villages. For example, the site is promoted on behalf of Noble Farms Ltd at Fengate Farm in Marsham contains vacant and unused buildings and areas of hardstanding associated with a former poultry unit. The former poultry use ceased in 2011. The buildings were damaged by fire in early 2020. The site is located outside but immediately adjacent to the village boundary. In all respects the site at Fengate Farm is suitable for redevelopment, it was promoted through the GNLP process, and yet has not been allocated. It is considered that land at Fengate Farm should be specifically allocated in Draft GNLP or be incorporated into the village boundary to enable the delivery of housing and affordable housing.
The policy approach of infill development within settlement boundaries at cluster villages is likely to provide a very limited amount of housing. It is likely that most infill development opportunities where they exist would deliver no more than one or two additional dwellings and would fall below the threshold where affordable housing is required. In these circumstances, it is unlikely that any affordable housing would be delivered from infill sites within village clusters.

Welbeck land strongly disagrees with the spatial growth strategy that is being proposed by the GNLP in the Reg 19 document.

The new approach being taken towards the Village Clusters is not supported and is considered to be both unsound and unjustified.

The identification of Village Clusters based on primary school catchment areas is also questioned as a suitable or sustainable approach to future planning growth.

At the same time, there is also a continued reliance on allocating undelivered, or stalled sites, which is also considered to be unjustified and unsound.

Overall, there appears to be no justifiable reason or rationale for the change from the approaches between the Reg 18(c) and the Reg 19 GNLP documents.

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.

A Sound Way Forward

1) Set the Total Housing Potential at the minimum local housing need figure of 40,541. This satisfies the Government’s Standard Methodology requirement.

2) Realise that by setting the housing target at 40,541 this number of new houses could be met by a combination of: 31,452 existing commitments; 5240 completions (2018 – 20); with the balance of 3,849 houses supplied by windfall developments and Brownfield sites in Norwich. In this scenario no new allocations for housing involving Greenfield sites need be made and therefore it would not be necessary to include any village cluster sites in the plan or utilise sites that might come forward as a result of policy 7.5. The negative aspects of dispersal would be avoided.

3) Accept that there is no need to introduce additional sites on the grounds that developers require more choice. The 31,452 existing commitments already provide an adequate supply of development land for many years to come and give developers all the flexibility they need in regard to site choices. Developers only build to market demand and if there is a surplus of sites they will simply “cherry pick” attractive rural sites and leave more sustainable sites land banked.

4) Learn from past mistakes. Clearly the JCS included a housing target that was far too large – hence 31,452 un-built commitments remain with only 5 years left on the plan. This time the GNLP should set a realistic target – 40,541 is probably already too large.

5) Concentrate development in and around Norwich. This is the best way to reduce greenhouse gas emissions. Setting a lower total housing potential makes this locational approach feasible.

6) Future proof the plan - Post Covid and Post Brexit things will be very different. Trends towards home working and internet shopping are leading to a reduction in the need for office and retail space in the city centre. In order to revitalise the city centre incorporate in to the GNLP the ever increasing potential for converting redundant office and retail space in to residential use. This is a sound approach NPPF paragraph 148 encourages: “the reuse of existing resources, including the conversion of existing buildings”. This kind of conversion could provide a large number of new dwellings in a sustainable location and take pressure of development in the countryside. The GNLP is possibly un-sound because it has not fully explored the potential for this kind of conversion.

7) Realise that the 5,000 houses included in the Total Housing Potential to provide an opportunity for extra capacity should the 2018 ONS household projection figures become reality could be treated as phased development i.e. even if sites for these houses are allocated they need only be brought forward for development if required. In this phased approach Brownfield sites should be prioritised. This way the GNLP will have soundly demonstrated that it is aware that the ONS 2018 projections may require this additional provision but also that it acknowledges the fact that this provision will only need to be brought on stream if the projections prove to be accurate.

8) Listen to parish councils who know what their residents want. For example in Hempnall the Parish Council considers the amount of new housing currently projected for the village, resulting from the JCS site south of Bungay Road, the affordable housing scheme that the parish council seeks to implement in conjunction with Saffron Housing at Millfields and from likely windfalls – totalling approximately 45 to 50 houses - is the right amount for the village (a 10% increase over current housing numbers). Therefore we do not want any of the sites put forward by landowners for inclusion in the GNLP to be allocated in the plan. We would also like our policy that all development be restricted to inside the current development boundary to be honoured except in regard to the provision of a rural exception site for affordable housing.

9) Provide affordable housing in villages via Rural Exception Sites. The Parish Council in conjunction with Saffron has plans to build affordable housing near Millfields. The site is owned by South Norfolk Council and they have asked for its inclusion in the GNLP as an allocated site. If their request is granted it will prevent its classification as an exception site and our affordable housing scheme will be lost. We ask that SNC complies with NPPF 77 which says: “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs”. Rural exception sites enable local affordable housing requirements to be fully met. Reliance on market schemes fails to achieve this objective. For example the 23 house JCS development south of Bungay Road was originally intended to include 7 affordable houses. Through the use of viability studies the developer has managed to reduce this in stages to just one (7 then 5 then 3 now 1).

10) Lobby central government to insist on carbon zero building standards at the earliest opportunity. As things stand currently the GNLP, for much of its 20 year plan period, will not operate in an environment where the highest standards are required.

Hempnall Parish Council considers that the Housing Growth Needs as set out in paragraphs 176 to 187 of the Draft GNLP Regulation 19 Publication (under Policy 1 – The Sustainable Growth Strategy in Section 5 of the document ‘The Strategy’) are unsound (and possibly not legally compliant) both in regard to the magnitude of the Total Housing Potential and in respect of the spatial distribution of development.

In particular we consider that both the total number of houses (Total Housing Potential) and the distribution of development conflict with Climate Change objectives and potentially contradict objectives set in regard to environmental protection and enhancement including protection of the landscape.

Relevant NPPF paragraphs and Climate Change Act targets relating to concerns over the magnitude of the Total Housing Potential

The NPPF requires that: “Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures” – paragraph 149

The Oxford English dictionary defines mitigating as: “having the effect of making something bad less severe, serious, or painful.” Therefore the NPPF says that local plans should take a proactive approach in making something bad (i.e. climate change) less severe, serious or painful.

NPPF paragraph 148 states that the planning system: “should help to shape places in ways that contribute to radical reductions in greenhouse gas emissions”



Climate Change Act 2008 has set a legally binding target for the UK to reduce its Greenhouse Gas emissions from 1990 levels by at least 80% by 2050.

The Climate Change Act 2008 (2050 Target Amendment) Order 2019
The UK has recently legislated to end its contribution to global warming by 2050, with a target that will require the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050, compared with the previous target of at least 80% reduction from 1990 levels.

Given that the carbon foot print resulting from the pre-construction and construction work necessary to build each new house is in the region of 100 tonnes of CO2 * then fulfilling the Total Housing Potential of 49,492 houses could generate 4,949,200 tonnes of CO2 and this is just the amount of CO2 resulting from building the houses. If the operational greenhouse gas emissions over the lifecycle of the properties is factored in the emissions total leaps to astronomical levels as the building phase is only responsible for about a quarter of total lifecycle emissions. Of course building methods could improve during the plan period, thus reducing both construction and operational emissions, but with the government constantly “kicking the can” down the road on introducing stricter building regulations this may well take many years to be realised and even with better standards total emissions resulting from the building and operation of 49,492 additional houses will still be very high.

There is a choice that can be made between retaining the policy draft figure of 49,492 or setting a lower total housing number in accordance with NPPF paragraph 60 which says 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”

Hempnall Parish Council contends that adherence to climate change policy should require local authorities to choose the minimum number of houses needed in order to comply with the local housing need assessment resulting from the appliance of the standard method in national planning guidance and to not set a housing target or housing potential at a higher level.

Therefore Hempnall Parish Council considers that the GNLP should reduce the Total Housing Potential to the level required to address local housing need as assessed by the standard method i.e. 40,541 dwellings as it is unsound to proceed with a Total Housing Potential for 49,492 extra houses by 2038 because the higher figure is not compatible with Government Climate Change Objectives.

In making a choice to proceed with the lower housing figure the GNLP would be demonstrating that:

• The plan has taken a proactive approach to mitigating climate change impacts (as required by NPPF paragraph 149) because it will have chosen the least damaging option in terms of greenhouse gas emissions (the huge CO2 emissions that would have resulted from building nearly 50,000 houses would be made less severe or serious) while still complying with NPPF paragraph 60. Of course the construction and operation of 40,541 houses will still generate enormous greenhouse gas emissions but the total will at least be around 20% less than if 49,492 were built.


• The plan has attempted to comply with NPPF paragraph 148, as best possible given the requirements of NPPF paragraph 60, by endeavouring to “shape places in ways that contribute to radical reductions in greenhouse gas emissions”. While choosing to build 40,541 extra houses is not going to lead to a radical reduction in greenhouse gas emissions making this choice radically lowers emission levels below those which would occur if 49,492 houses were built.

• The plan has attempted to comply, as best possible given the requirements of NPPF paragraph 60, with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050.


If the choice is made for the GNLP to proceed with the higher housing potential figure of 49,492 the plan will not have demonstrated that it has:

• Pursued a proactive approach to mitigate climate change impacts because it will have chosen an option that makes something bad (i.e. climate change) more severe and serious than it otherwise would have been if the lower local housing need figure was chosen. The plan would not be compliant with NPPF paragraph 149.

• Attempted to comply with NPPF paragraph 148 because it will have chosen not to take advantage of the opportunity to achieve the radically lower emission levels that would result from the adoption of the lower local housing need figure

• Complied, as best possible given the requirements of NPPF paragraph 60, with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050 because in not choosing the lower local housing need figure it will have facilitated the generation of considerably higher level of greenhouse gas emissions.



*(source: Climate Change section of the Environmental Statement for Chalgrove Airfield in Oxfordshire - this is 3000 home development. If you look to page 15, it says: “The total GHG emissions from pre-construction and construction are estimated to be in the order of 313,370 tCO2e” i.e. around 100 tonnes per house)


Furthermore Hempnall Parish Council considers that the GNLP should reduce the Total Housing Potential to the level required to address local housing need in order to provide a greater level of environmental and landscape protection

Clearly the land take to build 49,492 houses is considerably greater than that required to construct 40,541. Choosing the lower figure saves many Greenfields from the threat of development and in so doing makes it easier to protect countryside, habitats, landscape, flora and fauna.


Hempnall Parish Council’s concerns over the distribution of Housing

Allocating new sites in villages as part of a dispersal policy is unsound as it conflicts with the objective of the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050. Concentrating development in and around Norwich is the best way to reduce greenhouse gas emissions as such development can more easily be based on the usage of public transport. There is increasing potential for more residential space to be provided in Norwich as a result of trends towards home working and internet shopping which are leading to a reduction in the need for office and retail space in the city centre.

Vehicle use is often the main contributor to operational emissions resulting from new housing * *. Therefore development that is dispersed will create a greater level of greenhouse gas emissions than development that is concentrated in or close to Norwich. Eventually private cars will all be electric or hydrogen powered but for the “shelf life” of the GNLP (to 2038) the transition will not have been completed and for the first 12 years (and probably more) of the plan the majority of vehicles will remain as petrol or diesel powered.

The table on page 80 of the GNDP papers from June 23rd, 2017 clearly showed that the best spatial option for new housing in order to minimise negative environmental consequences was Option 1: Urban Concentration close to Norwich. This option was the one which was best for: minimising, air, light and noise pollution; improving well-being; reducing CO2 emissions; mitigating the effects of climate change; protecting and enhancing bio-diversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; reducing the need to travel and promoting the use of sustainable transport modes; minimising the use of the best agricultural land and maintaining and enhancing water quality and its efficient use. In terms of all these and other factors taken together the least desirable option was Option 4: Dispersal of Development.





Unfortunately the obvious conclusion that should have followed on from the publication of this table, i.e. for the GNLP to be based on Option 1, was not pursued. Instead the distribution pattern for new housing envisaged in the draft plan, while it includes a degree of urban concentration, still promotes dispersal of development through proposals to make new allocations in Village Clusters and via policy 7.5. These allocations are in addition to the rural housing sites already included in current commitments carried over from the JCS and are additional to estimates for windfall developments in villages.

If the GNLP proposals for the location of new housing are not changed a sizeable chunk of development will end up being dispersed and the plan will not have:

• Taken a proactive approach to mitigating climate change impacts (as required by NPPF paragraph 149) because the plan would be facilitating a distribution pattern of development that produces greater greenhouse gas emissions than would be the case if a better option (Option 1) had been chosen

• Complied with NPPF paragraph 148 which seeks to “shape places in ways that contribute to radical reductions in greenhouse gas emissions” because it clearly does not shape the development of places in a way that enables there to be a radical reduction in greenhouse gas emissions – far from it in fact. The shape of development in locational terms, because it includes a sizeable element of dispersal, would lead to an increase in greenhouse gas emissions. Concentrating development in and near Norwich is a much sounder spatial option if the requirements of paragraph 148 are to be met.

• Made the best attempt to comply with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050. Obviously by choosing to disperse a large amount of new housing greenhouse gas emissions will rise more rapidly than if development was all concentrated near Norwich - pursuing dispersal makes it less likely that emissions will reach net zero by 2050.

• Complied with paragraph 150 of the NPPF which states that “new development should be planned for in ways that can help to reduce greenhouse gas emissions, such as through its location, orientation and design.” Clearly dispersing a sizeable quantity of development is not locating housing in the right place to help reduce greenhouse gas emissions.

• Followed National Planning Practice Guidance (PPG) (2019) which states that: “effective spatial planning is an important part of a successful response to climate change as it can influence the emission of greenhouse gases” and “Planning can also help increase resilience to climate change impact through the location, mix and design of development.” In addition, the PPG provides examples of mitigating climate change by reducing greenhouse gas emissions and adapting to climate change through “Reducing the need to travel and providing for sustainable transport”. Dispersing development is not locating new housing in the best place to reduce climate change impacts nor is it reducing the need to travel or making it easy to provide sustainable public transport.




* * Source: Climate Change section of the Environmental Statement for Chalgrove Airfield in Oxfordshire – in this 3000 home development “total GHG emissions from operational phase (over 60 year design life) contribute 80% to the overall emissions of the Proposed Development.” Estimated operational emissions are summarised in Table 15-13 of the ES. Of these operational emissions four fifths (1,021,260 tonnes of CO2) will result from vehicle use.



Furthermore Hempnall Parish Council considers that the GNLP should remove plans to disperse housing in to village clusters and via policy 7.5 because this dispersal of development has a greater negative impact on the environment and landscape than that which would result from concentrating development in or near Norwich

It is clear from the table on page 80 of the GNDP papers from June 23rd, 2017 that dispersing development has far greater negative impacts on the environment and landscape than concentrating development in and close to Norwich.

Dispersal:

• Increases air, light and noise pollution

• Increases CO2 emissions

• Causes more Greenfield sites to be built on

• Robs us of valuable agricultural land

• Threatens habitats and bio-diversity

• Suburbanises the countryside


Conclusions

• Hempnall Parish Council considers that the GNLP in its present form is un-sound (and quite possibly not legally compliant) because it has set the total housing potential number unnecessarily high - this is not compatible with NPPF paragraphs 148 and 149 nor does it comply with the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050

• Furthermore we consider the GNLP to be un-sound because it chooses to disperse a significant amount of development, a policy which also does not “chime” with the requirements of NPPF paragraphs 148, 149 and 150 and the objective of the Climate Change Act 2008 (2050 Target Amendment) Order 2019 that requires the UK to bring all Greenhouse Gas emissions to ‘net zero’ by 2050. Nor does it follow the guidance provided by National Planning Practice Guidance (PPG) (2019)

• Setting the housing number so high and dispersing some development in the way the GNLP suggests also has a number of very negative consequences in regard to the landscape and the environment.


A Sound Way Forward

1) Set the Total Housing Potential at the minimum local housing need figure of 40,541. This satisfies the Government’s Standard Methodology requirement.

2) Realise that by setting the housing target at 40,541 this number of new houses could be met by a combination of: 31,452 existing commitments; 5240 completions (2018 – 20); with the balance of 3,849 houses supplied by windfall developments and Brownfield sites in Norwich. In this scenario no new allocations for housing involving Greenfield sites need be made and therefore it would not be necessary to include any village cluster sites in the plan or utilise sites that might come forward as a result of policy 7.5. The negative aspects of dispersal would be avoided.

3) Accept that there is no need to introduce additional sites on the grounds that developers require more choice. The 31,452 existing commitments already provide an adequate supply of development land for many years to come and give developers all the flexibility they need in regard to site choices. Developers only build to market demand and if there is a surplus of sites they will simply “cherry pick” attractive rural sites and leave more sustainable sites land banked.

4) Learn from past mistakes. Clearly the JCS included a housing target that was far too large – hence 31,452 un-built commitments remain with only 5 years left on the plan. This time the GNLP should set a realistic target – 40,541 is probably already too large.

5) Concentrate development in and around Norwich. This is the best way to reduce greenhouse gas emissions. Setting a lower total housing potential makes this locational approach feasible.

6) Future proof the plan - Post Covid and Post Brexit things will be very different. Trends towards home working and internet shopping are leading to a reduction in the need for office and retail space in the city centre. In order to revitalise the city centre incorporate in to the GNLP the ever increasing potential for converting redundant office and retail space in to residential use. This is a sound approach NPPF paragraph 148 encourages: “the reuse of existing resources, including the conversion of existing buildings”. This kind of conversion could provide a large number of new dwellings in a sustainable location and take pressure of development in the countryside. The GNLP is possibly un-sound because it has not fully explored the potential for this kind of conversion.

7) Realise that the 5,000 houses included in the Total Housing Potential to provide an opportunity for extra capacity should the 2018 ONS household projection figures become reality could be treated as phased development i.e. even if sites for these houses are allocated they need only be brought forward for development if required. In this phased approach Brownfield sites should be prioritised. This way the GNLP will have soundly demonstrated that it is aware that the ONS 2018 projections may require this additional provision but also that it acknowledges the fact that this provision will only need to be brought on stream if the projections prove to be accurate.

8) Listen to parish councils who know what their residents want. For example in Hempnall the Parish Council considers the amount of new housing currently projected for the village, resulting from the JCS site south of Bungay Road, the affordable housing scheme that the parish council seeks to implement in conjunction with Saffron Housing at Millfields and from likely windfalls – totalling approximately 45 to 50 houses - is the right amount for the village (a 10% increase over current housing numbers). Therefore we do not want any of the sites put forward by landowners for inclusion in the GNLP to be allocated in the plan. We would also like our policy that all development be restricted to inside the current development boundary to be honoured except in regard to the provision of a rural exception site for affordable housing.

9) Provide affordable housing in villages via Rural Exception Sites. The Parish Council in conjunction with Saffron has plans to build affordable housing near Millfields. The site is owned by South Norfolk Council and they have asked for its inclusion in the GNLP as an allocated site. If their request is granted it will prevent its classification as an exception site and our affordable housing scheme will be lost. We ask that SNC complies with NPPF 77 which says: “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs”. Rural exception sites enable local affordable housing requirements to be fully met. Reliance on market schemes fails to achieve this objective. For example the 23 house JCS development south of Bungay Road was originally intended to include 7 affordable houses. Through the use of viability studies the developer has managed to reduce this in stages to just one (7 then 5 then 3 now 1).

10) Lobby central government to insist on carbon zero building standards at the earliest opportunity. As things stand currently the GNLP, for much of its 20 year plan period, will not operate in an environment where the highest standards are required.

The value of the countryside and green spaces to the well being of all has been revealed throughout the Covid-19 pandemic. The Countryside deserves stronger protection in the GNLP than is currently on offer.

To ensure the plan is sound we propose that the settlement boundary reappraisal should take place before the plan is submitted for examination. Alternatively, the wording of Policy 7.4 should be amended to allow small scale windfall development on sites that are assessed on a case by case basis as forming a natural adjustment to the settlement boundary. As this assessment would be taking place on an ad hoc basis in lieu of a holistic settlement boundary reappraisal it is therefore proposed that windfall development permitted under this policy should be separate to the cumulative number of dwellings per parish allowed for under Policy 7.5.

For clarity, we also propose there should be a consistent use of either "settlement boundary" or "development boundary".

Please find attached the following Representation Forms for Policy 1, Policy 7.4, Policy 7.5 and Paragraph 301 of the above consultation document. I have also reattached our Reg 18 Supplement Statement and appendices for reference in support of our representation to Policy 7.4. Please do not hesitate to contact me if you require any further information.

Submitted by Bidwells on behalf of Abel Homes.

As detailed in comments relating to Policy 1 – The Sustainable Growth Strategy, the proposed Settlement Hierarchy is fully supported.

Village Clusters, such as Horsham St Faith, are sustainable rural locations that provide access to services, including primary schools, as well as access to employment opportunities and public transport links. Development in these locations will, in accordance with the NPPF, assist in enhancing and maintaining the vitality of rural communities.

Accordingly, it is wholly appropriate that Village Clusters should be identified as locations to accommodate a reasonable amount of growth (9% of the total housing growth) during the period to 2038. It fully supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.

Horsham St. Faith, which along with Newton St Faith, is identified as a Village Cluster. The cluster benefits from a Post Office and Store, pre-school, primary school, doctor’s surgery, public house, alongside a range of other services and amenities, as well as employment opportunities.

Accordingly, the identification of Horsham St Faith and Newton St Faith, which is in close proximity of Norwich and the NDR, as a village cluster supports the aspirations of directing growth to locations with good access to services and employment, alongside urban and rural regeneration and is fully supported.

On this basis, the proposed the Policy is considered to be sound.

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 7

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).

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.

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.

See attachment for full representation (section 4)

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)

It is considered necessary that a more flexible approach to this policy with regard to facilitating employment generating development in more rural locations be adopted. Furthermore, it is also considered prudent that further assessment of need and trends in relation to employment and business practices is carried out. The policy should also cater to the rise in need of small business and office spaces as well as the need for more sites in better locations where amenities such as public open space is available for employees, mirroring the current trend and protecting and enhancing employee welfare.

If this is route is not pursued, an alternative could be to allocate small sites in rural locations. For example, looking at Little Plumstead, we can see that there are local facilities, and sustainable transport options available to local people. As such, it is considered that an allocation for a small extension to the existing Octagon business park would cater to the needs of local residents within close proximity and future employers. Allocation GNLP2107 is considered to be an ideal village allocation which would accord with paragraph 83 and would supplement the sustainable growth and expansion of Little Plumstead whist providing a localised benefits.

Policy 7.4 is considered to be unjustified, ineffective, inconsistent with national policy and not positively prepared due to the restrictive nature of the policy and its ultimate undermining of the vitality of village clusters.

Policy 7.4 states that small scale employment uses will be acceptable in principle within development boundaries. This is permitted through the reuse of rural buildings or through the potential expansion of existing employment sites. However, policy 7.4 does not mention development that is adjacent to, or relates well to development boundaries. As such, the policy is considered to be overly restrictive, not allowing for the realistic or growth and expansion of employment uses. As such the policy is considered to be detrimental to rural economies which rely upon local jobs for local people and localised footfall to sustain existing service provision. As such, the policy is inconsistent with national policy, namely paragraphs 83 and 84 of the NPPF and ultimately, paragraph 35.

Looking at the impact that COVID-19 has had upon the working environment, there are new pressures upon employers to provide sites that can adhere to principles such as social distancing. Additionally, employers are looking for more flexible arrangements for employees, such as utilising smaller office spaces and capitalising upon the ability to work from home. As such the proliferation of small office spaces across the district would help aid rural economies, and by being small in nature, would not undermine the larger allocations within the plan. Additionally, given the rise in new home-based businesses, smaller workspaces and offices are seeing an increased demand at the expense of larger more industrial units and sites. Policy 7.4 does not acknowledge or address this trend, and instead is considered to be unjustified and ineffective.

As such, it is considered that the current plan is not positively prepared as it does not adequately address the radical change in employment practices of the previous year. Coupling this with the overly restrictive policy, it is considered that the proposed plan will have a detrimental impact upon rural economies whilst protecting antiquated employment strategies. It is therefore considered that the GNLP is not compliant with national policies and the aspiration to support and facilitate rural economies and therefore is considered in conflict with paragraph 35 of the NPPF.

Policy 7.4 - Given the spatial portrait (place setting), it is essential that this policy is modified to take account of brownfield and other potentially suitable development sites that may not be located within or adjacent to settlement limits. these sites could address the needs of our rural communities and businesses in accordance with paragraph 84 of the National Planning Policy Framework.

Policy 7.5 should be modified to take account of the context of the site and the sustainability of the location permitting more that 5 dwellings if the location is sustainable and the site is well-related to the settlement. For example, in an accessible location like the Norwich urban fringe and/or accessible and desirable locations such as Bracon Ash and Mulbarton.

There should be reference made to the importance of local standards of beauty, quality, and design, under the new rules which came into effect on 30 January 2021 under the national model design code and any local design codes which might be in place.

Policy 7.4 - Village Clusters is not positively prepared justified, compliant with national policy or effective as it fails to take account of the need to prioritise brownfield sites for provision of new homes and employment. Apart from on the allocated sites, new homes and businesses would be limited to infill within settlement boundaries or affordable housing led development. No consideration is given to established /brownfield sites that are suitable and available for redevelopment. The development of such sites could help to make more efficient use of land and better serve the needs of local communities. Additionally, they provide an excellent opportunity for regeneration and building back better, getting rid of ugly and deteriorating landscapes, enhancing biodiversity and improving drainage infrastructure.

Similarly, the policy does not address the need for enhancing the environment and improving the sustainability of existing rural businesses that may exist outside settlement limits.


The NPPF states in paragraph 78 that "housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." The GNLP does not propose a policy that supports this, instead through proposing an allocation only approach, and exceptionally limited windfall proposals through policy 7.5 the GNLP directly restricts growth of local rural economies in a manner inconsistent with the NPPF. The local rural economies require new development and new residents, to thrive. The Draft GNLP does not identify opportunities or provide a significant policy to support village and rural community growth in a meaningful manner, instead it actively restricts this, in conflict with paragraph 78 of the NPPF. Consequently, it is not consistent with national policy and is in conflict with paragraph 35 of the NPPF.

Furthermore, policy 7.5 is not positively prepared or justified as it does not take account of the disparate characteristics of the 'smaller parishes' and 'larger parishes' within the GNLP area. Within some of the larger parishes it is clear that there are highly sustainable settlements where in excess of 9 dwellings could be accommodated sustainably.

The recently published Building Better, Building Beautiful Commission "Living with Beauty" report and the Government's Design Code Template encourages development that respond to local area characteristics, which does not restrict development to an arbitrary number of units.

Policy 7.4

The policy should take account of brownfield and other potentially suitable development sites that may not be located within or adjacent to settlement limits taking heed of paragraph 84 of the National Planning Policy Framework.


Policy 7.5

Criteria for assessment to be added. For instance, brownfield sites being prioritised.

There should be reference made to the importance of local standards of beauty, quality and design under the new rules which came into effect on 30 January 2021, the national model design code and any local design codes which might be in place.

Policy 7.4 - Village Clusters

This policy is not positively prepared justified or compliant with national policy. It is not effective. It does not address the need to prioritise brownfield sites ahead of greenfield for provision of new homes. The policy needs to be broadened to consider the provision of new homes on brownfield sites that may be within a hamlet but situated to meet the needs of our rural communities. The regeneration of such sites, especially where supported by local parish councils, could have a huge impact on making the countryside more beautiful in line with new national policy. It would also help to reduce carbon emissions enabling families to remain in villages where they have long established links.

Although this policy is welcomed and supported, it needs to provide more detail of the criteria for assessment under the policy. It is not effective without this.

Policies 7.4 and 7.5 - Self-Build Provision

The GNLP refers to self/custom-build in Policy 7.4:

"Affordable housing led development, which may include an element of market housing (including self/custom build) if necessary, for viability, up to a maximum of 15 dwellings in total . These sites should be adjacent or well related to settlement boundaries with good access to' services, including safe routes to schools, subject to other policies of the local plan.11

and Policy 7.5:

"Policy 7.5 promotes small scale housing development, including self/custom build. This complements policies 5 and 7.4 which also support self /custom build .11

There were 113 people on the self/custom-build housing registers in 2018/19 alone, highlighting the demand for self/custom-build. I do not believe the GNLP's policies reflect this level of demand and I would like to see provision for self/custom-build strengthened in the GNLP.

As the Member of Parliament for South Norfolk, I write to comment on the Regulation 19 Publication of the Greater Norwich Local Plan {G NLP).

Policy 7.6 - New Settlements

I would like to place on record my support for the proposed new settlement site at Hethel, known as the Stanfield Garden Village, ahead of the investigation into new settlement sites later this year. This settlement would provide a self-sufficient, low-carbon community in a vibrant location. Moreover, the speed of delivery and the availability of both affordable and self/custom-build homes at scale would help to address local and national housing needs at pace, providing an innovative and sustainable solution to the current housing crisis. A new settlement at Hethel would also carry benefits with respect to meeting South Norfolk District Council's statutory duty to fulfil self-build demand.

Policies 7.4 and 7.5 - Self-Build Provision

The GNLP refers to self/custom-build in Policy 7.4:

"Affordable housing led development, which may include an element of market housing (including self/custom build) if necessary, for viability, up to a maximum of 15 dwellings in total . These sites should be adjacent or well related to settlement boundaries with good access to' services, including safe routes to schools, subject to other policies of the local plan.11

and Policy 7.5:

"Policy 7.5 promotes small scale housing development, including self/custom build. This complements policies 5 and 7.4 which also support self /custom build .11

There were 113 people on the self/custom-build housing registers in 2018/19 alone, highlighting the demand for self/custom-build. I do not believe the GNLP's policies reflect this level of demand and I would like to see provision for self/custom-build strengthened in the GNLP.



Email: richardbaconmp@parliament.uk Web: www.richardbacon.org.uk




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Primary School Provision in Poringland

While the current Plan seeks to address local education needs in Norfolk, it does little to address the needs of parents and children living in Poringland. Local children in Poringland are currently being taken to Trowse, approximately five miles away, via a bus. This is both costly and unnecessary seeing as Norfolk County Council has both a need and a funding allocation for a primary school in Poringland. I would very much like to see this addressed by the Plan.

SME Developers and Care Home Providers

There appears to be a shortfall of sites under 50 units for SME developers in the GNLP, both currently and in the next Local Plan period. This is unsustainable for small local developers and will result in the loss of valuable skills and housing choice in Norfolk. I believe that the number of sites suitable for SME developers should be significantly increased.

Care home providers in Norfolk also appear to have been neglected by the GNLP through the allocation process and I would like to see this addressed too.

I hope that the above comments will prove constructive. I very much look forward to hearing the responses to the points made during the GNLP Regulation 19 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.

Accordingly, on its own terms, the Sustainability Appraisal’s findings would appear to support a quite different approach to site allocation – one that avoids as far as possible new development on greenfield land and in unsustainable locations. The above allocations are an illustrative but not exhaustive list of instances of this problem in the plan.

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

In order to make the policy sound it is considered that policy 7.4 should be re consulted on, alongside all other policies that relate to housing when the South Norfolk Village Clusters Housing Allocations Local Plan becomes available. This way a united and informed policy can be carefully considered in light of the wider strategic policies of the GNLP. Irrespective of this however, it is considered that additional development should be supported that relates well to existing settlements and subject to other criteria, such as highway safety, design, and reflection of local densities, for example.

If a more flexible approach regarding the wording of the policy is not adopted, then specific site allocations in rural areas should be considered. For example, looking at Thurston/Ashby St Mary, the site located North of Mill Road, would be an ideal location for residential development. The site relates well to the existing settlement and would be located in a position that allows easy access onto the common. Development here would bolster the local economy whilst also allowing the village to grow in a controlled manner without relying upon significant densification as the current policy proposes, to meet local needs.

Policy 7.4 is unjustified, ineffective, not positively prepared, and not consistent with national policy. Policy 7.4 states that new sites in village clusters will be allocated through a South Norfolk Village Clusters Housing Allocations Local Plan. It is considered that the subdivision of an integral element of the GNLP is not proactive or justified when considering the cumulative growth over the three districts for the next 18 years. The policy states that 1200 homes will be allocated within South Norfolk, however it does not specify where development will be located or whether the strategy will propose equal disbursement of new dwellings across the district or concentrate development within a few key areas. This lack of clarity is in conflict with paragraph 16 of the NPPF which states that policy should be clearly written and unambiguous, resulting in the policy currently being inconsistent with national policy.

Irrespective of how development is proposed across South Norfolk, it is viewed that the second element of the policy, which relates to additional sites, is too restrictive to facilitate growth and ensure vitality of rural communities in accordance with paragraph 78 of the NPPF. Although it is understood why the GNLP proposes only in full development is acceptable, such a policy undermines and destroys the quintessential essence of the character and appearance of rural villages. Simply put, infill development encourages the subdivision of plots and the creation of highly dense development which is incongruous with the historic evolution of most traditional villages. Such a policy will see the densification as well as the upward extension of the more rural localities to the detriment of the character and appearance of the area which is not considered to be a justified approach.

Overall, it is considered that policy 7.4 is inappropriate in its current form as insufficient information has been provided as to how the village cluster allocations will ultimately look and function. There are a number of uncertainties at present regarding where development will be located which undermines any potential assessment of the policy. It is considered the best approach would be an even spread of development across the district, however even with this proposed it is viewed that the overly restrictive idea of infill development only will ultimately, in the long term, undermine the viability of most rural economies.

As such the lack of clarity regarding the proposed wording of the policy and lack of information about where development will be located is in inconsistent with paragraph 16 of the NPPF. Furthermore, the overly restrictive infill only policy is in conflict with paragraph 78 of the NPPF. As such the failure to accord with national policies is considered to render the policy and the GNLP unsound in accordance with paragraph 35 of the NPPF and the proposed overly restrictive strategy is considered to be an unjustified approach.

The soundness of the plan in respect of delivering its objectives would be greatly strengthened through a reduction in the number/scale of site allocations to be made through the Village Clusters document, in favour of more overt commitment to the contribution that well-planned
new settlement-scale growth.
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.

To make the GNLP sound in accordance with paragraph 35 of the NPPF, it is considered necessary that a further study into the implications of COVID-19 and the future of employment needs to be commissioned. Looking at rural communities, the option of providing flexible working spaces could be the key to unlocking not only the vitality but the viability of the more rural settlements. Currently the provision of large-scale employment allocations requires mass commuting to work. Instead, the creation of a policy that allows for flexibility of the smaller scale and bespoke employment uses within small settlements would allow for local people to commute sustainably (by walking, for example) thus reducing the carbon footprint, and supplementing the GNLP’s aspirations of providing for a healthier, more vibrant community. Such a policy would also help support rural economies by providing for more employment opportunities locally, as well as helping retain football within existing settlements where future viability of local facilities are questionable following the national lockdowns and associated loss of earnings.

Taking the settlement of Frettenham, if the policy is not amended, then specific allocations should be considered that would facilitate growth. We can see that there are facilities in Frettenham, and sustainable transportation options available for local people, however the option to walk to work will always have a lower carbon footprint than public transport. Furthermore, through providing a small number of employment opportunities locally, we can in accordance with paragraph 83 of the NPPF, supplement the sustainable growth and expansion of the settlement through well designed new buildings, providing local jobs for local people, as well as accommodating the smaller more bespoke businesses such as the arts and crafts sector and the tech industry, which would be incongruous with larger employment site allocations. Furthermore, it is prevalent that such industries do not wish to own large scale factories in traditional employment locations. As such a dedicated policy should be provided regarding the growth of small employment opportunities in more rural locations for the more bespoke businesses, or specific allocations should be promoted, such as GNLP2076 and GNLP2078.

Additionally, it is necessary that the policy is modified in either case to take account of the availability locally of brownfield sites that may not directly fall within the settlement but are adjacent to, or relate well to the settlement boundaries in accordance with paragraph 84 of the NPPF.

Policy 7.4 is not positively prepared, justified, compliant with national policy or effective as it does not consider distinguish between brownfield and greenfield land. The policy fails to prioritise brownfield development, or take into consideration brownfield land that is not infill which could make a more effective use of the land. Similarly, the policy does not address the need for enhancing the environment and improving the sustainability of existing rural businesses that may exist outside settlement limits.

Furthermore, Policy 7.4 states that small scale employment uses will be acceptable in principle within development boundaries. This is permitted through the reuse of rural buildings or through the potential expansion of existing employment sites. However, the policy does not take into consideration recent trends regarding the vast number of home working, and the need for small office space close to home for all sectors of the market. Currently, the assumption is that home working means people working from their own individual dwellings, however looking at the employment land assessment addendum 2020, no consideration has been given to the proliferation of office space and the potential for existing businesses wanting to move to less dense localities where there is more scope for incorporating employee welfare facilities and social distancing measures. As such, given the last year, it is considered the policy is unjustified in this regard. Furthermore, when coupled with the rise in entrepreneurial spirit and home businesses that have arisen during the lockdowns, there is an increased demand for small multipurpose spaces, ideally close to existing residential properties in more rural locations. The provision of such units will supplement existing rural economies in unprecedented ways, capitalising upon the radical shift of home working that the recent pandemic has caused, however the policy makes no effective or justified approach to addressing recent shifts in working.

The evidence base for employment uses and employment space was gathered in 2016 and 2017, and supplemented in 2020, based on a forecast model done in 2017. As such, it is considered that the evidence base does not adequately reflect the current circumstances as no one could have predicted the recent pandemic and the consequences for employment space. This has resulted in the proposed policy based on an unjustified strategy.

It is considered in accordance with paragraph 35 of the NPPF, that the policy does not pose an appropriate strategy taking into account reasonable alternatives. and is considered to be unjustified, unsound, not compliant with national policy and not effective.

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.