Policy 7.6 Preparing for New Settlements

Consult with the localities identified and explore other sites with a proper evaluation of all the sites identified and any new sites that might emerge.

The requirement /suggestion to build new settlement villages has not been consulted upon in those areas or localities where the intention to provide has been identified.

Consult with the localities identified and explore other sites with a proper evaluation of all the sites identified and any new sites that might emerge.

It is suggested that the timescales for the delivery of new settlements, the viability and deliverability of new infrastructure, and the ability of these types of developments to provide policy compliant levels of affordable housing, should be fully understood and assessed before they are considered as an option for a future GNLP. No modifications are requested to Policy 7.6.

Policy 7.6 refers to the possibility of a new settlement being needed through the next Local Plan. A number of potential locations for new settlements in close proximity to Wymondham have been promoted and assessed through the Draft GNLP process; none of these sites are proposed as allocations but are identified in the site assessments as reasonable alternatives.
It is noted that new settlements typically take much longer to proceed through the planning processes than originally predicted, largely because they are complex and require significant levels of primary infrastructure to be provided. It is normally the case that new settlements are not able to deliver policy compliant levels of affordable housing, at least not in the initial stages, mainly because of the costs associated with the delivery of transport and utilities infrastructure improvements and new community facilities.
It should be noted that the new settlement examples in Cambridgeshire which are under construction (Cambourne, Northstowe and Alconbury Weald), referred to in Paragraph 23 of the New Settlements Topic Paper, are not able to meet local affordable housing policy requirements; there is an additional new settlement example at Waterbeach (in South Cambridgeshire) which is providing no affordable housing in the first phase. It is noted that only one of the three proposed North Essex new settlements passed through the plan-making process and was allocated – the Tendring/Colchester Garden Community – with the other two new settlements not taken forward for a variety of reasons including the deliverability and viability associated with transport and public transport infrastructure.
It is suggested that the timescales for the delivery of new settlements, the viability and deliverability of new infrastructure, and the ability of these types of developments to provide policy compliant levels of affordable housing, should be fully understood and assessed before they are considered as an option for a future GNLP. No modifications are requested to Policy 7.6.

Policy 7.6 refers to the possibility of a new settlement being needed through the next Local Plan. It is noted that a strategic scale development for a new settlement of 1,000 dwellings has been promoted through Draft GNLP at land to the west of Marsham (Site Ref. GNLP0229). It is noted that new settlements typically take much longer to proceed through the planning processes than originally predicted, largely because they are complex and require significant levels of primary infrastructure to be provided. It is normally the case that new settlements are not able to deliver policy compliant levels of affordable housing, at least not in the initial stages, mainly because of the costs associated with the delivery of transport and utilities infrastructure improvements and new community facilities. It is suggested that the timescales for the delivery of new settlements, and the ability of these types of development to provide policy compliant levels of affordable housing, should be fully understood and assessed before they are considered as an option for a future Local Plan. No modifications are requested.

I support this policy and only wish that preparations were more advanced at this time thereby obviating the need to permit less sustainable and more damaging forms of development.

Glavenhill’s previously submitted comments on the Regulation 18C plan still stand.

Glavenhill consider that a new Garden Village at Hethel should be allocated now and the choice to not allocate the Stanfield Garden Village site at Hethel within this plan period is a missed opportunity. Identification of a first phase of development on this site within the plan period would provide a clear commitment to delivering the plan’s stated Vision and a clear means to meeting that Vision in a sustainable manner.

Glavenhill and its developer partner Human Nature have undertaken a considerable amount of site assessment and technical work to date and are confident that a first phase of development could be delivered within the plan period. In order to supplement the Vision and Delivery Documents and Technical Reports submitted with previous representations, we attach a Delivery Statement prepared by Human Nature which sets out how the site will be brought forward using innovations for the accelerated delivery of affordable homes, the potential for public/private partnership and IMPACT investment.

If an allocation for a new Garden Village at Hethel is not made within this plan period, then policy 7.6 Preparing for New Settlements is supported. It is a sensible approach to start preparing for delivery of a new Garden Village as soon as possible and we are ready to work with the GNDP to assist with the site options assessment and technical consultation immediately, having undertaken a significant amount of work to assess constraints and delivery already.

We are confident that there are no over-riding constraints to development and that a new Garden Village can be delivered in a sustainable manner at Hethel. In addition to the lack of technical constraints, the site has little requirement of upfront major road infrastructure, which had hampered many other projects nationally.

We are also confident that the site at Hethel represents the best location for a new Garden Village, in terms of its geographical location within the Cambridge-Norwich Tech corridor, its alignment with strategic policies, the focus that it can bring to investment and economic growth within this key area and the lack of technical constraints to development or impact upon the amenity of local residents. The site has been selected on its technical, environmental and market suitability coupled with the ambition to deliver an exemplar scheme on all levels.

In preparing for a new settlement we strongly advise that sufficient evidence in relation to the historic environment (including a Heritage Impact Assessment) is prepared to assist in the new settlement site selection process.

Policy 7.6 could make it clear what types of evidence will be needed, including heritage impact assessment.

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

4.3 A new settlement at Honingham Thorpe, GNLP4015A-G, would offer the opportunity to provide housing in a holistic and sustainable way in order to create a vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that new garden settlements can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares. Provision of a Country park, with enhanced provision to the Wensum and river valley, would create a significant area of green space, something which has become more important than ever in light of the pandemic. The relationship of the site with the Food Enterprise Park would support a key growth area and the emerging agri-tech corridor, creating a holistic and mutually supportive relationship between the new community, the Food Enterprise Park, Easton College, Norwich Research Park and the UEA.
4.4 As the country’s largest housing association and a registered charity, Clarion have an exemplary record for quality, social and environmental responsibility, delivery at scale and an unrivalled commitment to legacy, stewardship, and community issues. They recognise that quality and social purpose must be at the heart of development, and that the opportunity to develop on a large scale brings with it both dedicated to delivering an exemplar settlement which embodies the traditional Norfolk settlement, supports the region’s world-renowned Agri-Tech corridor, considers the UK’s commitment to reduce carbon emissions to net zero by 2050, helping to place the area at the forefront of the transition to a post carbon economy.
4.5 Clarion support the aims of the GNLP to provide better places, with multi-functional green spaces seeking to enhance the landscape, biodiversity, and connectivity, as well as the draft policy requirements for water conservation, energy efficiency, and decentralised energy generation as a means of contributing to national targets for carbon neutrality. However, the proposed carrying forward of allocations and concentration of growth to existing urban areas is considered to be misaligned with the aspirations of the Greater Norwich Local Plan, particularly in the context of Norwich City Council having declared a climate emergency and pledging to be carbon neutral by 2030, and the national target of 2050. Such an approach is considered to fail to adequately adapt to the changing circumstances and priorities of the Greater Norwich area, and beyond.

See attachment for full representation

See attachment for full representation

Brown & Co are instructed by Clarion Housing Group to respond to the pre submission draft Greater Norwich Local Plan that is currently at its Regulation 19 consultation stage.

It is considered that the draft Plan is unsound, as the strategy proposed is neither justified not effective. It is thought that sites GNLP0415A-G, collectively known as Honingham Thorpe offer an appropriate opportunity to deliver growth differently, creating a truly sustainable community which paves the way for the region to become the UK leader in clean growth whilst raising the standards for design and placemaking.

4. Conclusions

4.1 The GNLP in its current form is not considered to be sound as the strategy fails to adequately deliver on the overall purpose of the plan, in particular addressing the challenges of climate change and supporting ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy or to create truly beautiful places or spaces. The draft GNLP recognises the need to deal with the challenges of climate change and carbon neutrality and adapt accordingly, however it seeks to deliver growth through a traditional delivery model which perpetuates inherently inefficient, unsustainable, and uninspiring development.

4.2 Additionally, the strategy is considered to be ineffective as there is a significant reliance upon sites which have failed to deliver during the current plan period, with some sites having been originally allocated in previous iterations of the Local Plan, dating as far back as 2004. Continuing to roll forward sites which have failed to deliver in line with the housing trajectory places the strategy for growth at risk and undermines the Plan led approach. Insufficient evidence has been provided to demonstrate the ability of these, and other sites, to deliver within this plan period, with a number of sites having no promoter or developer on board.

4.3 A new settlement at Honingham Thorpe, GNLP4015A-G, would offer the opportunity to provide housing in a holistic and sustainable way in order to create a vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that new garden settlements can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares. Provision of a Country park, with enhanced provision to the Wensum and river valley, would create a significant area of green space, something which has become more important than ever in light of the pandemic. The relationship of the site with the Food Enterprise Park would support a key growth area and the emerging agri-tech corridor, creating a holistic and mutually supportive relationship between the new community, the Food Enterprise Park, Easton College, Norwich Research Park and the UEA.

4.4 As the country’s largest housing association and a registered charity, Clarion have an exemplary record for quality, social and environmental responsibility, delivery at scale and an unrivalled commitment to legacy, stewardship, and community issues. They recognise that quality and social purpose must be at the heart of development, and that the opportunity to develop on a large scale brings with it both dedicated to delivering an exemplar settlement which embodies the traditional Norfolk settlement, supports the region’s world-renowned Agri-Tech corridor, considers the UK’s commitment to reduce carbon emissions to net zero by 2050, helping to place the area at the forefront of the transition to a post carbon economy.
4.5 Clarion support the aims of the GNLP to provide better places, with multi-functional green spaces seeking to enhance the landscape, biodiversity, and connectivity, as well as the draft policy requirements for water conservation, energy efficiency, and decentralised energy generation as a means of contributing to national targets for carbon neutrality. However, the proposed carrying forward of allocations and concentration of growth to existing urban areas is considered to be misaligned with the aspirations of the Greater Norwich Local Plan, particularly in the context of Norwich City Council having declared a climate emergency and pledging to be carbon neutral by 2030, and the national target of 2050. Such an approach is considered to fail to adequately adapt to the changing circumstances and priorities of the Greater Norwich area, and beyond.

Please see the section addressing Policy 7.6 in the attached representations submitted on behalf of R Mason in support of the allocation of Land at Rightup Lane, Wymondham

Recommendation: Policy 7.6 should be deleted from the GNLP.

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

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

Please see the section addressing Policy 7.6 in the attached representations submitted on behalf of the Trustees of the WJ Gowing 1985 Settlement and the Trustees of the Howard Trust and Pigeon Capital Management 2 in support of the allocation of Land north of Brecklands Road, Brundall.

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

Please see the section addressing Policy 7.6 in the attached representations submitted on behalf of Michael and Jackie Buxton and Pigeon Capital Management 2 Ltd in support of the allocation of Land at Dereham Road, Reepham.

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

Response to the Greater Norwich Local Plan Regulation 19 consultation: Policy 7.1 – Norwich Urban Area including the fringe villages
Policy 7.6 – Preparing for New Settlements
This response addresses significant flaws in the classification of Honingham as being part of the urban fringe, linked to Easton, under Policy 7.1, and the proposal of a Garden Village at Honingham Thorpe under Policy 7.6.
The proposals are flawed on the following grounds:
• Insufficient account has been taken of the dramatic change and decrease in the retail offering in Norwich, which provides for a significant redevelopment from retail to housing. These changes are very likely to provide a significant increase in housing development, thereby reducing the need for “garden villages” in Norfolk.
• Policy 7.1 links the village of Honingham with Easton, which is designated as urban fringe. Honingham is, however, a rural village with a long history and certainly not urban fringe. Hence it is erroneous and damaging to link the village with Easton and consider the impact of massive development in this context. Arguably, this is deliberately misleading and seeks to provide justification for the plans.
• The proposed garden village at Honingham Thorpe under Policy 7.6, if it were to proceed would swamp the village of Honingham and totally destroy the culture, heritage and ambiance of the locality.
• The provision of the garden village will significantly and adversely affect the rural nature of this village being in a prominent position near to the heritage assets of the war memorial and heritage cottages.
• The village cannot adequately cope with further housing; it has very limited infrastructure of road networks, and no medical facilities, shops or schools.
• There are few job opportunities in the area. The inhabitants of the proposed houses in the urban fringe of Easton and Honingham, and the garden village, would almost certainly have to commute to Norwich, adding to further traffic congestion.
• The village has a very limited bus service, with a request stop only outside of the main village. The bus schedule is not conducive to being used by those travelling to work as the service stops at 5pm.
• The drainage in Honingham is already under stress and flooding on The Street has become a significant issue, further housing would only exacerbate the problem.
• The result of any development in Honingham would turn a small rural village with considerable identity and heritage into an urban fringe of Norwich. Such a development would be entirely counter to the ethos of Norfolk as a rural county.

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

See attachment.

Please see the section addressing Policy 7.6 in the attached representations submitted on behalf of the Hethersett Consortium in support of the allocation of Land at Hethersett.

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

Please see the section addressing Policy 7.6 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land west of Nelson Road, Diss.

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

Please see the section addressing Policy 7.6 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land at Walcot Green Lane, Diss.

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

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.

The policy would benefit from some additional policy wording and alterations in the interest of providing further support and direction.
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.