Key Service Centres Assessment Booklets

This submission recommends that area GLNP2149 be more clearly defined as outside the Blofield settlement limit and all references to area GLNP2149 be removed from the planning documentation as its presence suggests it remains an area identified for potential future development and contrary to reasons defined within the Appeal Decision (Ref: APP/K2610/W/19/3220992).

I believe that the Local Plan as published is unsound because references to Area GLNP2149 appears to suggest that it is an area remaining under consideration for potential future development.

Area GLNP2149 has been subject to a planning application (Ref: 20181043, dated 20 June 2018). This application was refused by notice on 15 August 2018.

An appeal was lodged (Ref: APP/K2610/W/19/3220992) and was subject to an exhaustive review and investigation following which the decision to dismiss was made and published on 09 May 2019.

The Appeal Decision to dismiss confirmed that area is outside of the current defined settlement limit, determined that develoment would; 'effect on the character and appearance of the area.'

Specifically; 'would comprise a significatly harmful incursion of piecemeal housing development within a valuable belt of natural vegetation which helps shield the defined built-up area of this part of Blofield from the adjacent major road,' and 'would have a detrimental impact on the landscape setting of this part of the village and be of significant harm to the character and appearance of the area.'

The decision also comments that the proposed development would; 'encroach in a rather incongruous fashion beyond the straight edge of the defined settlement boundary and in to an area of naturalised vegetation that joins and augments the narrower tree belt alongside the busy A47 dual carriageway trunk road.' Any access would require; 'an extension to a quite long and very narrow private access currently serving four houses.'

Other submissions suggesting minor adjustments to access from the main road would somehow make access suitable and compliant are simplistic and ignorant.

This submission recommends that area GLNP2149 be more clearly defined as outside the Blofield settlement limit and all references to area GLNP2149 be removed from the planning documentation as its presence suggests it remains an area identified for potential future development and contrary to reasons defined within the Appeal Decision (Ref: APP/K2610/W/19/3220992).

The Allocation REP2 should be discarded as it is no longer 'feasible' or relevant and REP1 should be discarded as it is no longer deliverable or 'fit for purpose'. Other Allocations should be re-examined that were previously supported by Broadland (GNLP0183) for 65-70 dwellings, and the Town Council (GNLP0180) for 35 dwellings. Both these sites would accommodate the required number of houses (100) as required by the GNLP proposals for Reepham. They are well located in the settlement and have satisfactory vehicle access and good footpath links with the Town centre.

The Reepham Assessment is flawed as the Allocations REP1 and REP2 are not in accordance with the requirements under the Broadland adopted Site Allocations DPD of 2016, or proposed GNLP.
REP2 is no longer able to accommodate 20 Market/Affordable homes due to the implementation of planning consent 20180963.
REP1 the current application 20200847 is for 141 houses and no Sports Hall despite the requirement of approximately 100 homes and Sports Hall. There is a current application 20201183 for a completely seperate Sport Hall location in a location where Broadland Planning Officers have indicated that no further building should take place.

GNLP0480 should be allocated for SME scale housing and / or residential care accommodation.

GNLP 0480 is being promoted by Glavenhill on behalf of the landowner for much needed SME scale housing and / or residential care accommodation and can, through appropriate landscaping, offer long term protection to the Strategic Gap between Hethersett and Wymondham.

Glavenhill support the Council’s conclusion that the site is suitable for residential
development but contend that the Council’s rationale for not allocating it is unjustified and therefore ‘unsound’

GNLP0494R is recommended for allocation. It is suitable, available and deliverable and its allocation for residential use is a ‘sound’ proposition.

The Council’s decision not to allocate more housing in the Poringland Area is considered by Glavenhill to be unjustified and therefore unsound.

It is Glavenhill’s opinion that it is appropriate to supplement local housing provision to support local needs and the continued vitality and viability of this Key Service Centre. This can and should be done through the allocation of suitable and deliverable sites such as Land to the south of Poringland Road, Upper Stoke (GNLP0494R).

Land to the north of Caistor Lane, Caistor St Edmund (GNLP site reference GNLP0485R) can through its allocation provide for a new country park, a site for a much needed new primary school, in the
order of 180 new homes and a generous and beneficial package of community sought facilities.

The proposed allocation site is a suitable, available and deliverable proposition which can deliver
much needed facilities which fail to be planned for within the GNLP Regulation 19 Document.

The site should be allocated as a justified, positive and a wholly ‘sound’ proposition.

The discounting of the proposed allocation site (GNLP0485R) is unjustified and unsound.

In addition to supplementing housing supply, the allocation of this site, will provide much
needed new primary school and community facilities which the Council has failed to consider.

The benefits to be delivered through the provision of a new Country Park at the site have failed to be assessed by the Council. The discounting of this site as a potential green infrastructure resource is unjustified.

The discounting of the site over access and highway concerns has also been demonstrated to be
unjustified.

See enclosed representations for further detail.

GNLP SHOULD NOT BE ADOPTED IN ITS CURRENT FORM
Removal of site GNLP0503 from the GNLP in accordance with the landowners wishes.
Removal of GNLP0503 due to undeliverability of the site due to the caveat ….” subject to provision of a safe access and a continuous footway at the west side of
Dereham Road from the site access to Pottles Alley”.
Removal of the 20 dwellings from the housing numbers specified for Hingham/Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an
alternative site to come forward.
AND
GNLP SHOULD NOT BE ADOPTED
Proper regard should be given to the representations made in opposition to GNLP0520 being allocated for development, especially with regard to flooding issues,
potential impact on historical heritage, the protection of valued landscape, the adequacy of footway links and proximity to ALL of the town’s facilities.
GNLP0520 should be removed from the plan.
Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an alternative site to come forward and for representations to be made.44
Consideration MUST be given to if a site would provide a benefit alongside the proposed housing development, and if it would enable opportunity to achieve the
aspirations of the community/town council for “future proofing” Hingham to be able to provide facilities to a growing community.

Allocations of any sites should be based on firm evidence that proposals made in order to mitigate, are actually feasible and achievable.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence
Representation 1 -
Site specific – relating to GNLP0503
Representation regarding the inclusion in the GNLP of (Land north of Springfield Way and west of Dereham
Road) GNLP0503, for develop of approximately 20 homes
Representations 2
Site specific GNLP0520
Representation regarding the inclusion in the GNLP of “Land south of Norwich Road, Hingham GNLP0520”
Representation 3
With regard to the site selection process:
The rejection of sites as reasonable alternatives, therefore no reasonable alternatives were put forward for the Regulation 18c consultation.
Representation 4
Regarding the plan making process
Representation 5
Policy 5.36. Two sites are allocated providing for at least 100 new homes in the key service centre (one for 80 homes, one for 20 homes). There are no carried forward residential allocations and a total of 20 additional dwellings with planning permission on small sites. This gives a total deliverable housing commitment for the key service centre of 120 homes between 2018 – 2038.
Representation 6 - Infrastructure requirements
Representation 7 - Settlement map
Representation 8 - Green Infrastructure Study
Representation 9 - Equality Impact Assessment

Recommendation: In order to provide greater certainty for the plan period, it will be necessary to increase the amount of housing in Key Service Centres, such as Loddon, which is capable of accommodating housing growth within the plan period. This provides the opportunity to allocate Land to the North and South of Norton Road, Loddon.

Policy 1- the Sustainable Growth Strategy

Policy 1 outlines the broad strategic approach for the plan period, which includes the proposed housing requirement and housing commitments.

Housing requirement

Paragraph 65 of the NPPF requires that a housing requirement is established within a Local Plan, which shows the extent to which their identified housing need can be met over the plan period.

The foreword to the Draft Local Plan identifies a "requirement" for about 49,500 homes over the period 2018-38. Paragraph 177 and Table 6 of the GNLP however identify a housing "target" for only 40,541 homes and Policy 1 identifies a "need" for around 40,550 homes.

The GNLP is therefore not only ambiguous such that it may not be effective, it also does not accord with national policy and therefore would benefit from a set housing requirement in strategic policies.

Recommended modification: to provide consistent references throughout the Local Plan to the 'housing requirement' as per Paragraph 65 of the NPPF.

The minimum housing need

The need for 40,541 homes is identified as having been calculated using the standard method. The standard method provides the minimum local housing need and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1. The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.

In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.92 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,388 homes.

Alternatively, the minimum local housing need from 2020 onwards can be calculated using the average household growth over the 10 consecutive years from 2020, namely 2020-30, with

1 As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book.


the affordability ratios of 2019 applied. The average household growth was 394, 505 and 680 respectively and the median workplace-based house price to earnings ratios were 9.01, 6.97 and 9.02 respectively. These figures produce a minimum local housing need of 2,008 homes per annum which equates to 36,148 homes over the period 2020-38. Table 6 of the GNLP identifies that 5,240 homes were completed in 2018-20. In addition to the minimum local housing need of 36,148 over the period 2020-38 this would again produce a minimum local housing need for 41,388 homes over the plan period.

It is therefore apparent that the standard method has been miscalculated within the GNLP and that the minimum local housing need is greater at 41,388 homes.

Recommended modification: In combination with the subsequent considerations, it will therefore be necessary to modify the emerging housing.

Historic under-delivery

In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 25,878 housing completions in the period 2008-20. However, only 20,924 homes have been delivered which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 23.7%. The overestimations of supply can be mainly attributed to the delivery rates of strategic infrastructure projects, and consequently, the ability of large scale SUE's to be delivered across Greater Norwich. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement which is 25% in excess of the minimum need for 40,541 homes. This would produce a housing requirement for 50,676 homes. Our client welcomes the Council's decision to include a substantial buffer of over 20% between its housing requirement and housing supply. This is essential to ensure the plan has sufficient flexibility to meet needs in full across the plan period.

Recommended modification: It is, therefore, recommended that a proposed minimum contingency of 25% is retained as a minimum.

POLICY 5 – HOMES

Policy 5 of the GNLP Draft Strategy sets out a requirement of 33% affordable housing on sites of 10 or more units, even though the 2017 Central Norfolk Strategic Housing Market Assessment (SHMA) identifies that there was a need for 39,486 homes, of which 11,030 represents 28% affordable housing. The affordable requirement should be based on up to date evidence and should be subject to detailed viability testing at a range of scenarios. Therefore, this aspect of Policy 5 will need to be amended.


Recommendation: In order to address this, it will be necessary to either recalculate the affordable housing needs based on the planned supply and then set affordable housing policies accordingly, or to reduce the affordable housing requirement within Policy 5 to 28%.

POLICY 7.3 – KEY SERVICE CENTRES

Paragraph 372 of the GNLP outlines that Key Service Centres have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving rural areas. It also identifies that these roles are intended to continue supported by appropriate levels of development.

The Draft GNLP Strategy states that the Key Service Centres of Acle, Blofield, Brundall, Hethersett, Hingham, Loddon / Chedgrave, Poringland / Framingham Earl, Reepham and Wroxham, will deliver 3,679 homes over the plan period (approximately 7% of the proposed housing growth).

Loddon has one new proposed housing allocation in the Draft GNLP Strategy, which is to the south-east of the settlement (Policy GNLP0312, Land to the east of Beccles Road) for the development of over 180 homes. Land to the north and south of Norton Road would adjoin onto the northwestern boundary of 'Land to the east of Beccles Road' (GNLP0312) and lead to the natural extension of the sustainable settlement of Loddon. The GNLP Loddon and Chedgrave Site Assessment Booklet assesses submitted sites in these settlements for consideration in the GNLP. It states that our client's site is "well related to services, is adjacent to a site which has been preferred for housing allocation, and offers the potential to increase permeability within this part of the town." As a result, the site was shortlisted for further assessment (Stage 6). The Stage 6 Assessment centred on the impacts on highways, flood risk, landscape visual and local services, as further set out in the paragraphs below.

Highways Impact

The initial Highways Authority comments from the Booklet state that Norton Road is not suitable for development traffic, but the southern section of the site may be accessed via the adjacent allocation Land to the east of Beccles (GNLP0312). As outlined with our client's Regulation 18 representations, they agree that suitable accesses can not only be achieved via the neighbouring allocation but also onto Norton Road.

Since the submission of Regulatory 18 representations, our client has commissioned technical transport assessments to evaluate the feasibility of creating two T-junctions on either side of Norton road, to serve both the site's northern and southern sections. At present, a through route via Land to the east of Beccles is not possible as this is a draft allocation (GNLP0312) and does not benefit from an extant consent. Therefore, the Transport Assessment (TA) solely assessed the highway's impact on two proposed Norton Road accesses. The Transport


Assessment recommended that a new footway is included on both sides of Norton Road and an extension of the existing 30mph towards the east. The TA concluded that such a proposal should be considered acceptable on transport-related grounds. Therefore, contrary to the initial Highways Authority comments, this detailed TA has found that it could be feasible to create safe vehicular access onto Norton Road.

Landscape Visual impact

Comments from Development Management raise concerns that the site would "cause harm to the landscape and the rural setting of the Broads." However, no further details are provided. A Landscape and Visual Impact Assessment (LVIA) instructed by our client, states that the views of the Site are considered to be well contained and highly localised within the context of the existing visual environment. The assessment concludes that the Site and receiving environment have the capacity to accommodate a strategic residential scheme. The allocation will not result in significant harm to the landscape character or visual environment and, as such, it is considered that a strategic housing proposal can be successfully integrated in this location.

Flood Risk impact

In terms of the other comments raised in the Loddon and Chedgrave Site Assessment Booklet, the Lead Local Flood Authority (LLFA) outlines that a complete geotechnical investigation will be needed to determine infiltration potential. Nevertheless, the LLFA outlines that "the site is at risk of surface water flooding, but this is not severe enough to prevent development of the site" and mitigation could be provided at the required planning stage." This is further supported in a Flood Risk Assessment (FRA) prepared by our client. The FRA concludes that with appropriate mitigation measures, the risk of flooding from all sources is generally low, and a development proposal can be operated safely and without significantly increasing flood risk elsewhere.

Sustainability

Land to the north and south of Norton Road is considered to be located in a sustainable location as it is easily accessible to Loddon's High Street (less than 10 minutes walk from the site), which has an excellent range of shops, services, employment opportunities and bus stops with a frequent bus service to Norwich city centre (one bus every 30 minutes). Furthermore, there are employment opportunities available at Loddon Industrial Estate (less than 10 minutes walk from the site). By affording sustainable levels of growth to areas such as this it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.


However, the Loddon and Chedgrave Site Assessment Booklet states that if this site was allocated in addition to the two other allocations in Loddon & Chedgrave, "development of this site may overwhelm public services." However, as previously stated in our clients' Regulatory 18 Representations, there is the potential to deliver new community facilities at Land off Norton Road, Loddon, for a range of uses, including public open space. Halsbury Homes Ltd will explore whether it may be possible to deliver additional facilities at the site. There is also the potential for off-site contributions to upgrade existing facilities. Halsbury Homes would welcome the opportunity to engage with the local community to understand what kind of facility will achieve the greatest benefit to the community.

Other Issues

Other technical reports commissioned by our client found there would be no adverse effects (subject to suitable mitigations) on nearby heritage assets, air quality, amenity and noise and trees.

Conclusion

The Loddon and Chedgrave Site Assessment Booklet concludes that the site is considered unsuitable for allocation. However, our client considers that the Councils should consider identifying additional available and deliverable small and medium sized sites from a range of locations capable of accommodating housing growth within the plan period. The site is available and deliverable within the plan period, with site access feasible to both the northern and southern sections of the site. The absence of additional allocations at Loddon is therefore not justified. The resultant disproportionately low level of growth will compromise the vitality of the settlement contrary to paragraph 78 of the NPPF

Recommendation: In order to provide greater certainty for the plan period, it will be necessary to increase the amount of housing in Key Service Centres, such as Loddon, which is capable of accommodating housing growth within the plan period. This provides the opportunity to allocate Land to the North and South of Norton Road, Loddon.

1 As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book.