New, Revised and Small Sites

GNLP 2168
On behalf of J. Alston & Sons Ltd, we set out below our further comments on the additional sites submitted for consideration as part of the Regulation 18 Consultation that closed in March 2018.
The new National Planning Policy Framework was published in July 2018, since the Reg 18 process closed. It is considered relevant to refer to ii in the context of site GNLP2168 about which we previously submitted representations. Certain other aspects have also changed or advanced which are described below.
Our comments with regard to site GNLP 2168 reiterate what we believe to be the attributes of the proposal, as follows:-
* It is consistent with increasing central government support for new garden settlements, as set out in a paper published by the Department for Communities and Local Government in March 2016 titled "Locally Led Garden Villages, Towns and Cities".
* This is further expanded upon in the updated NPPF in which there is specific reference to new settlements (the relevant aspects of which are outlined in further detail below).
* It would allow comprehensive maslerplanning to incorporate all required facilities.
* And would avoid the further need for continuing piecemeal development of the suburbs of Norwich and surrounding market towns, locations that have absorbed their fair share of recent growth and where further substantial growth would be unsustainable, unrealistic and would meet increasingly fierce resistance from the local population who will lake the view their locations have accepted more than enough development.
* The site is discrete.
* It is also in single ownership, which removes the potential obstacle to delivery that multiple ownership can create.
* It has a range of natural amenities, including various wooded areas, some of which is ancient woodland, mature trees and watercourses, all of which would complement a major development.
* The proposed development would enable important and much needed infrastructure improvements to be delivered, including a new connection to the south of Wymondham, off the A 11 and the possible extension of Spooner Row station to enable more frequent usage.
* Development to the south of Wymondham would avoid the need for consideration of any further sites to the north/north east that would compromise the integrity of the strategic gap between Wymondham and Hethersett and would also preserve the natural environment around the historic Kells Oak.

The Reg 18 process that concluded in March 2018 outlined 6 options for consultation. Site GNLP 2168 is consistent with:-

* Options 3 & 5 which refer to a new garden settlement.
* Option 2 which highlights the importance of established transport corridors. Site GNLP 2168 is very compliant with this option, being close to the A 11 and within easy walking distance of two railway stations.
* Option 3 which focuses on the increasingly significant Norwich to Cambridge hi-tech corridor (the A 11 and railway line connect Norwich to Cambridge). The profile of Norwich Research Park continues to rise - it was recently given an outstanding achievement award at the Eastern Daily Press Business awards. The importance of NRP as a major driver of economic growth in Norwich will grow and this can be accelerated by forging ever closer links to Cambridge.
* The ready availability of a range of housing types and tenures on the route of the corridor will encourage footloose organisations to consider Norwich Research Park as a viable location at which to move or establish their business.

Further relevant guidance is contained in the revised National Planning Policy Framework published in July 2018 post the closure of the Reg 18 process.

The NPPF defines sustainable development, the principles of which can be embodied in new garden settlements.

The economic objective requires that sufficient land of the right types is available. The scale of a new garden village achieves that objective.

The social objective focuses on the requirement to support strong, vibrant and healthy communities by ensuring a sufficient number and range of houses can be provided to meet the needs of present and future communities. The social objective also refers to a well designed and safe built environment with accessible services and open spaces that support communities health, social and cultural well being.

It is hard to see how the continuing piecemeal development of "bolt on" sites can deliver the overarching principles underpinning this objective of sustainable development. The evidence is that services are not comprehensively delivered through piecemeal development of the type recently experienced in the GNDP area. On the contrary, undue and unsustainable pressure has been exerted on existing services which local communities have found challenging.

However, once again, the scale of a new garden village will ensure the effective delivery of a genuine, vibrant and fully functioning community.

The environmental objective requires the protection and enhancement of the built and natural environments. Again, effective masterplanning of new settlements can deliver high quality public realm and in respect of site GNLP2 l 68, can provide accessibility to a range of existing features including historic woodlands, mature trees and watercourses.

The built environment the NPPF is seeking to encourage could be created as a consequence of the scale of development proposed at site GNLP2168. Best practice in masterplanning, design, sustainability, carbon reduction and minimisation of waste & pollution can be viably incorporated. Piecemeal development which lacks required scale will find it very difficult if not impossible to deliver the environmental objective laid out in the NPPF.

The delivery of these three fundamental objectives is enshrined in the presumption of sustainable development. It is believed our above comments demonstrate the substantial benefits of a new garden settlement on site GNLP2168 in a way that is entirely consistent with the principles underpinning the NPPF. Of more significance is that GNLP2 l 68 satisfies a number of key criteria of the GNDP in planning for future growth. It is difficult to see how an alternative location proposed within the GNLP area could deliver on these key specific objectives.

Paragraph 72 in the NPPF clearly states the "supply of new homes can often be best achieved through planning for larger scale developments, such as new settlements or significant extensions to existing villages & towns provided they are well localed and designed and supported by the necessary infrastructure and facilities".

In our above comments, we have demonstrated compliance with paragraph 72 a) in respect of taking opportunities presented by existing infrastructure, the area's economic potential and the scope for net environmental gains. The size of the development would ensure consistency with 72 b) and 72 c).

Section 8 of the NPPF applies to "Promoting Healthy and safe communities" Such a principle would be at the heart of maslerplanning and design of a new garden settlement on site GNLP2168.

Section 9 applies to sustainable transport. Again, existing infrastructure enables this to be provided at site GNLP2168 but equally, a development at the site could facilitate investment to further improve the existing networks as outlined above.

It is completely accepted by J. Alston & Sons Ltd and Harvey & Co that large settlements such as a new garden village can be challenging to deliver. Justifiable concerns have been raised in this respect and we recognise the essential requirement to provide the necessary confidence of delivery. With this in mind, a short list of prospective partners with the experience, resources and expertise required to deliver the project has been drawn up since the Reg 18 process closed. Negotiations are presently underway with a view to concluding a promotion agreement with the preferred partner in early 2019.

In summary, It Is because of all the points mentioned above that we believe site GNLP 2168 would be suitable to accommodate the long term housing growth of the Norwich Polley Area. There are many aspects of the guidance set out in the recently published NPPF with which new garden settlements In general and site GNLP2168 specifically are consistent.

Furthermore, site GNLP2168 is far more compliant with the options consulted on by the GNLP than other proposed new garden settlements which do not benefit from comparable transport connections, or the strategically important location on the Norwich
-Cambridge hi-tech corridor
And the essential need to give appropriate confidence of delivery is fully understood. Measures have been taken to ensure a reliable and effective delivery mechanism is in place

GNLP2169
The following comments are made on behalf of J. Alston & Sons Ltd in respect of site reference GNLP 2169, about which we submitted representations as part of the Regulation 18 process that closed in March 2018.

The response to our submission is that this site is situated within an area allocated by the last local plan for 1,230 dwellings (Policy WYM3) and would therefore not be suitable for inclusion in the next round of allocated sites.

The current allocation is acknowledged to be correct. However, the site is small, at 1.36 hectares. It is outside the control of the consortium of landowners and their promoter who is responsible for the delivery of the 1 ,230 houses. That number could therefore be delivered on land that excludes site GNLP 2169.

Should this be the case, site GNLP 2169 would remain undeveloped and would not be allocated for further development, even though it would be surrounded by new development.

Provision, therefore, needs to be made for the development of site GNLP 2169 in the event that the 1,230 houses associated within the current local plan are delivered on surrounding land and leave site GNLP 2169 undeveloped.

GNLP 2168
On behalf of J. Alston & Sons Ltd, we set out below our further comments on the additional sites submitted for consideration as part of the Regulation 18 Consultation that closed in March 2018.
The new National Planning Policy Framework was published in July 2018, since the Reg 18 process closed. It is considered relevant to refer to ii in the context of site GNLP2168 about which we previously submitted representations. Certain other aspects have also changed or advanced which are described below.
Our comments with regard to site GNLP 2168 reiterate what we believe to be the attributes of the proposal, as follows:-
* It is consistent with increasing central government support for new garden settlements, as set out in a paper published by the Department for Communities and Local Government in March 2016 titled "Locally Led Garden Villages, Towns and Cities".
* This is further expanded upon in the updated NPPF in which there is specific reference to new settlements (the relevant aspects of which are outlined in further detail below).
* It would allow comprehensive maslerplanning to incorporate all required facilities.
* And would avoid the further need for continuing piecemeal development of the suburbs of Norwich and surrounding market towns, locations that have absorbed their fair share of recent growth and where further substantial growth would be unsustainable, unrealistic and would meet increasingly fierce resistance from the local population who will lake the view their locations have accepted more than enough development.
* The site is discrete.
* It is also in single ownership, which removes the potential obstacle to delivery that multiple ownership can create.
* It has a range of natural amenities, including various wooded areas, some of which is ancient woodland, mature trees and watercourses, all of which would complement a major development.
* The proposed development would enable important and much needed infrastructure improvements to be delivered, including a new connection to the south of Wymondham, off the A 11 and the possible extension of Spooner Row station to enable more frequent usage.
* Development to the south of Wymondham would avoid the need for consideration of any further sites to the north/north east that would compromise the integrity of the strategic gap between Wymondham and Hethersett and would also preserve the natural environment around the historic Kells Oak.

The Reg 18 process that concluded in March 2018 outlined 6 options for consultation. Site GNLP 2168 is consistent with:-

* Options 3 & 5 which refer to a new garden settlement.
* Option 2 which highlights the importance of established transport corridors. Site GNLP 2168 is very compliant with this option, being close to the A 11 and within easy walking distance of two railway stations.
* Option 3 which focuses on the increasingly significant Norwich to Cambridge hi-tech corridor (the A 11 and railway line connect Norwich to Cambridge). The profile of Norwich Research Park continues to rise - it was recently given an outstanding achievement award at the Eastern Daily Press Business awards. The importance of NRP as a major driver of economic growth in Norwich will grow and this can be accelerated by forging ever closer links to Cambridge.
* The ready availability of a range of housing types and tenures on the route of the corridor will encourage footloose organisations to consider Norwich Research Park as a viable location at which to move or establish their business.

Further relevant guidance is contained in the revised National Planning Policy Framework published in July 2018 post the closure of the Reg 18 process.

The NPPF defines sustainable development, the principles of which can be embodied in new garden settlements.

The economic objective requires that sufficient land of the right types is available. The scale of a new garden village achieves that objective.

The social objective focuses on the requirement to support strong, vibrant and healthy communities by ensuring a sufficient number and range of houses can be provided to meet the needs of present and future communities. The social objective also refers to a well designed and safe built environment with accessible services and open spaces that support communities health, social and cultural well being.

It is hard to see how the continuing piecemeal development of "bolt on" sites can deliver the overarching principles underpinning this objective of sustainable development. The evidence is that services are not comprehensively delivered through piecemeal development of the type recently experienced in the GNDP area. On the contrary, undue and unsustainable pressure has been exerted on existing services which local communities have found challenging.

However, once again, the scale of a new garden village will ensure the effective delivery of a genuine, vibrant and fully functioning community.

The environmental objective requires the protection and enhancement of the built and natural environments. Again, effective masterplanning of new settlements can deliver high quality public realm and in respect of site GNLP2 l 68, can provide accessibility to a range of existing features including historic woodlands, mature trees and watercourses.

The built environment the NPPF is seeking to encourage could be created as a consequence of the scale of development proposed at site GNLP2168. Best practice in masterplanning, design, sustainability, carbon reduction and minimisation of waste & pollution can be viably incorporated. Piecemeal development which lacks required scale will find it very difficult if not impossible to deliver the environmental objective laid out in the NPPF.

The delivery of these three fundamental objectives is enshrined in the presumption of sustainable development. It is believed our above comments demonstrate the substantial benefits of a new garden settlement on site GNLP2168 in a way that is entirely consistent with the principles underpinning the NPPF. Of more significance is that GNLP2 l 68 satisfies a number of key criteria of the GNDP in planning for future growth. It is difficult to see how an alternative location proposed within the GNLP area could deliver on these key specific objectives.

Paragraph 72 in the NPPF clearly states the "supply of new homes can often be best achieved through planning for larger scale developments, such as new settlements or significant extensions to existing villages & towns provided they are well localed and designed and supported by the necessary infrastructure and facilities".

In our above comments, we have demonstrated compliance with paragraph 72 a) in respect of taking opportunities presented by existing infrastructure, the area's economic potential and the scope for net environmental gains. The size of the development would ensure consistency with 72 b) and 72 c).

Section 8 of the NPPF applies to "Promoting Healthy and safe communities" Such a principle would be at the heart of maslerplanning and design of a new garden settlement on site GNLP2168.

Section 9 applies to sustainable transport. Again, existing infrastructure enables this to be provided at site GNLP2168 but equally, a development at the site could facilitate investment to further improve the existing networks as outlined above.

It is completely accepted by J. Alston & Sons Ltd and Harvey & Co that large settlements such as a new garden village can be challenging to deliver. Justifiable concerns have been raised in this respect and we recognise the essential requirement to provide the necessary confidence of delivery. With this in mind, a short list of prospective partners with the experience, resources and expertise required to deliver the project has been drawn up since the Reg 18 process closed. Negotiations are presently underway with a view to concluding a promotion agreement with the preferred partner in early 2019.

In summary, It Is because of all the points mentioned above that we believe site GNLP 2168 would be suitable to accommodate the long term housing growth of the Norwich Polley Area. There are many aspects of the guidance set out in the recently published NPPF with which new garden settlements In general and site GNLP2168 specifically are consistent.

Furthermore, site GNLP2168 is far more compliant with the options consulted on by the GNLP than other proposed new garden settlements which do not benefit from comparable transport connections, or the strategically important location on the Norwich
-Cambridge hi-tech corridor
And the essential need to give appropriate confidence of delivery is fully understood. Measures have been taken to ensure a reliable and effective delivery mechanism is in place

GNLP2169
The following comments are made on behalf of J. Alston & Sons Ltd in respect of site reference GNLP 2169, about which we submitted representations as part of the Regulation 18 process that closed in March 2018.

The response to our submission is that this site is situated within an area allocated by the last local plan for 1,230 dwellings (Policy WYM3) and would therefore not be suitable for inclusion in the next round of allocated sites.

The current allocation is acknowledged to be correct. However, the site is small, at 1.36 hectares. It is outside the control of the consortium of landowners and their promoter who is responsible for the delivery of the 1 ,230 houses. That number could therefore be delivered on land that excludes site GNLP 2169.

Should this be the case, site GNLP 2169 would remain undeveloped and would not be allocated for further development, even though it would be surrounded by new development.

Provision, therefore, needs to be made for the development of site GNLP 2169 in the event that the 1,230 houses associated within the current local plan are delivered on surrounding land and leave site GNLP 2169 undeveloped.