Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 21892

Received: 12/03/2020

Respondent: Barton Willmore

(Representations made on behalf of KCS Developments)

We do not object to the vision and objectives however the broad vision for Greater Norwich should also reference the need to accelerate the delivery of homes in accessible locations to support the target level of jobs growth in order to maintain and grow a robust, vibrant and diverse economy.
We support the approach within the vision of building most new homes in and around Norwich and in the Cambridge Norwich Tech Corridor, with the recognition that suburbs, towns and villages will be vibrant places to live with good access to services and facilities, supported by new housing and jobs. We suggest that there does however need to be more emphasis on delivering new housing within towns and villages to support this part of the vision. This needs to be followed through into the proposed hierarchy and distribution of new housing growth within the GNLP.

Object

Representation ID: 21894

Received: 12/03/2020

Respondent: Barton Willmore

(Representations made on behalf of KCS Developments)

The GNLP advises that settlements within the bottom three tiers of the current framework would be merged into a single lowest tier of “Village Clusters” within a settlement hierarchy of just four tiers. This would serve to underplay the significance of Spooner Row as a service centre in terms of its scale, function and facilities as well as its capacity to accommodate future growth within the Cambridge to Norwich Growth Tech Corridor. This approach is flawed.
The grouping together of “Service Villages”, “Other Villages” and “Smaller Rural Communities and the Countryside” into a single lowest tier within a settlement hierarchy comprising just four rather than six tiers as is currently the case would significantly undermine the function and role that Service Villages can play in accommodating future growth.
Service Villages such as Spooner Row include a range of functions and services which are more closely aligned to the functions and service characteristics of Service Centres than they are to Other Villages which are defined by their offer of just a very basic, narrow range of services. Service Villages such as Spooner Row are much more sustainable settlements capable of accommodating much higher housing growth than Other Villages and Smaller Rural Communities and the Countryside. Spooner Row benefits from a range of local services such as primary school, village hall, church and a public house. Development of the settlement presents the opportunity to enhance these facilities and also provide a village shop. Spooner Row benefits from being well connected due to its situation along the A11 corridor and benefits from a railway station with services to Norwich and Cambridge which is key to its future growth.
If the settlement hierarchy is to continue to be rationalised into four tiers, we would recommend that Service Centres and Service Villages should be combined into a single 3rd tier and Other Villages combined with Smaller Rural Communities and the Countryside to form a 4th tier.
Proposed Distribution of Housing
In terms of the proposed distribution of housing within the hierarchy, the preferred option selected by the Council combines concentrating most of the development in and around Norwich and on the Cambridge Norwich Tech Corridor, with an element of dispersal to villages to support thriving rural communities.
Our Client supports this approach in principle as it would serve to ensure that there is a focus for delivering development along the A11 corridor, fulfilling the Spatial Objectives of supporting the Cambridge to Norwich Tech Corridor, plus locating growth near to jobs and infrastructure. The merging of a number of tiers within the Settlement Hierarchy however does not support this proposed distribution of growth, with Service Villages potentially missing out on growth by being categorised within Village Clusters even if they are situated within the Tech Corridor.
The GNLP proposes to allocate and permit housing growth of 4,024 homes within village clusters. This accounts for circa 9% of the total for Greater Norwich in the plan period. As discussed above, village clusters comprise of settlements which are currently categorised as service villages, other villages, smaller rural communities and the countryside. This accounts for a large proportion of settlements within Greater Norwich. The Core Strategy identifies 61 service villages and 39 other villages. The distribution of 4,024 homes across these settlements would result in a very low level of growth within each (circa 42 within each over the Plan Period) which is not likely to support their continued sustainability or viability.
There are clear differences between settlements within the village clusters and if the proposed hierarchy is to be adopted there needs to be clear recognition that larger villages such as Spooner Row should accommodate more growth than smaller villages which were previously lower in the settlement hierarchy.
Spooner Row is situated along the A11 corridor within the Cambridge to Norwich Tech Corridor. As well as being situated along the A11 corridor it also benefits from a railway station which is key to the settlement’s future growth. The proposed distribution of growth would result in this highly sustainable settlement which has the capacity to accommodate a generous amount of growth missing out on growth and the potential to improve its local services.
The distribution of growth should explicitly support more growth in certain service villages such as Spooner Row and more limited growth in other villages and smaller rural communities to reflect their sustainability and potential for additional growth.

Object

Representation ID: 21895

Received: 12/03/2020

Respondent: Barton Willmore

(Representations made on behalf of KCS Developments)

Our Client does not support the overall approach to village clusters. Firstly, our Client objects to the grouping together of several settlement sizes into one level within the hierarchy for the reasons discussed earlier within these representations. There are clear differences between settlements within the village clusters and if the proposed hierarchy is to be adopted there needs to be clear recognition that larger villages such as Spooner Row should accommodate more growth than smaller villages which were previously lower in the settlement hierarchy.
Secondly, our Client has concerns regarding the note within Policy 7.4 which states that sites between half a hectare and 1 hectare will be “particularly welcomed”. Sites of this size are likely to be more appropriate within other villages or smaller rural communities however there is no recognition that settlements which are currently categorised as service villages could accommodate a greater level of housing growth.

Object

Representation ID: 21896

Received: 12/03/2020

Respondent: Barton Willmore

(Representations made on behalf of KCS Developments)

Spooner Row benefits from being served by a railway station, a primary school, village hall, church and a public house. The settlement currently lacks any shop however development of our Client’s sites can help to facilitate this. Within the adopted Core Strategy Spooner Row is specifically identified as a settlement which may be considered for additional development however the settlement is effectively downgraded within the GNLP by including it within the broad category of “village clusters”.

Comment

Representation ID: 22263

Received: 16/03/2020

Respondent: Barton Willmore

Q1 & Q2) Please comment on or highlight any inaccuracies within the
introduction & Is the overall purpose of the Plan Clear?
2.3 Recognition of the role of the A11, and Cambridge Norwich Tech Corridor is welcomed, but
this needs to be reflected better in the wider growth strategy. The chapter also highlights
some positive things about the sustainability agenda – and the impacts of this – notably the
potential ban on gas boilers, phasing out of diesel cars etc. However, this places even more
emphasis on the need for growth to be in sustainable locations that have their immediate
needs served from a local community perspective. There is a danger that those less affluent
in society are impacted harder – due to cost associated with electric vehicles and
decarbonising, and this places an even greater need for development to be planned in
settlements of sufficient critical size to support a wider range of local services, and in a
comprehensive manner to serve the needs of the local population and minimise the need to
travel for smaller journeys – i.e. trips to a local convenience store, to drop children at primary
school, or to have access to an area of parkland/open space.
2.4 Accordingly, we do not support the Authorities’ proposal to ‘reserve’ the allocation of 1,200
homes to Villages as part of a separate Plan document. This approach pre-judges that is the
right number of homes to be allocated, before a full assessment of where housing could most
sustainably be accommodated. Some villages may have sufficient services to support small
scale growth, particularly where they are located within the wider A11 and Tech Corridors,
or served by public transport, but directing additional homes to Villages (many of which have
limited to zero services) on a very small scale as advocated – i.e. maximum 1 hectare in size
but accommodating between 15 and 25 units – as advocated in the Village clusters plan and
referenced in paragraphs 25 and 26, risks being totally at odds with the principles of
sustainable development.Q1 & Q2) Please comment on or highlight any inaccuracies within the
introduction & Is the overall purpose of the Plan Clear?
2.3 Recognition of the role of the A11, and Cambridge Norwich Tech Corridor is welcomed, but
this needs to be reflected better in the wider growth strategy. The chapter also highlights
some positive things about the sustainability agenda – and the impacts of this – notably the
potential ban on gas boilers, phasing out of diesel cars etc. However, this places even more
emphasis on the need for growth to be in sustainable locations that have their immediate
needs served from a local community perspective. There is a danger that those less affluent
in society are impacted harder – due to cost associated with electric vehicles and
decarbonising, and this places an even greater need for development to be planned in
settlements of sufficient critical size to support a wider range of local services, and in a
comprehensive manner to serve the needs of the local population and minimise the need to
travel for smaller journeys – i.e. trips to a local convenience store, to drop children at primary
school, or to have access to an area of parkland/open space.
2.4 Accordingly, we do not support the Authorities’ proposal to ‘reserve’ the allocation of 1,200
homes to Villages as part of a separate Plan document. This approach pre-judges that is the
right number of homes to be allocated, before a full assessment of where housing could most
sustainably be accommodated. Some villages may have sufficient services to support small
scale growth, particularly where they are located within the wider A11 and Tech Corridors,
or served by public transport, but directing additional homes to Villages (many of which have
limited to zero services) on a very small scale as advocated – i.e. maximum 1 hectare in size
but accommodating between 15 and 25 units – as advocated in the Village clusters plan and
referenced in paragraphs 25 and 26, risks being totally at odds with the principles of
sustainable development.2.5 Some villages and smaller settlements may be appropriate for growth, but to provide
additional homes in the manner suggested, would mean between 50 and 80 separate
allocations. This would mean development was never of a critical mass enough to support
existing or new facilities. This will mean such development is almost wholly reliant on the
private car, and totally at odds with the principle of sustainable development. As such the
allocations of all sites should be brought into the one plan increasing the overall amount of
housing to be delivered in this plan by 1,200 and directing growth to settlements that have
the services, and transport connections to support growth.
2.6 Furthermore, the idea of simply ‘rolling forward’ existing allocations suggests that the
Authorities have not undertaken an assessment of whether they are currently delivering
growth. The role of a new Plan is to assess the most sustainable means of achieving the
needs of the Authorities to 2038 and directing it in a means that is sustainable and
‘deliverable’. As we shall detail in later sections of these representations, there are existing
allocations that are clearly not ‘delivering’ as highlighted in the significant housing shortfall
that has occurred against planned growth in previous Joint Plan. The shortfall of housing has
made the affordability of housing even less within the reach of the population. This is
highlighted in the SHMA and on page 16 of the Strategy highlighting the salary multiple in
South Norfolk has risen to 8.8 x average salary. This is worse than the national average,
where the UK has declared a housing crisis, and it is essential that this plan identified the
most sustainable strategy for achieving the growth that is required, rather than simply relying
on, and rolling forward previous allocations.

Comment

Representation ID: 22266

Received: 16/03/2020

Respondent: Barton Willmore

Q1 & Q2) Please comment on or highlight any inaccuracies within the
introduction & Is the overall purpose of the Plan Clear?
2.3 Recognition of the role of the A11, and Cambridge Norwich Tech Corridor is welcomed, but
this needs to be reflected better in the wider growth strategy. The chapter also highlights
some positive things about the sustainability agenda – and the impacts of this – notably the
potential ban on gas boilers, phasing out of diesel cars etc. However, this places even more
emphasis on the need for growth to be in sustainable locations that have their immediate
needs served from a local community perspective. There is a danger that those less affluent
in society are impacted harder – due to cost associated with electric vehicles and
decarbonising, and this places an even greater need for development to be planned in
settlements of sufficient critical size to support a wider range of local services, and in a
comprehensive manner to serve the needs of the local population and minimise the need to
travel for smaller journeys – i.e. trips to a local convenience store, to drop children at primary
school, or to have access to an area of parkland/open space.
2.4 Accordingly, we do not support the Authorities’ proposal to ‘reserve’ the allocation of 1,200
homes to Villages as part of a separate Plan document. This approach pre-judges that is the
right number of homes to be allocated, before a full assessment of where housing could most
sustainably be accommodated. Some villages may have sufficient services to support small
scale growth, particularly where they are located within the wider A11 and Tech Corridors,
or served by public transport, but directing additional homes to Villages (many of which have
limited to zero services) on a very small scale as advocated – i.e. maximum 1 hectare in size
but accommodating between 15 and 25 units – as advocated in the Village clusters plan and
referenced in paragraphs 25 and 26, risks being totally at odds with the principles of
sustainable development.Q1 & Q2) Please comment on or highlight any inaccuracies within the
introduction & Is the overall purpose of the Plan Clear?
2.3 Recognition of the role of the A11, and Cambridge Norwich Tech Corridor is welcomed, but
this needs to be reflected better in the wider growth strategy. The chapter also highlights
some positive things about the sustainability agenda – and the impacts of this – notably the
potential ban on gas boilers, phasing out of diesel cars etc. However, this places even more
emphasis on the need for growth to be in sustainable locations that have their immediate
needs served from a local community perspective. There is a danger that those less affluent
in society are impacted harder – due to cost associated with electric vehicles and
decarbonising, and this places an even greater need for development to be planned in
settlements of sufficient critical size to support a wider range of local services, and in a
comprehensive manner to serve the needs of the local population and minimise the need to
travel for smaller journeys – i.e. trips to a local convenience store, to drop children at primary
school, or to have access to an area of parkland/open space.
2.4 Accordingly, we do not support the Authorities’ proposal to ‘reserve’ the allocation of 1,200
homes to Villages as part of a separate Plan document. This approach pre-judges that is the
right number of homes to be allocated, before a full assessment of where housing could most
sustainably be accommodated. Some villages may have sufficient services to support small
scale growth, particularly where they are located within the wider A11 and Tech Corridors,
or served by public transport, but directing additional homes to Villages (many of which have
limited to zero services) on a very small scale as advocated – i.e. maximum 1 hectare in size
but accommodating between 15 and 25 units – as advocated in the Village clusters plan and
referenced in paragraphs 25 and 26, risks being totally at odds with the principles of
sustainable development.2.5 Some villages and smaller settlements may be appropriate for growth, but to provide
additional homes in the manner suggested, would mean between 50 and 80 separate
allocations. This would mean development was never of a critical mass enough to support
existing or new facilities. This will mean such development is almost wholly reliant on the
private car, and totally at odds with the principle of sustainable development. As such the
allocations of all sites should be brought into the one plan increasing the overall amount of
housing to be delivered in this plan by 1,200 and directing growth to settlements that have
the services, and transport connections to support growth.
2.6 Furthermore, the idea of simply ‘rolling forward’ existing allocations suggests that the
Authorities have not undertaken an assessment of whether they are currently delivering
growth. The role of a new Plan is to assess the most sustainable means of achieving the
needs of the Authorities to 2038 and directing it in a means that is sustainable and
‘deliverable’. As we shall detail in later sections of these representations, there are existing
allocations that are clearly not ‘delivering’ as highlighted in the significant housing shortfall
that has occurred against planned growth in previous Joint Plan. The shortfall of housing has
made the affordability of housing even less within the reach of the population. This is
highlighted in the SHMA and on page 16 of the Strategy highlighting the salary multiple in
South Norfolk has risen to 8.8 x average salary. This is worse than the national average,
where the UK has declared a housing crisis, and it is essential that this plan identified the
most sustainable strategy for achieving the growth that is required, rather than simply relying
on, and rolling forward previous allocations.

Comment

Representation ID: 22268

Received: 16/03/2020

Respondent: Barton Willmore

Q3, Q4 & Q5) Greater Norwich Spatial Profile
2.7 Table 1 highlights the size of Wymondham as a settlement of significantly greater scale than
other centres. It is over double the size of the next settlement (Diss), and the facilities
available in Wymondham reflect that. Further Wymondham is served by a train station with
regular services to the regional employment hubs of Cambridge and Norwich. It is on the A11
linking the cities and within the Cambridge – Norwich Tech Corridor, highlighted in the
previous chapter as a strategic objective for growth. It is an obvious location to accommodate
growth.
2.8 Paragraph 34 acknowledges the residential profile of the area with a high student population
and an ageing population. It is accepted that students will live in smaller accommodation,
but page 16 of the Strategy clearly highlights that 81% of the housing need is for houses. As
such seeking higher density development (i.e. flatted developments) within the City Centre,
or within the Norwich Policy Area, will not deliver this need. High density family houses need
to be delivered in areas that are appropriate to that context, and where those most in needcan access local facilities. The focus of housing within the most urban areas will arguably
deliver housing that is not tailored to need. The Strategy and direction of growth should
clearly correspond to where the need can be provided for – and that is locations that can
deliver a range of 2 to 5-bedroom houses, including the appropriate amount of affordable
housing. Further, consistent with the vision, it should be directed to locations such as the
A11 and Cambridge to Norwich Growth Corridor, rather than such a broad distribution as
advocated. Again, it is clear that housing has been delivered in Wymondham and has delivered
the type of homes tailored to the local need, including 1-bed to 5-bed market and affordable
homes. This makes it a location to ‘rely’ on when actually ‘delivering growth’. In the context
of under-supply, and the unreliability of existing/previous allocations to deliver, the
Authorities should place greater emphasis on where the market is confident it can deliver.
Wymondham is this such location.
2.9 Reference at Paragraph 44 of the Draft Strategy that 87% of the Housing Target has been
delivered is inaccurate. Against a requirement of 22,506 dwellings in the period 2008/09 –
2018/19, only 18,221 dwellings have been delivered (a 4,283 dwelling shortfall), representing
circa. 80% delivery. The situation is even worse in the Norwich Policy Area where, against a
requirement of 20,163 dwellings only 13,994 dwellings have been delivered (a 6,169 dwelling
shortfall), representing only circa. 69% delivery.
2.10 Further reference to 133% of the housing target being delivered between 2015/16 and
2017/18 is wholly misleading, given the shortfall that exists (as highlighted further in
response to Question 9) of 4,283 homes. The shortfall increases to 6,169 homes within the
‘Norwich Policy Area’ where growth has been directed in the previous Plan period to 2026.
This extent of under-delivery requires the Authorities to fully assess how to ensure delivery
of the growth to 2038. It requires a review of where delivery has successfully occurred vs
where it has not, and as necessary re-calibrate the direction and location of growth to those
locations that have met or exceeded delivery requirements such as Wymondham.2.11 Drawing comparison to average performance across the Country is irrelevant, and the extent
of under-delivery we highlight in response to Question 9 should be clearly highlighted here,
as it impacts on affordability of housing, which is as local issue, rather than a national issue,
and highlighted as an acute issue in the Greater Norwich Area, worse than the national
average. It clearly provides the justification for a 20% buffer to be applied rather than the
9% advocated, a matter supported in assertions from the HBF.

Comment

Representation ID: 22269

Received: 16/03/2020

Respondent: Barton Willmore

Q3, Q4 & Q5) Greater Norwich Spatial Profile
2.7 Table 1 highlights the size of Wymondham as a settlement of significantly greater scale than
other centres. It is over double the size of the next settlement (Diss), and the facilities
available in Wymondham reflect that. Further Wymondham is served by a train station with
regular services to the regional employment hubs of Cambridge and Norwich. It is on the A11
linking the cities and within the Cambridge – Norwich Tech Corridor, highlighted in the
previous chapter as a strategic objective for growth. It is an obvious location to accommodate
growth.
2.8 Paragraph 34 acknowledges the residential profile of the area with a high student population
and an ageing population. It is accepted that students will live in smaller accommodation,
but page 16 of the Strategy clearly highlights that 81% of the housing need is for houses. As
such seeking higher density development (i.e. flatted developments) within the City Centre,
or within the Norwich Policy Area, will not deliver this need. High density family houses need
to be delivered in areas that are appropriate to that context, and where those most in needcan access local facilities. The focus of housing within the most urban areas will arguably
deliver housing that is not tailored to need. The Strategy and direction of growth should
clearly correspond to where the need can be provided for – and that is locations that can
deliver a range of 2 to 5-bedroom houses, including the appropriate amount of affordable
housing. Further, consistent with the vision, it should be directed to locations such as the
A11 and Cambridge to Norwich Growth Corridor, rather than such a broad distribution as
advocated. Again, it is clear that housing has been delivered in Wymondham and has delivered
the type of homes tailored to the local need, including 1-bed to 5-bed market and affordable
homes. This makes it a location to ‘rely’ on when actually ‘delivering growth’. In the context
of under-supply, and the unreliability of existing/previous allocations to deliver, the
Authorities should place greater emphasis on where the market is confident it can deliver.
Wymondham is this such location.
2.9 Reference at Paragraph 44 of the Draft Strategy that 87% of the Housing Target has been
delivered is inaccurate. Against a requirement of 22,506 dwellings in the period 2008/09 –
2018/19, only 18,221 dwellings have been delivered (a 4,283 dwelling shortfall), representing
circa. 80% delivery. The situation is even worse in the Norwich Policy Area where, against a
requirement of 20,163 dwellings only 13,994 dwellings have been delivered (a 6,169 dwelling
shortfall), representing only circa. 69% delivery.
2.10 Further reference to 133% of the housing target being delivered between 2015/16 and
2017/18 is wholly misleading, given the shortfall that exists (as highlighted further in
response to Question 9) of 4,283 homes. The shortfall increases to 6,169 homes within the
‘Norwich Policy Area’ where growth has been directed in the previous Plan period to 2026.
This extent of under-delivery requires the Authorities to fully assess how to ensure delivery
of the growth to 2038. It requires a review of where delivery has successfully occurred vs
where it has not, and as necessary re-calibrate the direction and location of growth to those
locations that have met or exceeded delivery requirements such as Wymondham.2.11 Drawing comparison to average performance across the Country is irrelevant, and the extent
of under-delivery we highlight in response to Question 9 should be clearly highlighted here,
as it impacts on affordability of housing, which is as local issue, rather than a national issue,
and highlighted as an acute issue in the Greater Norwich Area, worse than the national
average. It clearly provides the justification for a 20% buffer to be applied rather than the
9% advocated, a matter supported in assertions from the HBF.

Comment

Representation ID: 22270

Received: 16/03/2020

Respondent: Barton Willmore

Q3, Q4 & Q5) Greater Norwich Spatial Profile
2.7 Table 1 highlights the size of Wymondham as a settlement of significantly greater scale than
other centres. It is over double the size of the next settlement (Diss), and the facilities
available in Wymondham reflect that. Further Wymondham is served by a train station with
regular services to the regional employment hubs of Cambridge and Norwich. It is on the A11
linking the cities and within the Cambridge – Norwich Tech Corridor, highlighted in the
previous chapter as a strategic objective for growth. It is an obvious location to accommodate
growth.
2.8 Paragraph 34 acknowledges the residential profile of the area with a high student population
and an ageing population. It is accepted that students will live in smaller accommodation,
but page 16 of the Strategy clearly highlights that 81% of the housing need is for houses. As
such seeking higher density development (i.e. flatted developments) within the City Centre,
or within the Norwich Policy Area, will not deliver this need. High density family houses need
to be delivered in areas that are appropriate to that context, and where those most in needcan access local facilities. The focus of housing within the most urban areas will arguably
deliver housing that is not tailored to need. The Strategy and direction of growth should
clearly correspond to where the need can be provided for – and that is locations that can
deliver a range of 2 to 5-bedroom houses, including the appropriate amount of affordable
housing. Further, consistent with the vision, it should be directed to locations such as the
A11 and Cambridge to Norwich Growth Corridor, rather than such a broad distribution as
advocated. Again, it is clear that housing has been delivered in Wymondham and has delivered
the type of homes tailored to the local need, including 1-bed to 5-bed market and affordable
homes. This makes it a location to ‘rely’ on when actually ‘delivering growth’. In the context
of under-supply, and the unreliability of existing/previous allocations to deliver, the
Authorities should place greater emphasis on where the market is confident it can deliver.
Wymondham is this such location.
2.9 Reference at Paragraph 44 of the Draft Strategy that 87% of the Housing Target has been
delivered is inaccurate. Against a requirement of 22,506 dwellings in the period 2008/09 –
2018/19, only 18,221 dwellings have been delivered (a 4,283 dwelling shortfall), representing
circa. 80% delivery. The situation is even worse in the Norwich Policy Area where, against a
requirement of 20,163 dwellings only 13,994 dwellings have been delivered (a 6,169 dwelling
shortfall), representing only circa. 69% delivery.
2.10 Further reference to 133% of the housing target being delivered between 2015/16 and
2017/18 is wholly misleading, given the shortfall that exists (as highlighted further in
response to Question 9) of 4,283 homes. The shortfall increases to 6,169 homes within the
‘Norwich Policy Area’ where growth has been directed in the previous Plan period to 2026.
This extent of under-delivery requires the Authorities to fully assess how to ensure delivery
of the growth to 2038. It requires a review of where delivery has successfully occurred vs
where it has not, and as necessary re-calibrate the direction and location of growth to those
locations that have met or exceeded delivery requirements such as Wymondham.2.11 Drawing comparison to average performance across the Country is irrelevant, and the extent
of under-delivery we highlight in response to Question 9 should be clearly highlighted here,
as it impacts on affordability of housing, which is as local issue, rather than a national issue,
and highlighted as an acute issue in the Greater Norwich Area, worse than the national
average. It clearly provides the justification for a 20% buffer to be applied rather than the
9% advocated, a matter supported in assertions from the HBF.

Comment

Representation ID: 22271

Received: 16/03/2020

Respondent: Barton Willmore

Q6, Q7 & Q8 – Vision & Objectives for Greater Norwich
2.12 The vision is broadly supported, but the means of achieving it and how growth is distributed
is not supported by our client. For reasons set out in responses to latter questions, the
number of homes to be delivered should be increased, to improve affordability, particularly
in context of shortfalls to date. To reduce emissions and enhance green infrastructure,
development needs to be planned for in a means that minimises the number of trips
undertaken. People will always need to travel for work, and for various other purposes, and
it is important therefore to locate growth in areas where public transport is accessible.
However, it is also essential to minimise the number of small trips – i.e. to a convenience
store; to a local school etc. particularly for those less affluent who may not be able to afford
electric and hybrid vehicles in the short-medium term. The plans for NE Wymondham
presented will provide immediate day to day convenience needs and a primary School serving
in excess of circa. 1,000 homes within walking distances of the Site, alongside access to bus
stops within walking distances with services into Norwich and the train station, as well as
dedicated cycle access to Norwich.
2.13 Paragraph 114 of the Strategy advises that jobs growth will be delivered on strategic sites in
and around Norwich, with good access to the public transport and the major road network.
However, the Cambridge – Norwich tech corridor represents the most sustainable option to
achieve such growth, but equally it is essential that new homes are made available in the
same corridor to cater for those that may be employed by the new jobs. Strong cycle links
into the City Centre are also essential, and this highlights the need to focus development in
locations where public transport, major roads and cycle access is readily available.
Wymondham is one such location within the Tech Corridor. The Authorities’ desire to locate
up to 1,200 homes in villages – based on allocations that would support no more than 25
homes, would in most instances mean that none of these three criteria would apply. To
actively set aside an arbitrary number of homes (1,200) potentially in areas where there are
limited services, no cycle facilities and limited public transport, would be contradictory to the
principles of sustainable development, and thus contrary to the NPPF and the NPPG. It would
fail all 4 tests of soundness contained in Paragraph 35 of the NPPF.2.14 Paragraph 117 highlights that sustainable communities will be where people have good access
to “services and facilities including schools, health care, shops, leisure, and community
facilities and libraries – which in turn reduce the need to travel”. Accordingly, irrespective of
previous allocations, this Local Plan should undertake services audits of each settlement
(including the villages), outside the obvious case of the city centre, and identify a hierarchy
of centres. Those centres with the greatest variety of services and accessibility should then
be identified as the priority for accommodating future growth. There appears to be no suchassessment within the Local Plan or its supporting evidence base, and thus the soundness of
the strategy for growth is brought immediately into question. Indeed the Growth locations
identified in Map 7 appear to have no rationale, aside from simply carrying forward allocations
from the previous plan period irrespective of whether they have delivered, or meet the tests
of soundness for compliance with national policy in 2020, as opposed to when the previous
iteration of the Plan was prepared.
2.15 Similarly, our client wholly supports the sentiment of Paragraph 126, seeking to achieve a
radical shift away from the use of the private car. Locations with good quality footpath and
cycle links, as well as access to public transport are the most likely locations to achieve such
a shift. This is the case for land to the northeast of Wymondham, which has footpath links to
the town centre, and dedicated cycle routes into Norwich City Centre. However, achieving
this shift will be far more difficult in rural locations and small settlements, where roads are
narrow and cannot accommodate cycle/footpaths.
2.16 The Plan’s Objectives are set out on Page 34, with reference to promoting the ‘delivery’ of
housing, jobs and infrastructure to meet needs. The word delivery being key, as it is a key
test of the NPPF. The previous Plan period has failed to deliver the needs of the Greater
Norwich Area, particularly in respect of housing as set out in our response to Question 9.
This has impacted on affordability and access to housing. The Plan should recognise the
shortfalls of over 6,100 homes across the Norwich Policy Area and seek to remedy it through
directing growth to locations that have delivered successfully.