Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22272

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.

Comment

Representation ID: 22273

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.

Comment

Representation ID: 22274

Received: 16/03/2020

Respondent: Barton Willmore

Q9) Do you support, object, or have any comments relating to the approach to
Housing set out in the Delivery Statement?
2.17 We broadly support the approach to Housing set out in the Delivery Statement.
2.18 The Delivery Statement as set out within Section 4 of the Draft Strategy correctly identifies
how the delivery of housing, jobs and infrastructure are interlinked and mutually supportive.
We support the Plan identifying these matters as being interwoven and expect it to promote
and enable growth within key areas which maximise the benefits in respect of these. However,
we maintain that growth within the Villages should be assessed as part of a single Plan.
Arbitrarily directing 1,200 homes on small sites within villages and small settlements where
jobs, infrastructure and supporting services will be least readily available, is not supported.
The whole housing provision should be directed to this Plan comprehensively.2.19 Key to this is the need for the Plan for the right number of homes (accounting for past underdelivery
anticipated growth). The Authorities appear to have simply identified the minimum
number of homes, by referring to the standard method as 40,451 new homes. However, the
NPPG states that the standard method is the ‘minimum’ starting point for determining the
number of homes needed in the area. It does not reflect changing economic circumstances.
The NPPG specifically highlights that growth strategies and housing deals in place to facilitate
greater growth are such reasons to support housing above the standard method. The
Strategic Housing Market Assessment for Central Norfolk, specifically references that the
three authorities of Broadland, Norwich and South Norfolk have agreed a City Deal with
ambitious plans for an additional 13,000 jobs and 3,000 homes by 2026, making their JCS
target 27,000 additional jobs, plus those 13,000 City Deal jobs, over the period 2008-26. This
is referenced in the Economy Chapter and supporting text to Policy 6 and should be reflected
in the Housing Numbers. Accordingly, the SHMA identifies a need for 44,714 new homes
across the period 2016 – 2036, which equates to an average of 2,236 dwellings per annum.
2.20 It is not clear therefore why Table 6 of the GNLP highlights a need for 40,451 new homes.
Further, the SHMA goes on to highlight that to accommodate the additional workers
associated with the City Deal, a further 8,361 new homes should also be planned for. Table
6 of the GNLP should therefore clearly provide as a minimum for 44,714 homes, and given
the commitment to the City Deal, extend that by a further 8,361 homes in the Plan Period
consistent with the NPPG.
2.21 Similarly the NPPG states: “There may, occasionally, also be situations where previous levels
of housing delivery in an area, or previous assessments of need (such as a recently-produced
Strategic Housing Market Assessment) are significantly greater than the outcome from the
standard method. Authorities will need to take this into account when considering whether it
is appropriate to plan for a higher level of need than the standard model suggests”
2.22 Given the change associated with the standard method, and the high amount of housing in
the previous GNLP to 2026, against which there is a significant shortfall, we are strongly of
the view that a 20% buffer should be applied. This would support in the region of 9,000
homes over and above the housing need calculated using the standard method, and would
thus broadly align with the additional homes that would be required consistent with the City
Deal identified within the SHMA.
2.23 Once this additional quantity of housing has been accounted for – i.e. circa 49,000 – 54,000,
the GNLP should then seek to direct additional growth to the most sustainable locations - for
example the A11 and Cambridge to Norwich Tech Corridor as the priority for growth in the
region.
2.24 The Joint Core Strategy set a requirement for a total of 36,820 homes to be constructed over
the period 2008 to 2026, or 2,046 per year. Expected delivery has failed to materialise
resulting in a total shortfall of housing delivery since the start of the Plan period equating to
4,283 homes (a full 2 years of housing requirements). Within the Norwich Policy Area the
shortfall is greater with a cumulative under delivery of 6,169 homes since the start of the

Table 2.1: Greater Norwich/Joint Core Strategy Area Housing requirements and delivery
(from JCS and AMR’s)
Plan period (3.4 years of NPA housing requirements).
[see attached document]

2.25 We strongly believe that the shortfall in delivery should be remedied in the forthcoming Plan
period. Whilst the Authorities have reported an increase in delivery over the past three years
in their Annual Monitoring reports, the latter of these for the period 2018/2019 has been
specifically reported verbally by the Authorities as ‘Draft’. Notwithstanding, the shortfall
remains significant, and the means of calculating the delivery is not supported
2.26 Further, on the basis of previous under-delivery it is essential that housing numbers are
accelerated in the early years of the Plan Period, where we believe a 20% buffer should be
provided to the Five Year Housing Supply across the Greater Norwich Area, with a
commitment in the Plan to accelerate growth in the first five years of the Plan. Whilst it is
recognised that there are external factors that can affect delivery, the collective failure of
the Joint Core Strategy’s planned allocations in not meeting the target represents a real risk
that the existing commitments will not be fully delivered by 2036.
2.27 We actively encourage the Authorities to be ‘pro-active’ and plan for the homes required in
the Growth Deal and increase the buffer to 20% (against ‘need’). This will also make up for
the shortfall against the Core Strategy to date, which we highlight above.
2.28 Further, based on previous failings, housing should only be allocated to sites where there is
a reasonable prospect of delivery (in line with the requirement of the NPPF). The Plan
currently relies on sites (specifically within the Growth Triangle) which have not delivered as
anticipated against their Joint Core Strategy requirements. Evidence is not provided todemonstrate these sites will deliver within the proposed Plan Period which risks the Plan
being found unsound on account of being unjustified, not effective and not positively prepared
on this basis. This is discussed further in our response to Questions 38 – 40.
2.29 In this respect, it will be critical that the Plan allocates deliverable sites in suitable locations.
Footnote 45 to the Delivery Statement specifically states that: “The housing allocations in
this draft plan will only be carried forward to the submission version of the Plan if evidence
is provided to show that they can be delivered by 2038”. This suggests that the Authorities
have not yet undertaken an assessment of when sites will be delivered. The Housing &
Economic Land Availability Assessment (HELAA) is vague on detail over delivery and provides
no anticipated trajectory as would be expected. As detailed further later in this section, the
Growth Strategy fails to achieve this requirement.
2.30 We strongly recommend the Authorities revisits the strategy to support development in
suitable locations where there has been a track record of delivery. Wymondham, identified
as a contingency location, is such a location and continues to experience high demand for
new homes.2.31 As a key location within the Cambridge Norwich Tech Corridor, Wymondham should be
supported for further growth including upgrading the ‘contingency’ to a full allocation.

Comment

Representation ID: 22275

Received: 16/03/2020

Respondent: Barton Willmore

Q12) Do you support, object, or have any comments relating to the Climate Change
Statement?
2.32 We support the principles of the Climate Change Statement, in particular the need to reduce
the need to travel, particularly by the private car, and by seeking to locate development in a
way that ensures it is close to everyday services and jobs. However, the Strategy as currently
drafted fails to do just that. It fails to direct development to the most sustainable locations,
simply rolling forward previous allocations, as opposed to identifying those locations that
have greatest access to facilities through a services and facilities audit. That audit should
inform a hierarchy of sustainable locations against which development should be targeted.
The A11 corridor, Cambridge – Norwich tech Corridor is also served by regular trains between
Norwich and Cambridge. The locations served by cycle facilities into the city centre, and with
direct access to railway stations in this corridor are far more likely to achieve the shift change
to non-car modes. To secure a modal shift there has to be genuine choice that is viable,
affordable and no more time consuming than the convenience of the private car.

Comment

Representation ID: 22276

Received: 16/03/2020

Respondent: Barton Willmore

Q13) Do you agree with the proposed Settlement Hierarchy and the proposed
distribution of housing within the hierarchy?
2.33 Simply put, No. Firstly, as highlighted in our response to Question 9, we believe the amount
of homes to be identified within the GNLP should as a very minimum be consistent with
housing need calculated by the Standard Method and then be increased to account for the
Growth Deal, advocated in the SHMA. This would also help make up for the shortfall we have
highlighted against the GNLP to 2026. Second, as detailed in our response to questions 38 to
46, the proposed distribution of housing within the hierarchy is unjustified and would not be
effective at delivering housing requirements over the plan period.
2.34 We would stress that a number of the allocations that appear to have been ‘rolled forward’
are failing to deliver homes. Allocation GT6 (Land at Brook & Laurel Farm) has not yet
commenced, despite permission being granted in June 2014. Work is yet to commence on
Allocation GT11, and we note that planning permission has not yet been granted for the
Larkfleet Homes site East of Broadland Business Park. Combined these sites are anticipated
to deliver 1,450 homes. Accounting for the “Nathaniel Lichfield & Partners Start to Finish –
How Quickly do large scale housing sites deliver” (NLP November 2016) on average these
sites would take 5.3 years to actually deliver houses, of which circa 13 months would be post
approval of planning. The lead in time for smaller sites below 500 units extends to circa 2
years from the grant of planning permission. Sites GT13, GT14, DRA1, HEL1 and REP1 fall
into this category. The AMR provides no evidence of delivery or update on progress. As such
to carry forward such allocations, the Authorities must (a) be confident (through the provision
of clear evidence) that they will be granted planning permission and commence in the Plan
period; and (b) be confident that sites GT6 and GT11 will start delivering units before 2028
given the average build out rates for sites of this size are identified by NLP to represent no
more than 86 dwellings per annum on Greenfield sites and no more than 52 dwellings per
annum on brownfield sites.2.35 In addition, we highlight that Sites GT12 and GT16 are anticipated to deliver 3,500 and 3,000
dwellings respectively in the Plan period. To date neither have commenced – despite being
anticipated to deliver from 2019/2020 and 2016/2017 respectively. In the case of GT12, the
latter phases are dependent on Infrastructure Forward Funding. Neither sites have secured
detailed permission for any phase. Even if permission was to be granted now, accounting for
NLP lead in times, they would not commence before 2021. This is ambitious, and even then
would have to deliver housing at a rate of 220 dwellings per annum in the case of GT12, and
227 dwellings per annum in the case of GT16 (as set out in the AMR which anticipates no
housing on site until 2024). NLP 2016, highlights average build out rates of 171 dwellings per
annum on greenfield sites of this size, reducing to 148 dwellings per annum for brownfieldsites. Based on these averages and the anticipated delivery rates in the 2018/2019 AMR, it
would result in a housing shortfall of over 1,200 homes in itself. Accordingly, these allocations
should be reduced to 2,927 (GT12) and 2,388 (GT16) respectively. The shortfall must be
accounted for elsewhere.
2.36 Further, we would highlight that the sites identified above are within the Growth Triangle,
where there are clearly questions over deliverability. Allocating additional homes to the
Growth triangle in the context of under-delivery on housing to date (a shortfall of 6,169
homes in the NPA), and uncertainty over delivery of sites, would further undermine confidence
in the ability of the GNLP to deliver on its needs to 2038.
2.37 In addition we note that Page 46 of the GNLP highlights uncertainty over the site of Carrow
Works. This accounts for a further 1,200 homes. If there is uncertainty over delivery it should
be removed from the Plan. Accordingly, accounting for Carrow Works, and the reductions to
allocations GT12, and GT16 we have highlighted above, a further 2,400 need to be identified
in the Plan to alternative locations, notwithstanding the additional housing we believe should
be provided for in response to Question 9.
2.38 We would also stress that Long Stratton is subject to 2no. Hybrid applications submitted Jan
and Feb 2018 for 600 dwellings (213 detailed) and 1,275 dwellings (zero detailed)
respectively. Both applications remain undetermined. Based on the NLP lead in times, it is
unlikely either of these will deliver any houses before 2023/24 (accounting for 5.3 years for
schemes of 500-999 dwellings and 5.7 years for schemes of 1,001 – 1,499 dwellings). Based
on average build out rates of 86 dwellings per annum, it is unlikely all of the 1,800 homes
can be delivered within the plan period to 2038, requiring a further adjustment.2.39 Accounting for the matters we highlight in paragraphs 2.33 – 2.36 above, the distribution of
housing set out in Map 7 and Policy 1 should be adjusted. In addition, we strongly object to
simply allocating 1,200 additional homes to South Norfolk Village clusters on the grounds of
sustainable development. These 1,200 homes should be brought back into the GNLP. Together
there is therefore a need to identify additional land for circa 4,000 homes as a minimum,
which would increase to circa 13,000 further homes should growth from the New Deal be
planned for, as we advocate in response to earlier questions.
2.40 As set out in our March 2018 representations we endorse a strategic growth option which
serves and supports an identified ‘Core Area’ whilst focusing and 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. We continue to
advocate this approach which will fulfil the Vision and Objectives of the GNLP, whilst achievingthe full potential of the Cambridge Norwich Tech Corridor in a sustainable way that is
consistent with the Climate Change Statement. This area should be the focus of
accommodating the above shortfall, and the Housing Growth Allocations and Policy 1 should
be updated to reflect that.
2.41 The proposed dispersal should align more closely with the Growth Strategy. As discussed
above there are aspects of the current approach which need amending and will require
additional new allocations to be identified. This should include locating additional
development in Wymondham, one of the largest towns on the Cambridge Norwich Tech
Corridor, and a reduction in reliance of Sites in the Growth Triangle in recognition of past
poor delivery.

Comment

Representation ID: 22277

Received: 16/03/2020

Respondent: Barton Willmore

Q14) Do you support, object or wish to comment on the approach for housing
numbers and delivery?
2.42 We support the identification of the Government’s standard methodology as the starting point
for calculating the housing requirements of the Plan. This is consistent with the requirements
of the NPPF as the standard methodology is a demographic-based figure which includes an
uplift for affordability, partly accommodating past shortfall.
2.43 Planning Practice Guidance (Paragraph 010 Reference ID 2a-010-20190220) identifies the
circumstances where it may be appropriate to plan for a higher housing need figure than the
standard method indicates including situations where increases in housing are likely to exceed
past trends because of growth strategies or strategic infrastructure improvements.
2.44 The City Deal, which was signed into effect by the Government in December 2013, gives
Greater Norwich increased freedom to help business grow and create economic growth. As
detailed in the City Deal report (December 2013), the deal aims to bring an additional 13,000
jobs and 3,000 homes (above Joint Core Strategy requirements) to the Greater Norwich Area.
As detailed in the Central Norfolk Strategic Housing Market Assessment (June 2017) this
equates to a total of 45,390 jobs over the plan period.2.45 Paragraph 4.19 of the Growth Options Consultation Document (January 2018) identified the
housing requirement may need to increase to support potential job growth arising from the
City Deal, resulting in 1,700 further dwellings being required. No reference to this is included
in any form within the Draft Strategy. Furthermore, the Strategic Housing Market Assessment
for Central Norfolk, specifically references that the three authorities of Broadland, Norwich
and South Norfolk have agreed a City Deal with ambitious plans for an additional 13,000 jobs
and 3,000 homes by 2026, making their JCS target 27,000 additional jobs, plus those 13,000City Deal jobs, over the period 2008-26. This is referenced in the Economy Chapter and
supporting text to Policy 6 and should be reflected in the Housing Numbers.
2.46 Nevertheless, the Draft Strategy confirms the GNLP will seek to over-allocate by means of a
10% buffer (equating to circa. 4,050 dwellings) to ensure delivery. It needs to be clarified
whether this includes some of the dwellings required by the City Deal (8,361 homes as
advocated at figure 101 of the SHMA), thereby reducing the delivery buffer, or if the City
Deal requirement will be in addition to the housing requirements identified in Table 6.
2.47 It is not clear therefore why Table 6 of the GNLP highlights a need for 40,451 new homes.
Further, the SHMA goes on to highlight that to accommodate the additional workers
associated with the City Deal, a further 8,361 new homes should also be planned for. Table
6 of the GNLP should therefore clearly provide as a minimum for 44,714 homes, and given
the commitment to the City Deal, extend that by a further 8,361 homes in the Plan Period
consistent with the NPPG. 3,000 of these homes should be delivered by 2026 in accordance
with the commitments of the City.
2.48 Similarly the NPPG states: “There may, occasionally, also be situations where previous levels
of housing delivery in an area, or previous assessments of need (such as a recently-produced
Strategic Housing Market Assessment) are significantly greater than the outcome from the
standard method. Authorities will need to take this into account when considering whether it
is appropriate to plan for a higher level of need than the standard model suggests”.
2.49 Given the change associated with the standard method, and the high amount of housing in
the previous GNLP to 2026, against which there is a significant shortfall, we are strongly of
the view that a 20% buffer should be applied. This would support in the region of 9,000
homes over and above the housing need calculated using the standard method and would
thus broadly align with the additional homes that would be required consistent with the City
Deal identified within the SHMA.
2.50 Once this additional quantity of housing has been accounted for – i.e. circa 49,000 – 54,000,
the GNLP should then seek to direct additional growth to the most sustainable locations - for
example the A11 and Cambridge to Norwich Tech Corridor as the priority for growth in the
region.2.51 The ‘alternative approaches’ to housing numbers identifies that whilst the NPPF encourages
a higher housing requirement, this is not the preferred option as evidence of delivery over
the medium and longer term suggests that higher targets are unlikely to be achievable or
deliverable. We do not believe this position is evidenced, and in fact past poor delivery hasbeen as a result of incorrect sites being allocation and an overreliance on sites within the
Growth Triangle (as detailed above and further in response to Questions 38 – 40).

Comment

Representation ID: 22278

Received: 16/03/2020

Respondent: Barton Willmore

Q16) Do you support, object or wish to comment on the approach to Review and
Five-Year Land Supply?
2.52 We support the option for the Plan to be reviewed after 5 years, which is consistent with the
requirement of the Framework (para 33). The NPPF states that plans should be “reviewed to
assess whether they need updating at least once every five years” and goes on to state that
reviews “should be completed no later than five years after the adoption date of that plan”.
As such the Authorities’ policy to review the plan 5 years after adoption is not consistent with
national policy. The review must be completed prior to the plan being five years old to allow
for the prompt updating of the plan if necessary. We would therefore suggest the following
change is made: “This plan will be reviewed and the Authorities will complete and publish a
review of this plan 5 years after adoption to assess whether it needs to be updated”.

Comment

Representation ID: 22279

Received: 16/03/2020

Respondent: Barton Willmore

Q19) Do you support, object or have any comments relating to the specific
requirements of the Policy?
2.53 We would highlight that Point 4 of Policy 2 ‘Sustainable Communities’ seeks to make the most
efficient use of land supporting densities of 25 dwellings per hectare across the plan area.
This highlights the need to reconsider the approach advocated to Village clusters, where the
criteria is for sites of no more than a hectare yet delivering 15 units. This highlights the need
to allocate greater quantum of land to locations such as Wymondham and larger settlements
where the density can be met without impacting on local character.

Comment

Representation ID: 22280

Received: 16/03/2020

Respondent: Barton Willmore

Q24) Do you support, object or have any other comments relating to other
strategic infrastructure (energy, waste, health care, schools and green
infrastructure)?
2.54 The scale of development will clearly require the provision of new infrastructure to
appropriately and sustainably meet the demands of this growth.
2.55 There are key pieces of infrastructure that are necessary to be addressed that have otherwise
not been delivered or proposed to be delivered as part of the Joint Core Strategy 2013. A
good example, and as detailed further below, is the need to positively address the Education
capacity issue in Wymondham. This is an issue that has been highlighted by the Examining
Inspector for the Wymondham Area Action Plan as being “necessary to review” as part of
future plan-making exercises.

Comment

Representation ID: 22289

Received: 16/03/2020

Respondent: Barton Willmore

Q38 - 40) Consultation Questions for Policy 7.1 – The Norwich Urban area including the fringe parishes

2.56 The introduction to the draft Sites Allocation Document (SAD) confirms the document identifies the preferred sites for new allocation, the allocations to be carried forward from the current Local Plans, reasonable alternative sites (where appropriate) and unreasonable housing sites. The SAD is split into 50no. Settlement Papers which summarises the settlement characteristics and the existing and/or proposed allocations. 2.57 In the main, these provide a brief summary of existing allocations, and review whether these remain deliverable within the new Plan Period, and the sites submitted through previous call for sites, providing a rationale for why the sites should or should not be allocated.

2.58 One exception to the above are the existing allocations within the Growth Triangle, allocated through the Growth Triangle Area Action Plan (2016), which the Settlement Papers conclude to be carried forward:

High amounts of existing development commitment remains, as the allocations identified in the Growth Triangle Area Action Plan will not be superseded by the new local plan

2.59 No justification for this approach is provided within the Draft Strategy or the SAD.

2.60 As acknowledged in Table 2.1 and 2.2, the JCS has delivered poorly against its housing requirement since the start of the Plan period. A significant failing of the JCS has been the under delivery of allocations within the Growth Triangle. In particular allocations GT6, GT11, GT12, GT13, GT14 and GT16.

2.61 Policy 7.1 (The Norwich Urban Area including fringe parishes) identifies 12,019 dwellings as the ‘existing deliverable commitment’ for The Growth Triangle with 1,415 additional dwellings proposed through the GNLP.

2.62 Of the 12,019 committed dwellings, Appendix B1 (Broadland Sites Forecast) of Annual Monitoring Report 2018 – 19 (AMR, Appendix 4) identifies the Growth Triangle area is expected to deliver 4,485 dwellings between 2019/20 – 2025/26 (i.e. the remainder of the Joint Core Strategy Plan Period).

2.63 The AMR identifies the remaining 7,623 dwellings will be delivered in ‘2026 and beyond’. No updated trajectory is provided within the AMR or as part of the current GNLP consultation to demonstrate when these 7,623 dwellings (circa. 23% of the existing commitments) will be delivered i.e. by 2038 or beyond.
2.64 Table 2.3 below summarises 4no. allocated Growth Triangle sites which account for circa. 6,350 dwellings of the supply to be delivered ‘2026 and beyond’, not account for additional dwellings identified to be delivered in 2024/25 – 2025/26 (for which no evidence is provided).
Table 2.3: Growth Triangle Area Action Plan allocations [see attached document] 2.65 Sites GT12 and GT16 are anticipated to deliver 3,500 and 3,000 dwellings respectively in the Plan period. To date neither have commenced – despite being anticipated to deliver from 2019/2020 and 2016/2017 respectively. In the case of GT12, the latter phases are dependent on Infrastructure Forward Funding. Neither sites have secured detailed permission for any phase. Even if permission was to be granted now, accounting for NLP lead in times, they would not commence before 2021. This is ambitious, and even then would have to deliver housing at a rate of 220 dwellings per annum in the case of GT12, and 227 dwellings per annum in the case of GT16 (as set out in the AMR which anticipates no housing on site until 2024). NLP 2016, highlights average build out rates of 171 dwellings per annum on greenfield sites of this size, reducing to 148 dwellings per annum for brownfield sites. Based on these averages and the anticipated delivery rates in the 2018/2019 AMR, it would result in a housing shortfall of over 1,200 homes in itself. Accordingly, these allocations should be reduced to 2,927 (GT12) and 2,388 (GT16) respectively. The shortfall must be accounted for elsewhere.

2.66 The GNLP needs to provide a clear evidence-based justification for carrying over allocations identified in the Growth Triangle Area Action Plan. No such evidence is currently provided and as such the Plan risks being found unsound on account of being unjustified, not effective and not positively prepared on this basis. At the very least, we highlight for valid reasons the allocations GT12 and Gt16 cannot deliver the numbers anticipated, which should result in a reduction of 1,200 homes.
2.67 Furthermore, the Growth Strategy seeks to allocate additional land within the Growth Triangle with a proposed allocation for 1,200 dwellings in Sprowston. This site is under the control of the developers of the adjoining GT20 allocation (White House Farm) which is subject to an Outline application for 516 dwellings submitted August 2019 pending determination (application ref. 20191370). The AMR identifies an expectation for GT20 to commence in 2021/22 and complete in 2025, however given Outline consent has not yet been granted (and subsequent Reserved Matters prepared and submitted), this may be optimistic. The proposed allocation in Sprowston is identified to be built out after GT20 has completed. It is therefore unlikely the proposed allocation, for 1,200 dwellings, will be delivered within the Plan period. Policy 7.1 and Policy 1 should be updated to reflect this site is unlikely to deliver its full allocation within the Plan period.

2.68 To ensure the Plan delivers its housing growth requirement over the Plan Period, there is clearly a need to reduce the reliance on the Growth Triangle allocations which have not delivered as anticipated and allocate additional sites which are developable within the Plan Period, including in other locations outside the Growth Triangle. 2.69 Furthermore, Page 94 of the GNLP highlights that there is uncertainty over the Unilever/Carrow Works site. The NPPF requires clear evidence of delivery, and as such this allocation should be removed. As detailed in Section 3, Wymondham is such a location to accommodate at least some of this growth.

2.70 Accounting for the above, 1,200 homes as a minimum should be removed from the Growth Triangle, with further justification provided for all homes to be delivered in this location. Based on delivery to date in the Growth Triangle, we also strongly object to the addition of a further 1,415 homes in this location. To continue to rely on housing delivery in the Growth triangle undermines confidence in the GNLP to deliver on its needs. As such a minimum of 2,615 homes should be removed from the Growth triangle and re-allocated. As detailed in Section 3, Wymondham is such a location to accommodate at least some of this growth.

2.71 Within Wymondham, the Promoters have successfully secured consents resulting in circa. 900 dwellings being completed in the past 14 years from unidentified sites. This reflects not only the suitability of Wymondham as an appropriate location (i.e. people want to live there) but also represents a proven and trusted track record for the Promoters in bringing forward suitable sites.