Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22290

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development commitment remains, as the allocations identified in the Growth Triangle Area Action Plan will not be superseded by the new local plan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

Comment

Representation ID: 22291

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.

Comment

Representation ID: 22292

Received: 16/03/2020

Respondent: Barton Willmore

Q41 - 42) Consultation Questions for Policy 7.2 – The Main Towns

2.72 The Main Towns consist of the settlements of Wymondham, Aylsham, Diss and Harleston. Policy 1 of the Draft Strategy also identifies Long Stratton as a Main Town. Clearly Wymondham is a settlement at least twice the size of any subsequent settlement, and given the services available, it should be identified as a ‘Large Main Town’ in a means that separates it from the other towns. An audit of facilities and services should be undertaken to support this assertion and create a hierarchy of settlements for which Wymondham should be singled out as the largest town and the most suitable to accommodate growth. This would support the basis for the additional 1,000 homes identified for Wymondham as a ‘contingency’ location, and also support the case for it to accommodate a portion of the additional growth we have identified as (a) needing to be identified to accommodate additional homes linked to the Growth Deal; and a buffer of 20%; and (b) needing to be re-allocated as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46). 2.73 We do not object to the identification of Long Stratton given the existing growth committed for the town and its location within the Norwich Policy Area, but as set out in response to Question 13, we do believe the allocation needs scrutinising as based on NLP 2016 evidence, we believe it is unlikely that 1,800 homes can be delivered in Long Stratton before 2038.

2.74 As acknowledged at paragraph 308 of the Draft Strategy the Main Towns play a vital role in the rural economy, providing employment opportunities and services for wider hinterlands. We agree with this description but consider Wymondham to have additional roles and services which elevates it above the other Main Towns. Furthermore, Wymondham is located within the Norwich Policy Area (and SHMA ‘Core Area’) and within the Cambridge Norwich Tech Corridor.

2.75 Given the emphasis of the GNLP to focus housing, employment and infrastructure growth within a ‘Strategic Growth Area’ (illustrated on the Key Diagram of the Draft Strategy) which broadly reflects the Cambridge Norwich Tech Corridor, it is unclear why Wymondham is not a key location for growth within the Plan, and separated out as such within a settlement hierarchy.

2.76 Policy 7.2 identifies Wymondham to have an existing deliverable commitment of 2,463 dwellings (including delivery 2018/19). The AMR identifies 1,140 dwellings to be delivered in the next 5-years (2019/20 to 2023/24) with a further 328 dwellings to be delivered in the remainder of the JCS Plan Period. 2.77 For 2026 and beyond the AMR identifies a supply of only 502 dwellings for the latter phases of South Wymondham (477 dwellings) and for London Road/Sutton Lane (35 dwelling). This level should be significantly increased given its previous success in delivering homes, to accommodate at least a portion of the homes we have identified as (a) needed to accommodate additional homes linked to the Growth Deal and a buffer of 20%; and (b) needed for re-allocation as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46).

2.78 The Draft Strategy proposes to allocate an additional 100 dwellings only in Wymondham, across 2no. sites (50 dwellings each). Across the extended Plan Period (2026 – 2038) there is only likely to be circa. 600 dwellings delivered in Wymondham, despite the key location of the settlement within the Cambridge Norwich Growth Corridor and past strong housing delivery. This simply does not represent sustainable planning, and by raising its position within the settlement hierarchy the case can be made to support additional growth that needs to be re-allocated.

2.79 The GNLP does give some recognition to Wymondham, by acknowledging it as a settlement that could accommodate a contingency of 1,000 dwellings. This was based on whether “the GNLP area does not meet its local plan targets”. We have highlighted for reasons above, that the GNLP does not (a) plan for enough housing growth to meet need, particularly as a result of the Growth Deal; and (b) needs to re-allocate land that cannot deliver the anticipated level of housing – i.e. in the Growth Triangle; Carrow Works; Long Stratton and the Village Clusters. Accordingly the ‘contingency’ for Wymondham should be enacted into this Local Plan now, and additional growth beyond the 1,000 dwelling contingency should be allocated to Wymondham given its sustainable location within the A11 and Cambridge to Norwich tech corridor.

2.80 The supporting assessment of Wymondham identifies that there are 7 ‘reasonable’ sites that could accommodate additional growth. Park Farm (Site GNLP2168) and Stanfield Road (Site GNLP1055) are identified as new settlements, for which there is no need identified. However, Sites GNLP2155, GNLP2150 and principally GNLP0525R, were identified as ‘reasonable’ sites that together could knit circa 1,730 new dwellings into the housing that has already been delivered at the former Rugby Club; planned at Elm Farm, and located to the north of Tuttles Lane and Norwich Road. As set out in Chapter 3, our client has land that is available, nonconstrained and deliverable, that can provide a new sustainable community heart to the existing housing that has been delivered to date, that is permitted at Elm Farm, in addition to a further 600 homes, supported by a new primary school and a Local Centre. This land can also deliver a new Country Park and land for a new Sixth Form College. 2.81 The land offers the opportunity to create a new sustainable community that delivers infrastructure to the immediate community and has wider benefits to the town in respect of open space and education provision. This is a well located site within the A11 and Cambridge – Norwich Tech corridor, with good access to trains, bus facilities and dedicated cycle routes. It should form at least part of additional land allocations to Wymondham, necessary to deliver the growth required, and in need of being re-allocated for the reasons set out in responses to previous questions.

2.82 As detailed in Section 3 there is an existing education capacity constraint in Wymondham which was not addressed at the time of adoption of the Wymondham Area Action Plan but confirmed by the Examining Inspector as a matter which justified an early review of the Plan and needing a solution. A solution to this is achievable, through the re-location of Wymondham High Sixth Form, and supported by Norfolk County Council Education. However, this is not currently being addressed by the adopted Development Plan, nor would it be addressed by the emerging GNLP in its current form.

2.83 Only through the allocation of sufficient growth to Wymondham will the GNLP resolve the ongoing education capacity constraint. The education ‘issue’ therefore must be dealt with through this plan-making process, and our client’s land offers the opportunity to address that constraint through the provision of sustainable new community that will also bring local shops and services, a new Primary School and a new public park.

2.84 In order to achieve the Vision and Objectives set by the Growth Strategy, including realising the full potential of the Cambridge Norwich Growth Corridor and meeting existing infrastructure requirements, it is necessary for the Plan to support Wymondham as a key location for growth, beyond current commitments.

2.85 In addition to the above, whilst we have no objection to the Main Towns receiving additional growth to ensure they continue to successfully achieve their roles as providers of employment and services to serve rural areas, but it is clear, for the reasons we have established Wymondham, should be set apart as a new settlement hierarchy to accommodate a higher portion of the additional growth.

2.86 Notwithstanding the above comments, we do question why Harleston, as the smallest Main Town, is identified for allocations totalling 450 dwellings in addition to the existing commitments (173 dwellings). Harleston is the least accessible Main Town, not being located on the rail network or on an A road which connects to Norwich and is not located within the Norwich Policy Area or the SHMA Core Area.

2.87 The Draft Strategy is therefore not considered to be justified or effective in line with the requirements of the Framework. As such, the proposed strategy is considered unsound.

Comment

Representation ID: 22293

Received: 16/03/2020

Respondent: Barton Willmore

Q41 - 42) Consultation Questions for Policy 7.2 – The Main Towns

2.72 The Main Towns consist of the settlements of Wymondham, Aylsham, Diss and Harleston. Policy 1 of the Draft Strategy also identifies Long Stratton as a Main Town. Clearly Wymondham is a settlement at least twice the size of any subsequent settlement, and given the services available, it should be identified as a ‘Large Main Town’ in a means that separates it from the other towns. An audit of facilities and services should be undertaken to support this assertion and create a hierarchy of settlements for which Wymondham should be singled out as the largest town and the most suitable to accommodate growth. This would support the basis for the additional 1,000 homes identified for Wymondham as a ‘contingency’ location, and also support the case for it to accommodate a portion of the additional growth we have identified as (a) needing to be identified to accommodate additional homes linked to the Growth Deal; and a buffer of 20%; and (b) needing to be re-allocated as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46). 2.73 We do not object to the identification of Long Stratton given the existing growth committed for the town and its location within the Norwich Policy Area, but as set out in response to Question 13, we do believe the allocation needs scrutinising as based on NLP 2016 evidence, we believe it is unlikely that 1,800 homes can be delivered in Long Stratton before 2038.

2.74 As acknowledged at paragraph 308 of the Draft Strategy the Main Towns play a vital role in the rural economy, providing employment opportunities and services for wider hinterlands. We agree with this description but consider Wymondham to have additional roles and services which elevates it above the other Main Towns. Furthermore, Wymondham is located within the Norwich Policy Area (and SHMA ‘Core Area’) and within the Cambridge Norwich Tech Corridor.

2.75 Given the emphasis of the GNLP to focus housing, employment and infrastructure growth within a ‘Strategic Growth Area’ (illustrated on the Key Diagram of the Draft Strategy) which broadly reflects the Cambridge Norwich Tech Corridor, it is unclear why Wymondham is not a key location for growth within the Plan, and separated out as such within a settlement hierarchy.

2.76 Policy 7.2 identifies Wymondham to have an existing deliverable commitment of 2,463 dwellings (including delivery 2018/19). The AMR identifies 1,140 dwellings to be delivered in the next 5-years (2019/20 to 2023/24) with a further 328 dwellings to be delivered in the remainder of the JCS Plan Period. 2.77 For 2026 and beyond the AMR identifies a supply of only 502 dwellings for the latter phases of South Wymondham (477 dwellings) and for London Road/Sutton Lane (35 dwelling). This level should be significantly increased given its previous success in delivering homes, to accommodate at least a portion of the homes we have identified as (a) needed to accommodate additional homes linked to the Growth Deal and a buffer of 20%; and (b) needed for re-allocation as a result of re-directing (i) 2,615 homes from the Growth Triangle; (ii) 1,200 homes from East Norwich to account for uncertainty over Carrow Works; and (c) potential re-allocation of land from the 1,200 homes proposed in the Village Clusters (see response to Questions 45 and 46).

2.78 The Draft Strategy proposes to allocate an additional 100 dwellings only in Wymondham, across 2no. sites (50 dwellings each). Across the extended Plan Period (2026 – 2038) there is only likely to be circa. 600 dwellings delivered in Wymondham, despite the key location of the settlement within the Cambridge Norwich Growth Corridor and past strong housing delivery. This simply does not represent sustainable planning, and by raising its position within the settlement hierarchy the case can be made to support additional growth that needs to be re-allocated.

2.79 The GNLP does give some recognition to Wymondham, by acknowledging it as a settlement that could accommodate a contingency of 1,000 dwellings. This was based on whether “the GNLP area does not meet its local plan targets”. We have highlighted for reasons above, that the GNLP does not (a) plan for enough housing growth to meet need, particularly as a result of the Growth Deal; and (b) needs to re-allocate land that cannot deliver the anticipated level of housing – i.e. in the Growth Triangle; Carrow Works; Long Stratton and the Village Clusters. Accordingly the ‘contingency’ for Wymondham should be enacted into this Local Plan now, and additional growth beyond the 1,000 dwelling contingency should be allocated to Wymondham given its sustainable location within the A11 and Cambridge to Norwich tech corridor.

2.80 The supporting assessment of Wymondham identifies that there are 7 ‘reasonable’ sites that could accommodate additional growth. Park Farm (Site GNLP2168) and Stanfield Road (Site GNLP1055) are identified as new settlements, for which there is no need identified. However, Sites GNLP2155, GNLP2150 and principally GNLP0525R, were identified as ‘reasonable’ sites that together could knit circa 1,730 new dwellings into the housing that has already been delivered at the former Rugby Club; planned at Elm Farm, and located to the north of Tuttles Lane and Norwich Road. As set out in Chapter 3, our client has land that is available, nonconstrained and deliverable, that can provide a new sustainable community heart to the existing housing that has been delivered to date, that is permitted at Elm Farm, in addition to a further 600 homes, supported by a new primary school and a Local Centre. This land can also deliver a new Country Park and land for a new Sixth Form College. 2.81 The land offers the opportunity to create a new sustainable community that delivers infrastructure to the immediate community and has wider benefits to the town in respect of open space and education provision. This is a well located site within the A11 and Cambridge – Norwich Tech corridor, with good access to trains, bus facilities and dedicated cycle routes. It should form at least part of additional land allocations to Wymondham, necessary to deliver the growth required, and in need of being re-allocated for the reasons set out in responses to previous questions.

2.82 As detailed in Section 3 there is an existing education capacity constraint in Wymondham which was not addressed at the time of adoption of the Wymondham Area Action Plan but confirmed by the Examining Inspector as a matter which justified an early review of the Plan and needing a solution. A solution to this is achievable, through the re-location of Wymondham High Sixth Form, and supported by Norfolk County Council Education. However, this is not currently being addressed by the adopted Development Plan, nor would it be addressed by the emerging GNLP in its current form.

2.83 Only through the allocation of sufficient growth to Wymondham will the GNLP resolve the ongoing education capacity constraint. The education ‘issue’ therefore must be dealt with through this plan-making process, and our client’s land offers the opportunity to address that constraint through the provision of sustainable new community that will also bring local shops and services, a new Primary School and a new public park.

2.84 In order to achieve the Vision and Objectives set by the Growth Strategy, including realising the full potential of the Cambridge Norwich Growth Corridor and meeting existing infrastructure requirements, it is necessary for the Plan to support Wymondham as a key location for growth, beyond current commitments.

2.85 In addition to the above, whilst we have no objection to the Main Towns receiving additional growth to ensure they continue to successfully achieve their roles as providers of employment and services to serve rural areas, but it is clear, for the reasons we have established Wymondham, should be set apart as a new settlement hierarchy to accommodate a higher portion of the additional growth.

2.86 Notwithstanding the above comments, we do question why Harleston, as the smallest Main Town, is identified for allocations totalling 450 dwellings in addition to the existing commitments (173 dwellings). Harleston is the least accessible Main Town, not being located on the rail network or on an A road which connects to Norwich and is not located within the Norwich Policy Area or the SHMA Core Area.

2.87 The Draft Strategy is therefore not considered to be justified or effective in line with the requirements of the Framework. As such, the proposed strategy is considered unsound.

Comment

Representation ID: 22294

Received: 16/03/2020

Respondent: Barton Willmore

Q43 - 44) Consultation Questions for Policy 7.3 – The Key Service Centres

2.88 We support the identification of the Key Services Centres as locations which have an important role to play within the overall settlement hierarchy, providing facilities and services to serve the settlement and its hinterland.

2.89 Of these, the Draft Strategy only seeks to allocation additional land in Acle, Blofield, Hingham and Loddon/Chedgrave for housing, totalling 515 dwellings. 2.90 With the exception of Hethersett, which has a significant existing deliverable commitment, none of the Key Service Centres are located within the Cambridge Norwich Growth Corridor. However, Poringland, Hethersett, Brundall and Blofield are located within the Norwich Policy Area and, additional to these, Acle is located within the SHMA Core Area.

2.91 Whilst we do not object to the approach to allocating a limited level of development to the Key Service Centre, in line with our comments in respect of the Main Towns, the strategy needs to be justified, including ensuring it aligns with the Plan’s Vision and Aims. As currently drafted, it is unclear why settlements outside of the NPA/Core Area (the area with the strongest functional connection to Norwich) have been chosen in place of those within it. Q45 - 46) Consultation Questions for Policy 7.4 – The Village Clusters

2.92 We object to the approach advocated for the village clusters. Whilst it is acknowledged that these can make a vital contribution towards meeting housing and other growth requirements across the Plan Period, to arbitrarily allocate 1,200 additional homes is not justified or supported by clear evidence. We would argue it conflicts with the principles of sustainable development, and that growth should be focused on larger settlements, particularly those in more sustainable locations, such as the A11 corridor, served by rail and within the Cambridge – Norwich Tech Corridor.

2.93 Paragraph 25 of the Draft Strategy acknowledges that whilst the GNLP promotes housing choice and supports economic activity within the rural parishes, South Norfolk has decided to progress a separate development plan document to meet the overall housing numbers for its village clusters set out in the plan.

2.94 The decision to delay allocation of these sites until a further Development Plan document has been drafted, consulted on, and Examined separately risks serious impeding delivery of a substantial element of housing growth to be delivered by the Plan. Further, the current approach would support up to 80 separate small allocations if it is based on sites of no more than a hectare in size.

2.95 To ensure the Plan is positively prepared, effective and consistent with national policy, the GNLP should be seeking to allocate all housing to achieve its total growth needs in the GNLP, and distributed in a clearly evidenced manner that reflects the principles of sustainable development.

Comment

Representation ID: 22295

Received: 16/03/2020

Respondent: Barton Willmore

Q43 - 44) Consultation Questions for Policy 7.3 – The Key Service Centres

2.88 We support the identification of the Key Services Centres as locations which have an important role to play within the overall settlement hierarchy, providing facilities and services to serve the settlement and its hinterland.

2.89 Of these, the Draft Strategy only seeks to allocation additional land in Acle, Blofield, Hingham and Loddon/Chedgrave for housing, totalling 515 dwellings. 2.90 With the exception of Hethersett, which has a significant existing deliverable commitment, none of the Key Service Centres are located within the Cambridge Norwich Growth Corridor. However, Poringland, Hethersett, Brundall and Blofield are located within the Norwich Policy Area and, additional to these, Acle is located within the SHMA Core Area.

2.91 Whilst we do not object to the approach to allocating a limited level of development to the Key Service Centre, in line with our comments in respect of the Main Towns, the strategy needs to be justified, including ensuring it aligns with the Plan’s Vision and Aims. As currently drafted, it is unclear why settlements outside of the NPA/Core Area (the area with the strongest functional connection to Norwich) have been chosen in place of those within it. Q45 - 46) Consultation Questions for Policy 7.4 – The Village Clusters

2.92 We object to the approach advocated for the village clusters. Whilst it is acknowledged that these can make a vital contribution towards meeting housing and other growth requirements across the Plan Period, to arbitrarily allocate 1,200 additional homes is not justified or supported by clear evidence. We would argue it conflicts with the principles of sustainable development, and that growth should be focused on larger settlements, particularly those in more sustainable locations, such as the A11 corridor, served by rail and within the Cambridge – Norwich Tech Corridor.

2.93 Paragraph 25 of the Draft Strategy acknowledges that whilst the GNLP promotes housing choice and supports economic activity within the rural parishes, South Norfolk has decided to progress a separate development plan document to meet the overall housing numbers for its village clusters set out in the plan.

2.94 The decision to delay allocation of these sites until a further Development Plan document has been drafted, consulted on, and Examined separately risks serious impeding delivery of a substantial element of housing growth to be delivered by the Plan. Further, the current approach would support up to 80 separate small allocations if it is based on sites of no more than a hectare in size.

2.95 To ensure the Plan is positively prepared, effective and consistent with national policy, the GNLP should be seeking to allocate all housing to achieve its total growth needs in the GNLP, and distributed in a clearly evidenced manner that reflects the principles of sustainable development.

Comment

Representation ID: 22296

Received: 16/03/2020

Respondent: Barton Willmore

Q48) Any other Comments?

2.96 As set out within our March 2018 representations to the Growth Options Consultation Document we continue to support the use of a Policy area focused towards Norwich City.

2.97 Historically this has been achieved with the Norwich Policy Area (NPA) which enabled growth to be focused in the right areas to deliver a Norwich-centric spatial strategy and allow for appropriate monitoring.

2.98 The SHMA (2017), identifies that the NPA itself does not form a functional housing market area (HMA). As such, the Growth Options Consultation Document identified the GNLP would no longer include an NPA specific housing land supply.

2.99 The Draft Strategy contains no reference to the NPA or the ‘Core Area’ which the SHMA identifies as a functional HMA.

2.100 We strongly object to the loss of a Policy Area focused towards Norwich City with the Draft Strategy continuing the approach to confuse the role of a SHMA for the purposes of determining Housing Needs and a specific policy based area to ensure the right growth is delivered in the right locations.

2.101 The Greater Norwich Technical Report prepared to support our March 2018 representations (Appendix 2) the NPA continues to represent a relevant area to direct growth, being an appropriate Travel to Work Area where future job growth will be focused.

2.102 The GNLP evidence base further provides support for a functional HMA, in the form of a ‘Core Area’ (including Acle, Aylsham and Loddon). However, given no other settlements outside this area are sufficiently self-contained to establish a separate HMA (or areas), the SHMA concludes the most appropriate HMA, for the plan, is the Central Norfolk HMA.

2.103 Nevertheless, there is a clear evidence an area exists with the strongest functional connection to the Norwich Urban Area.

2.104 We strongly urge the GNLP to continue the approach set by the NPA in directing growth to a defined area (whether NPA or similar distinction) with the strongest functional relationship to Norwich. The boundary of this area should also reflect the preferred spatial strategy i.e. towards an A11 focus.

2.105 Without a Policy Area focusing growth in key locations, there are risks that the strategy will fail.