Draft Greater Norwich Local Plan – Part 1 The Strategy

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Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 6: Do you support or object to the vision and objectives for Greater Norwich?

Representation ID: 22125

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

The vision for the Local Plan is to achieve a ‘vibrant, healthy, inclusive and growing communities supported by the delivery of new homes, infrastructure and an enhanced environment.’ It is clear from Section 3 – The Vision and Objectives for Greater Norwich that a key theme throughout is playing a part in the national commitments to achieving net zero greenhouse gas emissions by 2050.

Scott Properties is passionate about the need to address Climate Change. It is agreed that this is one of the most important factors to our future and as such should be a key consideration in the preparation of the new Local Plan.

Chapter 14 of the National Planning Policy Framework (NPPF) focusses on ‘Meeting the challenge of climate change, flooding and coastal change’.
“The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.”
(Paragraph 148 – NPPF, 2019)

The Plan needs to be visionary looking forward beyond 2038, in particular having regard to the Government’s commitment to reach Net Zero Carbon by 2050. The Plan also needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the plan area.

We believe that our client’s site that has been considered as a Reasonable Alternative can help address the visions and objectives for the Greater Norwich. The scheme currently proposed at Land between Shelfanger and Mount Street could provide approximately 24 single-storey dwellings and publicly accessible open space, whilst facilitating the future expansion of the medical centre through a land transfer. Most importantly, the extensive area of new publicly accessible open space will make a positive contribution to the community’s health and well-being and can deliver significant biodiversity enhancements.

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Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 9: Do you support, object, or have any comments relating to the approach to Housing set out in the Delivery Statement?

Representation ID: 22126

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

The Delivery Statement set out at Paragraph 139 of the Draft Strategy sets out that the Plan will promote a pro-active approach to delivery through only allocating housing sites where a reasonable prospect of delivery can be evidenced, taking into account policy requirements. This approach accords with para 67 of the NPPF and is supported.

In terms of providing flexibility and including a 9% buffer this accords with the objective of ensuring that a sufficient amount and variety of land can come forward. It is also recognised that it is proposed that the buffer will increase to 10% at the Regulation 19 stage, when the village clusters allocations will be included. It is acknowledged that the plan aims to comply with the NPPF paragraph 68 requirement to accommodate at least 10% of housing requirement on sites no larger than 1 ha. However, given the uncertainty around the Carrow Works site (1,200 homes), it is recommended that where reasonable alternative sites exist in sustainable locations, additional smaller sites of up to c. 25 dwellings (expected delivery from 1 ha) should also be allocated throughout the Plan area to increase certainty around delivery and supply, particularly in the early parts of the Plan period, supporting the Government’s objective of significantly boosting the supply of homes. Our client’s site, Land between Shelfanger Road and Mount Street (Site Reference: GNLP0341), is one such site which should be allocated given its central location in a highly sustainable settlement.

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Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 11: Do you support, object, or have any comments relating to the approach to Infrastructure set out in the Delivery Statement?

Representation ID: 22127

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

the Delivery Statement states that it will continue to work to coordinate delivery with providers including Highways England and Anglian Water to ensure infrastructure will be delivered. The below approach outlined within the statement is also supported by our client.
- On-site and off-site provision required of development through conditions or legal agreements;
- Pooled use of CIL;
- Maximising opportunities to access Government and other sources of funding;
- Capital investment of public bodies and utilities companies; and
- Locally led delivery vehicles.

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Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 12: Do you support, object, or have any comments relating to the Climate Change Statement?

Representation ID: 22128

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

As previously outlined within our response to Question 6, Scott Properties is passionate about the need to address Climate Change and as such supports the Climate Change Statement that has been included within the Draft Strategy at paragraph 141.

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Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 13: Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

Representation ID: 22129

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

The preferred option for the Local Plan combines the concentration of the majority of development in and around Norwich and on the Cambridge to Norwich Tech Corridor, a large focus on market towns, with an element of dispersal to villages. This approach is supported and provides a balance across a range of the objectives of the Local Plan.

This approach would see housing commitments providing a total minimum deliverable commitment of 6,342 within the Main Towns over Plan period of 2018 – 2038.

The settlement hierarchy’s recognition of the contribution that the Main Towns like Diss make to the delivery of housing is acknowledged and supported. While it is acknowledged that Norwich should be the principal focus growth, the market towns have an important role in creating a vibrant sub-region, and in the case of Diss serve wide hinterlands from which people are drawn to use the town’s shops, services, and facilities, including both primary schools and secondary schooling as well as the train station.

In addition to the above, the preferred settlement hierarchy follows a typical approach and looks at the different levels of services between places, we support the clustering of villages within the countryside and believe this recognises that in some cases, existing businesses within the villages provide services not only for the village that they are located in, but also for smaller neighbouring settlements which may rely on the services they provide.

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Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

Representation ID: 22130

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

In developing the new Greater Norwich Local Plan, it will be important that an adequate mix of sites is promoted including a proportion of smaller sites as well as sites to meet specific housing needs (including housing for older people). Our client’s site, Land between Shelfanger and Mount Street could make a meaningful and positive contribution towards meeting these goals.

With regard to the delivery of new housing, the Greater Norwich Local Plan’s inclusion of a 9% buffer is supported, and while a higher buffer of up to 20% would normally be advisable to offset the potential for slow delivery on some sites, in particular large strategic sites. It is acknowledged that no allowance has been made in this instance for windfall within the overall supply and the contingency of approximately 2,000 homes provides additional flexibility to ensure that the overall housing needs are met. However, as outlined above, given the uncertainty around the Carrow Works site (1,200 homes), it would be advisable to allocate smaller sites up to c. 25 units (c. 1 ha) across the Plan area to help boost the supply of new homes.

It is acknowledged that the Plan aims to comply with paragraph 68 of the NPPF by accommodating at least 10% of the housing requirement on sites no larger than 1 ha, however, where there are reasonable alternatives available these should be included to maintain supply and avoid the need to rely on less certain strategic sites or large contingency sites.

The “presumption in favour of sustainable development” is at the heart of the National Planning Policy Framework 2019 (NPPF). The Planning and Compulsory Purchase Act 2004 (Section 39(2)) establishes a legal requirement for Plans to be prepared with the objective of contributing to the achievement of sustainable development.

Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and that it is therefore important that a sufficient amount and variety of land comes forward where it is needed.

To ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. The Government’s recently published housing delivery figures for 2019 indicate delivery for the Greater Norwich area comprising Broadland, Norwich and South Norfolk to be at 140%. This is very encouraging, however, housing delivery can be fragile and susceptible to changes in the economy or delays in the delivery of key infrastructure necessary for strategic sites to come forward.

Further to the above, Policy 1 – The Sustainable Growth Strategy sets the settlement hierarchy for the Plan Area as follows:
1. Norwich Urban Area (Norwich and Norwich Fringe)
2. Main Towns
3. Key Service Centres
4. Village Clusters

Further detail on Village Clusters is provided at Appendix 5 of the Draft Strategy, as the preferred option the Council consider that a ‘cluster approach better reflects the way people access services in rural areas and enhances social sustainability by facilitating levels of growth in small villages’ This statement is supported, however it is unclear how this approach will work effectively within the Plan area and how achievable it will be. As such, a focus should be made on small and medium sites. The distribution of growth to a variety of sites will enable a steady delivery of homes and ensure the District can meet its housing targets throughout the Plan period.

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Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 16: Do you support, object or wish to comment on the approach to Review and Five-Year Land Supply?

Representation ID: 22131

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

Policy 1: The Sustainable Growth Strategy states that the Plan will be reviewed 5 years after its adoption. At Paragraph 33, the NPPF states that Local 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, it is not considered that Policy 1 is consistent with National Policy and this needs to be made more clear, stating that a review will be undertaken within five years after adoption or in the event housing delivery, or housing land supply falls below the annual requirement.

In respect of Five-year land supply, as outlined at Policy 1 of the Draft Strategy, the five-year housing land supply will be calculated across the whole of the three districts comprising Greater Norwich. This approach is supported, however, given the political nature of planning decisions it should be monitored to ensure that all three districts continue to deliver in a proportionate manner.

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Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 18: Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

Representation ID: 22132

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

The preferred approach to sustainable communities is the requirement for sustainability assessments to accompany planning applications for major developments. This approach is supported and is considered to be in line with the National Planning Policy Framework.

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Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 25: Do you support, object or have any comments relating to the approach to on-site and local infrastructure, services and facilities?

Representation ID: 22133

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

Policy 4 – Strategic Infrastructure outlines the key elements to strategic infrastructure improvements that will be undertaken to support timely delivery of growth. The approach for on-site and local infrastructure, services and facilities is as follows:
‘Development proposals will provide on-site services and facilities and support local infrastructure capacity improvements through on-site provision, providing land and developer contributions.’

This approach is supported by our client and as proposed at their site, Land between Shelfanger Road and Mount Street (Site Reference: GNLP0341) there would be considerable community benefits from the provision of land to facilitate the expansion of the medical centre and the enhancements and public accessibility of a large area of open space.

There is scope within this part of Policy 4 to also address the need to provide community uses on larger schemes that will benefit both future and existing residents.

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Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 29: Do you support, object or have any comments relating to the approach to accessible and specialist Housing?

Representation ID: 22134

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Representation:

The Draft Strategy acknowledgs at paragraph 245 that an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation. The Plan seeks to assist Norfolk County Council’s aim to ‘reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supporte housing’.

This approach is supported in both National Policy and Planning Practice Guidance (PPG). In particular the ‘Housing for Older and Disabled People’ PPG, which requires plan makers to consider the diverse needs of older people, including those approaching retirement. The PPG also states that 'Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people' (Paragraph: 006 Reference ID: 63-006-20190626). We support the Draft Strategy’s recognition of the need to provide suitable homes in the right locations. A lack of availability of suitable accommodation forces people to move away from friends and family to find a property more suited to their needs, or, to make costly adaptions to their own homes.

In order to ensure an adequate provision of specialist housing, Scott Properties believe that Policy 5 – Homes should encourage a range of properties to suit a variety of needs, and specific allocations or requirements within site specific policies should be made for specialist housing, and portions of allocations such as Land between Shelfanger and Mount Street, Diss should be set aside for specialist housing. This will ensure that a varied type of housing can come forward to meet the diverse needs of older people as set out in PPG and provide choice for those in later life, which can include:
- Age-restricted general market housing
- Retirement living or sheltered housing
- Extra care housing or housing-with-care

To ensure a variety of the housing, as identified within PPG above is delivered within Greater Norwich, the Plan should make specific allocations as opposed to just a generic housing mix policy that requires a diverse mix of housing. General housebuilders do not build specialist housing, and by providing housing that is deemed as suitable for older people that is also available to the general housing market does not adddress the varied and diverse needs of older people, or those with a disability.

We would draw attention to the recent interim findings of the Inspector following the examination of the Suffolk Coastal Local Plan, which states:
'The Plan as submitted seeks to address the needs of older people through Policy SCLP5.8 Housing Mix. The Policy however, whilst supporting the provision of housing for older people, does not address clearly the significant need identified and would not be effective in delivering the market or affordable housing units for older people required. The Policy and supporting text should be amended to set out how the housing needs of older people will be addressed through the provision of housing and to boost the supply of this type of housing.'

We would therefore encourage the Council to consider the merits of allocating specific sites for specialist accommodation within the Greater Norwich Local Plan. It is vitally important that suitable housing is provided to meet the needs of an ageing population.

Approximately 24 single-storey properties specifically designed for those aged 55 and over as well as those with or supporting someone with a disability are proposed at Land between Shelfanger and Mount Street, Diss (as shown on the accompanying indicative masterplan). Providing this type of accommodation in a central town location, allows people to move to a property better suited to their current or future needs, whilst remaining close to friends and family.

At present, the retirement housing market is dominated by a handful of providers who typically produce flatted developments within town centres for those approaching the later years of their lives (predominantly 75+ years of age). This results in a lack of choice and highly inflated prices for those aged 75+, who are looking to move to a property more suited to their current or future needs but also wish to remain close to friends and family. Needless to say, the couples and individuals who are of the 60-75 age bracket are left with no alternative housing option, other than making costly adaptations to their existing property.

Extensive research has shown a number of benefits arising from the provision of suitable specialist accommodation for the older population. The lack of suitable alternative and attractive accommodation acts as a significant barrier to down-sizing for the over 55s. Providing such accommodation will facilitate the release of under-occupied housing through downsizing. This will free up more housing in the locality for families, thus reducing the pressures on the local authority to make provisions for additional housing and costly adaptations to their existing housing stock.

The proposed development could make contribution to not only accessible and specialist housing but also much need affordable and market housing within the Greater Norwich area in a sustainable location. As such we consider the GNLP should reconsider our client’s site Land between Shelfanger and Mount Street, Diss and include it as an alloaction in the Regulation 19 Draft Plan.

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