Draft Greater Norwich Local Plan – Part 1 The Strategy

Support

Representation ID: 21795

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full comments
We support the plan objectives as set out at Paragraph 135 of the Draft Strategy document, and in particular the need to make efficient use of land for housing, particularly given the long-term and historic challenges faced in the GNLP as regards the delivery of housing against targets;

Comment

Representation ID: 21796

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
Policy 1 – The Sustainable Growth Strategy – we broadly support the aims of Policy 1 but would support the Alternative Approach suggested in respect of the need to allow for additional windfall delivery to contribute towards the Plan targets. It is our view that, in light of the plan objectives referred to above, there may be scope for sites which are already consented (and in some cases where permissions have been implemented) to deliver additional residential units over and above the number consented – subject to the necessary planning approvals. It is our view that such an approach would be particularly appropriate within the Norwich Urban Area where sites are sustainably located;

Object

Representation ID: 21797

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
Policy 2 (iii) – Delivery Plans – whilst we support the need for the delivery of housing in order to meet targets (both in 5YHLS terms and across the longer Plan period), and we recognise the role of Delivery Plans in helping to ensure that delivery occurs, we believe that such Delivery Plans need to take account of the following allowances in order to work effectively:
a.Changes in market demand;
b.Viability challenges; and
c.Delays arising within the planning system or through the public engagement process;

Comment

Representation ID: 21798

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
Policy 5 – Homes – whilst we welcome the acknowledgement that high costs can have an impact on viability, and therefore the ability of sites to deliver 33% affordable housing, it is our view
that this approach should not be restricted solely to the City centre area. All sites within the Norwich Urban Area will by their urban nature be constrained and will face the same challenges as City centre sites, and it is our view that the same flexible approach should be applied to those sites, with the lower 28% threshold being applied. It is acknowledged that such a flexible approach would need to be supported by viability evidence;

Object

Representation ID: 21799

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
Policy 7.1 – The Norwich Urban Area including the fringe parishes – we object to this policy on the grounds that there are no new allocations, including those proposed at GNLP2170 and GNLP2171, within the Thorpe St Andrew area. We will deal with the Site Allocations further (in the attached), and this objection should therefore be read in the context of the objections and comments (in the attached);

Object

Representation ID: 21800

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
Appendix 1 – Infrastructure Requirements – in respect of ‘Sports and Leisure’ we note that the Greater Norwich Sports Facilities Strategy is currently being reviewed. On this basis, we would question the ability of any decisions or judgements to be made in respect of proposed site allocations on the grounds of sports or leisure provision. We have commented further in this respect (see attached) in relation to the Site Allocations, and this comment should be read in the context of the comments (in the attached)

Object

Representation ID: 22096

Received: 13/03/2020

Respondent: Quantum Land

Agent: Barton Willmore

We object to the spatial strategy for housing and the various linked policies associated with delivering that spatial strategy – Policy 1 and Policies 7.1-4. Our main objections are:
1.The lack of focus and housing allocations proposed for the “Key Service Centres” in comparison to lower settlement hierarchy tiers; and
2.The allocation of no housing growth to Brundall;
Of the 7,840 dwellings proposed for new allocations, they are distributed as follows:
1.Norwich Urban Area 56% (4,395 units)
2.Main Towns 16% (1,250 units)
3.Key Service Centres 7% (515 units)
4.Village Clusters 21% (1,200 units)
Whilst the focus on the urban area of Norwich Urban Area is appropriate, we consider that the balance across the settlement hierarchy is not optimal or justified. The “Main Towns” and “Key Service Centres” have individually less housing directed to them than the bottom of the settlement hierarchy, the “village clusters”, which has more dwellings. In fact, the second and third tiers of the settlement hierarchy have almost the same number in totality as the bottom tier. This seems unjustified given that they are the least sustainable locations for growth.
This if illustrated in that of the 9 key Service Centres only 4 have any new dwellings proposed and 1 of those 3 have only 15 units. Brundall has no housing allocated to it all despite being one of the closest and well-connected settlements to Norwich.
It is acknowledged that in both the Main Towns and Key Service Centres there are many “reasonable alternatives” that exist and so under alternative spatial approaches, a different spatial pattern could be achieved more sustainably. This is acknowledged in the consultation questions asked which notes:
“The 8% proportion of new housing in key service centres could be increased as many reasonable alternative sites have been proposed in key service centres. However, overall the preferred option is considered to provide a suitable amount of growth in relation to the settlement hierarchy, infrastructure and local constraints. The Sites document sets out the preferred option and reasonable alternative sites.”
We consider the spatial distribution should be reconsidered.

Object

Representation ID: 22097

Received: 13/03/2020

Respondent: Quantum Land

Agent: Barton Willmore

We object to the spatial strategy for housing and the various linked policies associated with delivering that spatial strategy – Policy 1 and Policies 7.1-4. Our main objections are:
1.The lack of focus and housing allocations proposed for the “Key Service Centres” in comparison tolower settlement hierarchy tiers; and
2.The allocation of no housing growth to Brundall;
The settlement hierarchy is defined as:
1.Norwich Urban Area
2.Main Towns
3.Key Service Centres
4.Village Clusters
Of the 7,840 dwellings proposed for new allocations, they are distributed as follows:
1.Norwich Urban Area 56% (4,395 units)
2.Main Towns16% (1,250 units)
3.Key Service Centres 7% (515 units)
4.Village Clusters21% (1,200 units)
Whilst the focus on the urban area of Norwich Urban Area is appropriate, we consider that the balance across the settlement hierarchy is not optimal or justified. The “Main Towns” and “Key Service Centres” have individually less housing directed to them than the bottom of the settlement hierarchy, the “village clusters”, which has more dwellings. In fact, the second and third tiers of the settlement hierarchy have almost the same number in totality as the bottom tier. This seems unjustified given that they are the least sustainable locations for growth.
This if illustrated in that of the 9 key Service Centres only 4 have any new dwellings proposed and 1 of those 3 have only 15 units. Brundall has no housing allocated to it all despite being one of the closest and well-connected settlements to Norwich.
It is acknowledged that in both the Main Towns and Key Service Centres there are many “reasonable alternatives” that exist and so under alternative spatial approaches, a different spatial pattern could be achieved more sustainably. This is acknowledged in the consultation questions asked which notes:
“The 8% proportion of new housing in key service centres could be increased as many reasonable alternative sites have been proposed in key service centres. However, overall the preferred option is considered to provide a suitable amount of growth in relation to the settlement hierarchy, infrastructure and local constraints. The Sites document sets out the preferred option and reasonable alternative sites.”
We consider the spatial distribution should be reconsidered.