Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 23068

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We have fundamental concerns with the draft Plan as it stands. These derive from the
Introductory sections of the Plan, and although our concerns do not relate to inaccuracies in terms
of what the Plan is to achieve, we are concerned with how the Plan itself aligns with the stated
position and its lack of alignment with the proposed policies. This is turn means that the purpose
of the Plan is not clear.

Paragraph 2 indicates that the GNDP have taken a long-term view of development needs to ensure
the development in the right place and at the right time. We contend that the GNDP has not
taken a long-term view or sought to locate development in the right place at the right time. As
is set out in further detail in response to Policy 1, the GNLP does not plan for sufficient housing
to meet the local needs in accordance with the National Planning Policy Framework (NPPF) and
National Planning Policy Guidance (NPPG). It does not take a long-term view in terms of the
growth of the Cambridge-Norwich Tech Corridor, and in policy terms, does little to encourage or
stimulate the success of the Corridor. This stance is not aligned with wider strategies and
initiatives, and therefore we consider the aim of the plan is undermined.

The Plan is not considered to identify sites to meet Greater Norwich’s growth needs from 2018 –
2038 sustainably. The preferred sites identified are not the most sustainable when compared to
reasonable alternatives and the Plan defers the allocation of sites for 1,200 homes to a future
‘Village Clusters’ Plan, which is discussed further in respect of Policy 1.

The introductory section sets out the context of other strategies which ‘provide the context for
development in Greater Norwich’. We agree with all of the initiatives and strategies referenced
but have grave concerns that this draft Plan does not align its growth strategy with them, as
detailed further below:
• Projects of national significance – improvements to A11 trunk road. This recently dualled
and important link between Cambridge and Norwich has been subject to substantial
investment. It is imperative that growth should maximise and support the investment
that has already been made. In this context allocating growth at SGV, with a new junction
on the A11 (funded by the development) would capitalise on these improvements, rather
than rely on significant and potentially uncertain future road improvements.
• Economic Growth – as is set out in Appendix 3 (Technical Review of Housing Need
prepared by Turley), we contend that the Plan does not make sufficient provision for
housing to meet the economic growth requirements.
• Transport Priorities including Transforming Cities – the recent Transforming Cities funding
bid includes allocation of funding for a mobility hub at Wymondham Station. The case
for investment should be supported through reaffirming Wymondham’s position in the
settlement hierarchy and its growth capabilities in this context. In accordance with
achieving sustainable development in line with the NPPF, the GNLP should align growth
locations with sustainable transport improvements. There is not sufficient recognition for
the growth potential of Wymondham, either in the context of the settlement hierarchy;
its location within the Tech Corridor; and its sustainable transport connections (with
planned investment). The GNLP should plan comprehensively for strategic growth at
Wymondham in this context and not simply provide for smaller scale sites incrementally.
• The GNLP indicates at paragraph 22 that there is a need for the Plan to look beyond the
current end date of 2038 by setting a strategy that can be sustainably added to in the
long term. This approach is not reflected in the policies contained within the plan. There
is, in fact, recognition that a new settlement may be needed in a review of the plan but
that the reason one is not to be allocated now is due to the long period for such
developments to establish (Paragraph 168 of the GNLP Strategy Document) . This wholly
contradicts paragraph 22. To plan ahead, the GNLP should be proactive in identifying and
allocating a new settlement to allow strategic scale growth to progress with certainty,
both for those responsible for its delivery and for the local communities affected.
• Paragraphs 24 - 26 indicates that a separate document is to be produced to allocate ‘small
sites’ across South Norfolk. This significantly undermines the purpose of the Plan by not
making clear how the Plan is treating its strategic policies in accordance with paragraphs
17 – 22 of the NPPF. These should make sufficient provision for housing (para 20) and
should provide a clear strategy for bringing sufficient land forward to address objectively
assessed needs over the plan period. We recognise that the NPPF allows for non-strategic
policies to be covered in a separately where they set out more detailed policies for specific
areas, neighbourhoods or types of development. However, the scale of growth attributed
to the Village Clusters document (at 1,200 homes) is considered significant in the context
of the relatively minimal new allocations made.
• Worryingly, it is also clear from the Interactive Mapping used by GNLP that it is not just
small sites that have been deferred for assessment in this separate plan. Some medium
to large scale sites across South Norfolk have also been deferred and therefore are not
assessed as part of the GNLP. Given that this is a Joint Local Plan, the approach of
preparing a separate document for just one constituent authority in isolation is not
considered a robust approach to plan making and risks making the GNLP ineffective. We
strongly consider that land for the 1,200 homes should be allocated within the current
GNLP: this is the only way to ensure growth options are considered holistically, particularly
in the context of infrastructure requirements.

Object

Representation ID: 23069

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

Our concerns with regard to the Spatial Profile are closely related to the introductory comments
above and focus on the lack of alignment with the policy direction of the Plan. We make the
following observations:
• Wymondham is the largest settlement outside of the Norwich Urban Area. Whilst it has
been subject to a number of development site allocations/consents in recent years, the
location of Wymondham and its services and amenities make it an ideal location for
strategic growth. This is not realised in the Plan. Some minimal additional growth is
allocated in two locations on the edge of the town, but it is not of a scale which can secure
significant investment in infrastructure and thus will put pressure on existing services and
facilities. Examining the potential for the reasonable alternative of a new settlement in
this location – which would deliver a more sustainable pattern of growth than that
currently proposed for allocation – is not considered in the plan.
• There is need to re-balance growth in the Greater Norwich area which has focused on
Norwich itself and the north east triangle in particular. This growth is not aligned with the wider growth and economic strategies which underpin the plan. As the next largest
settlement in the plan area, as well as being located in the Cambridge-Norwich Tech
Corridor and with a close relationship to the world class facilities at Norwich Research Park
, Wymondham should be identified as the priority location for accommodating strategic
development.
• Paragraph 67 states that the A11 corridor is a major focus for growth. We do not consider
this to be the case in the GNLP as no strategic sites with immediate/direct access to this
route have been allocated. SGV is positioned squarely within the A11 corridor with direct
access to it, and therefore it is not clear why this location has been overlooked for
allocation to realise the Plan’s stated growth objectives.
• In addition - and contrary to the statement that the A11 is a major focus for growth - the
Plan highlights the growth opportunities arising from other priority road investment
schemes. These improvements have not yet been undertaken, and some still need to
secure approval and funding, yet growth is more closely associated with these ‘uncertain’
future improvements than it is with the newly dualled A11. We cannot understand how
this approach can be presented as robust or sustainable, given it fails to maximise
infrastructure investments already completed.
• The context of the Transforming Cities funding bids is welcomed as the projects identified
are important in promoting the modal shift away from the private car. However, as noted
above such investments should inform and lead the approach to allocating growth to
ensure that sustainable transport connections can be planned in from the outset and that
the benefits of funding and investment can be maximised. This is the case for the
Wymondham Mobility Hub which will significantly improve Wymondham’s public transport
offer and as such should influence and facilitate growth. If modal shift is to be achieved,
particularly in new developments, it is essential that they are well positioned and have
direct access to the improved public transport network, but also that they are of a scale
which does not simply perpetuate current mobility patterns to access necessary services
elsewhere.

Object

Representation ID: 23070

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support and agree with the Vision insofar as it provides a sound basis for the Local Plan and
focuses on the pertinent issues that are key to the success of the area. The Vision and Objectives,
however, need to be effectively translated into policies and allocations within the Plan. There are
a number of important areas where there is a risk of misalignment, as evidenced below:

• The first paragraph of the Vision relates to a ‘low-carbon’ economy and to competing
globally through world class knowledge intensive jobs in the Cambridge–Norwich Tech
Corridor. To realise this ambition and economic objective of the Plan requires policies
that will encourage and support the success of the Corridor by ensure that it has the jobs,
homes and infrastructure it needs to flourish. This is not evident in the current draft Plan
allocations and policies.
• The GNDP rightly envision that there will be a variety of new homes that will cater for the
needs of all and that most homes will be built in and around Norwich and in the Cambridge
Norwich Tech Corridor. We do not consider that the allocations within the draft plan will meet the needs of all, or be in the right place to do so in a sustainable way: the current
draft plan results in 69% of the housing growth in the plan period coming from the Norwich
Urban area. We do not dispute that the Urban Area should be a focus for growth but with
almost 70% of the identified need relying on the urban area, the spatial strategy simply
does not align with the Vision and Objectives and thus risks not meeting the requirements
of those for whom the new housing is designed to satisfy. Whilst we acknowledge that
Norwich itself is understood to be included within the Tech Corridor, it is clear that in
spatial and policy terms Norwich Urban Area and the Corridor are considered as two
separate growth areas. With so much growth focused at Norwich, it is unclear how the
Plan meets its own objective of making provision for significant growth in in the Corridor.

Object

Representation ID: 23071

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the Delivery Statement and consider it a proactive and positive approach to securing
the growth required within Greater Norwich. As has been previously discussed above, however,
we do not consider that the priorities contained therein are achievable as the policy basis for them
is not evident within the plan. Crucially, we question how GNLP consider the Plan supports the
Tech Corridor to become an increasingly important axis to other significant growth corridors?

Furthermore, the Delivery Statement suggests the plan only allocates sites with a reasonable
prospect of delivery. Orbit has excellent local knowledge and experience of the market and do
not consider that the annual delivery rates that would be derived from the total commitments and
allocations, for instance in the ‘growth triangle’ (approximately 670 homes per annum) over 20
years is achievable in the context of what the market can deliver and support. We appreciate
that there are already substantial commitments in this location but question the logic of a plan
which seeks to allocate further homes and apply such annual delivery rates to an area which has
previously experienced slower than anticipated delivery rates? The delivery model of Orbit,
whereby Orbit themselves construct a significant proportion of the homes, would demonstrate
resilience against the delivery risks of other strategic sites that are controlled by multiple volume
housebuilders. Orbit’s availability of and access to finance also mean that delivery is not impeded
by significant upfront infrastructure costs.

Support

Representation ID: 23072

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

The climate change statement is welcomed and supported. However, integral to achieving the
measures set out is providing the right type of development in the right places. The scale of new
settlements offer the potential to plan comprehensively to meet all components of sustainability
which is simply not achievable through small to medium scale sites. We contend that the
allocation of SGV would contribute significantly to achieving the measures in the climate change
statement given its potential for a substantial modal shift to public transport and its commitment
to creating a NetZero development from the outset. Most notably, attributing 15% of the housing
requirements (1,200 homes) to villages just within the South Norfolk area will not lend itself to
sustainable modes of travel or will help facilitate any significant investment in the delivery of
renewable or low carbon energy generation. We assert that in order to better align with the
Council’s climate change statement and provide certainty for future growth across South Norfolk,
as a minimum, this unallocated housing requirement should be met within SGV as part of a wider GV allocation, and the Plan should be much more proactive in seeking out opportunities for
development that will tackle the climate change challenge head on.

Support

Representation ID: 23073

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the proposed settlement hierarchy and it is logical for the Norwich Urban Area and
the main towns to be the focus for growth. A clear vision and objectives for the Greater Norwich
Area are articulated in the Plan and there is a significant opportunity over the Plan period for the
area to flourish and attract significant growth and investment and become a nationally important
destination in terms of fulfilling an economic and educational, as well as tourism role within the
UK.

Object

Representation ID: 23074

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

There is, however, considered to be a significant lack of clarity regarding the approach to
distributing growth as there are multiple different locational criteria taken into account in addition
to the settlement hierarchy. This causes confusion and means that it is difficult to determine
whether the approach to distributing growth is robust. The priorities for locating growth, as
suggested in GNLP, include:
• ‘Growth broadly follows the settlement hierarchy’;
• ‘Focusses most of the growth in locations with best access to jobs, services and existing
and planned infrastructure in and around the Norwich Urban Area and the Cambridge
Norwich Tech Corridor’;
• ‘In the strategic growth area – which also includes the Cambridge Norwich Tech Corridor’.

It is not clear which of these take precedence and how they are intended to interrelate. As such,
it is not appropriate to simply ask whether there is agreement with the distribution of housing
within the hierarchy as this is not the only factor affecting the location of growth. This approach
should be clarified.

It is also not clear, apart from the allocations in the Norwich Urban Area, how the growth and
distribution strategy is reflective of any of the other reasonable alternatives considered in the
2018 Growth Options consultation. Worryingly, apart from providing a brief rationale as to why
alternative approaches have not been pursued in respect of Policy 1, there is no formal SA of
alternative approaches to the distribution of homes and the level of housing growth. Despite
reference to options being considered at previous Regulation 18 stages, this is not a robust
approach and could put at risk the draft plan in respect of its locational strategy as it has not been
subject to testing against alternatives. Flaws of the Sustainability Appraisal (SA) are covered in
the separate SA representation.

Furthermore, the simplistic approach of relating growth distribution to the settlement hierarchy
fails to have regard for alignment with other strategies, initiatives and investment in the area.
The Plan makes these other important considerations very clear in its introductory chapters with
particular reference to the transport network, recent and planned improvements, Transport for
Norwich, the Norfolk County Council Rail Prospectus, East West Rail and the Transforming Cities
Programme. In this context, the A11 corridor is clearly well placed to accommodate growth in
light of recent improvements and its role as the spine of the Cambridge – Norwich Tech Corridor.
Wymondham itself is a focus for investment under the Transforming Cities Programme; its railway
station is positioned on the potential extension of East West Rail and it is a growing hub for public
transport accessibility. This is not however, then reflected in the distribution of growth.

Object

Representation ID: 23075

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

Alignment of Settlement Hierarchy with Spatial Strategy
There is reference at paragraph 153 to the strategic sites contributing to the Cambridge-Norwich Tech Corridor and there is clearly a commitment throughout the Plan to supporting the Corridor and focusing growth within it. There is, however, no specific attribution of growth to the Corridor as a spatial area. Thus, there is no tangible evidence within the Plan as to how it is being supported. We strongly suggest that GNLP take an area-based approach to distributing growth; this has been partially undertaken for the Norwich Urban Area but then fails to articulate the Corridor as a spatial area for allocating sites. We contend that if the growth within the Corridor (excluding that which is attributed to the Norwich Urban Area in any case) was to be separately
identified, it would highlight that there is not in fact any significant policy support for strategic growth within the Corridor that is not delivering growth for the Norwich
Urban Area.

The Role of Wymondham as second in the hierarchy
Furthermore, we also raise concerns regarding Wymondham’s role and status. Wymondham is the largest settlement outside of the urban area and therefore placed second in the hierarchy. It is positioned at the heart of the Tech Corridor and is within the strategic growth area. The town is well served by local facilities, is situated within immediate access onto the A11 and benefits from a stopping station on the Norwich–Cambridge Rail Line. On this basis and in accordance with the distribution of growth principles set out above, Wymondham should be a key focus for
strategic-scale development.

Wymondham, however, receives the lowest quantum of growth of all the ‘main towns’ with only 100 new units allocated. We assume that the rationale for this approach is in part due to the existing commitments which already exist on the edge of the town. However, this approach is not reflective of the locational criteria that supposedly inform the distribution of future growth and we suggest that as part of the plan-making process and reviewing reasonable alternatives for growth, the locational criteria for future growth should be applied notwithstanding existing commitments. Existing commitments, coupled with the locational criteria and advantages identified in the paragraph above, simply serve to reinforce that Wymondham is an excellent location for planned strategic growth.

Impact of Contingency Allocations
We note that Wymondham is proposed as the location for a contingency provision of 1,000 additional dwellings should delivery of housing in the GNLP area not meet local plan targets (p106). However, no site(s) are identified for this contingency nor any locational criterial which would govern the selection of preferred sites or locations for this contingency in or around the town.

This approach runs counter to both the objectives and the clarity of the plan, instead providing a laissez-faire policy framework which will invite any number of speculative applications for circa 1,000 units or more numerous smaller scale applications to be submitted for consideration. There are a number of significant risks in this approach, for the main part associated with piecemeal infrastructure contributions and unmeasurable impact on existing services and the transport network. At 1,000 units, a single scheme would not be of the scale necessary to deliver significant new infrastructure on site or in totality but would instead place additional pressure on current
facilities. If multiple smaller schemes come forward to meet the contingency, these could only deliver modest localised highway improvements or financial contributions towards infrastructure.

In respect of achieving well planned growth and providing certainty around associated infrastructure delivery, a number of soundness issues can be raised with the current approach, related to:
• The uncertainty around planning for and being able to secure necessary infrastructure if
Wymondham accommodates 1,000 units in one or more unknown location(s);
• The same uncertainty applies if 1,200 units are allocated in currently unknown or
unidentified villages; and
• The failure to meet the requirement of assessing reasonable alternatives in terms of
specially considering alternatives to a) the contingency approach and b) the specific allocation of 1,200 units to the Village Clusters Document.

We strongly recommend that the 1,000-unit contingency should be attributed to the allocation of a Garden Village at Silfield.

Impact of South Norfolk Village Clusters Document It is also important to note that 1,200 homes are attributed to a future ‘South Norfolk Village Clusters Document’. In real terms this accounts for circa 15% of all new allocations within the GNLP and as such, from a hierarchy and distribution perspective, cannot be considered a sound approach that collectively means the villages accommodate approximately the same level of growth as the new allocations in the main towns.

Furthermore, the ability of the villages to accommodate growth has not been assessed and is therefore unknown. To attribute such a high figure towards them, given their position on the hierarchy, is therefore a significantly flawed approach and one that is likely to be undermined at Examination. No reasonable alternative for allocating this level of growth elsewhere within South
Norfolk or the wider GNLP area has been considered. This is a material error in the Sustainability Appraisal of the Plan and calls into question the soundness of plan making in this regard.

We strongly recommend that the 1,200 units as yet unidentified in a future Village Clusters Document should form part of the overall housing requirement to be met explicitly in the GNLP and such be attributed within the allocation of SGV.

Consideration of New Settlements
The supporting text to draft Policy 1 indicates that no new settlement is proposed at this time “as a significant proportion of the allocated sites are strategic scale commitments of 1,000 homes plus and the establishment of any new settlement is likely to take a long time” (Paragraph 168). This is a flawed assertion and has no grounding in the plan-led approach in terms of assessing reasonable alternatives and undertaking a sustainability appraisal of growth options. A similar
statement is provided in the accompanying Site Assessment booklets.

The existence of strategic commitments or other concurrent allocations have no bearing on whether a new settlement provides a more, or the most, suitable and sustainable growth option for a Local Plan. The assessment of the new settlement growth options within the Sustainability Appraisal and Site Assessment Booklets is inherently flawed and requires substantial review. We cover this point in more detail in our representations on these documents.

The approach to assessment of alternatives undertaken by the GNLP and the consequential decisions in arriving at the preferred policy option raises serious and wide-ranging issues of soundness. Most importantly, the alternative option accommodating growth at a new settlement rather than within the other growth typologies allocated (primarily urban extensions and village
clusters) has not been robustly or appropriately considered. We contend that if a robust assessment of all types of growth and distribution had been undertaken as the starting point of the GNLP, SGV would rate very highly against other reasonable alternatives given its locational characteristics, sustainability and self-containment credentials and ability to provide new facilities and amenities and investment in infrastructure.

We consider that the inconsistencies and flawed approach to the spatial distribution of growth set out within the Plan lead to a significant question mark over a large number of the proposed allocations. We contend that the current approach to the allocation of sites for least 5,200 homes does not represent the most sustainable option when considered against other reasonable alternatives. Given this level of inconsistency, we consider that the current assessment hitherto undertaken will undermine the progress of the Regulation 19 Plan, and its progress to Examination. On this basis we strongly recommend the GNDP undertakes a comprehensive review of the methodology and its conclusions prior to moving any further towards the publication of a Reg 19 Plan.


Suggested Alternative – A Deliverable Spatial Strategy and Planning Positively for Comprehensive Long-Term Growth

A Deliverable Spatial Strategy
In terms of hierarchy considerations, whilst we do not disagree with the stated role of Norwich and it being the main focus for growth, we are concerned that at 69%, the proportion of growth attributed to the urban area places too much reliance on a single growth location within Greater Norwich. This undermines the rationale and purpose of preparing a joint Local Plan. 4.30 It is understood that delivery issues have been experienced in bringing forward development within the growth triangle at north east Norwich. This area has extensive existing growth commitments - the equivalent to a major new settlement in its own right - with a significant amount still to be built out. The focus on Norwich – whilst logical in principle as the tier one settlement - has resulted in additional growth being allocated in north east Norwich in the draft Plan. However, when considering the current delivery position and the opportunities which derive from a joint plan for a wider area, the soundness of an approach which imposes further reliance on this area in terms of future delivery rates, particularly in the context of market saturation, is questioned.

The NPPF paragraph 73 requires that strategic policies should include a trajectory indicating the expected rate of delivery over the plan period. No such trajectory has been included in any of the Reg 18 stages of the plan thus far and on this basis we consider that a spatial strategy and approach to allocations relying on such a significant amount of existing commitments in the absence of this information is unsound. There is no evidence to suggest such numbers are deliverable or achievable within the plan period.

Furthermore, the continued focus of new allocations in the growth triangle does not align with supporting the Tech Corridor as a spatial growth pole. Lying on the far side of Norwich, growth here does not lend itself to reinforcing important connections with Cambridge, nor to supporting more sustainable patterns of movement along the A11/rail corridor. Neither does it align in terms of providing homes to support the economic hubs and jobs growth within the Tech Corridor.

On this basis, we suggest that rather than allocating a further 1,400 new homes to the growth triangle, a more appropriate and robust approach would be to redistribute this growth to align closely with the spatial objectives of the Tech Corridor thereby supporting the economic growth and success of Greater Norwich as well as providing a much-needed re-balancing of the local housing offer and a wider choice of locations within which to deliver new homes. Silfield GV would be an appropriate and deliverable location to accommodate this growth.

Similarly, we would question the GNDP decision to include an allowance for new homes from Carrow Works as part of the approach to housing allocations. Whilst we wholly support the redevelopment of brownfield land and the Councils’ ambition to create a new urban quarter for Norwich – and its consequent allocation as a ‘strategic regeneration area’ – we question the soundness of relying on the provision for 1,200 new homes to be delivered on this site as part of the housing strategy.

Despite the stated uncertainty about its delivery (as expressed on pages 46 and 94), the 1,200- home allocation represents circa 15% of the total housing numbers allocated in the plan. There is no rationale given for including a site for which there is significant uncertainty, nor does this approach accord with the NPPF.

Thus, we suggest that rather than making an explicit allocation for this level of housing, the GNDP treat the contribution to made from this site in the same way as a ‘windfall’ category. This approach would not only accord with the Plan’s overall approach of ‘building in flexibility to support higher than trend economic growth’ (page 45) but would be in line with the NPPF and Government’s objective to significantly boost the supply of housing (NPPF paragraph 59). Should Carrow Works deliver a proportion of its capacity within the plan period, this will serve to further boost the supply in Norwich. This approach would reduce the risk of the Plan failing to deliver its full housing requirement and having to make increased contingency allocations during or soon after the process to adoption. Maintaining the inclusion of the current contribution from Carrow Road as a firm and deliverable allocation undermines the soundness of the Plan looking ahead to Regulation 19 and the Examination, and risks incurring delay and further uncertainty over future growth locations.

In terms of meeting the consequent shortfall of 1,200 homes, we suggest re-distributing this growth from the Norwich Urban Area to the Tech Corridor would go some way to meeting our wide-ranging concerns regarding the mismatch between Plan objectives and spatial growth allocations. Silfield GV would be an appropriate and deliverable location to accommodate this growth.

Planning Positively for Comprehensive Well-Planned Growth

We have set out above our reasoning for the requirement for GNLDP to undertake a re-running of the assessment of alternatives to include new settlement scale growth from the outset. This would allow reconsideration of the overall spatial growth strategy, and importantly, would allow a full and proper assessment of the role that SGV can play as part of this strategy.

We have also set out above why the GNDP needs to plan comprehensively for the long-term growth of Wymondham rather than make small scale allocations in favour of future contingencies and/or village cluster sites.

Attributing the 1,000 contingency sites and the 1,200 units as yet unidentified through Village Cluster at SGV would provide certainty and accord with the Plan-led approach advocated by the NPPF. Whilst SGV has the capacity to deliver up to circa 6,500 new homes – and an allocation for the full extent of the GV should be made in this Plan - the re-allocation of the identified potential shortfall of 2,200 homes to the GV would be deliverable within the Plan period.

Wymondham, by virtue of its location and position in the hierarchy, will continue to be an appropriate focus for growth in perpetuity and across future plans. There is, therefore, a need to plan properly for its growth and ensure a comprehensive approach to its infrastructure requirements and the long-term future of the town. This should be taken forward through identifying the strategic growth potential of Wymondham, irrespective of past development commitments, but this time adopting a holistic view of the town’s future needs in terms of education, employment opportunities and role as an economic destination in the Tech Corridor.

In this context, SGV would be well placed, as a strategic allocation for a garden village, to address these long-term infrastructure considerations. It provides the ability to ‘re-balance’ the growth of the town and establish a more positive relationship with the A11, maximising the accessibility this provides for the town and not perceiving it as a barrier to growth. Reviewing the role of Wymondham and its growth potential in the context of allocating a garden village at Silfield, would align with other initiatives and funding such as the potential Transforming Cities investment and the Tech Corridor whilst removing the uncertainty over the location and impact of future growth – through both speculative or contingency sites – which is so damaging to local communities and runs counter to effective plan making.

We therefore strongly suggest that the GNDP review the current approaches taken towards the growth of Wymondham in favour of making an allocation at SGV to plan positively and with certainty the growth of Wymondham and ensure the town can secure necessary infrastructure provision to safeguard against pressure on services now and into the long-term.

Object

Representation ID: 23076

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

The Greater Norwich area has real potential for growth and compete as a nationally significant economic area. Such growth and success requires a positive and proactive policy basis; growth must be encouraged and not stifled. The GNLP approach to identifying the housing need for the area does not take a proactive approach; moreover, it risks inhibiting the economic and jobs growth that has been agreed as part of the City Deal, and more importantly the recent growth trends that have been evident.

Even more worryingly, there has been a very recent indication that the Greater Norwich housing delivery across Greater Norwich has achieved targets for the first time. This is a positive sign, but the numbers proposed as part of the GNLP would actually result in a reduction of delivery. This is a serious concern at a time when a key Government priority is to significantly boost the supply of housing, and in the context of strong local delivery which would be inhibited by the GNLP numbers.

The GNDP are aiming to meet a need of 2,027 homes per annum, with some further allowances for supply. It appears that GNDP have arrived at such a level of need by simply applying the standard method, introduced for the purposes of establishing a minimum need through recent revisions to the National Planning Policy Framework (NPPF) and related Planning Practice Guidance (PPG).

It is understood that GNDP view the outcome of this formula as an appropriate representation of the full need for housing in Greater Norwich, albeit there is a concerning lack of evidence to substantiate their position in this regard. This lack of consideration conflicts with national policy and guidance, which emphasises that the standard method produces only a minimum starting point and makes clear that there should be an assessment of whether housing need will actually be higher than implied by its formula.

The NPPG requires consideration of a number of factors as part of determining housing need from the starting point of the standard method including any affordability adjustment and taking account of economic circumstances. The GNDP do not appear to make any adjustment from the baseline of the standard method.

In this context we are concerned that the standard method baseline alone would not provide sufficient need as outcome of the method is intrinsically linked to projections that have underestimated population growth to date in Greater Norwich, and particularly failed to anticipate a more pronounced – and increasingly vital – net inflow of people from other parts of the UK. This calls into question whether the method is accurately capturing the housing needed by the population in this area, both now and in the future.

As noted above simply meeting the need implied by the method would also prompt a 16% reduction in the annual rate of housing delivery belatedly achieved over the past three years, when adopted housing targets were met for the first time. Such a reduction is unjustified at a time when the Government remains committed to significantly boosting housing supply and in light of the GNLP objectives to encourage growth and support the Tech Corridor.

Given the economic objectives and wider strategies and commitments to significant jobs growth in Greater Norwich, it is concerning also that with no adjustment for this, simply meeting the need implied by the method would likely grow the labour force and support in the order of 37,000 new jobs. Whilst this supposedly surpasses the target proposed in the Draft Plan (33,000), it falls short of the job growth that can be reasonably expected to result from an ongoing economic growth strategy, this is covered in more detail on the economy below.

The GNDP target is considered inadequate in this regard, given that it is derived from an unjustified and unduly simplistic manipulation of a scenario presented in an evidence base document which is now comparatively dated and pre-dates the revised NPPF. Equally, as a result of the datedness of the informing analysis, it is considered to fail to adequately reflect the strong economic context which Greater Norwich has demonstrated for a sustained period of time or the full impact of planned investment. In this context it is considered that planning for in the order of 40,000 jobs as a minimum over the plan period would be more reflective of the strong potential for truly enhanced growth in Greater Norwich. This clearly would not be supported where housing provision is restricted to the level implied by the standard method, and the associated ageing of the labour force also appears unlikely to support the desired shift towards higher value sectors. Based on the above, we consider that GNDP must update their evidence base prior to the next stage of consultation on the emerging Local Plan, to comply with the NPPF and PPG. This should properly evaluate the level of job growth that is likely in Greater Norwich, taking recent successes – no doubt linked to the City Deal and other initiatives – into account while reconsidering the prospects for long-term growth beyond “business as usual” in key locations and sectors. A related assessment of housing needs should also be produced, to locally test the minimum need implied by any standard method in and ensure that the housing needed to support a growing economy can be planned for.

GNDP also appear to have misconstrued the supply-led buffer proposed as part of its housing requirement, claiming that it provides flexibility to accommodate the consequences of successful investment strategies. The Draft Plan states:
“Our overall approach, including to windfalls and contingency, builds in flexibility to support higher than trend economic growth incorporating the Greater Norwich City Deal” (Paragraph 163 of the GNLP Strategy Document)

The NPPF and PPG are clear that it is a requirement of Local Plans that they are deliverable and sufficiently flexible to adapt to rapid change. The plan’s soundness will be judged against these requirements. The buffer is required to ensure an appropriate allowance for unforeseen circumstances or non-delivery of sites which might otherwise pass the ‘developable’ test. Whilst the Councils have recognised this general point, and the resultant need for an increased level of flexibility, this should not be seen to provide capacity to accommodate need pressures; it is intended to alleviate risks to supply. In this context, the PPG (PPG Reference ID: 2a-010- 20190220) is explicit in recognising that where authorities should consider the appropriateness of a higher housing need figure:
“This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan)”

The Draft Plan later describes another supposed reason as to why the GNDP have not sought to explore the appropriateness of a higher housing need figure, stating with reference to a higher housing figure being considered under a section titled ‘alternative approaches’ that:
“This is not the preferred alternative as evidence of delivery rates over the medium and longer term suggests that higher targets are unlikely to be achievable or deliverable. Setting a higher target that can* be achieved undermines the plan-led system [*it is assumed this should read cannot] (Page 54 of the GNLP Strategy Document)

This is not considered to represent an appropriate or PPG-compliant justification for not attempting to explore the appropriateness of a higher housing need figure. It is of note that the standard methodology recognises the realism of ‘delivery’ with regards to the capping of the adjustment from the baseline to 40%. The PPG specifically acknowledges (Paragraph Reference ID: 2a-007-20190220):
“The standard method may identify a minimum local housing need figure that is significantly higher than the number of homes currently being planned for. The cap is applied to help ensure that the minimum local housing need figure calculated using the standard method is as deliverable as possible”

It is of note that the adjustments for Greater Norwich are notably smaller than 40% and that, as is considered above in our representations [Paragraph 4.50], recent rates of delivery have exceeded the current plan target. As such, there is no justification for suggesting that deliverability concerns represent a valid reason for dismissing the appropriateness of a higher figure.

As previously mentioned in the context of delivery concerns with some of the allocated sites, the absence of a trajectory of this stage at the process to evidence how the sites will contribute to the housing need over the plan period, is a serious issue. This trajectory is required by the NPPF and by not having it available for representors to review and assess alongside the allocations, there is no certainty as to whether the housing needs will actually be met through the identified spatial strategy.

Based on the above, it is considered that the Councils must update their evidence base prior to the next stage of consultation on the emerging Local Plan to comply with the NPPF and PPG. Our objection to the housing needs to be met through the GNLP is set out in greater detail in the ‘Technical Review of Housing Needs in Greater Norwich’ Report by Turley, February 2020, included at Appendix 3.

Support

Representation ID: 23077

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the general approach to the growth of the economy and welcome the recognition of the Tech Corridor and its relationship to the globally significant axis between Cambridge and Oxford. We are however concerned that the Plan is not optimistic enough in making provision for economic growth, both in planning for sufficient jobs and planning for sufficient housing to support these jobs.

The Draft Plan targets the creation of at least 33,000 jobs over the plan period (2018-38) and confirms that this ‘has been established through local trend-based evidence’ (Paragraph 149 of the GNLP Strategy Document) . Whilst the Draft Plan attributes this to the East of England Forecast Model (EEFM) it also confirms its origination from evidence included in the Employment, Town Centre and Retail Study produced by consultancy GVA in 2017. This study used the then-latest published iteration of the EEFM to explore scenarios of job growth based on ‘business as usual’ and the potential for ‘enhanced economic growth’.

The latter scenario, which the Draft Plan confirms underpins its job target, identified that between 2014 and 2036 around 44,000 jobs could be created, an average of 2,000 jobs per annum. It built from the EEFM but applied positive adjustments to a number of sectors which were considered to better reflect local and national growth potential.

The 33,000-job target in the Draft Plan is explained as being based on:
• A netting off of the 15,000 jobs created to 2018 from the 45,000 jobs forecast in the Employment, Town Centre and Retail Study; and
• An extension of the forecast by a further two years to 2038, the extension implied to be based on the latest EEFM outputs.

Such an approach is considered to have a number of significant limitations:
• The Employment, Town Centre and Retail Study is now comparatively dated and should be revisited to ensure it is based on up-to-date economic datasets;
• The GNDP approach to manipulate the previously evidenced job forecast fundamentally fails to take into account the approach taken to generate the enhanced growth scenario or its forecast of job growth over the long-term; and
• At a wider level there have been more marked local and national changes to the economy which have a bearing on the forecasting of future job growth and should be taken into account through an updated evidence base. This will ultimately ensure that the Local Plan takes full account of the current ambitions of the GNDP and the Local Enterprise Partnership, as well as national Government.

It is noted that in seeking to justify the 33,000-job growth target the GNDP, through the Draft Plan, advance an argument of dismissing the potential for higher growth targets, as have evidently been set previously. This justification is predicated on questions as to whether ‘significantly higher targets’ are ‘achievable’ given ‘current economic uncertainties’ and the ‘enhanced growth’ that is ostensibly already provided for.

The suggestion that higher levels of growth would not be ‘achievable’ does not stand up to scrutiny when recognised that the target of 33,000 jobs represents a markedly lower rate of growth than that which has been seen in recent years, as used in the GNDP derivation of its target. The last three years alone have cumulatively seen nearly half as many jobs created than are assumed to be created over the much longer twenty-year period covered by the target.

The NPPF confirms that ”planning policies should…set out a clear economic vision and strategy which positively and proactively encourages sustainable growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration” (NPPF Paragraph 81a). In the context of economic growth priorities provided by the Cambridge-Norwich Tech Corridor and the importance of the New Anglia Local Enterprise Partnership’s existing Norfolk and Suffolk Economic Strategy (NSES) and the emerging Norfolk and Suffolk Local Industrial Strategy (LIS), it is undoubtedly appropriate for the Draft Plan to target an enhanced level of employment growth than implied by trend-based or ‘off-the-shelf’ forecasts. Given an evolving economic strategy context, the reliance on forecasts presented within a study produced in 2017 creates a concerning risk that the latest understanding of this growth potential is not fully captured. The strength of the local economy in creating new jobs would imply that whilst it represents an ‘enhanced’ outlook of growth it appears unduly modest when compared to this historic success.

We therefore, consider that to support the enhanced levels of economic growth that are evidently capable of being achieved and should be encouraged, the Plan should seek to make further provision for employment opportunities and these should be well located to the economic priority area – most significant the Tech Corridor. Supporting the continued success of Norwich Research Park should also be a key objective and should be promoted through ensuring new homes as well as complementary employment opportunities are made available at SGV.

The SGV proposition includes a ‘Tech Hub’ which has the potential to offer a range of flexible employment land opportunities associated with the key sectors of agri-tech and energy. As such an allocation at SGV would provide a necessary increase in the jobs target for the Plan and this would be supported by an interrelated increase in the number of homes to support these jobs. This is further explained in the ‘Technical Review of Housing Needs in Greater Norwich’ Report by Turley, February 2020, included at Appendix 3 which indicates a minimum of 40,000 jobs should be planned for in the GNLP.

We also note and support the importance of Hethel as a key economic destination in the Tech Corridor. We therefore consider it critical that the current employment uses at Hethel are not compromised through incompatible development and its potential to expand as an employment hub should be safeguarded. This would align well with a strategic Garden Village allocation at SGV.