Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 23078

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

The GNLP suggests that a review will be undertaken in five years in accordance with the NPPF. We consider that unless the GNDP undertake a significant review of the spatial growth strategy and increase housing and job targets to ensure the plan is optimistic; boosts the supply of housing; and will deliver the levels of economic growth required, then a much sooner review should be undertaken.

The Plan makes reference to the potential for a new settlement in a future review of the Plan and given the inclusion of contingencies, there is a suggestion that there are weaknesses in the current plan that need to be addressed ‘next time around’. If these weaknesses are not to be addressed in the Reg 19 plan, then in this context, an early review of the Plan would be essential.

Object

Representation ID: 23079

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

It is very clear that the A11 offers benefits in terms of supporting new growth as a result of its recent improvement. This sets it apart from other elements of the strategic network that still require investment. In drawing up a spatial growth strategy it is important that the use of existing infrastructure is prioritised above areas where substantial investment is required. The potential of the A11 being readily able to accommodate growth should be maximised in this context.

We are also concerned about the lack of alignment between other transport strategies and initiatives and the GNLP. Most acutely, the apparent lack of regard for rail and encouraging a significant modal shift away from the private car.

Wymondham has the potential to function as a public transport hub and this should reinforce it as an excellent location for strategic growth, particularly at a time when there is a global imperative to address the climate change challenge. GNLP should look to Wymondham as an absolute priority area to focus growth around public transport accessibility.

Furthermore, in the context of wider community infrastructure and ensuring that growth does not put further pressure on existing amenities, it is important to note that new settlements as a growth typology are the most sustainable as they have the critical mass to support and deliver the provision of new services and facilities that simply cannot be achieved through smaller developments, even up to 1,500 units.

Object

Representation ID: 23080

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We wholly support the sustainable communities policy. This should underpin the spatial growth strategy and sites that are best able to perform against these sustainability requirements should be the ones selected for allocation.

However, we consider that the Plan does not effectively translate its aims and objectives in relation to delivering sustainable communities into its spatial strategy. It fails to acknowledge the ability of larger strategic scale developments to achieve these policy requirements, many of which are inherent in the design of new settlement scale developments.

The opportunity at SGV truly stands apart from other strategic growth opportunities in its sustainability and energy offer. One of the central features of SGV, as demonstrated in the Prospectus, is its ability to be aligned with the delivery of a solar farm on adjacent land under the control of the same landowner.

In this context, Orbit have explored the measures necessary to achieve a NetZero development from the outset and put forward SGV on this basis. The detail of how the scheme could achieve NetZero is set out in Sustainability, Energy and Climate Change Strategy as part of the technical assessment in Appendix 4. To inform this Strategy estimates of possible construction and operational stage carbon emissions and costs estimates to address these emissions to net zero through on-site renewable energy, tree planting and carbon offsetting have been undertaken.

SGV as a prospective allocation would establish an important precedent for the GNLP area in demonstrating how requirements of Policy 2 can be met. It is vital that in preparing Local Plans, policy-makers are proactive in establishing policies to tackle climate change.

It is imperative that GDNP realise their ambitions as set out in Policy 2 in light of the growing global climate change challenge. Without such commitments the GDNP will fall short of making a meaningful contribution in the fight against global climate change.

The use of zero-carbon and energy-positive technology is one of the integral Town and Country Planning Association Garden Village principles which have been used to shape the SGV proposal since its inception. We contend that the use of the Town and Country Planning Association Garden Village principle framework ensures that GV proposals, in particular SGV, are better placed to respond to climate change issues than small – medium scale development as sustainability principles are embedded within the design of such schemes.

Comment

Representation ID: 23081

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

Our comments on transport reiterate our earlier concerns regarding the alignment of the growth strategy with transport priorities and investment, summarised as:
i. The A11 is the spine of the Tech Corridor and has been subject to substantial investment but within the GNLP is not being utilised or maximised to deliver growth;
ii. Given the future context of East West Rail and improvements on the Norwich to Cambridge line, as set out in the Rail Prospectus consultation (2020), the rail network, including the proposed mobility hub at Wymondham, should be given much more focus as an opportunity to support strategic growth in this location;
iii. If a modal shift is to genuinely be achieved, then new development allocations should be at locations close to, and their transport case absolutely integrated with, railway stations. This is not the case for a considerable number of the currently proposed allocations;
iv. Appendix 1 of the GNLP sets out infrastructure requirements required to unlock new growth and in the context of the above it appears that a number of strategic allocations are predicated on third party infrastructure investment which is by no means certain (for example, attributing further growth in close proximity to the A47 Longwater Interchange). We consider that this risks undermining the delivery of the GNLP.

Support

Representation ID: 23082

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the requirement to provide various different types of housing and highlight the ability of SGV, by virtue of its development partners (Orbit and Bowbridge), to commit to the delivery of a variety of housing types and tenures. The construction of a significant proportion of homes by Orbit – already a key RP in the area - would provide certainty not only over the housing delivery but also the range of tenures that would be provided to ensure local housing needs are effectively met in a timely manner.

Object

Representation ID: 23083

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

In responding to Policy 7.1 we refer back to our comments in respect of Policy 1. In summary we consider there to be serious flaws arising from:
i. the continued overreliance on East Norwich given past under-delivery;
ii. the failure to distribute new growth within other parts of the GNLP area to more closely align with local housing needs where they arise and thus avoid market saturation in areas of more marginal viability;
iii. misalignment between the spatial strategy and the economic priorities of the Plan related to the Tech Corridor; and
iv. the assumptions over the scale of housing delivery arising from a key regeneration site in the centre of Norwich (Carrow Road) which is subject to considerable and acknowledged uncertainty above).

Object

Representation ID: 23084

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

In responding to Policy 7.1 we refer back to our comments in respect of Policy 1. In summary we consider there to be serious flaws arising from:
i. the continued overreliance on East Norwich given past under-delivery;
ii. the failure to distribute new growth within other parts of the GNLP area to more closely align with local housing needs where they arise and thus avoid market saturation in areas of more marginal viability;
iii. misalignment between the spatial strategy and the economic priorities of the Plan related to the Tech Corridor; and
iv. the assumptions over the scale of housing delivery arising from a key regeneration site in the centre of Norwich (Carrow Road) which is subject to considerable and acknowledged uncertainty above).

Object

Representation ID: 23085

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

In responding to Policy 7.1 we refer back to our comments in respect of Policy 1. In summary we consider there to be serious flaws arising from:
i. the continued overreliance on East Norwich given past under-delivery;
ii. the failure to distribute new growth within other parts of the GNLP area to more closely align with local housing needs where they arise and thus avoid market saturation in areas of more marginal viability;
iii. misalignment between the spatial strategy and the economic priorities of the Plan related to the Tech Corridor; and
iv. the assumptions over the scale of housing delivery arising from a key regeneration site in the centre of Norwich (Carrow Road) which is subject to considerable and acknowledged uncertainty above).

Object

Representation ID: 23086

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We object to the lack of consideration of Wymondham as a strategic growth location. As has been extensively covered elsewhere in these representations, for a variety of reasons Wymondham is an excellent location for accommodating strategic scale growth. In summary:
• It is the largest settlement in the GNLP area outside the Norwich Urban Area;
• It has a prominent location at the heart of the Tech Corridor;
• It benefits from immediate access to the recently improved A11; and
• It is positioned on the Norwich Cambridge Railway line and has a key stopping station subject
to programmed station improvements and programmed (faster and more frequent) service improvements.

These factors suggest that Wymondham is a suitable location for new growth, yet it is subject to only two 50-unit allocations in the GNLP. Whilst Wymondham has some existing commitments this has no bearing as to whether it should continue to be identified as a key location for growth. The existing level of growth within Wymondham is not of such significant scale to suggest further development would inhibit delivery.

As is explained in the SGV Prospectus and in paras 4.16 to 4.21 above, Wymondham has been subject to sustained piecemeal delivery though planned and speculative development to the detriment of delivering necessary town-wide services and amenities.

Given its locational advantages and its position in the settlement hierarchy, the case for continued growth at Wymondham is incontestable. It is therefore imperative that the long-term future of the town is planned for comprehensively and safeguarded from further piecemeal growth which delivers no tangible infrastructure or service benefits for the town.

Furthermore, adopting a whole-town growth strategy for Wymondham – which includes strategic growth at SGV – would allow a more robust policy position to be adopted in respect of other key infrastructure objectives. For example, a whole-town strategy could introduce spatial policies to build on Plan objectives of enhancing existing strategic green infrastructure within/around the town and protecting it from inappropriate development, and/or strengthen policies to define and protect settlement/strategic gaps including between Wymondham and Hethersett.

We would welcome the opportunity to engage with the GNDP and local stakeholders to explore this policy position further as part of plan-making activity between now and the Reg 19 stage LP. In order to inform these discussions, set out below is suggested alternative policy framework which could support strategic-scale growth at SGV.

Alternative Policy – ‘Silfield Garden Village’
Silfield is one of three potential new settlement sites identified in the draft Plan for future consideration. No criteria-based assessment framework is suggested for this consideration, nor any policy protection given to these locations as having any preferred policy status (for example, through an ‘Area of Search’ policy or similar), and considerable uncertainty arises from the naming of growth future growth locations in such isolation.

At the same time, site allocations have been made in the GNLP – or proposed in subsequent documents – in unsustainable and undeliverable locations

We consider that rather than being considered in the next review of the plan, for the reasons set out above the GNLP should pursue a spatial strategy which allocates – and specifically identifies land for – a new settlement at Silfield within the current plan to 2038.

We contend that a policy for an allocation of a new settlement at Silfield Garden Village would comprise:
(a) Identification of the preferred location for a New Settlement south of Wymondham on the Key Diagram;
(b) Allocation of the Silfield Garden Village site (red line) for up to 6,500 homes [plus associated uses] in the Site Allocations document;
(c) Inclusion of a criteria-based New Settlement policy for Silfield GV identifying the key features and policy requirements of the new settlement – this could include the associated provision of a solar Farm and strategic green infrastructure as indicated by the green boundary on the site plan in appendix 2;
(d) Identification of the capacity of the new settlement within Policy 1 and Policy 7.1, reflecting its full capacity of 6,500 new homes plus associated uses, and also identifying the contribution that this allocation will make during the plan period to 2038 (circa 3,700 homes)

Aligned with a new settlement policy would be a redistribution of housing numbers to achieve a more sustainable and deliverable spatial strategy which more closely reflects the wider economic and growth objectives of the Plan. On this basis, we suggest that Policy 1 would be amended to reflect a redistribution of current draft allocations

Object

Representation ID: 23087

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We wish to express concerns generally regarding the approach to the allocation of sites for development across numerous Development Plan Documents (DPD). Our comments set out in the covering letter (under the heading Procedural Concerns) provide further details.
Specifically, we object to the approach taken within the draft GNLP Sites document in respect of South Norfolk Council’s intention to unilaterally prepare a separate Village Clusters Plan covering new and carried forward sites for housing in their village clusters, whilst the sites to be allocated for housing in the village clusters in Broadland District are included within the draft GNLP Sites document. We make three points of objection in principle:

i. Firstly, the GNLP is a joint plan. Decisions on site allocations should be made in the context of meeting whole plan objectives, evidence and SA relating to the plan area as a whole. Unlike the Broadland site allocations for village clusters, the decision-making process regarding the South Norfolk Village Cluster site allocations - which presumably is to be undertaken unilaterally by South Norfolk Council separately from joint planmaking - is neither logical nor transparent. This approach undermines and acts counter to the GNLP whole plan objectives and SA conclusions, which in turn risks the soundness of the Village Clusters document and the GNLP Plan as a whole. This is clearly not a desired outcome for any of the three authorities;
ii. Secondly, the Village Clusters document proposes to allocate sites for c.1,200 dwellings in total. The scale of housing land required to meet this requirement – and the options for how this requirement might best be met in a way which meets wider plan objectives - is such that if tests of soundness are to be met, can only be considered as an inherent part of the GNLP;
iii. Thirdly, the timing of a separate South Norfolk Village Clusters document has led to a blanket approach of postponing the assessment of sites within/around village clusters that have been promoted through the GNLP call for sites process until the preparation of this document takes place. Again, this risks undermining the overall soundness of the evidence base, SA and content of both plans as the assessment of cumulative impact or reasonable alternatives cannot be done in a holistic or robust manner;

Furthermore, some of the sites promoted through the call for sites process within/around village clusters are strategic in nature and scale. For example, site GNLP2101 (promoted for a residential-led mixed use development) at Spooner Row includes a site area of 77.26ha. Whilst this site has been assessed as part of the Housing and Economic Land Availability Assessment (HELAA) Addendum October 2018, it has not been subject to the same detailed site assessment process as sites considered for allocation within the draft GNLP Sites document. Rather, it is proposed that such sites will be subject to future consultation by South Norfolk Council, with no indicative timescales provided for when, how or against what objectives this further consultation will take place or how it will link with the progression and examination of the GNLP. However, a number of sites including GNLP21011 are considered strategic in scale, and as such go well beyond what should be reasonably considered as part of a separate or ‘lower order’ site allocation document.

None of the sites listed in the footnote below have been considered for allocation within the draft GNLP Sites document. As such, none of the sites have been subject to the same detailed site assessment as the sites considered for allocation within the GNLP despite being of a similar scale and nature. Rather, these sites will be subject to further, separate, consultation by South Norfolk Council.

In addition to the procedural disparity this creates – and one which will add to the complexity around site assessment and a confusion amongst public or wider stakeholders wishing to engage with the plan making process – the failure to consider such strategic scale sites compromises the growth strategy in a number of ways:

• it cannot fully consider all of the proposed strategic infrastructure that may be required for the Plan period within the GNLP;
• it assumes that the village clusters will remain at the same position within the GNLP settlement hierarchy; and
• it prevents the GNLP growth strategy being tested against all available reasonable alternatives.

On the basis set out above, we object to the approach proposed within the draft GNLP Sites document to allocate 1,200 dwellings within a separate DPD document on the grounds that it has led to a flawed site assessment process which compromises the proposed growth strategy and the soundness of the GNLP as a whole.

We suggest that to remedy the situation and to ensure that the GNLP can move effectively through Regulation 19 and Examination, those sites to be allocated for development at the village clusters in South Norfolk should be considered and allocated as part of the GNLP Sites document. There is an opportunity to undertake the necessary assessment (in tandem with the additional SA work we suggested is also needed to test reasonable spatial strategy alternatives to Policy 12) in the period between the end of consultation (Regulation 18c) and the next round of consultation (Regulation 19) scheduled for January/February 2021.


If GNDP continue to pursue a separate South Norfolk Village Clusters document as a separately-assessed and unilaterally-determined DPD, then we have serious reservations over the soundness of the Plan as a whole and its likely success at Examination.