Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22335

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22336

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22337

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22338

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22339

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

6. POLICY 6 – ECONOMY
6.1 Policy 6 proposes a number of employment allocations. However, these allocations do not necessarily reflect the balance of the workforce with the existing jobs, and therefore rely upon an increase in commuting flows between settlements.
6.2 By way of example, according to the 2011 Census, 2,268 residents of Hethersett were in work, but there were only 1,127 jobs in the settlement such that the remaining 1,141 or roughly half of residents were required to commute elsewhere for their work. The Joint Core Strategy then allocated an additional 1,000 homes at Hethersett and this is now proposed to increase to 1,369 homes in Policy HET1. The consequence of this is that the imbalance between the workforce and jobs within the settlement is likely to increase significantly which will mean that an even greater number of residents are required to commute to other settlements. This would appear to be directly contrary to paragraph 103 of the NPPF as it will increase the need to travel from Hethersett on a daily basis.
6.3 It is therefore considered that in settlements which experience such imbalances, appropriately sized employment allocations should be identified to accord with the NPPF and limit the need to travel. The Land off Melton Road, Hethersett provides an appropriate site to deliver additional jobs to address this imbalance and reduce the need to travel to work.

Comment

Representation ID: 22343

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail; main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 We reserve the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.

Comment

Representation ID: 22344

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail; main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 We reserve the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.

Comment

Representation ID: 22345

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail; main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 We reserve the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.

Comment

Representation ID: 22346

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.3 Key Service Centres
7.17 According to the GNLP, the Key Service Centres have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving the rural areas. It also identifies that these roles are intended to continue to be supported by appropriate levels of development.
7.18 Policy 7.3 identifies the growth to come forward at Key Service Centres in the plan period up to 2038. The Reg 18 GNLP identifies 3,253 homes and 11.79 hectares of employment land to come forward in the plan period across the Nine Key Service Centres.
7.19 Of the 3,253 homes to be allocated only 515 are new allocations with all other homes being derived from existing allocations or commitments.
7.20 Of particular concern is the fact that Hethersett is not identified for any additional allocations in the GNLP, other than an uplift at HET1 (which will not increase the rate of delivery but will simply elongate the development phase owing to be controlled by two housebuilders), despite being a Key Service Centre that provides a sustainable location where growth has previously been considered to be appropriate.
7.21 In failing to consider additional growth at such locations the Councils are missing opportunities provided by the Land at Hethersett to provide the required additional community facilities and a better range of uses at the Key Service Centres.
7.22 Land is proposed for a new educational campus at Land off Burnthouse Lane, Hethersett to provide a new primary school, thereby future proofing primary education in the village, and accommodation for Key Stage 3 students of Hethersett Academy, alleviating pressure on the existing school campus. This new campus will include a range of new recreation and sports facilities as well as providing the opportunity for new green infrastructure linkages for the benefit of existing and new residents alike. It is also proposed that a care home/care village will be provided to respond to the significant need for such accommodation across the GNLP area at Land off Station Road in close proximity to local services and with regular bus services to Norwich. The proposed provision of employment land will also be of significant benefit to the residents of Hethersett as it will enhance the opportunity for residents to be employed within the settlement and thereby reduce the need to travel.
7.23 In not providing an appropriate mix of uses through allocations at these locations the GNLP fails to provide flexibility and choice in the GNLP and risks the sustainability of the Key Service Centres as well as the timely delivery of market and affordable homes if allocated sites stall. Land at Hethersett is available and deliverable and provides not only for market and affordable homes but also for specialist accommodation to meet identified requirements.
7.24 The GNLP states that Hethersett is close to Norwich and within the Cambridge Norwich Tech Corridor. Paragraph 337 of the GNLP states the services and facilities that the settlement provides and the fact that it has good access to employment opportunities at a range of strategic and more local sites.
7.25 Land at Hethersett can provide for new market and affordable homes, new employment land, a new educational and sports campus and a new care home/care village. The attached Delivery Statement is based on technical evidence and clearly illustrates the sites and uses now promoted. We would welcome the opportunity to come and discuss these matters further with the Councils.
7.26 Whilst there is an existing allocation for the provision of 40 extra care units in Hethersett, this is insufficient given the identified need for 3,257 such homes across South Norfolk alone. Furthermore, following the allocation of this site in 2015, no planning application has been submitted in the subsequent 4 years which provides an indication that this site may not be attractive to the market or that there is a site-specific constraint which is acting as a barrier to development given the significant need for such accommodation.
7.27 The GNLP has not taken the opportunity that plan making provides to balance the delivery of new homes across the Key Service Centres and to consider how the delivery of new homes can also release land to provide new social and community infrastructure that the evidence base states is required at each settlement.

Comment

Representation ID: 22347

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.3 Key Service Centres
7.17 According to the GNLP, the Key Service Centres have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving the rural areas. It also identifies that these roles are intended to continue to be supported by appropriate levels of development.
7.18 Policy 7.3 identifies the growth to come forward at Key Service Centres in the plan period up to 2038. The Reg 18 GNLP identifies 3,253 homes and 11.79 hectares of employment land to come forward in the plan period across the Nine Key Service Centres.
7.19 Of the 3,253 homes to be allocated only 515 are new allocations with all other homes being derived from existing allocations or commitments.
7.20 Of particular concern is the fact that Hethersett is not identified for any additional allocations in the GNLP, other than an uplift at HET1 (which will not increase the rate of delivery but will simply elongate the development phase owing to be controlled by two housebuilders), despite being a Key Service Centre that provides a sustainable location where growth has previously been considered to be appropriate.
7.21 In failing to consider additional growth at such locations the Councils are missing opportunities provided by the Land at Hethersett to provide the required additional community facilities and a better range of uses at the Key Service Centres.
7.22 Land is proposed for a new educational campus at Land off Burnthouse Lane, Hethersett to provide a new primary school, thereby future proofing primary education in the village, and accommodation for Key Stage 3 students of Hethersett Academy, alleviating pressure on the existing school campus. This new campus will include a range of new recreation and sports facilities as well as providing the opportunity for new green infrastructure linkages for the benefit of existing and new residents alike. It is also proposed that a care home/care village will be provided to respond to the significant need for such accommodation across the GNLP area at Land off Station Road in close proximity to local services and with regular bus services to Norwich. The proposed provision of employment land will also be of significant benefit to the residents of Hethersett as it will enhance the opportunity for residents to be employed within the settlement and thereby reduce the need to travel.
7.23 In not providing an appropriate mix of uses through allocations at these locations the GNLP fails to provide flexibility and choice in the GNLP and risks the sustainability of the Key Service Centres as well as the timely delivery of market and affordable homes if allocated sites stall. Land at Hethersett is available and deliverable and provides not only for market and affordable homes but also for specialist accommodation to meet identified requirements.
7.24 The GNLP states that Hethersett is close to Norwich and within the Cambridge Norwich Tech Corridor. Paragraph 337 of the GNLP states the services and facilities that the settlement provides and the fact that it has good access to employment opportunities at a range of strategic and more local sites.
7.25 Land at Hethersett can provide for new market and affordable homes, new employment land, a new educational and sports campus and a new care home/care village. The attached Delivery Statement is based on technical evidence and clearly illustrates the sites and uses now promoted. We would welcome the opportunity to come and discuss these matters further with the Councils.
7.26 Whilst there is an existing allocation for the provision of 40 extra care units in Hethersett, this is insufficient given the identified need for 3,257 such homes across South Norfolk alone. Furthermore, following the allocation of this site in 2015, no planning application has been submitted in the subsequent 4 years which provides an indication that this site may not be attractive to the market or that there is a site-specific constraint which is acting as a barrier to development given the significant need for such accommodation.
7.27 The GNLP has not taken the opportunity that plan making provides to balance the delivery of new homes across the Key Service Centres and to consider how the delivery of new homes can also release land to provide new social and community infrastructure that the evidence base states is required at each settlement.