Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 23167

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Spatial Strategy
3.39 The Table at Policy 1 details the distribution of housing supply across the settlement hierarchy, including proposed new allocations as follows;
- Norwich urban area - 30,560 dwellings – approximately 70% of supply
- Main towns – 6,342 dwellings – approximately 14% of supply
- Key Service Centres – 3,417 dwellings – approximately 8% of supply
- Village clusters – 4,024 dwellings – approximately 9% of supply
3.40 Policies 7.1 to 7.5 provide further detail on the distribution of sites and the composition of existing and proposed allocations with regard to their size and brown or green field status.
3.41 Our clients raise concern over the proposed spatial strategy of the emerging GNLP owing to its over reliance on housing delivery in the Norwich urban area and the proposed discrepancy in terms of settlement hierarchy between the quantum of housing allocated to Main Towns, Key Service Centres and Village Clusters.
3.42 While the Norwich urban area is a sustainable location for growth, reliance on this area for the delivery of approximately 70% of the housing growth of the GNLP up to 2038 places a requirement on existing infrastructure to accommodate an additional 30,560 dwellings in the plan period, it also requires an annual delivery rate within the area of 1,698 dwellings per annum over each of the next 18 years. This requires that the level of development in Norwich urban area alone is broadly consistent with that which has been achieved across the entire GNLP plan area since 2008. This does not appear to be realistic. If the necessary boost to housing supply is to be achieved this will require a greater range and choice of sites across all of the sustainable settlements within the plan area.
3.43 Moreover, reference to Policy 7.1 demonstrates that delivery within the Norwich Urban Area is predicated on two substantial brownfield regeneration areas, the Northern City Regeneration Area and the East Norwich Strategic Regeneration Area and several urban extensions of over 1,000 dwellings each.
3.44 Brownfield regeneration is costly and time consuming and often involves the bringing together of multiple delivery partners to achieve. The likelihood of the totality of development proposed through regeneration delivering in the plan period is therefore slim.
3.45 New strategic urban extensions can also be timely to deliver with the need for new strategic infrastructure in terms of highways and drainage to be delivered in advance of new homes.
3.46 The Councils have not produced evidence to substantiate the delivery trajectory of the brownfield regeneration sites or the urban extensions in the Norwich Urban Area. We reserve the right to comment further on this matter at the Regulation 19 consultation stage. Delay in delivery at either source of supply could prejudice the delivery of the housing requirement of the GNLP and therefore go to the soundness of the plan.
3.47 Additional certainty over the delivery of the housing requirement could be achieved by changing the emphasis of the spatial strategy by allocating more housing to the Main Towns and the Key Service Centres, including Reepham, with an associated reduction in the percentage to be delivered in Norwich urban area and the Village Clusters.
3.48 Additionally, we have concerns over the fact that more dwellings are proposed in the spatial strategy across Village Clusters than are allocated at Key Service Centres, including a minimum of 1,200 dwellings through a South Norfolk Village Clusters Housing Site Allocations Development Plan Document.
3.49 Without certainty over the supply of land to deliver such a quantum of development in South Norfolk Village Clusters the soundness of the spatial strategy is questionable. As a percentage of the overall new housing allocations in the Reg 18 GNLP the current spatial strategy delegates approximately 15% to a document outside of its control (1200/7,840). This is not considered to be a reasonable approach and prejudices the delivery of the emerging GNLP by 2038.
3.50 A Settlement Hierarchy approach to the distribution of development would look to allocate a higher percentage of housing to more sustainable locations with smaller amounts being allocated to lower order settlements in recognition that small developments at villages can help maintain service provision, provide vitality and help address local market and affordable housing needs.
3.51 The Reg 18 GNLP allocates more development to Village clusters than to Key Service Centres which is a counter intuitive approach to achieving sustainable development. We consider this matter should be addressed by allocating additional sites at Reepham, with Pigeon being able to provide land for the development of new community facilities including healthcare, over and above sites for new housing development.
3.52 In failing to provide an increased number of dwellings at Main Towns and Key Service Centres the Councils are also missing the opportunities presented by Pigeon to provide new community facilities that can support existing and proposed new development in sustainable locations for the plan period and beyond.
3.53 The preceding representations on the Spatial Strategy are all set in the context that the identified housing need does not even accord with the minimum set by national policy and does not take account of the needs of specific groups. It is therefore evident that the quantitative elements of the Spatial Strategy will need
to be revised to ensure that housing needs can be met across the GNLP area. This should be achieved through directing more growth to the Main Towns and Key Service Centres to counterbalance the disproportionate levels of growth proposed within the Norwich urban area and Village Clusters.

Comment

Representation ID: 23168

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

POLICY 2 – SUSTAINABLE COMMUNITIES
4.1 While we broadly support the overall aims and objectives of the GNLP to facilitate the growth and delivery of sustainable communities the following representations are made in response to Policy 2 and its associated reasoned justification.
Criteria 3
4.2 This Criteria requires new development to;
“Contribute to multi-functional green infrastructure links, including through landscaping, to make best use of site characteristics and integrate into the surroundings;”
4.3 This is supported as it provides for the environmental objective of sustainable development. Pigeon’s site proposals at Reepham includes new green infrastructure linkages thereby supporting the environmental objectives of Criteria 3. These linkages will provide for biodiversity enhancement and new wildlife corridors as well as providing new footpath connectivity integrating with the existing public right of way network for the benefit of both existing and new residents.
Criteria 4
4.4 This Criteria requires new development to;
“Make efficient use of land with densities dependent on site characteristics, with higher densities and car free housing in the most sustainably accessible locations in Norwich. Indicative minimum densities are 25 dwellings per hectare across the plan area and 40 in Norwich.”
4.5 The density of residential development at any site is dependent on other community infrastructure or site-specific requirements that may arise as a result of emerging GNLP planning policy. It may transpire that a site promoted to the plan can provide educational or health facilities in association with residential development. The need for highway infrastructure and sustainable drainage features to be provided at a site also should be taken into consideration. To that end the policy should be amended to state that;
“...the indicative minimum net density of the residential element of a site allocation should be 25 dwellings per hectare.”
4.6 The Policy identifies that these minimum density standards are indicative. This is supported as it allows for flexibility to ensure that each parcel of land is used effectively, taking account of the type of development proposed, the site context and appropriate design characteristics.
Criteria 10
4.7 This Criteria contains the following bullet point;
“All new development will provide a 20% reduction against Part L of the 2013 Building Regulations (amended 2016);”
4.8 The Planning Practice Guidance states that;
“The National Planning Policy Framework expects local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy and adopt nationally described standards. Local requirements should form part of a Local Plan following engagement with appropriate partners, and will need to be based on robust and credible evidence and pay careful attention to viability.” PPG Climate Change – Paragraph: 009 Reference ID: 6-009-20150327 Last revised 27th March 2015
4.9 PPG Paragraph: 012 Reference ID: 6-012-20190315, last revised 15th March 2019, states that Local Plans can set energy efficiency standards that exceed the energy efficiency requirements of the Building Regs, it also states that such policies should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the code for Sustainable Homes – which is identified as approximately 20% above current Building Regs across the build mix. The PPG also requires such policy requirements to be viable.
4.10 The Code for Sustainable Homes was withdrawn in 2015 and replaced by technical housing standards. The GNLP Reg 18 has chosen to continue to pursue the ‘20% above Building Regs’ approach at criteria 10 of Policy 2.
4.11 The Alternative approaches section states that this target is a ‘challenging but achievable requirement’ and that to go beyond 20% would be unviable.
4.12 What is not clear however is the Councils’ evidence to require energy savings of ‘at least 20%’ above Building Regs when the PPG states ‘approximately 20% across the build mix’.
4.13 It is not clear either whether this policy requirement has been appraised across a range of site typologies in the viability appraisal and whether it has been tested in conjunction with the other policy requirements of the plan, including those of emerging Policy H5 which seeks:
i. 33% affordable housing, (except in Norwich City Centre);
ii. all new housing development to meet the Governments Nationally Described Space Standards; and
iii. 20% of major housing developments to provide ‘at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor’.
4.14 Whilst the objectives behind these are supported, taken together these emerging policy requirements of the plan could prejudice the delivery of some sites within the emerging plan.
Master planning
4.15 Community engagement prior to submitting an application is supported. However, Policy 2 identifies master planning using a recognised community engagement process for schemes of more than 200 dwellings will be encouraged. It is not clear what is meant by such a master planning process and clarity would be welcomed.
4.16 It is considered likely that such a master planning process would exceed the requirements of each of the joint authorities existing adopted Statements of Community Involvement and also goes beyond the requirements of paragraphs 39 to 41 of the NPPF and the PPG (20-010).
4.17 Furthermore, there is no guarantee that the masterplan outcomes of such a community engagement process will be considered appropriate or acceptable by the local authority as there is no mechanism for validating the outcomes of the process pre-submission. This could result in difficulties for all parties at the
application stage should masterplan amendments be required as a result of statutory and internal local authority consultations post submission.

Comment

Representation ID: 23169

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

POLICY 4 – STRATEGIC INFRASTRUCTURE
5.1 Policy 4 facilitates the Vision and Objectives of the GNLP by supporting the delivery of strategic infrastructure to meet the needs of the area. This ambition is to be welcomed. However, the GNLP is largely silent upon how this strategic infrastructure will be delivered and, in some cases, the GNLP does not make provision for this required infrastructure as described below.
5.2 Policy 4 also identifies that the authorities will lobby for the delivery of infrastructure including in the health care sector. Whilst any lobbying is to be welcomed, this does not provide for an effective policy to guide development. The wording should be revised to indicate that proposals that assist the delivery of infrastructure improvements will be supported.
5.3 The Infrastructure Needs Report demonstrates the particular importance of the delivery of healthcare infrastructure in a number of areas, including at Reepham and Aylsham where the medical practice is of an insufficient size to accommodate the number of registered patients.
5.4 The medical practice at Reepham can be readily expanded through the allocation of the site at Land at Dereham Road, Reepham with provision of land for the extension of the existing facility as detailed in the Delivery Statement and Concept Plan that accompany these representations.

Comment

Representation ID: 23170

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Space Standards
6.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
6.3 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’.
6.4 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.
6.5 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.
6.6 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.
6.7 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
5 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/524531/160519_Nationally_Described_Space_Standard____Final_Web_version.pdf
6 NPPG Housing Optional Space Standards: Paragraph: 003 Reference ID: 56-003-20150327 Revision date: 27 03 2015.
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.

Comment

Representation ID: 23171

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Accessible and Specialist Housing
6.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
6.9 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.
6.10 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. 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.
6.11 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.
6.12 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.
6.13 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.
6.14 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.”
6.15 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.
6.16 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.

Comment

Representation ID: 23172

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Self/Custom-Build
6.17 There does not appear to have been any assessment of the need for self/custom-build housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
6.18 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.
6.19 Pigeon are supportive of providing self-build plots and their proposals at Reepham allow for such development.
6.20 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.
6.21 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: 23173

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

POLICY 6 – ECONOMY
7.1 Policy 6 proposes a number of employment allocations. However, these allocations do not necessarily reflect the needs of individual communities.
7.2 For example, where an employer with a particular connection to a settlement has identified a need to relocate to more suitable premises, provision should be made for this relocation to occur at the settlement through the allocation of an appropriate site. This circumstance exists at Reepham where a significant local employer engaged in the tourism industry has identified a need for new premises to allow for the continued successful operation and expansion of their business.

Comment

Representation ID: 23174

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

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
- land in front of ATB Laurence Scott
8.6 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.
8.7 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.
8.8 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.
8.9 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.
8.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown 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.

Comment

Representation ID: 23175

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

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.
8.2 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.
8.3 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.
8.4 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.

Comment

Representation ID: 23176

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

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.
8.12 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.
8.13 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.
8.14 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.
8.15 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.
8.16 Our client reserves 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.