Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 23177

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.3 Key Service Centres
8.17 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 supported by appropriate levels of development.
8.18 However, many are planned to receive disproportionately low levels of development owing to a range of factors. Such constrained rates of growth are likely to compromise the role that these settlements play. In order to support such an unsustainable strategy, it would need to be demonstrated that the constraints identified by the Councils cannot be satisfactorily addressed rather than allowing the sustainability of these settlements to be compromised.
8.19 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.
8.20 Of the 3,253 homes to be allocated only 515 are new allocations with all other homes being derived from existing allocations or commitments.

Comment

Representation ID: 23178

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

In particular, the Key Service Centre of Reepham is proposed to receive no additional growth beyond the 142 homes which are currently committed. This represents 13% of the dwelling stock at 2011 and provides for one of the lowest proportional rates of growth of any of the Key Service Centres. It is therefore apparent that the GNLP is likely to compromise the vitality of Reepham.
8.22 Reepham is well located to receive new development including expansion of the doctor’s surgery which can be provided for by the provision of land to facilitate future expansion on Land north of Dereham Road in association with new employment development to meet the existing needs of a local firm providing support to the leisure industry across the wider area.
8.23 In failing to consider additional growth at such locations the Councils are missing opportunities provided by our client to provide the required additional community facilities identified in the GNLP Infrastructure Study at the Key Service Centres.
8.24 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: 23179

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Policy 7.4 – Village Clusters
8.25 The GNLP proposes a disproportionately high level of growth at the Village Clusters, a significant proportion of which are on as yet unknown sites to be identified in the South Norfolk Village Clusters Housing Site Allocations Plan.
8.26 Village Clusters are by definition less sustainable locations for growth and accordingly it would be expected that development would be restricted to that necessary to support rural or local needs. However, the GNLP seeks to direct more development to such settlements than to Key Service Centres which have a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving the rural areas according to paragraph 333 of the GNLP. Similarly, paragraph 308 identifies that the Main Towns serve the wider hinterlands including these Village Clusters. This would suggest that the needs of rural areas would be more sustainably provided thorough development at the Key Service Centres and Main Towns contrary to the strategy proposed in the GNLP. The GNLP strategy is even less sustainable, given that development at the Key Service Centres and Main Towns provides the opportunity to enhance community facilities which serve the rural areas.
8.27 Furthermore, the reliance upon a specific contribution from the unknown sites yet to be identified in South Norfolk may require unsustainable sites to be brought forward rather than identifying more sustainable sites now. In the absence of such specific sites being identified and allocated this will also adversely affect the housing land supply position of the Councils and provide for a lack of certainty going forward.