Draft Greater Norwich Local Plan – Part 1 The Strategy

Support

Representation ID: 22056

Received: 13/03/2020

Respondent: Norwich International Airport

Agent: Barton Willmore

3.2 Norwich Airport supports the vision for economic growth during the Plan period. Site 4
can be considered a strategic employment site, supporting the GNLP’s vision as it is
located with immediate access onto the strategic highway network (Broadland Northway).
Broadland Northway provides easy access to the region’s other strategic roads, including
the A47 and A140. Site 4 is also located in proximity to proposed residential / mixed use
sites shown in BDC’s Growth Triangle Area Action Plan (adopted in July 2016), which will
continue to come forward in the GNLP.
3.3 To support the previous representations in March 2018, Norwich Airport provided evidence
in a Local Market Analysis Report, undertaken by Roche and Bidwells, that demonstrated
Site 4’s potential to include large-scale B2 and B8 uses for which there is a proven demand
and lack of comparable space in the region. Its size gives the Site the flexibility to support
a wide range of economic sectors. A copy of the Report is available at Appendix 2.

Comment

Representation ID: 22057

Received: 13/03/2020

Respondent: Norwich International Airport

Agent: Barton Willmore

4.2 Site 4 can contribute to the region’s large-scale development. As mentioned in Question
6, it can support a number of uses, including large-scale B2 and B8 employment space.
4.3 Norwich Airport proposes an allocation at the Site of a mixture of aviation and nonaviation
uses, with the flexibility to release land for general employment depending on
market demand. Part of the Site benefits from extant planning consent restricted to
aviation-related uses. The lack of market demand has meant that there has been no
uptake in aviation floorspace. This has been the case since the original planning
permission for aviation-related uses was granted by NCC and BDC in 2013. The planning
flexibility to include non-aviation related employment floorspace will help bring the Site
into economic use and contribute towards the provision of infrastructure required to
support aviation-related employment, which is considered a knowledge-intensive sector
by the GNLP.

Comment

Representation ID: 22058

Received: 13/03/2020

Respondent: Norwich International Airport

Agent: Barton Willmore

5.2 Norwich Airport partly supports Policy 1 as the Airport area is considered a strategic
employment location. It is ideally located on the strategic road network, as shown in
Figure 1. The Site is suitable to support a wide range of economic sectors, helping to
contribute to the delivery of 33,000 additional jobs throughout the Plan period.
5.3 However, Norwich Airport would question the assertion that the land provided for in 2018
is sufficient for the region’s needs throughout the Plan period. The Report undertaken by
Bidwells and Roche has demonstrated that the existing employment floorspace is not of
a high quality to support new businesses, shown at Appendix 2. New companies require
flexibility and the Site is able to provide suitable floorspace that is beneficial from a
quantitative (it would be the largest single allocation in the Plan) and qualitative (it would provide modern floorspace, adapting to companies’ requirements and market changes)
perspective.

Comment

Representation ID: 22059

Received: 13/03/2020

Respondent: Norwich International Airport

Agent: Barton Willmore

6.2 Norwich Airport supports the delivery of the Norwich Western Link road and made
representations to Norfolk County Council in respect of the four potential route options in
February 2019. The Western Link is a critical infrastructure improvement that will help
facilitate this economic growth by increasing the Airport’s accessibility and connectivity.
6.3 As the Site connects directly onto Broadland Northway, the Western Link will connect it
to the A47 (towards King’s Lynn), reducing the number of vehicles using minor roads,
improving the economic growth of the Site and increasing its attractiveness as a strategic
employment location.
6.4 The Western Link Road should be prioritised for construction in the early period of GNLP.

Object

Representation ID: 22060

Received: 13/03/2020

Respondent: Norwich International Airport

Agent: Barton Willmore

Incorrect Site Area
7.5 Norwich Airport supports inclusion of the allocated land for employment in Policy 6 and
that 50% is allocated for general employment uses. However, the proposed allocation
does not include all of the land proposed for Site 4 that was submitted as part of the
previous Regulation 18 representations, which extends to 46.5ha. The plan of the Site is at Appendix 1.
7.6 The proposed allocation does not include available land to the west and east. It is
requested that this land is included in the draft allocation. Paragraph 117 of the National
Planning Policy Framework (NPPF) states that planning policies should promote an
effective use of land, utilising previously developed land. Airport land is defined as
previously developed land by the NPPF and therefore all the land should be made available
and be allocated for employment uses.
7.7 The Norwich Airport Masterplan, which has been adopted by NCC and BDC, does not
identify the Site for any future airport operational or expansion requirements, with the
exception of retaining the required fire training facilities. Paragraph 9.34 of the
Masterplan states that it will safeguard 44% of the land (equivalent to 20.5ha out of the
total 46.5ha) for aviation-related uses to maximise the opportunity for large-scale
aviation-related development. Chapter 9 of the Airport Masterplan is shown at
Appendix 3. This percentage was agreed between the Airport and NCC. This statement
should be reflected in the GNLP since the Airport Masterplan has been adopted by NCC
and BDC.
Inclusion of Roadside and Leisure Uses
7.8 In addition to providing large-scale industrial space for aviation and non-aviation uses,
the Site’s direct access onto Broadland Northway (A1270) makes it suitable for the
provision of roadside and leisure uses (Use Classes A1-A5 / sui generis / C1 / D2).
Broadland Northway is a strategic road, providing connections to other roads on the
strategic highway network (notably the A47 and A140). Given its location adjacent to the
region’s strategic highway network, it is ideally situated for roadside and leisure uses.
The future provision of the Western Link will improve the connection of the road still
further. Therefore, the uses of the Site allocation should be extended to accommodate
Use Classes A1-A5, sui generis, C1 and D2 uses in addition to the existing Class B and D1
Uses. The allocation of retail uses will help to improve the sustainability of the Site as a
whole by providing services and facilities for future employees in both aviation and nonaviation
industries, reducing the need to make vehicular trips.
7.9 Norwich Airport considers that the Policy should include a time limit, which seeks to reduce
the amount of aviation-related employment floorspace over time, reflecting market
conditions. As part of the ‘Call for Sites’ representations in March 2018, Norwich Airport
submitted a Report undertaken by York Aviation, which examined the existing and
predicted operational requirements for the Airport up to 2090. A copy of the Report is at
Appendix 4. York Aviation’s Report concluded that the land to the south of the runway
and 20% of Site 4, were sufficient to accommodate operational requirements for the
Airport, including MRO companies up to 2090. Through subsequent discussions with NCC,
an agreement of 44% retention was reached, which was inputted into the adopted
Masterplan. However, the Airport maintains that the Objective Evidence undertaken by
York Aviation is valid. Therefore, the allocation should be worded to allow for a greater
proportion of non-aviation floorspace should the proposed aviation occupier not be
realised in the next 5-10 years. This flexibility is supported by paragraph 81 (d) of the
NPPF, which states:
“Planning policies should be flexible enough to
accommodate needs not anticipated in the plan… and to
enable a rapid response to changes in economic
circumstance.”
7.10 In conclusion the proposed allocation in Policy 6 should:
1. Be extended to 46.5 ha in total make efficient use of previously developed land,
in accordance with national planning policy;
2. Include roadside and leisure uses (Use Classes A1-A5, sui generis, C1 and D2)
given its situation adjacent to the region’s strategic highway network and to
improve the sustainability of the remainder of the Site for future employees (both
aviation and non-aviation); and
3. Allow for a greater proportion of non-aviation floorspace to come forward in the
event that the aviation floorspace is not realised in the next 5-10 years.