Draft Greater Norwich Local Plan – Part 1 The Strategy

A number of these areas are subject to significant landscape and infrastructure constraints, which place delivery at jeopardy and could result in significant adverse impacts on local character and biodiversity. These issues have already impacted upon the delivery of a large proportion of the ‘existing deliverable commitment’. Additional consideration should be given to the individual characteristics of each town and their suitability for additional development, and the scale of this.

As with the approach to the urban fringe parishes and the main towns, we would raise concerns regarding the deliverability, and sustainability of additional ‘bolt-on’ developments in these locations. Such continuing urban sprawl is not considered to represent truly sustainable development, can often result in the creation of non-walkable neighbourhoods separated from services and facilities, places increased pressure on local infrastructure, and often comprise identikit housing which fail to adequately respect local character and create community cohesion.

We would support the distribution of some growth to smaller settlements in order to support their vibrancy and sustainability. These clusters are predicated on school catchment areas and justification for the proposed scale of development is based on the school’s ability to expand, however in a number of villages the schools are either at capacity or landlocked, thus preventing their expansion. It is considered that further work is required to ensure that the levels of development proposed in these areas is deliverable, and would not result in students needing to be transported to other areas to attend school as this would be counter-intuitive.

We consider that the approach for small scale windfall housing development is too restrictive in terms of the levels of development that would be considered acceptable.

We would raise concerns regarding the manner in which existing housing commitments and proposed new allocations have been counted towards the housing figures. It is considered that there is significant risk of double counting, particularly where some developments which are already being delivered are being proposed as new allocations. There appears to be no consistency between the circumstances as to whether sites are counted as delivered, existing commitments, or new allocations. Some settlement booklets refer to no allocations being carried forward, whilst the corresponding table within the Strategy document or Area Action Plan indicates that there are existing commitments to be carried forward.
We would raise concern regarding the deliverability of a significant proportion of housing by virtue of previous non-delivery, significant infrastructure restraints, and viability. Furthermore, we would raise concern regarding the ability to deliver a significant proportion of housing within the Plan period, and in particular in a timescale which means they can be relied upon to maintain a valid five-year housing land supply.
We object to the proposed strategy for growth as it is considered incompatible with the overall purpose of the plan, in particular the delivery of sustainable development which meets the challenges of climate change, and supports ambitious local and national targets for carbon neutrality. Additionally, it is not considered that the proposed distribution of growth is suitably forward thinking to facilitate the transition to a post-carbon economy, and the emergence of the region as the UK leader in clean growth.
The proposed new settlement Honingham Thorpe provides the opportunity to deliver growth differently, with purpose built infrastructure from day one and energy efficient and climate smart technologies built into the fabric of the community, to deliver a community with zero-carbon principles.