Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 21494

Received: 12/03/2020

Respondent: Hempnall Parish Council

Hempnall Parish Council would like to see the employment land already allocated in the JCS developed before any new sites are added. A large amount of the land allocated in the JCS for employment use remains available. The development of these existing sites should be prioritised before any new sites are added.

Allocated sites should be adhered to. This means that no exceptions should be made, particularly for larger businesses, to develop sites outside these allocated areas. If any such un-planned growth were to be permitted this would lead to further erosion of the area’s landscape and environment, along with issues regarding the sustainability of any such sites.

Object

Representation ID: 21498

Received: 12/03/2020

Respondent: Hempnall Parish Council

“Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside. It is difficult to understand the justification for changing the current settlement hierarchy within the JCS to that proposed in this draft plan, in particular by eliminating the JCS categories of Service Villages, Other Villages, smaller rural communities and the countryside, which provided opportunities for a more nuanced approach to housing allocation, appropriate to each category of community/settlement within their own setting, landscape and context. The “village cluster” approach is a relatively crude one, with much more of a ‘one size fits all’ approach. Hempnall Parish Council is particularly disappointed to see that the current JCS settlement hierarchy is not even offered as an ‘alternative approach’ in the draft GNLP, and wishes to see this rectified.

Even if the “village clusters” are adopted it would still be important to limit development to the areas within their development boundaries of settlements and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.

The different approach for “village clusters” in Broadland compared to those in South Norfolk is not acceptable given the emphasis on the GNLP being a strategic plan for the whole of Greater Norwich. The “village clusters” in Broadland and South Norfolk should be treated in the same way if they are to be included in the final GNLP. This means that a maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’. We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

Object

Representation ID: 21501

Received: 12/03/2020

Respondent: Hempnall Parish Council

We are concerned that all of the “village clusters” in South Norfolk (including Hempnall) will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

Object

Representation ID: 21503

Received: 12/03/2020

Respondent: Hempnall Parish Council

Hempnall Parish council considers that windfall development should be restricted to sites within settlement development boundaries. Housing need is already catered for by other policies in the Plan. Windfall developments should also count towards overall housing targets.

Comment

Representation ID: 21506

Received: 12/03/2020

Respondent: Hempnall Parish Council

Hempnall Parish council does not understand why there has been a major change in direction and policy as to where new development should be allocated in the GNLP compared to the current JCS. The JCS was only finally fully adopted in January 2014, just over 6 years ago. In the JCS housing concentrated in and close to Norwich was agreed and supported by hugely expensive infrastructure projects, in particular the Northern Distributor Road (now known as the Broadland Northway), which was primarily constructed to distribute traffic form and to new housing developments on the northern fringes of Norwich and in the North-east Growth Triangle. It would be a massive and costly folly to change that policy to one which allowed for the dispersal of much housing across the rural areas of Broadland and South Norfolk, where there is insufficient infrastructure, services and public transport, which would mean such development would be unsustainable. This would only lead to more congestion and pollution, leading to problems in meeting carbon-reduction targets.

Hempnall Parish council wants to see sites allocated for housing in the existing plan (the JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites.

It is very disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 68 Parish and Town Councils in Broadland and South Norfolk (over 37% and including Hempnall) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

We question the relevance of a plan whose horizon is 2038, which is likely to be reviewed and replaced on at least three occasions before its end-date, and we fear that on each of these occasions more unsustainable housing will be crammed in at the expense of the countryside. What is perhaps most disturbing is that so many people living in the area are not aware of the current JCS let alone the emerging GNLP, and that where citizens are engaged in the process they seem to have their views discounted. For example, this is clear where the views of over 37% of the Broadland and South Norfolk Parish and Town Councils regarding the phasing of housing development are apparently ignored.

Object

Representation ID: 21842

Received: 12/03/2020

Respondent: Hempnall Parish Council

Hempnall Parish Council as a signatory to the CPRE Norfolk Pledge which asks that existing housing allocations in current plans (in this instance the Joint Core Strategy) should be built out before new allocations made in emerging and new plans can be developed is seriously concerned that the Draft GNLP Strategy makes no mention of using phasing for the delivery of new housing. We consider that any new sites allocated in the GNLP should be phased by being placed on a reserve list, and under phased development only built out when most of the existing JCS sites have been used. Inclusion of all the sites for immediate development will lead to developers “cherry-picking” the most profitable sites and newly allocated green field sites in less sustainable locations will be developed first, with even more land banking of currently allocated sites. In short, deliver the already allocated 82% of the 44,500 new homes, before giving permissions on the remaining 18%.

The current Local Plan, the Joint Core Strategy (JCS) was adopted in March 2011 with amendments adopted in January 2014: it has been in place for just over 6 years. When adopted, it was considered to be the blueprint for development in Norwich, Broadland and South Norfolk until 2026, and in doing so provided clear signals about where growth should and should not take place. In the introduction to the current consultation document it is stated that housing, jobs, services and infrastructure needs to be provided at the right time ‘and in the right places’. Hempnall Parish Council questions how the response to this has changed so markedly since adoption of the JCS and well before that Local Plan was due to expire. In particular, the construction of the Broadland Northway (NDR) (noted in paragraph 7 of the introduction) was largely intended to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle. Moreover, there was a clear focus for housing and other growth to be in and close to Norwich, with minimal new development to be permitted in the rural policy areas of Broadland and South Norfolk. The GNLP strategy seems to be contradicting the direction of travel envisaged in the JCS and appears to undermine the planning process. A great strength of the JCS is the protection it gave to the rural areas, including Hempnall - this seems to be sacrificed in the GNLP Draft Plan.

Paragraph 6 of the Introduction is clear that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’ It will be difficult if not impossible to meet these targets if new housing to the scale proposed in the draft strategy is dispersed across the rural areas of Broadland and South Norfolk. The main justification for this appears to be the availability of primary school places in the “village clusters”, whereas there are more important measures for sustainability which should be taken into account, including the number of car journeys and journeys by delivery vehicles to new housing, along with the associated congestion such vehicles will result in.

The introduction mentions in paragraph 25 that South Norfolk District Council will draw up its own South Norfolk Village Clusters Housing Site Allocations document. Hempnall Parish Council is very concerned that by adopting such an approach this allocations document will not receive the same level of scrutiny as the main draft strategy document. We are also very concerned that the number of additional dwellings on top of the existing commitment of 1,349 houses is given as ‘a minimum of 1,200’. The use of the word ‘minimum’ is unnecessary and potentially very alarming, as in effect this gives no limit to the maximum number of houses which could be allocated in those “village clusters”. Given the draft plan provides enough committed sites ‘to accommodate 9% more homes than “need”, along with two “contingency” locations for growth’ (page 37) and does not include windfall developments in its housing totals, the word “minimum” should be replaced with “maximum” or “up to” as is the case with the figures for Broadland’s “village clusters”. Why is there this discrepancy in language between two authorities which are part of the same Local Plan: it appears to be inconsistent and illogical.

Object

Representation ID: 21843

Received: 12/03/2020

Respondent: Hempnall Parish Council

Paragraph 41 states that ‘this GNLP needs to plan for additional housing needs above and beyond existing commitments based on the most up-to date evidence’. However, the calculations of housing need are based on the 2014 National Household Projections, which are not the most up-to date statistics, nor are they sufficiently robust to be used for such an important and far-reaching strategy. Several Local Planning Authorities, including North Norfolk District Council, are challenging the use of the 2014 figures, instead suggesting that the more up-to date 2016 National Household Projections should be used. Hempnall Parish Council agrees that the GNLP needs to be based on the most up-to date evidence, and therefore requests the GNDP insists on using the 2016 National Household Projections. If the most recent ONS statistics had been used, current commitments are sufficient to cover housing needs to 2038.

Object

Representation ID: 21845

Received: 12/03/2020

Respondent: Hempnall Parish Council

A major concern is that the draft plan largely consists of a wish list, but lacks real targets or actions, particularly on the environment and climate change.

Paragraph 120 stresses the need for ‘good access to services and facilities’ for ‘our suburbs, towns and villages’. While this is provided in the first two categories of settlement there is insufficient provision or access to services in many of the settlements within the “village clusters”. The decision to allocate additional new housing beyond what is already allocated within the JCS is based almost solely on the existence of a primary school with available places or potential for expansion within the “cluster”. This does not amount to the provision of ‘good access to services and facilities’ and therefore this level of new housing in “village clusters” should not be permitted within the GNLP.

Paragraph 125 is perhaps the strongest argument for not allocating additional housing to “village clusters” within the GNLP. Clearly, there will be a major need for journeys from and to work for many of those living in any such new housing, in addition to additional journeys by delivery vehicles to this new housing. This paragraph states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ For the majority of the plan period it is highly wishful thinking to think that ‘electric vehicles will predominate throughout Greater Norwich’. These additional journeys will not only add to the “carbon footprint” but will also add to congestion on the road network, affecting air quality and the wellbeing of residents. If the intention of the GNLP is to locate housing close to jobs, which we agree should be a major aim, then any additional allocations of housing should be located in or close to Norwich, where there are realistic opportunities to walk or cycle to work and to services, or to use public transport to do so.
Paragraph 129 states: ‘greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable energy sources. To ensure that the water-supply to existing users is not compromised it is sensible to restrict the number of new houses to a level that realistically covers actual need, and this fact reinforces our case for phasing of housing and our questioning of the need for a higher than necessary buffer.

Paragraph 132 makes the claim that new quality development will be located to minimise the loss of green-field land. Hempnall Parish Council strongly suggests that the best way to achieve this is not to allocate additional sites for housing in “village clusters”. Indeed, there are already sufficient allocated sites for housing in the JCS being proposed to be carried forward to the GNLP in the Norwich fringe parishes, main towns and key service centres to keep pace with the likely build rates of development. The exception to this should be any brownfield sites, particularly those within Norwich, which should be prioritised into a “brownfield first” policy. This should form part of a phased approach to new housing, so that existing allocations from the JCS and any brownfield sites should be developed before permitting any additional allocated sites to be built-out.

In particular we ask that if additional sites, such as on the Britvic/Unilever Carrow Works site or the Anglia Square site (both in Norwich) become available for development, then these will not be counted as additional houses to the published targets, but that instead the extra housing numbers provided by these sites will be taken off the numbers scheduled for rural areas, reflecting the favoured view from the previous consultation for concentration of housing in and close to Norwich. In addition, this would help the GNLP to meet its Climate Change targets as well as providing more sustainable housing. We hope that a change of this nature can be accommodated before the Regulation 19 stage of the GNLP.

One effective way to prevent the unnecessary loss of much greenfield land, which in most instances is of a high quality for agriculture, would be to institute a green belt around. It is a matter of regret that this option has not been included in the current Draft plan.

In conclusion to this question, we find that the vision and objectives contain serious flaws, especially in regard to the way in which they conflict with policies within the current Local Plan, which withstood the rigorous inspection process.

Object

Representation ID: 21846

Received: 12/03/2020

Respondent: Hempnall Parish Council

This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ Hempnall Parish Council disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.

It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. We are one of 68 Parish and Town Councils in Broadland and South Norfolk (over 37%) that has supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

With an existing commitment (April 2019) of 33,565 houses available in the current JCS (draft GNLP Plan page 44), and a long-term delivery rate (2009-2019) that averages 1,652 net completions per annum (figures from JCS Annual Monitoring Reports,) it is highly likely that the current commitment is sufficient to cover at least 18 years of new housing development i.e. to 2038 as a minimum. In these circumstances there really is no need for any new sites to be allocated in the GNLP.

Object

Representation ID: 21847

Received: 12/03/2020

Respondent: Hempnall Parish Council

Given the stated measures in the Climate Change Statement, it is impossible to see how the proposed additional allocation of sites for housing in “village clusters” can be justified. Furthermore, it is stated that ‘growth in villages is located where there is good access to services to support their retention’, when this is rarely the case beyond providing a primary school with sufficient places or room for expansion. Many services are simply not located within the “village clusters” with many additional vehicle journeys being an inevitable consequence of such housing allocations. Therefore, these would be contrary to measures 2 and 3 of the Climate Change Statement.

By locating additional housing in “village clusters” there would be an increased need to travel, particularly by private car, due to the lack of viable and clean public transport. If Climate Change is seriously going to be addressed then it is unacceptable to allocate additional sites for housing in rural areas which are not at all, or poorly served by public transport. New housing must be located where jobs and a wide range of services are or can be provided.
Hempnall Parish Council has serious concerns about the lack of any detailed policy on the design of new housing in the draft Plan document, other than a brief mention in the ‘Design of development’ in the Climate Change Statement. Detailed requirements to insist that new houses are built to the highest possible environmental standards beyond the Government’s minimum standards are needed, if serious steps are to be taken towards addressing Climate Change issues. All new housing should have solar panels, be insulated to the highest standard and include features such as grey water capture.