Draft Greater Norwich Local Plan – Part 1 The Strategy

Hingham Town Council, in preparing this response the GNLP consultation, have gathered public opinion through Councillor attendance at the GNLP Hingham roadshow event on 25th February, corresponded and met with members of the GNLP team, received and discussed correspondence and held a dedicated GNLP public participation session at the Town Council meeting on 03 March 2020.
The GNLP consultation documents have been made available by the Town Council in Hingham Library, and at the February and March Town Council meetings. The site assessment booklet, preferred sites booklet and policy/strategy documents have been discussed extensively by Councillors via email and at the March Town Council meeting. Comments from the public and Councillors, both oral and written were collated and publicly relayed at the March Town Council meeting, at that meeting the Town Council agreed its outline response to the GNLP consultation.

An overriding consensus was that the GNLP consultation was poorly advertised (other than on social media), insufficient notice was given to enable the road show event to be advertised in the Parish Magazine, the road show was not organised in liaison with the Town Council, the GNLP website is not user friendly, with information being difficult to find, and the alternative ways of responding to the GNLP (other than using the website) were not sufficiently advertised. It is felt that the consultation process was not inclusive to all members of the community and was viewed by some residents as "pointless" as they considered that their comments would not be considered as they felt that the preferred sites allocations were a "done deal".

With specific reference to the site assessments, the Town Council consider that there are a number of contradictions within the site assessments and the sites put forward as preferred options for housing development and the decision on some sites to be deemed unsuitable, are extremely flawed.

Hingham Town Council would like to thank the members of the GNLP team who have engaged with the Town Council, listened to and taken on board these comments.


Hingham Town Council has signed the pledge to support the CPRE campaign objecting to any new sites being allocated for house building in revised local plans to 2038 until all existing allocations in current core strategies have been developed.
The Town Council's overriding response to the GNLP is to have a preference for no further development in Hingham, having already had several areas of housing development within the Town over the years, yet with little/insufficient improvement to the infrastructure to support the growth of the Town.

Under the GNLP, Hingham are being asked to accept 100 new homes, on top of the existing commitment of 16 homes and on top of that, an unknown number of new homes through small "windfall" development sites. The Council believe that this growth is not sustainable, without improvement to the existing infrastructure and facilities of the town.
Smaller sized gradual development may be less impactive on the existing infrastructure and facilities.
To be able to build and sustain a "stronger community", development in the Town needs to provide adequate affordable housing for local families, a range of suitable housing for a diverse population, housing in appropriate locations. Supporting infrastructure is required, such as provision of improved footways and pedestrian priority crossing points in key locations within the Town, road safety improvements to the "Fairland crossroads" , increased capacity at the primary school, a purpose built public car park within easy walking distance of the town centre, provision for green travel such as provision of publicly available vehicle charging points, extended green space for sports facilities, provision for an extension to the cemetery.

Hingham Town Council have recently acknowledged the Climate Emergency, any development need to address and mitigate environmental impact, including in terms of sustainability, green issues, pollution, and wildlife habitat.

Hingham Town Council is committed to working to try to secure the best outcomes for the community and to ensure that the infrastructure is adequate to support residents to be able to use local businesses and in turn enable those businesses to thrive.

The GNLP is set to run until 2038, by which time children now at the primary school will be seeking employment, they will need transport, they will need housing that they are able to afford to enable them to remain in a community where they grew up, if they so wish. Children not yet born will need to access both primary and secondary education. The GNLP needs to deliver adequate provision (alongside housing) to sustain both the community as it is today and tomorrow and the community that will be come 2038.

Hingham Town Council consider the Hierarchy to be flawed. Several parishes have been designated as Key Service Centres, at no point in the document is there a definition for a “Key Service Centre”. The lack of concrete criteria for a “Key Service Centre” renders the designation of such an entity meaningless.
Hingham Town Council object to any new sites being allocated for house building in revised local plans to 2038 until all existing allocations in current core strategies have been developed.
There is no evidence in the policy document of commitment to improved infrastructure in Hingham to enable the town to sustain the quoted 120 new homes, in particular additional primary school places and improvements to the road and footway network in the town.

Hingham has a allocation of 120 new homes (including 16 existing commitment), however the consideration of Windfall sites as being “acceptable in principle” – of sites of up to 3 homes within each parish would mean the ACTUAL homes that will be delivered is potentially unquantifiable (Policy 7.5 is ambiguous in its meaning and needs clarification).
Housing figures are not discussed inline with actual need within the community or taking into account the number of vacant properties already in existence.
Hingham Town Council have been told that “deliverability” is a key component to housing development site allocation. The Council would like to sate that just because something is deliverable it does not mean that it is right for a community, and there are concerns regarding the push to deliver housing development “en masse” which could potentially overwhelm the town’s facilities and infrastructure. The GNLP runs until 2038 and the Town Council are of the opinion that a phased approach to delivering smaller developments, as and when needed, with a higher focus on affordability for local people would be a more acceptable and appropriate approach.
Hingham Town Council object to any new sites being allocated for house building in revised local plans to 2038 until all existing allocations in current core strategies have been developed.

The allocation of employment locations should be considered in relation to allocation of preferred sites for housing development, and it should be considered how the 2 areas would impact on each other both positively and negatively. In Hingham a preferred site for housing development is sited opposite the designated employment area, only the “positive” of the potential for providing local employment (within walking distance) to residents of the new development has been highlighted. Siting a housing development so close to a “employment area” which is already home to heavy industry can have many negative impacts on residents, with regard to road safety, increased traffic in a confined area, noise and pollution. It should also be recognised that employment does not occur in just one designated area within a community.
There appears to be no time scales with regard to the development of the employment area - i.e when would the jobs be delivered?

Whilst Hingham Town Council support the policy “the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services” – there is absolutely no evidence to show how this will be achieved in Hingham. Hingham is in need of improvements to its footways, roads, school, green infrastructure and public transport – HOW in this going to be improved in Hingham to support the growth of the town?

Hingham Town Council supports the policy with regard to Sustainable Communities, but again question it’s deliverability, with specific reference to Hingham. It is disappointing that the GNLP housing development site assessment has concluded that a Preferred option – GNLP0520 is contrary to this policy on several counts. The development would not be able to provide safe and convenient access to existing facilities in the town (ref policy 2.1) , it would not respect, protect and enhance the landscape character (ref policy 2.5) and would unlikely to be able to manage travel (ref policy 2.6) demand due to Hingham’s limited public transport. The preferred option site GNLP0520 certainly would not “minimise flood risk or reduce the cause and impacts of flooding” (ref policy 2.8).
Whilst the policy theory for Sustainable Communities on paper is very desirable, HOW is this going to be achieved when preferred sites for housing development are allocated that are contrary to this policy.
The GNLP team and Planning Authorities thereafter should actively seek information from residents affected by or potentially affected by flooding in the vicinity of a proposed site allocation or development, rather than accepting the submittance from the developers that flooding has been / can be mitigated.

With reference to policy point 2 i (page 62) “ ….using a recognised community engagement process will be encouraged on larger sites……..200 dwellings” this is not far reaching enough. Community engagement should be mandatory for any development that would have a significant impact on a community – for example – with specific reference to Hingham – a development of 80 houses would have a significant impact on the town, in terms of integrating into the community, burden on local facilities such as Drs surgery and school and associated parking issues, as well as the visual and character impact a development would have on a small historic town such as Hingham.

As the Council have declared a climate emergency we believe that any new housing should be as energy efficient as possible and this is beyond the present building regs it should still be required. The use of community battery schemes would be useful in taking excess power generated during the day and making it available at night. If we are going to be required to drive electric cars then there will be a need for a much enhanced grid and the large power stations could be supplemented by local generation. On a historic note Hingham did at one time have it’s own gas works and similar small scale electrical generation should be welcomed

Hingham Town Council support the policy of environmental protection and enhancement. A community should have total confidence that if forced to accept more development , that the development would be an asset to and enhance the environment.

Preferred option site for housing development GNLP0520 is contrary to this policy. It has been commented upon that the recent Hops development adjacent to GNLP0520 (built by the same developer ) has “ruined” the approach to Hingham and is an “eyesore”. Communities should not be subject to development that instils such vehement dislike and opposition.
Policy 3 states “ The development strategy of the plan and the sites proposed for development reflect the area's settlement structure of the city, towns and villages, retaining the separate identities of individual settlements.
Development proposals will be required to conserve and enhance the built and historic environment through:
being designed to create a distinct sense of place and enhance local character taking account of local design guidance and providing measures such as heritage interpretation to further the understanding of local heritage issues;”
With the allocation of GNLP0520 as a preferred site to be built by the same developer as the Hops, residents fear being left with a large area of development (covering both the Hops and GNLP0520) that will not be in keeping with the historic environment of the very nearby areas of Hingham. Having one development of a distinctive style already been built, it does not mean that it is right for the settlement to be further developed by adding more of the same. In particular if its style and design is likely to be opposed and resented by residents of the town.

With regard to the Natural Environment –“ Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes”. Again with specific reference to GNLP0520. Development of GNLP0520 would be contrary to Policy 3 “The Natural Environment …. Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes” … it is clear from residents objections that the loss of such prominent and valued open landscape by developing GNLP0520 would definitely not “conserve or enhance the natural environment”, but permanently destroy it, on the approach to Hingham via the Norwich Road.
Sites should not be allocated for development when they are so clearly contrary to the policies that should be applied.

Whilst the Council believes that there should be no development until the present allocations have been built on it does believe that planners should give careful consideration to allowing more self build across the district and that they should be willing to allow some experimental green initiative building that takes account the need to address climate change/the climate emergency.
In the context of the climate emergency, where several species of wildlife native to Britain are becoming extinct or at risk of extinction the Council are concerned to ensure that housing developments are not built on areas where rare species of wildlife may exist, or indeed, where extension of the urban area will contribute to the depletion of wildlife. Should housing development take place wildlife habitat should be preserved, protected, enhanced and improved.

With regard to the Natural Environment –“ Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes”. Again with specific reference to GNLP0520. Development of GNLP0520 would be contrary to Policy 3 “The Natural Environment …. Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes” … it is clear from residents objections that the loss of such prominent and valued open landscape by developing GNLP0520 would definitely not “conserve or enhance the natural environment”, but permanently destroy it, on the approach to Hingham via the Norwich Road.
Sites should not be allocated for development when they are so clearly contrary to the policies that should be applied.

Whilst the Council believes that there should be no development until the present allocations have been built on it does believe that planners should give careful consideration to allowing more self build across the district and that they should be willing to allow some experimental green initiative building that takes account the need to address climate change/the climate emergency.
In the context of the climate emergency, where several species of wildlife native to Britain are becoming extinct or at risk of extinction the Council are concerned to ensure that housing developments are not built on areas where rare species of wildlife may exist, or indeed, where extension of the urban area will contribute to the depletion of wildlife. Should housing development take place wildlife habitat should be preserved, protected, enhanced and improved.