Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22691

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
6. The vision for the Local Plan is to achieve a ‘vibrant, healthy, inclusive and growing communities supported by the delivery of new homes, infrastructure and an enhanced environment.’ It is clear from Section 3 – The Vision and Objectives for Greater Norwich that a key theme throughout is playing a part in the national commitments to achieving net zero greenhouse gas emissions by 2050.
7. Scott Properties is passionate about the need to address Climate Change. It is agreed that this is one of the most important factors to our future and as such should be a key consideration in the preparation of the new Local Plan.
8. Chapter 14 of the National Planning Policy Framework (NPPF) focusses on ‘Meeting the challenge of climate change, flooding and coastal change’.
“The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.”
(Paragraph 148 – NPPF, 2019)
9. The Plan needs to be visionary looking forward beyond 2038, in particular having regard to the Government’s commitment to reach Net Zero Carbon by 2050. The Plan also needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the Plan area.
10. We believe that our client’s site can help address the visions and objectives for the Greater Norwich area, and we strongly support its inclusion in the draft Local Plan as a Site Allocation. The scheme currently proposed at Land at Briar Farm, Harleston could include approximately 20% single-storey dwellings suitable for older members of the community as well as those with or supporting someone with a disability, with associated site infrastructure and public open space forming part of a larger settlement extension of circa 330 dwellings, together with care, retail and recreational opportunities to serve the town.
11. It could deliver a proposed approximate mix of 5% 1 bed properties, 40% 2 bed properties, 40% 3 bed properties and 15% 4 bed properties, subject to further pre-application advice from Officers at South Norfolk District Council. The inclusion of circa 20% bungalows means as people age there is more choice and opportunity to plan for old age and move into more suitable accommodation when they no longer need a family home, while remaining in the local area and close to friends, family, and local support networks. New family housing also comes to the market as a result, reducing the pressure to provide additional family housing sites in the local area. This in turn enables new families to move to the area helping to redress the demographic imbalance and increase support for the continuance of demand for existing services and facilities.
12. The further inclusion of a site for a 90 bed C3 care block and additional specialist accommodation for older people (circa 30 units) as part of the care allocation will ensure that there is accommodation to meet the needs of an ageing population at a local level. Paragraph 34 of the spatial profile identifies that the population of Greater Norwich has a relatively high proportion of older people compared to national figures and that the pattern is set to increase to 2038. This further growth of the older population will add to the already significant pressure on home care services and will also feed through to increased demand for residential care facilities.
13. The proposed development could also make a significant contribution towards affordable housing provision.
14. In addition, public open space will be provided for the enjoyment of both new and existing residents, and it will be possible to deliver an area of allotment space for both the enjoyment of existing and new residents in the area.

Comment

Representation ID: 22692

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
15. The Delivery Statement set out at Paragraph 139 of the Draft Strategy sets out that the Plan will promote a pro-active approach to delivery through only allocating housing sites where a reasonable prospect of delivery can be evidenced, taking into account policy requirements. This approach accords with paragraph 67 of the NPPF and is supported.
16. In terms of providing flexibility and including a 9% buffer, this accords with the objective of ensuring that a sufficient amount and variety of land can come forward. It is also recognised that it is proposed that the buffer will increase to 10% at the Regulation 19 stage, when the village clusters allocations will be included. It is acknowledged that the Plan aims to comply with the NPPF paragraph 68 requirement to accommodate at least 10% of housing requirement on sites no larger than 1 ha. However, given the uncertainty around the Carrow Works site (1,200) homes, it is recommended that where reasonable alternative sites exist in sustainable locations, additional smaller sites of up to c. 25 dwellings (expected delivery from 1 ha) should also be allocated throughout the Plan area to increase certainty around delivery and supply, particularly in the early parts of the Plan period, supporting the Government’s objective of significantly boosting the supply of homes.

Comment

Representation ID: 22693

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
17. Further to the above, the Delivery Statement states that it will continue to work to coordinate delivery with providers including Highways England and Anglian Water to ensure infrastructure will be delivered. The below approach outlined within the statement is also supported by my client.
- On-site and off-site provision required of development through conditions or legal agreements;
- Pooled use of CIL;
- Maximising opportunities to access Government and other sources of funding;
- Capital investment of public bodies and utilities companies; and
- Locally led delivery vehicles.

Support

Representation ID: 22694

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
18. As previously outlined within our response to Question 6, Scott Properties is passionate about the need to address Climate Change and as such supports the Climate Change Statement that has been included within the Draft Strategy at paragraph 141.

Comment

Representation ID: 22695

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
19. The preferred option for the Local Plan combines the concentration of the majority of development in and around Norwich and on the Cambridge to Norwich Tech Corridor, a large focus on market towns, with an element of dispersal to villages. This approach is supported and provides a balance across a range of the objectives of the Local Plan.
20. This approach would see housing commitments providing a total minimum deliverable commitment of 6,342 within the Main Towns over Plan period of 2018 – 2038.
21. The settlement hierarchy’s recognition of the contribution that the Main Towns like Harleston make to the delivery of housing is acknowledged and supported. While it is acknowledged that Norwich should be the principal focus growth, the market towns have an important role in creating a vibrant sub-region, and in the case of Harleston, serve wide hinterlands from which people are drawn to use the town’s shops, services, and facilities, including both primary and secondary schooling.

Comment

Representation ID: 22696

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
22. In developing the new Greater Norwich Local Plan, it will be important that an adequate mix of sites is promoted including a proportion of smaller sites as well as sites to meet specific housing needs (including housing for older people). Our client’s site at Briar Farm, Harleston could make a meaningful and positive contribution towards meeting these goals.
23. With regard to the delivery of new housing, the Greater Norwich Local Plan’s inclusion of a 9% buffer is supported, and while a higher buffer of up to 20% would normally be advisable to offset the potential for slow delivery on some sites, in particular large strategic sites. It is acknowledged that no allowance has been made in this instance for windfall within the overall supply and the contingency of approximately 2,000 homes provides additional flexibility to ensure that the overall housing needs are met. However, as outlined above, given the uncertainty around the Carrow Works site (1,200 homes), it would be advisable to allocate smaller sites up to c. 25 units (c. 1 ha) across the Plan area to help boost the supply of new homes.
24. It is acknowledged that the Plan aims to comply with paragraph 68 of the NPPF by accommodating at least 10% of the housing requirement on sites no larger than 1 ha, however, where there are reasonable alternatives available these should be included to maintain supply and avoid the need to rely on less certain strategic sites or large contingency sites.
25. The “presumption in favour of sustainable development” is at the heart of the National Planning Policy Framework 2019 (NPPF). The Planning and Compulsory Purchase Act 2004 (Section 39(2)) establishes a legal requirement for Plans to be prepared with the objective of contributing to the achievement of sustainable development.
26. Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and that it is therefore important that a sufficient amount and variety of land comes forward where it is needed.
27. To ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. The Government’s recently published housing delivery figures for 2019 indicate delivery for the Greater Norwich area comprising Broadland, Norwich and South Norfolk to be at 140%. This is very encouraging, however, housing delivery can be fragile and susceptible to changes in the economy or delays in the delivery of key infrastructure necessary for strategic sites to come forward.
28. Further to the above, Policy 1 – The Sustainable Growth Strategy sets the settlement hierarchy for the Plan Area as follows:
1. Norwich Urban Area (Norwich and Norwich Fringe)
2. Main Towns
3. Key Service Centres
4. Village Clusters
29. Further detail on Village Clusters is provided at Appendix 5 of the Draft Strategy, as the preferred option the Council consider that a ‘cluster approach better reflects the way people access services in rural areas and enhances social sustainability by facilitating levels of growth in small villages’ This statement is supported, however it is unclear how this approach will work effectively within the Plan area and how achievable it will be. As such, a focus should be made on small and medium sites. The distribution of growth to a variety of sites will enable a steady delivery of homes and ensure the District can meet its housing targets throughout the Plan period.

Comment

Representation ID: 22697

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
30. Policy 1: The Sustainable Growth Strategy states that the Plan will be reviewed 5 years after its adoption. At paragraph 33, the NPPF states that Local Plans should be “reviewed to assess whether they need updating at least once every five years” and goes on to state that reviews “should be completed no later than five years after the adoption date of that plan”. As such, it is not considered that Policy 1 is consistent with National Policy and this needs to be made more clear, stating that a review will be undertaken within five years of adoption or in the event housing delivery falls, or housing land supply falls below the annual requirement.
31. In respect of the five-year land supply, as outlined at Policy 1 of the Draft Strategy, the Five-year housing land supply will be calculated across the whole of the three districts comprising Greater Norwich. This approach is supported, however, given the political nature of planning decisions it should be monitored to ensure that all three districts continue to deliver in a proportionate manner.

Support

Representation ID: 22698

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
32. Further to the response provided above in respect of Question 11, we support the approach to infrastructure that has been set out within Policy 1 – The Sustainable Growth Strategy in that the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Adequate infrastructure provision is key to supporting the development of the Plan area and enabling development to come forward. The statement provided within Policy 1 is vague and needs a greater explanation as to how the Greater Norwich Local Plan will ensure sustainable growth is supported by improvements to infrastructure.

Comment

Representation ID: 22699

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
33. The preferred approach to sustainable communities is the requirement for sustainability assessments to accompany planning applications for major developments. This approach is supported and is considered to be in line with the National Planning Policy Framework.

Comment

Representation ID: 22700

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
34. Policy 4 – Strategic Infrastructure outlines the key elements to strategic infrastructure improvements that will be undertaken to support timely delivery of growth. The approach for on-site and local infrastructure, services and facilities is as follows:
‘Development proposals will provide on-site services and facilities and support local infrastructure capacity improvements through on-site provision, providing land and developer contributions.’
35. This approach is supported by our client and as shown on the accompanying Masterplan for their site known as Land at Briar Farm, Harleston, this approach is being taken to ensure the site brings forward the required on-site services and facilities required.
36. There is scope within this part of Policy 4 to also address the need to provide community uses on larger schemes that will benefit both future and existing residents.