Draft Greater Norwich Local Plan – Part 1 The Strategy

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Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 1: Please comment on or highlight any inaccuracies within the introduction

Representation ID: 22919

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

The draft GNLP therefore does not do what it says it does – it is not a single plan for the Greater Norwich
area, prepared jointly by the three Districts.
Without sight of the ‘South Norfolk Village Clusters Housing Site Allocations’ document:

 it is impossible to know whether sufficient sites will be found for the 1,200 new homes assigned to
that area / document; and

 there is no evidence to demonstrate that overall pattern of development will be an appropriate and
sustainable strategy, taking into account the reasonable alternatives, based on proportionate
evidence.

Full text:

For full representation, please refer to attached suite of documents.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 13: Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

Representation ID: 22920

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

Overall, the proposed distribution of growth, including the focus on the area around Norwich, is considered to be the most appropriate strategy, and is supported.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 13: Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

Representation ID: 22921

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

the limited amount of growth assigned to Horsford (at just 1.6% over the later 15 years of the plan period), which despite being a village cluster, is the ninth most populous settlement across all three Districts, and recognised as being a sustainable location for additional residential development, is not supported.

It would be far more representative of positive planning, and a far more justified and effective strategy, to recognise and reflect the recent growth of Horsford and to provide for further growth to yet further improve the sustainability of the village.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

Representation ID: 22922

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

There is a conflict in the GNLP between i) the desire to ‘drive economic growth’ and ii) the provision of only the minimum number of new homes.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 18: Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

Representation ID: 22923

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

The requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations is not supported by the evidence that the policy relies upon.

There is no justification for the lack of any alternative approaches.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 27: Do you support, object or have any comments relating to approach to affordable homes?

Representation ID: 22924

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

There is no evidence or justification for the proposed 33% requirement as set out in the draft Policy.

Given the lack of evidence for the proposed approach, it is particularly unreasonable for the GNDP to not put forward any alternative approach.

The reference to ‘at least’ requires clarification.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 28: Do you support, object or have any comments relating to the approach to space standards?

Representation ID: 22925

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

Overall, it is evident that the requirement in Policy 5 of the GNLP that all new homes must meet the Government’s Nationally Described Space Standard for any internal space, has not been properly and sufficiently justified.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 45. Do you support or object or wish to comment on the overall approach for the village clusters? Please identify particular issues

Representation ID: 22926

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

We reiterate, in respect to these questions, the points that we make above in respect to the village clusters and Horsford in particular above, in respect to Policy 1 / The Distribution of Development / Question 13.

We also reiterate our comments below in respect of the Site Allocations / Site Assessment Booklet – i.e. Part / Document 2 of the draft GNLP.

Full text:

For full representation, please refer to attached suite of documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 46. Do you support or object or wish to comment on the approach for specific village clusters?

Representation ID: 22927

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Representation:

We reiterate, in respect to these questions, the points that we make above in respect to the village clusters and Horsford in particular above, in respect to Policy 1 / The Distribution of Development / Question 13.

We also reiterate our comments below in respect of the Site Allocations / Site Assessment Booklet – i.e. Part / Document 2 of the draft GNLP.

Full text:

For full representation, please refer to attached suite of documents.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 13: Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

Representation ID: 22967

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

Representation:

Our client supports the Councils’ approach to focussing growth based on the hierarchy of settlements in the Greater Norwich area. This approach will result in the necessary future growth needs being accommodated principally in locations with the best access to jobs, services and existing and planned infrastructure.

In accordance with the sustainable growth strategy the Councils should look to maximise the use of land in existing sustainable locations, rather than promote homes in locations that need significant infrastructure to make them sustainable. Furthermore, the densification of sites that have already been identified to accommodate housing will maximise the use of existing social and transport infrastructure and minimise disruption to existing communities.

At the top of the Sustainable Growth Strategy hierarchy is the Norwich urban area, which includes the fringe parish of Cringleford. Within this parish 1,200 homes were allocated through the Cringleford Neighbourhood Plan and consent has been granted for 1,300. As part of the Greater Norwich Local Plan an uplift of 360 homes is proposed across two sites (GNLP0307 and GNLP0327).

Maximising the use of land in deliverable sites within the higher order settlements of the identified hierarchy should be the first approach that the Greater Norwich Local Plan takes to accommodating its housing numbers. Whilst our client’s site (GNLP0307) is proposed to accommodate part of the proposed uplift of 360 homes for Cringleford these new homes are split between the remaining land on our client’s site and the adjacent site (GNLP0327). Both these sites have a combined net developable area of approximately 13.5ha, which would result in a net density of only 26 dwellings per hectare (dph) if the uplift in the number of new homes were restricted to only 360. The figure of 26dph is well below the average density of 44dph that has been approved on the Newfound Farm site and would not accord with paragraphs 122 and 123 of the National Planning Policy Framework 2019 (NPPF) that require planning policies to ensure the efficient use of land and identify the importance of avoiding homes being built at low densities, especially in sustainable locations.

We have submitted evidence through the Site Allocations consultation to demonstrate that the remainder of the BDW site at GNLP0307 has the capacity to deliver approximately 500 homes and that the potential delivery at this site should be increased accordingly.

Our support for this question is therefore caveated by our related request to increase the number of homes that can be delivered at the preferred allocation in Cringleford.

Full text:

For full representation, please refer to the attached documents.

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