Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22429

Received: 16/03/2020

Respondent: Gladman Developments

Question 6: Do you support or object to the vision and objectives for Greater Norwich?
Vision
4.1.1 Gladman supports the general pro-sustainable growth vision outlined by the Councils for the GNLP. The provision of new homes, opportunities for employment, strategic infrastructure and protection of the environment and resources all fulfil a key role in achieving the Councils’ vision. A core missing element of the vision, however, is the need to secure the integration of economic, housing and infrastructure strategies to ensure that the pattern of development provided through the Local Plan is sustainable and deliverable. The need for this integration in forming targets and determining the location of development and specific sites should be better reflected within the Plan’s vision.
Objectives
4.1.2 Objectives covering the economy, communities, new homes, infrastructure, delivery and the environment are outlined within the GNLP. In broad terms, Gladman is supportive of the objectives outlined, however in several instances it is considered that these do not go far enough. Under the economic objective the wording should be expanded to recognise the role housing delivery has in supporting sustainable economic growth, particularly in supporting town centres. In particular there is a need to ensure that the proposed level of allocations made through the GNLP maximises economic growth potential provided through the City Deal and the A11 Norwich to Cambridge technology corridor.
4.1.3 Beyond this, Gladman considers that reference is needed within the homes objectives which seeks to meet affordable housing needs in full and addresses house price unaffordability to promote home ownership and to secure homes in the area for first time buyers, families and the elderly. The objective should be expanded to also ensure that the housing needs of the elderly and disabled are met through the plan period.

Comment

Representation ID: 22430

Received: 16/03/2020

Respondent: Gladman Developments

5.1 Question 13: Settlement Hierarchy
Settlement Tiers
5.1.1 It is agreed that the Norwich Urban Area, including fringe parishes such as Costessey, forms the principal settlement within the joint plan area and wider region. The continued identification of the Norwich Urban Area at the top of the settlement hierarchy is supported by Gladman and is it accepted that the Urban Area should accommodate the largest proportion of new development planned for the plan period.
5.1.2 The inclusion of Diss and Wymondham as Main Towns in the second tier of the settlement hierarchy is supported. Gladman agrees that both settlements provide some of the most logical and sustainable locations for new development within the Greater Norwich Plan area beyond Norwich itself. Further development should therefore be directed towards both Diss and Wymondham through the GNLP.
Gladman also supports the identification of Poringland as a “Key Service Centre”. Poringland represents one of the more sustainable settlements listed as a “Key Service Centre” in the draft settlement hierarchy. Proportionate development relative the role and level of sustainability should be directed to Poringland.
Distribution of Development
General comments on Distribution
5.1.3 The Plan adopts Option 3, supporting the Cambridge to Norwich Tech Corridor as the basis for the distribution of development through the GNLP. It is acknowledged that the Tech Corridor forms a core role in the economic ambitions of the GNLP and as a result it is both appropriate and sound to concentrate new development towards this broad strategic location. However, as advised in our previous representations, the implementation of this strategy should not come at the cost of maintaining the sustainability and important role played by settlements which fall outside this corridor. It is important that sufficient development is directed to these settlements to support their longer-term sustainability and functionality. Opportunities should also be taken to focus growth towards those settlements which are well served by public transport to support climate change objectives. As such, Gladman consider that a mix of Options 2, 3 and 4 should form the basis of the distribution of growth adopted through the GNLP rather than Option 3 alone.
Norwich Urban Area
5.1.3 The Norwich Urban Area forms the largest built area in the plan area and wider county and is home to the largest and most diverse housing need. The Norwich Urban Area has the greatest range of services and facilities, the most diverse retail offer, and forms the economic hub of the plan area and wider county. The City Deal and strategic growth corridor initiatives provide significant opportunities for job creation, largely concentrated in the Norwich urban area. This means that the Norwich Urban Area plays an integral role to achieving the economic ambitions of the joint Plan which should be responded to through the allocation of additional land for development through the GNLP.
5.1.4 Gladman is supportive of Costessey being identified as the location for the planned 1,000 dwelling contingency. Costessey forms an integral part of the Norwich Urban area, with strong public transport links into Norwich City Centre, as well as access to the strategic road network. The infrastructure in and around Costessey is already well developed and Costessey benefits from a wide range of existing services and facilities, as well as access to local sources of employment. Importantly, Costessey is located on the opposite side of the Norwich Urban Area to the strategic growth triangle, which is to experience significant levels of growth over the plan period. Costessey has relatively limited commitments and as such there is little to suggest that additional supply directed to the settlement would result in a saturated market and reduced housing delivery. Costessey therefore represents a suitable location at which further housing needs can be realistically be sustainably accomodated.
5.1.5 Gladman however considers that the contingency site identified for Costessey is needed now and as such should be identified as an allocation for housing through the GNLP. Further homes are required in the Norwich urban area to respond to the extended plan period, as well as to capitalise on and secure the delivery of strategic economic objectives for the Norwich to Cambridge Technology Corridor. The Site should be allocated for housing now, to ensure that there is sufficient flexibility provided in the housing land supply to ensure full delivery of housing needs identified for the Norwich urban area should housing delivery at the Growth Triangle be lower than anticipated.
Diss
5.1.6 Diss is a market town located in the very south of the plan area, and forms an important service, retail and employment role for a large rural hinterland which extends beyond the plan area into North Suffolk. Further development is required in Diss to maintain and protect the quality of services and facilities available in the town.
5.1.7 Only limited growth is identified for Diss through the GNLP as drafted. Supporting information advising highways constraints appears to be founded on a much higher level of growth than proposed and known to be available. The role of new development in addressing broader constraints, such as school capacity, does not appeared to have been fully explored. 5.1.8 It is considered that the strategy for Diss fails to adequately support the sustainability of the town, or its role as a service centre for wider rural area. The limited growth identified for the town does not support opportunities and objectives to enhance the retail offer in the town. Diss forms the most appropriate location for development in the south of the plan area. It is also well served by public transport, and additional growth here would align to climate change policy and objectives by minimising reliance on unsustainable modes of transport. Further allocations should therefore be sought at the town.
Wymondham
5.1.9 Wymondham is sustainable settlement located on the A11 corridor. The town is the largest population centre in the plan area outside the Norwich urban area. It features a wide range of services and facilities including a primary school, secondary school, food store, doctor’s surgery, pharmacy, and community centre. The town benefits from rail links to Norwich and Cambridge, with a high-quality bus route into Norwich City Centre.
5.1.10 Wymondham is located within the Norwich to Cambridge Tech Corridor with access to both the A11 and the Norwich to Cambridge railway line. The growth corridor forms the heart of the spatial strategy for the draft GNLP, yet despite Wymondham’s strategic position within the corridor, minimal additional growth is planned in the settlement in addition to already committed development.
5.1.11 Gladman consider that the absence of allocations in Wymondham significantly reduces the effectiveness of the GNLP in delivering Tech Corridor ambitions and opportunities to the town and respond to evidence of updated needs and policy requirements which will not be captured by existing commitments. Gladman acknowledge the potential for further growth in the town brought by the possible contingency. Gladman is supportive of the Councils consideration of further opportunities for growth in Wymondham, however consider that this contingency should be made an allocation to make the most of Strategy Growth Corridor opportunities, and respond to overall concerns submitted later in these representations regarding the proposed housing requirement and amount of development planned.
Poringland
5.1.12 Poringland is a sustainable settlement, featuring a primary school, GP surgery, Secondary School, Pharmacy, Community Centre, and Food Store. The village is also served by highly regular bus services to Norwich. Poringland therefore represents both a suitable and sustainable location for new development and forms arguably the most appropriate Key Service Centre at which to meet development needs. 5.1.13 Currently, the draft Plan does not seek to direct any growth to Poringland beyond committed development. Gladman does not consider this to represent a sound strategy noting the above sustainability credentials which makes the settlement the principal option for accommodating rural housing needs. Opportunities for further sites for allocations should be sought and identified through the GNLP.

Comment

Representation ID: 22431

Received: 16/03/2020

Respondent: Gladman Developments

5.2 Question 14: Housing Numbers and Delivery
Proposed Housing Requirement
5.2.1 Draft Policy 1 proposes a housing requirement of 40,550 dwellings for the plan period 2018 to 2038 (2,028 dpa). This reflects the local housing needs for the Greater Norwich Plan Area using the Government’s standardised methodology. Having reviewed the wider evidence base informing the Plan, Gladman is not convinced that the standard method figure alone provides a sufficient level of housing growth for the Greater Norwich Plan Area especially in the context of the ambitious economic growth objectives set out in the draft GNLP. Further work is therefore necessary to understand the link between planned housing and job targets.
5.2.2 The standard method represents the minimum housing needs for the area and considers only demographic need and affordability. The standard method does not account for the housing needed to support economic growth needs or ambitions, nor does it align to commitments made for strategic investments or funding which might influence the level of housing growth required in an area.
5.2.3 PPG confirms the following circumstances in which the adoption of a higher housing requirement above the standard method may be justified3. This includes but is not limited to:
 Growth Strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
 Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;
 An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; and
 On occasion, situations where previous levels of housing delivery in an area, or previous assessments of need are significantly greater than the outcome from the standard method.
5.2.4 The Greater Norwich authorities benefit from the City Deal which commits to facilitating the delivery of 13,000 more jobs than the target set within the joint Core Strategy. Reflecting this commitment, Draft Policy 1 advises a job target of 33,000 jobs over the period 2018 to 2038. This requirement accounts for the remaining job growth associated with the City Deal and the longer term benefits the City Deal is predicted to have for the Greater Norwich economy. This represents an uplift of around 8,000 jobs against the baseline trend forecast as set out through the East of England Forecasting Model which might have otherwise informed the job targets of the emerging Plan.
5.2.5 Despite having influenced the economic growth strategy of the Draft GNLP, the City Deal does not appear to have been considered in determining the housing requirements of the Greater Norwich Draft Plan. This ignores the intricate links between the supply of housing and employment land, and the constraining nature insufficient delivery of housing can have on securing sustainable jobs growth otherwise recognised in Paragraph 81of the NPPF.
5.2.6 To ensure consistency with national planning policy, the authorities should assess to what degree the proposed housing requirement will support the implementation of the jobs growth figures set out in draft Policy 1. Should this assessment show that the supply of housing land planned through the GNLP would fail to provide for a sufficient economically active workforce, an appropriate upward adjustment should be made to the housing requirement to ensure that housing land supply does not act as a constraint to planned levels of economic growth. At present this additional, but important assessment, is missing from the supporting evidence base to the GNLP and is required to ensure that the proposed housing requirement is robust and consistent with national planning policy.
Supply
5.2.7 Gladman welcomes and is supportive in principle of the proposal to allocate surplus housing land in contrast to proposed requirements through the GNLP. This surplus will help secure a significant boost in housing land supply, heighten the deliverability of the defined housing requirement, and ensure that the GNLP is durable to any changes which might occur over the plan period.
5.2.8 The need to secure deliverability is significant in the case of the GNLP where much of the housing requirement is evidently already met by committed developments (around 85%), and in particular, a relatively small number of larger schemes. This includes the Old Catton, Sprowston, Rackheath, and Thorpe St Andrew growth triangle located north and east of Norwich which will provide around 13,500 dwellings, as well as other strategic development sites at Cringleford, Costessey, Long Stratton and Wymondham. Should any of these sites stall or fail to come forward as envisaged, the GNLP will quickly fail given the significant contribution made by these sites to the housing needs of the plan area. It is therefore important to plan for an increased supply and to allow flexibility to account for any potential shortfall at any of these sites.
5.2.9 A targeted buffer of 10% to the housing land supply is currently proposed through the draft Plan. Noting the significant degree of committed developments and the role played by large scale development cited above, Gladman does not consider this buffer to be sufficient and should be increased to no less than 20%. This would provide for a total supply of 48,660 dwellings (8,110 dwellings in excess of the requirement). The adoption of this higher buffer would provide greater certainty that the housing requirement, as currently defined, is met in full.
Contingency
5.2.10 In addition to the proposed buffer to the housing land supply, the GNLP identifies possible locations for further growth as contingency, should sites fail to come forward as envisaged. This includes 1,000 dwellings at Costessey, and the potential for a further 1,000 dwellings at Wymondham.
5.2.11 Further detail about the merits of specific locations for this contingency is set out under separate cover by Gladman. It is however unclear, at this draft stage, as to how the Councils envisage that the contingency sites might come forward when required in the plan period. As drafted the GNLP sets out no mechanism under which these contingency sites might come forward. The GNLP is therefore silent under what conditions these sites might be permitted by the relevant local authority, and what the approach to securing the delivery the proposed contingency locations are. In this regard the GNLP is ineffective, and a revised approach is necessary to secure its deliverability.
5.2.12 Gladman’s preference is for this contingency (at both Costessey and Wymondham) to be included within the Greater Norwich Local Plan as allocations for housing. This position takes into account comments made above in relation to housing need and the case for flexibility in planned levels of supply, should committed and other allocated sites fail to come to fruition. Allocating this land for housing provides the greatest certainty that sites can come forward without delay, sites are available and deliverable for housing, and reduces the need for future review.
5.2.13 Should the Councils disagree with the above, Gladman considers that additional wording is necessary in Draft Policy 1 to set out how contingency sites would come forward. The need for flexibility in this wording is key in order to minimise delay in meeting any arising unmet need and ensure that identified contingency sites are effective in responding to a requirement for an increase in the supply of housing land. As such, any policy requiring first a review of the GNLP before development is permitted at contingency sites should be avoided owing to the significant delay such a process would have, significantly reducing the merits of contingency sites in addressing any housing shortfall.

Comment

Representation ID: 22432

Received: 16/03/2020

Respondent: Gladman Developments

5.3 Question 16: Review and Five-Year Land Supply
Plan Review
5.3.1 Commitment is made within the GNLP to review after 5-years. Whilst the inclusion of this review within the Plan is welcomed, Gladman considers that wording relating to the timing of this review should be revised to ensure full consistency with national planning policy.
5.3.2 The GNLP should be reviewed within 5 years where necessary in response to significant changes in evidence, or where housing supply falls significantly and cannot be effectively addressed by the policies of the GNLP. This will provide flexibility for the Councils should conditions relevant to policy change significantly and unpredictably between adoption of the Plan and ahead of the 5-yearly review, ensuring that the development plan is responsive and durable to change.
5.3.3 In addition, and consistent with Paragraph 33 of the NPPF, the Councils should aim to complete the 5-year review of the GNLP ahead of the 5-year anniversary of adoption in order to avoid the Plan becoming out-of-date should land requirements depart significantly from evidence of needs. This takes into account the fact that national planning policy advises that the standard method will provide the basis for the calculation of five-year land supply where housing needs evidence supporting existing Local Plans becomes more than five-years old4.
5.3.4 Gladman considers that the future and early review of the GNLP should be inserted in draft Policy 1 or as a new policy.
Five-year land supply
5.3.5 The draft GNLP advises that the five-year housing land supply position for the plan area will be calculated as a whole, rather than on a district or sub-district basis. The move away from a subdistrict basis for this calculation is supported by Gladman. The current approach produces a fiveyear supply position for the Norwich Policy Area, and then a different supply position in the wider Districts beyond this location. This creates unnecessary complexity, reduces the scope for any deficiency in supply to be effectively addressed, and potentially removes the need or responsibility for action to address any supply shortages.
5.3.6 The proposed approach to calculate five-year supply across the GNLP area will address these flaws, securing a role for all of the Greater Norwich Councils in maintaining a sufficient level of supply over the plan period. The approach adopted is also responsive to the Housing Delivery Test which examines supply on this cross-boundary basis providing a single result for the authorities each year.

Comment

Representation ID: 22433

Received: 16/03/2020

Respondent: Gladman Developments

6.1 Question 27: Affordable Housing 6.1.1 Policy 5 outlines that the affordable housing requirement for residential development proposals of 10 dwellings for more is at least 33% across the plan area except in Norwich City Centre where the requirement is at least 28%. Gladman supports the principle of improving affordability across Greater Norwich and the need to identify an appropriate affordable housing target for differing built environments that reflects the local circumstances.
6.1.2 Notwithstanding the above support, the Councils will need to be able to demonstrate through clear, robust, up-to-date viability assessment that the provision of affordable housing in line with the proposed policy is viable on the majority of schemes. Gladman endorses the comments made by the HBF in this regard.
6.1.3 Gladman advocates the need for some flexibility within the affordable housing policy. This should be implemented dependant on the site-specific circumstances where constraints and limitations would hinder a site’s progression. This flexibility would ensure viability for development locations and guarantee delivery.

Comment

Representation ID: 22434

Received: 16/03/2020

Respondent: Gladman Developments

Question 29: Accessible and Specialist Housing 6.2.1 Policy 5 relates to the provision of accessible and specialist housing to meet the needs of older people, disabled people and vulnerable people with specific housing needs. Gladman is supportive of a policy in relation to this type of housing provision.
6.2.2 The provision of specialist housing to meet the needs of older people is of increasing importance and the Councils need to ensure that this is reflected through a positive policy approach within the GNLP. The Councils need a robust understanding of the scale of this type of need across the plan area.
6.2.3 Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own selfcontained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally accessible communal facilities including a residents’ lounge, library, dining room, guest suite, quiet lounge, IT suite, assisted bathroom, internal buggy store and changing facilities, reception and care manager’s office and staff facilities.
6.2.4 Policy 5 also relates to the Building Regulation M4(2) ‘accessible and adaptable dwellings’ and requires that 20% of housing should be built to this standard. 6.2.5 With regards to the provision of accessible and adaptable homes, Gladman refers to the PPG which provides additional guidance on the use of these optional standards. The Councils would need to ensure that any such policy in the GNLP is in line with the guidance and that the justification and specific details of the policy take account of the various factors that the PPG refers to:
“Based on their housing needs assessment and other available dataset it will be for the local planning authority to set out how they intend to approach demonstrating the need for Requirement M4(2) (accessible and adaptable dwellings), and/or M4(3) (wheelchair user dwellings), of the Buildings Regulations. There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including:
 The likely future need for housing for older and disabled people (including wheelchair user dwellings).
 Size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).
 The accessibility and adaptability of existing housing stock.
 How needs vary across different housing tenures.
 The overall impact on viability.” (ID 56-007-20150327)
6.2.6 In order to be able to include specific requirements in relation to M4(2) and M4(3) the Councils will need to be able to robustly justify the inclusion and demonstrate that consideration has been given to these requirements within the viability study. The provision of M4(3) wheelchair user dwellings is far more onerous in terms of size requirement therefore it is crucial that the implications of any proposed policy requirement have been properly considered.
6.2.7 With regards to M4(3) Gladman refers again to the PPG which states:
“Part M of the Building Regulations sets a distinction between wheelchair accessible (a home readily useable by a wheelchair user at the point of completion) and wheelchair adaptable (a home that can be easily adapted to meet the needs of a household including wheelchair users) dwellings.
Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.” (ID 56-009020150327)

Comment

Representation ID: 22435

Received: 16/03/2020

Respondent: Gladman Developments

Question 32: Self Build Plots 6.3.1 Policy 5 outlines a requirement for all housing sites (allocated or windfall except for flats / apartments) which comprise 40 or more dwellings to set aside a minimum of 5% of the net developable area for serviced plots to be offered for self-build.
6.3.2 Gladman objects to the inclusion of a fixed percentage requirement in relation to the provision of serviced self-build plots.
6.3.3 Whilst recognising the role attributed towards self-build in national planning policy as a source of housing land supply, we do not consider the inclusion of a requirement for all housing schemes over 40 dwellings to commit to onsite provision forms the most effective approach of responding to this source of housing need.
6.3.4 Gladman believes that those wishing to bring forward a self-build or custom build house are unlikely to wish to do this alongside a large-scale housing development. Consequently, rather than including a strict requirement for this provision Gladman would recommend the policy encourages the consideration of the provision of self-build plots in locations where the demand exists.
6.3.5 Gladman would prefer to see policy which seeks self-build plots being considered on an ad hoc basis as windfall rather than as a percentage requirement of larger development schemes. We consider this approach to be more in line with the wants and needs for the individuals seeking the plot and the developer’s requirements for larger sites.
6.3.6 Should a percentage approach be taken forward, the requirement should be supported by and proportionate to clear and robust evidence of this source of housing need. Gladman recommends that any policy requirement in relation to self-build housing has an element of flexibility built in to allow for negotiation over self-build plots on the basis of viability to ensure that site delivery is not delayed or prevented from coming forward. Any specific requirement to include self-build plots should be tested through the Council’s viability assessment of the Local Plan policies to ensure that the cumulative impacts of all proposed local standards and policy requirements do not put the implementation of the Plan as a whole at risk.
6.3.7 Gladman notes that the proposed policy does include a mechanism which allows developers the opportunity after 12 months to either continue to market the plots for self-build or to revert back to them being delivered as part of the wider market housing scheme. Gladman supports the inclusion of this policy mechanism as it is necessary to ensure that housing land is not unnecessarily prevented from being brought forward. This helps to provide flexibility and helps to ensure that the required housing is delivered. If there is genuine demand for self-build housing it is likely that these plots would be brought forward relatively quickly.

Comment

Representation ID: 22436

Received: 16/03/2020

Respondent: Gladman Developments

7.1 Question 40: Further Urban Area 7.1.1 Gladman supports the recognised need for housing delivery to be achieved on the edge of the main urban area of Norwich, with surrounding parishes within South Norfolk and Broadland accommodating this growth.
7.1.2 Policy 7.1 outlines the suggested housing growth directed to the urban area with large numbers attributed to strategic urban extensions at Taverham and within the growth triangle. Gladman would argue that the location identified as a contingency site at Costessey would also provide a logical location for residential growth within the plan period and should also be allocated for development through the GNLP and is actively promoting the site on behalf of the landowners
7.1.3 Furthermore, when taking the uncertainty surrounding some of the other location within the plan, namely the Carrow Works and well as the significant reliance placed on growth at the Growth Triangle, it seems logical that this alternative should be included in the Norwich urban area to ensure that the defined housing needs of the plan area are met at the most sustainable locations, and maintain a housing land supply throughout the plan period, given its deliverable nature.
7

Comment

Representation ID: 22437

Received: 16/03/2020

Respondent: Gladman Developments

Question 41: Main Towns 7.2.1 Gladman supports the allocation of additional land at identified Main Towns. This recognises the suitability and sustainability of these areas as suitable locations for development over the plan period. However, for the reasons set out in Paragraphs 5.1.3 and 5.1.6 to 5.1.11 Gladman do not consider that sufficient opportunities for new development, in addition to commitments, is identified particularly in Diss and Wymondham. In response, Gladman consider further allocations should be identified at both settlements, with the proposed contingency for Wymondham, formally allocated as a site for housing.
7.2.2 Gladman considers that strategic gaps should be reviewed and revised through the plan making process of the Greater Norwich Plan. Since defined and last reviewed the context for each strategic gap is likely to have altered taking into account more recent development, with the role of strategic gaps as a development management tool altered given the spatial strategy outlined within the draft Plan. A thorough evidenced based assessment of all affected land parcels together with wider related land is necessary to consider whether strategic gaps remain a relevant and necessary designation to prevent the coalescence of settlements within the plan area.

Comment

Representation ID: 22439

Received: 16/03/2020

Respondent: Gladman Developments

Question 43: Key Service Centres 7.3.1 Gladman supports the identification of settlements within this tier of the hierarchy and recognises the need for these locations to take growth in order to meet the local need for housing and encourage growth within the community.
7.3.2 However, it is felt that additional new allocations to some of the locations which do not receive any within the local plan review would be beneficial for both the settlements and the wider plan’s effectiveness. Namely, Poringland/Framingham Earl as the second largest Key Service Centre can accommodate additional levels of growth to boost the housing numbers in this tier and within the settlement. Given its location relative to Norwich and the facilities which are provided for within its confines, Poringland is an excellent candidate for additional growth through this plan despite the number which has already been attributed to it and could help bolster land supply with smaller sites that can demonstrate delivery now.