Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22440

Received: 16/03/2020

Respondent: Gladman Developments

Question 45: Village Clusters 7.4.1 Gladman generally supports this division of the hierarchy and the settlements which are contained within it. However, we put forward that the level of growth identified for these settlements should be proportionate to the level of services available within the settlement and does not undermine the wider spatial strategy which centres on the most sustainable locations within the three Greater Norwich authorities.

Comment

Representation ID: 22441

Received: 16/03/2020

Respondent: Gladman Developments

Question 47: Small Scale Windfall Housing 7.5.1 Gladman believes that Policy 7.5 in reference to small scale windfall housing development should be redirected to refer to any sustainable settlement with reference to ‘small scale’ removed allowing for greater flexibility within the windfall provisions.
7.5.2 The Council should establish a positive policy framework for windfall development to come forward at suitable and sustainable locations adjoined to its named settlements. To guide this, Gladman recommends that the Council adopt the approach applied by Ashford Council through Policy HOU5 of the adopted Local Plan. Policy HOU5 applies a criterion-based approach towards windfall proposals enabling an uplift in housing land supply. This is however controlled to ensure that the overall spatial strategy is not undermined or prejudiced, and a sustainable pattern of development is secured. An extract of Policy HOU5 of the Ashford Local Plan is included in Appendix 1 of this representation.

Comment

Representation ID: 22449

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution
2.1.1 Gladman supports the identification of Poringland (including Framlingham earl) as a Key Service
Centre in the settlement hierarchy. As Poringland is evidenced as the fifth largest settlement outside
the Norwich Urban Area, development at a scale to reflect the size of the settlement should be
deemed appropriate.
2.1.2 Poringland has a wide range of services and facilities including a primary school, doctor’s surgeries,
local shops, a supermarket, public houses and a post office. The town also benefits from a regular
bus service into Norwich City Centre. The settlement, therefore, forms a sustainable and logical
location for new development.
2.1.3 Gladman are concerned that currently no further growth is directed towards Poringland. The town
provides a sustainable setting for future growth, in a place where people want to live. Deliverable
sites should come forward in this location that could contribute to local economic, social and
environmental aspirations. Gladman believe the spatial strategy for housing growth needs to direct
higher numbers to sustainable settlements within the ‘Key Service Centres’ tier, such as Poringland.
This would help alleviate the pressure of delivery for larger strategic sites, with smaller allocations
that could deliver during the early stages of the adoption of the plan. .

Comment

Representation ID: 22450

Received: 16/03/2020

Respondent: Gladman Developments

2.2 Policy: 7.3 Key Service Centres
Growth directed to Poringland
2.2.1 Gladman welcomes the acknowledgement that Key Service Centres will continue to be developed
to enhance their function as places to live and work, and be providers of services to the settlement
and the hinterland. Whilst the level of growth directed to this tier is a minimum, the number of
houses committed to sustainable settlements falls short of the levels needed to meet housing need
and employment needs within the local areas, and the District as a whole.
2.2.2 Though Poringland has taken some growth, providing no new allocations is counterintuitive to the
role Poringland plays in the District. As explained previously, Poringland is a sustainable settlement
with sites readily available and deliverable now, that could provide extensive benefits to the
community and help boost significantly the supply of housing as emphasised through national
policy.
2.2.3 Gladman consider that allocating no new development through the Draft GNLP to a sustainable
settlement such as Poringland will not provide the flexibility needed to ensure land supply is met
over the plan period. The level of new growth to be directed to the settlement should be
substantially increased. 2.2.4 New allocations identified in ‘Key Service Centres’ would increase the flexibility of the Local Plan
and heighten its durability against unpredicted changes which might occur, especially with the
reliance on large strategic sites to deliver. Allocating land for sites at an appropriate scale to the
settlement through the Plan would address the current and future housing needs. Planning for
these sites now would increase deliverability soon after the plan is adopted.

Comment

Representation ID: 22451

Received: 16/03/2020

Respondent: Gladman Developments

Policy 7.5: Small Scale Windfall Housing Development
2.2.5 Gladman support the policy of allowing windfall development in principle. However, Gladman
object to the ‘small scale’ wording of this policy, and suggest this should be changed to ‘appropriate
scale’ and should apply not only to ‘Village Clusters’ but also ‘Key Service Centres’.
2.2.6 A flexible windfall policy should be introduced for development adjacent to existing settlement
boundaries of an appropriate scale to the settlement. This could work to accommodate existing
housing need and future needs of settlements, in sustainable locations that would provide benefits
to the local community and could contribute to the supply of housing for the District.

Comment

Representation ID: 22453

Received: 16/03/2020

Respondent: Gladman Developments

3.2.1 If allocated, the development of Land at Burston Road, Diss could deliver significant benefits to the
local area and wider community, this includes:
• Development of an appropriate scale for its location, providing for a wide range of tenure,
size and types of new homes;
• The delivery of policy compliant affordable homes;
• Land available for education uses to be discussed with relevant parties;
• Child play provision inclusive of a LEAP;
• A Country Park for the enjoyment of new and existing residents; and
• Potential highways improvements along with pedestrian and cycling links/improvements.

Comment

Representation ID: 22454

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution (Question 13)
2.1.1 Gladman is supportive of the identification of Diss as a Main Town within the settlement hierarchy.
Diss has the widest range of shops and services of the main towns, as well as a broad range of
employment opportunities. The town is located to the north west of the junction of the A140 and
A143 and benefits from rail connections to Norwich and London as well as acting as hub for local
bus links. As such, the settlement forms a sustainable and logical location for further development.
2.1.2 Diss has a key role to play in supporting the surrounding villages and rural hinterland through its
services and facilities. The retail offering of Diss is key in this supporting role with the large rural
catchment extending it to parts of South Norfolk and northern Suffolk. As such, Diss demonstrates
positive vitality and viability and has the opportunity to support further housing growth. There
would be strong justification to provide further growth than is currently proposed in Diss due to
this strong retail offering and other services, along with the good transport links to Norwich and
beyond.
2.1.3 It is the view of Gladman that should the preferred strategy be transposed to the publication version
of the plan this would represent a missed opportunity. Currently two further sites are identified in
Diss to provide only a further 400 dwellings in addition to existing commitments. This gives a total
of 743 dwellings between 2018-2038, a level of growth is comparable to that of Harleston, a main
town that does not benefit from the same transport links as Diss and serving a much reduced retail
catchment.
2.1.4 It is suggested in the consultation document that growth at Diss has been limited due to highways
constraints and congestion being considered a barrier to significant growth. This in itself is based
upon local evidence, the Diss Network Improvement Strategy (February 2020), which Gladman do
not consider to be a robust document.
2.1.5 This Strategy only considers four scenarios for future growth of varying scales ranging from
background traffic growth to significant northern and southern growth. Gladman consider there to
a gap in the ranges considered. Neither the northern nor southern areas are determined to be
deliverable but there is no further investigation to investigate the ‘tipping point’. Indeed, it is
suggested in the strategy that should the GNLP pursue a different option to those tested these
would also need to be tested, as the document currently does and therefore additional testing will
be required. As well as this testing Gladman suggest that other scenarios could be investigated as
it is Gladman’s view that additional growth than that proposed in the preferred options
consultation document could be accommodated at Diss. We are willing to engage with the Council
to see if development proposals being promoted by Gladman could provide assistance in
addressing highways constraints.

Comment

Representation ID: 22455

Received: 16/03/2020

Respondent: Gladman Developments

2.2 Policy 7.2 Main Towns
Allocations at Diss
2.2.1 Gladman welcome proposals made under Policy 7.2 for further growth to be allocated at Diss in
addition to existing commitments. It is however considered that the additional 400 dwellings
planned for through the Draft GNLP at Diss is not enough to meet housing and employment needs
(see main representations) and does not provide sufficient flexibility within the housing land supply
to ensure the deliverability of planned requirements. Gladman submit that the level of new growth
to be directed to the settlement could and should be increased.
2.2.2 Notwithstanding that Gladman think growth should be increased at Diss, we raise question marks
around the proposed allocations to the north of the Cemetery, west of Shelfanger Road and East of
Heywood Road. It is unclear what benefits the link road would provide when considered against the
potential landscape impact of the site. There does not currently appear to be certainty that the link
would alleviate the existing traffic problems, and this appears to be a ‘best guess’. Gladman suggest
further evidence will be needed to support this proposed allocation.

Comment

Representation ID: 22457

Received: 16/03/2020

Respondent: Gladman Developments

2.1 Policy 1: Settlement Hierarchy and Spatial Distribution (Question 13)
2.1.1 Gladman is supportive of the identification of Costessey as being included as part of the Norwich
Urban Area within the settlement hierarchy. Within Costessey, there is a diverse range of services
and facilities including a primary school, secondary school, food stores, doctor’s surgery and
pharmacy, all within walking distance of the Site. The Site benefits from being in close proximity to
a high quality, frequent bus service which provides at least four buses an hour into the centre of
Norwich in less than 20 minutes. Norwich Railway Station is located approximately five miles from
the Site and provides frequent direct services to a number of locations including Ipswich, London
and Cambridge.
2.1.2 The preferred option for the distribution of development to focus growth around Norwich as well
as the within the Cambridge Norwich Tech Corridor is supported by Gladman. This corridor holds
significant potential for economic growth over the plan period and will hold a key role in securing
the economic ambitions of the emerging Plan, particularly in delivering identified job targets. The
concentration of housing in this corridor will help secure a sustainable distribution of development
over the plan period and support economic growth.
2.1.3 Norwich is established as the pre-eminent regional centre for the East of England and as such the
city accommodates the majority of the jobs, key services and economic, leisure and cultural facilities
to serve the majority of Norfolk and parts of North Suffolk. It is therefore appropriate that the
Norwich Urban Area, including Costessey, forms the location for the largest concentration of
development over the plan period (inclusive of the proposed contingency). The Plan’s approach in
this regard is therefore justified.

Comment

Representation ID: 22458

Received: 16/03/2020

Respondent: Gladman Developments

2.2 Policy 3: Environmental Protection and Enhancement (Question 21)
2.2.1 Gladman has some concern with the proposed approach taken by Policy 3 towards development
proposals within Green Infrastructure Corridors illustrated in Map 8 of the draft Plan. Map 8
represents a high-level assessment of Green Infrastructure across the County with limited regard to
more detailed site data and functionality. For example, Gladman’s land interest at Long Lane,
Costessey is shown to be included within the Green Infrastructure Corridor which aligns with the
western edge of Norwich. Despite this designation, there have been planning applications
approved within the identified Green Infrastructure Corridors, including the land to the north of the
Site at Lodge Farm.
2.2.2 Taking this into account, it is unclear on what basis Policy 3 seeks to protect the Green Infrastructure
Corridors identified in Map 8 given that in some cases evidence of these corridors on the ground is
limited. Gladman considers that the focus of Policy 3 in relation to Green Infrastructure should be
to secure environmental benefits at the planning application stage to enhance the quality and extent of the corridors with the aim of securing the functionality and extent of the Green
Infrastructure corridors shown on Map 8 in the longer term. In this sense, contributions towards
Green Infrastructure corridors made by development proposals in the area should be considered a
planning benefit.
2.2.3 Should wording on protection of Green Infrastructure corridors be retained in the policy, Gladman
considers that further evidence is needed to set out what elements of the Green Infrastructure
corridors need to be protected and for what reason. It should also be set to a greater level of detail
what is meant by the term “effective management of development in accordance with the policies
of the development plan”. Gladman would be resistant to a policy approach which would refuse
development affecting a Green Infrastructure corridor where evidence shows limited
environmental site value and/or the proposed development could lead to enhancements in Green
Infrastructure.