Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22459

Received: 16/03/2020

Respondent: Gladman Developments

2.3 Policy 7.1 The Norwich Urban Area including the fringe parishes
(Question 40)
2.3.1 Gladman welcomes the proposals made under Policy 7.1 for the Norwich Urban Area and the fringe
parishes to continue being the area’s major focus for jobs, homes and services development and
welcomes the further allocations proposed in the city in addition to the existing commitments.
2.3.2 The policy identifies the delivery of a total of 30,560 new homes over the plan period 2018-2038
within the Norwich Urban Area, of which 85% consists of already committed development.
2.3.3 Gladman notes the proposals to include the site GNLP0581, in addition to site GNLP2043, as a
contingency site with a capacity of 1,000 homes, with associated amenity land, woodland and green
area, to be brought forward if the delivery of the GNLP housing allocations does not meet the Local
Plan targets.
2.3.4 It is however considered that this additional 1,000 dwellings should be planned for now, in the form
of a further allocation in the Plan, rather than being identified as a contingency. Such an approach
would increase the flexibility of the Local Plan and heighten its durability against unpredicted
changes which might occur over the remaining years of the plan. The plan making process provides
a good opportunity for the infrastructure requirements of Costessey and any future development
to be understood with a solution planned for. Planning for this upfront would reduce any delay in
meeting housing needs, which may not be possible through the planning application process.

Comment

Representation ID: 22463

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 Wymondham as a Main Town within the settlement hierarchy. Wymondham is home to a diverse range of services and facilities inclusive of primary school and secondary school provision, food store, doctor’s surgery, pharmacy, and community centre. The town benefits from rail connections to Norwich and Cambridge, and from high quality bus links to Norwich. As such, the settlement forms a sustainable and logical location for new development.
2.1.2 It is noted by Gladman that Option 3 (supporting the Cambridge to Norwich Tech Corridor) has been selected by the Councils as the basis for the spatial strategy of the Local Plan. 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 The location of Wymondham in the heart of this strategic corridor means that the town will and should play an important role in fulfilling this economic potential over the plan period with further employment and housing land required. Wymondham therefore forms one of the most appropriate location within the plan area at which to concentrate development over the plan period (inclusive of the proposed contingency). The Plan’s proposed approach in this regard is therefore justified.

Comment

Representation ID: 22464

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 broad brushed 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 Norwich Common, Wymondham is shown to be partially included within the Green Infrastructure corridor aligning to the A11, despite the Site showing limited evidence of ecological value as shown by technical reports produced as part of the current planning application.
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, with areas within these which important to ecological conservation subject to protection through formal designation.
2.2.3 Gladman consider that the focus of Policy 3 in relation to Green Infrastructure should be to secure environmental benefits at the planning application stage which are important to the enhancement of the quality and extent of Green Infrastructure corridors. This is in 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.
2.2.4 Should wording on protection of Green Infrastructure corridors be retained in the policy, Gladman consider that further evidence is needed to set out what elements of the Green Infrastructure corridors need to be protected and for what reason. The meaning of “effective management of development in accordance with the policies of the development plan” in terms of impacts for planning applications and decision making should also be clarified. 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 to the integrity and value of Green Infrastructure.

Comment

Representation ID: 22465

Received: 16/03/2020

Respondent: Gladman Developments

2.3 Policy 7.2 Main Towns
Allocations at Wymondham
2.3.1 Gladman welcome proposals made under Policy 7.2 for further growth to be allocated at Wymondham in addition to existing commitments. It is however considered that the 100 dwellings planned for through the Draft GNLP at Wymondham 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. The level of new growth to be directed to the settlement should be substantially increased.
2.3.2 In Wymondham, committed development accounts for 96% of the total growth requirements of the Local Plan over the period 2018-2038. The emerging GNLP therefore does very little to influence the strategy of the town, with policies to have limited effect in directing where, how and in what form development takes place in the town.
2.3.3 The effects of this are twofold. Firstly, growth in the town will not respond to the latest evidence base of need. For example, as drafted, the Plan will fail to respond to the housing needs of the elderly with no allocations for elderly accommodation, and little scope provided for elderly appropriate accommodation through the 100 dwellings allocated in Wymondham through the draft GNLP. Secondly, the GNLP does nothing to respond to the town’s location within the A11 tech corridor, and therefore fails to make the most of this opportunity, rendering it ineffective in this regard, and potentially harming the achievement of planned economic growth in the wider plan area.
2.3.4 Gladman notes the proposal to identify 1,000 dwellings worth of contingency in Wymondham to respond to unmet housing need. Noting the size of the Wymondham, its sustainability, and location as part of the Tech Corridor, Gladman consider that Wymondham forms one of the most appropriate locations within the plan area at which to address any housing shortfall and/or provide additional flexibility to respond to plan targets.
2.3.5 It is however considered that this additional growth should be planned for now, in the form further housing allocations in the Plan, rather than offset to a later date. Such an approach would increase the flexibility of housing land supply provided within the GNLP and heighten its durability against unpredicted changes which might occur over the plan period. Allocating land for a further 1,000 dwellings in the Plan would also address comments made above regarding the effectiveness of the GNLP in addressing the needs of Wymondham itself, as well as broader housing need. The plan making process provides a good opportunity for the infrastructure requirements of Wymondham and any future development to be understood with a solution planned for. Planning for this upfront would reduce any delay in meeting housing needs, which may not be possible through the planning application process.
Strategic Gaps
2.3.6 Gladman consider that strategic gaps should be reviewed and revised through the plan making process of the Greater Norwich Plan. As currently defined, the extent of the strategic gaps potentially forms an unnecessary constraint to development within the plan area, preventing the development of otherwise sustainable sites for development through the GNLP. Since defined and last reviewed the context for each strategic gap is likely to have altered considering more recent development changing the nature of the strategic gap and changing the need to retain land within this designation to fulfil its purpose.
2.3.7 Evidence of this is clear in the case of the strategic gap currently defined between Wymondham and Hethersett. In recent years the character of land at the north eastern edge of Wymondham along Norwich Common has significantly altered with new housing and employment development along the north of this road which has served to urbanise this area.
2.3.8 In response to this, Gladman commissioned FPCR to undertake an assessment of the Strategic Gap to consider how land included within this designation functions as an important part of the identified gap. This evidence (provided in Appendix 2) concludes:
 The gateway into Wymondham from the East is formed by Elm Farm Business Park. This is the most eastern extent of Wymondham;
 The B1172 (Norwich Common) represents the only visual receptor for the gap, given general absence of public footpaths and obscured views on the A11;
 Inter-visibility along the B1172 is however limited given intervening vegetation and built development;
 The settlement pattern in Wymondham has recently altered from a nucleated settlement following recent development in the north east of the town; and  There is a limited degree of openness within the strategic gap between Wymondham and Hethersett owing to existing intervening vegetation and built development.
2.3.9 Taking the above into account FPCR conclude that by maintaining the current minimum width of the Strategic Gap it is unlikely that further development will compromise inter-visibility, physical separation or perceived openness, with opportunities available to mitigate adverse effects on openness.
2.3.10 On account of this evidence, Gladman believe there is clear justification to revise the extent of the Strategic Gap defined at the edge of Wyondham to exclude land south of Norwich Common from within the gap to provide a new boundary defined at the entrance of the town provided at Elm Farm Business Park. Further commentary is provided within section 3 of this representation about how the land being promoted by Gladman at Norwich Common, Wymondham could be developed whilst safeguarding the integrity of the wider strategic gap.

Comment

Representation ID: 23151

Received: 16/03/2020

Respondent: Gladman Developments

Duty to Cooperate
3.1.1 The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the
Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The
DtC requires local planning authorities to engage constructively, actively and on an ongoing basis
with neighbouring authorities on cross-boundary strategic issues through the process of ongoing
engagement and collaboration.1
3.1.2 The revised Framework (2019) has introduced a number of significant changes to how local
planning authorities are expected to cooperate including the preparation of Statement(s) of
Common Ground (SOCG) which are required to demonstrate that a plan is based on effective
cooperation and has been based on agreements made by neighbouring authorities where crossboundary
strategic issues are likely to exist. The revised Framework (2019) sets out that local
planning authorities should produce, maintain, and update one or more Statement(s) of Common
Ground (SOCG), throughout the plan making process2. The SOCG(s) should provide a written record
of the progress made by the strategic planning authorities during the process of planning for
strategic cross-boundary matters and will need to demonstrate the measures local authorities have
taken to ensure cross-boundary matters have been considered and what actions are required to
ensure issues are proactively dealt with e.g. unmet housing needs.
3.1.3 As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans
Local Plan examinations, if a Council fails to satisfactorily discharge its DtC, a Planning Inspector
must recommend non-adoption of the Plan. This cannot be rectified through modifications.
3.1.4 It is noted that in Norfolk there is a strong history of cross-boundary cooperation and engagement.
This exists locally with the production of the joint Core Strategy and now GNLP, the Norfolk Spatial
Planning Framework, and work associated with the Anglia LEP. It will be important, in order to meet
legal requirements and the tests of soundness, that this cross-boundary engagement continues
through remaining stages of plan preparation, with evidence of ongoing working and mechanisms
for this to continue beyond adoption of the GNLP.