Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22224

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

As a start point, we broadly agree with the classification of settlements within the hierarchy itself. In particular we are pleased to acknowledge that Aylsham is identified as one of the principle settlements of the plan area, falling on the second tier of the hierarchy as a ‘Main Town’ and comprising a location for growth that is second only to Norwich itself in terms of importance.

We do, however, have concerns in respect of the proposed distribution of growth. In particular we are concerned about the continued reliance placed on strategic sites within the Norwich urban area as well as the proportionally significant level of growth to be directed towards South Norfolk’s Village Clusters.

The strategic sites issue is pertinent due to the chronic under-delivery of existing large allocations adjacent to and within the Norwich urban area, a matter which by Norwich City Council’s own admittance must be acknowledged by the plan1. The 2018/19 monitoring year was the first since the start of the Joint Core Strategy (JCS) plan period to see delivery in the Norwich Policy Area (NPA) meet its annual housing requirement. Otherwise, growth in the NPA took around 10 years to gather pace with exceptionally slow delivery in the first eight years of the plan period, as shown in the table below:

Table 1: Annual and cumulative delivery in the NPA since the adoption of the JCS Year Requirement Delivery Surplus / Deficit (cumulative) [see covering letter for table]


This lag in delivery during the early years of the plan is representative of the significant lead in times associated with large-scale strategic sites and stands to be replicated once again in the event that the reliance on large sites in and around the Norwich urban area is maintained by the GNLP.
The level of growth to then be directed to South Norfolk’s rural area raises two separate concerns. The first relates to the current complete lack of evidence assessing to the availability and deliverability of sites across the smaller villages of the district. The absence of such evidence means that the direction of such a high proportion of growth towards South Norfolk’s village network – currently proposed at 1,200 homes or 15.5% of all residual growth – represents a strategy that is neither justified nor even demonstrably deliverable. The second concern is that such a high level of growth in the rural area is entirely unsustainable (by comparison the main town tier, the second highest tier of the hierarchy comprising the most sustainable non-urban settlements, is only proposed to receive 50 more homes than South Norfolk’s villages).

To avoid further issues in respect of deliverability (a concern relating to the levels of growth directed towards both the Norwich urban area and South Norfolk villages tiers) whilst ensuring development is directed to sustainable locations, it is our clear view that a higher proportion of the housing requirement should be directed to deliverable sites at the Main Towns. Aylsham in particular represents a sustainable settlement with at least three medium-scale deliverable housing options (we consider our client’s site to be principle amongst them – see Annex 1) that would provide a significant contribution towards the growth needed across Greater Norwich. As it stands, and in light of these concerns, we recommend that the current proposed distribution of growth should be recast to reflect the suitability of the Main Towns. Resultantly, this tier of the hierarchy should receive a notably increased level of growth.

Regardless of the current approach to the distribution of growth, and as set out in our response to Question 14 below, it is our view that the proposed housing figure will also require a significantly uplift to account for City Deal and Tech Corridor growth commitments. To ensure the plan successfully allocates a range of additional sustainable and – vitally – deliverable sites that are able to meet an increased need for new homes from the earliest years of the plan period we consider that a large proportion of this additional growth will inevitably need to be met on unconstrained sites at the larger settlements of the hierarchy.

We therefore strongly suggest that the Main Towns should play a prominent role in meeting these additional needs. The identification of deliverable sites at the five Main Towns should be the priority due to the sustainability benefits these settlements offer, allied with their clear capacity to grow. These opportunities should then be complemented by additional sites across the remainder of the hierarchy in instances where it is clear development is deliverable and would result in wider sustainability benefits.

Comment

Representation ID: 22225

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

We have concerns in respect of the housing strategy set by the plan, both in terms of the basic housing target and the way in which these are to be delivered. In short, these concerns relate to the less than aspirational housing figures included in the plan and a failure to recognise the significant growth that an escalation in local job creation will place on the housing market.

Fundamentally we consider that the plan should be doing more to seize on the challenges and opportunities presented by two key economic growth strategies in the region, ensuring that their ambitions can be achieved. Currently the baseline housing need for the plan period 2018-2038 is 40,541 new dwellings representing Greater Norwich’s Local Housing Need (LHN) devised using the government’s Standard Methodology. This approach is in line with the NPPF’s minimum requirements described at paragraph 60 of the Framework.

The plan then proposes to identify sufficient allocations to achieve this requirement plus an additional 10% buffer, required by paragraph 73 of the NPPF to “account for any fluctuation in the market” during the course of the following year. Essentially the plan’s housing requirement comprises close on the bear minimum policy-compliant figure required by the NPPF and certainly does little to recognise additional known factors that will no doubt influence the demand for new homes across the plan area.

Indeed, Planning Practice Guidance (PPG) reaffirms that the standard method provides a minimum starting point in determining the number of homes needed in an area and that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. The PPG then advises that circumstances where setting a higher housing requirement may be appropriate would include the following two scenarios:

•
“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); (and)
•
strategic infrastructure improvements that are likely to drive an increase in the homes needed locally…”


Both of these factors are in play in respect of the GNLP.

Firstly, the ongoing Greater Norwich City Deal includes the commitment of the Greater Norwich Growth Board to secure significant infrastructure funding totalling £440 million along with the delivery of 3,000 additional homes at the city by 2026. Whilst it is recognised that the development requirements of the Deal have been facilitated in part by the allocation of 3,000 additional homes in the adopted Growth Triangle Area Action Plan (GTAAP) the delivery of these strategic housing sites has been slow. To this end the emerging GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal prior to 2026 to make up for any shortfall in new jobs and housing.

It does not, however, appear that the plan has grasped this opportunity. Indeed, Norwich City Council in its report to its Sustainable Development Panel on 15th January 2020, raises identical concerns, stating that “the level of growth proposed in the GNLP is considered insufficient to address the growth needs of Greater Norwich as a whole and the Norwich Urban Area in particular, and lacks the ambition express ed through the previous Joint Core Strategy and the Greater Norwich City Deal” .

Secondly, it is vital that the GNLP responds to the ambitions of the Cambridge Norwich Tech Corridor (CNTC), the vision of which seeks to attract 26,000 additional jobs and 46,000 further residents to the corridor prior to 2031. At this stage it is apparent that, whilst the CNTC proposals would be hugely positive for the city area, they currently represent what is still little more than an aspirational programme for growth with limited delivery mechanisms in place. This is where the GNLP must play a major role in making the CNTC vision a reality.

To the plan’s credit it is noted that the spatial distribution of growth included in the draft strategy orientates a high proportion of the plan area’s homes towards the corridor. What is a concern, however, is that the overall housing target for the plan fails to recognise that the CNTC proposals, and the significant investment and jobs growth that will hopefully come with them, will likely result in an increased housing demand above and beyond the baseline requirement calculated using the Government’s Standard Methodology. The strategy of skewing the delivery of new homes which are already required to meet the needs of the local population towards the corridor to satisfy the CNTC’s aspiration does not represent a positive planning response. Instead this will simply create an imbalance in housing delivery across the plan area.

One of the options put forward in the previous Regulation 18 GNLP consultation in March 2018 was to provide an additional uplift in the housing requirement to take account of the City Deal. However, this approach was discounted as it was considered that the uplift applied built into the LHN figure (i.e. that proposed to tackle local issues in respect of affordability) was sufficient swell to accommodate the demands of the City Deal. Assessment of this approach did not even consider the additional implications of the CNTC. We were strong advocates of the City Deal uplift then – little has changed to lead us to alter this view. To simply maintain a figure close to the basic LHN as the need housing figure for the plan demonstrates a critical misunderstanding of the way in which the figure is calculated. Indeed, the absence of an appropriate uplift fails to reflect the fact that the standard method is a ‘policy off’ calculation of the housing requirement and any adjustments required to due to ‘policy on’ decisions (i.e. to sign a City Deal) should be factored in further.

Indeed, we note that the SHMA published in April 2017 identifies that the jobs growth facilitated by the City Deal would likely result in a demand for approximately 8,361 new homes above and beyond those required as a result of general demographic change over the period until 2036. Even when deducting the 3,000 dwellings planned for in the GTAAP this results in an additional requirement of 5,361 homes that appear not to have been considered when setting the GNLP housing requirement.

On this basis we consider that the OAN proposed by the plan falls short of adequately responding to local demand by an approximate 5,4002 homes. This is before the additional demand generated by the CNTC is taken into account. In which case the absolute minimum housing requirement for the GNLP should be somewhere in the region of 46,0003 dwellings before any NPPF paragraph 73 buffer is applied. In which case it is our view that upon the application of the appropriate buffer the GNLP should be planning for somewhere between 48,300 and 50,6004 dwellings as a minimum based on the demand generated by the City Deal alone. In addition, we would urge officers to undertake the work necessary to quantify the impact of the CNTC – the draw of the Corridor will inevitably result in the eventual housing figure rising further.

Comment

Representation ID: 22226

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

To reiterate our response to Question 13 we have concerns in respect of the comparatively low level of growth that is to be directed towards the Main Towns, a tier of the settlement hierarchy that historically yields sites that benefit from ease of delivery whilst lying in demonstrably sustainable locations. It must be remembered that the five main towns form the second highest tier in the settlement hierarchy and represent the most sustainable locations for new homes away from the Norwich urban area yet are allocated just 14.5% of total proposed growth over the plan period. It is a concern that the current strategy appears to somewhat arbitrarily constrain growth at these settlements and fails to take full advantage of the combination of deliverable sites, high levels of service provision and strong infrastructure connections present at each town.

Officers will note that our responses towards the earlier stages of the GNLP concluded that the Main Towns should realistically be expected to accommodate a far greater level of growth than currently, approximately 2,750 new dwellings across the tier. This results in an average figure of 550 homes per settlement, albeit it is acknowledged that some of the towns have a greater capacity to grow than others. In respect of Aylsham specifically our response to the Growth Options Consultation in March 2018 concluded that, due to the high levels of sustainability and accessibility it offers allied with the availability of suitable and deliverable housing sites, it would not be unreasonable to direct approximately 750-1,000 new homes towards the town. Our views in this respect remain unaltered. However, it is apparent from the ‘Housing’ table included as part of Policy 7.2 of the ‘Draft Strategy’ document that the total proposed housing to be allocated at Aylsham over the plan period falls well below this figure at only 300. In terms of cumulative growth (including existing commitments) the level of delivery at Aylsham would be the lowest of the five settlements comprising the Main Town tier. This is despite Aylsham comprising the fourth largest settlement in the plan area allied with a range of demonstrably deliverable and highly accessible sites at the town. It is also set to receive a lower level of allocated growth than both Diss and Harleston.

Indeed, Aylsham is described at paragraph 312 of the GNLP as having a good range of shops and services as well as strong transport links to Norwich. Meanwhile, Harleston (which is to receive a greater level of growth both by way of allocation and cumulatively over the plan period) is characterised as having shops and transport links designed to meet a localised catchment only. To this end the level of growth now proposed at Aylsham appears disproportionately low when the sustainability of the town and its capacity to meet the wider needs of the Greater Norwich area are both considered.

It is also noted that Anglian Water now has plans to increase capacity at the Aylsham water recycling centre, an infrastructure constraint that has held back the town’s ability to grow in recent times. Indeed, the January 2018 consultation document identified the capacity of the local water treatment capacity as the only real brake limiting the growth of the town. Otherwise the same document describes Aylsham as a town benefitting from strong market interest, thus demonstrably enhancing the case that sites at the town are attractive and deliverable. It is therefore our view that there is no good reason to arbitrarily limit the growth of Aylsham in the event that sustainable and deliverable sites at the town can be identified.

On this basis we are pleased to reiterate, and indeed reinforce, the availability of our client Westmere Homes’ land at North East Aylsham (site reference GNLP0336). This represents one of three sites that we understand officers consider to comprise suitable locations for the delivery of approximately 300 dwellings at the town. In fact, it is our clear view that our client’s site – currently identified within the evidence base of the GNLP as a reasonable alternative – represents by far the most suitable site for the delivery of meaningful growth at Aylsham. Additional evidence describing the deliverability, suitability and overall sustainability of the site is included at Annex 1 of this letter.

Regardless, on the basis of our analysis set out above we consider that there is a compelling case for more than one site to come forward at the town with a view to delivering far in excess of the 300 dwellings currently proposed by the GNLP.

Comment

Representation ID: 22227

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

To reiterate our response to Question 13 we have concerns in respect of the comparatively low level of growth that is to be directed towards the Main Towns, a tier of the settlement hierarchy that historically yields sites that benefit from ease of delivery whilst lying in demonstrably sustainable locations. It must be remembered that the five main towns form the second highest tier in the settlement hierarchy and represent the most sustainable locations for new homes away from the Norwich urban area yet are allocated just 14.5% of total proposed growth over the plan period. It is a concern that the current strategy appears to somewhat arbitrarily constrain growth at these settlements and fails to take full advantage of the combination of deliverable sites, high levels of service provision and strong infrastructure connections present at each town.

Officers will note that our responses towards the earlier stages of the GNLP concluded that the Main Towns should realistically be expected to accommodate a far greater level of growth than currently, approximately 2,750 new dwellings across the tier. This results in an average figure of 550 homes per settlement, albeit it is acknowledged that some of the towns have a greater capacity to grow than others. In respect of Aylsham specifically our response to the Growth Options Consultation in March 2018 concluded that, due to the high levels of sustainability and accessibility it offers allied with the availability of suitable and deliverable housing sites, it would not be unreasonable to direct approximately 750-1,000 new homes towards the town. Our views in this respect remain unaltered. However, it is apparent from the ‘Housing’ table included as part of Policy 7.2 of the ‘Draft Strategy’ document that the total proposed housing to be allocated at Aylsham over the plan period falls well below this figure at only 300. In terms of cumulative growth (including existing commitments) the level of delivery at Aylsham would be the lowest of the five settlements comprising the Main Town tier. This is despite Aylsham comprising the fourth largest settlement in the plan area allied with a range of demonstrably deliverable and highly accessible sites at the town. It is also set to receive a lower level of allocated growth than both Diss and Harleston.

Indeed, Aylsham is described at paragraph 312 of the GNLP as having a good range of shops and services as well as strong transport links to Norwich. Meanwhile, Harleston (which is to receive a greater level of growth both by way of allocation and cumulatively over the plan period) is characterised as having shops and transport links designed to meet a localised catchment only. To this end the level of growth now proposed at Aylsham appears disproportionately low when the sustainability of the town and its capacity to meet the wider needs of the Greater Norwich area are both considered.

It is also noted that Anglian Water now has plans to increase capacity at the Aylsham water recycling centre, an infrastructure constraint that has held back the town’s ability to grow in recent times. Indeed, the January 2018 consultation document identified the capacity of the local water treatment capacity as the only real brake limiting the growth of the town. Otherwise the same document describes Aylsham as a town benefitting from strong market interest, thus demonstrably enhancing the case that sites at the town are attractive and deliverable. It is therefore our view that there is no good reason to arbitrarily limit the growth of Aylsham in the event that sustainable and deliverable sites at the town can be identified.

On this basis we are pleased to reiterate, and indeed reinforce, the availability of our client Westmere Homes’ land at North East Aylsham (site reference GNLP0336). This represents one of three sites that we understand officers consider to comprise suitable locations for the delivery of approximately 300 dwellings at the town. In fact, it is our clear view that our client’s site – currently identified within the evidence base of the GNLP as a reasonable alternative – represents by far the most suitable site for the delivery of meaningful growth at Aylsham. Additional evidence describing the deliverability, suitability and overall sustainability of the site is included at Annex 1 of this letter.

Regardless, on the basis of our analysis set out above we consider that there is a compelling case for more than one site to come forward at the town with a view to delivering far in excess of the 300 dwellings currently proposed by the GNLP.

Comment

Representation ID: 22228

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

Consistent with our views set out above we consider that the GNLP should seek to take an evidence-based approach towards the identification of the capacity of every settlement across the plan area to accommodate growth. Where sites are identified that are both deliverable and can enhance the sustainability of a settlement through the delivery of a proportionate number of new homes they should be identified as allocations in the plan. This process should be indivisible from the exercise undertaken to inform the spatial distribution of growth across the plan area.

We are pleased to see that such an evidence-led process has been closely observed in directing growth towards the Village Cluster tier across Broadland. The profile of each cluster across the district provided as part of the evidence base of the plan takes a clear stepped approach to identifying site allocations. This is done by firstly identifying the capacity that exists in the local community infrastructure; then considering whether there are any additional development constraints applicable to the village or cluster; and finally through an assessment of whether appropriate sites exist within each cluster to deliver an appropriate level of growth up to the level of capacity offered by the local primary school in particular.

This process has resulted in the identification of proposed allocations at 10 of the 25 Village Clusters across Broadland. Of these, five of the clusters have been allocated between 10-20 dwellings, eight will receive between 20-40 dwellings and two will host a range of 40-60 dwellings. This identification of suitable sites has then informed the level of growth to be directed towards Broadland’s network of clusters – stated as 480 dwellings.

Whilst Hainford / Stratton Strawless represents one of the 10 Village Clusters not proposed to receive any growth we are pleased to confirm that our client’s proposal at Harvest Close, Hainford (site reference GNLP2162) is now able to overcome the single principle constraint at the village that led to the current decision not to direct growth towards the cluster. Our client’s revised proposals are explained in detail at Annex 2. Importantly, as the housing figure for the Village Cluster tier has been formulated though a ‘bottom-up’ approach (that is, through the identification of suitable sites rather than by way of an arbitrary apportionment of growth) it is clear that additional sites can be identified at this tier without conflicting with the GNLP’s spatial strategy.

By comparison, the approach proposed in respect of South Norfolk’s Village Clusters is far from evidence based and, in contrast to the methodology applied at Broadland, seeks to prescribe the network an arbitrary growth figure of 1,200 dwellings. The draft GNLP then indicates that allocations to meet this requirement across South Norfolk’s villages will be identified in a separate plan to be produced by South Norfolk District Council at a later date. This strategy is speculative and uncertain in nature and risks placing an onerous requirement on South Norfolk to allocate sites that are either undeliverable or unsustainable – or potentially both. Put simply, there is no evidence currently available to suggest that the district’s villages comprise sites that can appropriately accommodate what is a strategic level of new growth.

This approach significantly undermines strategic approach to delivery in these settlements and cannot be considered to be in accordance with paragraphs 17 – 22 of the NPPF which make clear that strategic policies should provide a clear strategy for bringing sufficient land forward to address objectively assessed needs over the plan period. The scale of growth that must be delivered through the district’s Village Clusters plan (1,200 homes, representative of almost 15% of all new allocations across the Greater Norwich area) is clearly of strategic importance in the context of the GNLP.

To defer the identification and allocation of sites to meet such a significant level of growth to a future plan without an assessment of the ability of the villages it covers to accommodate new homes is clearly a flawed approach. We consider that in order to accord with the NPPF, allocations in the village clusters must be brought back into the GNLP and based on a thorough assessment of need and capacity. In turn, this may (and arguably should) result in the redirection of a proportion of this growth either towards Broadland’s village network or more suitably to higher tiers of the hierarchy.

Comment

Representation ID: 22229

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

Our clients, Westmere Homes Ltd and Saltcarr Farms Ltd, jointly have an interest in land at Harvest Close, Hainford (GNLP2162). Upon review of the Site Assessment booklet for Hainford is without dispute that our clients’ land represents the most sustainable and appropriate location for residential development at the village. It is clear, however, that any growth at the village is considered to be constrained by poor pedestrian access to the local primary school, a facility which is considered to represent the core of the Hainford / Stratton Strawless Village Cluster.

On this basis we are pleased to conclude that, following further analysis of how this constraint may be mitigated, our client’s proposals now include a significantly enhanced pedestrian route providing safe access from both the
Response to GNLP ‘Draft Strategy’ Joint response on behalf of Westmere Homes Ltd and Saltcarr Farms Ltd March 2020
8
site and the wider village to the school. This upgrade in connectivity would represent a clear sustainability benefit that would help the village realise its potential to accommodate the 40-60 dwellings identified in the Village Cluster background paper. It would also ensure that best use is made of the capacity that currently exists on the primary school’s student role5.
The way in which this enhanced pedestrian link would be secured, along with an updated analysis of our clients’ site, is set out at Annex 2.