Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22405

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Draft Policy 6 ‘The Economy’
3.1 The draft GNLP states that it seeks to support small and medium sized businesses within both urban and rural areas by allocating sufficient employment land and allowing for windfall sites to come forward. However, Policy 6 ‘The Economy’, as drafted does not provide a flexible policy basis to accommodate the needs not anticipated by the Local Plan or to enable the expansion of existing small and medium size employment sites across of the GNLP area. Policy 6, as drafted therefore does not align with the NPPF or adopted Joint Core Strategy Policy 5 ‘The Economy’ and it is requested that the policy is amended to allow for the expansion of existing small and medium sized employment sites, such as the Abbey Farm Commercial Park site.
3.2 Paragraph 116 of the GNLP explains that the role of smaller scale employment sites in the urban area, market towns and villages will help to deliver good access to jobs for all. To promote the delivery of jobs, Section 4 of the GNLP explains that the draft plan provides choice and flexibility by providing for a wide range of type and size of employment sites. In terms of smaller scale and rural employment sites, Section 4 explains that such sites will be supported in accessible and sustainable locations.
3.3 Policy 1 outlines the Local Plans sustainable growth strategy and the supporting text to this policy explains at paragraph 151 that the plan allocates employment sites totalling around 360 hectares. Paragraph 155 explains that the Plan also allocates land and allows for additional windfall delivery of smaller scale sites to provide for jobs growth elsewhere in the urban area, towns and villages, providing local job opportunities and supporting small-scale businesses and a vibrant rural economy.
3.4 Whilst Policy 6 as drafted recognises the needs of small, medium and start-up businesses and explains that this will be addressed through the allocation and retention of smaller scale employment sites across the area, the policy as drafted does not allow for the expansion of existing small and medium sized sites.
3.5 Policy 5 ‘The Economy’ of the Joint Core Strategy specifically addressed the needs of small and medium sized businesses within the policy by allowing for the expansion of existing small and medium sized employment sites. We consider that this part of Policy 5 should be carried forward into draft Policy 6 of the GNLP.
3.6 By allowing existing employment sites to expand, this would enable existing businesses to grow and meet their evolving requirements on site rather than relocate, potentially out of the GNLP area. Paragraph 80 of the NPPF states planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Paragraph 81 goes on to state that policies should be flexible enough to accommodate needs not anticipated in the plan and to enable a rapid response to changes in economic circumstances.
3.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows: 2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.

Comment

Representation ID: 22406

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Draft Policy 6 ‘The Economy’
3.1 The draft GNLP states that it seeks to support small and medium sized businesses within both urban and rural areas by allocating sufficient employment land and allowing for windfall sites to come forward. However, Policy 6 ‘The Economy’, as drafted does not provide a flexible policy basis to accommodate the needs not anticipated by the Local Plan or to enable the expansion of existing small and medium size employment sites across of the GNLP area. Policy 6, as drafted therefore does not align with the NPPF or adopted Joint Core Strategy Policy 5 ‘The Economy’ and it is requested that the policy is amended to allow for the expansion of existing small and medium sized employment sites, such as the Abbey Farm Commercial Park site.
3.2 Paragraph 116 of the GNLP explains that the role of smaller scale employment sites in the urban area, market towns and villages will help to deliver good access to jobs for all. To promote the delivery of jobs, Section 4 of the GNLP explains that the draft plan provides choice and flexibility by providing for a wide range of type and size of employment sites. In terms of smaller scale and rural employment sites, Section 4 explains that such sites will be supported in accessible and sustainable locations.
3.3 Policy 1 outlines the Local Plans sustainable growth strategy and the supporting text to this policy explains at paragraph 151 that the plan allocates employment sites totalling around 360 hectares. Paragraph 155 explains that the Plan also allocates land and allows for additional windfall delivery of smaller scale sites to provide for jobs growth elsewhere in the urban area, towns and villages, providing local job opportunities and supporting small-scale businesses and a vibrant rural economy.
3.4 Whilst Policy 6 as drafted recognises the needs of small, medium and start-up businesses and explains that this will be addressed through the allocation and retention of smaller scale employment sites across the area, the policy as drafted does not allow for the expansion of existing small and medium sized sites.
3.5 Policy 5 ‘The Economy’ of the Joint Core Strategy specifically addressed the needs of small and medium sized businesses within the policy by allowing for the expansion of existing small and medium sized employment sites. We consider that this part of Policy 5 should be carried forward into draft Policy 6 of the GNLP.
3.6 By allowing existing employment sites to expand, this would enable existing businesses to grow and meet their evolving requirements on site rather than relocate, potentially out of the GNLP area. Paragraph 80 of the NPPF states planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Paragraph 81 goes on to state that policies should be flexible enough to accommodate needs not anticipated in the plan and to enable a rapid response to changes in economic circumstances.
3.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows: 2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.

Comment

Representation ID: 22407

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Draft Policy 6 ‘The Economy’
3.1 The draft GNLP states that it seeks to support small and medium sized businesses within both urban and rural areas by allocating sufficient employment land and allowing for windfall sites to come forward. However, Policy 6 ‘The Economy’, as drafted does not provide a flexible policy basis to accommodate the needs not anticipated by the Local Plan or to enable the expansion of existing small and medium size employment sites across of the GNLP area. Policy 6, as drafted therefore does not align with the NPPF or adopted Joint Core Strategy Policy 5 ‘The Economy’ and it is requested that the policy is amended to allow for the expansion of existing small and medium sized employment sites, such as the Abbey Farm Commercial Park site.
3.2 Paragraph 116 of the GNLP explains that the role of smaller scale employment sites in the urban area, market towns and villages will help to deliver good access to jobs for all. To promote the delivery of jobs, Section 4 of the GNLP explains that the draft plan provides choice and flexibility by providing for a wide range of type and size of employment sites. In terms of smaller scale and rural employment sites, Section 4 explains that such sites will be supported in accessible and sustainable locations.
3.3 Policy 1 outlines the Local Plans sustainable growth strategy and the supporting text to this policy explains at paragraph 151 that the plan allocates employment sites totalling around 360 hectares. Paragraph 155 explains that the Plan also allocates land and allows for additional windfall delivery of smaller scale sites to provide for jobs growth elsewhere in the urban area, towns and villages, providing local job opportunities and supporting small-scale businesses and a vibrant rural economy.
3.4 Whilst Policy 6 as drafted recognises the needs of small, medium and start-up businesses and explains that this will be addressed through the allocation and retention of smaller scale employment sites across the area, the policy as drafted does not allow for the expansion of existing small and medium sized sites.
3.5 Policy 5 ‘The Economy’ of the Joint Core Strategy specifically addressed the needs of small and medium sized businesses within the policy by allowing for the expansion of existing small and medium sized employment sites. We consider that this part of Policy 5 should be carried forward into draft Policy 6 of the GNLP.
3.6 By allowing existing employment sites to expand, this would enable existing businesses to grow and meet their evolving requirements on site rather than relocate, potentially out of the GNLP area. Paragraph 80 of the NPPF states planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Paragraph 81 goes on to state that policies should be flexible enough to accommodate needs not anticipated in the plan and to enable a rapid response to changes in economic circumstances.
3.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows: 2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.

Comment

Representation ID: 22408

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Draft Policy 6 ‘The Economy’
3.1 The draft GNLP states that it seeks to support small and medium sized businesses within both urban and rural areas by allocating sufficient employment land and allowing for windfall sites to come forward. However, Policy 6 ‘The Economy’, as drafted does not provide a flexible policy basis to accommodate the needs not anticipated by the Local Plan or to enable the expansion of existing small and medium size employment sites across of the GNLP area. Policy 6, as drafted therefore does not align with the NPPF or adopted Joint Core Strategy Policy 5 ‘The Economy’ and it is requested that the policy is amended to allow for the expansion of existing small and medium sized employment sites, such as the Abbey Farm Commercial Park site.
3.2 Paragraph 116 of the GNLP explains that the role of smaller scale employment sites in the urban area, market towns and villages will help to deliver good access to jobs for all. To promote the delivery of jobs, Section 4 of the GNLP explains that the draft plan provides choice and flexibility by providing for a wide range of type and size of employment sites. In terms of smaller scale and rural employment sites, Section 4 explains that such sites will be supported in accessible and sustainable locations.
3.3 Policy 1 outlines the Local Plans sustainable growth strategy and the supporting text to this policy explains at paragraph 151 that the plan allocates employment sites totalling around 360 hectares. Paragraph 155 explains that the Plan also allocates land and allows for additional windfall delivery of smaller scale sites to provide for jobs growth elsewhere in the urban area, towns and villages, providing local job opportunities and supporting small-scale businesses and a vibrant rural economy.
3.4 Whilst Policy 6 as drafted recognises the needs of small, medium and start-up businesses and explains that this will be addressed through the allocation and retention of smaller scale employment sites across the area, the policy as drafted does not allow for the expansion of existing small and medium sized sites.
3.5 Policy 5 ‘The Economy’ of the Joint Core Strategy specifically addressed the needs of small and medium sized businesses within the policy by allowing for the expansion of existing small and medium sized employment sites. We consider that this part of Policy 5 should be carried forward into draft Policy 6 of the GNLP.
3.6 By allowing existing employment sites to expand, this would enable existing businesses to grow and meet their evolving requirements on site rather than relocate, potentially out of the GNLP area. Paragraph 80 of the NPPF states planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Paragraph 81 goes on to state that policies should be flexible enough to accommodate needs not anticipated in the plan and to enable a rapid response to changes in economic circumstances.
3.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows: 2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.

Comment

Representation ID: 22409

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Draft Policy 7.4 ‘Village Clusters’
3.8 Horsham and Newton St Faith are identified as village cluster 17 with the GNLP consultation. Policy 7.4 ‘Village Clusters’ includes a table that sets out allocated employment areas within all the village clusters. The existing employment allocation (site reference HNF3) land West of Abbey Farm Commercial Park is not included within this table. Given that the site is allocated, and is proposed to be carried forward as an employment allocation in the GNLP, and the site owners intend to submit a planning application this Spring for its development for employment use, we request that the site is included in the Table.
3.9 As well as identifying specific allocated employment sites, Policy 7.4 states “other small-scale employment development will be acceptable in principle elsewhere within village development boundaries or through the re-use of rural buildings”.
3.10 We consider that the policy as drafted is not flexible enough to meet the changing requirements of businesses or facilitate development not anticipated by the Local Plan within rural areas. We therefore request that the policy is amended to allow for the expansion of small and medium sized employment sites. This change would align with national policy within the NPPF that requires policies to be flexible enough to enable businesses to expand and adapt.
3.11 With the above national policy context in mind, we consider draft Policy 7.4 is not flexible enough to meet the changing requirements of businesses and request that the penultimate paragraph of Policy 7.4 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that the penultimate paragraph of Policy 7.4 is amended as follows: • Other small-scale employment development will be acceptable in principle elsewhere within village development boundaries or through the re-use of rural buildings or through the potential expansion of existing small and medium sized employment sites (LPP suggested text) subject to meeting other policies in the development plan.

Comment

Representation ID: 22410

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Draft Policy 7.4 ‘Village Clusters’
3.8 Horsham and Newton St Faith are identified as village cluster 17 with the GNLP consultation. Policy 7.4 ‘Village Clusters’ includes a table that sets out allocated employment areas within all the village clusters. The existing employment allocation (site reference HNF3) land West of Abbey Farm Commercial Park is not included within this table. Given that the site is allocated, and is proposed to be carried forward as an employment allocation in the GNLP, and the site owners intend to submit a planning application this Spring for its development for employment use, we request that the site is included in the Table.
3.9 As well as identifying specific allocated employment sites, Policy 7.4 states “other small-scale employment development will be acceptable in principle elsewhere within village development boundaries or through the re-use of rural buildings”.
3.10 We consider that the policy as drafted is not flexible enough to meet the changing requirements of businesses or facilitate development not anticipated by the Local Plan within rural areas. We therefore request that the policy is amended to allow for the expansion of small and medium sized employment sites. This change would align with national policy within the NPPF that requires policies to be flexible enough to enable businesses to expand and adapt.
3.11 With the above national policy context in mind, we consider draft Policy 7.4 is not flexible enough to meet the changing requirements of businesses and request that the penultimate paragraph of Policy 7.4 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that the penultimate paragraph of Policy 7.4 is amended as follows: • Other small-scale employment development will be acceptable in principle elsewhere within village development boundaries or through the re-use of rural buildings or through the potential expansion of existing small and medium sized employment sites (LPP suggested text) subject to meeting other policies in the development plan.

Comment

Representation ID: 22411

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Question 6 - Do you support or object to the vision and objectives for Greater Norwich?
4.2 The site owners support the vision and objectives for the Greater Norwich Area with regards to the economy as they recognise the role that smaller scale employment sites have in helping to deliver good access to jobs for all. However, the role that smaller scale employment sites across the area will play in delivering jobs should be recognised within Policy 6 ‘The Economy’, and a flexible policy approach should be adopted that allows for the appropriate expansion of existing small and medium size employment sites to meet needs not anticipated by the Local Plan and businesses changing requirements.
4.3 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:
2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.

Comment

Representation ID: 22414

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Question 10 - Do you support, object, or have any comments relating to the approach to Economic Development set out in the Delivery Statement?
4.4 The site owners do not support the approach to economic development with regards to existing small and medium sized employment sites. Section 3 sets out the reasons why Policy 6 ‘The Economy’ requires amending because as drafted, it does not align with the vision and objectives of the GNLP or the NPPF - Section 6 ‘Building a Strong and Competitive Economy’. It is therefore requested that Policy 6 is amended to allow for the expansion of small and medium sized employment sites.
4.5 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:
2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.

Comment

Representation ID: 22415

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Question 15 - Do you support, object or wish to comment on the approach for the Economy?
4.6 As explained above, the site owners do not support the Plan’s approach to the economy with regards to existing small and medium size employment sites. Section 3 sets out the reasons why Policy 6 ‘The Economy’ requires amending. It is therefore, requested that Policy 6 is amended to allow for the expansion of small and medium sized employment sites.
4.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:
2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.
Question 34 - Do you support, object or have any comments relating to the approach to employment land?
4.8 As explained above, the site owners do not support the approach to employment land with regards to existing small and medium size employment sites. Section 3 sets out the reasons why Policy 6 ‘The Economy’ requires amending. It is therefore, requested that Policy 6 is amended to allow for the expansion of small and medium sized employment sites.
4.9 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:
2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.
Question 46 - Do you support or object or wish to comment on the approach for specific Village Clusters?
4.10 The site owners do not support the approach to Village Clusters as drafted within Policy 7.4 for the reasons set out in Section 3. It is requested that the policy is amended to include the existing employment allocation (site reference HNF3) land West of Abbey Farm Commercial Park within the policy. It is also requested that the text is amended to allow for the expansion of small and medium sized employment sites. We therefore request that the penultimate paragraph of Policy 7.4 is amended as follows: • Other small-scale employment development will be acceptable in principle elsewhere within village development boundaries or through the re-use of rural buildings or through the potential expansion of existing small and medium sized employment sites (LPP suggested text) subject to meeting other policies in the development plan.