Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 20360

Received: 27/02/2020

Respondent: Sworders

Number of people: 2

Table 6 sets out the details of Establishing the Plan’s total housing figure. It notes that 7,840 new
homes will be provided on sites proposed to be allocated through the GNLP (6,640) and sites for 1,200
new homes will be identified in the South Norfolk Village Clusters Housing Sites Allocation Plan.
DATE: 14th February 2020
Our ref: RUT2458 219245
gnlp@norfolk.gov.uk
By email:
martin.ranner@sworders.com
11 Holkham Studios
Longlands, Holkham Estate
Wells-next-the-Sea
Norfolk NR23 1SH
T: 01328 854 400
Dear Sir/Madam,
RE: GREATER NORWICH LOCAL PLAN CONSULTATION – LAND OPPOSITE POST OFFICE LANE, WESTON
LONGVILLE, NORWICH, NORFOLK.
Draft reps to GNLP consultation Jan-Feb 2020 Page 2 of 7
Paragraph 162 of the Plan identifies that a contingency site in Costessey could deliver around 1,000
homes and that further sites could be allocated in Wymondham should this prove to be required due
to low delivery of allocated housing sites. We suggest that this approach does not comply with the
guidance in the NPPF which states in paragraph 23 that:
‘Strategic policies should provide a clear strategy for bringing sufficient land forward…. This should
include planning for and allocating sufficient sites to deliver the strategic priorities of the area.’
If there is concern that the Plan’s focus on large sites could result in delays to delivery of housing, this
should be addressed at the Plan making stage by the allocation of further, smaller sites in the villages;
these smaller sites are likely to be more deliverable and such a strategy would provide a greater
degree of certainty of delivery.

Comment

Representation ID: 20361

Received: 27/02/2020

Respondent: Sworders

Number of people: 2

Table 7 sets out the proposed Housing Growth 2018 – 2038. It notes that the Norwich urban area will
see a 29% increase in housing growth, but the village clusters will only experience a 9% increase.
Paragraph 168 of the Plan notes that; ‘a significant proportion of the allocated sites are strategic scale
commitments of 1,000 homes plus’, This reliance on large sites to deliver new homes could result in
delays to the delivery of those homes because of the need for significant infrastructure provision to
be delivered before the homes can be built and occupied.
Paragraph 164.6 of the Plan notes that 12% of the homes allocated through the Plan are on sites of
no larger than 1 hectare and that this complies with paragraph 64 of the NPPF which requires that at
least 10% of sites are no larger than 1 hectare. However, we propose that significantly more growth
should be distributed to smaller sites in this Plan, to off-set the inevitable delays associated with large
scale strategic growth, which forms the majority of the proposed new homes in the Plan.
Distributing a greater proportion of the proposed new homes to smaller sites in and adjacent to the
villages will improve the flexibility of the Plan to respond to changing circumstances, and will help to
ensure a steady delivery of homes to contribute to the five year housing land supply and throughout
the plan period.

Comment

Representation ID: 20362

Received: 27/02/2020

Respondent: Sworders

Number of people: 2

Paragraph 341 states that village clusters are based on primary school catchments, which provide a
proxy for social sustainability. It is accepted that primary school catchments can provide one measure
of social sustainability. However, to base the housing allocation for each village solely on a single
criterion such as the primary school catchments is, we believe, very limiting. The ability of a primary
school to accept children from new developments can only ever provide a snapshot in time of an
Draft reps to GNLP consultation Jan-Feb 2020 Page 3 of 7
ever-changing situation. The amount of housing allocated on the basis of this criterion alone also only
reflects the existing provision and does not take account of the potential of new housing to fund
growth and improvements to the schools, or to any other community facilities, and therefore
potentially stymies future growth and could contribute to a cycle of stagnation or decline.
Paragraph 83 of the NPPF states that:
‘Planning policies should enable …. The retention and development (my underlining) of accessible local
services and community facilities, such as local shops, meeting places, sports venues, open spaces,
cultural buildings, public houses and places of worship.’
We propose that the amount of housing allocated to village clusters is based on a much wider range
of criteria, including the existence and absence of community facilities and services, such as a village
shop, broadband connection, public house etc, and consideration of the role the village plays in
serving other smaller settlements.
As a case in point, despite there being seven distinct settlements within the grouped ‘Village Cluster’
of Great Witchingham, Lenwade, Weston Longville, Alderford, Attlebridge, Little Witchingham and
Morton on the Hill, as the school located within the cluster (Great Witchingham Primary Academy) is
located within Great Witchingham, this limits any housing allocations to Great Witchingham itself.
Consequently, this means the assessment precludes any housing allocations within any of the other
villages that comprise the cluster and, in this sense, the ‘Village Cluster’ concept is an ineffective
designation when determining housing allocations, resulting in limiting housing distribution rather
than ensuring it is distributed and shared across the ‘cluster’.

Object

Representation ID: 20423

Received: 06/03/2020

Respondent: Sworders

Number of people: 2

Table 6 sets out the details of Establishing the Plan’s total housing figure. It notes that 7,840 new
homes will be provided on sites proposed to be allocated through the GNLP (6,640) and sites for 1,200
new homes will be identified in the South Norfolk Village Clusters Housing Sites Allocation Plan.
Paragraph 162 of the Plan identifies that a contingency site in Costessey could deliver around 1,000
homes and that further sites could be allocated in Wymondham should this prove to be required due
to low delivery of allocated housing sites. We suggest that this approach does not comply with the guidance in the NPPF which states in paragraph 23 that:
‘Strategic policies should provide a clear strategy for bringing sufficient land forward…. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.’
If there is concern that the Plan’s focus on large sites could result in delays to delivery of housing, this should be addressed at the Plan making stage by the allocation of further, smaller sites in the villages; these smaller sites are likely to be more deliverable and such a strategy would provide a greater degree of certainty of delivery.

Object

Representation ID: 20424

Received: 06/03/2020

Respondent: Sworders

Number of people: 2

Table 7 sets out the proposed Housing Growth 2018 – 2038. It notes that the Norwich urban area will see a 29% increase in housing growth, but the village clusters will only experience a 9% increase.
Paragraph 168 of the Plan notes that; ‘a significant proportion of the allocated sites are strategic scale commitments of 1,000 homes plus’, This reliance on large sites to deliver new homes could result in delays to the delivery of those homes because of the need for significant infrastructure provision to be delivered before the homes can be built and occupied.
Paragraph 164.6 of the Plan notes that 12% of the homes allocated through the Plan are on sites of no larger than 1 hectare and that this complies with paragraph 64 of the NPPF which requires that at least 10% of sites are no larger than 1 hectare. However, we propose that significantly more growth should be distributed to smaller sites in this Plan, to off-set the inevitable delays associated with large scale strategic growth, which forms the majority of the proposed new homes in the Plan.
Distributing a greater proportion of the proposed new homes to smaller sites in and adjacent to the villages will improve the flexibility of the Plan to respond to changing circumstances, and will help to ensure a steady delivery of homes to contribute to the five year housing land supply and throughout the plan period.

Object

Representation ID: 20425

Received: 06/03/2020

Respondent: Sworders

Number of people: 2

Paragraph 341 states that village clusters are based on primary school catchments, which provide a proxy for social sustainability. It is accepted that primary school catchments can provide one measure of social sustainability. However, to base the housing allocation for each village solely on a single criterion such as the primary school catchments is, we believe, very limiting. The ability of a primary school to accept children from new developments can only ever provide a snapshot in time of an ever-changing situation. The amount of housing allocated on the basis of this criterion alone also only reflects the existing provision and does not take account of the potential of new housing to fund growth and improvements to the schools, or to any other community facilities, and therefore, potentially stymies future growth and could contribute to a cycle of stagnation or decline.
Paragraph 83 of the NPPF states that:
‘Planning policies should enable …. The retention and development (my underlining) of accessible local services and community facilities, such as local shops, meeting places, sports venues, open spaces, cultural buildings, public houses and places of worship.’
We propose that the amount of housing allocated to village clusters is based on a much wider range of criteria, including the existence and absence of community facilities and services, such as a village shop, broadband connection, public house, post office, provision of public transport services, and consideration of the role the village plays in serving other smaller settlements.
We note that paragraph 343 of the Plan states that:
‘A separate South Norfolk Village Clusters Housing Site Allocations document will be produced. This plan will include sites for a minimum of 1,200 homes in addition to the 1,349 already committed in the village clusters to be identified in South Norfolk.’
We welcome the invitation to submit further sites through this consultation, set out in Policy 7.4, although we consider that the invitation to submit further sites should be made much more clearly on the consultation homepage.