Draft Greater Norwich Local Plan – Part 1 The Strategy

Q14: At present, the growth strategy is very strongly based on the vast majority of housing growth (69%) taking place in the Norwich Urban Area. There may be a question as to whether the housing market can support such a high proportion of new housing being concentrated in this area. We note and agree with the total housing provision being a minimum figure of 44,340 new homes.
In respect of the housing commitments presented under Policy 1, we wish to query the figure of 4,024 homes attributed to village clusters. At present, there is no South Norfolk Village Clusters Housing Site Allocations document and therefore it is not possible to consider whether the above figure is achievable or suitable. This document should be published simultaneously with the Greater Norwich Local Plan or indeed, preferably, be combined with it.
We do not understand the approach to contingency sites set out in paragraph 162. The specific contingency at Costessey raises a number of questions:
• Why is Costessey the preferred location for a contingency site? This does not appear to be explained in the Strategy;
• What is the basis of the figure of 1,000 dwellings? and
• What is meant by ‘low delivery of allocated housing sites’ and how will this be measured? Additional clarification is required as to how this policy approach would be monitored.
We do agree that Wymondham is a suitable location for a contingency site and in our response to Document 2: Sites Plan we have set out suggestions for potentially accommodating a part of this contingency.

We agree with the proposed settlement hierarchy and broadly agree with the distribution of housing within that hierarchy.
In particular, we support the identification of Wymondham as one of the main towns and it is clear that Wymondham is by far the largest of the five main towns. Given the geography of the areas in which the five main towns are located then there is an argument for a greater proportion of the total housing growth to be steered to those five towns. The wording in Policy 1 specifically refers to Hethersett (which is not a main town but a key service centre) and Wymondham alongside the Norwich urban area which highlights the importance of these two rural settlements.

We support the identification of land at Browick Interchange, Wymondham as a strategic employment location. The potential economic growth associated with this site is important and supports the concept of additional housing growth at Wymondham.

Future review of local plan – although we note that NPPF requires reviews at least every five years we would expect such a review to be initiated 2-3 years after adoption.

The approach set out in draft Policy 1 is somewhat vague in simply stating that the growth strategy will be supported by infrastructure improvements. We would suggest that more specific commitments are required in this policy or cross reference to other policy proposals.

Q18: We have one comment on Policy 2 in respect of the preferred approach to sustainable communities. This relates to Item iii of the policy which sets out means of assisting the broad-based approach of the policy.
Item iii states that ‘delivery plans are required with planning applications for 100 dwellings plus ….’. It is far from clear what is meant by a ‘delivery plan’ and the requirement ignores the fact that planning applications are frequently promoted by individuals, landowners, institutions or promotional companies rather than housebuilders. Such applicants sell their land on to housebuilders following the granting of permission and therefore have no control over the timing or actual delivery of development. In addition, planning applications for sites of 100+ dwellings will generally take some time to be determined and will require S106 Agreements, so it is somewhat unrealistic to require detailed delivery plans (such as timetables) at the time of an application submission.

We support the approach to the provision of affordable housing.

Q32: generally, we support the idea of an element of self-build plots. Typically, due to market demand, these need to be reasonably generous sized plots providing scope for larger detached dwellings. We are of the view that there is a relationship between housing mix and the potential for self-build. For example, if the Local Planning Authority insists on, say, semi-detached dwellings on a site, then the ability to deliver self-build plots may be severely hampered.
We are unsure as to the basis of the stated threshold of 40 dwelling developments and request that this is further justified in the next version of the Local Plan.

Q41: we broadly support the overall approach to housing for the Main Towns as set out under Policy 7.2. Specifically, we agree that, of the 5 Main Towns, Wymondham should accommodate the greatest proportion of the overall housing growth being directed to the Main Towns. Although there is a considerable level of existing deliverable commitments at Wymondham, we do feel that the town is capable of further growth within this plan given its location within the Cambridge-Norwich corridor, the available transport links, its existing service base and its growing employment sector. We also support the employment allocation in Wymondham although, over the longer term, there may well be a case for additional employment land.

Q42: Elsewhere (Q13 under Policy 1) we have queried the basis of the 1,000 dwelling contingency identified for Wymondham. Three comments arise:
• The fact that Wymondham has been identified for this possible contingency suggests that there is an acceptance that this settlement is capable of accommodating further growth. We support that view;
• We do believe that there is scope for accommodating some further housing development at Wymondham within this plan which would reduce the contingency figure and therefore provide a greater degree of certainty for all parties through increased land allocations; and
• It is unclear how the Local Planning Authority will monitor or measure whether ‘delivery of housing in the GNLP area does not meet local plan targets ‘. In addition, if the contingency is triggered by low delivery rates in the GNLP area – how might the allocation of suitable land be achieved i.e. what is the statutory mechanism for facilitating such a contingency? The approach set out for this contingency provides little certainty for residents, landowners, service organisations or statutory undertakers planning future service provision.