Draft Greater Norwich Local Plan – Part 1 The Strategy

The objective of delivering high quality homes that contribute to the delivery of mixed, inclusive, resilient and sustainable communities that are supported by appropriate economic and social infrastructure is fully supported. The approach is fully consistent with the National Planning Policy Framework.

The requirement that sites should only be allocated for housing where, having regard to policy requirements, there is a reasonable prospect that housing can be delivered fully accords with para 67 of the NPPF.
Whilst the submission of Delivery Plans as part of a planning application is supported the documents need to recognise that there may be unforeseen material changes in circumstances, which could impact the delivery of an allocation.
The Council’s approach to providing choice and flexibility in terms of housing growth by accommodating 9% more homes than are needed, along with contingency sites, is, in principle, supported.
This buffer will help maintain the supply and delivery of housing, in accordance with the NPPF and specifically the Government’s objective of encouraging authorities to consider more growth than required to meet local housing need, particularly in locations where there is potential for significant economic growth, such as the Cambridge Norwich Tech Corridor.
However, to guard against non-delivery, particularly in relation to the potential failure of larger strategic sites in the Norwich urban area to come forward, a minimum buffer of 10% should be identified. Indeed, the draft GNLP states on page 45 that the Regulation 19 version of the Plan will aim to provide a minimum buffer of 10% (at least 250 further homes), which is likely to be provided through a combination of additional sites proposed through the consultation, and the contingency sites.
This approach will provide certainty for stakeholders, including the public, and ensure that the plan is sufficiently flexible to enable it to respond to changing circumstances.
Based on the foregoing, it is recommended that the contingency locations are upgraded to committed sites. The identification of contingency sites provides ambiguity as to when and where development may be located. This uncertainty has the potential to undermine the ability to ensure that development during the plan period is delivered in a coordinated manner. More specifically, the potential for Wymondham to be required to accommodate between 100 and 1,100 units provides significant uncertainty, making it difficult for stakeholders, such as Norfolk County Council Education, to identify a clear strategy in relation to infrastructure provision.
This is particularly relevant given the under delivery of housing in the Greater Norwich Area between 2011 and 2019, which in locations such as Wymondham has resulted in unplanned and uncoordinated development.
The identification of the Norwich Urban Area and Main Towns, such as Wymondham, as suitable locations for the majority of growth within the Greater Norwich Urban Area, given that they provide a range of services and amenities is supported. For example, Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth. However, within these locations, clear evidence needs to be provided to demonstrate that there is a realistic prospect of development being delivered on the sites, particularly the large strategic allocations which are classed as existing commitments, but are yet to be delivered.

Whilst there is support, in principle, for the proposed approach to infrastructure, particularly the need for key stakeholders to work collaboratively, the Delivery Statement should make it clear that infrastructure requirements will be proportionate to each development and based on clear assessments of need. Failure to do this will result in certain developments being financially unviable and, therefore, undeliverable.

The proposed Settlement Hierarchy is, in principle, supported. It is recognised that The Norwich Urban Area and Main Towns, such as Wymondham, provide a range of services and amenities and are, therefore, the most sustainable and suitable locations for the majority of growth within the Greater Norwich Urban Area.
Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth in accordance with the identified settlement hierarchy.
Whilst the principle of identifying the Norwich urban area as the focus for most of the identified housing growth is supported, the ability of existing allocations / commitments, as well as certain new allocations, to deliver the scale of growth forecast is, without the provision of clear evidence demonstrating the delivery of certain sites in accordance with criteria contained within the NPPF, questioned. This is highlighted by the fact that the draft Local Plan states at various locations that there is uncertainty regarding the delivery of 1,200 dwellings at the Carrow Works site in Norwich.
With specific regard to existing allocations and commitments, the reliance on certain strategic sites is questioned. More specifically, North Rackheath has, in part, been allocated since 2010 and was initially earmarked for delivery in the 2010-2011 Annual Monitoring Report (AMR) during 2013/2014. Since this initial allocation, the scale of growth forecast for North Rackheath has been increased to 3,000 units (Reference GT:16). However, development is yet to start on site. The latest AMR (2018/19) now envisages that development will commence on site in 2022/23. This demonstrate a considerable delay in the delivery of the site and questions whether, in accordance with the draft GNLP Delivery Statement, it can be considered to represent a site where there is a reasonable prospect of delivery.
Similarly, the Beeston Park allocation, which is forecast to deliver 3,520 homes has, since its first inclusion in an AMR in 2013/14, been delayed by 4 years.
On this basis, there is considerable doubt as to whether there is clear evidence that large strategic sites that are identified as ‘existing deliverable commitments’ can be relied on. Similarly, there is, as acknowledged by the draft Local Plan and detailed above, doubt as to whether certain strategic allocations within the Norwich Urban Area, notably Carrow Works (1,200 units), can be delivered.
In addition, whilst the concept of village extensions is, in principle, supported, we would, based on the evidence provided to date, question the ability of a minimum of 1,200 dwellings to be delivered within South Norfolk Village Clusters.
As we understand, South Norfolk Council are preparing a South Norfolk Village Cluster Site Allocations Document. The need to prepare this document has arisen as a result of the previous Regulation 18 consultation stages into the draft Greater Norwich Local Plan not identifying the choice of sites in the village clusters that would address the requirements in those settlements. (See paragraph 2.1 of South Norfolk Village Clusters Allocations Document – Site Assessment Process and Draft Timetable, Agenda Item 5, Regulation & Planning Policy Committee, 18th February 2020.)
The scale of development focused in the village clusters will range from 12 units up to 1 hectare i.e. 20-25 homes. Based on the 48 village clusters identified in Appendix 1 of the above referenced document, it will mean that each cluster has to accommodate the maximum number of units i.e 25, if the minimum of 1,200 units within South Norfolk village clusters is to be provided.
Given that the identified village clusters are, partly due to their rural location, likely to present a range of issues relating to constraints i.e. utilities, flood risk, suitable access, and impact i.e. landscape and biodiversity, it is difficult, particularly without the provision of clear evidence, to see how the scale of growth directed to the South Norfolk village clusters can be justified. In addition, given the scale of the developments in the villages clusters i.e. a maximum of 25 units, they will not be of a sufficient scale to ensure the provision of social and community infrastructure.
On this basis, we suggest that the quantum of growth directed to both the Norwich urban area and the village clusters in South Norfolk cannot, without the provision of clear evidence relating to delivery, be relied on. Accordingly, a suitable proportion of this housing growth should be reallocated to alternative settlements within the settlement hierarchy, which are capable of demonstrating that they can deliver housing growth; specifically the allocation of sites that would otherwise classed as contingency sites.

See comments made in relation to Question 13 on behalf of Welbeck Strategic Land III LLP

The proposed review of the plan 5 years after adoption is fully consistent with paragraph 33 of the NPPF. In addition, we agree that, given the joint approach to the preparation of the draft GNLP, the assessment of 5 year land supply should continue to cover all 3 administrative areas.

Support, with comments
The need to support sustainable growth through the provision of infrastructure improvements, such as schools and health centres, is, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on a local need and not undermine delivery.
When considering infrastructure, consideration should be given to whether it is unviable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. schools and health centres, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan. The potential for infrastructure costs which are specific to larger strategic sites to be secured by Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the delivery of the infrastructure, should be explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change. To demonstrate the ability to secure these objectives, the preparation of a Sustainability Statement as part of an application for a major development is supported. The use of master planning for the delivery of larger strategic sites, in conjunction with community engagement, and provision of Delivery plans is also supported.
Whilst the requirement to ensure the efficient use of land by, amongst other things, providing an indicative minimum density of 25 dwellings per hectare, is supported, the policy, or supporting text, should make it clear that, as well as giving consideration to on site characteristics, consideration will be given to a range of other site / scheme specific issues, such as housing mix, design considerations and the densities of the surrounding area.

Comments
Clarification is required as to the extent of education contributions likely to be required.
Paragraph 229 states that “if a new development is likely to generate enough children to fill a new school, Norfolk County Council asks developers for the full cost of building that school.” However, the paragraph goes onto state that “with the current CIL approach locally, only land can be secured through a S106 agreement and the build cost of the new school is claimed through CIL.”
From discussions with NCC Education and the GNLP it is understood that when a new School is required the situation will remain as existing i.e. the developer will be expected to provide the land for the School, with the construction being funded through CIL. If this position has changed, it will have significant implications for viability.
The flexibility provided in relation to provision of new schools (para 231), ensuring that they are only provided as and when they are required is fully supported.
As detailed in comments made to Question 17, when considering infrastructure, consideration should be given to whether it is unviable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. schools and health centres, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan. The potential for infrastructure costs which are specific to larger strategic sites to be secured by Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the delivery of the infrastructure, should be explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).

Support, with comments
The need to support sustainable growth through the provision of infrastructure improvements is, such as schools and health centres, in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on a local need and not undermine delivery.
As detailed in comments made to Question 17 and 25, when considering infrastructure, consideration should be given to whether it is unviable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. schools and health centres, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan. The potential for infrastructure costs which are specific to larger strategic sites to be secured by Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the delivery of the infrastructure, should be explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).