Draft Greater Norwich Local Plan – Part 1 The Strategy

No justification or viability information has been provided to support the increase from 28% to 33% affordable housing within the draft plan. The 28% figure was confirmed through the 2017 SHMA and we are not aware that there has been any update to the SHMA, or any other evidence that would support this change. Unless there is compelling new evidence to support the increase to 33%, then the requirement should remain at 28% in line with the latest SHMA.

The term “at least” should be removed from the policy prior to each percentage requirement as this does not provide the necessary certainty for developers. Affordable housing policies should not be seeking to establish requirements as minimums.

Lanpro object to Student accommodation schemes being asked to provide a commuted sum equivalent to the amount of affordable housing that would be expected if the site was developed for general needs housing. This will be very difficult to accurately assess without an alternative housing scheme being drawn up to take into account individual site constraints and viability and market factors. What will be the mechanism for agreeing this? It is too simplistic to consider doing it on a site area basis and is likely to delay schemes coming forward and potentially affect viability.

Student housing is meeting a particular identified housing need in its own right as evidenced by Norwich City Council’s Student Accommodation Need Assessment.

The policy requires C3 accommodation for older people to provide on-site affordable housing and this provides insufficient flexibility. Such affordable housing provision has proven to be incompatible with managed sheltered housing developments as housing providers are often unwilling to take on such units. We are concerned that the policy would stifle delivery of sheltered housing accommodation. Such an approach conflicts with the positive approach towards housing delivery contained within the NPPF and as such is unsound. Accommodation for older people should not be required to provide onsite provision for affordable housing and should instead be required to provide a commuted sum in lieu of provision. The policy should be amended accordingly.

Please see our answers to questions 23 and 24 setting out our concerns regarding the delivery of infrastructure to meet the needs of small rural cluster village sites. Our conclusion is that dispersal to small rural cluster villages outside of the old NPA area is not sustainable.

Please see our response to question 27.

Instead of having a requirement for at least 5% of plots on residential schemes over 40 dwellings to provide serviced self/custom build plots we suggest that a policy approach similar to that in the South Northamptonshire Local Plan (which has gone through examination but is not yet adopted) should be pursued. This offers a more flexible approach that is more appropriate to the custom build market.

It allows for small scale self-build sites immediately adjoining the confines of defined villages to be approved, rather than requiring them to be provided on allocated land. A similar policy could be drafted based upon the Greater Norwich development hierarchy. The South Northamptonshire Policy reads as follows:

1. Proposals for single self or custom build sites immediately adjoining the confines of Rural Service Centres, Primary, Secondary (A and B) and Small Villages as defined in policy SS1 of this plan will normally be permitted where they help to meet demand as demonstrated by Part 1 of the Council’s Self and Custom Housebuilding Register and is compliant with other policies of this plan.

2. Proposals for two or more self or custom build sites immediately adjoining the confines of Rural Service Centres, Primary, Secondary (A) as defined in policy SS1 of this plan will normally be permitted where they help to meet demand as demonstrated by Part 1 of the Council’s Self and Custom Housebuilding Register and is compliant with other policies of this plan.

3. Housebuilders occupying a self or custom build dwelling will be required to demonstrate a local connection.

4. Reserved matters planning applications for custom build plots will need to be made by the intended occupier.

5. Proposals for custom and self-build dwellings will be controlled by the following means:
a) Developments of 10 or more custom build dwellings in a single site location are supported by a design code; and
b) Where plots have been made available and marketed and have not sold the Council will consider proposals for the development of housing in accordance with policy LH8 and LH10 where:
I) they have been actively marketed for self/custom build for at least 12 months; and
II) prior to the application being made they have been offered to the Council, a housing association or the town/parish council for the delivery of affordable housing products.

Please read in conjunction with our response to question 15.

The commitment in paragraph 5 of the draft plan to “build on our strengths” and particularly “to help turn our world class knowledge and ideas into world class jobs, particularly in sciences and biotechnology, agri tech, food and drink, information and communication technology (ICT), digital creative industries and high-value engineering” is supported.

The draft plan also sets out that it “will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor” (paragraph 108).

It also seeks to:
“strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” (Delivery Statement page 36).

Lanpro’s concern is whether these commitments will be achieved through the preferred growth strategy and particularly whether the allocations for housing and employment are adequate and in the right place to achieve this goal.

In terms of employment, it is notable that only 0.8 ha of new land is to be allocated in addition to the available 20 hectares of employment land at Hethel within the Cambridge Norwich Tech Corridor. No new allocations are made anywhere else within the corridor.

Lanpro consider that the allocation of additional employment land linked to the first phase of a new settlement at Hethel would provide a tangible commitment to delivering on the stated vision and objectives set out above.

In addition, land at Harford (GNLP0497), also within the Hi-Tech corridor should be allocated to ensure a healthy supply of viable sustainably located employment sites that will help the plan to meet its objectives for jobs growth.

The plan allocates employment sites totalling around 360 hectares including land on the strategic sites referred to above.

Notably, at paragraph 3.44 of the GVA 2017 report. It states:
“The Norwich urban area extends beyond the city centre, accommodating a diverse array of economic activity within its various business parks, industrial estates and specialist facilities. Often these sites make a distinct offer to businesses which, given the scale of each, is likely to direct the future nature of activity and development. As such infill, intensification and redevelopment of the existing estates will act as important locations for a range of activities, however, may offer few options to diversify the existing portfolio.” (Our underlining)
Norfolk County Council’s Employment Land Monitoring Report 2018-2019[1], states that whilst there may be in excess of 400 hectares of monitored employment land (‘monitored land’ is land without planning permission) there are only 48.4 hectares of employment land with outline planning permission across the County. Clearly, in itself, land with outline planning permission can be speculative in nature.

In summary, we submit, that the emerging GNLP will be reliant upon an employment land supply that is not flexible or diverse enough; that is not ambitious enough; is made up of key sites which either have infrastructure constraints to delivery, or have other environmental constraints to expansion; and as such the emerging GNLP plan will conflict with the NPPF and is unsound.

The approach to East Norwich is supported. This is a key area of the City Centre that will benefit from regeneration and can support an attractive new community area for the city. The inclusion of sustainable energy generation is only supported if the type and scale of generation is compatible with achieving a healthy and attractive environment for the proposed new residential community and does not compromise air quality or amenity standards for residents.

In the absence of any evidence regarding delivery to support existing commitments, Lanpro are concerned about the reliance in the draft plan on the delivery of 13,430 homes in the Growth Triangle to 2038. Delivery of homes on key parts of the Growth Triangle has been very slow to progress since planning permission was granted.

Despite the plan’s emphasis in its vision (page 31) and delivery statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes are allocated within the Tech Corridor itself: at Wymondham. By contrast, 400 are proposed in Diss which is neither within the Strategic Growth Area, the Cambridge Norwich Tech corridor, or close enough to Norwich to benefit from higher order services.

It is recognised that towns like Diss and Aylsham can accommodate some additional housing growth and do offer their own job opportunities and service provision. However, this should not take precedent over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Cambridge Norwich Tech corridor. Therefore, it is proposed that numbers in Diss should be halved to 200 and numbers in Harleston, which is also well outside of the Tech corridor, should be reduced to 150. The displaced 500 homes should be relocated within the Tech Corridor/ Strategic Growth Area.

See our answer to question 41.

Key Service Centres are identified under draft Policy 1 of the Regulation 18 Stage C Consultation Document as a third-tier settlement, with growth proposed to these areas after the ‘Norwich Urban Area’, and the ‘Main Towns’.

Despite their position in the hierarchy, only 515 new homes are proposed to come forward through new allocations within all nine Key Service Centres. This compares to a minimum of 1,680 homes that are proposed to come forward in the lower (fourth) tier, ‘Village Clusters’.

Whilst Lanpro recognise the benefits to be delivered to the vitality of rural areas through allocating some new sites and thus increasing footfall within small village locations, it is considered both unsustainable and inappropriate to apportion a greater amount of growth to these areas than to the higher order Key Service Centres which it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.

With specific reference to draft Policy 7.3 of the Regulation 18, Stage C Consultation Document, Lanpro object to the Council’s decision not to allocate any additional sites for residential development within the Poringland / Framinghams area, which is sustainably located within the old NPA. This decision appears to be neither justified or positively prepared, nor to have been sufficiently tested and is therefore considered ‘unsound’.