Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22841

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

We note that the introduction includes:
"14. Transport priorities which influence the GNLP are set out in several other strategies including: the Norfolk Local Transport Plan; the Norwich Area Transportation Strategy; the emerging Transport for Norwich strategy and Transforming Cities. These are in addition to national and regional rail and road investment strategies and programmes."

The Norfolk Local Transport Plan and the Transport for Norwich strategy are both currently in the early stages of review, with no published drafts. The current Norfolk Local Transport Plan was published in 2011, and the Norwich Area Transportation Strategy was adopted in 2004 (with Implementation Plan update in 2013). Given the age of these documents, we suggest they have reduced influence on the transport priorities of the GNLP, especially when considering the additional emphasis that has been placed on sustainable transport in recent years and the technological and social changes which have resulted in modal shift. In order to future-proof the transport priorities of the GNLP, it is considered to be essential that the evidence base relied upon is up-to-date, or that contingencies are ensconced within the GNLP. We therefore anticipate commenting further within the GNLP process once these documents are published as part of the wider evidence base.

Comment

Representation ID: 22842

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Paragraph 54 of the Draft Plan states:
“Greater Norwich is key to the region's economy with considerable potential for growth in world class knowledge intensive jobs. Strategic employment sites and competitive land and business lets, mainly those in and around the Norwich and Wymondham area, support a globally significant growth axis within the Cambridge Norwich Tech Corridor.”

The Greater Norwich economy includes life-sciences, agri-tech, IT, leisure and culture, and retail. The Greater Norwich City Deal 2013 focusses on science, technology and advanced manufacturing. Paragraph 60 of the Draft Plan notes that “Rural enterprises are important to the local economy and home working is increasing in significance. The proportion of micro-businesses employing up to nine people is above the national average in Broadland and South Norfolk.”

We consider that whilst the GNLP emphasises the growth of hi-tech and food-tech industries, it has not addressed the low-tech sector. Whilst rural businesses are acknowledged as important to the local economy, we are concerned that this acknowledgement is not translated into policy later in the GNLP. We discuss this further, later in this representation.

Norwich City Centre has largest concentration of employment in Greater Norwich and is a focus for further employment growth. Paragraph 78 of the Draft Plan notes that successful modal shift has already been achieved through previous Transport for Norwich programme, with a 375,000 increase in Norwich bus journeys. This requires building on, with further improvement of the Park and Ride network which will allow capacity to rise in line with demand as more journeys switch to bus and as the growth strategy comes to fruition. The Draft Plan is constrained by a lack of detail on the Transport for Norwich review. This will include the Park and Ride network. We are promoting the Loddon P&R site, located on the only major transport route into Norwich without P&R facilities, as part of the solution to ongoing strategies to achieve sustainable transport and modal shift.

Object

Representation ID: 22843

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Transport modal shift is supported, however, it is not considered that the GNLP currently provides enough detail or methods on how this vision is to be achieved, particularly in terms of the infrastructure improvements. The Draft Plan is constrained by a lack of detail on the Transport for Norwich review. This will include the Park and Ride network. We are promoting the Loddon P&R site, located on the only major transport route into Norwich without P&R facilities, as part of the solution to ongoing strategies to achieve sustainable transport and modal shift.

The support for electric vehicles is encouraging, however detail needs to be provided as to where the charging infrastructure for these electric vehicles is to be located. While new development may be able to provide private charging where viable, this does not cater to the charging of electric vehicles where owners do not have that facility at home or work, and it will take time and incentives for existing development to retro-fit the necessary infrastructure. It is considered that public EV charging stations will be necessary and the proposed Loddon Park & Ride site that we are promoting will allow the opportunity for charging infrastructure to be embedded into that development from the start.

The Vision for Greater Norwich to 2038 includes stimulating economic investment and “the creation of a strong, enterprising, productive and broad-based economy, and the growth of a wide range of economic sectors” (para 113), which we support. “Most of the jobs growth we expect to see will have been delivered on strategic sites in and around Norwich with good access to public transport, the major road network and a comprehensive cycling network.” (para 114). “Parallel to this, the role of smaller scale employment sites elsewhere in the urban area, market towns and villages will help to deliver good access to jobs for all.” (para 116).

As noted above, we are concerned that the need for low-tech employment space has not been translated into policy, which we discuss under Section 5 below. Without that issue being addressed jobs will not be available “for all” as desired by the Vision.

Support

Representation ID: 22844

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

In terms of leisure, the Plan’s vision is noted at paragraph 133: “The development of a multi-functional green infrastructure network will continue across Greater Norwich. This enhanced network will have helped our communities mitigate and adapt to the effects of climate change, by providing for biodiversity gain through improved and linked habitats, reducing flood risk and improving opportunities for active travel and leisure. Improved access to the countryside will have been provided and the quality of our environmental assets will have been enhanced. Visitor pressure on the Broads and other internationally and nationally protected sites will be reduced by new and improved green infrastructure both on and linked to developments, including delivery of the North West Woodland Country Park in Horsford.”

We consider it is important that development and green infrastructure go hand-in-hand. We note that the GNLP proposes significant new development to the East and South-East of Norwich, in the vicinity of the Whitlingham Country Park (WCP). To support the GNLP’s vision for improved opportunities for active travel and leisure, we consider that additional land at WCP, site reference GNLP3052, should be safeguarded for the future delivery of green infrastructure. This relates geographically to the extensive new development proposed by the GNLP to the South and South-East of the City, and would therefore be linked to those developments. It should be supported in addition to the Country Park at Horsford, which is to the North-West of the city. Policies to safeguard the additional land for future country park use will facilitate confidence in investment in the site.

The Plan’s objectives leading from this vision, as they relate to the economy, environment and housing are as follows:
“Economy - To support and promote clean growth and progress towards a post-carbon economy through the expansion of internationally important knowledge-based industries in the Cambridge Norwich Tech Corridor as part of an entrepreneurial, enterprising, creative and broad-based economy with high productivity and a skilled workforce.

“The vision in the draft Local Plan states that future job growth in and around Norwich will happen in locations where there is good access to public transport and the major road network.

“Environment - To protect and enhance the built, natural and historic environments, make best use of natural resources, and to significantly reduce emissions to ensure that Greater Norwich is adapted to climate change and plays a full part in meeting national commitments to achieve net zero greenhouse gas emissions by 2050.

“Homes - To enable delivery of high-quality homes of the right density, size, mix and tenure to meet people's needs throughout their lives and to make efficient use of land.”

We support these objectives, and we comment in Section 5 below on the way they have been translated into policy.

Comment

Representation ID: 22846

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The Delivery Statement for Housing includes that “Additional opportunities will be provided, particularly for small scale growth at villages and on small brownfield sites across Greater Norwich, through windfall development.”

The additional opportunities need to be clarified in relation to small-scale housing at villages and windfall sites. We discuss this further under policy 7.5 below, but raise here that sites on the edges of villages should be encouraged, in order to ensure ongoing vitality and viability of village life whilst not undermining the wider spatial strategy. We consider that arbitrary numeric restrictions on housing should be replaced by policy wording that relates to the character and appearance of the locality of such sites.

Support

Representation ID: 22847

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The Delivery Statement for Economic Development includes that “Smaller scale and rural employment sites are less likely to be constrained by infrastructure requirements and will be supported in accessible and sustainable locations. Together, these varied sites provide for growth of both a broad based and a high value knowledge economy.”

We support this approach. However, “smaller scale” is not defined. We anticipate that the development management policies of each Council will control details of such provision, but it is important in the GNLP that appropriate sites are formally allocated. Without allocation, sites will be classed as countryside, where general development management policies would rule against their use for employment. For example, we are promoting Park Farm as an employment allocation, which will ensure that potential occupiers will be confident in the planning process to secure their use.

The Delivery Statement also refers to a high value knowledge economy, but it must be borne in mind that low value, low-tech uses also play a vital role in the wider economy in terms of jobs that are not knowledge-based. Such employment relies on lower-cost rural sites, as they are priced out of new-build business parks in more central locations.

Support

Representation ID: 22848

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The infrastructure priorities referred to in the Delivery Statement are supported, particularly the reference to the broad intent for a shift to sustainable modes of transport. However as discussed above from the perspective of Park & Rides there is little contained in the Local Plan which substantially moves the situation forward in terms of allocating sites for P&R to meet the increase in demand which will occur if the objectives of the GNLP for modal shift are met.

We are promoting the Loddon P&R site, and will be adding to representations once the review of P&R is published as an evidence base document.

Object

Representation ID: 22849

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Our concern relates to opportunities for windfall developments outside village boundaries. Windfalls are considered by the GNLP to relate to small sites within built-up parts of villages, leaving no positive planning policy support or control over village edge sites. It is important that windfall sites are defined in a way that includes edge of settlement sites, controlled by policies regarding sustainability, accessibility, character and appearance, rather than arbitrary figures. We expand on this under the windfall policy 7.5 below.

Object

Representation ID: 22850

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

We are concerned that the Plan relies on the, yet to be formulated, South Norfolk Village Clusters Housing Sites Allocation document. Without this, there is no evidence that the GNLP’s target numbers can be met, which may well lead to a delay in the GNLP process. Such approach is inconsistent with paragraphs 20 and 23 of the NPPF, which require that Councils make sufficient provision for housing through strategic policies that provide a clear strategy for bringing sufficient land forward.

Despite the representation of housing numbers as a minimum figure, the reality at planning application stage is that sites that have not been allocated will be technically contrary to policy. Additionally, the housing numbers should be sufficient to keep up with additional job numbers, anticipated and indeed promoted by the GNLP to facilitate growth. It is therefore imperative that opportunities to allocate sites for housing are taken. We are promoting land at Octagon Farm for mixed use development, building upon the presence of the business use of the converted Octagon Barn and mindful of the presence of new development on the opposite side of the road and the presence of the site on the edge of Poringland, a high order settlement in the hierarchy which has no proposed new allocations. We consider that this site should be allocated to support sustainable growth.

Object

Representation ID: 22851

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Policy 1 refers to the allocation of smaller scale employment sites within built up areas, but misses the opportunity to support the allocation of sites where the conversion of existing rural buildings would contribute to employment in lower value sectors, where premium locations would prevent such businesses from establishing.