Draft Local Plan-Part 2 Site Allocations

Full Representations makes comments on BRU2, TROW1, Question 27 and Rackheath as well as Aylsham. Check Summaries for submission on these other sites/location or question.

I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.

Aylsham
Norfolk Homes Ltd supports the classification of Aylsham as a Main Town in its settlement hierarchy, the Sustainable Growth Strategy in relation thereto and the identification of the town as a sustainable community able to accommodate additional, significant housing (and related) growth.
In promoting the allocation of our site on Norwich Road, Aylsham, we also wish to highlight that Aylsham is a highly sustainable location capable of accommodating greater, planned growth. The town has all the requisite services, facilities and employment, together with good transport links, sufficient to support sustained housing and associated growth (as set out in the HELAA and related Local Plan evidence).

The merits of further growth in Aylsham are self-evident and indeed referenced in the supporting evidence, namely:
• Aylsham has a vibrant town centre which supports a sizable number of retail and service businesses;
• Access to most of the remainder of the Greater Norwich area and beyond has been improved with the opening of the NDR;
• Local employment opportunities are provided in the town centre and the Dunkirk Industrial Estate to the north-east of Aylsham;
• There exists a good range of services and facilities within the town, including primary and secondary education;
• There are two GP surgeries and a dental surgery in Aylsham, all of which are still accepting patients;
There are a number of recreational opportunities in or near the town including a recreation ground on Sir Williams Lane, a new football facility at Woodgate Farm, the Bure Valley Way, The Marriott's Way and facilities at Blickling Hall.

Indeed, the town has seen continuous and planned housing growth since the early 1990s; it is capable of continuing to accommodate sustainable growth through at least the new Plan period and thereby make an important contribution to the provision of new housing in
a Greater Norwich, above existing commitments and the 300 houses indicated in the draft Local Plan.

Norwich Road, Aylsham (GNLP0596)
We reiterate/clarify the proposed allocation of this site for circa 300 dwellings, access, land for community use (2-hectare primary school site), public open space and associated infrastructure.

We note that in the draft Greater Norwich Local Plan the Norwich Road site is identified as a "Reasonable Alternative", indicating that:
''This site is considered to be a reasonable alternative if additional growth is needed in the towns, subject to mitigation measures. For highways reasons, requirements would include a maximum of 100 dwellings with access from Norwich Road and a2-metre-wide footpath across the site frontage. 250 dwellings would require two points of access, but this would require further investigation as it would not be possible from either Copeman Road or Buxton Road. This site is therefore of secondary preference for allocation in the town."
It is noted that another site is identified as the proposed allocation

GNLP0311, 0595 and 2060: There are a number of similarly performing sites put forward in Aylsham but this combination of sites is favoured for allocation as it is preferred in highway terms as long as two points of access are provided. The site allocation includes a requirement/or a new primary school in Aylsham required to meet growth needs."
In subsequent discussion with officers we have been advised that - in reality - they feel that there is very little between the three sites in question (that identified as the 'Proposed Allocation' and the two sites identified as 'Reasonable Alternatives').
We believe that the summaries above - both the reason for identifying site ref. GNLP0311, 0595 and 2060 ahead of the Norwich Road (0596) site, and for not proposing the allocation of the latter - are based on incorrect information. Specifically:

• Contrary to the above statements, there is no highway constraint to the safe accessing of the Norwich Road site. We have subsequently been advised by Norfolk County Council Highways that the arrangement set out in the attached Indicative Masterplan would make the site's allocation/development acceptable in principle (see attached correspondence). The masterplan shows two points of access via Norwich Road, with a potential emergency access and/or cycle/footpath link only via Buxton Road [Please note that Norfolk Homes Ltd. also has control over the adjacent former motel site (for a primary/secondary access point), and the entirety of the Norwich Road frontage from the just north of the roundabout to the northern extent of the motel site (to accommodate the requisite footpath and other off-site highway improvement works)].
• Contrary to the published HELAA Comparison Table, the site should be identified as
green not amber against the issues of Access to Service, Uilities Capacity/Utilities Infrastructure (see below) and Compatability with Neighbouring Uses.

In particular it should be noted that in meeting and correspondence with Anglian Water it advised us (specifically with reference to the Norwich Road site) that ''Anglian Water can confinn that there is currently capaci.ty at Aylsham Water Recycling Centre to accommodate the 300 dwellings proposed. We closely monitor housing and economic growth in our region to align investment and the operation of our infrastructure to additional demand for used water." In effect, that Anglian Water is able to meet - through infrastructure investment- any additional housing and related demand, and environmental impacts arising therefrom. Water management ought not therefore to be viewed as a constraint to additional housing allocations in Aylsham, and this is acknowledged in the emerging Plan.
With regard to Compatibility with Neighbouring Uses, please note the accompanying Air Quality Assessment and Noise Assessment. The former concludes that air quality impacts are considered to be not significant, in accordance with the IAQM guidance, and that air quality issues are not a constraint to approving development of the site as proposed. The latter - which is of necessity high level, pending assessment of a detailed layout - concludes that some acoustic mitigation would be needed closest to the A140 but that noise levels at the site are generally low enough that non-acoustic glazing and trickle vents can be used across the majority of the site.

The attached plans illustrate in more detail how access is to be achieved, together with related off-site highway improvement works. The plans have been seen by Norfolk County Council and confirmed as acceptable in principle (see attached correspondence).

Furthermore, we are advised by NCC
Education/Children's services that there is a requirement for a 2ha site to allow the building of a new 2FE/ 420 place school. We confirm that we are willing and able to make provision for such on the proposed (Norwich Road, 0596) site, as indicated on the attached Indicative Masterplan, and at any stage of the development required by the County Council.

Our view - therefore - is that the Greater Norwich Development Partnership has made an incorrect assessment of the sustainability/merits/deliverability of the sites considered, in particular those of the Norwich Road site (GNLP0596).

Norfolk Homes has undertaken considerable work with a view to being able to make an early planning application and ensure early delivery of the requisite primary school and housing. To that end I attach copies of the work undertaken to date and which demonstrate that there are no constraints to said development:
• Indicative Masterplan;
• Access Plans (including off-site highway works);
• Tree Survey;
• Air Quality Assessment;
• Noise Assessment;
• Landscape and Visual Impact Assessment;
• Ecology (Habitat Survey completed; species surveys scheduled for March-May 2020 )

Furthermore, Norfolk Homes Ltd. is content to explore - as part of the development proposals for the site - the Town Council's Cittaslow objectives (concerning park and ride) as set out in its 'Aylsham - Shaping the Future' document.
It is clear from the above and attached that the Norwich Road site (GNLP0596) is the best and most sustainable site to meet the growth/housing needs of Aylsham. The evidence hereby submitted demonstrates that the site should therefore be a proposed new allocation rather than a reasonable alternative. It is important to note that this is a view shared by Aylsham Town Council (see below).

In conclusion, Norfolk Hornes has a legal control over all the land in question, and has
undertaken significant work to date to demonstrate the suitability, deliverability and sustainability of the site's development as proposed. The site is available and deliverable in the short term - via a detailed planning application - to assist in meeting the Greater Norwich Local Plan's objective of delivering a sufficient supply of homes in the right locations.

Community Support
Please also note that Aylsham Town Council resolved to respond to the GNLP Local Plan consultation as follows (Minutes of Aylsham Town Council meeting of 19 February 2020):
'The town accepted that one site would need to be accommodated but this must include a primary school and this must be commissioned in the first phase of the project. The affordable housing element must be strictly adhered to. The Town Council would like a transport hub included in the development. The Town Council rejected Burgh Road as the most favourable site and instead would only agree to Norwich Road."

This representation demonstrates not only that the site is available, deliverable and sustainable, but has the support of the local community, a significant consideraion we suggest in determining the most appropriate sites for allocation.

BRU2
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant/developer of the site at Yarmouth Road, Brundall (20180935 and 20190604), identified - in part - under Policy BRU2 of the Draft Local Plan.
The Draft Plan proposes no new allocations in Brundall but to carry forward - from the current Local Plan - sites BRU and BRU3. The former corresponds with Norfolk Homes' outline planning permission (ref. 20180935) and current Reserved Matters submission (ref. 20190604), together with the Parish Council's adjacent formal recreation site south of Yarmouth Road (ref. 20191377). The draft Plan notes:
'The site was allocated in the previous local plan and it is intended to carry this allocation forward, recognising the public benefit in providing informal open space. However, it is likely that the allocation of BRU2 will need further revision given the recent planning permission on the site for 155 dwellings which includes alternative provision for recreation (reference: 20161483). The site was also promoted through the local plan process as GNLP0325. The recreational allocation under BRU2 remains appropriate pending the residential development taking place."
The plan appears to attempt to keep options open - pending what happens on site - but it is our view that the identification/proposed allocation of the entire site for recreational open space - albeit at draft Plan stage - is potentially confusing and contradictory. A large portion of the site has planning permission for 15 5 dwellings ( with Reserved Matters approval pending ) and development will have commenced - anticipated late 2020 - well before the Plan is adopted, thus rendering it immediately out-of-date. We see no difficulty in allocating the formal recreation part of the site with a corresponding permission, but not the permitted housing part.

The Councils might also consider extending the settlement boundary to include that part of the site with permission for housing, again given that its implementation/commencement will pre-date the adoption of the Plan.

TROW1
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the developer of the site at Phase 1, White Horse Lane, Trowse (ref. 2016/0803 and 2016/0805) and the applicant/developer of Phase 2, White Horse Lane, Trowse (ref. 2019/2318), cumulatively identified under Policy TROW1 of the Draft Local Plan.
TROW1 is proposed to be carried forward as a housing allocation but it is noticeable that the wording of TROW1 (between adopted Local Plan and as now proposed) is different in the following way:
The Introduction to the policy is briefer now, but the main change is "approximately 173 dwellings"in lieu of "150 to 160 dwellings".
In the Notes to the policy, it states that the allocated site benefits from planning permission for 173 dwellings. It references Norfolk Homes' Phase 1 permission for 98 dwellings and an undetermined Reserved Matters for 75 dwellings. The latter has been superseded by Norfolk Homes' current full application for 83 dwellings, which is not referenced in the text
Given that Norfolk Homes' current application would increase the cumulative development of the site to 181 dwellings, we would request that:
• The current planning application is acknowledged in supporting text (Notes);
• The policy title refers to "at least 173 dwellings"

Question 27
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.
It is noted that at paragraph 240 of the Draft Local Plan, it states:
"240. The policy sets a general requirement for on-site affordable housing provision of 33% on sites that show better viability based on local evidence, with a lower requirement in Norwich City Centre. This is based on:
o The Strategic Housing Market Assessment 2017 which identifies a need for 11,030 affordable homes in Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point;
o Under national policy, small sites under 10 dwellings are not required to provide affordable housing. Larger sites will therefore have to ensure that overall affordable housing need is delivered;
o The most recent viability study.findings which conclude that centrally located brownfield sites which have higher development costs which affect viability are generally able to provide 28% affordable housing;
o Some specific sites have very high costs associated with development. These are allocated with lower affordable housing requirements."
Within 'Policy 5 -Homes' is included:
"Affordable Housing"
Major residential development proposals and purpose-built student accommodation will provide:

• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a different percentage of affordable housing;
• affordable housing on-site except where exceptional circumstances justify off-site provision;
• a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking account of the most up-to-date local evidence of housing need. This will include 10% of the affordable homes being available for affordable home ownership where this meets local needs;
• affordable housing of at least equivalent quality to the market homes on-site.

The sub-division of a site to avoid affordable housing provision will not be permitted."
This begs the question: if the most up-to-date SHMA identifies a need for 28% affordable housing, why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication -although somewhat disingenuous -is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived 'shortfall' through major housing schemes (10 or more units).
We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the Joint Core Strategy is carried forward into the new Local Plan: 'The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area." (Draft policy 5 only says that "a mix of affordable housing sizes, types, and tenures ... " should reflect the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period - notably since the publication of the 2017 SHMA -and has been reflected in Councils' approaches to decision making thereafter. There now appears to be a marked change in the Councils' approach to an evidentially-based and up-to date proportion of affordable housing, without justification.
The GNDP may feel it has a case to make -other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments -but we cannot find any proper rationalisation in the Draft Local Plan, nor in its supporting evidence, including the Interim Viability Study (November 2019). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period.

Rackheath
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant of the current application of the site off Green Lane West, Rackheath (ref. 20171464).
Whilst acknowledging that the site in question does not as yet having planning permission,
Broadland Council has resolvd to do so (Planning Committee - 10 April 2019). We therefore suggest that - in the interests of completeness, and given that by the time of the next iteration of the Local Plan there will be an extant planning permission for 322 no. dwellings and associated development on the land - an appropriate note should be added to the Plan's supporting text (Notes).
Please let me know if you require any further information or clarification.

Full Representations makes comments on BRU2, TROW1, Question 27 and Rackheath as well as Aylsham. Check Summaries for submission on these other sites/location or question.

I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.

Aylsham
Norfolk Homes Ltd supports the classification of Aylsham as a Main Town in its settlement hierarchy, the Sustainable Growth Strategy in relation thereto and the identification of the town as a sustainable community able to accommodate additional, significant housing (and related) growth.
In promoting the allocation of our site on Norwich Road, Aylsham, we also wish to highlight that Aylsham is a highly sustainable location capable of accommodating greater, planned growth. The town has all the requisite services, facilities and employment, together with good transport links, sufficient to support sustained housing and associated growth (as set out in the HELAA and related Local Plan evidence).

The merits of further growth in Aylsham are self-evident and indeed referenced in the supporting evidence, namely:
• Aylsham has a vibrant town centre which supports a sizable number of retail and service businesses;
• Access to most of the remainder of the Greater Norwich area and beyond has been improved with the opening of the NDR;
• Local employment opportunities are provided in the town centre and the Dunkirk Industrial Estate to the north-east of Aylsham;
• There exists a good range of services and facilities within the town, including primary and secondary education;
• There are two GP surgeries and a dental surgery in Aylsham, all of which are still accepting patients;
There are a number of recreational opportunities in or near the town including a recreation ground on Sir Williams Lane, a new football facility at Woodgate Farm, the Bure Valley Way, The Marriott's Way and facilities at Blickling Hall.

Indeed, the town has seen continuous and planned housing growth since the early 1990s; it is capable of continuing to accommodate sustainable growth through at least the new Plan period and thereby make an important contribution to the provision of new housing in
a Greater Norwich, above existing commitments and the 300 houses indicated in the draft Local Plan.

Norwich Road, Aylsham (GNLP0596)
We reiterate/clarify the proposed allocation of this site for circa 300 dwellings, access, land for community use (2-hectare primary school site), public open space and associated infrastructure.

We note that in the draft Greater Norwich Local Plan the Norwich Road site is identified as a "Reasonable Alternative", indicating that:
''This site is considered to be a reasonable alternative if additional growth is needed in the towns, subject to mitigation measures. For highways reasons, requirements would include a maximum of 100 dwellings with access from Norwich Road and a2-metre-wide footpath across the site frontage. 250 dwellings would require two points of access, but this would require further investigation as it would not be possible from either Copeman Road or Buxton Road. This site is therefore of secondary preference for allocation in the town."
It is noted that another site is identified as the proposed allocation

GNLP0311, 0595 and 2060: There are a number of similarly performing sites put forward in Aylsham but this combination of sites is favoured for allocation as it is preferred in highway terms as long as two points of access are provided. The site allocation includes a requirement/or a new primary school in Aylsham required to meet growth needs."
In subsequent discussion with officers we have been advised that - in reality - they feel that there is very little between the three sites in question (that identified as the 'Proposed Allocation' and the two sites identified as 'Reasonable Alternatives').
We believe that the summaries above - both the reason for identifying site ref. GNLP0311, 0595 and 2060 ahead of the Norwich Road (0596) site, and for not proposing the allocation of the latter - are based on incorrect information. Specifically:

• Contrary to the above statements, there is no highway constraint to the safe accessing of the Norwich Road site. We have subsequently been advised by Norfolk County Council Highways that the arrangement set out in the attached Indicative Masterplan would make the site's allocation/development acceptable in principle (see attached correspondence). The masterplan shows two points of access via Norwich Road, with a potential emergency access and/or cycle/footpath link only via Buxton Road [Please note that Norfolk Homes Ltd. also has control over the adjacent former motel site (for a primary/secondary access point), and the entirety of the Norwich Road frontage from the just north of the roundabout to the northern extent of the motel site (to accommodate the requisite footpath and other off-site highway improvement works)].
• Contrary to the published HELAA Comparison Table, the site should be identified as
green not amber against the issues of Access to Service, Uilities Capacity/Utilities Infrastructure (see below) and Compatability with Neighbouring Uses.

In particular it should be noted that in meeting and correspondence with Anglian Water it advised us (specifically with reference to the Norwich Road site) that ''Anglian Water can confinn that there is currently capaci.ty at Aylsham Water Recycling Centre to accommodate the 300 dwellings proposed. We closely monitor housing and economic growth in our region to align investment and the operation of our infrastructure to additional demand for used water." In effect, that Anglian Water is able to meet - through infrastructure investment- any additional housing and related demand, and environmental impacts arising therefrom. Water management ought not therefore to be viewed as a constraint to additional housing allocations in Aylsham, and this is acknowledged in the emerging Plan.
With regard to Compatibility with Neighbouring Uses, please note the accompanying Air Quality Assessment and Noise Assessment. The former concludes that air quality impacts are considered to be not significant, in accordance with the IAQM guidance, and that air quality issues are not a constraint to approving development of the site as proposed. The latter - which is of necessity high level, pending assessment of a detailed layout - concludes that some acoustic mitigation would be needed closest to the A140 but that noise levels at the site are generally low enough that non-acoustic glazing and trickle vents can be used across the majority of the site.

The attached plans illustrate in more detail how access is to be achieved, together with related off-site highway improvement works. The plans have been seen by Norfolk County Council and confirmed as acceptable in principle (see attached correspondence).

Furthermore, we are advised by NCC
Education/Children's services that there is a requirement for a 2ha site to allow the building of a new 2FE/ 420 place school. We confirm that we are willing and able to make provision for such on the proposed (Norwich Road, 0596) site, as indicated on the attached Indicative Masterplan, and at any stage of the development required by the County Council.

Our view - therefore - is that the Greater Norwich Development Partnership has made an incorrect assessment of the sustainability/merits/deliverability of the sites considered, in particular those of the Norwich Road site (GNLP0596).

Norfolk Homes has undertaken considerable work with a view to being able to make an early planning application and ensure early delivery of the requisite primary school and housing. To that end I attach copies of the work undertaken to date and which demonstrate that there are no constraints to said development:
• Indicative Masterplan;
• Access Plans (including off-site highway works);
• Tree Survey;
• Air Quality Assessment;
• Noise Assessment;
• Landscape and Visual Impact Assessment;
• Ecology (Habitat Survey completed; species surveys scheduled for March-May 2020 )

Furthermore, Norfolk Homes Ltd. is content to explore - as part of the development proposals for the site - the Town Council's Cittaslow objectives (concerning park and ride) as set out in its 'Aylsham - Shaping the Future' document.
It is clear from the above and attached that the Norwich Road site (GNLP0596) is the best and most sustainable site to meet the growth/housing needs of Aylsham. The evidence hereby submitted demonstrates that the site should therefore be a proposed new allocation rather than a reasonable alternative. It is important to note that this is a view shared by Aylsham Town Council (see below).

In conclusion, Norfolk Hornes has a legal control over all the land in question, and has
undertaken significant work to date to demonstrate the suitability, deliverability and sustainability of the site's development as proposed. The site is available and deliverable in the short term - via a detailed planning application - to assist in meeting the Greater Norwich Local Plan's objective of delivering a sufficient supply of homes in the right locations.

Community Support
Please also note that Aylsham Town Council resolved to respond to the GNLP Local Plan consultation as follows (Minutes of Aylsham Town Council meeting of 19 February 2020):
'The town accepted that one site would need to be accommodated but this must include a primary school and this must be commissioned in the first phase of the project. The affordable housing element must be strictly adhered to. The Town Council would like a transport hub included in the development. The Town Council rejected Burgh Road as the most favourable site and instead would only agree to Norwich Road."

This representation demonstrates not only that the site is available, deliverable and sustainable, but has the support of the local community, a significant consideraion we suggest in determining the most appropriate sites for allocation.

BRU2
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant/developer of the site at Yarmouth Road, Brundall (20180935 and 20190604), identified - in part - under Policy BRU2 of the Draft Local Plan.
The Draft Plan proposes no new allocations in Brundall but to carry forward - from the current Local Plan - sites BRU and BRU3. The former corresponds with Norfolk Homes' outline planning permission (ref. 20180935) and current Reserved Matters submission (ref. 20190604), together with the Parish Council's adjacent formal recreation site south of Yarmouth Road (ref. 20191377). The draft Plan notes:
'The site was allocated in the previous local plan and it is intended to carry this allocation forward, recognising the public benefit in providing informal open space. However, it is likely that the allocation of BRU2 will need further revision given the recent planning permission on the site for 155 dwellings which includes alternative provision for recreation (reference: 20161483). The site was also promoted through the local plan process as GNLP0325. The recreational allocation under BRU2 remains appropriate pending the residential development taking place."
The plan appears to attempt to keep options open - pending what happens on site - but it is our view that the identification/proposed allocation of the entire site for recreational open space - albeit at draft Plan stage - is potentially confusing and contradictory. A large portion of the site has planning permission for 15 5 dwellings ( with Reserved Matters approval pending ) and development will have commenced - anticipated late 2020 - well before the Plan is adopted, thus rendering it immediately out-of-date. We see no difficulty in allocating the formal recreation part of the site with a corresponding permission, but not the permitted housing part.

The Councils might also consider extending the settlement boundary to include that part of the site with permission for housing, again given that its implementation/commencement will pre-date the adoption of the Plan.

TROW1
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the developer of the site at Phase 1, White Horse Lane, Trowse (ref. 2016/0803 and 2016/0805) and the applicant/developer of Phase 2, White Horse Lane, Trowse (ref. 2019/2318), cumulatively identified under Policy TROW1 of the Draft Local Plan.
TROW1 is proposed to be carried forward as a housing allocation but it is noticeable that the wording of TROW1 (between adopted Local Plan and as now proposed) is different in the following way:
The Introduction to the policy is briefer now, but the main change is "approximately 173 dwellings"in lieu of "150 to 160 dwellings".
In the Notes to the policy, it states that the allocated site benefits from planning permission for 173 dwellings. It references Norfolk Homes' Phase 1 permission for 98 dwellings and an undetermined Reserved Matters for 75 dwellings. The latter has been superseded by Norfolk Homes' current full application for 83 dwellings, which is not referenced in the text
Given that Norfolk Homes' current application would increase the cumulative development of the site to 181 dwellings, we would request that:
• The current planning application is acknowledged in supporting text (Notes);
• The policy title refers to "at least 173 dwellings"

Question 27
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.
It is noted that at paragraph 240 of the Draft Local Plan, it states:
"240. The policy sets a general requirement for on-site affordable housing provision of 33% on sites that show better viability based on local evidence, with a lower requirement in Norwich City Centre. This is based on:
o The Strategic Housing Market Assessment 2017 which identifies a need for 11,030 affordable homes in Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point;
o Under national policy, small sites under 10 dwellings are not required to provide affordable housing. Larger sites will therefore have to ensure that overall affordable housing need is delivered;
o The most recent viability study.findings which conclude that centrally located brownfield sites which have higher development costs which affect viability are generally able to provide 28% affordable housing;
o Some specific sites have very high costs associated with development. These are allocated with lower affordable housing requirements."
Within 'Policy 5 -Homes' is included:
"Affordable Housing"
Major residential development proposals and purpose-built student accommodation will provide:

• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a different percentage of affordable housing;
• affordable housing on-site except where exceptional circumstances justify off-site provision;
• a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking account of the most up-to-date local evidence of housing need. This will include 10% of the affordable homes being available for affordable home ownership where this meets local needs;
• affordable housing of at least equivalent quality to the market homes on-site.

The sub-division of a site to avoid affordable housing provision will not be permitted."
This begs the question: if the most up-to-date SHMA identifies a need for 28% affordable housing, why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication -although somewhat disingenuous -is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived 'shortfall' through major housing schemes (10 or more units).
We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the Joint Core Strategy is carried forward into the new Local Plan: 'The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area." (Draft policy 5 only says that "a mix of affordable housing sizes, types, and tenures ... " should reflect the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period - notably since the publication of the 2017 SHMA -and has been reflected in Councils' approaches to decision making thereafter. There now appears to be a marked change in the Councils' approach to an evidentially-based and up-to date proportion of affordable housing, without justification.
The GNDP may feel it has a case to make -other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments -but we cannot find any proper rationalisation in the Draft Local Plan, nor in its supporting evidence, including the Interim Viability Study (November 2019). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period.

Rackheath
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant of the current application of the site off Green Lane West, Rackheath (ref. 20171464).
Whilst acknowledging that the site in question does not as yet having planning permission,
Broadland Council has resolvd to do so (Planning Committee - 10 April 2019). We therefore suggest that - in the interests of completeness, and given that by the time of the next iteration of the Local Plan there will be an extant planning permission for 322 no. dwellings and associated development on the land - an appropriate note should be added to the Plan's supporting text (Notes).
Please let me know if you require any further information or clarification.

Full Representations makes comments on BRU2, TROW1, Question 27 and Rackheath as well as Aylsham. Check Summaries for submission on these other sites/location or question.

I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.

Aylsham
Norfolk Homes Ltd supports the classification of Aylsham as a Main Town in its settlement hierarchy, the Sustainable Growth Strategy in relation thereto and the identification of the town as a sustainable community able to accommodate additional, significant housing (and related) growth.
In promoting the allocation of our site on Norwich Road, Aylsham, we also wish to highlight that Aylsham is a highly sustainable location capable of accommodating greater, planned growth. The town has all the requisite services, facilities and employment, together with good transport links, sufficient to support sustained housing and associated growth (as set out in the HELAA and related Local Plan evidence).

The merits of further growth in Aylsham are self-evident and indeed referenced in the supporting evidence, namely:
• Aylsham has a vibrant town centre which supports a sizable number of retail and service businesses;
• Access to most of the remainder of the Greater Norwich area and beyond has been improved with the opening of the NDR;
• Local employment opportunities are provided in the town centre and the Dunkirk Industrial Estate to the north-east of Aylsham;
• There exists a good range of services and facilities within the town, including primary and secondary education;
• There are two GP surgeries and a dental surgery in Aylsham, all of which are still accepting patients;
There are a number of recreational opportunities in or near the town including a recreation ground on Sir Williams Lane, a new football facility at Woodgate Farm, the Bure Valley Way, The Marriott's Way and facilities at Blickling Hall.

Indeed, the town has seen continuous and planned housing growth since the early 1990s; it is capable of continuing to accommodate sustainable growth through at least the new Plan period and thereby make an important contribution to the provision of new housing in
a Greater Norwich, above existing commitments and the 300 houses indicated in the draft Local Plan.

Norwich Road, Aylsham (GNLP0596)
We reiterate/clarify the proposed allocation of this site for circa 300 dwellings, access, land for community use (2-hectare primary school site), public open space and associated infrastructure.

We note that in the draft Greater Norwich Local Plan the Norwich Road site is identified as a "Reasonable Alternative", indicating that:
''This site is considered to be a reasonable alternative if additional growth is needed in the towns, subject to mitigation measures. For highways reasons, requirements would include a maximum of 100 dwellings with access from Norwich Road and a2-metre-wide footpath across the site frontage. 250 dwellings would require two points of access, but this would require further investigation as it would not be possible from either Copeman Road or Buxton Road. This site is therefore of secondary preference for allocation in the town."
It is noted that another site is identified as the proposed allocation

GNLP0311, 0595 and 2060: There are a number of similarly performing sites put forward in Aylsham but this combination of sites is favoured for allocation as it is preferred in highway terms as long as two points of access are provided. The site allocation includes a requirement/or a new primary school in Aylsham required to meet growth needs."
In subsequent discussion with officers we have been advised that - in reality - they feel that there is very little between the three sites in question (that identified as the 'Proposed Allocation' and the two sites identified as 'Reasonable Alternatives').
We believe that the summaries above - both the reason for identifying site ref. GNLP0311, 0595 and 2060 ahead of the Norwich Road (0596) site, and for not proposing the allocation of the latter - are based on incorrect information. Specifically:

• Contrary to the above statements, there is no highway constraint to the safe accessing of the Norwich Road site. We have subsequently been advised by Norfolk County Council Highways that the arrangement set out in the attached Indicative Masterplan would make the site's allocation/development acceptable in principle (see attached correspondence). The masterplan shows two points of access via Norwich Road, with a potential emergency access and/or cycle/footpath link only via Buxton Road [Please note that Norfolk Homes Ltd. also has control over the adjacent former motel site (for a primary/secondary access point), and the entirety of the Norwich Road frontage from the just north of the roundabout to the northern extent of the motel site (to accommodate the requisite footpath and other off-site highway improvement works)].
• Contrary to the published HELAA Comparison Table, the site should be identified as
green not amber against the issues of Access to Service, Uilities Capacity/Utilities Infrastructure (see below) and Compatability with Neighbouring Uses.

In particular it should be noted that in meeting and correspondence with Anglian Water it advised us (specifically with reference to the Norwich Road site) that ''Anglian Water can confinn that there is currently capaci.ty at Aylsham Water Recycling Centre to accommodate the 300 dwellings proposed. We closely monitor housing and economic growth in our region to align investment and the operation of our infrastructure to additional demand for used water." In effect, that Anglian Water is able to meet - through infrastructure investment- any additional housing and related demand, and environmental impacts arising therefrom. Water management ought not therefore to be viewed as a constraint to additional housing allocations in Aylsham, and this is acknowledged in the emerging Plan.
With regard to Compatibility with Neighbouring Uses, please note the accompanying Air Quality Assessment and Noise Assessment. The former concludes that air quality impacts are considered to be not significant, in accordance with the IAQM guidance, and that air quality issues are not a constraint to approving development of the site as proposed. The latter - which is of necessity high level, pending assessment of a detailed layout - concludes that some acoustic mitigation would be needed closest to the A140 but that noise levels at the site are generally low enough that non-acoustic glazing and trickle vents can be used across the majority of the site.

The attached plans illustrate in more detail how access is to be achieved, together with related off-site highway improvement works. The plans have been seen by Norfolk County Council and confirmed as acceptable in principle (see attached correspondence).

Furthermore, we are advised by NCC
Education/Children's services that there is a requirement for a 2ha site to allow the building of a new 2FE/ 420 place school. We confirm that we are willing and able to make provision for such on the proposed (Norwich Road, 0596) site, as indicated on the attached Indicative Masterplan, and at any stage of the development required by the County Council.

Our view - therefore - is that the Greater Norwich Development Partnership has made an incorrect assessment of the sustainability/merits/deliverability of the sites considered, in particular those of the Norwich Road site (GNLP0596).

Norfolk Homes has undertaken considerable work with a view to being able to make an early planning application and ensure early delivery of the requisite primary school and housing. To that end I attach copies of the work undertaken to date and which demonstrate that there are no constraints to said development:
• Indicative Masterplan;
• Access Plans (including off-site highway works);
• Tree Survey;
• Air Quality Assessment;
• Noise Assessment;
• Landscape and Visual Impact Assessment;
• Ecology (Habitat Survey completed; species surveys scheduled for March-May 2020 )

Furthermore, Norfolk Homes Ltd. is content to explore - as part of the development proposals for the site - the Town Council's Cittaslow objectives (concerning park and ride) as set out in its 'Aylsham - Shaping the Future' document.
It is clear from the above and attached that the Norwich Road site (GNLP0596) is the best and most sustainable site to meet the growth/housing needs of Aylsham. The evidence hereby submitted demonstrates that the site should therefore be a proposed new allocation rather than a reasonable alternative. It is important to note that this is a view shared by Aylsham Town Council (see below).

In conclusion, Norfolk Hornes has a legal control over all the land in question, and has
undertaken significant work to date to demonstrate the suitability, deliverability and sustainability of the site's development as proposed. The site is available and deliverable in the short term - via a detailed planning application - to assist in meeting the Greater Norwich Local Plan's objective of delivering a sufficient supply of homes in the right locations.

Community Support
Please also note that Aylsham Town Council resolved to respond to the GNLP Local Plan consultation as follows (Minutes of Aylsham Town Council meeting of 19 February 2020):
'The town accepted that one site would need to be accommodated but this must include a primary school and this must be commissioned in the first phase of the project. The affordable housing element must be strictly adhered to. The Town Council would like a transport hub included in the development. The Town Council rejected Burgh Road as the most favourable site and instead would only agree to Norwich Road."

This representation demonstrates not only that the site is available, deliverable and sustainable, but has the support of the local community, a significant consideraion we suggest in determining the most appropriate sites for allocation.

BRU2
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant/developer of the site at Yarmouth Road, Brundall (20180935 and 20190604), identified - in part - under Policy BRU2 of the Draft Local Plan.
The Draft Plan proposes no new allocations in Brundall but to carry forward - from the current Local Plan - sites BRU and BRU3. The former corresponds with Norfolk Homes' outline planning permission (ref. 20180935) and current Reserved Matters submission (ref. 20190604), together with the Parish Council's adjacent formal recreation site south of Yarmouth Road (ref. 20191377). The draft Plan notes:
'The site was allocated in the previous local plan and it is intended to carry this allocation forward, recognising the public benefit in providing informal open space. However, it is likely that the allocation of BRU2 will need further revision given the recent planning permission on the site for 155 dwellings which includes alternative provision for recreation (reference: 20161483). The site was also promoted through the local plan process as GNLP0325. The recreational allocation under BRU2 remains appropriate pending the residential development taking place."
The plan appears to attempt to keep options open - pending what happens on site - but it is our view that the identification/proposed allocation of the entire site for recreational open space - albeit at draft Plan stage - is potentially confusing and contradictory. A large portion of the site has planning permission for 15 5 dwellings ( with Reserved Matters approval pending ) and development will have commenced - anticipated late 2020 - well before the Plan is adopted, thus rendering it immediately out-of-date. We see no difficulty in allocating the formal recreation part of the site with a corresponding permission, but not the permitted housing part.

The Councils might also consider extending the settlement boundary to include that part of the site with permission for housing, again given that its implementation/commencement will pre-date the adoption of the Plan.

TROW1
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the developer of the site at Phase 1, White Horse Lane, Trowse (ref. 2016/0803 and 2016/0805) and the applicant/developer of Phase 2, White Horse Lane, Trowse (ref. 2019/2318), cumulatively identified under Policy TROW1 of the Draft Local Plan.
TROW1 is proposed to be carried forward as a housing allocation but it is noticeable that the wording of TROW1 (between adopted Local Plan and as now proposed) is different in the following way:
The Introduction to the policy is briefer now, but the main change is "approximately 173 dwellings"in lieu of "150 to 160 dwellings".
In the Notes to the policy, it states that the allocated site benefits from planning permission for 173 dwellings. It references Norfolk Homes' Phase 1 permission for 98 dwellings and an undetermined Reserved Matters for 75 dwellings. The latter has been superseded by Norfolk Homes' current full application for 83 dwellings, which is not referenced in the text
Given that Norfolk Homes' current application would increase the cumulative development of the site to 181 dwellings, we would request that:
• The current planning application is acknowledged in supporting text (Notes);
• The policy title refers to "at least 173 dwellings"

Question 27
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd.
It is noted that at paragraph 240 of the Draft Local Plan, it states:
"240. The policy sets a general requirement for on-site affordable housing provision of 33% on sites that show better viability based on local evidence, with a lower requirement in Norwich City Centre. This is based on:
o The Strategic Housing Market Assessment 2017 which identifies a need for 11,030 affordable homes in Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point;
o Under national policy, small sites under 10 dwellings are not required to provide affordable housing. Larger sites will therefore have to ensure that overall affordable housing need is delivered;
o The most recent viability study.findings which conclude that centrally located brownfield sites which have higher development costs which affect viability are generally able to provide 28% affordable housing;
o Some specific sites have very high costs associated with development. These are allocated with lower affordable housing requirements."
Within 'Policy 5 -Homes' is included:
"Affordable Housing"
Major residential development proposals and purpose-built student accommodation will provide:

• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a different percentage of affordable housing;
• affordable housing on-site except where exceptional circumstances justify off-site provision;
• a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking account of the most up-to-date local evidence of housing need. This will include 10% of the affordable homes being available for affordable home ownership where this meets local needs;
• affordable housing of at least equivalent quality to the market homes on-site.

The sub-division of a site to avoid affordable housing provision will not be permitted."
This begs the question: if the most up-to-date SHMA identifies a need for 28% affordable housing, why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication -although somewhat disingenuous -is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived 'shortfall' through major housing schemes (10 or more units).
We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the Joint Core Strategy is carried forward into the new Local Plan: 'The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area." (Draft policy 5 only says that "a mix of affordable housing sizes, types, and tenures ... " should reflect the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period - notably since the publication of the 2017 SHMA -and has been reflected in Councils' approaches to decision making thereafter. There now appears to be a marked change in the Councils' approach to an evidentially-based and up-to date proportion of affordable housing, without justification.
The GNDP may feel it has a case to make -other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments -but we cannot find any proper rationalisation in the Draft Local Plan, nor in its supporting evidence, including the Interim Viability Study (November 2019). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period.

Rackheath
I hereby make representations pursuant to the current (Regulation 18) consultation on behalf of Norfolk Homes Ltd., the applicant of the current application of the site off Green Lane West, Rackheath (ref. 20171464).
Whilst acknowledging that the site in question does not as yet having planning permission,
Broadland Council has resolvd to do so (Planning Committee - 10 April 2019). We therefore suggest that - in the interests of completeness, and given that by the time of the next iteration of the Local Plan there will be an extant planning permission for 322 no. dwellings and associated development on the land - an appropriate note should be added to the Plan's supporting text (Notes).
Please let me know if you require any further information or clarification.