Question 38. Do you support or object or wish to comment on the approach for the city centre? Please identify particular issues.

Showing comments and forms 1 to 18 of 18

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 19829

Received: 03/02/2020

Respondent: Mr David Hooker

Representation:

It might be appropriate to suggest a longer term plan to exclude traffic from the city centre altogether. This concept is being developed in Oslo with considerable success.

Full text:

It might be appropriate to suggest a longer term plan to exclude traffic from the city centre altogether. This concept is being developed in Oslo with considerable success.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21641

Received: 16/03/2020

Respondent: The Theatres Trust

Representation:

The Trust is supportive of the proposed approach to supporting culture and cultural facilities. We would also recommend inclusion of a policy which protects cultural venues from unnecessary loss in line with paragraph 92 of the NPPF.

Full text:

The Trust is supportive of the proposed approach to supporting culture and cultural facilities. We would also recommend inclusion of a policy which protects cultural venues from unnecessary loss in line with paragraph 92 of the NPPF.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21764

Received: 16/03/2020

Respondent: Brown & Co

Representation:

We support the approach to the economy, and retail and leisure provision within the city centre.
However, we would query the ability to deliver the volume of housing proposed for the area in light of previous delivery rates and the proportion of carried forward allocations.

Full text:

We support the approach to the economy, and retail and leisure provision within the city centre.
However, we would query the ability to deliver the volume of housing proposed for the area in light of previous delivery rates and the proportion of carried forward allocations.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22289

Received: 16/03/2020

Respondent: Barton Willmore

Representation:

Q38 - 40) Consultation Questions for Policy 7.1 – The Norwich Urban area including the fringe parishes

2.56 The introduction to the draft Sites Allocation Document (SAD) confirms the document identifies the preferred sites for new allocation, the allocations to be carried forward from the current Local Plans, reasonable alternative sites (where appropriate) and unreasonable housing sites. The SAD is split into 50no. Settlement Papers which summarises the settlement characteristics and the existing and/or proposed allocations. 2.57 In the main, these provide a brief summary of existing allocations, and review whether these remain deliverable within the new Plan Period, and the sites submitted through previous call for sites, providing a rationale for why the sites should or should not be allocated.

2.58 One exception to the above are the existing allocations within the Growth Triangle, allocated through the Growth Triangle Area Action Plan (2016), which the Settlement Papers conclude to be carried forward:

High amounts of existing development commitment remains, as the allocations identified in the Growth Triangle Area Action Plan will not be superseded by the new local plan

2.59 No justification for this approach is provided within the Draft Strategy or the SAD.

2.60 As acknowledged in Table 2.1 and 2.2, the JCS has delivered poorly against its housing requirement since the start of the Plan period. A significant failing of the JCS has been the under delivery of allocations within the Growth Triangle. In particular allocations GT6, GT11, GT12, GT13, GT14 and GT16.

2.61 Policy 7.1 (The Norwich Urban Area including fringe parishes) identifies 12,019 dwellings as the ‘existing deliverable commitment’ for The Growth Triangle with 1,415 additional dwellings proposed through the GNLP.

2.62 Of the 12,019 committed dwellings, Appendix B1 (Broadland Sites Forecast) of Annual Monitoring Report 2018 – 19 (AMR, Appendix 4) identifies the Growth Triangle area is expected to deliver 4,485 dwellings between 2019/20 – 2025/26 (i.e. the remainder of the Joint Core Strategy Plan Period).

2.63 The AMR identifies the remaining 7,623 dwellings will be delivered in ‘2026 and beyond’. No updated trajectory is provided within the AMR or as part of the current GNLP consultation to demonstrate when these 7,623 dwellings (circa. 23% of the existing commitments) will be delivered i.e. by 2038 or beyond.
2.64 Table 2.3 below summarises 4no. allocated Growth Triangle sites which account for circa. 6,350 dwellings of the supply to be delivered ‘2026 and beyond’, not account for additional dwellings identified to be delivered in 2024/25 – 2025/26 (for which no evidence is provided).
Table 2.3: Growth Triangle Area Action Plan allocations [see attached document] 2.65 Sites GT12 and GT16 are anticipated to deliver 3,500 and 3,000 dwellings respectively in the Plan period. To date neither have commenced – despite being anticipated to deliver from 2019/2020 and 2016/2017 respectively. In the case of GT12, the latter phases are dependent on Infrastructure Forward Funding. Neither sites have secured detailed permission for any phase. Even if permission was to be granted now, accounting for NLP lead in times, they would not commence before 2021. This is ambitious, and even then would have to deliver housing at a rate of 220 dwellings per annum in the case of GT12, and 227 dwellings per annum in the case of GT16 (as set out in the AMR which anticipates no housing on site until 2024). NLP 2016, highlights average build out rates of 171 dwellings per annum on greenfield sites of this size, reducing to 148 dwellings per annum for brownfield sites. Based on these averages and the anticipated delivery rates in the 2018/2019 AMR, it would result in a housing shortfall of over 1,200 homes in itself. Accordingly, these allocations should be reduced to 2,927 (GT12) and 2,388 (GT16) respectively. The shortfall must be accounted for elsewhere.

2.66 The GNLP needs to provide a clear evidence-based justification for carrying over allocations identified in the Growth Triangle Area Action Plan. No such evidence is currently provided and as such the Plan risks being found unsound on account of being unjustified, not effective and not positively prepared on this basis. At the very least, we highlight for valid reasons the allocations GT12 and Gt16 cannot deliver the numbers anticipated, which should result in a reduction of 1,200 homes.
2.67 Furthermore, the Growth Strategy seeks to allocate additional land within the Growth Triangle with a proposed allocation for 1,200 dwellings in Sprowston. This site is under the control of the developers of the adjoining GT20 allocation (White House Farm) which is subject to an Outline application for 516 dwellings submitted August 2019 pending determination (application ref. 20191370). The AMR identifies an expectation for GT20 to commence in 2021/22 and complete in 2025, however given Outline consent has not yet been granted (and subsequent Reserved Matters prepared and submitted), this may be optimistic. The proposed allocation in Sprowston is identified to be built out after GT20 has completed. It is therefore unlikely the proposed allocation, for 1,200 dwellings, will be delivered within the Plan period. Policy 7.1 and Policy 1 should be updated to reflect this site is unlikely to deliver its full allocation within the Plan period.

2.68 To ensure the Plan delivers its housing growth requirement over the Plan Period, there is clearly a need to reduce the reliance on the Growth Triangle allocations which have not delivered as anticipated and allocate additional sites which are developable within the Plan Period, including in other locations outside the Growth Triangle. 2.69 Furthermore, Page 94 of the GNLP highlights that there is uncertainty over the Unilever/Carrow Works site. The NPPF requires clear evidence of delivery, and as such this allocation should be removed. As detailed in Section 3, Wymondham is such a location to accommodate at least some of this growth.

2.70 Accounting for the above, 1,200 homes as a minimum should be removed from the Growth Triangle, with further justification provided for all homes to be delivered in this location. Based on delivery to date in the Growth Triangle, we also strongly object to the addition of a further 1,415 homes in this location. To continue to rely on housing delivery in the Growth triangle undermines confidence in the GNLP to deliver on its needs. As such a minimum of 2,615 homes should be removed from the Growth triangle and re-allocated. As detailed in Section 3, Wymondham is such a location to accommodate at least some of this growth.

2.71 Within Wymondham, the Promoters have successfully secured consents resulting in circa. 900 dwellings being completed in the past 14 years from unidentified sites. This reflects not only the suitability of Wymondham as an appropriate location (i.e. people want to live there) but also represents a proven and trusted track record for the Promoters in bringing forward suitable sites.

Full text:

Full representations (with appendices) submitted in response to the current Regulation 18 consultation of the Greater Norwich Local Plan on behalf of Landstock Estates Ltd and Landowners Group Ltd.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22343

Received: 16/03/2020

Respondent: Pigeon Investement Management Ltd

Agent: Pegasus Group

Representation:

Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail; main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 We reserve the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.

Full text:

Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Hethersett. Please find attached the response form, the representations and a Delivery Statement

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22378

Received: 16/03/2020

Respondent: Pigeon Investement Management Ltd

Agent: Pegasus Group

Representation:

7. POLICIES 7.1-7.5 – THE SPATIAL STRATEGY
Policy 7.1 – Norwich Urban Area including the Fringe Parishes
7.1 Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail, main town centre uses and leisure development.
7.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
7.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
7.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.
7.5 The East Norwich area is also identified as a strategic regeneration area on the GNLP Key Diagram with named brownfield sites including;
- Yare at Carrow Works
- the Deal Ground
- the Utilities Site 7.6 It is of particular note that outline planning permission was granted at the Deal Ground in 2013 but no applications for the approval of reserved matters or for the discharge of conditions have since been submitted in the subsequent 7 years. This is indicative of the length of time that it can take to resolve issues on large brownfield sites prior to delivery.
7.7 The GNLP area is stated as having the long-term potential to deliver a new urban quarter and no certainty is provided that the named sites can deliver in the plan period up to 2038. Indeed, a master planned approach through a Supplementary Planning Document is proposed to co-ordinate the delivery of the area, including a local energy network and sustainable transport options.
7.8 The GNLP is therefore correct to suggest that East Norwich represents a long term growth option as the brownfield regeneration of historic industrial and former manufacturing areas takes many years of concerted effort, often with the intervention of the public sector to address funding gaps owing to constraints such as contamination, heritage and flood risk.
7.9 Much of the East Norwich Strategic Growth Area is located adjacent to existing water course including the Rivers Wensum and Yare therefore flood risk will represent an issue with regard to delivery.
7.10 Moreover the Reg 18 document highlights the uncertainty over the Britvic/Unilever Carrow Works site, this is the largest regeneration site shown in the Key Diagram (Map 9) for the east Norwich Strategic Growth Area, therefore assumptions made over the quantum of housing to be delivered from this brownfield source should be questioned until there is further clarity over the availability of the site. To that end the emerging GNLP should not place an over reliance on the new East Norwich allocation (1,200 homes) and should look to other sources of supply to meet its housing requirements.
7.11 Policy 7.1 also places emphasis on the delivery of large urban extensions (sites of over 1,000 dwellings) 20,765 of which are stated as being existing commitments and 2,815 of which are proposed as new allocations. Indeed, the proposed capacity from ‘elsewhere within the Norwich urban area’ represents 78% of the housing supply in the total Norwich Urban Area. 7.12 Urban extensions often require the delivery of substantial highway and drainage infrastructure before the delivery of new homes can commence. The delivery of 19,944 new homes on urban extensions appears overly optimistic. This is especially the case given the previous over-optimism which is evident in the trajectories within the GNLP area which have overestimated supply by circa 25%. It is also considered to be over-optimistic given that this includes 3,000 homes on a single site at North Rackheath which is not expected to achieve its first completion until 2024/25 according to the Annual Monitoring Report leaving only 14 years of the plan period to deliver at an average rate of 214 dwellings per annum which has been achieved on very few sites nationally.
7.13 The last paragraph of Policy 7.1 states that a large contingency site has been identified at Costessey to be bought forward if delivery of housing in the GNLP does not meet local plan targets. Such an approach is not considered to be reasonable given the existing over reliance on large strategic sites in the Norwich Urban Area to deliver homes in the plan period.
7.14 To conclude, the over reliance on the Norwich Urban Area to deliver 30,560 new homes in the plan period is considered to be an overly optimistic strategy given the reliance on large brownfield regeneration sites that are as yet unconsented plus a heavy associated reliance on large urban extensions, plus the growth triangle, to deliver the quantum of homes proposed in the GNLP by 2038.
7.15 An alternative strategy proposed by Pigeon, which seeks a greater percentage of development allocated to smaller, eminently deliverable sites at Main Towns and Key Service Centres, will not only help provide certainty to the delivery of the plan but provide for sustainable growth at locations with services and facilities, will assist the GNLP in evidencing a five-year housing land supply, provide a range and choice of sites to support delivery, and will provide new community facilities including land for education and healthcare purposes.
7.16 Our client reserves the right to comment further at Regulation 19 once housing trajectories are published, on the deliverability of sites and the associated soundness of the plan.
Policy 7.2 - Main Towns
7.17 Policy 7.2 sets out the level of growth to be delivered in the plan period for the Main Towns of Aylsham, Diss, Harleston, Long Stratton and Wymondham. Collectively these towns will provide 6,342 homes, approximately 14% of housing growth for the plan period.
7.18 Paragraph 308 of the GNLP states that these towns play ’a vital role on the rural economy’ as they ‘provide employment opportunities and services for rural hinterlands’. It goes on to say that the settlements are ‘the engines of rural growth’.
7.19 Accordingly, it is necessary to make appropriate provision at these highly sustainable settlements to ensure that the rural economy is supported and that local housing needs are addressed including at Diss.
7.20 The GNLP states that Diss is ‘strategically located’ with the ‘widest range of shops and services of the main towns’ plus a ‘broad range of employment opportunities’. It is identified at paragraph 317 as having ‘potential for economic growth as an enhanced centre serving a large rural hinterland in South Norfolk and northern Suffolk’. Paragraph 322 identifies Diss as having ‘potential for jobs growth on existing undeveloped allocated employment land particularly for manufacturing, including high value activities.’ (emphasis added)
7.21 Given the above statements about Diss taken from the introduction to Policy 7.2 it is concerning that it ranks third out of the five main towns for proposed housing delivery in the plan period with 743 new homes proposed, 343 from existing commitments and 400 from new allocations, representing just 12% of new housing development to come forward at main towns.
7.22 It would seem appropriate given the status Diss is given in the GNLP that it would provide a greater percentage of new housing growth especially as it is the only main town that is a net importer of workers as described in the spatial strategy representation above.
7.23 It is of particular importance if the plan is to balance the delivery of homes to jobs that Diss is allocated more housing growth to address the current shortfall of workers. Additional housing over and above that required to address the current shortfall will be required to provide for workers at new employment development coming forward on the allocated 10.8ha site at Diss. There are therefore strong arguments to increase the level of new housing proposed at this main town. 7.24 Proposed housing allocations at Diss, as set out in the draft GNLP, include a new green field site to the north of the town, and a large brownfield site to the east of the town immediately adjacent to the train station.
7.25 Concern is raised over the deliverability of the brownfield site (GNLP0102 Frontier Agriculture Ltd) as this is an existing employment site in active use by the UK’s leading crop production and grain marketing business. The site provides one of the company’s nationwide network of grain storage and processing facilities each of which are located in strategically placed locations to provide optimum accessibility for producers across the local area. The loss of the facility from Diss would be disadvantageous to the local agricultural sector.
7.26 The delivery of new residential development at the site would also be almost entirely surrounded by employment land meaning that it would be largely disconnected from neighbouring residential uses which provide for natural surveillance and reduce the potential for crime. There may be issues with residential amenity given the presence of businesses immediately on virtually all sides, each of which is likely to be served by heavy goods vehicles potentially operating throughout the day and night, with the potential for noise and air quality issues.
7.27 Moreover, the Diss Sites Evidence Base document states that the use of the site for residential purposes is not supported by the local community who consider the allocation of the site to be prejudicial to the delivery of the Diss Neighbourhood Plan. (A previous outline application for demolition of existing buildings at the site and the erection of 90 dwellings was withdrawn (2015/2816) on 17th October 2016.)
7.28 The Stage 6 detailed site assessment states that no additional documents have been submitted to support the site.
7.29 Therefore, in terms of residential amenity and delivery, this residential allocation is considered to be inappropriate when other deliverable alternatives are available such as land at Walcot Green Lane (GLNP1044) which will provide new green infrastructure linkages including circular footpath routes, market and affordable homes and self-build plots plus new highway improvements to Walcot Green Lane, all of which will provide benefits to existing and new residents alike. 7.30 The land at Walcot Green Lane is deliverable and additional technical work that has been carried out in support of promoting the site evidences that highway constraints identified by the Council’s evidence base can be overcome through the provision of a high quality pedestrian and cycle link via Orchard Croft to the south. The site is not otherwise constrained and can contribute to the authorities five-year housing land supply.
7.31 In conclusion Diss should be providing additional housing through allocations in the GNLP in order to balance jobs with homes at the Main Towns. The quantum of housing currently proposed in the GNLP is inadequate to achieve a jobs/homes balance and additional employment land is proposed through the GNLP. The argument for additional and alternative housing allocations at Diss is compelling, especially given the proposed brownfield allocation at the town which is not appropriate in terms of place making or delivery. The land at Walcot Green (GNLP1044) is an appropriate alternative which should be allocated to help address the emerging unmet housing needs at Diss.

Full text:

Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Walcot Green Lane, Diss.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22423

Received: 16/03/2020

Respondent: Norwich Green Party

Representation:

We generally support the approach for the city centre. In order to support and protect the city centre, we consider that it is necessary to limit the temptation of businesses to move to peripheral locations by constraining the amount of parking allowed for new developments across the Greater Norwich area and introducing workplace parking charges in and around Norwich. Parking charges would provide an income for investing in a public transport system.
As the opportunities arise, we would like to see redevelopment at Riverside with higher densities and far fewer parking spaces. Riverside is a badly planned site where land has been squandered on surface car parking and a major access road

Full text:

For full representation and additional information submitted, please refer to the attached documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22424

Received: 16/03/2020

Respondent: Norwich Green Party

Representation:

We object to a Northern City Centre Strategic Regeneration Area based around a large district centre/mixed use development at Anglia Square. We objected to the Anglia Square scheme and participated in the recent public inquiry. We recognise that the Anglia Square site provides the most sustainable and accessible in the city centre. However, in our view and many others, the scheme called in by the Secretary of State is not consistent with sustainable development.
If the scheme is rejected by the Secretary of State, we advocate a low rise high density mixed use development comprising mixed housing, (with a higher percentage of affordable housing), local retail, employment, cultural and community facilities built to high sustainability standards.
Support for a lower number of dwellings than the 1,250 envisaged for Anglia Square, would require new sites to be identified elsewhere. Windfall sites are highly likely.

Full text:

For full representation and additional information submitted, please refer to the attached documents.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22538

Received: 16/03/2020

Respondent: Historic England

Representation:

Para 271: This section recognises the unrivalled historic environment of the historic city centre which is welcomed.

Para 273: We welcome the reference to the need to make the best use of its distinctive assets.

Full text:

For full representation, please refer to attached documents

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22539

Received: 16/03/2020

Respondent: Historic England

Representation:

Para 274: Bullet point 2 should be amended to read conserving and enhancing the historic and natural environment to more closely reflect the NPPF

Full text:

For full representation, please refer to attached documents

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22542

Received: 16/03/2020

Respondent: Historic England

Representation:

Policy 7.1 Housing figures
Historic England has some concerns regarding the housing figures.
In particular the figures provided in the table for housing include those for both Anglia Square (awaiting the Inspector’s decision) but it is Historic England’s view that the capacity of that site is closer to 600 than 1200 dwellings) and the Carrow Works (where we have suggested caution regarding the capacity of the site and have requested that a more detailed HIA be undertaken to more carefully consider the likely impact of development upon heritage assets and thus the likely capacity of the site).
Whilst we consider that it will be possible to achieve high densities on brown field sites compared with the densities of many parts of the city, it would not be appropriate to seek the densities associated with very tall buildings in metropolitan areas.
We appreciate the emphasis in national policy on high density development in sustainable locations but highlight paragraph 11b and footnote 6 of the NPPF which states that there may be circumstances where the application of policies in the framework that protect areas or assets of particular importance (including designated heritage assets) provides a strong reason for restricting the overall scale, type or distribution of development in the plan area.
Historic England consider that Norwich’s historic character is under pressure from recent developments permitted without or against our advice (Pablo Fanque House, new student accommodation below St. Giles) and by proposals such as those for Anglia Square.
We are concerned at some of the indicative site capacity figures given in the site allocations (and contributing to this table).
One of the first questions any Inspector will ask at EiP concerns the capacity of the sites to accommodate the level of development indicated in the Plan.
To that end we consider that it is essential evidence base document is prepared outlining the site capacities and the assumptions that have been made in reaching these figures, particularly for the sites in the City. The evidence should set out the indicative site capacity, site area, density (as dwellings per hectare dph), assumed maximum height, surrounding heights of development, other on site and off site capacity considerations (e.g. heritage, natural environment etc.). This will provide a helpful starting point for us to be able to consider whether the indicative site capacities are justified, realistic and achievable in terms of their impact upon the historic environment (and other factors).
We refer you to our publication, ‘Increasing residential density in historic environments’ which can be found here. This study explores the factors that can contribute to successfully delivering developments which increase residential density in historic environments. It uses a combination of literature review and case studies to provide a series of recommendations to support decision making. In addition we commend the work by Ash Sakula in relation to Anglia Square and the demonstration of how that particular site could be developed at high density whilst respecting the historic environment.

Suggested Change: Amend housing figures if necessary following the Inspectors decision on Anglia Square and upon completion of an HIA for Carrow Works.
Prepare an evidence base document to consider indicative site capacities of allocations.

Full text:

For full representation, please refer to attached documents

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22543

Received: 16/03/2020

Respondent: Historic England

Representation:

Historic England broadly supports redevelopment of brownfield sites both in the City Centre, (including the northern city centre), east Norwich and the wider urban area. However, all such development should conserve and enhance the historic environment and be of an appropriate scale and massing, reflecting the grain and historic street patterns of the City.

Full text:

For full representation, please refer to attached documents

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22544

Received: 16/03/2020

Respondent: Historic England

Representation:

"5. The Natural and Built Environment"
We suggest that this section should also refer to the historic environment in the title to read, The built, natural and historic environment.
We suggest that the first word of the first sentence should be To rather than The.
We broadly welcome bullet points one and two.
We suggest the addition of the following bullet points as key principles of development:
 Development should be of a scale and massing in keeping with the surrounding area;
 Development should respect and reinterpret the historic grain, street layouts, burgage plots and morphology of the City;
 Development should avoid breaking the skyline or competing with historic landmark buildings across the City;
 Development should use materials in keeping with the historic fabric of the City.
We have concerns regarding bullet point 3 which encourages landmark buildings at the gateways to the city centre. While landmark buildings are not necessarily an issue per se, invariably such buildings are often tall and out of scale with the surrounding area. The particular skyline and historic setting of the city of Norwich as a whole means that the area is particularly sensitive to such development. Any such development must be of an appropriate scale and not harm the significance of heritage assets including for example the City Centre Conservation Area through development within its setting. To that end we recommend the deletion of bullet point 3.

Full text:

For full representation, please refer to attached documents

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22781

Received: 16/03/2020

Respondent: Whitbread PLC

Agent: Savills

Representation:

This representation only seeks to comment on the ‘City Centre’ section of the policy and specifically Point 3 (Leisure, culture and entertainment and the visitor economy) and Point 5 (The Natural and Built Environment).

Point 3 states:
“Development of new leisure and cultural facilities, hotels and other visitor accommodation to strengthen the city centre's role as a visitor and cultural destination will be accepted in accessible locations well related to centres of activity and transport hubs.”

Given that the CC4b site allocation has an existing hotel that will be redeveloped as part of a future scheme, and sits in close proximity to a existing and future transport hub at Norwich Station and its surroundings, we welcome and support the above point:

Point 5 states:
“New landmark buildings at the gateways to the city centre will be accepted where they are of exceptional quality and help to define or emphasise the significance of the gateway”

We support the encouragement for gateway developments within the city centre in appropriate locations. It is considered that Policy CC4b site allocation is an appropriate location for a landmark building due its strategic location within the City Centre and its proximity to Norwich Train Station. This approach is in line with the principle so the NPPF and the National Design Guide in promoting the effective use of land, high quality design and emphasising important places.

Full text:

For full representation, please refer to the attached document.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22860

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Representation:

The growth of the city centre is supported as a sustainable location for growth. However, this should be matched by accessibility. We are promoting the Loddon P&R site to ensure that all road routes into the city are provided with Park and Ride sites to facilitate sustainable “final mile” journeys into the city, with associated benefits to congestion and air quality in the city centre. Without the support of infrastructure, growth in the city risks not being sustainable.

Full text:

For full representation, please refer to the attached documents.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 23083

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

Representation:

In responding to Policy 7.1 we refer back to our comments in respect of Policy 1. In summary we consider there to be serious flaws arising from:
i. the continued overreliance on East Norwich given past under-delivery;
ii. the failure to distribute new growth within other parts of the GNLP area to more closely align with local housing needs where they arise and thus avoid market saturation in areas of more marginal viability;
iii. misalignment between the spatial strategy and the economic priorities of the Plan related to the Tech Corridor; and
iv. the assumptions over the scale of housing delivery arising from a key regeneration site in the centre of Norwich (Carrow Road) which is subject to considerable and acknowledged uncertainty above).

Full text:

For full representation, please refer to the attached documents.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 23175

Received: 16/03/2020

Respondent: Pigeon Investement Management Ltd

Agent: Pegasus Group

Representation:

Policy 7.1 details existing commitments and proposed allocations for the City Centre, East Norwich and elsewhere in the urban area including fringe parishes for housing and employment purposes. It also provides policies for retail, main town centre uses and leisure development.
8.2 A total of 30,560 new homes are proposed in the Norwich urban area for the plan period up to 2038, of which 26,165 homes (approximately 86%) are stated as comprising existing commitments. As currently proposed the Norwich urban area will provide 68.9% (approximately 70%) of housing land supply for the GNLP.
8.3 Closer examination of this source of supply demonstrates a reliance on brownfield regeneration sites and large urban extensions. These sources of supply are explored further below.
8.4 The Northern City Centre strategic regeneration area is dependent on the delivery of Anglia Square, a high density housing-led mixed-use redevelopment which was ‘called-in’ by the Secretary of State for the purpose of decision making on 21st March 2019 and is the subject of a public inquiry which commenced on 28th January 20207. The appeal Inspector will make recommendations to the Secretary of State however the site should not be relied upon for the delivery of a large quantum of homes until the Secretary of State allows the appeal. To that end the emerging GNLP should not place an over reliance on the allocation and should look to other sources of supply to meet its housing requirements.

Full text:

Pegasus Group are pleased to submit representations for Pigeon Investment Management Ltd on behalf of the landowners in support of the proposed development of the site at Land at Dereham Road, Reepham. Please find attached the response form, the representations and a Delivery Statement.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 23180

Received: 16/04/2020

Respondent: Network Rail

Representation:

NR would like to ensure this site stays part of the GNLP as the site is becoming an important part of NRs wider plans for this area to deliver housing and improved station parking. Using this land would also support the NPPFs default position of supporting the re-use of brownfield land and increasing the density around transport hubs.

A wider reaching concern is also that this de-designation could destabilise the emerging masterplan for land around Carrow Road and Canary Way, as site CC13 could have a significant role to play in the comprehensive planning of this wider area. I would therefore urge you to reconsider this de-designation.

NRs preferred development of this site would be to reduce the parking, freeing up the land to designate a proportion for housing and consolidate and rationalise the operational accommodation of NR maintenance.

The Norwich Lower Clarence Road plan attached shows the MDU left in situ on the Potter plan being the largest of the turquoise areas. The remaining grey blue is the current car park area.

NR are currently working on the feasibility of the options for this site. The plan attached (L2001_NRW_SK02) shows the level of development that may be possible on the site and whether this is deliverable within the GNLP plan period to 2038, which we currently believe it would be.

This option (attached), that has been worked up in guidance with the current policy in place on this site, is a residential scheme. The scheme is 83 units in total with a density of 77 units per hectare (65% flats & 35% houses). This is a higher density than the current policy, but this is supported by the Council.

The scale of the buildings is within the region of 2 to 4 stories across the site which ensures that the site flows and is reflective of that in the surrounding areas.

This area has been marked as a car park reduction area/retention area which this scheme reflects. As detailed plans are developed up there is scope to work up car share schemes, shared surfaces, low car use/ car free homes. Since this is an urban plot near a mobility hub reduced car ownership would be envisaged. The scheme would have decked carpark to the north for 80-100 cars which helps to support this.

This option doesn’t conclude our consolation of the maintenance use of the site however it is not thought that this will have an impact on providing a high standard scheme with similar densities.

The current policy CC13 states that:

“The site is close to a range of city centre facilities and the train station. It represents a good opportunity to provide housing development in a sustainable location.

Although the site is immediately adjacent to the railway line, in practical terms it is separated vertically by the slope on the southern boundary. Development of the site should address its constraints which include noise generated by the railway, and its topography.

The site is on the northern side of the river valley and development would be visible from a wide area and will affect the setting of the City Centre and potentially Bracondale Conservation Areas. Therefore the design, including height and layout of the development, should take this into account. Given its accessible location there is scope for some car free housing in this location.”

NR feel that this is still very relevant and that the proposals that are currently being put together reflect this policy.

I hope this is enough evidence for you to reconsider the de-designation of this site. NR are at the early stages in developing this site however we feel that this site is more than deliverable within the plan.

Full text:

I would like to thank you again for letting Network Rail have the time to respond to the consultation, Greater Norwich Local Plan Regulation 18 Draft Consultation, 29 January – 16 March 2020.

NR would like to ensure this site stays part of the GNLP as the site is becoming an important part of NRs wider plans for this area to deliver housing and improved station parking. Using this land would also support the NPPFs default position of supporting the re-use of brownfield land and increasing the density around transport hubs.

A wider reaching concern is also that this de-designation could destabilise the emerging masterplan for land around Carrow Road and Canary Way, as site CC13 could have a significant role to play in the comprehensive planning of this wider area. I would therefore urge you to reconsider this de-designation.

NRs preferred development of this site would be to reduce the parking, freeing up the land to designate a proportion for housing and consolidate and rationalise the operational accommodation of NR maintenance.

The Norwich Lower Clarence Road plan attached shows the MDU left in situ on the Potter plan being the largest of the turquoise areas. The remaining grey blue is the current car park area.

NR are currently working on the feasibility of the options for this site. The plan attached ('draft plan') shows the level of development that may be possible on the site and whether this is deliverable within the GNLP plan period to 2038, which we currently believe it would be.

This option (attached), that has been worked up in guidance with the current policy in place on this site, is a residential scheme. The scheme is 83 units in total with a density of 77 units per hectare (65% flats & 35% houses). This is a higher density than the current policy, but this is supported by the Council.

The scale of the buildings is within the region of 2 to 4 stories across the site which ensures that the site flows and is reflective of that in the surrounding areas.

This area has been marked as a car park reduction area/retention area which this scheme reflects. As detailed plans are developed up there is scope to work up car share schemes, shared surfaces, low car use/ car free homes. Since this is an urban plot near a mobility hub reduced car ownership would be envisaged. The scheme would have decked carpark to the north for 80-100 cars which helps to support this.

This option doesn’t conclude our consolation of the maintenance use of the site however it is not thought that this will have an impact on providing a high standard scheme with similar densities.

The current policy CC13 states that:

“The site is close to a range of city centre facilities and the train station. It represents a good opportunity to provide housing development in a sustainable location.

Although the site is immediately adjacent to the railway line, in practical terms it is separated vertically by the slope on the southern boundary. Development of the site should address its constraints which include noise generated by the railway, and its topography.

The site is on the northern side of the river valley and development would be visible from a wide area and will affect the setting of the City Centre and potentially Bracondale Conservation Areas. Therefore the design, including height and layout of the development, should take this into account. Given its accessible location there is scope for some car free housing in this location.”

NR feel that this is still very relevant and that the proposals that are currently being put together reflect this policy.

I hope this is enough evidence for you to reconsider the de-designation of this site. NR are at the early stages in developing this site however we feel that this site is more than deliverable within the plan.

Attachments: