Comment

Representation ID: 22224

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

As a start point, we broadly agree with the classification of settlements within the hierarchy itself. In particular we are pleased to acknowledge that Aylsham is identified as one of the principle settlements of the plan area, falling on the second tier of the hierarchy as a ‘Main Town’ and comprising a location for growth that is second only to Norwich itself in terms of importance.

We do, however, have concerns in respect of the proposed distribution of growth. In particular we are concerned about the continued reliance placed on strategic sites within the Norwich urban area as well as the proportionally significant level of growth to be directed towards South Norfolk’s Village Clusters.

The strategic sites issue is pertinent due to the chronic under-delivery of existing large allocations adjacent to and within the Norwich urban area, a matter which by Norwich City Council’s own admittance must be acknowledged by the plan1. The 2018/19 monitoring year was the first since the start of the Joint Core Strategy (JCS) plan period to see delivery in the Norwich Policy Area (NPA) meet its annual housing requirement. Otherwise, growth in the NPA took around 10 years to gather pace with exceptionally slow delivery in the first eight years of the plan period, as shown in the table below:

Table 1: Annual and cumulative delivery in the NPA since the adoption of the JCS Year Requirement Delivery Surplus / Deficit (cumulative) [see covering letter for table]


This lag in delivery during the early years of the plan is representative of the significant lead in times associated with large-scale strategic sites and stands to be replicated once again in the event that the reliance on large sites in and around the Norwich urban area is maintained by the GNLP.
The level of growth to then be directed to South Norfolk’s rural area raises two separate concerns. The first relates to the current complete lack of evidence assessing to the availability and deliverability of sites across the smaller villages of the district. The absence of such evidence means that the direction of such a high proportion of growth towards South Norfolk’s village network – currently proposed at 1,200 homes or 15.5% of all residual growth – represents a strategy that is neither justified nor even demonstrably deliverable. The second concern is that such a high level of growth in the rural area is entirely unsustainable (by comparison the main town tier, the second highest tier of the hierarchy comprising the most sustainable non-urban settlements, is only proposed to receive 50 more homes than South Norfolk’s villages).

To avoid further issues in respect of deliverability (a concern relating to the levels of growth directed towards both the Norwich urban area and South Norfolk villages tiers) whilst ensuring development is directed to sustainable locations, it is our clear view that a higher proportion of the housing requirement should be directed to deliverable sites at the Main Towns. Aylsham in particular represents a sustainable settlement with at least three medium-scale deliverable housing options (we consider our client’s site to be principle amongst them – see Annex 1) that would provide a significant contribution towards the growth needed across Greater Norwich. As it stands, and in light of these concerns, we recommend that the current proposed distribution of growth should be recast to reflect the suitability of the Main Towns. Resultantly, this tier of the hierarchy should receive a notably increased level of growth.

Regardless of the current approach to the distribution of growth, and as set out in our response to Question 14 below, it is our view that the proposed housing figure will also require a significantly uplift to account for City Deal and Tech Corridor growth commitments. To ensure the plan successfully allocates a range of additional sustainable and – vitally – deliverable sites that are able to meet an increased need for new homes from the earliest years of the plan period we consider that a large proportion of this additional growth will inevitably need to be met on unconstrained sites at the larger settlements of the hierarchy.

We therefore strongly suggest that the Main Towns should play a prominent role in meeting these additional needs. The identification of deliverable sites at the five Main Towns should be the priority due to the sustainability benefits these settlements offer, allied with their clear capacity to grow. These opportunities should then be complemented by additional sites across the remainder of the hierarchy in instances where it is clear development is deliverable and would result in wider sustainability benefits.