Object

Representation ID: 24303

Received: 22/03/2021

Respondent: FCC Environment Ltd

Number of people: 2

Agent: Sirius Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy 1 The Sustainable Growth Strategy
Policy 1 sets out the broad strategic approach for growth. FCC supports paragraph 15 of the Pre-Submission Draft Strategy that “our ambitions for delivering sustainable growth through the GNLP must reflect the Government’s requirements for local plans set out in the NPPF”. The settlement hierarchy presented in policy 1 includes village clusters which covers all other settlement areas outside the key service centres. FCC consider that the countryside should be identified on the settlement hierarchy enabling the growth of the rural economy.
It is noted that paragraph 169 of the Pre-Submission Draft Strategy states that the total amount of allocated and permitted employment land in 2018 is more than enough to provide for expected and promoted growth. Therefore, it is understood that a large number of employment allocations have been brough forward from current adopted plans and that the GNLP does not make significant additional allocations of employment land beyond those already identified. A detailed review of the employment figures and allocations has not been undertaken; however, FCC consider that the reassessment of all undeveloped allocated sites should be undertaken to determine whether they are likely to be developed by the end of the GNLP period. If a site is no longer considered to be deliverable, it should be de-allocated and replaced by an alternative allocation. Policies also need to remain flexible enough for any new sites to be considered acceptable over and above allocated sites.
Paragraph 161 of the Pre-Submission Draft Strategy states that the GNLP takes a flexible approach. FCC consider that the plan could go further with the need for some flexibility to be contained within spatial employment growth to reflect changes in the demand for land. This is in line with paragraph 120 of the NPPF which states that “planning policies and decisions need to reflect changes in the demand for land. They should be informed by regular reviews of both the land allocated for development in plans and of land availability…”.
Policy 1 states that smaller scale employment sites are allocated, and additional windfall sites will be provided in urban areas, towns and large villages providing local job opportunities and a vibrant rural economy. FCC consider that to be consistent with the NPPF, the GNLP needs to go further in supporting development in the countryside where there is a justified locational need. Paragraph 82 of the NPPF states that “planning policies and decisions
should recognise and address the specific locational requirements of different sectors”. The policy should be amended to provide greater flexibility in relation to rural areas, not limiting development to within village settlements if that development can demonstrate that it would enhance the vitality and viability of the local community and services; the policy should enable the impacts of such a scheme to be weighed against any benefits.
Paragraph 188 of the Pre-Submission Draft Strategy states that the strategy for the location of growth is to maximise brownfield development and regeneration opportunities, which are mainly in Norwich. FCC considers that this should be strengthened to maximise brownfield land within rural areas too. The NPPF encourages the effective use of land by reusing all brownfield land.