Question 48. Do you support or object or wish to comment any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

The draft plan only pays lip service to the environmental consequences of this dramatic expansion. In many areas valuable natural areas are proposed to be fit for development rather than agricultural land. The proposed expansion of roads and consequent traffic has the implication for driving climate change rather than curbing it. The lack of sustainability in the draft plan needs to be addressed for a more secure future for Norwich residents.

I'd like to feedback my generic concerns not just about sites near where I live.

I notice developments springing up everywhere as if the plan is to spread development out so no one area is over developed and everybody shares in increased housing.

The problem with this is that were losing the essence of Norfolk when developing in and around our villages. Norfolk is a tourist spot because of its beauty yet our plans do not include any protection for our villages and scenery.

I live in Strumpshaw and can see how nearby Lingwood and Brundall have changed to be more like suburbs with modern development sites. It's wrong to transform our villages like this under the guise of progress. It's ruining Norfolk. Please stop development in or close to our villages and protect that rural village feel which attracts us to Norfolk. It is not anyone's plan to change the look or feel or Norfolk yet but by bit it's happening.

Housing stock seems more about developer profit than actual needs. There's a shortage of bungalows yet when was the last bungalow only site developed? When was the last self build site of more than a couple of houses approved?

Equally on a larger scale , seeing what's happened to New Costessey, gaining from the bypass of the 80s but then ruined by increased traffic as a result of long water. It's madness. Our roads can't cope with development like this and tinkering with layouts adding short widened roads doesn't solve the problem.The route through bowthorpe , Costessey and the larkman area is now busier than it was before the bypass was implemented. And getting worse as housing expands further

It seems we economise on our roads as we can't afford to build them adequately for the future. The NDR is a great example of this. It's roundabouts are a nightmare simply because insufficient funds to build proper slip roads and fly overs.

The route through bowthorpe , Costessey and the larkman area is now busier than it was before the bypass was implemented.

Squeezing in thousands of new homes with thousands of new cars is great but they will all want to converge on Norwich at some time or junctions onto the main roads. These junctions need to be fit for purpose not rat runs ruining the quality of life for those nearby.

To me it feels like we're full already but we plough on building more homes and pretending the traffic will be ok.
Removing lanes to provide bus lanes doesn't solve the issues it just prioritises buses and taxis. It doesn't get us out of cars onto the buses. Half hearted bicycle lanes don't work either. I ride a bicycle through Norwich but as the cycle lanes don't have priority and you have to mount unmount the pavement to cross junctions it's safer and simpler to cycle on the road.

Yes lots of moans but in essence, leave our villages alone and protect Norfolk. Build new estates with proper access to a main road without impacting nearby local roads. Build more bungalows that people want.

Finally if our roads are too busy and too costly to fix yet we need more housing, a strategic plan to reduce traffic is needed. Why not start by banning diesels in the centre of Norwich. There seems to be no strategic plan to resolve the traffic issues that go with housing expansion. The two should and must go hand in hand.

If public transport and cycles are part of the solution then they need support. Bus fares are too expensive. Its cheaper to drive and park in the city. How daft is that?

My brief input is just to state that generally the excessive development throughout Norfolk at present is crazy when no account is taken of the incapacity of the health service, especially hospitals, and many other services to currently cope with existing demand. A real backlash will occur in future, but, of course, that will then be a problem for your successors. ''Lessons will have been learned'', of course.

Having attended the helpful viability workshop on 14 Feb it would be useful to see the supporting evidence behind the assumptions ie conversion rates for ART and AHO sold at 60 and 75% of OMV respectively? BLV at £650K Urban and £200K service village, per acre ?
The ongoing debate around the use of BCIS cost indices verses a QS cost plan needs to be agreed . (could a panel of regional QS firms be used?)
Similarly, scheme GDV needs to reflect actual sale evidence.
Presumably NPS can make their source material available?

No more house building

1) Any new housing must be totally environmentally sustainable i.e. solar panels, full insulation, grey water capture - and no new houses should be built to below this standard.
2) Any additional housing should be social i.e. council or public. There is no need for further private housing.
3) The housing already notionally allocated should be built before any new sites should be called for.
4) The figures on which the additional housing is proposed are questionable & incorrect. Housing growth will not be as great as projected (you are using out of date government criteria).
5) Any new developments must have infrastructure - schools, GPs, community facilities - in place before the building starts - not afterwards.
6) Developers should not be allowed to reduce percentage of affordable homes in any new development.
7) South Norfolk are disingenuous in not showing their plans as part of this plan.
8) Public transport in Norfolk in rural areas is not good enough to support any developments in villages in south Norfolk. This needs solving before any new development takes place.
8) Public transport in Norfolk in rural areas is not good enough to support any developments in villages in South Norfolk. This needs solving before any new development takes place.
9) Development should be near employment not scattered across rural areas.

I care for our wildlife, please would you take my views into consideration, i would like to say, No to the Western Link, No to dualling the A47 and No to ever building on Greenfield sites.
In the face of the climate crisis, these plans are suicidal.
Humans are not the only species that should be taken into account in planning documents. Our survival depends on healthy ecosystems, not construction.

General Objections

The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.

The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.

I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.

One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.

Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.

Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.

Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.

GNLP3003
I object to GNLP3003:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
• The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
• The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

I make no apology for echoing other residents concerns as detailed below.

General objections:
The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.
The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.
I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.
One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.
The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.
Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.
Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.
Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
Outside the development boundary for the village.
Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.
GNLP3003
I object to GNLP3003:-
Outside the development boundary for the village.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

CPRE Norfolk does not understand why there has been a major change in direction and policy as to where new development should be allocated in the GNLP compared to the current JCS. The JCS was only finally fully adopted in January 2014, just over 6 years ago. In the JCS housing concentrated in and close to Norwich was agreed and supported by hugely expensive infrastructure projects, in particular the Northern Distributor Road (now known as the Broadland Northway), which was primarily constructed to distribute traffic form and to new housing developments on the northern fringes of Norwich and in the North-east Growth Triangle. It would be a massive and costly folly to change that policy to one which allowed for the dispersal of much housing across the rural areas of Broadland and South Norfolk, where there is insufficient infrastructure, services and public transport, which would mean such development would be unsustainable. This would only lead to more congestion and pollution, leading to problems in meeting carbon-reduction targets.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (the JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites.

It is very disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 68 Parish and Town Councils in Broadland and South Norfolk (over 37%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

We question the relevance of a plan whose horizon is 2038, which is likely to be reviewed and replaced on at least three occasions before its end-date, and we fear that on each of these occasions more unsustainable housing will be crammed in at the expense of the countryside. What is perhaps most disturbing is that so many people living in the area are not aware of the current JCS let alone the emerging GNLP, and that where citizens are engaged in the process they seem to have their views discounted. For example, this is clear where the views of over 37% of the Broadland and South Norfolk Parish and Town Councils regarding the phasing of housing development are apparently ignored. Current consultation processes are not reaching the majority of people: perhaps a Citizens’ Assembly approach would be a means which would enable more people to be involved.

Otley Properties Ltd request that the CIL charging instalment policy is revised to provide more flexibility for small builders and developers. Otley Properties Ltd would be very happy to engage in discussions about the CIL to explain the issues small developers face.

GENERAL OBJECTIONS

The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.

The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.

I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.

One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.

OBJECTIONS SPECIFIC TO REEDHAM

Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.

The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.

Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.

There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.

Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.

Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.

Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.

Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.

SITE SPECIFIC OBJECTIONS

GNLP1001

I object to GNLP1001:-

•Outside the development boundary for the village.

•Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.

•Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.

GNLP3003

I object to GNLP3003:-

•Outside the development boundary for the village.

•Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.

•The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.

•The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

Hempnall Parish council does not understand why there has been a major change in direction and policy as to where new development should be allocated in the GNLP compared to the current JCS. The JCS was only finally fully adopted in January 2014, just over 6 years ago. In the JCS housing concentrated in and close to Norwich was agreed and supported by hugely expensive infrastructure projects, in particular the Northern Distributor Road (now known as the Broadland Northway), which was primarily constructed to distribute traffic form and to new housing developments on the northern fringes of Norwich and in the North-east Growth Triangle. It would be a massive and costly folly to change that policy to one which allowed for the dispersal of much housing across the rural areas of Broadland and South Norfolk, where there is insufficient infrastructure, services and public transport, which would mean such development would be unsustainable. This would only lead to more congestion and pollution, leading to problems in meeting carbon-reduction targets.

Hempnall Parish council wants to see sites allocated for housing in the existing plan (the JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites.

It is very disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 68 Parish and Town Councils in Broadland and South Norfolk (over 37% and including Hempnall) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

We question the relevance of a plan whose horizon is 2038, which is likely to be reviewed and replaced on at least three occasions before its end-date, and we fear that on each of these occasions more unsustainable housing will be crammed in at the expense of the countryside. What is perhaps most disturbing is that so many people living in the area are not aware of the current JCS let alone the emerging GNLP, and that where citizens are engaged in the process they seem to have their views discounted. For example, this is clear where the views of over 37% of the Broadland and South Norfolk Parish and Town Councils regarding the phasing of housing development are apparently ignored.

Turner Morum LLP have, on behalf of Welbeck Land, reviewed the Greater Norwich Local Plan, Interim Viability Study, prepared by NPS group (November, 19) and have identified a number of comments which are outlined below.
Whilst there is general support for the approach adopted and the collaborative approach that the GNLP Team are seeking to adopt, there is concern that the assumptions made within the Viability Study in relation to, amongst other things, sales values, build costs and benchmark land values are too generic and not backed up by comparable evidence. Further evidence on this is provided below.
In addition, there is concern that the typologies used within the Viability Study are both too general and do not reflect the allocations within the draft GNLP. For example, the largest size development appraised within the Viability Study is 600 units, notwithstanding the fact that a number of the carried forward allocations / preferred sites are well in excess of this figure. These larger sites are likely to require the more significant infrastructure obligations i.e. primary schools and health centres, so an assessment of viability and the implications for deliverability is key. To ensure a more robust and realistic approach we would suggest that site specific viability studies are undertaken of a selection of the preferred sites of varying sizes.
As part of this work, consideration should be given to whether it is unviable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. schools and health centres, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan. The potential for infrastructure costs which are specific to larger strategic sites to be secured by Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the delivery of the infrastructure, should be explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).
General Comments
• The document has adopted average market revenues of £279 per ft2 for Wymondham, which is considered too high. Based on market evidence the figure should be £250 per ft2.
• The affordable rent values are included at 60% of Open Market Values (OPV) averaging £168 per ft2 , which we believe is too high. Based on recent evidence we would suggest that this figure should be between 45%/50% of open market value.
• The intermediate units (Affordable Homes Ownership) are included at 75% of OMV averaging £212 per ft2, which we believe is too high. Based on recent evidence we would suggest that assuming a shared ownership model, the figure should be between 65% of open market value.
• The Interim Viability Study document is vague about what the Affordable Housing units are intended to be. However, the GNLP Viability Assessment Paper (2018) is clear that standard intermediate housing are the intended units.
• A figure of only £193,000 per net acre for strategic infrastructure is included whereas, based on experience of similar viability assessments, this should be approximately double. The approach is to include 20% on-top of BCIS for all external and strategic infrastructure costs, although 10% (as a minimum) would be required for plot externals costs – which leaves the remaining 10% for strategic infrastructure costs.
• The GNLP analysis does not apply contingency or professional fees to the externals works of strategic infrastructure costs – which is a significant figure that would be further increased if strategic infrastructure cost were included
• The allowance for finance costs, which are equivalent to juts 1.0% of GDV/ 1.3% of scheme costs, is very low. Based on comparable viability assessments, these costs should be double.

Hethersett Parish Council concurs with the South Norfolk Council identification of 'unreasonable' as attached to ALL the sites allocated to Hethersett in the Section 18 document 2020. The Parish Council include in that a rejection of any construction on GNLP 04804 so maintaining the strategic gap between Wymondham and Hethersett as delineated by the agreed Local Plan 2016-2026.

It must be recognised (and stated as such) that Hethersett already has its maximum allocation of housing and not the 'minimum' of 1349 as mentioned in the Consultation Document as a commitment. All have been allocated under the still current plan of 2016.

The Parish Council notes too that a phased development plan should be in order so that sites with permission are used first and not land banked to increase market competitiveness.

Given we are approaching the 2050 Carbon Neutral Goal we must seriously address other sustainability issues of water usage, transport and well-being as impacted by development. This is the profit we need to invest in. The document merits proximity to a Primary School as an indicator of sustainability. The Parish Council considers that the GNLP will be incomplete without due consideration for the well being of its citizens which demands adequate attention to the medical, physical and ecological requirements of settlements. New housing must be placed within an infrastructure that can support and enhance and not create friction and overcrowding with ensuing problems.

There is an opportunity to lead on climate issues and housing which is missing from the plan. Items for example such as domestic energy features, the reduction of the Per Capita Consumption water rate and the creation of a linking green belt.

Hethersett Parish Council argues that the South Norfolk village cluster plan should also be available to public scrutiny and not be seen as distinct from the GNLP. It is also noted that the more recent figures from the National Office for Statistics for 2016 have not been used with a preference for those of 2014. The statistics from 2016 provide current commitments to cover housing need to 2038.

The Parish Council want to see that the environment is protected and that this is intrinsic to a Local Plan. A local plan that includes care for the well-being of all which will not allow for tokenism but listens and acts on the consultations made.

Representing Norfolk Constabulary:

Norfolk Constabulary have the responsibility for policing and making Norfolk a safe place where people want to live, work, travel and invest in.

Appendix 1 details infrastructure requirements and it provides additional detail to support policy 4 of this plan. It sets out infrastructure requirements to serve growth as identified in the Greater Norwich Local Plan Infrastructure Needs Report (GNLPINR). The GNLP confirms that the GNLPINR (and appendix 1) will be updated to inform the GNLP Regulation 19 version.
The infrastructure will be provided by a variety of organisations and funding sources.

Norfolk Constabulary recognise the importance of providing robust and fully justified evidence to support their infrastructure requirements. Work is underway to prepare a Police Infrastructure Needs Strategy to inform the Regulation 19 version of the GNLP and the Greater Norwich Local Plan Infrastructure Needs Report.

It is small surprise that the Schools Strike over Climate change gains momentum, when the Greater Norwich Local Plan focuses so relentlessly on Growth at all Costs, without acknowledging the real implications and that "mitigation" provides an insult to what has been lost. A 27% brownfield target, the impact of 73% loss to the countryside surrounding the City, Towns and Villages is already being seen. Worse, the disconnect between these developments and their surrounds is evident from Hoveton to Cringleford. And then, the plan states we need to look ahead for more of the same. Unimaginative, Unsustainable, Undesirable, Destructive.

Yes we will all need new houses as populations increase but a balance needs to put on this.
Lets keep our village /small towns identities
Lets ensure that we have an infrastructure to support these developments prior to building , not after when existing infrastructures are stretched
Lets provide bespoke cycle ways not painted line on pavements /roads.
Lets connect our transport systems together
Lets enhance our existing Villages, Towns not kill them off with overdevelopment.
Lets provide facilities for the communities not rely on local charities all the time to provide

FCC has reviewed the Village Clusters Non-Residential Site Assessment Booklet, hereafter referred to as the Site Assessment Booklet, detailing how the site (GNLP2128) was assessed and has identified discrepancies between that and the HELAA 2018 addendum, which the site was originally assessed within.

The ‘Stage 2 – HELAA Comparison Table’ within the Site Assessment Booklet (page 4) has no supporting text, but it is assumed that the intention is to draw together the results of the RAG assessment undertaken within the HELAA 2017 and Addendums (2018 and 2020). The site was initially scored within the HELAA Addendum 2018 and was considered ‘Green’ for all constraints accept contamination. However, within the HELAA Comparison Table, referenced above, the site now scores ‘Amber’ on a number of factors, namely Site Access, Access to Services, Significant Landscapes, Historic Environment and Transport and Roads.

It is not clear whether this revised scoring is due to a clerical error but in any event FCC has reviewed the RAG assessment criteria as set out within the Norfolk Housing and Economic Land Availability Assessment Methodology (July 2016). Appendix A details the constraints and provides criteria for scoring in relation to each of the relevant constraints. FCC has considered those scored ‘Amber’ and comments as follows:

Access to Site: The site has an existing two-way bellmouth access junction built to adoptable standards which has historically been used for significant transport movements. The site provides direct access onto the B1334 with immediate access to the A140. The assessment criteria states that to score ‘Green’ access by all means should be possible; thus, given this existing access, the site should have scored ‘Green’.

Significant Landscapes: The assessment criteria dictates that sites should score ‘Amber’ where they would have a detrimental impact on sensitive or other landscapes which would be mitigated, whereas sites should score ‘Green’ where the development would have a neutral or positive impact on sensitive landscapes or their setting. The site is not located within any designated landscapes or a landscape which is considered to be sensitive. The site is a disused brownfield site which has no protected trees; redevelopment of the site would have a neutral impact on any sensitive landscapes and therefore the site should have scored ‘Green’.

Historic Environment: There are no designated or non-designated heritage assets within the site. The assessment criteria dictates that sites which will have either a neutral or positive impact on any designated or non-designated heritage assets should score ‘Green’ ; thus, it is considered this site should have scored ‘Green’.

Transport and Roads: The site assessment criteria dictates that to score ‘Green’ development of the site should not have a detrimental impact on the functioning of trunk roads or local roads. It states that consideration will be given to access to public transport, housing, traffic generation and capacity of local junctions. The site is located adjacent to the junction of the A140/B1334 which is a two lane roundabout and would have capacity to accommodate redevelopment of the site. A bus stop is located adjacent to the site boundary on the A140 and provides a regular bus service to Norwich and Diss. Therefore, it is considered that the site should have scored ‘Green’ for this criterion.

Para 5.10 of the HELAA 2017 states that technical consultees inputted into the RAG assessment and, whilst they were provided with a copy of the methodology, some took a more precautionary approach than is required. It states that “at this stage the assessment of the site is not sufficiently detailed to know whether particular issues can or cannot be resolved…hence the role of professional officer judgement”. It is not clear if, in instances where technical consultees have adopted an overly precautionary approach, this has followed through to the final RAG assessment or if they have been adjusted accordingly. FCC considers this should be more transparent and if the technical consultees have not applied the appropriate methodology then these scores should be adjusted.

Within the Site Assessment Booklet (page 8) the Parish Council have made comments in relation to the site, stating that a refuelling station had closed down in the 1990’s due to lack of trade and that a new refuelling station has been permitted at Scole roundabout. Their comments also made reference to a couple of farm/garden centre type retail outlets in the area. Within Stage 4 of the Site Assessment Booklet, whereby the sites are shortlisted, conclusions regarding the site state “This site is not considered to be suitable for allocation as to justify a local plan allocation in this location more evidence would be required to demonstrate need and the likely end-user businesses who would bring forward development”. Thus, it is inferred that the Council have some queries/concerns regarding the achievability of the site. Para 5.12 of the HELAA 2017 states that all proposers confirmed that their submitted sites are viable, and states that “since all site proposers have stated that their site is viable, we have not undertaken a site by site viability analysis”. In addition, the HELAA addendum 2018 suitability assessment proforma states that “further area-wide work on viability typologies will be done as plan-making progresses and will inform decisions on viability”. However, from a review of the available evidence base documents, this high level viability work has only been undertaken in relation to residential developments. The HELAA does not appear to have queried the developer stated viability of any other sites assessed and therefore it is not clear why this conclusion has been drawn for this site, nor is there any evidence to support this reason to discount the site.

FCC maintain that the redevelopment of this site is viable/achievable with sufficient market demand; there is a significant amount of growth permitted within Long Stratton, some 4.5km to the north of site straight up the A140, including ~1900 new houses and ~10 ha of employment land which is likely to generate significant additional traffic movements along the A140, past the site. FCC commissioned an independent specialist consultant to inform their development aspirations for the site, who undertook a viability assessment which concluded that there is demand for a variety of commercial uses including the proposed use.

Stage 4 of the Site Assessment Booklet also states the following in relation to the site: “An important consideration is GNLP2128 has brownfield land status as a former waste transfer station”. However, FCC question the level of consideration that has been given to the ‘brownfield land’ status of the site; paragraph 3.11 of the HELAA 2017 refers to an assessment of brownfield land capacity within Norwich and Main Towns and concludes that all relevant sites have been identified through the call for sites. However, it is not clear what level of precedence has been given to the redevelopment of brownfield sites over greenfield sites within the HELAA methodology; this did not form part of the RAG assessment criteria and, other this a comment of ‘importance’ within the published Site Assessment Booklet, it is not clear what consideration has been given to this, if any.

Paragraph 117 of the NPPF states “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land”, further, paragraph 118 states “planning policies and decisions should …support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land”. Paragraph 84 also states that “planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent or beyond existing settlement limits…The use of previously developed land…should be encouraged where suitable opportunities exist”. Given that there is no specific criteria relating to brownfield land within the HELAA assessment, it is unclear how the council can demonstrate that they have considered the use of previously developed land above greenfield development sites. Therefore, the soundness of the evidence base documents, and thus, the Local Plan is questioned.

FCC consider that the site is suitable, available and achievable for redevelopment, and would provide an opportunity to redevelop a redundant brownfield site, which national planning policy requires local plans to strive to achieve. Thus, the site should be allocated for development within the Local Plan.

The Consortium have reviewed the Interim Viability Study (November 2019) and have a number of comments. Of particular concern is the lack of consideration given to strategic-scale sites (i.e. 1000+ dwellings). The largest scale development typology is 600 units, which is significantly smaller than the scale of development proposed on a number of sites, including site GNLP0132, and therefore not a reliable or robust comparator. Furthermore, no allowance is included for the provision of strategic infrastructure on larger sites.

In addition, the timing of the CIL Review is such that any comments regarding viability must be accepted on the basis of the current regime, and the outcome of the CIL Review may have significant implications on viability, and this must be acknowledged by the Councils.

The timing of the proposed CIL Review is such that the Councils must acknowledge that the outcome may have significant implications for viability.

We wish to re-confirm the deliverability of site GT13 (Norwich Rugby Club). Its allocation in the Growth Triangle Area Action Plan confirms that it is an entirely suitable and sustainable location for growth, and will deliver a significant quantum of the required housing growth. Consent has been secured for the relocation of the Rugby Club (South Norfolk Council reference number 2018/1830) and works to implement this consent are underway. Kier Living have been brought on board to deliver the housing, once the relocation of the Rugby Club is completed, which will be well within the extended Plan period.

Our campaign does not see why the GNLP draft plan contains such significant increases in targets compared with the JCS (adopted in 2014). The Broadland Northway was supported and funded on the assumption that it would enable significant expansion of housing along the fringes of Norwich and within the designated growth area. These proposals implies massive expansion in housing in Broadland and South Norfolk, this appears at odds with the JCS position and would in effect open up vast tracts of green land for housing. We noted earlier in our responses there is no mention phasing of development.

Appendix 1 Infrastructure requirements.
Water – the text references a number of water recycling centres in the Greater Norwich Local plan area as set out in Anglian Water’s Water Recycling Long Term Plan.
However there is no reference made to there being a requirement for improvements to the water supply and/or foul sewerage networks to accommodate further development. This will include those sites which are allocated in the Local Plan sites together with any sites which come forward for development which are not currently identified.

Why has there been a change in direction and policy towards the location of new housing development in the GNLP from the JCS? The NDR was constructed in order to cater for the new houses to be built on the northern fringes of Norwich so it does not make sense to now propose housing development away from this area.
Sites allocated in the JCS should be built out before any new sites allowed to be developed.
Why has phasing of all development not been included.
Increasing land available for development does not mean more houses will be built.

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

Because South Norfolk is so widespread, we do not believe that the Climate Change objectives can be met with the building of more than 1200 new houses. Transport is necessary in rural areas and it is not environmentally friendly.
Also, as the plan projects forward to 2038, it is likely that climate change will be having a greater effect by then.
Lord Deben (John Gummer) Chair of Climate Change Committee
“We know we’ve caused global warming, but we can stop making it worse!”
“We know the way to stop it – all we need now is the will”

I am objecting to some matters regarding the governance of the plan preparation, which I can submit in Consultation 19, in 2021, but I would like to express my concern now. There was an intention to have a consultation in September 2018, this did not occur. We had been notified in the 2018 documents (and during contact in person with GNLP and contact by email with GNLP )an opportunity for submissions for a change of development boundaries could be put forward, at the time of this consultation.
In the current consultation document 2020 the opportunity to present alterations to current small sites development boundaries process is unclear. II can see no evidence in the plan of any strategy to mitigate against the effects of this change of direction.
I believe that an opportunity to discuss development boundaries is an important part of the process of making an up to date plan.

Persimmon Homes (Anglia) will be submitting further evidence in response to the Interim Viability Study in the near future.

Mention is made in Appendix 1 of extending the Strumpshaw waste management site be. Given the location of this facility close to Strumpshaw fen, the RSPB requests greater information be provided on the scale of this extension and whether there will be additional waste services provided?

We would raise concerns regarding the manner in which existing housing commitments and proposed new allocations have been counted towards the housing figures. It is considered that there is significant risk of double counting, particularly where some developments which are already being delivered are being proposed as new allocations. There appears to be no consistency between the circumstances as to whether sites are counted as delivered, existing commitments, or new allocations. Some settlement booklets refer to no allocations being carried forward, whilst the corresponding table within the Strategy document or Area Action Plan indicates that there are existing commitments to be carried forward.
We would raise concern regarding the deliverability of a significant proportion of housing by virtue of previous non-delivery, significant infrastructure restraints, and viability. Furthermore, we would raise concern regarding the ability to deliver a significant proportion of housing within the Plan period, and in particular in a timescale which means they can be relied upon to maintain a valid five-year housing land supply.
We object to the proposed strategy for growth as it is considered incompatible with the overall purpose of the plan, in particular the delivery of sustainable development which meets the challenges of climate change, and supports ambitious local and national targets for carbon neutrality. Additionally, it is not considered that the proposed distribution of growth is suitably forward thinking to facilitate the transition to a post-carbon economy, and the emergence of the region as the UK leader in clean growth.
The proposed new settlement Honingham Thorpe provides the opportunity to deliver growth differently, with purpose built infrastructure from day one and energy efficient and climate smart technologies built into the fabric of the community, to deliver a community with zero-carbon principles.