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This growth particularly applies to large developments such as Long Stratton which currently has a large catchment area. However, when Long Stratton expands dramatically in housing numbers, will Bunwell still be allowed to send their children there if extra provision is not made at the High School?

Aylsham needs a new primary school now, not when a development is completed. By linking infrastructure improvements to developments they always arrive to meet the need before the development not what is needed after the further increase in population. There needs to be a radical re-assessment of the provision of schools.

The County Council needs to be providing the schools that are needed for the communities. If they are only responding to new developments and waiting for houses to be completed there will always be over-crowding in schools.

The provision for sufficient new schools and additional places at existing schools needs to happen in advance of the housing development if overcrowding of classrooms and relocation of children to other schools is to be avoided. Long Stratton is a prime example of where there is to be significant new housing development and if local schools do not have capacity will children from outlying villages such as Bunwell be relocated to other schools where there is capacity? That must be avoided to prevent disruption and upset to the children at an important time in their lives.

• Rackheath continues to be the focus of housing development and it is imperative that the bigger picture is considered in relation to infrastructure, services and connectivity to ensure that the existing Rackheath community is not impacted by this large scale development. Educational capacity must be increased to ensure community can grow seamlessly and to ensure new developments integrate successfully.

There needs to be a plan as to where and when these new schools and further educational establishments will be built and who will fund them.

This plan states that the GNLP will need to make provision for additional schools and school places to serve growth and then is silent on the plans to achieve this. The questionable Rackheath North development has included plans for one new secondary school and two new primary schools. If this development does not go ahead or is changed significantly then where will these schools be located. The current school in Rackheath is over subscribed.

It is considered that the spatial strategy of the GNLP would be better suited to following a more traditional and sustainable approach to the distribution of growth through the agreed settlement hierarchy.

In the case of South Norfolk, Welbeck Land strongly suggest the site on land north of Tuttles Lane East, Wymondham (GNLP00006), should become an allocated site.

The site on land north of Tuttles Lane East, Wymondham (GNLP00006), has the ability to deliver more suitable and sustainable growth, whilst addressing the identified infrastructure issues and requirements of one of the GNLP's largest settlements.

Please see the full representations made by James Bailey Planning Ltd. on behalf of Welbeck Land in the accompanying document.

1. EXECUTIVE SUMMARY

1.1 These representations have been prepared by James Bailey Planning Ltd. on behalf of Welbeck Strategic Land III Limited (Welbeck Land), with input from BasfordPowers, Sterling Transport Consultancy Ltd, Waterman Group, and Cannon Consulting Engineers. James Bailey Planning Ltd. are now instructed to represent Welbeck Land in this matter having inherited the instruction from Bidwells.

1.2 Welbeck Land have substantial interests in Wymondham in which they seek to promote large
scale development on the basis that the land represents a highly sustainable and suitable site for development.

1.3 These representations relate to the Greater Norwich Local Plan (GNLP), Regulation 19 PreSubmission Draft Plan document, February 2021.

1.4 They relate to the two parts of the plan, together with submissions on the legal compliance and soundness of the GNLP, both in terms of how it has been prepared and if it meets the prescribed tests of soundness.

1.5 While these representations consider all aspects of the GNLP, there is a specific focus on Section 5 – The Strategy, and particularly Policy 7 – Strategy for areas of growth. The representations concentrate specifically on the proposed growth for the Main Town of Wymondham.

1.6 In essence, the spatial growth strategy as currently being proposed by the GNLP Reg 19 is seriously questioned.

1.7 There are long standing sites that continue to be allocated that have failed to deliver over a number of years, and there is an unjustified growth being proposed towards ‘Village Clusters’.

1.8 The distribution of housing associated with the approach being taken in the GNLP Reg 19 document does not seem proportional or well considered or compatible with the requirement to promote a sustainable spatial strategy.

1.9 In essence, Welbeck Land consider that rather than solving any problems, this policy change creates additional new ones, notwithstanding the obvious difficulty of trying to judge whether the new “Cluster” allocations will be successful or not, when there is no indication where a significant proportion of them will actually be located.

1.10 Welbeck Land have continued to promote land to the north of Tuttles Lane East in the town of Wymondham (ref: GNLP0006) over a number of years, through the ‘Call for Sites’ requests, and then through previous stages of the emerging Local Plan.

1.11 It is suggested that the previous representations and submissions made to the earlier stages of the emerging GNLP, notably those at Reg. 18(c) stage previously submitted by Bidwells, remain relevant and should therefore still be considered as the document moves forward towards Examination by an Independent Inspector.

1.12 The Wymondham Area Action Plan (WAAP) was adopted by South Norfolk Council in October 2015. It identified a series of sites for the growth of housing, employment, and infrastructure. Delivery of some of the allocated housing sites remains a problem.

1.13 In March 2020, Wymondham Town Council submitted a Neighbourhood Area application,
designating the whole civil parish, which South Norfolk Council has confirmed. Progress on the Neighbourhood Plan remains unclear at the time of preparing these representations.

1.14 In summary, it is considered there is insufficient growth being proposed by the GNLP for Wymondham during the plan Period up to 2038. As an identified ‘Main Town’, there is also a weight of expectation that an appropriate level of growth will be ascribed to Wymondham, which has failed to materialise through the GNLP Reg 19 document.

1.15 It is believed that there are also mixed messages coming from the GNLP process. During the Reg 18(c) stage, Wymondham had a contingency identified for 1,000 new homes, however this has now been removed at the current Reg 19 stage. Conversely, Costessey (without comparable linkages or connections to Wymondham) had a contingency site identified at Reg 18(c) stage, which has carried through to an 800-unit contingency site in the Reg 19 document. This approach appears wholly unjustified and inconsistent.

1.16 There is also a large reliance on existing strategic sites being retained as allocations within the latest GNLP Reg 19 document, which have failed to be delivered over a number of years, such as the site at North Rackheath. This casts serious doubt not only of the delivery of these sites, but on the growth over the plan period. If allocated sites are not brought forward, then it will not be long before ‘hostile applications’ are made.

1.17 What is clear is that GNLP Reg 19 document appears to place an overreliance on delivery coming
forward through ‘windfall sites’, with a significantly disproportionate amount of housing growth being directed to the ‘Village Clusters’.

1.18 However, the South Norfolk Village Clusters Housing Site Allocations Local Plan is yet to be produced. Therefore, it is surely unjustified to place a reliance on a document that itself has yet to be tested.

1.19 The impact of Covid-19, and the knock-on effect of change in people’s habits, such as working arrangements and commuting patterns, is also considered within these representations. It is suggested that the current global pandemic is likely to have an impact on future housing growth, which the GNLP still has time to properly consider.

1.20 It is therefore believed that, although being positively prepared, the approach being taken to the spatial growth strategy across the Greater Norwich area is fundamentally flawed, and on this basis is therefore ‘unsound’ as it is neither justified nor effective.

1.21 To modify part of this deficiency, Welbeck Lane request that the land north of Tuttles Lane East, previously identified as a “reasonable alternative” in the Reg 18(c) document, be recognised as a formal allocation at Wymondham for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wymondham High School.

1.22 It is considered that identifying sites, such as land north of Tuttles Lane East at Wymondham, will help to provide a robust and proper planning approach to spatial growth. Allocating sites that prove their suitability; availability; and deliverability, in the most sustainable locations, will also enable the necessary infrastructure to be properly costed, programmed, and implemented.

1.23 In summary, the GNLP:-
• Over relies on long standing strategic site proposals, despite the knowledge from past history that some of them are unlikely to come to fruition within the Plan period;
• Introduces a change in policy direction to significantly increase reliance on development of small Village Cluster sites;
• Reduces the clear benefit to be gained from developing sustainable and available Main Town sites;
• Actually reduces proposals for certain Main Towns despite there being a clear expectation of new development;
• Is inconsistent in proposing certain Main Town sites to the detriment of other clearly more sustainable Main Town sites; and
• Proposes a spatial growth strategy that is fatally flawed, and therefore “unsound”.

1.24 Welbeck Land asks the Inspector to propose allocation of land to the north of Tuttles Lane
East for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wyndham High School. This action would go a long way to clarifying the clear deficiencies of the Plan as currently proposed and could easily be achieved without any need to delete other
current proposals.

1.25 The latest version of the Illustrative Masterplan for the site has been included as Appendix One.

1.26 A draft Statement of Common Ground has also been prepared to accompany these
representations and is attached as Appendix Two.

1.27 A Transport Working Note has been prepared to support these representations and is included
as Appendix Three.

THE NEXT SECTION OF THIS SUBMISSION IS SET OUT IN CHRONOLOGICAL ORDER AGAINST
THE GREATER NORWICH LOCAL PLAN (GNLP) REGULATION 19 PRE-SUBMISSION DRAFT PLAN
DOCUMENT FEBRUARY 2021.

See full representation attached.