CC16 Policy

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

Changes Sought
However, whilst the allocation of land adjoining Norwich City Football Club is generally considered sound
based on the tests of soundness set out in paragraph 35 of the NPPF, minor alterations to the wording of
Policy GNLP0520 are considered necessary.

The policy states that a minimum of 270 homes will be accommodated on the site. However, it is not clear
as to whether this figure includes committed developments that are being constructed, or specifically refers to new homes. In our view, it should be the latter.

The only parts of the allocation that are not in the process of being developed are surface car parks, which
paragraph 2.192 recognises is an inefficient use of the site. Accordingly, the policy’s supporting text should
make it clear that these areas will be the focus of the proposed mixed-use development, including high
density housing.

Initial design work has demonstrated that the surface car parking areas have the capacity to accommodate
200 units, having regard to various site opportunities and constraints. Accordingly, to ensure that the
development potential of the site is maximised through the efficient use of land, the policy should state that
the site will accommodate at approximately 200 homes. This approach and the one detailed in the
preceding policy will ensure that the policy is justified, consistent with national policy and, therefore, sound.

In addition, the policy should be reviewed to outline which aspects have already been already and,
therefore, are not relevant to the remaining undeveloped part of the site. For example, the developments
under construction have enhanced the river frontage; improvements which cannot be delivered by the
development of the surface car parkd.

The site has the potential to help facilitate the regeneration of the East Norwich area by ensuring that any development on the site does not prejudice the ability to ensure future connectivity, most notably through
pedestrian and public transport links, in the future. However, whilst future connectivity with the East
Norwich area is a key objective, the development of the site, which may be developed in phases, is not
dependent on the regeneration of the wider area, as is demonstrated by the above referenced
developments; a fact that should be specifically mentioned in either the policy or supporting text in order
to provide certainty. Failure to do this will potentially result in the policy being unsound on the basis it does
not provide an appropriate strategy.

As drafted, the policy requires that any development provides a public transport interchange on site,
together with a public transport strategy for the wider east Norwich strategic regeneration area. As detailed
above, the site occupies a highly sustainable location and significant improvements have been made to
public transport accessibility in recent years, principally the inclusion of a bus stop on Canary Fields and a
bus gate between Geoffrey Watling Way and Koblenz Avenue. Accordingly, whilst it is acknowledged that
any development will need to demonstrate how it will connect and be accessible by public transport, the
requirement to provide a public transport interchange is not justified and is considered unnecessary. No
information has been required on what is required to deliver a public transport interchange on the site.
Therefore, it has not been possible to assess the implications for the viability of any development on the
site of this requirement.

The policy also states that any proposal will be required to provide a public transport strategy for the wider
east Norwich strategic regeneration area. As detailed above, whilst the redevelopment of the Norwich East
area is supported, its delivery is completely independent from the development of the land covered by
Policy CC16. In addition, given the strategic nature of the Norwich East area, the public transport
improvements for this area are likely to be significantly greater than those required on land immediately to
the east of Norwich City Football Club. Therefore, whilst it is recognised that any proposal must
demonstrate how it would facilitate future links with the wider Norwich East area, the requirement to provide
a public transport strategy for the wider Norwich East areas as part of the development of Policy CC16
would be both unreasonable and disproportionate.

Accordingly, it is proposed that in order to ensure the proposed policy is justified and, therefore, sound that
reference to both a public transport interchange on site and a public transport strategy for the wider Norwich
East area is removed.

See attachment for revised policy wording.

Bidwells continue to strongly support the allocation of land adjoining Norwich City Football Club for mixed
use development. The site is entirely deliverable, and capable of making a significant contribution towards
the need for additional leisure, community, residential, retail and office uses in the Greater Norwich Area
during the period to 2038. The site occupies a highly sustainable location within Norwich City Centre due
to its proximity to a range of services and amenities and sustainable modes of transport, notably Norwich
Railway Station
The site has, and continues to, make a significant contribution towards housing delivery in the Greater
Norwich area. As detailed in the draft policy’s supporting text, the Carrow Quay and Carrow View
developments which will provide a total of 323 units, are being implemented by Broadland Housing, with
some units already occupied. These developments have already delivered a number of the objectives of
the Policy CC16.
The wider allocation has the potential to be developed to provide a range of uses, which as well as
residential could include a multi-purpose Arena, that could be used for, amongst other things, sport, music
and conferencing; helping to achieve a sustainable mixed use development.

See Attachment.

Please find my ward-specific consultation response to the East Norwich Thorpe Hamlet aspects of Reg 19 Pre-Publication Draft GNLP attached. This is in addition to that submitted by Cllr Denise Carlo on behalf of the Green Group of city councillors. I also endorse the climate related work sent in by Dr Andrew Boswell for CEPP