Norwich and Urban Fringe Assessment Booklets

I seek assurances from the GNLP team that although the above sites are deemed based on the stage 1-7 assessment process "unreasonable sites". Could you confirm that they or any other sites within the Wensum Valley will be classified as suitable for development unclear any current planning process.

Proposed site GNLP0478 should be allocated.

It is noted that there are two site allocations identified in Rackheath for housing providing for approx. 220 new homes. There are two additional dwellings with planning permission on small sites. This gives a total deliverable housing commitment for Rackheath of 222 homes between 2018 – 2038 in this plan (not including commitments and allocations carried forward from the Growth triangle Area Action Plan).
It is also noted that further planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath.
The Plan’s supporting text and annotated Settlement Map is not an accurate reflection of proposed development in Rackheath and particularly along Green Lane West.
Further land off Green Lane West (GNLP0478) was put forward for development as a strategic housing site to deliver circa 300 dwellings, consistent in location with other proposals on Green Lane West which have been supported.
The proposal has been designed to reflect its edge of settlement location next to the NDR and would facilitate the delivery of a new Rackheath Country Park (circa 32 ha).
This is considered to be a sustainable and deliverable development that responds well to the delivery of biodiversity and environmental net gain through the promotion of public access.
The Rackheath Booklet identifies the settlement hierarchy and the potential for significant growth in this urban fringe parish.
GNLP 0478 was considered at Stage 1 assessment.
GNLP 0478 was considered at Stage 2 and faired favourably when viewed alongside the other proposed sites, particularly on utilities, market attractiveness, townscape, biodiversity/geodiversity, historic environment and open space and GI.
The Stage 3 consultation responses centred around the need for extra infrastructure. The proposed North Rackheath development is set to deliver essential infrastructure and it would be a missed opportunity if this site on Green West Lane (one of the few areas remaining uncommitted for development) was not brought forward given its low-density proposition and green infrastructure credentials.
Stage 4 of the Rackheath Booklet discusses the site and notes the potential to consider this site in combination with other sites put forward for development on Green Lane West. Some constraints are identified (e.g., noise from the industrial estate and impact on landscape character and Rackheath Hall). There is the potential to adequately mitigate these constraints as evidenced by the GT 16 allocation and recent planning permissions granted for development. The location of the industrial estate or Rackheath Hall is not considered an impediment to future development.
The site was considered on the shortlist of reasonable alternatives (Stage 5) with a reduced number of dwellings (142 and a combination of market and affordable along with 31,78 ha of green infrastructure).
Stage 6 presents the site assessment and raises comments on site constraints, highways, landscape impact and minerals safeguarding.
It is noted that the site received no red flags during its assessment and was comparable to other sites considered in terms of potential constraints. It is considered that an access solution can be engineered, there is sufficient ‘green space’ with the proposed site area to more than adequately address landscape mitigation and most of the land in the locality is underlain by sand and gravel which is not an impediment to development.
Stage 7 of the Assessment deems the site ‘unreasonable’. The ONLY reason it is deemed so relates to site access. In the event that an access can be delivered through an appropriate design, the site would be then at best be deemed a reasonable alternative and should be carried forward as an allocation. It is noted that there is no highways objection per se.
The site sits immediately adjacent to the proposed allocated site (GNLP 0172). Its context is no different to that when viewed against the NDR or wider allocations such as GT 16.
It is considered that the only perceived constraint preventing its allocation as a reasonable site is highways and access, for which an engineered solution is possible.

We therefore request that the actual zoning in the final GNLP be altered to where the proposed accommodation is being advanced. But we reserve the right to object to any proposals for this particular area on the grounds that it is outside the development boundary which we wish to protect along the lines of the Parish Plan.

Colney Parish Meeting is pleased to offer comments on the proposed zoning for the land surrounding Colney Hall as part of the Greater Norwich Development Plan consultation.

According to the provisions in the attached map of the site, this area is zoned for “older people’s accommodation”.

The actual area identified for this purpose is misleading as it contains historic parkland outside the development boundary.

Only the Hall itself and a small area of land to the west of the drive would be available for this use.

The owner has told us he intends to build specialised housing on the former rose garden. This is the area at the top of the drive with a semi-circular shape on its northern boundary.

This suggested area is outside the development boundary of the Parish. The Parish Committee wishes to protect this development boundary and will only support proposals which satisfy the agreed purposes of its Parish Plan.

Soundness
Clear evidence of the need for the increase in number of dwellings over and above those approved in the Cringleford Neighbourhood Development Plan. Provision of this 'evidence of need' should aim at a dialogue between the authors of the GNLP and Cringleford Parish Council to establish a more appropriate level of development that fits with the local environment.

Duty of Co-operation
There is no reasoning provided for the uplift in the number of houses allocated to our parish in the GNLP. Evidence that local concerns have been discussed collaboratively, listened to, and acted upon is required. Our Neighbourhood Plan accepts the need for development and was the result of consultation with our parishioners. A parish council is the conduit for the voice of local people to be heard at county and national level. A clear audit trail with evidence is required to demonstrate co-operation has occurred, potentially resulting in amendments being made to the housing requirements in Cringleford within the GNLP (or any plan for housing development).

Cringleford Parish Council: Response to Greater Norwich Local Plan Summary
• Cringleford Parish Council challenges the GNLP’s Regulation 19 proposals for the Parish of Cringleford on the grounds of Soundness and Lack of Compliance with the Duty to Cooperate.
• The GNLP has not taken into consideration biodiversity or the changing economic environment when considering its proposals for our Parish.
• The GNLP has ignored Government, Local and its own most recent documents in formulating its proposals.
• There are no net gains in the proposals for Cringleford.
• The GNLP has ignored comments of the Parish made under Regulation 18 and is proposing a 32% increase over planned residential dwellings without providing evidence of need for the additional housing in Cringleford.

See attachment for full submission.

Prepare an evidence document on site capacities in advance of the EiP

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.