MM87 - Policy GNLP0132

We write in relation to the consultation over the Proposed Main Modifications in the GNLP 2018-2038, specifically on the site allocated for development GNLP0132.

1. Map Modifications MAP32 - GNLP0132
The amendment says that residential numbers will be revised from 1,200 to a range of 1,000 - 2,000. We believe the range should be 1,000 to 1,200 homes (see pages 28/29 of the Monitoring Framework Document).

2. Main Modifications - Sites
Urban Fringe MM87 - GNLP0132 Page 236
The text refers to 1,000 - 2,000 homes dependent on whether there is provision of a secondary school on the site.

The additional language about the provision of a secondary school raises concerns, as 'the secondary school site will be safeguarded from development until 1 April 2026 or such time as a planning application including land for the secondary school at Rackheath on GT16 is approved and land for the secondary school is secured through a planning obligation, or such time as a formal notification is received from the Local Education Authority that the secondary school is not required, whichever is sooner' (whichever is sooner emphasised as bold in email).

We request that this additional language be removed from the GNLP. We suggest that recent events have impacted the timescale for GT16 to make progress and that the 1 April 2026 deadline for releasing the land earmarked for the school on GNLP0132 is premature.

The timescale for this condition might have been reasonable in February 2022, at the time the Statement of Common Ground was signed. However, time has moved on:

-We believe the inspectors heard at the GNLP hearings that the developers had allowed the option on the land comprising GNLP0132 to lapse.

- Nutrient Neutrality has come to the fore, leading to a significant delay in the timetable for GT16 which, at the date of writing, has still to deliver a revised masterplan.

We therefore have concerns that the express reference to a deadline of 1 April 2026 for the release of the land on GNLP0132 earmarked for the school in the GNLP is unhelpful.

We also have concerns on sustainability, if, by implication, the catchment area for the school at GT16 will include developments on the Salhouse Road in Sprowston. There will be no safe access for pupils on the south west of the A1270 to reach GT16 except by vehicle, given that they will have to cross the A1270 Broadland Northway.

We further note that Norfolk County Council has asked, in relation to GT16, that vehicle access to that site be limited to the A1151 Wroxham Road and that Stonehouse Road and Muck Lane are both intended to be closed off at the Salhouse/ Norwich Road end, so the route to the GT16 school from the Sprowston end of Salhouse Road will be a circuitous route and will exacerbate the congestion on the A1151 created by 4,000 additional dwellings on GT16, again unhelpful in the context of sustainability.

We therefore request that the sentence referring to the timetable be removed.

Thank you for inviting Sport England to comment on the above document.

Sport England is the Government agency responsible for delivering the Government's sporting objectives. Maximising the investment into sport and recreation through the land use planning system is one of our priorities. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields.

Sport England has assessed this consultation in the light of the Sport England's Planning for Sport: Planning for Sport Guidance ('Guidance').

The overall thrust of the Guidance is that a planned approach to the provision of facilities and opportunities for sport is necessary, new sports facilities should be fit for purpose, and they should be available for community sport. To achieve this, our objectives are to:

PROTECT the right opportunities in the right places
ENHANCE opportunities through better use of existing provision
PROVIDE new opportunities to meet the needs of current and future generations.

Sport England's aim in working with the planning system is to help provide active environments that maximise opportunities for sport and physical activity for all, enabling the already active to be more so and the inactive to become active. The importance of sport should be recognised as a key component of local plans, and not considered in isolation.

The following comments are provided within the context of:
The National Planning Policy Framework (DCLG, 2021).
Sport England's Planning for Sport webpages including Planning for Sport Guidance https://www.sportengland.org/how-we-can-help/facilities-and-planning/planning-for-sport

Sprowston Town Council opposes the proposed modifications on the basis that the modifications are unsustainable and unsound. Should the inspector be minded to approve the modifications, the Town Council requests removal of the high school land option expiry date of 1st April 2026. The option to build a high school on GNLP0132 should remain safeguarded until such time as a final decision on the new high schools' location is made; however long that may take.

Norfolk County Council as the Mineral and Waste Planning Authority wish to raise the following objections regarding the proposed Main Modifications to the Greater Norwich Local Plan.

Main Modifications relating to Safeguarded Mineral Resource, Mineral Infrastructure or Waste Management site.

We note that in the main modifications the policy text regarding safeguarded mineral resources and safeguarded sites is proposed to be removed from all of the relevant site allocation policies and moved into the supporting text. This affects over 30 allocated sites. We understand that this change was proposed by the Inspector because he considered that the current text was not a policy requirement and was simply signposting to another policy of the development plan and as a result was unsound. We disagree with this approach and consider that it is, and should be, an allocation policy requirement to ensure that safeguarded mineral resources are not sterilised by non-mineral development where this could be avoided. We are therefore objecting to the removal of the reference to mineral safeguarding from the site allocation policy wording. The affected policies were not unsound when they included the mineral safeguarding requirement, therefore the modifications proposed to remove the mineral safeguarding requirement are not required to make the document sound.

We consider that it is appropriate and relevant for the requirements of a strategic policy, in this case Policy CS16 within the Norfolk Minerals and Waste Core Strategy, to be included in a site allocation policy where it sets out how the policy will apply to a specific site at the development management stage. We accept that including this wording as a cross reference to Policy CS16 may not be the most appropriate way to include this information in the site allocation policies and therefore we have proposed alternative policy wording which we consider addresses the Inspector's concerns.

Removing the mineral safeguarding requirement from the site policies would be unsound because it would not be in accordance with the NPPF (paragraph 212) which states that local planning authorities should not normally permit other development proposals in Mineral Safeguarding Areas if it might constrain potential future use for mineral working. Further information is provided in the NPPG paragraph 005 Reference ID: 27-005-20140306.

For site located in proximity to existing safeguarded mineral infrastructure or waste management facilities, the agent of change principle (NPPF paragraph 187) is also relevant.

We consider that for the sites that are underlain by safeguarded mineral resource the policy wording should state: "This site is underlain by a safeguarded mineral resource; therefore investigation and assessment of the mineral will be required, potentially followed by prior extraction to ensure that needless sterilisation of viable mineral resource does not take place."

Relevant sites:
MM69/70 Policy COL1/GNLP0331BR/GNLP0331CR
MM78 Policy GNLP0307/GNLP0327
MM81 Policy EAS1
MM83 Policy HEL2
MM87 Policy GNLP0132
MM88 Policy 0337R
MM110 Policy HET1 (part of GNLP0177A)
MM137 Policy HNF2/GNLP0466R
MM26 Policy GNLP0133DR
MM40 Policy CC4a
MM52 Policy R1
MM62 Policy R30
MM63 Policy R31
MM64 Policy R36
MM65 Policy R37
MM71 Policy COL2 (GNLP0140C)
MM79 Policy KES2 (including GNLP0497)
MM82 Policy HEL1
MM85 Policy GNLP0172
MM89 Policy GNLP0159R
MM90 Policy TROW1
MM111 Policy HET2
MM118 Policy POR3
MM119 Policy REP1
MM122/MM124 Policy GNLP0293/CAW2
MM130 Policy FOU2
MM148 Policy BKE3
MM72 Policy GNLP0253
Plus the following sites where the policy in the pre submission GNLP document did not include a safeguarding requirement:
MM80 Policy DRA1
MM103 Policy GNLP0378R/GNLP2139R
MM115 Policy 0312
MM116 Policy GNLP0463R
MM92 GNLP0596R

We consider that for the site that is within a mineral infrastructure site consultation area the policy wording should state: "The site is within the consultation area for safeguarded mineral infrastructure; therefore, the development must not prevent or prejudice the use of the existing safeguarded infrastructure for those purposes unless suitable alternative provision is made, or the applicant demonstrates that the site no longer meets the needs of the aggregate industry."

Relevant site:
MM48 Policy CC16

We consider that for the sites that are within a waste management site consultation area the policy wording should state: "The site is within the consultation area for a safeguarded waste management facility; therefore, the development must not prevent or prejudice the use of the existing waste management facility unless suitable alternative provision is made, or the facility is demonstrated to no longer be required."

Relevant sites:
MM74 Policy COS3/GNLPSL2008
MM100 Policy HETHEL2
Plus the following sites where the policy in the Pre Submission GNLP document did not include a safeguarding requirement:
AYL3
AYL4