Object
Strategy
Representation ID: 25304
Received: 22/11/2023
Respondent: Historic England
East Norwich
Whilst we welcome the reduction in site capacity for East Norwich to 3362 homes (elsewhere 3000 in the housing numbers table) we remain concerned as to whether this can be realistically achieved without harming the historic environment. Is there a reason for the difference in numbers between the table and the text? Should these be consistent?
Thank you for consulting Historic England about the Proposed Modifications to the Greater Norwich Local Plan. We have the following comments to make on the suggested changes to the Plan:
We welcome many of the proposed Main Modifications. Our detailed comments on the proposed Main Modifications to the Plan are set out in Appendix A.
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
The key outstanding issue relates to East Norwich. We remain particularly concerned about the location of development around the Abbey. We have suggested revised policy wording in Appendix A, reflecting our earlier advice in our hearing statement and at EiP. We have raised these concerns in relation to the emerging SPD too.
Other policies
There are a number of other more minor issues relating to wording for the following policies/sites:
MM8 Policy 2 Sustainable Communities
MM13 Policy 7.1The Norwich Urban Area including the Fringe - East Norwich
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
MM33 GNLP1061R Norwich Airport
MM43 CC8 King Street Stores
MM92 GNLP0596R Land at Norwich Road, Aylsham
MM100 Hethel2 Land south and south west of Lotus Cars, Hethel
Our concerns in relation to the above sites set out in Appendix A reflect the proposed wording set out in our SOCG with the Council.
Archaeology Criterion
In a number of policies in the Local Plan, there have been amendments made to a policy criterion relating to archaeology. The criterion previously read 'Historic Environment Record to be consulted to determine any need for archaeological surveys prior to development' and now reads, 'An archaeological assessment will be required prior to development'.
Whilst this is an improvement on the previous wording, we suggested that the policy would be even better is it read, 'Planning applications should be supported by a desk based archaeological assessment and, where necessary, the results of a field evaluation as advised by the LPAs archaeological advisors'. This is accordance with para 194 of NPPF.
Finally, we would like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.
Support
Strategy
Representation ID: 25305
Received: 22/11/2023
Respondent: Historic England
We welcome the simplification of the policy in relation to East Norwich and the move to include the site specific information in a separate policy and avoid (potentially inconsistent) duplication of policy requirements.
Thank you for consulting Historic England about the Proposed Modifications to the Greater Norwich Local Plan. We have the following comments to make on the suggested changes to the Plan:
We welcome many of the proposed Main Modifications. Our detailed comments on the proposed Main Modifications to the Plan are set out in Appendix A.
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
The key outstanding issue relates to East Norwich. We remain particularly concerned about the location of development around the Abbey. We have suggested revised policy wording in Appendix A, reflecting our earlier advice in our hearing statement and at EiP. We have raised these concerns in relation to the emerging SPD too.
Other policies
There are a number of other more minor issues relating to wording for the following policies/sites:
MM8 Policy 2 Sustainable Communities
MM13 Policy 7.1The Norwich Urban Area including the Fringe - East Norwich
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
MM33 GNLP1061R Norwich Airport
MM43 CC8 King Street Stores
MM92 GNLP0596R Land at Norwich Road, Aylsham
MM100 Hethel2 Land south and south west of Lotus Cars, Hethel
Our concerns in relation to the above sites set out in Appendix A reflect the proposed wording set out in our SOCG with the Council.
Archaeology Criterion
In a number of policies in the Local Plan, there have been amendments made to a policy criterion relating to archaeology. The criterion previously read 'Historic Environment Record to be consulted to determine any need for archaeological surveys prior to development' and now reads, 'An archaeological assessment will be required prior to development'.
Whilst this is an improvement on the previous wording, we suggested that the policy would be even better is it read, 'Planning applications should be supported by a desk based archaeological assessment and, where necessary, the results of a field evaluation as advised by the LPAs archaeological advisors'. This is accordance with para 194 of NPPF.
Finally, we would like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.
Object
Strategy
Representation ID: 25421
Received: 06/12/2023
Respondent: Anglian Water Services Ltd
East Norwich Strategic Regeneration Area: We note the modifications to this section of the policy and support the requirement that the redevelopment of the ENSRA will be guided by an area-wide Supplementary Planning Document. As Anglian Water has critical operational sewerage assets within the ENSRA allocation (sewerage pumping stations and rising mains), we would seek an amendment to the modifications to include critical sewerage infrastructure within the local issues section.
We note the modifications to this section of the policy and support the requirement that the redevelopment of the East Norwich Strategic Regeneration Allocation (ENSRA) will be guided by an area-wide Supplementary Planning Document. As Anglian Water has critical operational sewerage assets within the ENSRA allocation (sewerage pumping stations and rising mains), we would seek an amendment to the modifications to include critical sewerage infrastructure within the local issues section as follows - new text in square brackets[]:
"Development must also protect and enhance biodiversity and green infrastructure; provide for sustainable energy provision and its management; conserve, and where opportunities arise, enhance the significance of heritage assets; and address local issues including: the active railway, the protected minerals railhead, [critical sewerage infrastructure], noise, contamination and flood risk issues."
Anglian Water has informally engaged with the preparation of the ENSRA SPD and has raised the matters regarding our critical sewerage infrastructure within the allocation, and will continue to formally engage through the consultation process for the SPD in due course. We would seek the amendment to this modification to ensure that specific regard is had to our infrastructure in the design and layout of ENSRA, specifically on the Deal Ground part of the site.
Comment
Strategy
Representation ID: 25423
Received: 06/12/2023
Respondent: Natural England
To comply with para 176 of the NPPF, under the East Norwich heading of the policy we recommend inserting "take account of its setting adjacent to the Broads" into the section of policy below, as follows :
"Development must also protect and enhance biodiversity and green infrastructure; take account of its setting adjacent to the Broads; provide for sustainable energy provision and its management; conserve, and where opportunities arise, enhance the significance of heritage assets; and address local issues including the active railway, the protected minerals railhead, noise, contamination and flood risk issues."
To comply with para 176 of the NPPF, under the East Norwich heading of the policy we recommend inserting "take account of its setting adjacent to the Broads" into the section of policy below, as follows :
"Development must also protect and enhance biodiversity and green infrastructure; take account of its setting adjacent to the Broads; provide for sustainable energy provision and its management; conserve, and where opportunities arise, enhance the significance of heritage assets; and address local issues including the active railway, the protected minerals railhead, noise, contamination and flood risk issues."
Comment
Strategy
Representation ID: 25472
Received: 06/12/2023
Respondent: Serruys Property Co. Ltd
Agent: Maddox Planning
We continue to support the allocation following previous representations we have submitted. Specifically, we support the policy with regard to proposals coming forward at different time scales. It is noted that target housing numbers has reduced to 3000, however this should be barrier to deliver more homes within the allocation and each application should be determined on a design based approach to ensure the most efficient use of land and ultimately address housing need. Also, given the complex nature of the East Norwich Strategic Regeneration Area (SRA), and the effects of nutrient neutrality, it is right that there is flexibility on the level of affordable housing requirements in general policy, allowing the masterplan to address deliverability of the SRA.
Additionally, we continue to support the allocations inclusion of all land within the extant planning permission 12/00875/O and 2011/0152/O; the extant consent for May Gurney Headquarters site [and] within policy GNLP0360 (Deal Ground, Trowse Pumping Station and May Gurney). The regeneration of the area should not overlook the commercial/industrial existing use and opportunities including projects linked to renewable energy. For instance, if the prevailing economic and market conditions at the time do not allow for a viable residential solution, commercial alternatives should be sought, either in part or as a whole.
The regeneration area includes a CWS, which does not preclude development, and so a clear and unambiguous policy is required to assess the acceptability of proposals that will affect it. We therefore propose that Policy 7.1 is amended to set out a clear benefit a development can provide, such as 10% biodiversity net gain. Please see our representation to Policy 3, which should be referred to in Policy 7.1.
We continue to support the allocation following previous representations we have submitted. Specifically, we support the policy with regard to proposals coming forward at different time scales. It is noted that target housing numbers has reduced to 3000, however this should be barrier to deliver more homes within the allocation and each application should be determined on a design based approach to ensure the most efficient use of land and ultimately address housing need. Also, given the complex nature of the East Norwich Strategic Regeneration Area (SRA), and the effects of nutrient neutrality, it is right that there is flexibility on the level of affordable housing requirements in general policy, allowing the masterplan to address deliverability of the SRA.
Additionally, we continue to support the allocations inclusion of all land within the extant planning permission 12/00875/O and 2011/0152/O; the extant consent for May Gurney Headquarters site [and] within policy GNLP0360 (Deal Ground, Trowse Pumping Station and May Gurney). The regeneration of the area should not overlook the commercial/industrial existing use and opportunities including projects linked to renewable energy. For instance, if the prevailing economic and market conditions at the time do not allow for a viable residential solution, commercial alternatives should be sought, either in part or as a whole.
The regeneration area includes a CWS, which does not preclude development, and so a clear and unambiguous policy is required to assess the acceptability of proposals that will affect it. We therefore propose that Policy 7.1 is amended to set out a clear benefit a development can provide, such as 10% biodiversity net gain. Please see our representation to Policy 3, which should be referred to in Policy 7.1.
Comment
Strategy
Representation ID: 25481
Received: 04/12/2023
Respondent: Stantec UK Ltd
Policy 7.1 - The Norwich Urban Area including the Fringe Parishes
Our Client supports the increase in housing numbers within Thorpe St Andrew (404 increased from 386), however the 404 dwellings is based on existing planning permissions (including completions 2018/19- 2021/22) and it is unclear whether this includes the existing outline planning permissions of up to 231 dwellings at Pinebanks (ref.20130649) and up to 71 dwellings at Griffin Lane (ref. 20130650), which were confirmed lawfully implemented through CLEUDs (ref. 20181334 and 20181533 respectively).
In addition, there are no new allocations within Thorpe St Andrew and the housing numbers do not take consideration of forecasted units through existing applications that sit outside of allocated sites. As noted in the paragraph above, there are up to 302 dwellings deliverable at Pinebanks and Griffin Lane through the existing planning permissions and, as set out within our previous representations of 23rd March 2023, there are current live outline planning applications for up to 265 dwellings at Pinebanks (ref.20212058). up to 90 dwellings at Langley North (ref. 20212059), up to 70 dwellings at Langley South (ref. 20212060) and up to 130 dwellings at Griffin Lane (ref. 20212061), all owned by the Client. It is considered the sites are sustainable previously developed land and would provide a significant contribution to housing numbers (up to 550 dwellings, 248 units over what it already permitted across the Pinebanks and Griffin Lane sites) within the Norwich Urban Area which should be taken into account.
Representations to the Main Modifications of the Greater Norwich Local Plan (GNLP) on behalf of Berliet Limited
Pinebanks, Langley North, Langley South and Griffin Lane, Thorpe St Andrew
We write on behalf of Berliet Limited ('the Client') in respect of the consultation on main modifications to the Greater Norwich Local Plan (GNLP) and to make representations in respect of the above Sites, which are in control of our Client.
Policy 1 - The Growth Strategy
It is unclear why the overall housing figures set out in Table 6, Table 7 and Policy 1, both the figures for delivery within the Plan period and the figures for the Greater Norwich Area, have been reduced significantly other than reflecting the amendments to the total forecast supply buffer in Table 6 being reduced from 22% to 11%. Further evidence for this reduction should be provided and new site allocations proposed to account for further housing delivery, where necessary. If the reduction to housing numbers is as a result of nutrient neutrality impacts on development, this should be clearly stated.
Policy 2 - Sustainable Communities
In principle, the proposed amendments to Policy 2 part 4 which seek to focus density, taking account of accessibility and local character, are supported. However, it is suggested that the current specified target of a minimum net density of 25dph elsewhere in the Plan area outside of Norwich City Centre be reconsidered in order to make the most efficient use of land in accordance with paragraph 124 of the NPPF and in light of the reductions in housing numbers reflected above in respect of Policy 1.
NPPF paragraph 125 states that plans should optimise use of land and meet as much of the identified need for housing as possible, including use of minimum density standards for city and town centres and other locations served well by public transport that seek a "significant uplift in the average density within these areas, unless it can be shown there are strong reasons why it would be inappropriate". A range of minimum densities for other parts of the plan area may be appropriate to "reflect the accessibility and potential of different areas, rather than one broad density range".
It is considered that higher densities above 25dph may be suitable outside of Norwich City Centre where development makes the most efficient use of land on sustainable sites to meet identified needs for housing and other forms of development. Given the broad range of urban and landscape characteristics across the Plan area outside of Norwich City Centre, a range of densities would be suitable, where the development is well designed and served by sufficient infrastructure, in order to give greater flexibility and respond to local context.
Policy 3 - Environmental Protection and Enhancement
Our Client supports in principle the removal of mitigation contributions being determined by the Norfolk Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy. This is considered to enable flexibility as different mitigation providers and packages continue to come forward.
The proposed amendments to Policy 3 should confirm what evidence would be required for the Local Planning Authority to conclude through a Habitats Regulations Assessment that the proposal will not adversely affect the integrity of sites, and define what is meant by both "site integrity" and "unfavourable condition".
In addition, there needs to be an agreed mechanism for regular review of the protected sites to establish what their condition is and whether or not continued mitigation is required and, if so, what and where. The conditions within each catchment and at protected sites will continue to change over time as they respond to proposed mitigation measures, therefore any future mitigation requirements should reflect this. Any proposed mitigation approach needs to take account both of the existing established/lawful use of sites, and of the mix of units proposed on any site.
Policy 5 - Homes
Our client supports in principle the removal of "brownfield sites" when referring to applicant's demonstrating that particular circumstances justify the need for a viability assessment at decision-making stage. It is considered that the assessment of viability should not be restricted solely to brownfield sites, as greenfield sites within Norwich Urban Area and Fringe are still urban in nature, with the same challenges as brownfield sites, and therefore should be afforded the same flexibility in relation to viability.
The removal of the requirement to provide 10% of affordable homes as available for affordable home ownership, where it meets local need, is also supported in principle by our Client. Removing this requirement provides greater flexibility for development to take account of the market and could lead to a greater number and or more varied types of affordable housing provision.
Policy 7.1 - The Norwich Urban Area including the Fringe Parishes
Our Client supports the increase in housing numbers within Thorpe St Andrew (404 increased from 386), however the 404 dwellings is based on existing planning permissions (including completions 2018/19- 2021/22) and it is unclear whether this includes the existing outline planning permissions of up to 231 dwellings at Pinebanks (ref.20130649) and up to 71 dwellings at Griffin Lane (ref. 20130650), which were confirmed lawfully implemented through CLEUDs (ref. 20181334 and 20181533 respectively).
In addition, there are no new allocations within Thorpe St Andrew and the housing numbers do not take consideration of forecasted units through existing applications that sit outside of allocated sites. As noted in the paragraph above, there are up to 302 dwellings deliverable at Pinebanks and Griffin Lane through the existing planning permissions and, as set out within our previous representations of 23rd March 2023, there are current live outline planning applications for up to 265 dwellings at Pinebanks (ref.20212058). up to 90 dwellings at Langley North (ref. 20212059), up to 70 dwellings at Langley South (ref. 20212060) and up to 130 dwellings at Griffin Lane (ref. 20212061), all owned by the Client. It is considered the sites are sustainable previously developed land and would provide a significant contribution to housing numbers (up to 550 dwellings, 248 units over what it already permitted across the Pinebanks and Griffin Lane sites) within the Norwich Urban Area which should be taken into account.
Object
Strategy
Representation ID: 25491
Received: 11/12/2023
Respondent: Wain Estates
Agent: Stantec
Object to deletion of Costessey Contingency Site
The Council has amended the GNLP to delete section 8 which relates to the Costessey Contingency Site. Given this deletion of Policy GNLP0581/2043 supporting text at Policy 7.1 (MM13) which reads ‘ a large contingency site is identified in Costessey to be brought forward if delivery of
housing in the GNLP area does not meet local plan targets’ and paragraphs 3.20 and 3.21 (MM76) have also been deleted.
We assume that the Inspectors are in agreement that the principle of the contingency site is consistent with national policy 2 but that the issue, as raised in the Inspectors’ letter, is that the trigger mechanism is not deemed to be effective and nor could it be reasonably be made effective by modification. We respectfully disagree with this position as the suggested wording we put forward in our Matter 3 statement (repeated below) would be responsive and therefore successful in producing the desired or intended result of resolving an issue with the housing supply in the Plan:
‘The site will become an allocation for development if any of the following apply at any point in the Plan period:
a) the Council’s Housing Delivery Test shows that delivery has fallen below 95% in the previous year; or
b) if annual monitoring data indicates that forecast housing land supply falls lower than 5.5 years; or
c) net affordable housing delivery (as a percentage of overall housing delivery) falls below 28% over a period of two consecutive years’
Reference is also made in the Inspectors’ letter to there not being a need for the contingency as the housing supply will be ‘sufficient’ to meet housing needs in the Plan period.
We respectfully again disagree and therefore object to this deletion on the basis that removing this site, which could deliver up to 800 homes and supporting infrastructure on a site which, by the Council’s own assessment, is relatively unconstrained and in a sustainable location
consistent with the spatial strategy and objectives of the Plan. Deleting this contingency allocation would undermine the previously identified benefits the site presented in terms of securing flexibility and security of housing supply; which for reasons we set out above and in our earlier representations, is at risk for a number of factors including Nutrient Neutrality.
The purpose of GNLP20943/0581 as a contingency site was that when a specific trigger was met the site would become an allocation. The trigger was originally proposed as follows (we have suggested changes as above):
‘…if there are three consecutive years in which Annual Monitoring Reports show that housing completions in Greater Norwich are more than 15% below annual targets in each year and where under-delivery is the result of site specific constraints (for example there are infrastructure or ownership constraints or significant abnormal costs have been identified) preventing the delivery of committed and allocated housing sites.’
In the Inspectors response, a primary reason for the MM, omitting the contingency site, was that the ‘trigger mechanism is ineffective and could not be madereasonable by modification’
When taken against the updated Housing Delivery Trajectory Document (MM20, now Appendix 4) which establishes a residual annual housing requirement of 1990 homes, a 15% under delivery can be calculated as just 299 homes per annum. That is, any year with a delivery of 1,691 homes or less would surpass this ‘trigger’. In light of potential risks to supply, including the
implications of Nutrient Neutrality upon housing delivery at major sites within the GNLP catchment, the requirement for this contingency site is not unreasonable or unjustified.
As detailed at our response to MM9 above, Nutrient Neutrality has stalled progress and held up delivery of thousands of homes withinthe Local Plan area. The Council have acknowledged, in previous Housing Trajectories, namely that of April 20224 that of the 37,651 forecast housing supply to 2038, 23,948 of these would be impacted/delayed by Nutrient Neutrality.
The updated Housing Trajectory 5 published as part of this Main Modifications stage, ‘Appendix 4’ establishes a ‘Total Forecast Supply’ of 45,041’ which exceeds the requirement for 40,541 to 2037/38. This requirement figure accounts for average delivery 2018/19 to 2021/22 for which annual housing completions kept pace with meeting the need for 40,541 homes by 2038.
Notwithstanding this, average completion progress is based four years prior to the issue of Natural England’s Nutrient Neutrality advice. Following this advice made on 16th March, the GNLP acknowledged minimum delays of 18 months for residential schemes (as set out in our Matters 15 response, ID 24244).
At this current time progress towards certainty around Nutrient Neutrality remains limited and thus impacted development is still stalled. On 13th September 2023, 16 months following the announcement, the House of Lords voted on government proposals which were intended to unlock 100,000 homes between 2023 and 2030 in areas affected by Nutrient Neutrality. However, the necessary amendments to the LURB (now LURA) were not supported in the House of Lords and therefore were not added to the Bill. As such, Nutrient Neutrality, and the resulting delays to housing delivery remain with the Government still to make further announcements. Most recently Government has been reported to confirm that no legislative changes are on the
horizon, with no mention of the issue through the King’s Speech or the Autumn Statement, other than additional funding for mitigation through the Nutrient Mitigation Fund. Whilst the GNLP anticipated an 18-month delay, we suggest that delays are likely to be significantly greater than this as many parts of the country affected by this are still left without mitigation solutions (or at least sufficient mitigation to release all housing required to meet local plan requirements) for 4 -5 years, if not more. This could skew the housing trajectory and implicate delivery of a sufficient supply of homes, particularly in the first 5 years of the plan.
Given the uncertainty presented with regard to housing trajectory, it is critical that additional sites for housing are identified. We strongly object to the omission of the Costessey contingency site on the basis that the flexibility it affords is imperative to the effectiveness of the Local Plan.
The Sustainability Appraisal of the Main Modifications (October 2023) states that ‘new and amended policies would be expected to improve the sustainability performance of the GNLP or would have no significant change with regard to sustainability’. We disagree, not only in relation to the benefits a sustainable site in an accessible location could provide in terms of housing supply in the early years and throughout the Plan period, but also in relation to the unrealised benefits of the contingency site not coming forward, notably around education.
The proposed to be deleted allocation included a requirement that ‘approximately 4 hectares of the site should be safeguarded for education to provide a new primary school and a sixth form college in agreement with the education authority’.
As we have set out in our Matter 5 statement, which includes a Statement of Common Ground with the Local Education Authority, there is significant pressure for secondary school places in the locale, which necessitates the loss of the Ormiston Victory Academy sixth form to expand secondary provision to meet the demand from existing housing growth. Given that one of the
objectives of the Local Plan is to increase inter alia secondary school provision to facilitate this housing growth, one of the infrastructure requirements for the site at Costessey was that ‘approximately 4 hectares of the site should be safeguarded for education to provide a new
primary school and a sixth form college in agreement with the education authority’. This was agreed, as reflected within the Statement of Common Ground with the Education Authority (Appendix 2). Our Education Impact and Mitigation Assessment (EIMA), submitted at part of our Matter 5 response (Appendix 3), explores the Plan’s education requirements. Relating to Sixth Form
need the EIMA sets out that on the basis of ONS population projections, from a baseline date of mid-2021 the number of for 17 and 18 year-olds living in the Norwich, South Norfolk and Broadland District areas is predicted to increase every year until 2030. Between mid-2021 and mid-2030 a 26% increase can be expected. The demand for sixth form places is therefore expected to increase significantly in the foreseeable future. There is a need to increase the supply of Sixth
Form places in the Plan period to meet the current and planned need for housing. It is a clear requirement of National policy to deliver adequate education infrastructure (see NPPF 16, 20, 22, 24-27, 31 and 35). Despite this, there is no identified alternative site for a replacement sixth form college other than our
site. Without our site, there will be insufficient secondary or sixth form places to meet the identified growth in the Plan and will lead to unsustainable patterns of travel
given the lack of sixth form options locally. This will undermine the Plan and its objective to deliver ‘vibrant, healthy, inclusive and growing communities supported by the delivery of new homes, infrastructure’, as set out in our response to Matter 1.
Thank you for inviting comments on the Greater Norwich Development Partnership (2021) Greater Norwich Local Plan (GNLP) Main Modifications (Section 20(7C) of the Planning and Compulsory Purchase Act 2004) Consultation. These representations are made on behalf of Wain Estates, an experienced site promotion company, who have secured land on the edge of Costessey, referred to as ‘Land off Bawburgh Lane, Costessey’ (the ‘Site’). The site was secured from Terra Strategic, who have previously promoted the site through the GNLP Examination, when it was a draft contingency allocation. Wain Estates control the majority of the site, with the remainder controlled by Norwich City Council (Property and Economic Development Team), who are supportive of the development proposal and have agreed for Wain Estates to take the lead with promotion of the Site
through the Local Plan process.
These representations follow on from the previous representations made by Terra Strategic.
We respond to the Main Modifications Stage 20(7C) Submission Draft Local Plan which identifies a
joint planning strategy for growth across the Greater Norwich area (comprising Norwich City, Broadland and South Norfolk District) for the period 2018 -2038. Specifically in relation to the Site. Our main objection relates to the proposed deletion of our Client’s contingency site, which was suggested in the Inspectors’ letter dated 9th August 2023.
See attached submission
Object
Strategy
Representation ID: 25506
Received: 11/12/2023
Respondent: Norfolk Wildlife Trust
Policy 7.1 The Norwich Urban Area including the fringe parishes
Point 5 The Built, Natural and Historic Environment: The wording of the final bullet point for this section has been weakened by changing the wording ‘assist in delivering’ to ‘have regard to’ the River Wensum Strategy. We recommend that the original wording be used.
East Norwich: We note that the new text removes mention of corridors and enhancing linkages, as well as removing the mention of local energy networks. We recommend that these be re-inserted.
Greater Norwich Local Plan: Main Modifications Consultation
Please find comments from Norfolk Wildlife Trust regarding the main modifications on the Greater Norwich Local Plan below.
Policy 1: The Sustainable Growth Strategy
We welcome the inclusion of the new paragraph 187 which recognises that at present, there is no need to pursue the development of a new settlement.
On map 7 it states there are 1,919 houses from windfall, whereas table 6 gives a windfall allowance of 830.
We ask for clarification on which windfall figure is correct, in order to ensure that there aren’t any outstanding errors in the collective/overall (sites & windfall) allocation numbers.
Policy 2: Sustainable Communities
Point 1: We support the inclusion of reference to non-car modes and the encouragement of walking, cycling and public transport in relation to ensuring access to developments.
Point 3: We support the inclusion of street trees and other tree planting.
Point 4: We support the inclusion of the following sentence: “In the most accessible locations in Norwich, regard should be given to providing low or car-free housing in accordance with Policy DM32 of the Norwich Development Management Policies Local Plan”, but recommend that in order to ensure delivery of this policy in planning decisions that a more objective goal is set in the policy requirements, such as ‘In the most accessible locations in Norwich, low or car-free housing should be delivered in accordance with Policy DM32 of the Norwich Development Management Policies Local Plan’.
Point 7: We support the inclusion of this new sentence.
Point 8: We support this inclusion of this new wording around flood risk and water efficiency.
Point 9: We are disappointed that the final sentence “If the potential to set more demanding standards locally is established by the Government, the highest potential standard will be applied in Greater Norwich” has been removed and recommend that this be re-inserted.
Point 10: We object to the revision of this paragraph. Promoting the use of established assessment frameworks can be a resource-efficient way of delivering better quality and higher standards in new developments. There is an urgent need to build genuinely net-zero buildings as soon as possible. A significant role therefore remains for local planning authorities in setting binding netzero policies that are more ambitious than the Building Regulations.
Policy 3: Environmental Protection and Enhancement
The Natural Environment - “Development proposals [will be required to conserve and (deleted text)] should (added text) enhance the natural environment” We recommend that this be changed to ‘Development proposals will be required to enhance the natural environment, through the following measures, where applicable’ in order to restore the certainty of delivery in the previous wording whilst reflecting the updated focus on nature’s restoration in current national policy.
We note that the wording in the paragraph about biodiversity net gain has been amended: “[It will need to (deleted text)] should (added text) be demonstrated”. We recommend that this be changed back to ‘It will need to be demonstrated’ in order to restore the certainty of delivery in the previous wording whilst reflecting the updated focus on nature’s restoration in current national policy.
We welcome the inclusion of the reference to provision or enhancement of green infrastructure.
We support the inclusion of the new paragraphs regarding the requirement for a Habitats Regulations Assessment on proposals that may adversely affect European sites and the statement that applications will be refused if it cannot be ascertained that there will be no adverse impact.
Policy 4 Strategic Infrastructure
Transport
We are disappointed to see the inclusion of reference in the GNLP for the proposed Norwich Western Link (NWL) development by Norfolk County Council as a regional connectivity project. At a previous consultation stage for the GNLP we received confirmation that the NWL is not necessary for the delivery of any of the allocations in the plan and recommend that the policy wording here is revised to make it clear that there is no direct policy support in the GNLP for this controversial proposal, which we understand is due to be submitted as a planning application in 2024.
Due to the national importance for bat conservation of the woodlands and surrounding landscape on the proposed NWL route (and compliance with the multiple wildlife laws protecting bat roosts from disturbance, damage and destruction), we do not consider that it is possible that the NWL can be delivered, and consider that the need and deliverability of the proposal should not be taken for granted and given any policy weight in the GNLP. We therefore strongly recommend that the wording of the regional connectivity section of this policy is revised to only reference elements which have demonstrated they are necessary for the delivery of the GNLP.
Policy 6 The Economy
Point 2: We note the new paragraph “Support for rural enterprises through the conversion of rural buildings, the development and diversification of agricultural and other land based rural businesses and well-designed new build. If new build development is proposed to meet local business and community needs in rural areas the use of previously developed land and sites that are physically well-related to existing settlements should be encouraged where suitable opportunities exist. For sites beyond existing settlements and in locations not well served by public transport then development should be well designed and sensitive to its surroundings, should not have an unacceptable impact on local roads and should exploit any opportunities to make the location more sustainable.” We recommend the addition of wording that any new development should not have an unacceptable impact on the environment.
Policy 7.1 The Norwich Urban Area including the fringe parishes
Point 5 The Built, Natural and Historic Environment: The wording of the final bullet point for this section has been weakened by changing the wording ‘assist in delivering’ to ‘have regard to’ the River Wensum Strategy. We recommend that the original wording be used.
East Norwich: We note that the new text removes mention of corridors and enhancing linkages, as well as removing the mention of local energy networks. We recommend that these be re-inserted.
Policy 7.6 New Settlements
We support the deletion of this policy for new settlements.
Sites
General comment: We support the change of wording in site specific policies to strengthen the protection of trees (eg Point 3 and paragraph 2.140). We recommend updated policy wording to be applied consistently across all other site allocation policies where applicable.
Norwich Policy GNLP0360/ 3053/R10 East Norwich Strategic Regeneration Area (ENSRA)
Point 13a: states that “Development must allow scope for greater use of the Rivers Wensum and Yare for water based recreation, leisure and tourism including the potential inclusion of marinas and riverside moorings”. We recommend that additional text is added to stipulate that this would not have an adverse impact on the nature conservation value of these rivers.
We support the addition of text outlining the need for new developments for all sites within ENSRA to include high-quality pedestrian and cycle routes.
Monitoring Framework
Table 3 Sustainability Appraisal Indicators
We suggest including “rates of active travel (walking and cycling)” as an indicator within the air theme, with a target to ‘increase’. This will demonstrate policy effectiveness of policy 2 ‘sustainable communities.
We recommend that the percentage loss of the ecological network indicator within the biodiversity, flora and fauna theme needs revision, as it has no metric to measure it by at present. We suggest that this monitoring target covers the extent of priority habitats (as measured on MAGIC mapping) as an interim metric. This can be revisited this once the Nature Recovery Network map is completed.
We recommend the inclusion of an indicator reflecting population number of protected species within the biodiversity, flora and fauna theme, with a target of increasing population sizes.