Draft Greater Norwich Local Plan – Part 1 The Strategy

The proposed 2040 ban on petrol and diesel engines specified at paragraph 9 will need updating to 2032 - 2035 in light of the Governments’ consultation on this announced 4/2/2020.

The overall purpose of the plan is generally set out clearly within the introduction. However, Glavenhill Ltd make the following observations and suggestions:

a) It would be useful if the base date of the plan was set out in the introduction as well as the end date of 2038 to save hunting for this in the document.

b) The commitment in paragraph 5 to “build on our strengths” and particularly “to help turn our world class knowledge and ideas into world class jobs, particularly in sciences and biotechnology, agri tech, food and drink, information and communication technology (ICT), digital creative industries and high-value engineering” is supported.

Our concern is whether this commitment will be achieved through the preferred growth strategy and particularly whether the allocations for housing and employment are adequate and in the right place to achieve this goal. We will expand upon this point later in our representations.

c) Paragraph 9 rightly recognises that upcoming bans on fossil fuels in homes and cars will become major factors affecting development through the plan period, particularly in relation to energy policy and transportation. Our concern is whether this is a clear reflection of what the preferred growth strategy will actually help achieve, particularly with regard to transportation. We will expand upon this point later in our representations.

d) Paragraph 12 identifies important strategies and initiatives including the LEP’s Norfolk and Suffolk Economic Strategy (2017) and the Cambridge-Norwich Tech Corridor initiative (2018) both of which have been signed up to by the Greater Norwich local authorities. Lanpro suggest that greater clarity is needed on how the plan knits together with and supports these strategies in a meaningful way.

e) Paragraph 13 refers to the Greater Norwich City Deal Growth requirements agreed with Government in 2013 being met through the Greater Norwich Local Plan. The introduction should explain what the City Deal requirements are in terms of numbers, otherwise the reference is meaningless to readers, particularly the general public. Either in the introduction or elsewhere in the document should be an explanation of how these numbers have been accounted for in the overall housing requirement. This is currently unclear within the document.

f) An approach as set out at paragraph 22, that looks beyond the end date of the plan by setting a strategy that can be sustainably added to in the long term is important and is supported in principle.

g) Paragraph 24 explains that new allocations on small sites in South Norfolk villages are not included in the document. Paragraph 25 states:

“In South Norfolk there are more villages clustered around more primary schools. South Norfolk, therefore, intend to prepare a separate village clusters plan covering new sites for small scale housing in the rural parishes that collectively form primary school clusters.”

This statement does not provide clear reasoning for the omission of these sites from the draft plan at this stage. Firstly, it does not explain “more villages” in comparison to where, or what. It also doesn’t justify why even if there is more primary school clustering in South Norfolk than presumably Norwich or Broadland, this should be the deciding factor in determining the growth strategy for South Norfolk. The Cambridge-Norwich Tech corridor runs through South Norfolk District and paragraph 5 of the introduction puts the focus on planning to and building on our strengths, particularly referencing the Cambridge-Norwich Tech Corridor and its high value jobs. It would, therefore, make much more sense if this was a main consideration in the choice of locations for housing within South Norfolk.

A clear justification is needed if a strategy of significant dispersal (as proposed at present) to small sites in the rural area and towns like Diss and Harleston is to provide the focus in South Norfolk, otherwise it is difficult to understand how this can be a sound approach. It places doubt upon the intent in paragraph 5 to build upon the strengths identified therein and also upon the delivery of the Vision for Greater Norwich in 2038 set out in paragraph 108. This states:

“by promoting this Greater Norwich Local Plan our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech corridor.”

An explanation should be provided as to how the number of 1200 homes (15% of new allocations) can be relied upon on small sites in South Norfolk when the sites have not yet been identified or assessed.

We consider that it is premature to ask stakeholders to comment on the acceptability of an overall growth strategy for the next 20 years, when 15% of the new allocations are missing. We appreciate the intent to get on with producing the plan, but these sites form a fundamental part of the overall strategy and without identification of these, the strategy is clearly not sound.

Paragraph 43 refers to the percentage numbers of required homes which were delivered 2011 to 2019 (87%) and 2015/16 to 2017/18 (133%). It would be useful if actual numbers were specified in the document as well. From the figures given, it is assumed that the numbers mean that 32,033 homes were delivered between 2011 and 2019 out of a JCS target of 36,820. Is this correct?

Paragraph 156 of the consultation document explains that existing commitments (sites which are allocated or with planning permission) provide 82% of the housing growth identified in the new plan to 2038. From the point of view of the reader, it is difficult to understand how there can be both an 87% delivery figure against JCS targets and an almost equally high figure of 82% of the new housing requirement to 2038 made up of carried forward allocations and other commitments making up the required numbers. It would be useful if this could be explained with information provided about the deliverability of sites making up the identified commitment.

Does the delivery percentage figure for 2015/16 and 2017/18 relate to the combined annual requirement for these years? Please can this be clarified?

Paragraph 44 states that in 2018 Greater Norwich had a five-year housing supply. This was only when measured against the Strategic Housing Market Assessment (SHMA) and not against the Joint Core Strategy (JCS). It was disputed at various appeals where Inspectors upheld the view that the SHMA figures held limited weight e.g. APP/L2630/W/15/3039128. Therefore, it can only be claimed to be the Greater Norwich authorities’ opinion that there was a 5-year supply in 2018, rather than a fact. We would suggest that this paragraph is removed from the document as it serves little purpose.

Paragraph 57 vaguely mentions the City Deal but provides no detail about it for readers of the plan. More information is needed on the City Deal – what it is and what it commits the Councils to deliver in terms of extra housing and employment over and above the JCS targets.

Glavenhill Ltd is generally supportive of the overall vision. We support paragraph 108 which states:

“our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor”.

We support the ambition set out in paragraph 119 that:

“Most new homes will have been built in and around Norwich and in the Cambridge-Norwich Tech Corridor.”

However, we are not convinced the plan will deliver on either of these aims for reasons set out in our answers to questions 13 and 14 in particular.

Paragraph 113 should also refer to employment growth being provided on strategic sites in the Cambridge-Norwich Tech Corridor as well as in and around Norwich. Otherwise the aim set out in paragraph 108 cannot be met.

We are concerned that the vision for new schools, health facilities to be expanded to serve growing communities (paragraph 127) is not compatible with the dispersal of such significant numbers to small villages in the rural parts of South Norfolk.

Glavenhill Ltd offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth. However, we do not consider that dispersal of such large numbers (1200) homes to small villages throughout South Norfolk is compatible with the stated environment objectives, which include reduction of emissions, as it will inevitably increase car and other journeys. Small villages, particularly those falling outside of the old Norwich Policy Area are not generally sustainable locations for growth and directing 9% of allocations to such settlements is too high a figure. A smaller proportion of homes directed to accessible cluster villages with a primary school would be more appropriate.

The objectives for growing vibrant and healthy communities should include good access to education as well as jobs, services and facilities.

Explanation and justification should be provided for removing the Norwich Policy Area (NPA). This is a long-standing policy tool which has now been omitted and there is no reference to it within the consultation document. We consider that an explanation should be provided as to why it is no longer to be used as this helped to ensure that housing growth took place in sustainable locations focussed around Norwich. It is understood that OAN now has to be calculated across the whole of the plan area but the NPA approach to ensuring that the majority of development for the three Districts takes place in and around the City has been a sound approach to date, ensuring that the majority of development takes place in the most sustainable settlements with good access to jobs and services and reducing the need to travel. The new strategy which includes a significantly higher degree of dispersal to smaller settlements outside of the old NPA has not been adequately explained or justified.

If it is the case that the Strategic Growth Area effectively replaces the NPA then the plan should ensure that new allocations are focussed within that area, particularly the Cambridge Norwich Tech corridor part of it. A significant proportion of new allocations, particularly in South Norfolk towns and yet to be identified small rural villages are proposed outside of the Strategic Growth Area which conflicts with the main vision and aims of the plan.

The emphasis on the opportunity to “strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” is supported.

The delivery statement claims a proactive approach to delivery through only allocating housing sites where a reasonable prospect of delivery, taking into account delivery requirements of the plan can be evidenced.

However, no evidence of delivery of the 36,000 commitments and existing allocations being carried forward is provided within this consultation. It is noted that 13,430 of the commitments are in the Growth Triangle where delivery has been slow to date.

Glavenhill Ltd have queried the lack of availability of delivery evidence and been informed that this information will be provided at the Regulation 19 stage. In our view this is too late for consultees to be able to make any meaningful comments on the likely delivery of these commitments which make up 82% of the required housing numbers to 2038.

In order to be able to test and influence the soundness of the chosen strategy this information is needed at an earlier stage than Regulation 19. It is accepted that the information may change over time, but the current document identifies a commitment figure at this point in time that the Greater Norwich Partnership are asking consultees to assume is deliverable with no evidence to back this up. Evidence of this should be provided prior to Regulation 19 to enable proper opportunity for review and comment by consultees and the potential to suggest changes to the strategy that could be taken on board prior to the Regulation 19 consultation stage.

Compulsory purchase powers are mentioned where delivery turns out not to be in accordance with agreed delivery plans for “strategically significant development”. What is the plan’s definition of “strategically significant development”? This should be defined. How realistic is the use of compulsory purchase when this can be costly and time consuming?

The 9% buffer specified is below the 10% minimum buffer required in the NPPF. It is recognised that two contingency locations have also been identified including a site at Costessey and no specific site at Wymondham.

With the emphasis placed on the deliverability of the selected site allocations and existing commitments as set out in the first part of the Delivery Statement, the size and need for any required future contingency site is assumed to be relatively small. It is not considered that contingency land at both Costessey and Wymondham should be needed and if it is, this would be better allocated as part of an early phase of development at a new settlement at Hethel where it can support jobs growth in the hi-tech corridor and be properly planned to deliver new infrastructure and community facilities taking pressure away from Wymondham in the longer term.

If a contingency option is provided within the plan, it should be clearly identified now and the process for how and when it might be brought forward should be explained. Glavenhill Ltd consider that it would help provide clarity to landowners and developers and speed up delivery if needed.

Currently, the plan identifies reasonable alternative sites in Wymondham for 4000+ homes that could possibly come forward as a contingency if needed. This is a large and vague number that casts doubt on the confidence of the Greater Norwich Partnership about the deliverability of existing commitments and new allocations.

The Vision for Greater Norwich states:

“our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor”.

The first part of the Delivery Statement again highlights the opportunity to “strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors”

This is supported. However, the Economic Development section of the Delivery Statement then fails to mention the Cambridge Norwich Tech Corridor at all. Support for and delivery of economic growth within this corridor as a particular focus of the growth strategy should be emphasised within this section if there is a real commitment to making this happen.

This section should also refer to and set out how the plan integrates with and will help deliver the relevant ambitions of the LEP and the Norfolk and Suffolk Economic Plan. It should set out how there will be an integrated and responsive approach to working with the LEP to ensure the economic potential of the area can be realised.

We support the importance of early engagement with infrastructure providers and the delivery of required infrastructure to support growth.

The climate change statement is supported. However, Glavenhill Ltd consider that if the Growth Strategy includes 9% dispersal to small village clusters which could potentially be in the rural parts of South Norfolk and some within the rural parts of Broadland (outside of the old NPA) this is incompatible with the specified climate change ambitions, particularly insofar as they relate to reducing car and other journeys.

Although the majority of growth allocated in the plan may well be located to help reduce the need to travel by locating it in accessible larger settlements with good employment opportunities within them, or well connected by public transport, locating significant housing growth in small rural cluster villages may not support the specified Climate Change Measure to reduce the need to travel, particularly by the private car. We would, therefore, question whether the plan is doing enough to meet this important climate change objective and suggest that it could do more by amending its overall approach to the location of development and reducing the amount of dispersal to small rural villages (outside the old NPA). See our response to question 13 for further information on this.