Draft Greater Norwich Local Plan – Part 1 The Strategy

Glavenhill Ltd do not support the proposed settlement hierarchy as currently proposed. Although we offer 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, without first understanding where these sites are to be located and whether they are in fact sustainable, we cannot support the significant emphasis that is placed upon rural village clusters (outside of the old NPA). As currently drafted, the plan potentially allows a significant number of new homes (1200, 15% of all new allocations) to be located in small settlements in the rural area of South Norfolk. Other small sites are identified within the rural parts of Broadland. We do not consider this approach to be sustainable or compatible with the objectives in relation to tackling climate change.

The draft plan indicates that more homes (new allocations and commitments) are proposed in the cluster villages (9%) than in the key service villages (8%), yet cluster villages represent the bottom tier of the settlement hierarchy. As the bottom tier, they should have a correspondingly lower amount of growth in the hierarchy, otherwise this is not a sensible hierarchical approach to growth.

We consider that a more sustainable approach, that would be more in line with the overall objectives and vision set out for the Growth Strategy would be to clearly direct 400 of the South Norfolk 1200 to cluster villages and key service centres within the old NPA parts of South Norfolk and 500 as the first phase of a new settlement at Hethel in the Cambridge – Norwich Tech corridor. There is scope for a limited amount of more rural dispersal to contribute to the vitality of small rural villages and therefore, the remaining 300 should only be allocated to small cluster villages in the more rural parts of South Norfolk (outside the old NPA) where there is walkable access to a primary school and good public transport links to other key services. Any Broadland allocations outside of the old NPA should also only remain if the same applies.

Allocating 500 of the homes to a new settlement at Hethel would also provide land to expand the opportunity for hi-tech engineering jobs within the growth corridor. In this location the homes would help to ensure that the plan “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” (paragraph 108).

They will also:
“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” (Delivery Statement page 36).

The current strategy of significant dispersal to small rural village clusters will make no positive contribution to these key threads of the plan. It will have negative impacts in terms of increasing the number of private car and other journeys and it will place greater demand on small local schools and services. These demands are more difficult and costly to address within a spread of small rural villages rather than within a new settlement where social infrastructure can be properly planned and funded from the outset with corresponding economies of scale.

As currently proposed, the settlement hierarchy presents an unambitious variation on the previous Joint Core Strategy (JCS) with an unjustified increase in rural dispersal. The draft plan states that 82% of the new housing requirement to 2038 is made up of existing JCS allocations that have been carried forward (paragraph 156). This means that including the proposed uplift on existing allocations, 36,503 homes out of a total housing figure of 44,343 are carried forward.

Of the 7840 new housing allocations included in the draft plan, 4395 are to be located within Norwich and its fringe parishes. This is supported because these are clearly sustainable locations within Greater Norwich with good access to jobs and higher order services. However, despite the plan’s emphasis in its Vision (page 31) and Delivery Statement (page 36) on realising the ambitions of the Cambridge Norwich Hi Tech corridor, only 100 new homes (new allocations) are proposed within the corridor itself, at Wymondham. By contrast, 400 are proposed in Diss which is neither within the Strategic Growth Area, the Cambridge Norwich Tech corridor, or close enough to Norwich to benefit from higher order services.

It is recognised that towns like Diss and Aylsham should accommodate some additional housing growth and do offer their own job opportunities and service provision. However, this should not take precedence over redirecting the policies in the new plan beyond those in the JCS to ensure that there is a real new focus and commitment on meeting the stated vision for the Strategic Growth Area and Cambridge Norwich Tech corridor. Therefore, it is proposed that numbers in Diss should be halved to 200 and numbers in Harleston, which is also well outside of the Tech corridor and Strategic Growth Area, should be reduced to 150. The displaced 500 homes should be relocated within the Tech Corridor/ Strategic Growth Area. Some of these should be placed in a new settlement at Hethel.

Overall, Glavenhill Ltd’s conclusion is that the plan is saying the right things about future ambitions for Greater Norwich and the Tech corridor, but doing another, by virtue of directing too much growth to the rural areas outside of both the Tech corridor and the newly identified Strategic Growth Area. This needs to be addressed by ensuring that 900 of the 1200 homes proposed for village clusters in South Norfolk are redirected to villages within the old NPA area (400) with 500 to a new settlement at Hethel to support the Cambridge Norwich Tech corridor. The remaining 300 allocations in the rural parts of South Norfolk should only be in cluster villages where there is good walking access to a primary school and good public transport links to other key services. The same approach should be taken in Broadland. In addition, 500 homes should be redistributed from Diss and Harleston into the Tech corridor at Hethel and/or Strategic Growth Area. A new Garden Village settlement at Hethel could deliver up to 2000 homes within the plan period to 2038 with more beyond.

We have already commented on our concerns regarding the deliverability of the large housing commitment which makes up 82% of the housing requirement that has been set out to 2038. There is no evidence to assess regarding this at the present time and this should be provided prior to the Regulation 19 stage.

Glavenhill Ltd also believe that the overall housing requirement figure should be larger than the 44,343 homes set out in the draft plan. It is accepted that the updated NPPF now requires the new Standard Methodology to be used to assess housing need. However, the City Deal numbers have not been added to the need figure generated through the Standard Methodology. It is recognised that the Standard Methodology includes an uplift for affordability, but the NPPG clearly states that:

“The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area.”

The NPPG recognises that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the Standard Method indicates. It states that circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of factors such as:

“growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals).”

The agreed City Deal included the delivery of 3000 additional homes on top of JCS targets and an additional 13000 jobs. It is considered that these housing numbers should be added to the overall housing requirement figure.

Paragraph 162 refers to building in flexibility to support higher than trend economic growth incorporating the City Deal through contingency and windfalls only, rather than making it a key part of the strategy and identified housing requirement. If the Greater Norwich Authorities are serious about supporting the Vision set out in the plan for above target economic growth including within the Cambridge-Norwich Tech corridor and are serious about supporting the strategic initiatives of the LEP and Norfolk and Suffolk Economic Plan for jobs growth, then these additional housing numbers should be added to the standard methodology housing need figures to form part of the housing requirement figure. Furthermore, additional employment land should be allocated within the Hi-Tech corridor at Hethel as part of a new Garden Village settlement.

As set out above, we consider that a new settlement at Hethel should be allocated now. We support paragraph 167, which recognises the potential for a longer-term new settlement, provided this is located within the Cambridge Norwich Tech corridor.

We consider that greater clarity should be provided under Policy 1 regarding the housing numbers allocated to Norwich City itself and its fringe parishes to correspond with the preferred allocations document. Greater clarity is also needed regarding the proposed uplift figures. At the moment the table in policy 1 includes uplift as a commitment which is confusing when compared to the preferred new allocations tables which also include uplift. This needs to be properly and clearly explained.

The employment growth target is stated as 33,000 jobs for the plan period. Paragraph 55 states that 29,100 jobs were delivered 2011-2018. The previous regulation 18 Growth Strategy consultation suggested a target of 45,000 jobs for the new plan period based on the East of England Forecast Model (EEFM) and City Deal (13,000 more than JCS target). The GVA Grimley Study 2017 suggested 44,000 jobs would be needed. There is no explanation in the draft document for the significant reduction other than it is based upon the EEFM. This should be explained and justified. Again, it would appear that the additional above target jobs growth agreed through the City Deal has not been included. The 33,000 figure seems unambitious in the context of the Vision set out for the Cambridge Norwich Tech Corridor and the number of jobs previously delivered in the 7 years to 2018.

Glavenhill Ltd, therefore, consider that the employment growth target number should be more ambitious and would suggest that the previously specified 45,000 figure still remains appropriate. The number should be specified within Policy 1 which currently does not include any target figure.

Greater emphasis should also be included within the policy on supporting knowledge intensive employment growth in the Cambridge-Norwich Hi-Tech corridor in line with paragraph 108 of the Vision and Objectives for Greater Norwich.

The plan allocates employment sites totalling around 360 hectares including land on the strategic sites referred to above.

Notably, at paragraph 3.44 of the GVA 2017 report. It states:
“The Norwich urban area extends beyond the city centre, accommodating a diverse array of economic activity within its various business parks, industrial estates and specialist facilities. Often these sites make a distinct offer to businesses which, given the scale of each, is likely to direct the future nature of activity and development. As such infill, intensification and redevelopment of the existing estates will act as important locations for a range of activities, however, may offer few options to diversify the existing portfolio.”

Norfolk County Council’s Employment Land Monitoring Report 2018-2019[1], states that whilst there may be in excess of 400 hectares of monitored employment land (‘monitored land’ is land without planning permission) there are only 48.4 hectares of employment land with outline planning permission across the County. Clearly, in itself, land with outline planning permission can be speculative in nature.

In summary, we submit, that the emerging GNLP will be reliant upon an employment land supply that is not flexible or diverse enough; that is not ambitious enough; is made up of key sites which either have infrastructure constraints to delivery, or have other environmental constraints to expansion; and as such the emerging GNLP plan will conflict with the NPPF and is unsound.

As set out in our answer to question 9, Glavenhill Ltd consider that the timing and process for identifying the need for contingency site/s to be brought forward should be clearly set out within the plan.

Glavenhill Ltd consider that five year land supply should be calculated across the three Districts with figures provided for the newly identified Strategic Growth Area and the rural area beyond this in order to help monitor and ensure that the majority of housing delivery takes place within the Strategic Growth Area.

The NPPF states at paragraph 33 that plans should be “reviewed to assess whether they need updating at least once every five years” and goes on to state that reviews “should be completed no later than five years after the adoption date of that plan”. As such the Council’s policy to review the plan 5 years after adoption is not consistent with national policy. The review must be completed prior to the plan being five years old to allow for the prompt updating of the plan if necessary. The policy wording should be amended accordingly.

The policy should say how the suggested improvements will be achieved e.g. through CIL, site specific policies, specific infrastructure policy.

Glavenhill Ltd generally supports this policy but without knowing where the small rural village cluster allocations will be made in South Norfolk and whether they are sustainable, we are concerned that they may not be able to meet some of these requirements. 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, but are concerned about the scale of growth to be directed to such sites and particularly the amount that could be directed to locations outside the old NPA, as set out in our response to question 13.

Glavenhill Ltd consider a national and standardised approach to improving issues such as the energy efficiency of buildings, the provision of renewable energy and the delivery of electric vehicle charging points to be the most effective approach that balances improvements with continued delivery of housing and infrastructure. It is our preference for a national approach to improving the environmental performance of residential developments, rather than local authorities setting their own standards. We consider this is necessary to allow research and development and supply chains to focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these new requirements. It is fundamentally inefficient to create a plurality of standards.

The National Planning Policy Framework (the NPPF) places great weight on protecting and enhancing the natural environment. It seeks to ensure that development not only avoids harm to natural environmental assets but also encourages Local Plans to actively protect, promote and enhance biodiversity so that development results in net gain (paragraph 174).

An Interim Habitats Regulations Assessment (HRA) has been published alongside the Local Plan Regulation 18, Stage C Consultation Document. This deals specifically with the potential impact of the draft Local Plan Growth Strategy on designated ecological habitats, including the Broads and the Norfolk Coast in accordance with the NPPF.

The HRA identifies a range of mitigation measures that may assist in alleviating recreational pressure from new housing sites identified in the Regulation 18, Stage C Consultation Document. These include (i) the provision of new, alternative green space (referred to in the HRA as SANGS) and (ii) a programme of improvements to existing areas of infrastructure. The HRA confirms that the SANG could take the form of a new country park containing woodland and waterbodies.

This need for additional, useable and attractive green infrastructure within Greater Norwich in order to mitigate proposed growth is not a new one. The Greater Norwich Development Partnership (GNDP) undertook an Open Spaces Indoor Sports and Community Recreation Assessment (OSISCRA) using Planning Policy Guidance 17 (PPG17) assessment methodology in September 2007.

This OSISCRA concluded that there was a requirement in 2007 to deliver 87.5 sq. m of combined formal, seminatural, amenity, play, sports and outdoor spaces per person resident in South Norfolk Council area. The OSISCRA went on to conclude that South Norfolk Council did not have a large enough network of public open spaces (at the start of the adopted Joint Core Strategy review) to meet the needs of the District.

Since 2007 this Habitat Regulations problem within South Norfolk has worsened due to large scale housing growth and the Council’s failure to implement a strategy to deliver new natural and semi-natural green spaces to manage this impact.

Whilst the current Joint Core Strategy identifies the potential to create a new country park at Bawburgh Lakes to mitigate the impact of its growth strategy, this site remains undelivered. The Joint Core Strategy for Norwich, Broadland and South Norfolk Annual Monitoring Report strategy 2016-2017 published April 2018 (AMR) has since confirmed that there has been no net increase in the amount of natural and semi-natural open spaces delivered within South Norfolk Council area since the 2007 assessment and thus the impact of the existing Local Plan growth strategy remains unmitigated.

Despite this and the requirement for new SANGs to mitigate the additional recreational pressure to be created by the emerging Local Plan, there is no site identified within the Regulation 18 Stage C Consultation Document for a new Country Park. To the contrary, footnote 74 of the Regulation 18, Stage C Consultation Document defers consideration of potential sites for a new Country Park to the Regulation 19 stage.

In the absence of any identified deliverable sites for a Country Park within the Regulation 18, Stage C Consultation Document, draft Policy 3 requests that new development provide onsite infrastructure as necessary. In addition, and rather than allocating sites, the plan suggests that new country parks can be identified through green infrastructure strategies and be funded in the most part, by CIL.

Glavenhill Ltd contend that the GNGB’s approach to the natural environment as set out in Policy 3 of the Regulation 18, Stage C Consultation Document, specifically the lack of any discernible or deliverable site for a new country park, is ‘unsound’.

Glavenhill Ltd request that before any further strategic scale growth can be planned through the Greater Norwich Local Plan, that South Norfolk Council establish a proposal for a realistic and deliverable new network of SANG’s. This could be achieved in part, through the allocation and early release of a Country Park at Caistor Lane (GNLP 0485).

The proposed Country Park at Caistor can be delivered at a scale and in a form that ensures its attractiveness to new visitors, thus diverting visitors away from The Broads National Park and existing Natura 2000 sites, SAC’s and SSSI’s present within the District.

Importantly, the set-up and long-term maintenance of this new park will be funded by housing delivery across the same site and would not be reliant on the public purse.

Glavenhill Ltd support the delivery of transport improvements (particularly those that facilitate public transport, walking and cycling) in a timely manner. This is essential to support delivery of proposed housing and employment growth. Delivery of necessary infrastructure to support significant dispersal of housing growth to small rural village clusters will, however, be difficult and expensive. Small schemes may have limited ability to fund or provide both on and off-site transport improvements through land provision and developer contributions. Therefore, significant dispersal of housing growth to small rural clusters should not form part of the growth strategy (see our response to Q.13).

Glavenhill Ltd support the delivery of strategic infrastructure in a timely manner. This is essential to support delivery of proposed housing and employment growth. Delivery of necessary infrastructure to support dispersal of housing growth to small rural village clusters will, however, be difficult and expensive. The ability of small schemes to fund the provision of on-site services and facilities and to support local infrastructure capacity improvements through land provision and developer contributions is limited. Therefore, significant dispersal of housing growth to small rural clusters should not form part of the growth strategy (see our answer to Question 13).