Draft Greater Norwich Local Plan – Part 1 The Strategy

Key Service Centres are identified under draft Policy 1 of the Regulation 18 Stage C Consultation Document as a third-tier settlement, with growth proposed to these areas after the ‘Norwich Urban Area’, and the ‘Main Towns’.

Despite their position in the hierarchy, only 515 new homes are proposed to come forward through new allocations within all nine Key Service Centres. This compares to a minimum of 1,680 homes that are proposed to come forward in the lower (fourth) tier, ‘Village Clusters’.

Whilst Glavenhill Ltd recognise the benefits to be delivered to the vitality of rural areas through allocating some new sites and thus increasing footfall within small village locations, it is considered both unsustainable and inappropriate to apportion a greater amount of growth to these areas than to the higher order Key Service Centres which it can be assumed from their position in the hierarchy, are more sustainable and offer greater service provision.

With specific reference to draft Policy 7.3 of the Regulation 18, Stage C Consultation Document, Glavenhill Ltd object to the Council’s decision not to allocate any additional sites for residential development within the Poringland / Framinghams area, which is sustainably located within the old NPA. This decision appears to be neither justified or positively prepared, nor to have been sufficiently tested and is therefore considered ‘unsound’.

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 support the significant amount of growth to be directed to village clusters, potentially allowing 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 (outside of the old Norwich Policy Area). Other small sites are identified within the rural parts of Broadland. Without knowing where the South Norfolk sites are and whether they are accessible and sustainable in all respects, we are concerned that the approach is neither sustainable or compatible with the objectives in relation to tackling climate change.

We consider that a more sustainable approach, that would be in line with the overall objectives and vision set out for the Growth Strategy would be to allocate 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 some 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 allows significant dispersal to small rural village clusters and without further explanation and justification, we are concerned that this may not make a positive contribution to these key threads of the plan. It could 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.

Given the slow rate of delivery to date, it is likely that windfall will need to play an important role in delivering the required housing numbers to 2038. Paragraph 159 anticipates 3870 dwellings being delivered in the plan period to 2038 by windfall based upon previous trends. However, future trends could be very different in the absence of 5-year land supply sites and sites within the City Centre being identified as allocations in this plan rather than windfall.
Windfall will need to come forward in a range of settlements in the hierarchy and it is appropriate for more to come forward in the higher order settlements than in the lower tiers. Policy 7.4 deals with small scale windfall development being provided in village clusters. We consider that there is a need to ensure that this is small scale through identification of appropriate development boundaries, as these settlements are not the most sustainable in the hierarchy. The requirement that “the cumulative amount of windfall development permitted during the plan period should not have a negative impact on the character and scale of settlements in any village cluster in Broadland” should help to achieve this. However, why does this statement not refer to South Norfolk village clusters also? Or is a separate policy going to cover these?