Publication

It is considered that either policy 6 needs to be reworded, or a new policy dedicated towards employment generating uses in rural locations be provided. At present, the more rural settlements will miss out on the potential for windfall development which could serve to boost local economic vitality. It is considered the creation of employment generating uses in rural locations on a small scale would provide local people with local jobs, helping to reduce carbon emissions from commuting, whilst also reflecting the current trend of home working and the proliferation of new start-up businesses that have arisen over the last year during the pandemic.

For example, taking the sustainable settlement of Ashby St Mary and Thurston, it is considered that some small employment generating uses here would supplement the vitality of the settlement, in accordance with the aspirations of paragraphs 83 and 84 of the NPPF. If policies are not reworded to be more flexible, then dedicated allocations should be considered, such as those proposed between Norwich Road and Mill Road as part of the 4 hectare allocation. Furthermore, due to the more rural location, employment land here would be highly attractive for the more creative and tech industries, which would normally not want to be located on busy commercial parks. Instead the opportunity to create a small network of smaller scale employment sites would better reflect the economic composition of the locality where there is an abundance of entrepreneurial spirit and the surge in consumer demand for more bespoke and local produce.

It is considered that Policy 6 does not propose an effective or justified strategy for the economy of rural areas. Policy 6 states that the needs of small, medium and start-up businesses are addressed through the provision of small-scale business opportunities in all significant residential and commercial developments. Additionally, the policy goes on to state that the promotion of creative industries will be focused on the city center. It is considered that this policy approach is not appropriate for the rural hinterland that composes two of the three relevant districts. Paragraph 83 of the NPPF states that planning policies and decisions should enable the sustainable growth and expansion of all types of business in rural areas, both through the conversion of existing buildings and well-designed new buildings. Paragraph 84 of the NPPF goes on to state that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. Paragraph 84 also states that sites that are physically well related to existing settlements should be encouraged where suitable opportunities exist.

Policy 6, therefore is not consistent with national policy due to this inherent conflict with paragraphs 83 and 84 of the NPPF. Policy 6 directs employment generating uses to existing allocations and the city center, ignoring the needs of the rural communities resulting in an unjustified strategy for supporting rural vitality. As such the GNLP is considered to be unsound in relation to the provision of employment generating uses in rural communities.

To make the policy and plan sound, it is recommended that a more flexible approach be adopted regarding windfall developments, stating that proposed development, except where allocated, may not result in more than a certain percentage of existing dwellings be proposed over the plan period. This way the policy would allow for larger settlements supporting substantially more than smaller hamlets, whilst applying a more individualistic approach reflecting the respective settlement hierarchy.

The major issue with Policy 7.5 regarding its effectiveness is that it is too generic and does not take into consideration the specific circumstances of sustainable settlements. Taking Ashby St Mary and Thurston for example, the settlement boasts local amenities and sustainable transport options, yet no growth is proposed. Instead policy 7.5 would see the settlement overly restricted, which would strangle the existing weak (in the wake of Covid and Brexit) local economy. Here policy 7.5 would only allow for the development of only 3 dwellings, which is not sustainable, nor encouraging necessary growth to facilitate rural vitality in accordance with national policies. As such, it is considered necessary that if the policy is not reworded, then specific allocations should be proposed, such as the 4 hectare site (proposing a mixed use development that would infill between the two roads (Norwich Road and Mill Road) or the 1 hectare site that adheres to the existing linear development along Mill Road, opposite where dwellings have already been granted (Applicati

Policy 7.5 of the GNLP is not sound as it is too restrictive regarding windfall development. The policy only allows for a blanket approach of either 3 or 5 dwellings to be built, irrespective of how sustainable a settlement is, or local need, meaning the proposed strategy is ineffective.

This approach is in direct conflict with paragraph 77 of the NPPF where it states that planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local need. Furthermore, paragraph 68 of the NPPF states that Local Authorities should support the development of windfall sites through their policies and decisions - giving great weight to the benefits of using suitable sites within existing settlements for homes.

Policy 7.5 of the GNLP does not support the development of windfall sites, but actively restricts development, potentially undermining viability and ensuring no affordable housing or other obligations are sought, by limiting development to a number far below policy thresholds. As such, it is considered that Policy 7.5 of the GNLP is not compliant with national policy either, conflicting with paragraph 35 of the NPPF.

Overall the policy is considered to propose an ineffective strategy for handling development, based on an unjustified strategy in conflict with national policy. Therefore the plan is considered to be unsound.