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BRU2 Policy
Representation ID: 23259
Received: 01/03/2021
Respondent: Norfolk Homes Ltd
Agent: Cornerstone Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021), it remains our view that Policy BRU2 is insufficiently up-to-date/accurate, and is thus unsound in seeking to allocate the entire site for recreational open space (please see attached).
The housing part has approval and development has lawfully commenced to build and deliver 155 dwellings, and so the option for recreational use of that land has been removed. Brundall Parish Council has planning permission for the provision of formal recreation on the remainder.
We see no difficulty in amending the proposed Plan to accurately represent what is happening/will happen on different parts of the BRU2 site, rather than continue that the site be allocated for recreational use in its entirety. Without such an amendment, we contend that the Plan - insofar as it relates to Policy BRU2 – is unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021), it remains our view that Policy BRU2 is insufficiently up-to-date/accurate, and is thus unsound in seeking to allocate the entire site for recreational open space (please see attached).
The housing part has approval and development has lawfully commenced to build and deliver 155 dwellings, and so the option for recreational use of that land has been removed. Brundall Parish Council has planning permission for the provision of formal recreation on the remainder.
We see no difficulty in amending the proposed Plan to accurately represent what is happening/will happen on different parts of the BRU2 site, rather than continue that the site be allocated for recreational use in its entirety. Without such an amendment, we contend that the Plan - insofar as it relates to Policy BRU2 – is unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021), it remains our view that Policy BRU2 is insufficiently up-to-date/accurate, and is thus unsound in seeking to allocate the entire site for recreational open space (please see attached).
The housing part has approval and development has lawfully commenced to build and deliver 155 dwellings, and so the option for recreational use of that land has been removed. Brundall Parish Council has planning permission for the provision of formal recreation on the remainder.
We see no difficulty in amending the proposed Plan to accurately represent what is happening/will happen on different parts of the BRU2 site, rather than continue that the site be allocated for recreational use in its entirety. Without such an amendment, we contend that the Plan - insofar as it relates to Policy BRU2 – is unsound.
Object
Publication
TROW1 Policy
Representation ID: 23260
Received: 01/03/2021
Respondent: Norfolk Homes Ltd
Agent: Cornerstone Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached – we request that Policy TROW1 is brought fully up-to-date.
The current draft Plan has been amended - from the Regulation 18 iteration – to correctly state the number of dwellings but still states that: “the second phase is pending completion of the S.106 agreement at the time of writing” (paragraph 3.83). In fact, planning permission has now been granted on Phase 2 and development lawfully commenced. We request that Policy TROW is updated accordingly.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached – we request that Policy TROW1 is brought fully up-to-date.
The current draft Plan has been amended - from the Regulation 18 iteration – to correctly state the number of dwellings but still states that: “the second phase is pending completion of the S.106 agreement at the time of writing” (paragraph 3.83). In fact, planning permission has now been granted on Phase 2 and development lawfully commenced. We request that Policy TROW is updated accordingly.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached – we request that Policy TROW1 is brought fully up-to-date.
The current draft Plan has been amended - from the Regulation 18 iteration – to correctly state the number of dwellings but still states that: “the second phase is pending completion of the S.106 agreement at the time of writing” (paragraph 3.83). In fact, planning permission has now been granted on Phase 2 and development lawfully commenced. We request that Policy TROW is updated accordingly.
Object
Publication
Settlement Map
Representation ID: 23261
Received: 01/03/2021
Respondent: Norfolk Homes Ltd
Agent: Cornerstone Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached, planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath (ref. 20171464; planning permission and site location plan attached).
We suggest that – in the interests of completeness and to provide an accurate picture of housing provision here – an appropriate note should be added to the Plan’s supporting text (probably at paragraph 3.55) and an annotation to the Settlement Map. Without such an amendment, we contend that the Plan - insofar as it relates to Rackheath – is unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached, planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath (ref. 20171464; planning permission and site location plan attached).
We suggest that – in the interests of completeness and to provide an accurate picture of housing provision here – an appropriate note should be added to the Plan’s supporting text (probably at paragraph 3.55) and an annotation to the Settlement Map. Without such an amendment, we contend that the Plan - insofar as it relates to Rackheath – is unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached, planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath (ref. 20171464; planning permission and site location plan attached).
We suggest that – in the interests of completeness and to provide an accurate picture of housing provision here – an appropriate note should be added to the Plan’s supporting text (probably at paragraph 3.55) and an annotation to the Settlement Map. Without such an amendment, we contend that the Plan - insofar as it relates to Rackheath – is unsound.
Object
Publication
Policy 5 Homes
Representation ID: 23262
Received: 01/03/2021
Respondent: Norfolk Homes Ltd
Agent: Cornerstone Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.
The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.
There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.
The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.
There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.
The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.
There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.
Object
Publication
3.55
Representation ID: 23286
Received: 01/03/2021
Respondent: Norfolk Homes Ltd
Agent: Cornerstone Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached, planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath (ref. 20171464; planning permission and site location plan attached).
We suggest that – in the interests of completeness and to provide an accurate picture of housing provision here – an appropriate note should be added to the Plan’s supporting text (probably at paragraph 3.55) and an annotation to the Settlement Map. Without such an amendment, we contend that the Plan - insofar as it relates to Rackheath – is unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached, planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath (ref. 20171464; planning permission and site location plan attached).
We suggest that – in the interests of completeness and to provide an accurate picture of housing provision here – an appropriate note should be added to the Plan’s supporting text (probably at paragraph 3.55) and an annotation to the Settlement Map. Without such an amendment, we contend that the Plan - insofar as it relates to Rackheath – is unsound.
Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached, planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath (ref. 20171464; planning permission and site location plan attached).
We suggest that – in the interests of completeness and to provide an accurate picture of housing provision here – an appropriate note should be added to the Plan’s supporting text (probably at paragraph 3.55) and an annotation to the Settlement Map. Without such an amendment, we contend that the Plan - insofar as it relates to Rackheath – is unsound.
Object
Publication
0596R Policy
Representation ID: 24142
Received: 21/03/2021
Respondent: Norfolk Homes Ltd
Number of people: 2
Agent: Cornerstone Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy GNLP0596R
On behalf of Norfolk Homes Ltd – the owner of the Norwich Road, Aylsham site - I write in support of the proposed allocation of GNLP0596R for at least 255 homes, community use to meet sustainable transport objectives, and a 90-bed care unit/extra care housing. Norfolk Homes Ltd confirms that 0.25 hectares of the site will be provided for community use to meet sustainable transport objectives, as set out in the Aylsham Neighbourhood Plan. It also supports the intentions for the provision of care/extra care, and in particular the flexibility afforded the provision of - what is understands to be – housing under Classes C2 and C3. The landowner is presently in discussion with specialist developers, with a view to understanding the local market for such, and thus bringing forward an appropriate type/form/scale of development on site to meet such needs.
A revised/updated indicative masterplan has been prepared (and attached) to assist both the Inspector and the GNDP in understanding the landowner’s broad intentions with regard to the site and pending planning application.
In discussion with the GNDP, a revised/updated Statement of Common Ground will be prepared to reflect the current position/planning status of the site. The landowners/developers have undertaken most preparatory work necessary for an application and have engaged with Broadland District Council through a formal ‘pre-application’ process. In principle, Norfolk Homes Ltd. seeks to prepare, complete and submit an application around the middle of 2021, to be determined by or around the time the Plan is examined (scheduled for November/December 2021). This will ensure that the emerging Plan (both in terms of strategic policies and site allocations) can be given appropriate weight in determining the application (in accordance with paragraph 48 of the NPPF) and can demonstrate soundness through the deliverability of the Plan’s strategy/sites. As the determination of the application will be broadly concurrent with the closing stages of the preparation/adoption of the Plan, the applicant intends – as far as possible - that the application complies with the draft policies thereof. Norfolk Homes Ltd. look to commence development of the site - and delivery of homes, etc - as soon as possible thereafter (with a scheduled start on site of June 2022, an annual delivery rate of 25 dwellings, and a likely housing completion date for the site of June 2031).
With regard to the numbered criteria, Norfolk Homes Ltd supports these, subject to the following comments:
3. There is reference to “revision of speed limit”, in relation to which we seek clarification. Norwich Road (from the A140 roundabout into the town centre) is presently 30mph; what revision is the policy proposing?
4. It should be noted that whilst Norfolk Homes have indicated - through the submitted masterplan for the site - that there would be two points of vehicular/pedestrian access to Norwich Road, and a footpath/cycleway/emergency access to Buxton Road, there is no means or intention to access Copeman Road. The latter would require third party land, over which Norfolk Homes has no control. It is therefore recommended that reference to Copeman Road be deleted.
These matters should be clarified in order to make the Plan sound.
See above.
Representations regarding site GNLP0596R in Aylsham submitted by Cornerstone Planning on behalf of Norfolk Homes
See attachment for masterplan
Support
Publication
4.9
Representation ID: 24143
Received: 21/03/2021
Respondent: Norfolk Homes Ltd
Number of people: 2
Agent: Cornerstone Planning Ltd
Paragraph 4.9
Norfolk Homes Ltd confirms that 0.25 hectares of the site will be provided for community use to meet sustainable transport objectives, as set out in the Aylsham Neighbourhood Plan.
Representations regarding site GNLP0596R in Aylsham submitted by Cornerstone Planning on behalf of Norfolk Homes
See attachment for masterplan
Object
Publication
4.8
Representation ID: 24144
Received: 21/03/2021
Respondent: Norfolk Homes Ltd
Number of people: 2
Agent: Cornerstone Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Paragraph 4.8
It should be noted that whilst Norfolk Homes have indicated - through the submitted masterplan for the site - that there would be two points of vehicular/pedestrian access to Norwich Road, and a footpath/cycleway/emergency access to Buxton Road, there is no means or intention to access Copeman Road. The latter would require third party land, over which Norfolk Homes has no control. It is therefore recommended that reference to Copeman Road be deleted.
The error should be corrected in order to make the Plan sound.
See above
Representations regarding site GNLP0596R in Aylsham submitted by Cornerstone Planning on behalf of Norfolk Homes
See attachment for masterplan
