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Publication
Climate Change Statement
Representation ID: 24453
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We support the GNLP’s ambition to address climate change and shift to a post-carbon economy. We do, however, strongly believe that aligning growth spatially with committed strategic infrastructure improvements and delivering holistically planned growth by way of a new
settlement presents the best opportunity to achieve these ambitions both within the current plan period and beyond as opposed to the range of sites of varying sizes that do not present a coherent approach to addressing the ambition of a net zero carbon emissions growth plan.
SEE FULL REP ATTACHED
Include criteria-based policy governing new settlement, SEE FULL REP ATTACHED
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 1 - The Sustainable Growth Strategy
Representation ID: 24454
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Whilst we support the thrust of Policy 1 and its supporting text, we consider that the amendments
to Policy 1 proposed in the Reg 19 plan fail to address a number of key issues:
(a) Ensuring housing need is fully aligned with economic growth ambitions;
(b) Properly embedding the commitment expressed in Policy 7.6 to a new settlement for accommodating higher housing needs arising within the current plan period (this should specifically be referenced under the Housing text of Policy 1); and
(c) Failing to provide sufficient certainty and clarity by identifying within Policy 1 and the Key Diagram a preferred spatial growth area within which any new settlement could come forward.
SEE FULL REP ATTACHED
Prepare a robust Housing and Economic Needs Assessment to comply with national guidance and clarify the number of homes likely to be needed in Greater Norwich where this appears likely to exceed the outcome of the standard method.
Policy 1 would benefit from the inclusion of a para under the Settlement Hierarchy to reference the commitment to a new settlement to meet additional housing needs within the Plan period.
Expanding Policy 1 to include within its spatial strategy more specificity about what a ‘sustainable community’ might constitute at a strategic scale would be helpful in guiding decisions about the criteria for new settlements, decisions for which will need to be taken in the next 2
years if the Councils delivery programme is to be met.
SEE FULL REP ATTACHED
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 3 Environmental Protection and Enhancement
Representation ID: 24455
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
it would be helpful if further clarity could be provided in the submission version of the Plan on the following:
Given that the background evidence advocates a site-specific approach to calculating and delivering BNG, it is unclear how the policy requirement for at least 10% gain can be justified. District wide policy of £205 differs from evidence base figure. SEE FULL REP ATTACHED.
Policy 3 should be adjusted to allow ability to deliver on-site mitigation as an alternative to per dwelling contributions.
SEE FULL REP ATTACHED.
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 4 Strategic Infrastructure
Representation ID: 24456
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The evolution of the GNLP – and the selection of development sites - has not ‘considered transport from the earliest stages of plan-making’, particularly in respect of the
choices around the location of new growth which can limit the need to travel or providing a genuine choice of sustainable transport options.
SEE FULL REP ATTACHED
Rectify the disconnect between sustainable transport and spatial growth planning, by engaging with the County Council and other statutory transport providers to align priorities.
SEE FULL REP ATTACHED
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 5 Homes
Representation ID: 24457
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
GNLP evidence base does not include any housing needs assessment, or equivalent, nor is there any record of the self-build and custom housebuilding register for the GNLP area to align the 5% requirement with the underlying demand evidence.
SEE FULL REP ATTACHED
Include housing needs assessment and register for self build housing. Amend viability assessment to take account of 5% policy requirement for self build. SEE FULL REP ATTACHED.
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 6 The Economy
Representation ID: 24458
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 6 fails to capitalise on the opportunity to futher support and direct employment growth to the Cambridge-Norwich Tech Corridor.
SEE FULL REP ATTACHED.
Include CNTC in Policy 6. SEE FULL REP ATTACHED
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 24459
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Over-emphasis on the Norwich area poses a risk to the overall deliverability and soundness of the plan.
SEE FULL REP ATTACHED
Rather than allocate contingency sites the GNDP could put in place a supportive policy framework to favourably consider a new settlement allocation during the first part of the plan period.
SEE FULL REP ATTACHED.
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Support
Publication
Policy 7.2 The Main Towns
Representation ID: 24460
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
We support the policy as currently drafted. SEE FULL REP ATTACHED.
The critical mass of a new settlement closely related to a town can deliver the appropriate levels of infrastructure.
SEE FULL REP ATTACHED.
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 7.4 Village Clusters
Representation ID: 24461
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
SN Village Clusters Plan proposes to allocate sites for
1,200 homes. As a result, almost 10% of the total Greater Norwich new development to 2038 will be delivered essentially through a dispersed settlement strategy. We also maintain our procedural objection to the decision to draw up the two plans in parallel but not to jointly assess or record through the HELAA or SA processes the overall environmental impact of the GNLP as a whole. This approach would not be permissible through EIA of a development proposal, and we consider that the decision to adopt such an inconsistent approach could threaten the soundness of the GNLP evidence base.
SEE FULL REP ATTACHED
The soundness of the plan in respect of delivering its objectives would be greatly strengthened through a reduction in the number/scale of site allocations to be made through the Village Clusters document, in favour of more overt commitment to the contribution that well-planned
new settlement-scale growth.
SEE FULL REP ATTACHED
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Policy 7.6 Preparing for New Settlements
Representation ID: 24462
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Whilst we support the principle and intent of Policy 7.6, we have a number of concerns over the brevity of the Policy wording and supporting text as currently drafted.
SEE FULL REP ATTACHED.
The policy would benefit from some additional policy wording and alterations in the interest of providing further support and direction.
SEE FULL REP ATTACHED
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
