Publication

• The inclusion of a second site put forward in Reg 19 should be withdrawn.
• The second site was included in Reg 19 to meet a target of 5000+ new homes beyond Reg 18. The 250 new homes allocated for the second site in Aylsham can be met by several different options:
1. The approval of two further developments at Drayton and near Rackheath, that were not in Reg 19, increases the number of additional homes put forward by over 400;
2. The GNLP could consider the allocation of a small number of homes in villages which need homes to maintain their viability;
3. The impact of Covid and Brexit will almost certainly lead to an increase in the number of brownfield sites becoming available for development. This option is certain to provide space for at least 250 more homes. It is perhaps worth highlighting that the area that provided the largest percentage of new homes from Reg 18 to Reg 19 was the main towns – a decision that was taken without consultation.
• Even without a second site in Aylsham, there needs to be improvements in the infrastructure to deal with the demand of 300 new homes:
1. The primary school should be in the first stage of development;
2. Before any further development Aylsham should have improved health and care facilities with a viable medical centre, including a doctor’s surgery, and a day care centre as put forward by ACT;
3. There must be a viable road management system with increased parking to be able to meet the needs of an increased population;
4. There must be significant improvements to the water supply and water management system before further development;
5. There must be improved broadband access;
6. There must be an upgrade to electrical sub-stations and provision of electrical charging points.
7. There must be protection for the green infrastructure around the town.
• All these infrastructure issues apply to Reg 18 where one site was put forward. However, to move to two sites, without consultation, creates a problem that may be insurmountable without significant investment, way beyond the support given by the developers for two sites. The local authority and the county council must be prepared to change their policies in respect of investment or accept that the damage caused by 550 new homes in a market town based on a medieval town structure with a population with a high percentage of senior people, is not suitable for this scale of development.
• Therefore, the second site put forward in Reg 19 should be withdrawn.
• Any further development must be in keeping with the points laid out in the Aylsham Neighbourhood Plan.

Response to GNLP Regulation 19
Aylsham Town Council have discussed the draft Greater Norwich Local Plan at meetings attended by several members of the public and have unanimously agreed to object to the plan in its current state. The reasons for this are listed below.

Is the plan legally compliant?
To ensure legal compliance the following must be adhered to:
• The process of community involvement for the plan should be in general accordance with the LPA’s Statement of Community Involvement [SCI]. In regard to Aylsham no virtual engagement methods have been used to “to engage with community and stakeholder bodies “in the town.
• 1.6 Paragraph 155 of the National Planning Policy Framework (2012), states: 'Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged . . .
In regard to Aylsham, the Town Council were not approached and there is no evidence that "a wide section of the community has been proactively engaged".
• Section 33A of the Planning and Compulsory Purchase Act 2004 [F133 Duty to co-operate ] requires Broadland to engage constructively, actively and on an ongoing basis with neighbouring authorities and certain other bodies over strategic matters during the preparation of the plan.
The LPA will be expected to provide evidence of how they have complied with the duty.
In regard to Aylsham, Broadland has not engaged constructively or otherwise with Aylsham Town Council, nor with North Norfolk District Council in respect of the Badersfield development near Aylsham.
We ask that Broadland provide evidence of how they have complied with this duty.
From the above for Regulation 19 to be legally compliant there must be evidence of consultation. Below are the key points on this issue.
• Aylsham Town Council, the residents of the town and the District Councillors were consulted on Regulation 18 when there was one site put forward for Aylsham with 300 homes.
• There has been no consultation with Aylsham Town Council or the residents on the changes regarding the content of the sites section of Regulation 19. There are two sites in Regulation 19 with 550 homes, an increase of 83% on the homes consulted upon in Regulation 18.
• There was no consultation on Regulation 19 with Aylsham Town Council or residents in regard to the infrastructure as it was assumed by the GNLP board that Regulation 18 consultation was sufficient, despite the significant changes in the two plans.
• The GNLP suggested that the feedback for Reg 18 gave ‘confidence to the deliverability of new residential development in Aylsham’. The only supportive responses came from the developers. Therefore, the understanding of the response is inadequate and therefore both not legally compliant and unsound.



Is Regulation 19 Sound?

Is Regulation 19 positively prepared?

• There are inaccuracies within the information provided on Aylsham, such as the day of the main market and the cycle route to Norwich. This brings into question how well the GNLP understand Aylsham.
• Previous documents produced by Broadland District Council, the GNLP and Anglian Water highlight the problems of water supply and sewage disposal in respect of Aylsham. The requirement of an upgrade by Anglian Water is made but this does not come with guarantees or timescales. This issue was highlighted as a severe problem with the recent developments and with the one site put forward in Reg 18 this was considered a major issue. By putting forward two sites it becomes almost inevitable that there will be problems that could be insurmountable.
• By putting forward two sites the quality and speed of broadband will be severely tested and there will be a strong chance that the Central Government Target will not be met.
• Reg 19 describes the uniqueness of the town highlighting its history and the importance of retaining this. This has been a severe problem with the recent developments of 550 new homes at Willow Park and Bure Meadows, to add a further 300 as in Reg 18 would strain this considerably. However, to increase the number of new homes by a further 83% on the edge of the town indicates that Reg 19 could not have been positively prepared as the evidence points to significant damage to the uniqueness of the medieval town.
• Reg 19 states that it has considered the impact of Covid. However, there is a lack of analytical analysis to show how that will impact on Aylsham’s way of life and economy post pandemic. In Reg 18, Aylsham was allocated one site. Then, in the middle of the Covid crisis, the town was allocated two sites without consultation, or consideration that more brownfield sites may become available when the crisis is over. This indicates that Reg 19 has not been positively prepared and opportunities to look beyond the large-scale developments on the edge of towns and cities have been lost.
• There is a similar lack of thought in Reg 19 concerning Brexit, which will have a significant impact on the greater Norwich area. To commit, without consultation, two sites for a small market town such as Aylsham, when the country will be in a significant period of economic flux demonstrates a lack of preparation and thought.
Is Regulation 19 Justified?
• As stated under legal compliance, the residents of the town were consulted on the need for ONE site. There were concerns with Reg 18, particularly in respect of the demands it would make on the infrastructure of the town. However, to have two sites as in Reg 19 magnifies these infrastructure issues. In Reg 18 there was no mention of Aylsham having two sites and there has been no consultation with the Town Council or the residents on the allocation of two sites in Reg 19. Therefore, Reg 19 has not met the test of being justified.
• Two sites brings an increase to the proposed level of development to 83% on the consultation figure – 550 homes increases the total number of homes by 15.6%. The population of the town is likely to increase by a similar figure. This increase contradicts point 188 in the Strategy section which states there should be “reasonable levels of growth in the main towns.” This increase cannot be met by the current infrastructure in the town or by improvements offered by the plans within Reg 19.
• There is a lack of clarity and urgency in Reg 19 on the building of a primary school. A sound approach would be to state that, with all the primary schools in Aylsham full, the building of the school should take place as a priority.
• On the original Reg 18 consultation there was a policy for a school in Aylsham, but this is watered down in Policy GNLP0311, 0595 and 2060 where it merely states “2 ha of land at nil value to be provided for a new primary school on site”. There are no details as to when this will come forward. The school needs to come before the houses. There is no capacity in Aylsham schools currently and the full impact of the new housing at Bure Meadows and Willow Park is still to be felt. Also, we understand, this is not a new school, but a replacement of the existing school and there is no indication of the increase in size. There is a lack of urgency in this policy. Schools in neighbouring villages are also at capacity and Aylsham High School is also near capacity. In Reg 18 there was consultation on one site and the provision of a school. As there has been no consultation for two sites, the significant impact this will have on the provision of education in Aylsham and the surrounding area has not been addressed. Therefore, the decision to allocate two sites is not justified.
• There is limited nursery provision in Aylsham. This will be put under significant pressure by 300 homes let alone the extra 250 homes allocated.
• The road network through the town will not cope with the extra traffic generated by the new school and the increased population. The developers of this site and the GNLP have put in some mitigating factors in the immediate vicinity of the sites but ignored the fact that the road from the town to the site is already busy and in places needs to be single tracked and cannot be widened to accommodate additional traffic. These road problems will be magnified with the second site on Norwich Road and the proposed site at Badersfield. In addition, creation of nearly 900 new homes within a short distance of Aylsham town centre will create severe parking problems, which, pre-Covid, was already a major issue in Aylsham and once some normality is returned will continue to be. These issues highlight that the plans for Aylsham in Reg 19 are not sound as the document has failed to make a case that they are justified and will not significantly harm the town.
• The Town Council have been extremely disappointed with recent work undertaken by both Broadland District Council and Norfolk County Council on making improvements to the road network. Both authorities have looked at small sections rather than the whole town. Consultation so far has been inadequate at best and a meaningless cost exercise at worst. The Town Council have looked at this and come up with an initial plan and are continuing to refine this work. Reg 18 with one site would obviously create real problems for the road network; Reg 19 with two sites would make the problem significantly worse. The Plan does not justify in any way that it can cope with these problems.
• Reg 19 fails to justify how two sites with 550 homes would not have an adverse impact on the health and social care of the town. The consultation in Reg 18 concerning the issue of health and social care was in regard to 300 homes. Aylsham Care Trust (ACT) responded to an earlier consultation that they would like to see a day unit built to try and keep people in their own home, which is in keeping with government policy. In addition, there are already urgent problems regarding medical care within the town, which Reg 19 fails to consider.
In putting forward a second site, Reg19 offers a 90-bed care unit/extra care housing. However, without consultation, the response to the needs of health and social care and infrastructure in general within Aylsham have not been met and there is a real problem of soundness and in reality, neglect.
• The points above highlight how the allocation of two sites contradicts the Strategy section point 132 which states that new communities “will be reasonable and sustainable communities” and “well integrated with our existing communities”. To increase the number of homes in Aylsham in a short space of time by more than 15% will mean this objective of the Strategy document cannot be met.
• In point 136 it states that “homes will have good access to services and facilities” and they “will enhance local character to meet the needs of all mixed communities”. The failure to meet the infrastructure needs of the town, while wanting to expand the number of new homes by 83% from Reg 18, does mean that Reg 19 is not justified in respect of the document’s own strategy.
Is Regulation 19 effective?
• There is no evidence in the document that there has been any consideration of what is happening in the area to the north, north east and north west of Aylsham, which is in North Norfolk Local Authority. Recent announcements regarding a development of 300+ houses at nearby Badersfield will have an impact on Aylsham, as the majority of children from Badersfield attend Aylsham High School. There would also be increased pressure on the town centre and other services. This development is almost akin to a third site in Aylsham. Therefore, Reg 19 fails to be sound on a basic issue, consulting with and working with the neighbouring authority (See Section 33A of the Planning and Compulsory Purchase Act 2004 [F133 Duty to co-operate]).
Is Regulation 19 Consistent with National Policy
• An important strategy of the document and Central Government Policy is the move towards a carbon neutral footprint with awareness of climate change to be at the forefront of any decisions. Reg 19 fails to consider these issues in respect of Aylsham by putting forward two sites for development on the edge of the town where the residents will be dependent upon cars, thereby increasing the carbon footprint of the area, rather than looking to reach the carbon neutral target. One site, as was consulted upon in Reg 18, was a problem regarding working towards a climate neutral target, but to increase the number of new homes dependent on cars by 83% without consultation is negligent in respect of keeping to Central Government Policy and the Paris Accord.

Conclusion
• Reg 18 stated that Aylsham would have one site that was put forward for consultation. Reg 19 states there will be two sites, which has never been consulted. Therefore, this means that Reg 19 has failed to be legally compliant.
• Reg 19 has failed in soundness in considering the impact of two sites with 550 homes on the infrastructure of the town.
• Reg 19 has failed in soundness in its failure to keep to the strategy put forward in the first part of the Plan and central government policy.
• An important strategy of the document and central government policy is the move towards a carbon neutral footprint with awareness of climate change to be at the forefront of any decisions. Reg 19 fails to consider these issues in respect of Aylsham by putting forward two sites for development on the edge of the town where the residents will be dependent upon cars, thereby increasing the carbon footprint of the area, rather than looking to reach the carbon neutral target.

What changes should be made to GNLP Regulation 19 in respect of Aylsham?

• The inclusion of a second site put forward in Reg 19 should be withdrawn.
• The second site was included in Reg 19 to meet a target of 5000+ new homes beyond Reg 18. The 250 new homes allocated for the second site in Aylsham can be met by several different options:
1. The approval of two further developments at Drayton and near Rackheath, that were not in Reg 19, increases the number of additional homes put forward by over 400;
2. The GNLP could consider the allocation of a small number of homes in villages which need homes to maintain their viability;
3. The impact of Covid and Brexit will almost certainly lead to an increase in the number of brownfield sites becoming available for development. This option is certain to provide space for at least 250 more homes. It is perhaps worth highlighting that the area that provided the largest percentage of new homes from Reg 18 to Reg 19 was the main towns – a decision that was taken without consultation.
• Even without a second site in Aylsham, there needs to be improvements in the infrastructure to deal with the demand of 300 new homes:
1. The primary school should be in the first stage of development;
2. Before any further development Aylsham should have improved health and care facilities with a viable medical centre, including a doctor’s surgery, and a day care centre as put forward by ACT;
3. There must be a viable road management system with increased parking to be able to meet the needs of an increased population;
4. There must be significant improvements to the water supply and water management system before further development;
5. There must be improved broadband access;
6. There must be an upgrade to electrical sub-stations and provision of electrical charging points.
7. There must be protection for the green infrastructure around the town.
• All these infrastructure issues apply to Reg 18 where one site was put forward. However, to move to two sites, without consultation, creates a problem that may be insurmountable without significant investment, way beyond the support given by the developers for two sites. The local authority and the county council must be prepared to change their policies in respect of investment or accept that the damage caused by 550 new homes in a market town based on a medieval town structure with a population with a high percentage of senior people, is not suitable for this scale of development.
• Therefore, the second site put forward in Reg 19 should be withdrawn.
• Any further development must be in keeping with the points laid out in the Aylsham Neighbourhood Plan.

You need to consult and then this question can be answered!

Section 33A of the Planning and Compulsory Purchase Act 2004 [F133 Duty to co-operate ] requires Broadland to engage constructively, actively and on an ongoing basis with neighbouring authorities and certain other bodies over strategic matters during the preparation of the plan.
The LPA will be expected to provide evidence of how they have complied with the duty.
In regard to Aylsham, Broadland has not engaged constructively or otherwise with Aylsham Town Council, nor with North Norfolk District Council in respect of the Badersfield development near Aylsham.
We ask that Broadland provide evidence of how they have complied with this duty.
There is no evidence in the document that there has been any consideration of what is happening in the area to the north, north east and north west of Aylsham, which is in North Norfolk Local Authority. Recent announcements regarding a development of 300+ houses at nearby Badersfield will have an impact on Aylsham, as the majority of children from Badersfield attend Aylsham High School. There would also be increased pressure on the town centre and other services. This development is almost akin to a third site in Aylsham. Therefore, Reg 19 fails to be sound on a basic issue, consulting with and working with the neighbouring authority (See Section 33A of the Planning and Compulsory Purchase Act 2004 [F133 Duty to co-operate]).

The policy should state the school MUST come before the houses and Norfolk County Council must commit to this. IF both sites are agreed then the school must be built on the first site to come to development

There is a lack of clarity and urgency in Reg 19 on the building of a primary school. A sound approach would be to state that, with all the primary schools in Aylsham full, the building of the school should take place as a priority.

Detailed consultation is still required to see if or how these issues can be mitigated. The GNLP Failed to do this as they bypassed 18d

Other points highlight how the allocation of two sites in Aylsham contradicts the Strategy section point 132 which states that new communities “will be reasonable and sustainable communities” and “well integrated with our existing communities”. To increase the number of homes in Aylsham in a short space of time by more than 15% will mean this objective of the Strategy document cannot be met.

Remove the requirement for two sites

In point 136 it states that “homes will have good access to services and facilities” and they “will enhance local character to meet the needs of all mixed communities”. The failure to meet the infrastructure needs of Aylsham, while wanting to expand the number of new homes by 83% from Reg 18, does mean that Reg 19 is not justified in respect of the document’s own strategy.

Revert to Reg 18

Aylsham Town Council have been extremely disappointed with recent work undertaken by both Broadland District Council and Norfolk County Council on making improvements to the road network. Both authorities have looked at small sections rather than the whole town. Consultation so far has been inadequate at best and a meaningless cost exercise at worst. The Town Council have looked at this and come up with an initial plan and are continuing to refine this work. Reg 18 with one site would obviously create real problems for the road network; Reg 19 with two sites would make the problem significantly worse. The Plan does not justify in any way that it can cope with these problems.
Reg 19 fails to justify how two sites with 550 homes would not have an adverse impact on the health and social care of the town. The consultation in Reg 18 concerning the issue of health and social care was in regard to 300 homes. Aylsham Care Trust (ACT) responded to an earlier consultation that they would like to see a day unit built to try and keep people in their own home, which is in keeping with government policy. In addition, there are already urgent problems regarding medical care within the town, which Reg 19 fails to consider.
In putting forward a second site, Reg 19 offers a 90-bed care unit/extra care housing. However, without consultation, the response to the needs of health and social care and infrastructure in general within Aylsham have not been met and there is a real problem of soundness and in reality, neglect.

Reduce the number of houses to the Reg 18 level

An important strategy of the document and Central Government Policy is the move towards a carbon neutral footprint with awareness of climate change to be at the forefront of any decisions. Reg 19 fails to consider these issues in respect of Aylsham by putting forward two sites for development on the edge of the town where the residents will be dependent upon cars, thereby increasing the carbon footprint of the area, rather than looking to reach the carbon neutral target. One site, as was consulted upon in Reg 18, was a problem regarding working towards a climate neutral target, but to increase the number of new homes dependent on cars by 83% without consultation is negligent in respect of keeping to Central Government Policy and the Paris Accord.

The plan should be withdrawn as the methodology for calculating new homes is flawed

Two sites in Aylsham brings an increase to the proposed level of development to 83% on the consultation figure – 550 homes increases the total number of homes by 15.6%. The population of the town is likely to increase by a similar figure. This increase contradicts point 188 in the Strategy section which states there should be “reasonable levels of growth in the main towns.” This increase cannot be met by the current infrastructure in the town or by improvements offered by the plans within Reg 19.

Withdraw the plan until proper consultation has taken place

As stated under legal compliance, the residents of the town were consulted on the need for ONE site. There were concerns with Reg 18, particularly in respect of the demands it would make on the infrastructure of the town. However, to have two sites as in Reg 19 magnifies these infrastructure issues. In Reg 18 there was no mention of Aylsham having two sites and there has been no consultation with the Town Council or the residents on the allocation of two sites in Reg 19. Therefore, Reg 19 has not met the test of being justified.

Withdraw and consult

The process of community involvement should be in general accordance with the LPA’s Statement of Community Involvement [SCI]. In regard to Aylsham no virtual engagement methods have been used “to engage with community and stakeholder bodies “in the town.
1.6 Paragraph 155 of the NPPF (2012), states: 'Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged . . .
In regard to Aylsham, the Town Council were not approached and there is no evidence that "a wide section of the community has been proactively engaged".