Publication

See attached document for full representation and suggested amendments to the wording of the policy.

On behalf of M Scott Properties Ltd (Scott Properties) we strongly support the allocation of GNLP0337R, Land between Fir Covert Road & Reepham Road, Taverham.

However, whilst the principle of the policy is considered sound, in accordance with the tests set out in paragraph 35 of the NPPF, the detailed wording is not sound, as elements are neither effective or justified. Minor alterations are therefore sought to ensure its soundness.

See attached document for full representation.

Submitted by Bidwells on behalf of Scott Properties

The GNLP’s approach to providing choice and flexibility in terms of housing growth by accommodating 22% more homes than are needed+ is supported.

The buffer will help maintain the supply and delivery of housing in accordance with the NPPF and specifically the Government’s objective of encouraging authorities to consider more growth than required to meet local housing need, particularly where there is potential for significant economic growth.

The proposed Settlement Hierarchy is fully supported. Norwich and the Urban Fringe, which includes Taverham, is the most sustainable location within the Greater Norwich area and is the focus for significant economic growth. Norwich is the catalyst for economic growth in the area and provides a range of amenities, services and infrastructure to support sustainable housing. Accordingly, it is wholly appropriate and consistent with Government Guidance that it should be identified as the preferred location to accommodate 66% of the housing growth during the period to 2038.

On this basis, the proposed the Policy is considered to be sound.

To make the Local Plan sound, criterion 4 of Policy 2 - Sustainable Communities should be revised as follows:


Make efficient use of land with densities dependent on site characteristics and scheme specific considerations, with higher densities and car free housing in the most sustainably accessible locations in Norwich. Indicative minimum net densities are 25 dwellings per hectare across the plan area and 40 in Norwich.

Submitted by Bidwells on behalf of Scott Properties.

The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change is supported.

To demonstrate the ability to secure these objectives, we support the preparation of a Sustainability Statement as part of an application for a major development, and, where applicable, the provision of Delivery Statements.

However, whilst principle of the policy is considered sound, amendments are required to the detailed wording of the policy to ensure that, in accordance with the tests set out in paragraph 35 of the NPPF, it is sound. Therefore, minor alterations to Policy GNLP0132 are therefore sought, to ensure its soundness.

The requirement to ensure the efficient use of land by, amongst other things, providing an indicative minimum density of 25 dwellings per hectare is supported, however, the policy should make it clear that, as well as giving consideration to on site characteristics, consideration will be given to a range of other site / scheme specific issues, such as housing mix and design considerations? For example, the inclusion of bungalows within a development to meet an identified need is likely to result in a lower density development.

On this basis, it is considered that, as drafted, the policy is neither positively prepared or justified given that it falls to provide flexibility to enable the policy to respond to changing circumstances and meet identified need.

To ensure that strategic infrastructure can be provided through the development of the strategic sites identified in the Local Plan, and that specific sites do not bear a disproportionate burden of infrastructure provision, the policy should be amended to make provision for a reduction in other policy requirements, such as affordable housing, where appropriate and demonstrated to be justified, in order to ensure that developments required to delivery strategic infrastructure are viable.


To ensure that strategic infrastructure, such as primary schools, can be provided through the development of the strategic sites identified in the Local Plan, we consider that site specific viability appraisals should be undertaken to ensure that, notwithstanding the identified infrastructure requirements, the developments are viable. This would ensure a consistent approach with paragraph 57 of the Viability Assessment (December 2020)

The proposed amendment will ensure that the local plan is deliverable over the plan period and, therefore, sound.

Submitted by Bidwells on behalf of Scott Properties.

The strategic objectives in relation to transport, education, energy, water and health infrastructure are generally supported.

In particular, the flexibility the policy provides for the provision of new schools to take account of changing circumstances and allow for the timely delivery of schools when and where they are required, is supported.

Notwithstanding the foregoing, when considering infrastructure provision, consideration should be given to the implications for development viability on some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. the requirement to provide schools and health centres on land which otherwise would be land developable for alternative uses and which is required to facilitate growth in the wider area, not just to meet demand generated by the site itself.

The implications for viability on the larger strategic sites should be considered through site specific Viability Appraisals as suggested by paragraph 57 of the Viability Assessment (December 2020).

Affordable Housing

The policy should be revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.

Space Standards
In the apparent absence of the necessary robust evidence to justify it, the policy should, if this element is to be retained, provide some flexibility to recognise need and viability, where necessary.


The policy should clarify the type of specialist housing that will be required to provide affordable housing, as well as a definition of what is affordable care.

Self and Custom Build

The threshold should be increased, to better reflect the likely need. Clarity on the definition of self/custom build should be provided in the policy or supporting text.

Submitted by Bidwells on behalf of Scott Properties.

The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an aging population is also supported. However, there are a number of elements of the Policy that require alteration to ensure soundness.

Affordable Housing

As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.

On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.

Space Standards

Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.

This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms. At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.

Accordingly, we would suggest that if this element of the policy is to be retained that , as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.

Whilst the principal of specialist housing is generally supported, clarity is required on what type of specialist housing will be required to provide affordable housing. More specifically, it is not considered that residential and nursing care homes constitute dwellings that generate a requirement for affordable housing provision. In addition, it is considered that the policy should provide a definition as to what is affordable care. Without this information, the policy is not considered to be effective.

Self & Custom Build

The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.

The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own, deliver substantially more than the identified need.

Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is reduced to a level which better reflects need.

In addition, to provide clarity the policy, or supporting text, should provide further evidence on what is classified as a self / custom build unit. For example, if a developer provides a potential purchaser with a degree of choice in relation to the layout and design of their unit, such as the reconfiguration of layouts to suit individual requirements, or the provision of foundations, pipework to facilitate an extension at a later date, does this constitute a Custom Build unit for the purposes of the policy?

On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.

Submitted by Bidwells on behalf of Scott Properties.

The proposed Settlement Hierarchy and the identification of Norwich and the Urban Fringe as the location to accommodate 66% of the housing growth during the period to 2038 is strongly supported.

Norwich and the Urban Fringe is the catalyst for economic growth in the area and provides a range of amenities, services and infrastructure to support sustainable housing.

The Urban Fringe will play a significant role in providing sustainable growth, given their proximity to employment opportunities, services and strategic infrastructure, such as Broadland Northway. In addition, by virtue of its location, the fringe parishes are in close proximity of the countryside providing ease of access to the leisure and recreation opportunities it provides.

The fringe parishes provide opportunities for strategic growth i.e. over 1,000 units. Developments of this scale are capable of providing a wide range of infrastructure improvements, such as schools, employment, health centres and green infrastructure, which will provide benefits to both existing and future residents.

This approach is entirely consistent with paragraph 72 of the NPPF, which advises that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided that they are well located and designed and supported by the necessary infrastructure and facilities.”

The identification of Taverham as a location to accommodate approximately 1,400 dwellings by way of a strategic urban extension is fully supported.

Taverham provides a highly sustainable location to provide a strategic urban extension of a minimum of 1,400 units. It represents an excellent location with good access to Norwich, that has been significantly enhanced by the recent delivery of the Broadland Northway. The buffer created by the Broadland Northway presents an opportunity for a logical strategic urban extension to the settlement of Taverham at a size and scale that can, whilst being proportionate to the scale of the settlement, accommodate a significant quantum of the infrastructure and housing required in the Greater Norwich Area over the next two decades.

Taverham already benefits from a variety of amenities including a public house, a supermarket, takeaways, petrol filling station and a garden centre. In addition, the area is within close proximity of the amenities provided within Thorpe Marriott and Drayton. Nightingale and Ghost Hill Infant schools are located in close proximity of the site, as are Taverham Junior and High Schools. A private school (Langley Preparatory School at Taverham Hall) is located nearby. These will be sustained and enhanced by the increased population proposed.

Please see accompanying statement and supporting information. Site GNLP0341 in Diss should be allocated for older peoples housing

Please see accompanying statement and supporting information regarding Land between Shelfanger Road and Mount Street Diss (Reference GNLP0341).

Please see accompanying statement and supporting information. Site GNLP0341 in Diss should be allocated for older peoples housing in the plan

Please see accompanying statement and supporting information regarding Land between Shelfanger Road and Mount Street Diss (Reference GNLP0341).

Please see accompanying statement and supporting information for site GNLP0341 in Diss and the request for it to be allocated for older peoples housing in the plan.

Please see accompanying statement and supporting information regarding Land between Shelfanger Road and Mount Street Diss (Reference GNLP0341).

Please see accompanying statement.

Please see attached representation and supporting documents.