Publication

Comments on behalf of clients Hopkins Homes, Persimmon Homes and Taylor Wimpey regarding site GNLP0132 in Sprowston.

The proposed Settlement Hierarchy and the identification of Norwich and the Norwich Fringe as the
location to accommodate 66% of the housing growth during the period to 2038 is strongly supported.
Norwich and the Norwich Fringe is the catalyst for economic growth in the area and provides a range of
amenities, services and infrastructure to support sustainable housing.
The fringe parishes 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 faclities.”
The identification of Sprowston as a location to accommodate significant growth is fully supported.
Sprowston is a highly sustainable location, within the Growth Triangle, and enjoys easy access to strategic
employment opportunities, particularly at Broadland Business Park and Norwich Airport Industrial Estate,
as well as local employment within Rackheath and Salhouse Road. It also enjoys high quality public
transport links into Norwich City Centre, and has a good relationship with the existing services and facilities
in the Norwich fringe.

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 provide some flexibility to recognise need and viability, where necessary.

Self and Custom Build

The threshold should be increased, to better reflect the likely need.

Comments on behalf of clients Hopkins Homes, Persimmon Homes, Taylor Wimpey with regard to site GNLP0132 in Sprowston

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 ageing
population is also supported.
However, there are a number of elements of the Policy that are not currently sound, as they are not justified
or consistent with national policy.
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.
Self and 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.
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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 increased to a level which better reflects 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, and the potential for CIL exemption, where appropriate, in order to ensure that developments required to deliver strategic infrastructure are viable.

In addition, it is considered that site specific viability appraisals should be undertaken for the strategic sites (1000+ units) to ensure that, notwithstanding the identified infrastructure requirements, the developments are viable, with the option for bespoke policy requirements and CIL arrangements for the sites if necessary. This approach would be in accordance with paragraph 005 of the Planning Practice Guide, and paragraph 34 of the NPPF, and will ensure that the local plan is deliverable over the plan period and, therefore, sound.

Comments on behalf of clients Hopkins Homes, Persimmon Homes, Taylor Wimpey regarding site GNLP0132 in Sprowston

The strategic objectives in relation to transport, education, energy, water and health infrastructure are generally supported. However, the Policy is not currently entirely sound, as certain elements are not justified, effective or consistent with national policy.

More specifically, the policy fails to acknowledge that the requirement to accommodate or deliver strategic infrastructure may have implications for the viability of some of the larger strategic sites. For instance, a requirement for an individual site to accommodate a large item of strategic infrastructure, such as a secondary school, which is required to facilitate growth in the wider area, and not just to meet the demand generated by the site itself, is likely to impact on the viability of that particular site in a disproportionate and unfair manner.

Such impacts have not been properly considered or reflected in the Viability Study that underpins the Regulation 19 Plan; this is at odds with paragraph 34 of the NPPF. Paragraph 005 of the Planning Practice Guide makes it clear that it is important to consider the specific circumstances of strategic sites, and that plan makers can undertake site specific viability assessments for sites that are critical to delivering the strategic priorities of the plan, such as sites that enable or unlock other development sites.

Requirement to accommodate strategic infrastructure

In the absence of any more generic wording in the Strategy Document, it is considered that the policy
wording should make provision for future consideration of site-specific viability, and the ability to negotiate on matters such as affordable housing and CIL if necessary, if the site is required to provide/accommodate
strategic infrastructure, which is required to facilitate the delivery of wider growth aspirations. This approach would be in accordance with Paragraph 34 of the NPPF and Paragraph 005 of the Planning Practice Guide.
In this instance, there is a requirement for this site to accommodate a secondary school that will serve the
North-East growth area more widely, far in excess of the requirement to mitigate the impacts of the individual development. Indeed, this is the only site in the Regulation 19 Plan which carries such a requirement. This will, inevitably, impact on the viability of the site, and its ability to deliver a fully policy compliant
development. This was recognised in our Regulation 18C Representation, which requested flexibility in relation to affordable housing provision and CIL.
In addition, Anglian Water have indicated that it may be necessary for the site to accommodate a Terminal
Pumping Station, to enable the delivery of wider network improvements. Again, even if there is no requirement for the Consortium to fund this infrastructure, it has the potential to impact on the site’s viability, by reducing the amount of land available for development.
It is clear from this that the site is critical to the provision of key infrastructure to facilitate the wider growth
aspirations for north-east Norwich.
The updated Viability Study that underpins the Regulation 19 Publication does not consider the impact of such matters on the larger strategic sites. In order to ensure soundness, in circumstances where a site is required to provide or accommodate strategic infrastructure, provision should be made for other policy requirements that impact on viability, such as affordable housing, to be negotiated.
Subject to resolution of the matters identified above, the proposed allocation is considered to be sound.
The site is an entirely suitable location for strategic-scale growth, and is deliverable within the Plan period.

Introduction
On behalf of a Consortium of regional and national housebuilders, comprising Persimmon Homes, Hopkins
Homes and Taylor Wimpey (hereafter ‘the Consortium’), we strongly support the proposed allocation of site GNLP0132 for residential development. As demonstrated during the various Regulation 18 consultations, the site is suitable, available and viable, and capable of delivering a significant quantum of development in a highly sustainable location. The Consortium have an excellent track record of delivery in the area; they are currently on site building out Phase 1 of the wider White House Farm landholding (1,179 dwellings) and have secured a resolution to approve outline planning permission for Phase 2 (up to 456 dwellings), immediately to the east of site GNLP0132. As set out in the draft Statement of Common Ground, the site can be delivered in the Plan Period. However, whilst the principle of allocating the site for development is considered sound, in accordance
with the tests set out in paragraph 35 of the NPPF, the detailed wording and requirements of the policy are
not sound, as elements are neither effective, justified nor consistent with national policy. Minor alterations to Policy GNLP0132 are therefore sought, to ensure its soundness.

Quantum of development
In January 2020, as part of the Regulation 18(C) Consultation, a requirement for the site to demonstrate
“the potential for the site to incorporate a well-located High School” was introduced into the wording of Policy GNLP0132. As part of our Regulation 18 (C) Representation, the Consortium confirmed that they
were amenable to considering accommodating a secondary school, but at that stage, there had not been
sufficient time to fully understand the implications of this on the wider site. A crude estimate of the likely reduction in dwelling numbers had been undertaken, and reduced the likely quantum of development from the 1,350 originally sought, to 1,200 with the secondary school.
During the summer of 2020, the Consortium continued to engage with Norfolk County Council’s Education
department on this matter, and NPS, on behalf of the County Council, undertook a feasibility study to identify where within the site it might be possible to accommodate the 12ha school site. Their key requirements were for the site to be as flat as possible, and for the full 12ha to be provided with as few constraints as possible (for instance, avoiding key Green Infrastructure corridors as far as possible). As a result of this, a potential location for the school was identified in the north-eastern corner of the site. Following this, the Consortium have undertaken a review of the initial high-level Masterplan for the site,
that was drawn up in 2017/18 in support of the first Regulation 18 consultation. Reflecting on not only the
provision of the school site, but also other consultation responses received during the Regulation 18(C)
Consultation, notably those from the Woodland Trust and Norfolk Wildlife Trust, the review of the Masterplan has identified that it may not be possible to deliver 1,200 homes and a secondary school on the site, at an appropriate density. The site is subject to a number of considerations, including buried services/infrastructure, bat corridors crossing the site, and areas of Ancient Woodland, which will influence the scale of development that can be accommodated, and the capacity of the site is likely be closer to 1,000 dwellings. It is therefore considered prudent to reflect this in the policy wording, whilst allowing sufficient flexibility through the use of ‘at least’ to deliver more than this, should it be possible to achieve this during detailed design. Should the land for the secondary school not be required, then the site will be
able to deliver significantly in excess of the 1,000 unit figure.

Shared Use of School Sports Provision
During the ongoing discussions with NCC Education that took place in 2020, it was agreed that the sports pitches provided by the school would be made available for community use, and that it would consequently not be necessary for any further sports pitches to be provided within the site to serve the residential development. This agreement was critical to ensuring the continued viability of the site, and fundamental to the Consortium’s agreement to consider accommodating the secondary school, as it reduces the impact of the school’s land requirement on the developable area of the site by in the region of 5 hectares. Unfortunately, whilst this agreement is reflected in the wording of bullet point 5 of the Policy, bullet point 8 erroneously requires the provision of formal recreation, in the form of sports pitches and childrens’ play space, adjacent to the ancient woodland (which is located in the south-eastern corner of the site). In addition to being contrary to the agreed position in relation to sports pitch provision, bullet point 8 is also unnecessary in relation to childrens’ play space; the most suitable location for children’s play space will be determined through the Masterplanning process. It is assumed that the requirement to locate the formal recreation space adjacent to the ancient woodland is in response to the comments received at Regulation 18 C stage from the Woodland Trust and Norfolk Wildlife Trust, in relation to buffering of Bulmer Coppice. It is considered that bullet point 6 offers adequate protection to the Ancient Woodland, and appropriate buffering, if found to be required based on further consideration of the nature and value of Bulmer Coppice, will be incorporated into the Masterplan for the site.

Requirement to accommodate strategic infrastructure
In the absence of any more generic wording in the Strategy Document, it is considered that the policy
wording should make provision for future consideration of site-specific viability, and the ability to negotiate on matters such as affordable housing and CIL if necessary, if the site is required to provide/accommodate strategic infrastructure, which is required to facilitate the delivery of wider growth aspirations. This approach would be in accordance with Paragraph 34 of the NPPF and Paragraph 005 of the Planning Practice Guide.
In this instance, there is a requirement for this site to accommodate a secondary school that will serve the
North-East growth area more widely, far in excess of the requirement to mitigate the impacts of the individual development. Indeed, this is the only site in the Regulation 19 Plan which carries such a requirement. This will, inevitably, impact on the viability of the site, and its ability to deliver a fully policy compliant development. This was recognised in our Regulation 18C Representation, which requested flexibility in relation to affordable housing provision and CIL.
In addition, Anglian Water have indicated that it may be necessary for the site to accommodate a Terminal
Pumping Station, to enable the delivery of wider network improvements. Again, even if there is no requirement for the Consortium to fund this infrastructure, it has the potential to impact on the site’s viability, by reducing the amount of land available for development.
It is clear from this that the site is critical to the provision of key infrastructure to facilitate the wider growth
aspirations for north-east Norwich.
The updated Viability Study that underpins the Regulation 19 Publication does not consider the impact of such matters on the larger strategic sites. In order to ensure soundness, in circumstances where a site is required to provide or accommodate strategic infrastructure, provision should be made for other policy
requirements that impact on viability, such as affordable housing, to be negotiated.
Subject to resolution of the matters identified above, the proposed allocation is considered to be sound.
The site is an entirely suitable location for strategic-scale growth, and is deliverable within the Plan period.