Publication

Please see the separate sheet appended to this representation.

The policy’s objective of encouraging the delivery of Purpose-Built Student Accommodation (PBSA) to support the growth of the University is, in principle, supported.

Away from the UEA campus, the draft policy states that proposals for PBSA will be supported where the need for the development is justified by the current or proposed size of Norwich’s higher education institutions, and the proposals will adhere to a range of criterion.

One of these criterion requires off-campus PBSA to make provision for a policy-compliant proportion of affordable housing that would be expected if the site were developed for general needs housing.

This element of the policy is considered unsound, as PBSA should not be expected to contribute towards affordable housing provision. Paragraph 64 of the NPPF specifies that, where the provision of housing is proposed, at least 10% of the homes should be made available for affordable home ownership. Paragraph 64(b) of the NPPF states that PBSA is exempt from this 10% requirement.

On this basis, to ensure that the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to recognise that PBSA should not be expected to contribute towards affordable housing provision.

On behalf of our clients University of East Anglia, we support the proposed allocation of Policy GNLP0133-C – Land North of Cow Drive, within the Pre-Submission (Reg 19) Joint Local Plan.

Delivery of the site within the Plan period to 2038 is achievable, and the site remains suitable, available, achievable and viable for the following reasons:

Suitable
The identification of the site as a preferred allocation will help to support the expansion of the UEA, alongside sustaining and enhancing the valuable role which the UEA holds for Norwich and the wider context. The UEA are fully committed to development on this site, and view it as an integral part of meeting the UEA’s future growth requirements.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenants on the site. The availability of the site has been demonstrated by the extant planning consent on the site. Consequently, the site is readily available for development

Achievable
Based on the suitability assessment above, there are no site-specific constraints which could preclude the delivery of student accommodation on the site. In addition the achievability of the site has been demonstrated by the extant planning consent on the site. Therefore, the development of student accommodation on the site is deemed to be entirely achievable.

Viable
We are confident that the delivery of the site is viable having regard to the policy requirements of the draft GNLP and there are no factors that we are aware of, at this moment in time, that could prevent the delivery of the site. The viability of development on the site has been demonstrated by Phase 1 (Blocks A and B), which have been completed on the site.

To ensure the legal compliance of the policy wording, we would suggest that reference to 'Use Class F1' is revised to read 'Use Class F.1'. This is suggested to ensure exact compliance with the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020.

On behalf of our clients the University of East Anglia, we support the proposed allocation of Policy GNLP0133-BR – Land adjoining the Enterprise Centre at Earlham Hall, within the Pre-Submission (Reg 19) Joint Local Plan.

A minor modification to policy wording, specified within Section 6 of this document, outlines the amendment we consider is necessary to achieve legal compliance.

Delivery of the site within the Plan period to 2038 is achievable, and the site remains suitable, available, achievable and viable for the following reasons:

Suitable
The identification of the site as a draft allocation will help to support the expansion of the UEA, alongside sustaining and enhancing the valuable role which the UEA holds for Norwich and the wider context. The UEA are fully committed to development on this site, and view it as an integral part of meeting the UEA’s future growth requirements.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenants on the site. Consequently, the site is readily available for development.

Achievable
There are no site-specific constraints which could preclude the delivery of university related uses on the site. Therefore, delivery of university related uses on the site is deemed to be entirely achievable.

Viable
We are confident that the delivery of the site is viable having regard to the policy requirements of the draft GNLP and there are no factors that we are aware of, at this moment in time, that could prevent the delivery of the site.

To ensure the soundness of the policy wording, we would suggest that Point 6 of the Policy GNLP0133-E is revised to read as follows: 'Include an enhanced pedestrian and cycling connection through the site from Bluebell Road to the Broad, and linkages to and along the open river valley landscape to the south and east'.

The deletion of the remainder of this element of policy wording is considered necessary to secure the deliverability of all elements of Policy GNLP0133-E. The Bartram Mowers site is not within the University's land control, so enhancement of linkages to open spaces within this site, and the development as approved through application ref: 19/00911/F, cannot be guaranteed.

In addition, the following changes to policy wording are recommended, to assist in developing the design proposals for the site during the Plan period:

Point 2 to be reworded as follows: 'Generally low-rise development (at least 2-3 storeys) however acknowledging the enclosed nature of the site, the scale/building height of any proposed development will be tested against an assessment of its landscape and visual impact, to consider the impact on adjoining residential properties and established open space'

On behalf of our clients the University of East Anglia, we support the proposed allocation of Policy GNLP0133-E – Land at the UEA Grounds Depot Site, within the Pre-Submission (Reg 19) Joint Local Plan.

A modification to policy wording, specified within Section 6 of this document, outlines the amendment we consider is necessary to achieve soundness. Delivery of the site within the Plan period to 2038 is achievable, and the site remains suitable, available, achievable and viable for the following reasons:

Suitable
The identification of the site as a draft allocation will help to support the continued expansion of the UEA, alongside sustaining and enhancing the valuable role which the UEA holds for Norwich and the wider context. The UEA are fully committed to development on this site, and view it as an integral part of meeting the UEA’s future growth requirements.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenants on the site. Consequently, the site is readily available for development.

Achievable
There are no site-specific constraints which could preclude the delivery of student accommodation and a small element of ancillary university related uses. Therefore, student accommodation and a small element of ancillary university related uses development on the site is deemed to be entirely achievable

Viable
We are confident that the delivery of the site is viable having regard to the policy requirements of the draft GNLP and there are no factors that we are aware of, at this moment in time, that could prevent the delivery of the site.

To ensure the soundness of the policy wording and associated preamble text, we would suggest that Paragraph 2.39 is revised to delete the following text: 'Since the proposal involves the loss of existing open space, any development must include the opening up of new areas for public access as compensation for this loss'

The University campus, and associated University-owned and managed open spaces, are free for the public to access and enjoy. As the vast majority of University-owned open spaces are not impacted by Policy GNLP0133-DR, it is not considered that this wording is justified or necessary.

On behalf of our clients the University of East Anglia, we support the proposed allocation of Policy GNLP0133-DR – Land Between Suffolk Walk and Bluebell Road, within the Pre-Submission (Reg 19) Joint Local Plan.

A modification to policy wording, specified within Section 6 of this document, outlines the amendment we consider is necessary to achieve legal compliance.

Delivery of the site within the Plan period to 2038 is achievable, and the site remains suitable, available, achievable and viable for the following reasons:

Suitable
The identification of the site as a draft allocation will help to support the expansion of the UEA, alongside sustaining and enhancing the valuable role which the UEA holds for Norwich and the wider context. The UEA are fully committed to development on this site, and view it as an integral part of meeting the UEA’s future growth requirements.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenants on the site. Consequently, the site is readily available for development.

Achievable
Based on the suitability assessment above, there are no site-specific constraints which could preclude the delivery of academic and non-academic university related development on the site. Therefore, academic and non-academic development on the site is deemed to be entirely achievable.

Viable
We are confident that the delivery of the site is viable having regard to the policy requirements of the draft GNLP and there are no factors that we are aware of, at this moment in time, that could prevent the delivery of the site.

On behalf of our clients University of East Anglia, we support the proposed allocation of Policy GNLP0140-C, within the Pre-Submission (Reg 19) Joint Local Plan.

Delivery of the site within the Plan period to 2038 is achievable, and the site remains suitable, available, achievable and viable for the following reasons:

Suitable
The identification of the site as a draft allocation will help to support the expansion of the UEA and the wider NRP, alongside sustaining and enhancing the valuable role which the UEA and NRP hold for Norwich and the wider context. The UEA are fully committed to development on this site, and view it as an integral part of meeting the UEA’s future growth requirements. Given that the site benefits from historic planning consent for an Innovation Centre (reference: 2008/0736), the suitability of development on the site has been previously established.

Available
The UEA are long-term leaseholders of the site. It is anticipated that development on the site would commence within the plan period, noting the expiry of the current use in 2027.

Achievable
Based on the suitability assessment above, there are no site-specific constraints which could preclude the delivery of Class E Science Park development, hospital expansion and other proposals ancillary and complementary to these uses.

Viable
We are confident that the delivery of the site is viable having regard to the policy requirements of the draft GNLP and there are no factors that we are aware of, at this moment in time, that could prevent the delivery of the site.