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Policy 1 - The Sustainable Growth Strategy
Representation ID: 24091
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
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. The identification of Village Clusters as a location for development ensures that a proportion of forecast growth is distributed to sustainable locations in rural areas; an approach that ensures the provision of choice and will assist in enhancing and maintaining the vitality of rural communities. Accordingly, it is wholly appropriate and consistent with Government Guidance that Village Clusters should be identified as the preferred location to accommodate 9% of the housing growth during the period to 2038.
On this basis, the proposed Policy is considered to be sound.
Submitted by Bidwells on behalf of Abel Homes
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. The identification of Village Clusters as a location for development ensures that a proportion of forecast growth is distributed to sustainable locations in rural areas; an approach that ensures the provision of choice and will assist in enhancing and maintaining the vitality of rural communities. Accordingly, it is wholly appropriate and consistent with Government Guidance that Village Clusters should be identified as the preferred location to accommodate 9% of the housing growth during the period to 2038.
On this basis, the proposed Policy is considered to be sound.
Support
Publication
Policy 2 Sustainable Communities
Representation ID: 24092
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
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, if applicable, the provision of a Delivery Statement
Submitted by Bidwells on behalf of Abel Homes.
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, if applicable, the provision of a Delivery Statement
Support
Publication
Policy 7.4 Village Clusters
Representation ID: 24093
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
As detailed in comments relating to Policy 1 – The Sustainable Growth Strategy, the proposed Settlement Hierarchy is fully supported.
Village Clusters, such as Horsham St Faith, are sustainable rural locations that provide access to services, including primary schools, as well as access to employment opportunities and public transport links. Development in these locations will, in accordance with the NPPF, assist in enhancing and maintaining the vitality of rural communities.
Accordingly, it is wholly appropriate that Village Clusters should be identified as locations to accommodate a reasonable amount of growth (9% of the total housing growth) during the period to 2038. It fully supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.
Horsham St. Faith, which along with Newton St Faith, is identified as a Village Cluster. The cluster benefits from a Post Office and Store, pre-school, primary school, doctor’s surgery, public house, alongside a range of other services and amenities, as well as employment opportunities.
Accordingly, the identification of Horsham St Faith and Newton St Faith, which is in close proximity of Norwich and the NDR, as a village cluster supports the aspirations of directing growth to locations with good access to services and employment, alongside urban and rural regeneration and is fully supported.
On this basis, the proposed the Policy is considered to be sound.
Submitted by Bidwells on behalf of Abel Homes.
As detailed in comments relating to Policy 1 – The Sustainable Growth Strategy, the proposed Settlement Hierarchy is fully supported.
Village Clusters, such as Horsham St Faith, are sustainable rural locations that provide access to services, including primary schools, as well as access to employment opportunities and public transport links. Development in these locations will, in accordance with the NPPF, assist in enhancing and maintaining the vitality of rural communities.
Accordingly, it is wholly appropriate that Village Clusters should be identified as locations to accommodate a reasonable amount of growth (9% of the total housing growth) during the period to 2038. It fully supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.
Horsham St. Faith, which along with Newton St Faith, is identified as a Village Cluster. The cluster benefits from a Post Office and Store, pre-school, primary school, doctor’s surgery, public house, alongside a range of other services and amenities, as well as employment opportunities.
Accordingly, the identification of Horsham St Faith and Newton St Faith, which is in close proximity of Norwich and the NDR, as a village cluster supports the aspirations of directing growth to locations with good access to services and employment, alongside urban and rural regeneration and is fully supported.
On this basis, the proposed the Policy is considered to be sound.
Support
Publication
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 24094
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
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.
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.”
Taverham represents an excellent location with good access to Norwich, that has been significantly enhanced by the recent delivery of the Broadland Northway.
Taverham 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.
Submitted by Bidwells on behalf of Abel Homes.
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.
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.”
Taverham represents an excellent location with good access to Norwich, that has been significantly enhanced by the recent delivery of the Broadland Northway.
Taverham 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.
Object
Publication
Policy 5 Homes
Representation ID: 24095
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
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.
Affordble 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 & 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 current demonstrable 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.
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.
Self and Custom Build
The threshold for on-site provision should be increased to better reflect the demonstrable need. Clarity on the definition of self/custom build should be provided in the policy or supporting text.
Submitted by Bidwells on behalf of Abel Homes
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.
Affordble 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 & 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 current demonstrable 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.
Object
Publication
0125R Policy
Representation ID: 24096
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
On behalf of Abel Homes, we strongly support the allocation of GNLP0125R, land west of West Lane, Horsham St Faith for residential development. The site is entirely deliverable and capable of making a valuable contribution towards satisfying the Council's housing needs during the period to 2038.
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 (specifically some of criteria attached to the policy) is not sound, as elements are neither effective or justified. Minor alterations to Policy
GNLP0125R are therefore sought, to ensure its soundness.
See attached document for full representation
See attached document for representation including proposed wording changes to the policy
Submitted by Bidwells on behalf of Abel Homes.
See attached document for full representation
Object
Publication
0159R Policy
Representation ID: 24097
Received: 19/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
On behalf of Abel Homes, we strongly support the allocation of GNLP0159R for residential development. The site is entirely deliverable, and capable of making a valuable contribution towards satisfying the Councils’ housing needs during the period to 2038.
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 (specifically the identified quantum of the development that can be accommodated on the site) is not sound, as elements are neither effective or justified. Accordingly, minor alterations to Policy GNLP0159R are sought to ensure its soundness.
See attached document for full representation.
See attached document for full representation, including suggested changes to policy wording
Submitted by Bidwells on behalf of Abel Homes.
See attached document for full representation
Object
Publication
0520 Policy
Representation ID: 24191
Received: 22/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
On behalf of Abel Homes, we strongly support the allocation of GNLP0520, land South of Norwich
Road, Hingham. As demonstrated during the various Regulation 18 consultations, the site is entirely deliverable, and capable of making a significant contribution towards satisfying the Councils’ housing needs during the period to 2038.
The continued suitability of the site is detailed below. In considering the suitability of the site regard has been given to the specific requirements of Policy GNLP0520, as well as additional technical work, and discussions with key stakeholders, including the Lead Local Flood Authority and NCC (Highways), that have taken place since the Regulation 18 (c) consultation
On this basis, the allocation of land to the south of Norwich Road is considered to be sound based on the test of soundness set out in paragraph 35 of the NPPF, subject to minor alterations to the wording of Policy GNLP0520.
See attachment for full details
On this basis, it is recommended that the wording of Policy GNLP0520 is revised to state that the
site will accommodate at least 80 new homes; an approach that would be consistent with other site
allocations in the draft Greater Norwich Local Plan. The proposed amendment would ensure that
the policy is positively prepared, justified, and, therefore, sound.
On behalf of Abel Homes, we strongly support the allocation of GNLP0520, land South of Norwich
Road, Hingham. As demonstrated during the various Regulation 18 consultations, the site is entirely deliverable, and capable of making a significant contribution towards satisfying the Councils’ housing needs during the period to 2038.
The continued suitability of the site is detailed below. In considering the suitability of the site regard has been given to the specific requirements of Policy GNLP0520, as well as additional technical work, and discussions with key stakeholders, including the Lead Local Flood Authority and NCC (Highways), that have taken place since the Regulation 18 (c) consultation
On this basis, the allocation of land to the south of Norwich Road is considered to be sound based on the test of soundness set out in paragraph 35 of the NPPF, subject to minor alterations to the wording of Policy GNLP0520.
See attachment for full details
Support
Publication
Policy 7.3 The Key Service Centres
Representation ID: 24192
Received: 22/03/2021
Respondent: Abel Homes
Number of people: 2
Agent: Bidwells
As detailed in comments relating to Policy 1 – The Sustainable Growth Strategy, the proposed Settlement Hierarchy is fully supported. Key Service Centres, such as Hingham, are sustainable locations that provide a range of services, as well as access to employment opportunities and public transport links. Accordingly, it is wholly appropriate that Key Service Centres should be identified as locations to accommodate a reasonable amount of growth (7% of the total housing growth) during the period to 2038. It fully supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.
As detailed at paragraph 377, Hingham is a location which has a range of services and amenities to support day to day life, including a primary school, Co-op Food, White Hart Pub, library, a doctor’s surgery, alongside a range of employment uses. The suitability and sustainability of Hingham for growth has been demonstrated through The Hops, a development of 88 dwellings. The Hops, which was allocated under Policy HIN 1 of the Adopted Development Plan, had a delivery rate of three and a half years (from submission of planning application to completion).
On this basis, the proposed policy is considered to be sound.
On behalf of Abel Homes, we strongly support the allocation of GNLP0520, land South of Norwich
Road, Hingham. As demonstrated during the various Regulation 18 consultations, the site is entirely deliverable, and capable of making a significant contribution towards satisfying the Councils’ housing needs during the period to 2038.
The continued suitability of the site is detailed below. In considering the suitability of the site regard has been given to the specific requirements of Policy GNLP0520, as well as additional technical work, and discussions with key stakeholders, including the Lead Local Flood Authority and NCC (Highways), that have taken place since the Regulation 18 (c) consultation
On this basis, the allocation of land to the south of Norwich Road is considered to be sound based on the test of soundness set out in paragraph 35 of the NPPF, subject to minor alterations to the wording of Policy GNLP0520.
See attachment for full details
