Publication

Object

Representation ID: 24289

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation.

Policy 1 – The Growth Strategy

4.2.1 As discussed in Section 3, the local housing needs assessment conducted using the Standard Method set out in national planning guidance forms only the minimum level of housing need for a local authority and does not establish a housing requirement figure.
4.2.2 Using the Government’s standard methodology for identifying local housing need, based on the 2014 household projections, the GNLP’s housing requirement for the period 2018-2038 is 40,541.
4.2.3 Nonetheless, the standard method does not account for changing economic circumstances, government policies or other issues that may affect demographic behaviour. In this instance, national planning policy does highlight circumstances whereby additional housing growth above the figure indicated by the standard method may be appropriate, including:
• “growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.”
4.2.4 It is vital that the Plan considers economic growth when assessing the local housing need and considers if it is appropriate to set a higher housing requirement than indicated by the standard method to support economic growth ambitions
. Further to this, the Greater Norwich City Deal was signed with Government in December 2013 which aimed to create an additional 19,000 jobs and 3,000 homes. In order to support the enhanced growth potential, it is vital
that the GNLP plans for a sufficient number of new homes.
4.2.5 Additionally, the Government has highlighted the long-term role the planning system and housebuilding has to play in the economic recovery from the COVID-19 pandemic, locally and nationally
. In this way, Gladman encourages the GNDP to fully consider the merits of planning for a housing figure beyond the minimum requirement of 2,027 dwellings per annum. For instance, an increased housing figure would enable the Greater Norwich authorities to capture
a larger proportion of the £7 billion yearly housebuilder contributions10. With 218,000 homes predicted not to be built due to COVID-19 from now to 2024/2511, it is also imperative that the GNLP identifies sufficient land to support the delivery of homes.
4.2.6 In order for the housing needs for the whole plan period to be met, it will also be essential to provide sufficient headroom within the housing supply. In this regard, Gladman supports the Home Builders Federation’s recommendation that local plans should seek to identify sufficient deliverable sites to provide a 20% buffer between the housing requirement and supply.
4.2.7 Table 6 sets out the GNLP’s total housing potential between 2018 and 2038 which establishes that the GNLP has the potential to provide a buffer of 22% over its housing requirement. Gladman acknowledges and supports the GNLP in its provision of a 22% buffer above thelocal housing need figure but questions whether the buffer is sufficient after taking into consideration the additional housing needs of Norwich due to the signed City Deal. Any homes which are included in the figures to meet the need of the greater growth aspirations should not be included within the buffer. If the result of removing this additional need from the current 22% buffer resulted in a buffer of below 20%, then further sites should be
allocated.
4.2.8 Gladman notes that 74% of the growth expected to come forward over the plan period to 2038 is from completions since the start of the plan period in 2018, permitted sites and existing allocations and commitments from the Site Allocations Plans, Area Action Plans for
Wymondham, Long Stratton and the Growth Triangle and Neighbourhood Plans. Gladman acknowledges that a proportion of these sites already benefit from planning permission however raise concern over the deliverability of these sites.
4.2.9 Gladman has specific concerns that the levels of housing proposed will not be delivered on these existing allocations, many of which have been allocated for over five years and have not come forward to date. Gladman questions whether any further analysis or evidence has been provided to understand why these sites have not delivered and to demonstrate clearly that
these sites will realistically be delivered within the plan period to 2038.
4.2.10 In order to achieve the figure of 31,452 dwellings coming from existing commitments, the GNLP is reliant upon an uplift of the housing density on the existing allocated sites. Gladman questions whether this approach is realistic or feasible. It appears to be an uncertain strategy to assume densities will increase on allocated sites and any uplift needs to be fully supported
by evidence that there is a realistic chance that the uplifted quantum of development is achievable on the site. It is important to consider the implications Covid-19 has had on the demand on certain types of properties. A recent Savills Survey12 found that 39% of under 50s
now want a bigger home with greater importance being put on more outdoor space. With this in mind, Gladman questions if it is realistic to assume that an uplift in the density of existing allocations can be achieved and suggests a more appropriate strategy would be to
allocate further sites to ensure that a sufficient buffer is available.
Settlement Hierarchy
4.2.11 Table 7 sets out Policy 1’s settlement hierarchy. The hierarchy comprises four tiers to support
a proportionate amount of growth according to the size and role of the settlement.
4.2.12 Gladman is supportive of the settlement hierarchy and particularly the identification of Diss and Wymondham as Main Towns. Table 7 shows that the growth in this tier of the hierarchy is 6,806 additional dwellings up to 2038. The amount of growth allocated to the Norwich Urban Fringe is 32,691 dwellings to 2038. Gladman submits that there is a risk to the delivery
of the sites identified on the Norwich Urban Fringe due to issues such as market saturation. Gladman also questions whether the uplift to the assumed densities on sites in this location are realistic and achievable.
4.2.13 Gladman submits that further growth should be allocated to the Main Towns to ensure the housing need figure is delivered and to allow for greater flexibility. Offering a wider variety of sites to the market in varied locations across the Greater Norwich area will provide greater certainty that the housing requirement will be met. Gladman’s submissions in respect of the growth strategy are provided in more detail below under Policy 7 – Strategy for Areas of Growth.

Object

Representation ID: 24290

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation.

Policy 2 – Sustainable Communities

4.3.1 This policy seeks to ensure that the design of development is of high quality, contributes to the establishment and maintenance of resilient and inclusive communities, promotes low carbon development and helps to address climate change. Table 8 sets out the key issues addressed by Policy 2, which include access to services and facilities, new technologies, green infrastructure, densities, local character, travel, inclusive and safe communities, resource efficiency and pollution, water and energy.

Densities
4.3.2 Gladman supports the principle of developments making effective use of land and that densities should be dependent upon on-site characteristics with higher densities in the most sustainable locations. The policy stipulates that indicative minimum net densities are 25
dwellings per hectare across the plan area and 40 in Norwich. Gladman submits that higher densities applied to the proposed allocations should be applied with caution unless specific evidence has been provided from the developer, landowner or promoter to support delivery.
If the higher densities are not achieved on the draft allocations, there is a risk to the delivery of the strategy within the GNLP.

Object

Representation ID: 24291

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation particularly sections 4.5.2 - 4.5.8 and section 5.1)

Policy 7.1 – The Norwich urban area including the fringe parishes
4.5.2 A total of 32,691 homes are to be delivered in Norwich and the surrounding parishes accounting for 66% of the overall growth for the GNLP area.
4.5.3 Gladman support the identification of Norwich as the most sustainable location for growth however they consider that there are deliverability concerns regarding the quantum of development which has been directed to Norwich. Out of a total commitment of 32,691 new
homes at the Norwich Urban Area, 79%, or 26,019 homes are expected to be delivered on existing commitments and allocations.
4.5.4 Of particular note is the GNLP’s over reliance on The Growth Triangle which is expected to deliver 13,507 homes within the plan period. Gladman question whether it is realistic to assume that this quantum of development could come forward within the plan period to 2038
due to concerns over market saturation and market interest from developers.
4.5.5 The East Norwich Strategic Regeneration Area was identified in the March 2020 Regulation 18 Draft GNLP as having an existing deliverable commitment of 780 dwellings and a total deliverable commitment of 2,000 dwellings following the allocation of a further 1,220
dwellings. The Regulation 19 GNLP establishes a total deliverable commitment of 4,000 homes for the East Norwich Strategic Regeneration Area. Gladman accept that the Deal Ground has increased in size however sufficient evidence must be supplied to demonstrate that the capacity for the area has the ability to increase by 2,000 dwellings.
4.5.6 Gladman support regeneration however realistic timeframes have to be considered when projecting completions from such sites. The supporting policy text in the Regulation 19 GNLP Greater Norwich Local Plan Gladman Representations Pre-Submission Regulation 19
states that further land is yet to be acquired. Given that land within the area is still to be acquired, in addition to the associated costs and remediation works associated with brownfield development, Gladman consider that there could be significant delays to delivery on this site.
4.5.7 As considered before, Covid-19 has changed home buyers’ priorities with a recent Savills survey finding that 71% of younger buyers crave more outdoor space and rural locations. With this in mind Gladman would also question whether the demand exists for 4,000 dwellings
in this location.
4.5.8 Taking this uncertainty over demand for urban dwellings into consideration, it seems logical that further allocations should be located at the Main Towns.

NORWICH
5.1.1 Gladman supports Norwich being identified at the top of the settlement hierarchy as the mostaccessible and sustainable location in the area. The Pre-Submission Draft GNLP sets out the following housing figures for Norwich:
• Homes delivered in Norwich between 1st April 2018 to 31st March 2020: 1,885
• Unimplemented planning permissions and allocations in existing local plans: 5,254
• New allocations and uplift on existing allocations: 4,527
• Total: 11,666
5.1.2 Gladman notes that whilst a large number of sites contributing to the above benefit from planning permission, there are a number of sites allocated in previous local plans which have been brought forward into the GNLP. Gladman questions whether there is sufficient evidence to confirm that these sites will realistically be delivered within the plan period.
5.1.3 As previously mentioned there are risks to the delivery of a large number of dwellings in one market location such as market saturation and Gladman questions whether it is realistic to assume the total number of dwellings assumed will be delivered
5.1.4 Whilst Gladman supports regeneration there is also the question as to whether sites with medium to long term potential such as the East Norwich Strategic Regeneration Area, will deliver over the plan period. Additional infrastructure requirements, costs and remediation works associated with brownfield development need to be taken into consideration when
making assumptions on delivery timescales.

Object

Representation ID: 24292

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation in particular sections 4.5.9 - 4.5.26, section 5.2, section 6.1 - Land at Norwich Common, Wymondham and section 6.2 - Land at Burston Road, Diss

Policy 7.2 – The Main Towns
4.5.9 Gladman on the whole is supportive of Policy 7.2 which distributes growth to the Main Towns of the Greater Norwich Area, recognising the need for these locations to accommodate growth and support the wider aims of the urban area.
4.5.10 The sustainability and suitability of both Diss and Wymondham as locations for further development is welcomed by Gladman. It is considered that the allocations made at both settlements through the Local Plan however is insufficient.
Wymondham
4.5.11 Wymondham is identified within the GNLP as a Main Town and has good transport links, including mainline rail services to Norwich, Cambridge and Stansted Airport. Wymondham is the main town serving the south-west of Greater Norwich and has potential to contribute to the development of the Cambridge Norwich Tech Corridor
. Wymondham is located at the
heart of the A11 Cambridge to Norwich Tech corridor meaning that the town should play an important role in fulfilling this economic potential over the plan period with further employment and housing land required. Despite its location, the GNLP only proposes to allocate 150 new homes to the Main Town of Wymondham.
4.5.12 The Regulation 18 Draft GNLP included the potential provision of a contingency site around
Wymondham for the delivery of up to 1,000 dwellings. Gladman note that the regulation 19 GNLP has removed the reference to a potential contingency site around the edge of Wymondham without providing justification for its removal.
4.5.13 Given previous comments made above relating to the quantum of development proposed to come forward in and around the Norwich Urban Area, Gladman question the inclusion of a contingency site around Costessey as opposed to Wymondham. If the market is failing to deliver homes around the edge of Norwich, providing further land for residential development
in the same location will not solve the matter. Taking this into consideration Gladman propose that the inclusion of land around Wymondham, where much needed education capacity can be provided on site, should be included within the GNLP.
4.5.14 Taking into consideration the comments made above in relation to housing need and the case for flexibility in planned levels of supply, should committed and other sites fail to come to fruition, Gladman believe that not only should a contingency site around Wymondham be included, but that the site should be allocated. Allocating the land for housing provides
greatest certainty that site can come forward without delay, is available and deliverable for housing and reduces the need for a future review.
4.5.15 In this regard, Land off Norwich Common, Wymondham represents a logical extension to the
settlement and should be further considered for allocation through the plan making process.
4.5.16 Gladman consider that strategic gaps should have been reviewed and revised through the plan making process of the GNLP. Since defined and last reviewed the context for each strategic gap is likely to have altered taking into account more recent development. Evidence
of this is clear in the case of the strategic gap between Wymondham and Hethersett. In recent years the character of the land at the north eastern edge of Wymondham along Norwich Common has significantly altered with new housing and employment development along the north of this road.
4.5.17 A thorough evidence-based assessment of all effected land parcels, together with wider related land has not been undertaken to consider whether strategic gaps remain a relevant and necessary designation to prevent the coalescence of settlements. As such, Gladman
contend that the inclusion of the ‘rolling over’ of the strategic gap policy without a review is not based upon up-to-date evidence and is therefore not sound.
Diss
4.5.18 Gladman is supportive of the identification of Diss as a Main Town within the settlement hierarchy. Diss has the widest range of shops and services of the main towns, as well as a broad range of employment opportunities. The town is located to the north west of the
junction of the A140 and A143 and benefits from rail connections to Norwich and London as well as acting as hub for local bus links. As such, the settlement forms a sustainable and logical location for further development.
4.5.19 Diss has a key role to play in supporting the surrounding villages and rural hinterland through
its services and facilities. The retail offering of Diss is key in this supporting role with the large rural catchment extending in to parts of South Norfolk and northern Suffolk. As such, Diss demonstrates positive vitality and viability and has the opportunity to support further housing growth. There would be strong justification to provide further growth than is currently proposed in Diss due to this strong retail offering and other services, along with the good transport links to Norwich and beyond.
4.5.20 In progressing from the Regulation 18 consultation draft of January 2020 to the now submission version currently being consulted, matters have taken a backward step in Diss. The proposed strategy is now one which seeks to defer to the allocation of housing sites to the
emerging Diss and District neighbourhood plan. One proposed allocation for 150 dwellings remains, with the emerging neighbourhood plan to determine the location of the remaining 250 dwellings to be allocated to Diss. In combination with the existing commitment of just
over 300 dwellings, from the base date of the plan period, this takes the total housing target for Diss to just over 743 during the plan period.
4.5.21 For one of the main towns, the most significant settlement in the south of the plan area serving a wide rural hinterland with the largest retail offer outside of Norwich, this is an insufficient development quantum.
4.5.22 Reasons stated for limiting the level of growth towards Diss are attributed to environmental constraints and traffic constraints, based upon local evidence. Gladman are promoting land south of Burston Road (GNLP4049). Assessed following the close of the Regulation 18 consultation, the site is recognised as suitable for further consideration (Diss booklet of sites
evidence base paper). Based on the concept plan prepared to date we have sought to address ‘amber’ scoring issues, summarised as townscape and landscape considerations, to show that environmental impact is not an insurmountable constraint. Therefore, the issue in bringing this site forward is not an environmental one but instead highlighted as highways. It therefore follows that environmental concerns cannot be a reason for limiting growth in Diss.
4.5.23 Instead, the limiting factor is considered to be purely a highways constraint. Recognising this fact, it is therefore considered inappropriate to leave the decisions around the majority of housing allocations of Diss to the emerging neighbourhood plan. Seeking to resolve the
highways issue in Diss is considered to be a strategic matter best tackled during the local plan making process, not through the neighbourhood plan. We would welcome allocations being left to the community to decide if this was in addition to a suitable quantum of development
steered towards Diss.
4.5.24 Paragraph 102 of the Framework is clear that transport issues should be considered from the earlier stages of plan-making so that potential impacts of development on transport networks can be addressed. Whilst issues have been identified it is considered that there is currently insufficient evidence to seek to limit the quantum of development directed towards to Diss
for these reasons. If this was such an insurmountable issue, referring site allocations to the neighbourhood plan, a mechanism inappropriate to tackle highways constraints is only likely to exacerbate the highways issue.
4.5.25 The Diss Network Improvement Strategy (April 2020) has identified a number of junctions requiring improvement and options for providing these improvements. It appears that little regard has been had for changing transport technology and usage over the plan period and how this could alleviate highways concerns. For example, as a longer-term impact of the
coronavirus pandemic commuting patterns may change allowing for further growth in one of the main towns where services and facilities are readily available, allowing development to be focussed in locations which are or can be made sustainable, as per Paragraph 103 of the Framework.
4.5.26 Instead, we are left to rely on a report which states that by 2036 the Morrison’s junction would be over capacity with improvements needed. Doing nothing to address this is therefore not considered to be an option. Other options assessed, and ruled out, to address this can be summarised as either a northern link road or southern link road. These are considered to be
extreme options which would cement commuting patterns rather than seeking to support a shift. Further testing should have been undertaken to determine a quantum of development that could be satisfactorily delivered without the need for new link roads. .. In this regard, further development than identified would be expected to contribute towards unlocking the necessary improvements identified.

5.2 MAIN TOWNS
5.2.1 Gladman supports the identification of Diss and Wymondham as Main Towns and submits that the sites we are actively promoting in these locations should be allocated to offer greater flexibility and to ensure that the housing need can be met over the plan period.

Object

Representation ID: 24293

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation particularly sections 4.5.27 - 4.5.34, section 5.3 and section 6.3 - Land south of Burgate Lane, Poringland.

Policy 7.3 The Key Service Centres
Poringland
4.5.27 Poringland (including Framingham Earl) is identified in table 1 of the Regulation 19 consultation document as having the 6th largest population when compared to the 15 settlements in the Greater Norwich Area. Making it the second largest Key Service Centre after Hethersett, and larger than the Main Towns of Long Stratton and Harleston. This indicates the sustainability and popularity of Poringland within the Greater Norwich Area.
4.5.28 The Key Service Centres, of which Poringland is one, are described as having “a relatively good range of services, access to public transport and employment opportunities and play a vital role in serving the rural areas.” Poringland does have a good range of services which include both a primary school and a secondary school, village hall, community hall, pharmacy, post
office, two doctors’ surgeries, a dentist, O’Fylnns Budgens Supermarket and numerous other
shops and services. Norwich is also only approximately 6 miles (9.6km) from Poringland and is accessible via sustainable means of transport within 15 minutes.
4.5.29 As such, Poringland demonstrates positive vitality and viability and has the opportunity to support further housing growth. There would be strong justification to provide further growth in Poringland due to being host to a range of services and facilities, along with the good
transport links to Norwich and beyond.
4.5.30 The ‘Towards a Strategy’ document identifies a requirement for 400-600 dwellings in Poringland. However, the proposed strategy for Poringland in the Greater Norwich Regulation 19 Plan does not allocate any further growth to Poringland. There are 536 dwellings with planning permission at the base date of the plan meaning that a substantial amount of landcontinues to be promoted for development in Poringland/Framingham Earl (including land in adjacent parishes of Bixley, Caistor St Edmund, Framingham Pigot, Framingham Earl, and
Stoke Holy Cross). This high level of commitment suggests limiting further growth to Poringland going forward to this plan.
4.5.31 Aside from stating prior development commitments as a reason to limit growth, there are additional issues relating to the rural nature of large parts of the parishes, with the distinctive setting created by areas of heavily wooded former parkland. The 2012 South Norfolk Place
Making Guide suggests that development should not further accentuate the linear settlement pattern. The settlement has a history of surface water and ground water drainage difficulties, which will be a consideration for many sites in Poringland and Framingham Earl, and
mitigation will be needed for any development on such sites. Amongst the constraints to further development is the need for a new additional primary school.
4.5.32 Gladman are concerned that currently no further growth is directed towards Poringland. As stated above the town provides a sustainable setting for future growth, in a place where people want to live. Deliverable sites should come forward in this location that could
contribute to local economic, social and environmental aspirations. Gladman believe the spatial strategy for housing growth needs to direct higher numbers to sustainable settlements within the ‘Key Service Centres’ tier, such as Poringland. This would help alleviate the pressure of delivery for larger strategic sites, with smaller allocations that could deliver during the early
stages of the adoption of the plan. It also provides more certainty than the approach to allocate up to 1,200 homes within the “Village Cluster” on smaller sites in much smaller settlements which are not deemed as sustainable as settlements in the Key Services such as Poringland.
4.5.33 While it is accepted that Poringland has taken some growth, providing no new allocations is
counterintuitive to the role Poringland plays in the District. As explained previously, Poringland is a sustainable settlement with sites readily available and deliverable now, that could provide extensive benefits to the community and help boost significantly the supply of housing as emphasised through national policy.
4.5.34 Gladman consider that allocating no new development through the Regulation 19 GNLP to a
sustainable settlement such as Poringland will not provide the flexibility needed to ensure land supply is met over the plan period. The level of new growth to be directed to the settlement should be substantially increased

5.3 KEY SERVICE CENTRES
5.3.1 Given previous comments made regarding the sustainability of Poringland and its connectivity to Norwich, Gladman submit that the level of growth directed to Poringland should be increased in order to provide the flexibility needed to ensure land supply is met over the plan period

Object

Representation ID: 24545

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

See attachment for full representation

Policy 5 – Homes
Affordable Housing
4.4.1 Policy 5 sets out that major residential development proposals of ten dwellings or more will provide at least 33% affordable housing on-site across the plan area except in Norwich City Centre where the requirement is at least 28%. Gladman supports the principle of improving
affordability across Greater Norwich and the need to identify an appropriate affordable housing target for differing built environments that reflects the local circumstances.
4.4.2 Notwithstanding the above support, the Councils will need to be able to demonstrate through clear, robust, up-to-date viability assessment that the provision of affordable housing in line with the proposed policy is viable on the majority of schemes.
4.4.3 Gladman supports the element of flexibility within the draft policy allowing viability assessments to be submitted in respect of brownfield sites in particular circumstances. To confirm, the sites which are being promoted by Gladman for inclusion within the plan can all
provide a policy compliant level of affordable housing, if not greater for example Poringland offers 36% affordable housing.
Accessible and Specialist Housing
4.4.4 The policy states that development proposals providing specialist housing options for older people’s accommodation and others with support needs, including sheltered housing, supported housing, extra care housing and residential/nursing care homes will be supported
on sites with good access to local services including on sites allocated for residential use.
4.4.5 Gladman is supportive of this policy approach as the provision of specialist housing to meet
the needs of older people is of increasing importance.
4.4.6 Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide
internally accessible communal facilities including a residents’ lounge, library, dining room,
guest suite, quiet lounge, IT suite, assisted bathroom, internal buggy store and changing facilities, reception and care manager’s office and staff facilities.
Self/Custom Build
4.4.7 The policy states that with the exception of flats, at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots unless a lack of need can be demonstrated or plots have been marketed for 12 months and have not been sold.
4.4.8 Gladman objects to the inclusion of a fixed percentage requirement in relation to the provision
of serviced self-build plots.
4.4.9 Whilst recognising the role attributed towards self-build in national planning policy as a source of housing land supply, we do not consider the inclusion of a requirement for all housing schemes over 40 dwellings to commit to onsite provision forms the most effective
approach of responding to this source of housing need.
4.4.10 Gladman believes that those wishing to bring forward a self-build or custom build house are unlikely to wish to do this alongside a large-scale housing development. Consequently, rather than including a strict requirement for this provision Gladman would recommend the policy encourages the consideration of the provision of self-build plots in locations where the
demand exists.
4.4.11 Gladman would prefer to see policy which seeks self-build plots being considered on an ad hoc basis as windfall rather than as a percentage requirement of larger development schemes. We consider this approach to be more in line with the wants and needs for the individuals
seeking the plot and the developer’s requirements for larger sites.
4.4.12 Should a percentage approach be taken forward, the requirement should be supported by clear and robust evidence of this source of housing need. Gladman recommends that any policy requirement in relation to self-build housing has an element of flexibility built in to
allow for negotiation over self-build plots on the basis of viability to ensure that site delivery is not delayed or prevented from coming forward. Any specific requirement to include selfbuild plots should be tested through the Council’s viability assessment of the Local Plan
policies to ensure that the cumulative impacts of all proposed local standards and policy
requirements do not put the implementation of the Plan as a whole at risk.
4.4.13 Gladman notes that the proposed policy does include a mechanism which allows developers the opportunity after 12 months to either continue to market the plots for self-build or to revert back to them being delivered as part of the wider market housing scheme. Gladman supports the inclusion of this policy mechanism as it is necessary to ensure that housing land
is not unnecessarily prevented from being brought forward. This helps to provide flexibility and helps to ensure that the required housing is delivered. If there is genuine demand for selfbuild housing it is likely that these plots would be brought forward relatively quickly

Object

Representation ID: 24546

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

See attachment for full representation (section 4.4.14)

Policy 6 – The Economy (including Retail)Policy 6 sets out the strategy for delivering economic growth over the plan period in accordance with the New Anglia LEP’s Norfolk and Suffolk Economic Strategy and Local Industrial Strategy, the Cambridge Norwich Tech Corridor
initiative, and the enhanced growth outlined in the Greater Norwich City Deal. Gladman is supportive of the ambitious economic growth strategy, however the GNDB should recognise the role housing delivery has in supporting sustainable economic growth, particularly in
supporting town centres. There is a need to ensure that the proposed level of allocations made through the GNLP maximises economic growth potential provided though the City Deal and the A11 Norwich to Cambridge Tech Corridor. It is both appropriate and sound to concentrate
new development towards this broad strategic location. However, as advised in our previous representations, the implementation of this strategy should not come at the cost of maintaining the sustainability and important role played by settlements which fall outside this corridor. It is important that sufficient development is directed to these settlements to support their longer-term sustainability and functionality. Opportunities should also be taken to focus
growth towards those settlements which are well served by public transport to support climate change objectives.

Object

Representation ID: 24547

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please see attachment for full representation particularly section 5.4

5.4 COSTESSEY CONTINGENCY SITE
5.4.1 Gladman notes the identification of a contingency site which will become an allocated site in the event the GNLP is not delivering housing at the anticipated rate. Gladman submits that the site we are promoting at Norwich Common, Wymondham would be a more suitable alternative for inclusion under this policy for the following reasons:
• The site is being actively promoted by Gladman, we have the experience and expertise to deliver a site of this scale.
• An outline planning application has been submitted by Gladman to South Norfolk Council and the technical information submitted with the application demonstrates
that there are no constraints which would prohibit the development of the site.
• We are working with South Norfolk Council and have offered to provide additional land for education and other community uses as part of the development.
• The site can be suitably accessed using land entirely within our control.