Publication

Object

Representation ID: 24372

Received: 22/03/2021

Respondent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As per our previous representation, we welcome and support site allocation Policy CC4b in principle, however
we want to ensure that the contents of the policy is consistent what our client is aiming to build out on site and that correct terminology is used within the policy text.

See attachment for full submission including proposed changes to the policy.

Object

Representation ID: 24373

Received: 22/03/2021

Respondent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Our previous Regulation 18 representation sought to comment on the sections relation to affordable housing
and purpose-built student accommodation (PBSA). In terms of the first bullet point of this policy, we requested
that the following wording (underlined) should be added:
“at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a
different percentage of affordable housing, and subject to viability testing in line with the NPPF”

The revised policy has been re-worked and now includes a section (b) relating to brownfield sites and affordable
housing. This states:
“for brownfield sites where the applicant can demonstrate that particular circumstances justify the need
for a viability assessment at decision-making stage;
 affordable housing on-site except where exceptional circumstances justify off-site provision;
 a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking
account of the most up-to-date local evidence of housing need. This will include 10% of the
affordable homes being available for affordable home ownership where this meets local needs;
 affordable housing of at least equivalent quality to the market homes on-site”

We welcome the inclusion of viability text within the policy, however, would request the below amendment on
the first bullet point to ensure that the viability testing as referred to within the NPPF is appropriately
incorporated into the policy:
“affordable housing on-site except where viability assessments or exceptional circumstances justify offsite provision”;

See attachment for full submission and suggested amendments to the policy.

Object

Representation ID: 24374

Received: 22/03/2021

Respondent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Our previous Regulation 18 representation sought to comment on the ‘City Centre’ section of the policy and
specifically Point 3 specifically Point 3 (Leisure, culture and entertainment and the visitor economy) and Point
5 (The Natural and Built Environment). Our representation stated:
“Point 3 states:
Development of new leisure and cultural facilities, hotels and other visitor accommodation to strengthen
the city centre's role as a visitor and cultural destination will be accepted in accessible locations well related to centres of activity and transport hubs.
Given that the CC4b site allocation has an existing hotel that will be redeveloped as part of a future scheme, and sits in close proximity to an existing and future transport hub at Norwich Station and its surroundings, we welcome and support the above point.
Point 5 states:
New landmark buildings at the gateways to the city centre will be accepted where they are of exceptional quality and help to define or emphasise the significance of the gateway
We support the encouragement for gateway developments within the city centre in appropriate
locations. It is considered that Policy CC4b site allocation is an appropriate location for a landmark building due its strategic location within the City Centre and its proximity to Norwich Train Station. This approach is in line with the principle so the NPPF and the National Design Guide in promoting the effective use of land, high quality design and emphasising important”

We welcome that Point 3 has been retained within the revised plan. However, the point relating to landmark
buildings has been removed and as referred to above (in Policy CC4b section) we disagree that a landmark
reference should not be included within the policy.
Whilst we consider that the our site can include a landmark building and much work has already gone into the development of this with the Council. In terms of the wider City Centre we consider that well-designed landmark buildings should be encouraged and this approach is in line with the principle of the NPPF and the National Design Guide in promoting the effective use of land, high quality design and emphasising important places.

See attachment for full submission.