Publication

Draft policy 1 refers to settlement boundaries in the Norwich Urban Area (which includes Thorpe St Andrew) and states that housing growth will be considered acceptable within settlement boundaries. An amendment to the policy map is proposed to include Oasis Sport and Leisure Centre GNLP0540 within the settlement boundary. This is on the basis that planning permission for housing development (ref: 20151132 and 20190016) has been approved and the inclusion of this land outside of the settlement boundary will weaken the interpretation of draft policy 1 as it will not be clear what is built form of a settlement and where the countryside policies should apply.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 1 is clearly written and unambiguous.

We support the changes to policy 7.1 following previous representations we have submitted, notably on an increase in housing numbers, which have doubled from 2,000 to 4,000 homes to 2038. Also, given the complex nature of the East Norwich Strategic Regeneration Area (SRA), it is right that there is flexibility on the level of affordable housing requirements in general policy, allowing for the masterplan to address deliverability of the SRA. Additionally, the change in boundary of the allocation is also very much supported to include all land within the extant planning permissions 12/00875/O and 2011/0152/O; the May Gurney Headquarters site and within policy GNLP0360 (Deal Ground, Trowse Pumping Station and May Gurney). The regeneration area includes a CWS, which does not preclude development, and so a clear and unambigious policy is required to assess the acceptability of proposals that will affect it. We therefore propose that Policy 7.1 is amended to set out a clear benefit a development can provide, such as 10% biodiversity net gain. Please see our representation to Policy 3, which should be referred to in Policy 7.1.

In accordance with the Framework (16), Policy 7.1 could be more clearly written and unambigous on development that affects the CWS in the regeneration area.

The draft plan states that an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as, inter alia, care homes (275, GNLP). Consequently, the draft plan makes a specific allocation for specialised housing for older people and site allocations with an element of specialist housing. This means that the plan should support the redevelopment of vacant or unviable care homes to other uses. We therefore propose amendments to draft policy 5, so that where existing older people's accommodation and others with support needs is either unviable, vacant or it does not have good access to local services then redevelopment to residential will be supported. Amended draft policy 5 below:

“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. Should it be demonstrated that existing older people's accommodation and others with support needs is either unviable, vacant or it does not have good access to local services then redevelopment to residential will be supported in principle. Irrespective of C2 or C3 use class classification, specialist older people’s housing will provide 33% affordable housing or 28% in the city.”

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

We support the changes to policy 7.1 following previous representations we have submitted, notably on an increase in housing numbers, which have doubled from 2,000 to 4,000 homes to 2038. Also, given the complex nature of the East Norwich Strategic Regeneration Area (SRA), it is right that there is flexibility on the level of affordable housing requirements in general policy, allowing for the masterplan to address deliverability of the SRA. Additionally, the change in boundary of the allocation is also very much supported to include all land within the extant planning permissions 12/00875/O and 2011/0152/O; the May Gurney Headquarters site and within policy GNLP0360 (Deal Ground, Trowse Pumping Station and May Gurney). The regeneration area includes a CWS, which does not preclude development, and so a clear and unambigious policy is required to assess the acceptability of proposals that will affect it. We therefore propose that Policy 7.1 is amended to set out a clear benefit a development can provide, such as 10% biodiversity net gain. Please see our representation to Policy 3, which should be referred to in Policy 7.1.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

Draft policy 1 refers to settlement boundaries in the Norwich Urban Area (which includes Thorpe St Andrew) and states that housing growth will be considered acceptable within settlement boundaries. An amendment to the policy map is proposed to include Oasis Sport and Leisure Centre GNLP0540 within the settlement boundary. This is on the basis that planning permission for housing development (ref: 20151132 and 20190016) has been approved and the inclusion of this land outside of the settlement boundary will weaken the interpretation of draft policy 1 as it will not be clear what is built form of a settlement and where the countryside policies should apply.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

Draft policy 3 of the GNLP does not refer specifically to County Wildlife Sites (‘CWS’) but states that development proposals will be required to conserve and enhance the natural environment avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development and the harm has been minimised. This means that a CWS designation does not preclude development, but it will be a high and undefined bar to demonstrate that the benefits of development overrides harm unless policy is clearer. We therefore propose that draft policy 3 is amended to set out a clear benefit a development can provide, such as a 10% biodiversity net gain. Draft Policy 3 is proposed to read as follows:

“Development proposals will be required to conserve and enhance the natural environment (including valued landscapes, biodiversity including priority habitats, networks and species, ancient trees and woodlands, geodiversity, high quality agricultural land and soils) through: • being designed to respect and retain, and add to, natural assets; taking account of local design and other guidance, and undertaking landscape, biodiversity or other appropriate assessments if significant impacts might arise; • avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development, for example at least a 10% biodiversity net gain, and the harm has been minimised”.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

Draft policy 3 of the GNLP does not refer specifically to County Wildlife Sites (‘CWS’) but states that development proposals will be required to conserve and enhance the natural environment avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development and the harm has been minimised. This means that a CWS designation does not preclude development, but it will be a high and undefined bar to demonstrate that the benefits of development overrides harm unless policy is clearer. We therefore propose that draft policy 3 is amended to set out a clear benefit a development can provide, such as a 10% biodiversity net gain. Draft Policy 3 is proposed to read as follows:

“Development proposals will be required to conserve and enhance the natural environment (including valued landscapes, biodiversity including priority habitats, networks and species, ancient trees and woodlands, geodiversity, high quality agricultural land and soils) through: • being designed to respect and retain, and add to, natural assets; taking account of local design and other guidance, and undertaking landscape, biodiversity or other appropriate assessments if significant impacts might arise; • avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development, for example at least a 10% biodiversity net gain, and the harm has been minimised”.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.