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Object

Publication

Policy 1 - The Sustainable Growth Strategy

Representation ID: 23642

Received: 18/03/2021

Respondent: Clarion Housing Group

Agent: Brown & Co

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is considered that the proposed strategy is not appropriate and is incompatible with the overall purpose of the plan, in particular, the delivery of sustainable development which meets the challenges of climate change, and supports ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy, and the emergence of the region as the UK leader in clean growth. Furthermore, the proposed strategy is not considered suitable to deliver beautiful places or spaces.

Change suggested by respondent:

It is thought that sites GNLP0415A-G, collectively known as Honingham Thorpe, offer an appropriate opportunity to deliver growth differently, creating a truly sustainable community which paves the way for the region to become the UK leader in clean growth whilst raising the standards for design and placemaking.

Full text:

It is considered that the proposed strategy is not appropriate and is incompatible with the overall purpose of the plan, in particular, the delivery of sustainable development which meets the challenges of climate change, and supports ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy, and the emergence of the region as the UK leader in clean growth. Furthermore, the proposed strategy is not considered suitable to deliver beautiful places or spaces.

Object

Publication

Policy 7.6 Preparing for New Settlements

Representation ID: 24054

Received: 18/03/2021

Respondent: Clarion Housing Group

Number of people: 2

Agent: Brown & Co

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attachment for full representation.

4.1 The GNLP in its current form is not considered to be sound as the strategy fails to adequately deliver on the overall purpose of the plan, in particular addressing the challenges of climate change and supporting ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy or to create truly beautiful places or spaces. The draft GNLP recognises the need to deal with the challenges of climate change and carbon neutrality and adapt accordingly, however it seeks to deliver growth through a traditional delivery model which perpetuates inherently inefficient, unsustainable, and uninspiring development. 4.2 Additionally, the strategy is considered to be ineffective as there is a significant reliance upon sites which have failed to deliver during the current plan period, with some sites having been originally allocated in previous iterations of the Local Plan, dating as far back as 2004. Continuing to roll forward sites which have failed to deliver in line with the housing trajectory places the strategy for growth at risk and undermines the Plan led approach. Insufficient evidence has been provided to demonstrate the ability of these, and other sites, to deliver within this plan period, with a number of sites having no promoter or developer on board.

Change suggested by respondent:

4.3 A new settlement at Honingham Thorpe, GNLP4015A-G, would offer the opportunity to provide housing in a holistic and sustainable way in order to create a vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that new garden settlements can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares. Provision of a Country park, with enhanced provision to the Wensum and river valley, would create a significant area of green space, something which has become more important than ever in light of the pandemic. The relationship of the site with the Food Enterprise Park would support a key growth area and the emerging agri-tech corridor, creating a holistic and mutually supportive relationship between the new community, the Food Enterprise Park, Easton College, Norwich Research Park and the UEA.
4.4 As the country’s largest housing association and a registered charity, Clarion have an exemplary record for quality, social and environmental responsibility, delivery at scale and an unrivalled commitment to legacy, stewardship, and community issues. They recognise that quality and social purpose must be at the heart of development, and that the opportunity to develop on a large scale brings with it both dedicated to delivering an exemplar settlement which embodies the traditional Norfolk settlement, supports the region’s world-renowned Agri-Tech corridor, considers the UK’s commitment to reduce carbon emissions to net zero by 2050, helping to place the area at the forefront of the transition to a post carbon economy.
4.5 Clarion support the aims of the GNLP to provide better places, with multi-functional green spaces seeking to enhance the landscape, biodiversity, and connectivity, as well as the draft policy requirements for water conservation, energy efficiency, and decentralised energy generation as a means of contributing to national targets for carbon neutrality. However, the proposed carrying forward of allocations and concentration of growth to existing urban areas is considered to be misaligned with the aspirations of the Greater Norwich Local Plan, particularly in the context of Norwich City Council having declared a climate emergency and pledging to be carbon neutral by 2030, and the national target of 2050. Such an approach is considered to fail to adequately adapt to the changing circumstances and priorities of the Greater Norwich area, and beyond.

See attachment for full representation

Full text:

See attachment for full representation

Brown & Co are instructed by Clarion Housing Group to respond to the pre submission draft Greater Norwich Local Plan that is currently at its Regulation 19 consultation stage.

It is considered that the draft Plan is unsound, as the strategy proposed is neither justified not effective. It is thought that sites GNLP0415A-G, collectively known as Honingham Thorpe offer an appropriate opportunity to deliver growth differently, creating a truly sustainable community which paves the way for the region to become the UK leader in clean growth whilst raising the standards for design and placemaking.

4. Conclusions

4.1 The GNLP in its current form is not considered to be sound as the strategy fails to adequately deliver on the overall purpose of the plan, in particular addressing the challenges of climate change and supporting ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy or to create truly beautiful places or spaces. The draft GNLP recognises the need to deal with the challenges of climate change and carbon neutrality and adapt accordingly, however it seeks to deliver growth through a traditional delivery model which perpetuates inherently inefficient, unsustainable, and uninspiring development.

4.2 Additionally, the strategy is considered to be ineffective as there is a significant reliance upon sites which have failed to deliver during the current plan period, with some sites having been originally allocated in previous iterations of the Local Plan, dating as far back as 2004. Continuing to roll forward sites which have failed to deliver in line with the housing trajectory places the strategy for growth at risk and undermines the Plan led approach. Insufficient evidence has been provided to demonstrate the ability of these, and other sites, to deliver within this plan period, with a number of sites having no promoter or developer on board.

4.3 A new settlement at Honingham Thorpe, GNLP4015A-G, would offer the opportunity to provide housing in a holistic and sustainable way in order to create a vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that new garden settlements can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares. Provision of a Country park, with enhanced provision to the Wensum and river valley, would create a significant area of green space, something which has become more important than ever in light of the pandemic. The relationship of the site with the Food Enterprise Park would support a key growth area and the emerging agri-tech corridor, creating a holistic and mutually supportive relationship between the new community, the Food Enterprise Park, Easton College, Norwich Research Park and the UEA.

4.4 As the country’s largest housing association and a registered charity, Clarion have an exemplary record for quality, social and environmental responsibility, delivery at scale and an unrivalled commitment to legacy, stewardship, and community issues. They recognise that quality and social purpose must be at the heart of development, and that the opportunity to develop on a large scale brings with it both dedicated to delivering an exemplar settlement which embodies the traditional Norfolk settlement, supports the region’s world-renowned Agri-Tech corridor, considers the UK’s commitment to reduce carbon emissions to net zero by 2050, helping to place the area at the forefront of the transition to a post carbon economy.
4.5 Clarion support the aims of the GNLP to provide better places, with multi-functional green spaces seeking to enhance the landscape, biodiversity, and connectivity, as well as the draft policy requirements for water conservation, energy efficiency, and decentralised energy generation as a means of contributing to national targets for carbon neutrality. However, the proposed carrying forward of allocations and concentration of growth to existing urban areas is considered to be misaligned with the aspirations of the Greater Norwich Local Plan, particularly in the context of Norwich City Council having declared a climate emergency and pledging to be carbon neutral by 2030, and the national target of 2050. Such an approach is considered to fail to adequately adapt to the changing circumstances and priorities of the Greater Norwich area, and beyond.

Attachments:

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