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Policy 2 Sustainable Communities

Representation ID: 24386

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Number of people: 2

Agent: Mrs Nicole Wright

Representation Summary:

Policy 2
This policy addresses a number of key issues including the need for among other things, sustainable access to on-site services and facilities reducing the need to travel. The policy appears to be sound.

Full text:

Representation submitted in relation to site GNLP3024 at Sprowston by Le Ronde Wright on behalf of Trustees

Policy 2
This policy addresses a number of key issues including the need for among other things, sustainable access to on-site services and facilities reducing the need to travel. The policy appears to be sound.

Policy 6

The policy states that small scale retail and leisure developments serving local needs are encouraged to serve new residential developments in existing residential areas promoting active travel. It discusses the importance of providing choice retaining and allocating smaller scale employment sites. The policy appears to be sound.

Policy 7.1

The policy states among other things, that elsewhere in the fringe parishes a range of sites will be provided for different types of employment and community uses and promote walking and cycling. This policy appears to be sound.

Although individually, the above policies appear be sound the overall Plan is not effective without allocations of smaller employment sites in key locations to address the impact of housing growth. Site GNLP3024 is a key allocation to be provided at Sprowston. The Plan would be unsound without it. In addition, a review of the settlement boundary of the town is necessary as it is incorrect as shown on the map regarding Sprowston.

Proposed Allocation GNLP3024

This proposed allocation of this business and community hub adjacent to allocation GNLP0132 would secure essential social and community infrastructure in close proximity to the new and existing homes in the locality, and better facilitate Sprowston's future planned growth and expansion. The SoCG (copy enclosed for ease of reference) and previous representations outline the mix of uses intended. There is extant planning consent for a mix of commercial and community uses. However, further flexibility is sought to complement the neighbouring developments. The allocation of this site would help to secure its future viability and deliverability and provide much needed extended services and amenities to serve the local growing population.

Support

Publication

Policy 6 The Economy

Representation ID: 24387

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Number of people: 2

Agent: Mrs Nicole Wright

Representation Summary:

Policy 6

The policy states that small scale retail and leisure developments serving local needs are encouraged to serve new residential developments in existing residential areas promoting active travel. It discusses the importance of providing choice retaining and allocating smaller scale employment sites. The policy appears to be sound.

Full text:

Support

Publication

Policy 7.1 The Norwich Urban Area including the Fringe Parishes

Representation ID: 24388

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Number of people: 2

Agent: Mrs Nicole Wright

Representation Summary:

Policy 7.1

The policy states among other things, that elsewhere in the fringe parishes a range of sites will be provided for different types of employment and community uses and promote walking and cycling. This policy appears to be sound.

Although individually, the above policies appear be sound the overall Plan is not effective without allocations of smaller employment sites in key locations to address the impact of housing growth. Site GNLP3024 is a key allocation to be provided at Sprowston. The Plan would be unsound without it. In addition, a review of the settlement boundary of the town is necessary as it is incorrect as shown on the map regarding Sprowston.

Full text:

Object

Publication

Settlement Map

Representation ID: 24389

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Number of people: 2

Agent: Mrs Nicole Wright

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Proposed Allocation GNLP3024

This proposed allocation of this business and community hub adjacent to allocation GNLP0132 would secure essential social and community infrastructure in close proximity to the new and existing homes in the locality, and better facilitate Sprowston's future planned growth and expansion. The SoCG (copy enclosed for ease of reference) and previous representations outline the mix of uses intended. There is extant planning consent for a mix of commercial and community uses. However, further flexibility is sought to complement the neighbouring developments. The allocation of this site would help to secure its future viability and deliverability and provide much needed extended services and amenities to serve the local growing population.

Change suggested by respondent:

The allocation of small and medium-sized sites to provide services and amenities to support major housing allocations where these can be accessed by alternative modes to the private car. A key example is site GNLP3024 at Sprowston.

Full text:

Object

Publication

Policy 1 - The Sustainable Growth Strategy

Representation ID: 24402

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Agent: Mrs Nicole Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The plan is unsound and unjustified.

As part of the Greater Norwich Local Plan, an understanding of the relevant evidence base is necessary to derive an appropriate strategy. No up-to-date assessment of Public Open Space (POS) needs has been provided, which affects future and existing residential amenity. A Public Open Space Assessment has been undertaken for Sprowston East. The study shows deficits in certain typologies of public space (namely Parks and Gardens -3.21ha, Amenity Green Space -3.30ha, and Playing Pitches -5.10ha). This would be exacerbated by the planned growth in Sprowston (LAPs -0.21ha, Parks and Gardens -6.01ha, Amenity Green Space -5.40ha, Playing Pitches -9.30ha). The Open Space Assessment is available in full upon request. The plan is not justified as it is based on an inadequate evidence base. As a result, reasonable alternatives cannot be considered in accordance with paragraph 35 of the NPPF.

Change suggested by respondent:

An up-to-date evidence base in relation to the current and proposed open space and play space provision is required to inform the Strategy and proposed allocations.

Full text:

This representation is submitted by Le Ronde Wright on behalf of the Trustees of site at Sprowston Sports and Social Club.

This submission relates to Policy 1, Policy 2 & 3, Policy 5 and paragraphs 275 to 277, and Policy 6. See summaries for detail.

Object

Publication

Policy 2 Sustainable Communities

Representation ID: 24403

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Agent: Mrs Nicole Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The GNLP has admirable ambitions regarding the delivery of Green Infrastructure, however the proposed allocations do not reflect the policy aspirations of the plan resulting in this not being effective or deliverable in conflict with policy 35 of the NPPF. The NPPF, echoes the GNLP through placing a great emphasis on not only the preservation of existing green infrastructure, but also on the creation of new more accessible green infrastructure.

Policy 2 requires the following key sustainable development objectives to be met:
- Provision of accessible social and community infrastructure
- Making more effective use of land
- Contributions to multi-functional green infrastructure links
- Provision of safe and accessible open spaces available to all ages encouraging walking and cycling, increased opportunities for social interaction and for living healthier, more active lifestyles.

However, the plan is not effective in achieving the requirements of Policy 2. In particular, at Sprowston, where insufficient land has been allocated (and insufficient provision made in the new allocation) to take account of the economic, housing and open space needs of all ages.

Change suggested by respondent:

The evidence base needs to be brought up-to-date.

At Sprowston, a new site needs to be identified to provide a LEAP and more accessible public open space in the form of a local park and garden.

Proposed policies should actively support developments that would link existing areas of green infrastructure (GI) and require the provision of POS and GI where possible to link and interconnect with existing provision nearby. Additionally, it is considered that proposed allocations should set an exemplary way forward, aligning the policies for future developments to achieve this. As such, allocations should be promoted that contribute to the creation of new links between existing GI and contribute to an area-wide green infrastructure network. For example, the land at the Sprowston Sports and Social Club, surrounded by allocation GT5 in the Growth Triangle Area Action Plan would see the linking of an existing natural woodland, with a new proposed community park and garden, which could then link into the new playing fields/skate park being proposed in the south western edge of GT5. Such a proposal would exemplify the policy aspirations of linking existing Green Infrastructure into a more local network, whilst also providing new, much needed POS as highlighted by the Open Space Assessment for Sprowston.

Full text:

Object

Publication

Policy 3 Environmental Protection and Enhancement

Representation ID: 24404

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Agent: Mrs Nicole Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

This policy is not effective. Although it requires provision or enhancement of adequate green infrastructure, it does not provide any clear guidance on the need to be met, nor is there defined elsewhere in the Plan. As a result, the need to be met by new developments is not adequately fulfilled.

Change suggested by respondent:

To be more effective the Plan needs to be based on a more up to date evidence base and identify more green infrastructure particularly in proximity to large strategic allocations as is the case at Sprowston.

The redevelopment of the site of the Sprowston Sports and Social Club to provide beautiful, high-quality, much needed new homes for older people and open space and play facilities accessible to all. In the form of a public park, would be a much more efficient use of land in keeping with the principles and objectives of the sustainable development expressed in the NPPG, National Planning Policy Framework, GNLP Pre-Submission Draft Strategy and recent government policy requiring all new developments to meet local standards of beauty, quality and design. It would set an example of the high quality, beautifully designed places expected from every development throughout the plan period and beyond.

It would meet the three overarching objectives and purpose of planning; that is, ensuring a more responsive and competitive local economy and coordinating the provision of infrastructure (the economic objective of sustainable development), support strong, vibrant and healthy communities through provision of accessible open spaces where it is needed (the social objective) and through making more efficient use of brownfield land to encourage healthier, more active lifestyles (the environmental objective).

Full text:

Object

Publication

Policy 5 Homes

Representation ID: 24405

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Agent: Mrs Nicole Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy 5 has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy as it fails to secure a suitable strategy to deliver high-quality elderly accommodation in sufficient numbers to address an identified need.

Paragraphs 275 to 277 of the GNLP discuss an identified need regarding elderly accommodation (there is discrepancy in the councils figures regarding need with 2842, 3857, and 3909 spaces identified as needed). The GNLP identifies the strategy to address this need through a mix of allocated sites (4 in total, equating to approximately 300 spaces) and the rest of the identified need to be taken up on housing allocations. It is known that having a small proportion of elderly needs units on larger allocations creates a poor quality of life for residents, as they are typically isolated, away from POS and interaction with others. Additionally, such policies have additional viability implications, potentially undermining housing allocations. This is reinforced by the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, summarising that specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This is reflected in paragraphs 59 to 61 of the NPPF where a variety of land is needed to come forward to ensure the needs of groups with specific requirements are addressed.

The current plan places a great emphasis on the delivery of elderly accommodation through housing allocations, which is not considered to be an effective or justified strategy, nor a strategy consistent with national policy.

Change suggested by respondent:

It is considered that to make the plan sound, a significant number of dedicated allocations should be made regarding the provision of elderly accommodation. It is considered that traditional C2 institutions are not the answer, but instead the promotion of ‘care villages’ where semi-independence can be secured for elderly people, with care and welfare available on site as their health deteriorates. Given the substantial need, it is considered that a policy supporting elderly care provision is not sufficient, and that as a strategic priority more dedicated sites should be allocated to provide elderly accommodation.

One potential site that could be allocated to help address the need is the Sprowston Sports and Social Club. The loss of the site would be mitigated through the allocation of a care village, providing necessary social infrastructure. Additionally, with the provision of POS on site, it would benefit the local community whilst encouraging a healthier and active lifestyle for the elderly residents, adhering to the aspirations of the GNLP.

Full text:

Object

Publication

Policy 6 The Economy

Representation ID: 24406

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Agent: Mrs Nicole Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

This policy does not address the need to allow room for change in existing businesses affected by the recent and current issues such as the pandemic. It is not effective, positively prepared or justified given the evidence base of the plan. As such, it is not consistent with paragraph 11 a) of the NPPF requiring plans to be positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change.

Paragraph 71 of the GNLP Pre-Submission Draft Strategy states that: “The GNLP should support the growth of a wide ranging and changing economy, ranging from high tech businesses with the capacity for major growth through to smaller rural enterprises.”

Paragraph 127 states that: “Generating the right level of growth in the right places will help our local economy by stimulating economic investment, new infrastructure, new technologies and environmental improvements. This will improve access across Greater Norwich to services and jobs, and lead to better environmental quality.

As per paragraph 35 of the NPPF, local plans are required to be consistent with national policy. Paragraph 80 of the NPPF states "Planning policies and decisions should help create the conditions in which businesses can invest, expand, and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future." Businesses, such as the Sprowston Sports and Social Club face an uncertain future and there should be policy considerations to address these concerns for local businesses to allow for diversification, or at least policy support that sees local businesses that are forced to closed to be replaced in part with new assets that serve local communities, such as a new Park and Garden that addresses a local deficit.

The failure to address these issues directly conflicts with paragraph 35 of the NPPF .

Change suggested by respondent:

Policy 6 needs to be adapted to provide a more flexible framework to encourage the sustainable change of use of existing land and businesses affected by the pandemic.
.....................................................
For example, the site of the Sprowston Sports and Social Club is located in a sustainable location close to new housing allocations where it would be appropriate to provide a mix of publicly accessible open space alongside housing for older people with care and amenities shared with the wider community in line with the ambitions of paragraphs 46 and 47 of the Pre-Submission Draft Strategy.

Full text:

Object

Publication

Settlement Map

Representation ID: 24426

Received: 22/03/2021

Respondent: Trustees of Richard Gurney Children's Settlement

Agent: La Ronde Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Town has undergone significant growth in recent years and it is important to review its settlement boundary to ensure that it is positively and effective.

Paragraph 3.63 provides for this wide area of the Norwich Urban Fringe only one site allocation for housing. This is a single large allocation of 1,200 homes. The paragraph notes that only 26 additional dwellings are accounted for by small sites, which represents an inadequately small number and proportion of such new homes. Although the paragraph notes that the allocations identified in the Growth Triangle Area Action Plan will not be superseded by the GNLP, this fails to reflect that not all the land adjacent to the Sprowston settlement boundary falls within that Area Action Plan. T

The Plan is not consistent with national policy. NPPF paragraph 68 states that "small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should: identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved". Additional small allocations should be considered in the town or the windfall policy needs to respond to the need for smaller sites to improve deliverability. One such site could be that of the old sawmill at Blue Boar Lane opposite the Sprowston Sports and Social Club. With the development boundary adjusted in this location the site could come forward in this sustainable location within 3 years.

Change suggested by respondent:

Allocation of the site comprising land to the west of Blue Boar Lane [site plan enclosed], or its inclusion otherwise within the Sprowston development boundary, would be both consistent with national policies and provide an effective and justified strategy in delivering the new housing needed to meet the area’s objectively assessed needs.

NPPF paragraph 68 requires the identification of sites less than 1ha to promote the development of a good mix of sites. The paragraph notes that small sites "make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly". The site west of Blue Boar Lane would provide such a small and deliverable site, measuring 0.6ha, and capable of providing 7 family homes of varying sizes. (For clarity, the area and housing referred to does not include the two existing houses, 156 & 158 Blue Boar Lane.)

The site is located entirely outside of the Growth Triangle Area Action Plan (2016) as defined in the Broadland Site Allocations Development Plan Document (2016) and the current GNLP Sprowston Settlement Map. Policy GT 2 of that Area Action Plan therefore does not apply to the site, notwithstanding the indication by the plan to the AAP of a Secondary Corridor under that policy applying to a small part of the site.

A part of the site already falls within the existing development boundary as defined in the Broadland Site Allocations Development Plan Document (2016) and the current GNLP Sprowston Settlement Map. This reflects the situation that the land forms a contiguous part of the existing built up area of Sprowston.

The site, as a former sawmill (use class B2) and with remaining access, hardstanding and fixtures, is brownfield or previously developed land, as defined in the NPPF (“Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure.”) NPPF paragraph 117 requires that "Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land" and paragraph 118 requires that "Planning policies and decisions should: c) give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land" and d) "promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively".

Furthermore, the site is 1.25km from the nearest listed building and there are no other heritage assets in the vicinity.

Full text:

There are insufficient small sites in Sprowston, and Policy 7.5 is inadequate to meet this need. See summaries for full detail.

Attachments:

Map of site embedded in document (1.73 MB)

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