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Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 23916
Received: 15/03/2021
Respondent: Chapelfield GP Limited c/o LaSalle Investment Management
Number of people: 2
Agent: Savills (UK) Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Yes
It is not considered that the policies reflect the requirements of the National Planning Policy Framework (‘NPPF’) and Planning Practice Guidance (‘PPG’), or the objectives of The Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 (‘UCO’).
3.1 The representations on the emerging Plan cover the following points:
1. The requirement to provide a flexible approach to enable City Centres to grow and diversify to enable them to respond to rapid changes in commercial property markets.
2. The requirement to ensure that policies in the emerging Plan are reflective of national legislation.
3. The requirement to ensure the development plan when taken as a whole including existing documents covering the Greater Norwich area are consistent.
3.2 The representations set out below suggest amendments to the emerging Plan in order to ensure its consistency with national policy and the regulatory framework enacted by Government over the last year. Importantly, the amendments suggested below support the objective that the policies are seeking to achieve in terms of supporting the vitality and viability of centres.
3.3 The representations relate exclusively to Policy 7.1 that provides the emerging policy in relation to ensure the vitality and viability of centres.
3.11 With the above in mind, Policy 7.1 starts by providing a positive approach to ensure flexibility, but then provides a restrictive approach that does not support Chantry Place, a pivotal location in the City Centre, in being able to expand and diversify in terms of City Centre uses. This restrictive approach is to the detriment of Chantry Place being able to contribute positively to the City Centre’s vitality and viability. The restrictive nature that the emerging Plan takes to delivering leisure uses within the City Centre at locations such as Chantry Place is therefore in conflict with objectives to ensure the vitality and viability of the City Centre.
3.13 Firstly, Chantry Place is located outside of the defined leisure area, which is defined by the Norwich Local Plan Policies Map, adopted December 2014. Therefore, Chantry Place is penalised by emerging Policy 7.1 as it is not in a location where leisure uses are promoted, and further where applications for them are submitted at locations such as Chantry Place, support for them does not exist as an applicant must demonstrate that there are no alternative locations within the defined leisure area (i.e. the sequential approach). This creates an environment where Chantry Place is treated as an ‘out-of-centre’ location, yet located within the City Centre. Such an approach would be inconsistent with the requirements of Paragraph 85 of the NPPF, and the definitions of edge and out of centre locations at Annex 2 of the NPPF and the subsequent policy requirements for those locations. The approach is not consistent with the positive strategy required to in-centre locations as part of either Parts (a) or (b) of Paragraph 85 of the NPPF. Policy 7.1 as drafted is therefore not consistent with national policy.
3.14 Therefore, either the Policy should be expanded to support leisure uses within all areas of the City Centre, or the definition of the areas where leisure use are supported should include Chantry Place and any other similar locations within the City Centre. Such an approach would ensure Policy 7.1 is consistent with the NPPF.
See Attachment for full details
Please see attached Consultation Statement in relation to Chantry Place, Norwich. Statement submitted on behalf of Chapelfield GP Limited c/o Lasalle Investment Management.
