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Publication
0337R Policy
Representation ID: 24056
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not legally compliant
The approach taken in the assessment of sites and referred to in various site assessment booklets does not represent a transparent, objective or evidence based approach. The GNDP has failed to properly comply with its legal obligation to assess the Reasonable Alternatives on a comparative basis, having regard to a transparent and objective evidence, as is required by The Strategic Environmental Appraisal Directive 2001. (reference Legal Opinion at Appendix 1 of seperate attached representation document).
cc Representation report document
The GNDP should prepare proportionate evidence, properly informed by a Sustainability Appraisal and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites
GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.
Object
Publication
0581 2043 Policy
Representation ID: 24057
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not legally compliant
The approach taken in the assessment of sites and referred to in various site assessment booklets does not represent a transparent, objective or evidence based approach. The GNDP has failed to properly comply with its legal obligation to assess the Reasonable Alternatives on a comparative basis, having regard to a transparent and objective evidence, as is required by The Strategic Environmental Appraisal Directive 2001. (reference Legal Opinion at Appendix 1 of seperate attached representation document).
cc Representation report document
The GNDP should prepare proportionate evidence, properly informed by a Sustainability Appraisal and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites
GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.
Object
Publication
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 24058
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not legally compliant
The approach taken in the assessment of sites and referred to in various site assessment booklets does not represent a transparent, objective or evidence based approach. The GNDP has failed to properly comply with its legal obligation to assess the Reasonable Alternatives on a comparative basis, having regard to a transparent and objective evidence, as is required by The Strategic Environmental Appraisal Directive 2001. (reference Legal Opinion at Appendix 1 of seperate attached representation document).
cc Representation report document
The GNDP should prepare proportionate evidence, properly informed by a Sustainability Appraisal and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites
GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.
Object
Publication
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 24059
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not effective
A plan preparation uninformed by the anticipated rate of development for specific sites and instead based on an average of past delivery rates on different sites with entirely different issues at a different time with different economic and social circumstances is likely to be unsound and is certainly not transparent and tested for its ability to deliver sufficient houses within the plan period. In our view, this is particularly important where a plan such the GNLP seeks to supply a large number of homes on large scale development formats. As stated in paragraph 72 of the Framework, in identifying large scale development, authorities should "make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites...."
cc See seperate attached representation document (Reg19)
In view of the concerns and to ensure that the plan is effective and sound under this test we recommend
that:
a) evidence should be produced to define, explain and allow proper testing of the anticipated delivery rates of all committed and allocated sites. This would be in accordance with advice contained in paragraph 72 of the Framework.
b) Additional medium sized site allocations should be identified in order to reduce the over-reliance
of the plan's supply of housing on large-scale development sites. This would be in accordance
with advice contained in paragraph 68 of the Framework which confirms how small and medium
sized sites can make an important contribution to meeting the housing requirement of an area.
c) Additional contingency sites should be identified to provide greater assurance that additional
allocations could be made and delivered quickly if housing delivery in the plan area fell short of
expectation. As with additional allocations referred to in b) above additional contingency sites
should include small and medium sized sites sufficient to make a material impact on delivery and
capable of quick delivery and build-out.
d) Alternatively, other contingency sites should be identified to replace the Costessey contingency
site referred to in Policy GNLP0581/2043. The site is not considered to be justified and suitable
for development and, in any event, is unlikely to be delivered quickly given the substantial
necessary and in some cases uncertain improvements and mitigation
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.
Object
Publication
0581 2043 Policy
Representation ID: 24060
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not effective
A plan preparation uninformed by the anticipated rate of developemnt for specific sites and instead based on an average of past delivery rates on different sites with entirely different issues at a different time with different economic and social circumstances is likely to be unsound and is certainly not transparent and tested for its ability to deliver sufficient houses within the plan period. In our view, this is particularly important where a plan such the GNLP seeks to supply a large number of homes on large scale development formats. As stated in paragraph 72 of the Framework, in identifying large scale development, authorities should "make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites...."
cc See seperate attached representation document (Reg19)
In view of the concerns and to ensure that the plan is effective and sound under this test we recommend
that:
a) evidence should be produced to define, explain and allow proper testing of the anticipated delivery rates of all committed and allocated sites. This would be in accordance with advice contained in paragraph 72 of the Framework.
b) Additional medium sized site allocations should be identified in order to reduce the over-reliance
of the plan's supply of housing on large-scale development sites. This would be in accordance
with advice contained in paragraph 68 of the Framework which confirms how small and medium
sized sites can make an important contribution to meeting the housing requirement of an area.
c) Additional contingency sites should be identified to provide greater assurance that additional
allocations could be made and delivered quickly if housing delivery in the plan area fell short of
expectation. As with additional allocations referred to in b) above additional contingency sites
should include small and medium sized sites sufficient to make a material impact on delivery and
capable of quick delivery and build-out.
d) Alternatively, other contingency sites should be identified to replace the Costessey contingency
site referred to in Policy GNLP0581/2043. The site is not considered to be justified and suitable
for development and, in any event, is unlikely to be delivered quickly given the substantial
necessary and in some cases uncertain improvements and mitigation
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.
Object
Publication
0337R Policy
Representation ID: 24061
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not effective
A plan preparation uninformed by the anticipated rate of developemnt for specific sites and instead based on an average of past delivery rates on different sites with entirely different issues at a different time with different economic and social circumstances is likely to be unsound and is certainly not transparent and tested for its ability to deliver sufficient houses within the plan period. In our view, this is particularly important where a plan such the GNLP seeks to supply a large number of homes on large scale development formats. As stated in paragraph 72 of the Framework, in identifying large scale development, authorities should "make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites...."
cc See seperate attached representation document (Reg19)
In view of the concerns and to ensure that the plan is effective and sound under this test we recommend
that:
a) evidence should be produced to define, explain and allow proper testing of the anticipated delivery rates of all committed and allocated sites. This would be in accordance with advice contained in paragraph 72 of the Framework.
b) Additional medium sized site allocations should be identified in order to reduce the over-reliance
of the plan's supply of housing on large-scale development sites. This would be in accordance
with advice contained in paragraph 68 of the Framework which confirms how small and medium
sized sites can make an important contribution to meeting the housing requirement of an area.
c) Additional contingency sites should be identified to provide greater assurance that additional
allocations could be made and delivered quickly if housing delivery in the plan area fell short of
expectation. As with additional allocations referred to in b) above additional contingency sites
should include small and medium sized sites sufficient to make a material impact on delivery and
capable of quick delivery and build-out.
d) Alternatively, other contingency sites should be identified to replace the Costessey contingency
site referred to in Policy GNLP0581/2043. The site is not considered to be justified and suitable
for development and, in any event, is unlikely to be delivered quickly given the substantial
necessary and in some cases uncertain improvements and mitigation
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.
Object
Publication
Policy 7.1 The Norwich Urban Area including the Fringe Parishes
Representation ID: 24064
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
We recommend that:
a) proportionate evidence, properly informed by Sustainability Appraisal should be prepared and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
b) Subject to evidence and consultation, the GNDP could elect to allocate or identify both sites GNLP0332R and GNLP0334R for development or contingency, as alternatives to presently allocated or identified contingency sites or as additional allocated or contingency sites.
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
Object
Publication
Appendix 6 Housing delivery trajectory
Representation ID: 24065
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
We recommend that:
a) proportionate evidence, properly informed by Sustainability Appraisal should be prepared and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
b) Subject to evidence and consultation, the GNDP could elect to allocate or identify both sites GNLP0332R and GNLP0334R for development or contingency, as alternatives to presently allocated or identified contingency sites or as additional allocated or contingency sites.
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
Object
Publication
0337R Policy
Representation ID: 24066
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
We recommend that:
a) proportionate evidence, properly informed by Sustainability Appraisal should be prepared and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
b) Subject to evidence and consultation, the GNDP could elect to allocate or identify both sites GNLP0332R and GNLP0334R for development or contingency, as alternatives to presently allocated or identified contingency sites or as additional allocated or contingency sites.
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
Object
Publication
0581 2043 Policy
Representation ID: 24067
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
We recommend that:
a) proportionate evidence, properly informed by Sustainability Appraisal should be prepared and consulted on either to demonstrate the suitability of the proposed allocation sites and contingency site in comparison with other Reasonable Alternative sites or to demonstrate the suitability of sites GNLP0332R and GNLP0334R as either allocated sites or contingency sites.
b) Subject to evidence and consultation, the GNDP could elect to allocate or identify both sites GNLP0332R and GNLP0334R for development or contingency, as alternatives to presently allocated or identified contingency sites or as additional allocated or contingency sites.
Unsound - Not justified
The plan has failed to justify through proportionate and consistent evidence the selection of allocated site GNLP0337, identified contingency site GNLP2043/0581 and the rejection of Reasonable Alternative sites GNLP0332R and GNLP0334R.
See seperate attached representation document (Reg19) and evidence from Reg 18 stage.
