Publication

See attachment

We would add the following:
i. Policy 5 – Homes –we welcome the acknowledgement that high costs can have an impact on viability, and the adjustment to this Policy at ‘Affordable Housing, 1st bullet, (b)’ for brownfield sites. However, it is our view that this approach should not be restricted solely to brownfield sites. All sites within the Norwich Urban Area and Fringe will by their urban nature be constrained and will face the same challenges as City centre sites, and it is our view that the same flexible approach should be applied to those sites, with the lower 28% threshold being applied. As acknowledged by the proposed amendment to the Policy, this would need to be supported by viability evidence; and
ii. Policy 7.1 – The Norwich Urban Area including the fringe parishes – we continue to object to this policy on the grounds that there are no new allocations, including those proposed at GNLP2170 and GNLP2171, within the Thorpe St Andrew area. These sites were considered to be reasonable alternatives within the HELAA and are sustainable urban previously developed sites. There is no evidence to support the development of these sites as resulting in a loss of playing pitches, and the presence of Ancient Woodland is not considered to be a barrier to their development, rather an asset to be managed and protected within a redevelopment scheme.

See Attachment.

We would add the following:
i. Policy 5 – Homes –we welcome the acknowledgement that high costs can have an impact on viability, and the adjustment to this Policy at ‘Affordable Housing, 1st bullet, (b)’ for brownfield sites. However, it is our view that this approach should not be restricted solely to brownfield sites. All sites within the Norwich Urban Area and Fringe will by their urban nature be constrained and will face the same challenges as City centre sites, and it is our view that the same flexible approach should be applied to those sites, with the lower 28% threshold being applied. As acknowledged by the proposed amendment to the Policy, this would need to be supported by viability evidence; and
ii. Policy 7.1 – The Norwich Urban Area including the fringe parishes – we continue to object to this policy on the grounds that there are no new allocations, including those proposed at GNLP2170 and GNLP2171, within the Thorpe St Andrew area. These sites were considered to be reasonable alternatives within the HELAA and are sustainable urban previously developed sites. There is no evidence to support the development of these sites as resulting in a loss of playing pitches, and the presence of Ancient Woodland is not considered to be a barrier to their development, rather an asset to be managed and protected within a redevelopment scheme.