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0297 Policy
Representation ID: 24383
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Please refer to full representations comprising covering letter and supporting documents. Whilst strong support is given to the draft policy, objection is raised to draft Policy GNLP0297 criteria 6 on the basis that there is ambiguity regarding the justification for its inclusion in respect of this specific site. In addition the wording could be interpreted as seeking to unnecessarily limit the delivery of housing at the site and therefore comment is made about the consistency of the draft policy wording with planning practice guidance.
It is noted that the Statutory Water and Sewerage Undertaker has a statutory duty to make provision for essential water supplies and the collection, treatment and disposal of used water. It is stated in the Greater Norwich Infrastructure Needs Report 2021 that “AW’s Water Resources Management Plan does not identify a need for additional water supply infrastructure to serve growth in Greater Norwich to 2038” (para 3.1.2). Notwithstanding this, it is stated at paragraph 6.14 of the Local Plan that “There is not currently enough capacity in Aylsham Water Recycling Centre to accommodate development and no plans to upgrade in terms of flow…”.
In respect of Buxton, the Greater Norwich Water Cycle Study identifies that the existing capacity at the Aylsham Water Recycling Centre, as operated by Anglian Water Services, is controlled via permit. It is identified in the report that ‘Aylsham WRC’s flow permit would be exceeded once all the growth within its catchment is delivered by 2038 and a new permit would be required.’ (page 17). However, Table 4-30 of the Greater Norwich Water Cycle Study states ‘AWS have confirmed upgrades are planned between 2020 and 2025’. As such it is currently unclear as to whether the flows associated with the proposed allocation have already been taken into consideration as part of the planned upgrades at Aylsham Water Recycling Centre or not. Clarity is sought on this matter as to confirm whether it is necessary for Policy GNLP0297 for include reference to draft policy criteria 6.
The Greater Norwich Water Study states at Table 4-30, in respect of applications submitted from 2020 onwards, “…developers should contact AWS to confirm flow rates and intended connection points (via a pre-development enquiry) to demonstrate that the WRC can accept the additional flows”.
If it is found that the proposed allocation flows are not included within the planned upgrade works, it is suggested that draft Policy0297 criteria 6 is reworded to state:
“Development proposals at Buxton should have regard to the findings of the Water Cycle Study which indicates potential capacity limitations at the Aylsham Water Recycling Centre’. A Utilities Statement will be required to support the planning application to demonstrate how capacity be made available to serve the site.”
It is suggested that this alternative wording better reflects the Planning Practice Guidance contained at paragraph 020 Reference ID: 34-020-20140306 which states “The preparation of plans should be the focus for ensuring that investment plans of water and sewerage companies align with development needs. If there are concerns arising from a planning application about the capacity of wastewater infrastructure, applicants can be asked to provide information about how the proposed development will be drained and wastewater dealt with…”
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
Policy 5 Homes
Representation ID: 24384
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
Draft Policy 5 states: “Major residential development proposals and purpose-built student accommodation will provide:
• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28% …”
This policy wording is not considered to be effective by inclusion of the reference “at least 33% affordable housing”.
In addition the policy wording does not appear to be robustly justified by the support evidence base. It is stated at paragraph 271 that the supporting Strategic Housing Market Assessment 2017 identifies a need for 11,030 affordable homes across Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point. In addition it is also stated at paragraph 271 that “The most recent viability study findings… conclude… generally able to provide 28% affordable housing”. Whilst it is noted that the Council has updated its Viability Evidence in December 2020 it doesn’t appear to relate to Broadland Village Clusters. In addition I am aware that Broadland Council has been seeking 28% affordable housing in recent S106 agreements based upon the relevant evidence base.
NDSS
The Pre-Submission Plan does not adequately demonstrate that a policy requirement for all new housing residential development comply with the Nationally Described Space Standards (NDSS) is ‘needed’. The fact that some proposals are already providing development which complies with the relevant standards is not sufficient justification. As such, the Plan is not justified, will not be effective, and is not consistent with national policy.
Affordable Housing
It is requested the policy is amended to state: “Major residential development proposals will provide 28% affordable housing on-site across the plan area. The Council will negotiate with developers if an accurate viability assessment indicates that this target cannot be met in full.”
NDSS
Specific reference to compliance with the NDSS should therefore be removed as it is not justified.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
Policy 2 Sustainable Communities
Representation ID: 24385
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The proposed policy requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations is not robustly supported by the Local Plan evidence base. As such, the Plan has not been positively prepared, is not justified, will not be effective, and is not consistent with national policy.
The ‘Greater Norwich Energy Infrastructure Study’ states at para. 5.4.1, that to respond to the aim to ‘minimise energy demand of the new development’ that: “New residential … developments need to meet Part L building regulations relevant at the time of construction …” (emphasis added). As such this is a proposed local policy requirement which needs to be robustly considered in terms of viability implications for all development if it is to be applied. The supporting evidence base does appear to demonstrate this.
Remove reference to the proposed requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations as it does not appear to be justified by the evidence base.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
0297 Policy
Representation ID: 24511
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Please refer to full representations comprising covering letter and supporting documents. Whilst strong support is given to the draft policy, objection is raised to draft Policy GNLP0297 criteria 6 on the basis that there is ambiguity regarding the justification for its inclusion in respect of this specific site. In addition the wording could be interpreted as seeking to unnecessarily limit the delivery of housing at the site and therefore comment is made about the consistency of the draft policy wording with planning practice guidance.
It is noted that the Statutory Water and Sewerage Undertaker has a statutory duty to make provision for essential water supplies and the collection, treatment and disposal of used water. It is stated in the Greater Norwich Infrastructure Needs Report 2021 that “AW’s Water Resources Management Plan does not identify a need for additional water supply infrastructure to serve growth in Greater Norwich to 2038” (para 3.1.2). Notwithstanding this, it is stated at paragraph 6.14 of the Local Plan that “There is not currently enough capacity in Aylsham Water Recycling Centre to accommodate development and no plans to upgrade in terms of flow…”.
In respect of Buxton, the Greater Norwich Water Cycle Study identifies that the existing capacity at the Aylsham Water Recycling Centre, as operated by Anglian Water Services, is controlled via permit. It is identified in the report that ‘Aylsham WRC’s flow permit would be exceeded once all the growth within its catchment is delivered by 2038 and a new permit would be required.’ (page 17). However, Table 4-30 of the Greater Norwich Water Cycle Study states ‘AWS have confirmed upgrades are planned between 2020 and 2025’. As such it is currently unclear as to whether the flows associated with the proposed allocation have already been taken into consideration as part of the planned upgrades at Aylsham Water Recycling Centre or not. Clarity is sought on this matter as to confirm whether it is necessary for Policy GNLP0297 for include reference to draft policy criteria 6.
The Greater Norwich Water Study states at Table 4-30, in respect of applications submitted from 2020 onwards, “…developers should contact AWS to confirm flow rates and intended connection points (via a pre-development enquiry) to demonstrate that the WRC can accept the additional flows”.
If it is found that the proposed allocation flows are not included within the planned upgrade works, it is suggested that draft Policy0297 criteria 6 is reworded to state:
“Development proposals at Buxton should have regard to the findings of the Water Cycle Study which indicates potential capacity limitations at the Aylsham Water Recycling Centre’. A Utilities Statement will be required to support the planning application to demonstrate how capacity be made available to serve the site.”
It is suggested that this alternative wording better reflects the Planning Practice Guidance contained at paragraph 020 Reference ID: 34-020-20140306 which states “The preparation of plans should be the focus for ensuring that investment plans of water and sewerage companies align with development needs. If there are concerns arising from a planning application about the capacity of wastewater infrastructure, applicants can be asked to provide information about how the proposed development will be drained and wastewater dealt with…”
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
Policy 5 Homes
Representation ID: 24512
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
Draft Policy 5 states: “Major residential development proposals and purpose-built student accommodation will provide:
• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28% …”
This policy wording is not considered to be effective by inclusion of the reference “at least 33% affordable housing”.
In addition the policy wording does not appear to be robustly justified by the support evidence base. It is stated at paragraph 271 that the supporting Strategic Housing Market Assessment 2017 identifies a need for 11,030 affordable homes across Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point. In addition it is also stated at paragraph 271 that “The most recent viability study findings… conclude… generally able to provide 28% affordable housing”. Whilst it is noted that the Council has updated its Viability Evidence in December 2020 it doesn’t appear to relate to Broadland Village Clusters. In addition I am aware that Broadland Council has been seeking 28% affordable housing in recent S106 agreements based upon the relevant evidence base.
NDSS
The Pre-Submission Plan does not adequately demonstrate that a policy requirement for all new housing residential development comply with the Nationally Described Space Standards (NDSS) is ‘needed’. The fact that some proposals are already providing development which complies with the relevant standards is not sufficient justification. As such, the Plan is not justified, will not be effective, and is not consistent with national policy.
Affordable Housing
It is requested the policy is amended to state: “Major residential development proposals will provide 28% affordable housing on-site across the plan area. The Council will negotiate with developers if an accurate viability assessment indicates that this target cannot be met in full.”
NDSS
Specific reference to compliance with the NDSS should therefore be removed as it is not justified.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
Policy 2 Sustainable Communities
Representation ID: 24513
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The proposed policy requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations is not robustly supported by the Local Plan evidence base. As such, the Plan has not been positively prepared, is not justified, will not be effective, and is not consistent with national policy.
The ‘Greater Norwich Energy Infrastructure Study’ states at para. 5.4.1, that to respond to the aim to ‘minimise energy demand of the new development’ that: “New residential … developments need to meet Part L building regulations relevant at the time of construction …” (emphasis added). As such this is a proposed local policy requirement which needs to be robustly considered in terms of viability implications for all development if it is to be applied. The supporting evidence base does appear to demonstrate this.
Remove reference to the proposed requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations as it does not appear to be justified by the evidence base.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
