Publication

The GNLP should include all potential allocations within its administrative boundary, ensure a comprehensive strategy for growth is applied, and that all three areas are adequately provided for. This is also crucial when considering other policies, such as Policy 7.5 which refers to windfall schemes as without knowing where growth is planned in South Norfolk, there is an unacceptable reliance on all development and growth to be supplied by schemes of 3 to 5 dwellings in the absence of allocations.

Specifically, the GNLP, if the existing windfall policy is adopted as is, would require a substantial amount of allocated development to ensure rural communities and businesses remain viable. Taking Dickleburgh for example, this is a sustainable location, with local amenities and facilities, however following Covid-19 and the shut down of businesses, a larger development of more than 5 dwellings would be expected to truly support the settlement, allowing it to capitalise and thrive on new patrons and neighbours. GNLP2145 was submitted to this effect, providing a wealth of new community open space, as well as much needed housing for all ages. Such a development adheres and infills the settlement, whilst supplementing the viability of local businesses which are necessary to preserve the sustainable nature of Dickleburgh.

The GNLP in paragraph 1.3 states that South Norfolk villages are being prepared separately and are therefore not integral to the GNLP. As such, in accordance with paragraph 35 of the NPPF, the proposed strategy for South Norfolk, Broadland, and Norwich City is not positively prepared (how can the policy adequately address an objectively identified need if there is a third of the strategy is withheld?) and is not effective (the policy clearly states that strategic matters should be addressed rather than deferred). As such, the GNLP is found to be unsound in its current form omitting a substantial part of the allocations for future development within a third of the administered area and in direct conflict with paragraph 35 of the NPPF.

It is considered to make the plan sound that a dedicated policy to provide clarity and instruction on rural growth and development is needed. A policy which goes further than policy 7.5 and truly addresses the aspirations of paragraph 136 where all settlements will be supported by new housing and jobs. Such a policy can support windfall proposals, or allow for limited development, but in either case, would supplement the existing rural economies, facilitating growth. It is considered that growth of more than 5 dwellings, which would require affordable housing contributions, should be allowed.

For example, taking the village of Dickleburgh, out of the allocations that have been proposed at Regulation 18, GNLP2145 would be an ideal proposal. Such a development would ensure a good proportion of growth is available (which could be phased to be spread out over a period of time) which would supplement the existing local facilities in a more substantial way than ad hoc development of 3 to 5 dwellings. Such a development would aid in not only creating a more sustainable settlement, where new business may be attracted, but also secure the existing facilities with a wider customer base, especially in light of the recent economic challenges national lockdowns have created.

The GNLP proposes an unjustified strategy that is not positively prepared, conflicting with its aspirations in paragraph 136; "Our suburbs, market towns and villages will also be vibrant places to live with good access to services and facilities, supported by new housing and jobs and changing technologies. Homes here will be built at appropriate densities to respect and enhance local character and to meet the needs of all in mixed communities." The NPPF states in paragraph 78 that "housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." The GNLP does not propose a policy that supports this, instead proposing an allocation only approach, and exceptionally limited windfall proposals through policy 7.5 the GNLP. This approach is not consistent with national policy and directly restricts and impedes upon local rural economies which require new development, and new residents to expand and thrive. Given the GNLP does not identify opportunities or provide significant policy to support village and rural community growth in a meaningful manner, it is considered the GNLP actively restricts this, in conflict with paragraph 78 of the NPPF. As such the GNLP is not consistent with national policy and is in conflict with of paragraph 35 of the NPPF and proposes an unjustified strategy that does not provide an adequate strategy to ensure rural viability.

The conflict highlighted between the delivery statement and the housing policy (Policy 7.5) risks undermining the delivery of needed sustainable development. Instead, a clear policy should be provided for that outlines what is considered acceptable for windfall schemes, especially sites for larger sustainable settlements that would be defined as villages but housing 2500+ residents. This policy should address volume/density of development, as well as how it should relate to existing settlements or be allowed in sustainable locations in meaningful quantities to support rural economies.

Furthermore, if the policy is not addressed to facilitate meaningful growth, then housing allocations should be proposed to enable growth beyond the settlement boundaries in a way that supports the local economy. Additionally, clarity must be provided regarding what constitutes small scale growth. For example, looking at proposed allocation GNLP2145, we can see that growth is proposed in a way that compliments the settlements existing size, whilst infilling an edge of village location up to the highway network of the A140. This would result in a complimentary development, bringing a wealth of public benefits, as well as ensuring the vitality of Dickleburgh by allowing a sustainable settlement to expand to support itself.

Policy 7.5 is considered to be unjustified and inconsistent with national policy. Within the Delivery Statement for housing, the Regulation 19 GNLP states that "Additional opportunities will be provided, particularly for small scale growth at villages and on small brownfield sites across Greater Norwich, through additional windfall development." These additional opportunities are proposed through policy 7.5 of the GNLP. However Policy 7.5 does not provide any significant support for meaningful development. It is considered that the proposed limiting of development to 3 or 5 dwellings would not contribute affordable housing, public open space, or other benefits and would impede settlement viabilities, restricting necessary growth necessary to support existing services and facilities. As such, there is an inherent contradiction within the GNLP regarding the aspirations for the support for village growth, and the actual policies restricting growth. This also conflicts with the NPPF in paragraph 78 which supports rural vitality resulting in the policy being inconsistent with national policy. As such the proposed policies are not considered to be justified, effective, and is inconsistent with national policies.