GNLP 2045 Regulation 20 Scoping Consultation

Loddon Town Council welcomes the opportunity to comment on the Greater Norwich Local Plan
2045 Scoping Consultation.
The Council recognises the need to plan positively for housing, employment and sustainable
communities. However, it considers it essential that future development is genuinely infrastructureled
and that the cumulative impact of previous, committed and proposed development on
settlements such as Loddon is properly understood before further significant growth is allocated.
Loddon is a Key Service Centre serving not only its own residents but a substantial surrounding rural
area. Its shops, schools, healthcare, community facilities, employment opportunities and transport
network therefore perform a wider role than population figures for Loddon alone may suggest.
The Town Council considers that this wider function, together with existing infrastructure constraints,
should be central to decisions about the amount and location of future growth.
Question 1 – Are there any other key Strengths, Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis for Greater Norwich?
Loddon Town Council response:
The Council considers that greater recognition should be given to the infrastructure pressures
experienced by rural service centres which support a much wider catchment area.
A settlement may appear to have a good range of services and facilities and therefore be considered
a sustainable location for additional development. However, the existence of a facility does not
necessarily mean that it has su􀆯icient capacity to accommodate substantial additional growth.
The SWOT analysis should therefore recognise:
 pressure on highways and transport infrastructure within established settlements;
 capacity of healthcare, education and other community services;
 wastewater, drainage and water-supply constraints;
 the cumulative impact of successive developments;
 limited public transport choices in rural areas and the resulting reliance on private vehicles;
and
 the potential loss of landscape character and settlement identity through continued
peripheral expansion.
Infrastructure constraints should not simply be viewed as matters which can be addressed following
the allocation of development. They should inform the amount and location of growth from the
outset.
Question 2 – Is there any other baseline data that should be considered?
Loddon Town Council response:
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The Council considers that settlement-level infrastructure capacity data should form an important
part of the evidence base.
For Loddon this should include, as a minimum:
 highway capacity and tra􀆯ic movements, including the A146 and routes through the town
centre;
 cumulative tra􀆯ic impacts arising from existing, committed and potential development;
 public transport frequency, capacity and accessibility;
 school capacity;
 GP, dental and other healthcare capacity;
 wastewater treatment and sewer network capacity;
 surface-water drainage and flood risk;
 availability and capacity of sports, recreation and community facilities;
 pedestrian and cycling connectivity; and
 the availability and quality of green infrastructure and public open space.
The Council particularly considers that assessments should distinguish between the presence of a
service and its actual capacity to accommodate further population growth.
Question 4 – Which elements of the existing growth strategy and settlement hierarchy have and
have not worked well?
Loddon Town Council response:
The Council recognises the principle of directing development towards settlements with access to
services, employment and public transport.
However, there is a risk that settlements classified as Key Service Centres experience repeated
growth precisely because they contain services, without su􀆯icient consideration being given to
whether those services and the surrounding infrastructure have the capacity to accommodate
continued expansion.
Loddon has experienced significant development and the cumulative impact of this growth needs to
be properly assessed before determining an appropriate level of further development.
The Council therefore supports a more sophisticated approach which considers infrastructure
capacity, connectivity and environmental constraints alongside the number of existing services
within a settlement.
Question 6 – What areas do you consider appropriate for additional growth and what
infrastructure, services and amenities would need to be prioritised?
Loddon Town Council response:
At this early stage, Loddon Town Council does not consider it appropriate to identify or support
individual areas around Loddon for additional growth. The Council understands that individual Call
for Sites submissions have not yet been assessed and will be considered through a later stage of the
Local Plan process.
Before determining whether further significant growth should be directed towards Loddon, the
Council considers that a comprehensive assessment of the town's infrastructure capacity is
required.
Particular consideration should be given to:
 the A146 and its junctions;
 tra􀆯ic movements through Loddon and the town centre;
 highway capacity and road safety;
 sustainable transport and bus provision;
 safe pedestrian and cycling connections;
 education capacity;
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 GP, dental and healthcare provision;
 wastewater and drainage capacity;
 flood risk;
 sports, recreation and community facilities;
 green infrastructure and biodiversity; and
 the cumulative impact of existing and committed development.
Where development is proposed, the necessary infrastructure should be identified, funded and
delivered at an appropriate stage, rather than development being permitted in anticipation that
infrastructure improvements may follow at a later date.
Question 7 – Should changes be made to the settlement hierarchy?
Loddon Town Council response:
The Council supports reviewing the methodology used to establish the settlement hierarchy.
Loddon's designation as a Key Service Centre reflects its range of services and facilities and its
important role in serving the surrounding rural area. However, classification within the settlement
hierarchy should not automatically imply capacity for significant additional growth.
The Council supports an approach which combines accessibility and connectivity with a detailed
assessment of infrastructure and service capacity.
Any revised methodology should therefore consider:
1. the availability of services;
2. the capacity of those services;
3. sustainable transport accessibility;
4. highway constraints;
5. environmental constraints;
6. the amount of development already delivered or committed; and
7. the cumulative e􀆯ect of additional development.
This would provide a more realistic assessment of the ability of individual settlements to
accommodate further growth.
Question 15 – How can infrastructure delivery be well co-ordinated and funded to support
growth?
Loddon Town Council response:
The Council strongly supports an infrastructure-led rather than development-led approach.
Infrastructure requirements should be identified through the Local Plan evidence base before sites
are allocated wherever possible.
Development should contribute appropriately towards the infrastructure required as a consequence
of the additional population it generates, including highways, education, healthcare, community
facilities, sports and recreation, public transport, walking and cycling infrastructure and green
infrastructure.
The Council is concerned about situations where development is delivered significantly ahead of the
infrastructure required to support it.
The Local Plan should therefore establish clear mechanisms for phasing development against
infrastructure provision and should ensure that infrastructure commitments are deliverable and
adequately funded.
The cumulative impact of multiple developments within the same settlement or catchment must also
be considered when establishing infrastructure requirements.
Question 16 – Accessibility, wastewater capacity and net zero
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Loddon Town Council response:
The Council supports measures which improve accessibility to employment, services, sports and
community facilities through walking, cycling and public transport.
However, the realities of rural communities must be recognised. Residents of Loddon and the
surrounding villages remain considerably more dependent on private vehicles than residents of
Norwich, particularly for journeys which cannot readily be undertaken by public transport.
New development should therefore provide genuinely usable sustainable transport connections
rather than relying solely on theoretical proximity to existing services.
Wastewater treatment and sewer network capacity should also be established before significant new
development is allocated. Where infrastructure improvements are necessary, there should be
confidence that they can be funded and delivered within the required timescale.
Question 17 – Water e􀆯iciency, nature recovery and green infrastructure
Loddon Town Council response:
The Council supports strong standards for water e􀆯iciency, nature recovery, biodiversity and green
infrastructure.
Green infrastructure should be considered essential infrastructure rather than residual land
remaining after development.
New development should provide connected, accessible and appropriately managed green spaces
which contribute to biodiversity, recreation, climate resilience and the health and wellbeing of
residents.
Particular consideration should also be given to the cumulative loss of undeveloped land around
settlements and the importance of maintaining ecological connectivity between habitats.
Question 18 – High-quality design, landscape, townscape and historic environment
Loddon Town Council response:
The Council strongly supports policies requiring development to respond to local landscape,
townscape and historic character.
Loddon has a distinctive historic centre and an important relationship with the surrounding rural
landscape and the Broads.
Future development should therefore be designed in response to the specific character of Loddon
rather than applying generic development layouts and designs.
The Local Plan should seek to protect important views, landscape setting, heritage assets, mature
trees and hedgerows and ensure that new development creates attractive and distinctive places
which integrate successfully with the existing settlement.
The Council would also support meaningful early engagement with town and parish councils
regarding design and placemaking for significant developments.
Question 19 – Evidence required to prepare the GNLP 2045
Loddon Town Council response:
The Council considers that robust settlement-level infrastructure assessments should form part of
the evidence used to determine the distribution of growth.
For Key Service Centres such as Loddon, these assessments should consider infrastructure capacity
alongside the cumulative impact of development already completed, under construction or
committed through existing allocations and planning permissions.
The Council particularly supports evidence being gathered on:
 highway and junction capacity;
 tra􀆯ic and transport movements;
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 public transport accessibility;
 education capacity;
 healthcare capacity;
 wastewater and drainage infrastructure;
 flood risk;
 sports and recreation provision;
 community facilities; and
 green infrastructure.
This evidence should be available before decisions are made at the next stage regarding the preferred
distribution of growth and potential site allocations.
Question 22 – Is there anything else you would like to comment on?
Loddon Town Council wishes to emphasise that it is not opposed in principle to sustainable
development.
However, the Council considers that future growth must be proportionate to the ability of settlements
to accommodate it and must be supported by appropriate infrastructure.
The designation of Loddon as a Key Service Centre should not, by itself, be taken as evidence that the
town can accommodate substantial additional development.
Before determining the level of further growth appropriate for Loddon, the GNLP should assess:
what development the town has already accommodated; what development is already
committed; what capacity remains within its infrastructure and services; and what additional
infrastructure can realistically be delivered.
The Council considers that this evidence-led approach would provide the most appropriate basis for
determining whether, where and to what extent further growth around Loddon should take place.
Loddon Town Council looks forward to engaging further with the GNLP process when potential
growth options and individual sites are assessed at the next stage.