GNLP 2045 Regulation 20 Scoping Consultation

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.

These representations are submitted on behalf of M Scott Properties (MSP) and provide
comments on the GNLP Scoping Consultation. We fully support the
ambitions of the GNLP to provide growth to strategic areas within the districts.
Background
MSP is working in partnership with a landowner, and therefore have an interest in land to
the east and west of the A and north of the A, around the settlements of Bawburgh,
Little Melton, Cringleford and the Norwich Research Park growth area (known as Melton
Park). The land, which is in single ownership, extends to approximately acres and has
the potential for strategic growth encompassing residential, retail, employment and
community uses.
Question Response
. Are there any other key Strengths,
Weaknesses, Opportunities or Threats that
should be included in the SWOT analysis
for Greater Norwich? Why?
We are in support of the SWOT analysis as
a way of understanding an area and
informing the vision and future objectives
for the area. In particular, we would like to
emphasise the importance of:
• Major road infrastructure
improvements could increase
capacity for growth in wellconnected
locations
• Significant viability pressures which
can affect the location and
deliverability of growth
• Co-location of infrastructure and
housing around emerging
economic clusters to create
sustainable and desirable places.
• World leading higher education and
research sectors
• Major challenges around the
delivery of brownfield sites
restricting growth coming forward
in highly sustainable locations
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. Is there any other baseline data that we
should consider when developing our
SWOT and analysis of the key issues facing
Greater Norwich?
Market and sales prices alongside
construction and major infrastructure
costs could be considered to ensure sites
are viable and have the ability to meet the
aspirations of the policies.
Accessibility, in particular connectivity and
sustainable transport from local
settlements to strategic employment and
retail areas could be considered
The Department of Transport
Connectivity Tool, or similar methods to
understand the existing and potential
connectivity could be inform residential
led growth areas.
. Do you agree with the proposed broad
structure of the GNLP  above? If not,
please suggest an alternative approach or
approaches which could be taken to
structuring the plan.
We believe the proposed GNLP 
structure is a logical way of locating
strategic growth in the most suitable and
sustainable locations, allocating specific
sites and creating site specific policies.
The proposed structure follows similar
methods to the adopted GNLP, which
overall is a very clear and well informed
document.
We support the digitalisation of the
document, and the use of clear measurable
and deliverable outcomes.
. Which elements of the existing growth
strategy and settlement hierarchy do you
think have and have not worked well?
We believe the existing growth strategy
and settlement hierarchy have located
growth in available and suitable locations
to date.
The focus of the majority of growth
around the Strategic Growth Areas, where
there is a range of existing infrastructure,
employment and amenities / services, as
well as the Main Towns (the 'blended
approach'), has enabled the required level
of growth to be accommodated in a
sustainable manner; striking an
appropriate balance between rural and
urban development.
The suitability of the existing growth
strategy is highlighted by the majority of
key sites coming forward in accordance
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
with the objectives of the GNLP<
notwithstanding challenging economic
conditions.
. How can the GNLP  support the
development of brownfield sites?
What development types would you
support as part of our updated Growth
Strategy?
Brownfield sites present a number of
challenges in relation to delivery, not least
those associated with viability. Site specific
policies should recognise this, factoring
infrastructure and other costs, which
without a full and proper understanding
can impact viability and delivery.
In terms of the types of development, we
would support residential led mixed use
developments, which are capable of
utilising and enhancing existing
infrastructure, employment, services and
amenities, in a sustainable manner, either
as stand-alone developments, or as part of
a wider strategic vision.
. What areas do you consider to be
appropriate for additional growth and
what infrastructure, services and amenities
would need to be prioritised to enable
growth in these locations?
Residential led growth should primarily be
located around existing and expanding
strategic employment opportunity areas,
the strategic road network where
infrastructure upgrades have (or are
planned to be delivered) sustainable
transport networks and existing
community infrastructure, such as
educational and health facilities.
Providing housing near strategic areas of
employment will create the opportunity to
enhance and deliver sustainable modes of
travel, including walking and cycling, in a
cost effective manner.
Locating growth near the strategic road
network which has been subject to
significant upgrades in recent years, will
reduce the need for large infrastructure
improvements, and should not contribute
to congestion around the more isolated
settlements.
The utilisation of existing infrastructure
will enhance the viability of development,
enabling quick delivery. This approach is
considered essential to ensure the housing
needs are met during the plan period.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Combining a mixture of employments uses
adjacent to residential growth will allow
sustainable neighbourhoods to be formed
providing all the necessary amenities
within the local area, supporting economic
growth.
This strategic approach to development
will also enable multiple developments to
contribute to required upgrades in terms
of infrastructure upgrades, services and
amenities in a proportionate manner;
helping ensuring a greater range and
number of developments are viable and
therefore can be delivered.
Given the challenges associated with
brownfield development, and the need to
drive development towards the most
sustainable locations, it is likely that the
Norwich fringe will remain the main focus,
in part, for growth.
In light of comments above relating to
growth being in locations close to strategic
employment clusters, as well as the
improved strategic road network, the area
to the west of the A and north of the A
(Melton Park), is considered to be an ideal
location for growth. It is one of the few
locations around the perimeter of Norwich
which has not been subject to growth in
recent years.
The area is in close proximity to Norwich
Research Park (the principal employment
area in the locality), as well as the upgraded
A and A. As well as utilising existing
infrastructure upgrades, development in
this location would provide an opportunity
to further improve existing infrastructure,
services and amenities. For example,
development could promote enhanced
connectivity between locations such as
Little Melton and NRP, whilst also
providing high-quality housing in close
proximity to the employment area;
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
increasing its attractiveness to investors
and developers.
. Should any changes should be made to
the settlement hierarchy through the new
local plan? Please explain your reasons.
We consider the settlement hierarchy
should be amended. A mix of new growth
should be appropriately portioned
throughout the GNLP area, providing
residential development in areas of
strategic growth.
We support the 'early policy direction of
thoughts' detailed in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper.
The document states that whilst the NPPF
supports a settlement-based approach to
growth, it should place greater emphasis
on the relationship between settlement
hierarchy, accessibility and transport
connectivity.
When identifying the settlement hierarchy,
as well the presence of existing services
and facilities within settlements, we
support consideration of how people can
access homes, employment, services and
infrastructure across the wider area
through the use of sustainable modes of
transport. We would further support the
use of the Department for Transport
Connectivity Tool and other evidence
sources to help demonstrate how
development in certain locations, and
associated improvements to connectivity,
can further contribute to achieving
sustainable development objectives.
In this regard, the comments that the
traditional settlement hierarchy approach
is unlikely to be responsive to changes that
may affect the sustainability of individual
settlements e.g. infrastructure provided as
a result of growth, new/improved public
transport, the opening of the NDR,
dualling of the A, is supported and
applies to the area to the west of Norwich.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
. What measures could the councils take
to improve housing delivery rates through
the local plan?
Improved viability for strategic sites
through site specific policies to allow for
site specific constraints, related
infrastructure requirements or aspirational
community projects.
Handling and response times, particularly
for consultees during consultation
processes, could be improved to reduce the
time of pre and planning applications,
reserved matters and infrastructure
agreements.
. The plan must include % of homes on
both small and medium-sized sites. Should
the plan aim to allocate a higher
proportion than this and, if so, why?
. What should the GNLP  do to
assist the delivery of:
• affordable housing
• accessible and adaptable homes
• specialist housing
• gypsy and traveller and travelling
showpeople sites
• self- and custom-build housing
The delivery of strategic sites which
contribute significantly to the housing
need, including specialist housing, can be
assisted by creating a site-specific policy
considering its constraints and required
infrastructure. This would assist with the
viability of the site to ensure the target
number of housing is met, and reducing
the risk of a viability issue being raised
further into the Local Plan process.
Specific minimum requirements should be
detailed, with any additional costs over
typical standard housing factored into the
allocation of the site and overall viability of
the Local Plan.
Self & custom build homes should be
allocated in small and rural settlements to
reflect the existing nature of development
and demand. Small allocations of self &
custom build homes located in villages will
be better suited to SME developers, as
opposed to strategic sites developed by
regional and national housebuilders.
. Should the GNLP :
• Provide additional coverage of rural
housing and development outside
settlement limits beyond that
contained in the draft NPPF?
• Retain aspects of existing local
policy concerning housing outside
settlement limits, such as self-build
and custom-build housing, barn
Rural housing should be considered in
settlements that:
• Are located in or near areas of
significant growth
• Are located near the strategic road
network, public transport links, or
the cycle and pedestrian network
• Benefit from existing facilities such
as education and health, or that
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
and other rural building
conversions, replacement
dwellings, the subdivision of
existing dwellings, and dwellings
connected to rural enterprises?
development can provide/enhance
these facilities
Self and custom build housing,
conversions and replacement dwellings
should be located in suitable smaller
settlements to retain the rural character.
Smaller development sits on the edge of
settlements are more suited to SME
developers.
. How should the GNLP :
• deliver the right types and mixes of
flexible and adaptable commercial
spaces in the right places?
• help our growth sectors to thrive,
possibly including protection of
site-specific industries?
• support other opportunities for
economic growth, including the
rural economy?
• strengthen skills and workforce
development?
• plan for freight and logistics?
• support small businesses and startups?
Growth should be directed near current
identified areas and infrastructure.
The spatial strategy and identification of
suitable locations for growth, should
recognise the link between economic
growth and the provision of high quality
housing and other everyday services, in
easily accessible locations that are well
connected by sustainable modes of
transport.
The plan should adopt a strategic approach
to growth, identifying the opportunity for
larger areas / clusters rather than
traditional settlements that are, or can be,
well connected to employment areas, to be
the focus for growth.
. How should the GNLP :
• help strengthen the city, town,
district and local centres?
• deal with thresholds for retail
impact assessments?
• address the evening and the latenight
economy in the city centre?
. How can the GNLP  support the
ongoing development of tourism,
whilst responding sensitively to the local
area?
. How can infrastructure delivery be well
co-ordinated and funded to support
growth?
The delivery of strategic infrastructure
should be co-ordinated throughout the
plan process, consulting with the sitespecific
land owners and consultees to
ensure any infrastructure is feasible,
deliverable and adequately funded.
Growth should be located in proximity to
areas of strategic infrastructure to assist
with the delivery and maximise the
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
potential opportunities through the Local
Plan.
However, as a first priority and as
recognised in the Greater Norwich
Development Partnership's Settlement
Hierarchy Topic Paper, Infrastructure
improvements, such as the dualling of the
A, should be recognised in the
preparation of the settlement hierarchy,
and utilised to secure well connected and
viable sustainable development that is
deliverable, when compared with new
settlements, in the early years of the plan
period.
. How should the GNLP  support
• Improved accessibility to housing,
employment, services, sports and
other community facilities?
• Delivery of wastewater treatment
capacity and address nutrient
neutrality?
• Clean power and net zero
objectives?
The Local Plan has the ability to allocate
strategic sites that are capable of providing
significant community benefits to new and
existing residents.
Wastewater treatment improvements are
the responsibility of Anglian Water and the
cost of upgrading infrastructure should not
be passed to developers, otherwise there is
a significant change development will not
be viable.
Whilst aspirations for clean power and net
zero objectives are supported in principle,
any associated additional costs should be
considered as part of the Local Plan's
viability.
. Should the GNLP :
• Set the most demanding local
standards possible for water
efficiency?
• Include higher or new standards for
nature recovery and allocate sites
for nature recovery or biodiversity
enhancement?
• Identify sites for enhanced green
infrastructure, including Suitable
Alternative Natural Greenspace,
and set local green infrastructure
standards?
Nutrient Neutrality has caused delivery
issues within the current Local Plan. The
ownership should be redirected to the
water companies instead of the developers,
with the ability for financial contributions
towards any maintenance.
Higher standards will have financial
implications on the development of sites,
creating unviable sites and leading to the
loss of potential housing.
Sites can be allocated to enhance the green
infrastructure within the area, however
consideration should be given on how
strategic sites deal with the quantum of
Natural Greenspace if there are other
strategic infrastructure requirements.
GNLP  Scoping Consultation Representations September 
Land to the East and West of the A and North of the A (Melton Park) 
Pooled S contributions would be an
appropriate way to provide environmental
gain in the most suitable locations.
. How should the GNLP  plan for
high quality design that promotes
sustainability and responds to local
landscape and townscape character and
the historic environment?
Supplementary Planning Documents are a
positive way of influencing the design of
developments. Design codes for growth
areas or strategic sites could be used to
illustrate the required parameters of built
form, architectural types, and landscape
mitigation strategies to ensure
development responds positively to the
local landscape and townscape character
and the historic environment.
. Should:
• the scope of any of the proposed
evidence studies be changed?
• any other evidence be updated or
commissioned to prepare the GNLP
?
The proposed scoping is considered to be
extensive and should be sufficient to direct
growth in the most suitable and
sustainable areas.
. Do you consider that our proposed
approach to engagement at the statutory
consultation stages correctly identifies:
• the purpose of each stage of
engagement?
• the target audience(s) at each stage?
• appropriate engagement methods
throughout?
We support the level of consultation
proposed, reiterating the need for
stakeholder and consultee engagement
throughout the Local Plan process in a
timely and efficient manner.