GNLP 2045 Regulation 20 Scoping Consultation

It is our view that no additional local policy covering rural exception sites and isolated countryside homes is required beyond what is already set out in national draft NPPF policies HO10 and HO11. These national policies provide an up-to-date and robust framework, and creating additional local policy would risk introducing confusion, causing delay, and creating divergence from national standards. The categories of development that may be approved outside settlement boundaries including brownfield redevelopment, limited infilling, rural exception sites, housing near well-connected railway stations, and limited isolated homes are already clearly defined within national policy Section S5, and do not require further local interpretation.
However, existing local policies covering other forms of rural development should be retained. The provisions currently in place relating to self-build and custom-build housing, conversion of rural buildings, replacement dwellings, subdivision of existing properties, and dwellings associated with rural enterprises are not duplicates of national policies and address different circumstances that HO10 and HO11 do not cover in detail. These existing policies have been demonstrated to work well, are locally tailored, and support forms of sustainable rural development that are particularly appropriate to the character of the Greater Norwich area. Retention of these proven policies alongside the application of national policy will provide both clarity and deliverability, combining a consistent national framework with targeted local provisions that reflect local circumstances.

To deliver the right types and mix of commercial space in appropriate locations, the plan should allocate a range of employment sites from small starter plots through to larger strategic allocations distributed across all tiers of the settlement hierarchy. Design standards should enable flexibility of use and adaptable floorplates to accommodate changing business needs, and new workspace should be located alongside residential allocations where practicable and if commercially desired to reduce travel distances and support local labour markets.
To support key growth sectors, strategically important sites including Norwich Research Park, Hethel Engineering Centre, the Food Enterprise Park and Norwich Airport should be protected from inappropriate competing development. Land should be allocated specifically to support the needs of identified growth sectors including life sciences, clean energy, agri-tech, digital industries and advanced manufacturing, and sufficient housing should be delivered in proximity to these major employment hubs to support workforce recruitment and retention.
Opportunities in the rural economy should be supported through positive policy provision for farm diversification and rural business expansion, and through permitting appropriate light industry and workspace development in suitable rural locations. This will support the continued growth of the agri-food sector at key production clusters across the plan area.
Workforce and skills development should be supported primarily through housing policy, ensuring that homes of appropriate types, tenures and price points are available close to major employment hubs and educational establishments to attract and retain workers at all skill levels.
In relation to freight and logistics, policy should remain proportionate given that evidence confirms Greater Norwich is not a national logistics hub. Priorities should focus on delivering planned A47 and A11 capacity improvements and providing appropriate strategic HGV parking provision rather than allocating large areas of land for logistics uses.
Support for small businesses and start-ups should be provided through a positive local policy framework that encourages small-scale workspace provision within new developments and existing buildings, simplifies planning requirements for small enterprise, and makes affordable workspace available through allocation of appropriately sized plots within new communities if the market conditions are suitable.

To deliver the right types and mix of commercial space in appropriate locations, the plan should allocate a range of employment sites from small starter plots through to larger strategic allocations distributed across all tiers of the settlement hierarchy. Design standards should enable flexibility of use and adaptable floorplates to accommodate changing business needs, and new workspace should be located alongside residential allocations where practicable and if commercially desired to reduce travel distances and support local labour markets.
To support key growth sectors, strategically important sites including Norwich Research Park, Hethel Engineering Centre, the Food Enterprise Park and Norwich Airport should be protected from inappropriate competing development. Land should be allocated specifically to support the needs of identified growth sectors including life sciences, clean energy, agri-tech, digital industries and advanced manufacturing, and sufficient housing should be delivered in proximity to these major employment hubs to support workforce recruitment and retention.
Opportunities in the rural economy should be supported through positive policy provision for farm diversification and rural business expansion, and through permitting appropriate light industry and workspace development in suitable rural locations. This will support the continued growth of the agri-food sector at key production clusters across the plan area.
Workforce and skills development should be supported primarily through housing policy, ensuring that homes of appropriate types, tenures and price points are available close to major employment hubs and educational establishments to attract and retain workers at all skill levels.
In relation to freight and logistics, policy should remain proportionate given that evidence confirms Greater Norwich is not a national logistics hub. Priorities should focus on delivering planned A47 and A11 capacity improvements and providing appropriate strategic HGV parking provision rather than allocating large areas of land for logistics uses.
Support for small businesses and start-ups should be provided through a positive local policy framework that encourages small-scale workspace provision within new developments and existing buildings, simplifies planning requirements for small enterprise, and makes affordable workspace available through allocation of appropriately sized plots within new communities if the market conditions are suitable.

The existing retail hierarchy should be retained but boundaries updated to reflect changes that have occurred since the original plan was adopted, ensuring the classification accurately reflects current vitality. The plan should support mixed-use development within all centres, enabling homes, offices, leisure and community uses to operate alongside retail to ensure centres remain viable even where retail demand contracts. New housing should be encouraged within walking distance of town and district centres to sustain footfall and transport accessibility and parking provision should be enhanced to maintain centre attractiveness.
Retail impact assessment thresholds should be set at proportionate risk-based levels so that small developments are not subjected to disproportionate assessment that causes delay. Stronger protection and lower impact thresholds should apply to Norwich city centre and the Main Towns, while more proportionate testing should apply at lower tiers of the hierarchy. All policies should be aligned to up-to-date retail evidence including latest catchment data, vacancy rates and centre health assessments.
Policy relating to the evening and late-night economy should be reviewed to reflect changed market conditions. The existing Late-Night Activity Zone was designed for a market that has since contracted significantly, and strict boundaries may no longer be appropriate. A broader range of evening and leisure uses should be encouraged across a wider area of the city centre to support vitality, with amenity impacts managed through building design and operational conditions rather than through blanket exclusion of housing from appropriate locations.

The plan should set out a positive presumption in favour of appropriate tourism development across the Greater Norwich area. Capacity should be allocated for a range of visitor accommodation types including hotels, self-catering provision, glamping and rural lodgings, distributed to match patterns of visitor demand. Farm diversification into tourism uses should be actively supported including provision of holiday accommodation, visitor facilities and rural leisure activities. Investment in public realm, signage, active travel infrastructure and public transport links to key visitor destinations will also support the ongoing growth and broadening of the visitor economy.
All development should be designed and located sensitively to respect local landscape, settlement character and heritage assets. The plan should encourage a dispersed pattern of tourism growth to distribute economic benefit while avoiding over-concentration that could adversely affect amenity or environmental quality. New development should demonstrate protection and enhancement of natural assets including biodiversity net gain, and the design and operation of tourism uses should manage potential impacts including visitor parking, noise and seasonal activity to ensure compatibility with existing residential communities. In this way the growth of the visitor economy can be supported alongside the protection of the area's character and environment.

Coordination of infrastructure delivery should be strengthened through formalising and enhancing the existing Greater Norwich Growth Board and Greater Norwich Infrastructure Partnership model to provide a single strategic overview across all participating authorities. Infrastructure capacity should be mapped alongside proposed housing allocations so that the availability of services, constraints and required improvements are understood before sites are allocated. All infrastructure should be phased to come forward in step with housing occupation so that new residents receive services as they are needed, rather than infrastructure being treated as an upfront barrier or being delivered many years after homes are occupied. Engagement with water, energy and telecoms providers should commence early in the plan-making process to agree multi-year reinforcement programmes and establish available capacity.
Funding mechanisms should be reformed to pool contributions across developments so that major strategic infrastructure requirements can be funded collectively rather than charged disproportionately to individual sites. Clear standardised contribution schedules should be published to remove repeated negotiation and delay at planning application stage. Funding sources should be blended equitably combining developer contributions, public grant funding and utility investment, and payment mechanisms should remain flexible to allow phased payments or in-kind contributions where site viability is constrained. Infrastructure investment must be coordinated, fairly funded and realistically phased so that it enables growth rather than preventing it.

Growth should be prioritised in locations close to railway stations, and where high-frequency bus services operate to maximise sustainable travel choice. New housing allocations should be connected to active travel routes including the Local Cycling and Walking Improvement Plan network and key paths and public transport improvements including community transport provision should be planned alongside growth in rural areas where commercial services are limited.
To address wastewater capacity and nutrient neutrality, priority should be given to accelerating improvement programmes at Whitlingham and other wastewater treatment works. A plan-wide strategic approach to nutrient mitigation should be adopted enabling aggregated accredited provision rather than requiring individual site solutions that cause repeated delay. Sites located in areas outside the nutrient constraint zone should be prioritised for early delivery while strategic catchment improvements are progressed.
On energy and climate, all new housing should be built to national standards including the Future Homes Standard due to apply from March 2027, with no additional local energy efficiency standards set above national requirements. Energy infrastructure needs should be assessed early including grid reinforcement, district heating opportunities and on-site renewable capacity, and housing allocations should be directed to locations where sufficient energy supply capacity exists or can be provided in reasonable timescales.
Community infrastructure including schools, healthcare facilities, sports provision and open space should be delivered alongside housing so that capacity keeps pace with population growth. Existing gaps in GP, dental and library provision particularly in Broadland and South Norfolk should be addressed through targeted investment, and full fibre and 5G digital infrastructure should be required as standard within all new developments.

Water efficiency standards should be aligned to the approach permitted within the NPPF and should not exceed national guidance through imposition of additional unevidenced requirements that add cost without demonstrated benefit.
For nature recovery and biodiversity, the statutory requirement for ten percent Biodiversity Net Gain should be applied across all qualifying development. The plan should move away from purely site-by-site mitigation toward enabling contributions to strategic plan-wide schemes addressing nutrient reduction and habitat restoration, which deliver greater overall environmental benefit than fragmented on-site provision. Strategic nature recovery areas should be identified alongside housing allocations so that mitigation capacity is known upfront, and developers should be permitted to contribute to accredited strategic schemes where on-site provision cannot be delivered effectively.
Green infrastructure planning should build upon the recently published 2025 Greater Norwich Green Infrastructure Strategy and should follow national green infrastructure standards rather than creating conflicting local requirements. Suitable Alternative Natural Greenspace and strategic green infrastructure corridors should be identified and safeguarded early in the plan preparation process so that land is available when needed and delivery delays are avoided. All green infrastructure should be designed to deliver multiple benefits combining flood management, biodiversity enhancement, public access and recreational value to maximise public benefit from investment.

High quality design should be promoted through adoption of design codes and masterplanning frameworks that set clear consistent expectations across the plan area. A building height sensitivity study should be undertaken to identify where taller development can be accommodated without harming heritage assets or important views, enabling brownfield intensification in appropriate locations while protecting the setting of the cathedral, conservation areas and wider historic environment. Density standards should be varied appropriately with higher densities encouraged in the city centre and around major public transport hubs, transitioning sensitively downwards at settlement edges to respect existing character.
The historic environment should be protected through retention of robust policies covering Listed Buildings, Conservation Areas and their settings. New development should respect established scale, architectural character and traditional materials, complementing rather than competing with historic assets, while high-quality contemporary design should be welcomed where it is well-conceived and respects its context.
The adopted Landscape Susceptibility guidance should be retained and updated. The policy should evolve from protection alone toward delivering multifunctional benefits where opportunities arise to combine landscape enhancement with biodiversity gain, flood management and green infrastructure provision.

Adjustments are recommended to the scope of several proposed studies. The New Settlements Study should acknowledge the long lead times required to bring major new settlements forward and its findings should not be relied upon to deliver housing numbers needed before 2045. The Housing Capacity Study should explicitly test housing capacity at increased allocation caps to reflect demonstrated delivery rates rather than being constrained by existing settlement boundaries. The Water Cycle Study and Habitats Regulations Assessment should identify strategic plan-wide mitigation solutions as well as assessing site-specific impacts so that catchments can be unlocked at scale rather than site-by-site. The Viability Study should use fully up-to-date economic evidence and should test whether combined policy requirements risk rendering development unviable. The Brownfield and Densification Study should acknowledge realistic brownfield capacity based on existing plan evidence and should identify viability constraints and policy solutions rather than theoretical potential alone.
Additional evidence that should be commissioned includes, a forecast of five-year housing land supply position through the plan period, an infrastructure funding gap assessment comparing identified need against available revenue, and a deliverability audit distinguishing early-delivery sites from longer-term strategic allocations. All evidence studies should continue to be undertaken on a shared basis with neighbouring authorities through the Norfolk Strategic Planning Framework to ensure consistency, reduce duplication and share costs.