GNLP 2045 Regulation 20 Scoping Consultation

The existing GNLP growth strategy has provided a broadly sound basis for directing development towards sustainable locations and has supported significant housing delivery. However, the evidence presented in the Scoping Consultation demonstrates that the actual distribution of development has differed from that anticipated by the adopted strategy. Between 2018 and 2025, the Norwich Urban Area accounted for around 49% of housing delivery against a plan-period target of 62%, whilst Main Towns, Key Service Centres and villages delivered higher proportions than anticipated. This demonstrates the value of maintaining a balanced and flexible growth strategy, rather than relying predominantly upon the largest settlements.

The existing strategy's commitment to maximising brownfield opportunities should also be retained and strengthened. The consultation identifies an approximate 22% brownfield / 78% greenfield split in housing delivery. Whilst this reflects the limited availability of large brownfield sites and the viability and delivery challenges associated with sites of this nature, it should not be interpreted as limiting the potential contribution of brownfield land. Instead, it demonstrates the importance of using policy to encourage a wider range of brownfield opportunities, including smaller and predominantly previously developed sites and mixed sites where development makes effective use of existing developed land in sustainable locations.

The GNLP 2045 should therefore apply a clear brownfield-first principle, while ensuring that this is not focused solely on major urban regeneration schemes. Smaller brownfield opportunities can provide housing in locations where existing infrastructure and services are already available and can often contribute to delivery more quickly than major strategic schemes.

The role of village clusters and sustainable rural settlements should similarly be retained. The existing strategy recognised that growth in villages can support local services and community facilities, and the evidence demonstrates that villages have delivered a significantly greater proportion of housing than originally anticipated, reflecting demand and sustainability in these locations.

The GNLP 2045 should build upon this evidence. Proportionate growth in sustainable villages is important not simply as a source of housing but in ensuring that smaller communities continue to grow, evolve and support their existing services and facilities. A strategy which concentrates growth too heavily in larger settlements risks limiting the ability of smaller communities to respond to changing housing needs and maintain their vitality. It also limits the potential to mitigate for shortfalls in the delivery of committed development set out in the draft Village Clusters Housing Allocation Plan (VCHAP), which remains under consideration, and shortfalls in delivery in the initial years of the Local Plan period which have been seen following the adoption of the Greater Norwich Local Plan (March 2024).

Equally, the plan should avoid excessive reliance upon a limited number of large strategic allocations. The Council acknowledges that strategic sites and new settlements can have lengthy lead-in periods, whereas smaller sites can provide earlier and more flexible contributions to housing supply. A diverse portfolio of strategic, medium and smaller sites would provide greater resilience, particularly given the recent reduction in annual housing delivery and windfall completions. The consultation records a fall in overall delivery from 2,340 homes in 2023/24 to 1,893 in 2024/25 which seems to have occurred following the adoption of the Greater Norwich Local Plan (2024) and could be indicative of the reliance on delivering homes through large schemes directly connected to the Norwich area.

The review of the settlement hierarchy provides an opportunity to reflect these lessons. Settlement size and service provision should remain important considerations, but the hierarchy should also take account of actual connectivity, accessibility, public transport, walking and cycling opportunities, infrastructure capacity and the relationship between settlements. The Council's proposal to consider connectivity alongside the existing hierarchy is therefore supported.

Settlement boundaries should likewise not be treated as an absolute measure of sustainability. Sites immediately adjoining an existing settlement can be physically and functionally well related to it and may provide sustainable development opportunities, particularly where they comprise previously developed land and have good access to existing services and infrastructure.

Lowlands at Newton Flotman provides an example of this type of opportunity. The site is immediately adjoining the settlement, comprises predominantly previously developed and under-utilised land and benefits from close access to the village's services, pedestrian infrastructure and public transport. It illustrates how modest growth in a sustainable village can contribute to housing supply while supporting the wider objectives of the Growth Strategy.

Overall, the GNLP 2045 should build upon the strengths of the existing strategy and respond to the initial evidence rather than simply increasing the scale of strategic allocations. A balanced approach, combining strategic development with greater opportunities for brownfield land, small and medium-sized sites and proportionate growth in sustainable villages, would provide a more diverse and resilient housing supply while ensuring that communities across Greater Norwich are able to continue to grow and thrive.

The GNLP 2045 consultation recognises the important role that previously developed land can play in meeting the area's housing requirement and reducing pressure for development on wholly greenfield land. It is reassuring that this is reflected in the list of potential development types that could be utilised in response to the areas increased housing need as set out in the consultation material.

The current Local Plan identifies an approximate 22% brownfield/78% greenfield split in anticipated housing delivery throughout the plan period and noted the importance of delivering development on small brownfield sites to bolster housing delivery. However, the consultation identifies the limited supply of large brownfield sites and the viability, land assembly, contamination, abnormal cost and infrastructure challenges which can affect their delivery. These factors should not, however, lead to brownfield land being regarded as a marginal source of housing supply.

Instead, the GNLP 2045 should use policy to encourage the wider range of brownfield opportunities that exists across Greater Norwich, including smaller sites and sites comprising a mixture of previously developed and undeveloped land. To summarise, the updated Growth Strategy should support:
• redevelopment and intensification of previously developed and under-utilised land, including sites within and immediately adjoining existing settlements;
• smaller brownfield sites capable of contributing to housing delivery in the short to medium term;
• mixed brownfield/greenfield sites where development makes effective use of the previously developed component; and
• appropriate redevelopment and development opportunities within and adjoining sustainable rural settlements.

In this context, sites comprising a significant proportion of previously developed or under-utilised land, even if partially comprising greenfield or outside of a settlement boundary, should be assessed on their overall characteristics, setting and sustainability rather than excluded because part of the site is undeveloped or they sit outside of the policy area. This approach still favours developed land over historically undeveloped greenfield land but widens the extent of potential viable sites for redevelopment.

Policy should also help address some of the practical barriers to brownfield delivery. This includes ensuring that planning policies are sufficiently flexible to accommodate viable redevelopment schemes, avoiding unnecessary policy constraints and ensuring that infrastructure and other requirements are proportionate to the scale and nature of development.

In terms of the latter half of Question 5, the updated Growth Strategy should provide a balanced and flexible range of development opportunities, rather than relying predominantly on a small number of large strategic allocations. This should include brownfield intensification, strategic and smaller urban extensions, and appropriately located growth within and adjoining sustainable towns and villages as set out in the development type options in the consultation material. The contribution of smaller and medium-sized sites should be increased where they can make effective use of existing infrastructure and contribute to housing delivery over shorter timescales.

The strategy should also continue to recognise the role of sustainable rural settlements in meeting local housing needs and supporting vibrant and sustainable communities. The emerging VCHAP provides a framework for addressing these needs and acknowledges the contribution that appropriate growth can make to the vitality and resilience of rural settlements. However, there is scope to do more to support the delivery of suitable sites in these locations, particularly where they are well related to existing settlements, services and infrastructure and comprise previously developed land. Providing greater opportunities for proportionate growth in sustainable villages would help broaden the supply of deliverable sites and ensure that the benefits of growth are distributed across the wider Greater Norwich area.

Additional growth should be distributed across a range of sustainable locations rather than relying disproportionately upon major strategic sites or new settlements. The consideration of a range of development types within the consultation material is therefore supported. As is the council’s acknowledgement of potential implications of market conditions, infrastructure funding, build-out rates and lead-in times associated with larger scale developments.

The plan should therefore adopt a portfolio approach, ensuring that housing delivery is spread across a diverse range of site sizes, locations and delivery mechanisms. This should include strategic sites alongside smaller and medium-sized sites, brownfield and previously developed land, and appropriately located sites within and adjoining sustainable settlements. Such an approach would provide greater flexibility and resilience in the housing supply, reduce reliance on any single type or scale of development, and recognise that different sites can make different contributions to meeting housing need and delivery at different stages of the plan period.

Importantly, this should include a meaningful role for smaller and medium-sized sites in sustainable towns and villages. The adopted GNLP recognised that a range of smaller sites can provide choice, assist delivery and enable smaller-scale developers and builders to participate in the market, while its village clusters approach sought to support rural life and services through appropriate growth. The GNLP 2045 provides an opportunity to build on this approach, acknowledging the clear need and demand for housing in smaller settlements as is evident from the evidence provided in the consultation material. This demonstrates that 32% of housing delivered between 2018 and 2025 came from non-allocated sites, while villages accounted for around 17% of delivery against 9% anticipated over the plan period. The GNLP 2045 should therefore ensure that the contribution of such sites is fully recognised within the overall housing supply, alongside larger strategic allocations, providing a broader and more resilient pipeline of housing delivery. This will also ensure the council have more control over infrastructure and design parameters for sites of this nature through formal allocations rather than allowing them to come forward on an ad-hoc basis.

It is acknowledged that growth in sustainable villages should be supported by infrastructure and services that reinforce their existing role as rural settlements, rather than seeking to replicate the scale of provision found in larger settlements. Priorities should include safe and convenient walking and cycling connections to existing services and facilities, appropriate public transport provision, education and healthcare capacity either within the village or in surrounding settlements, and access to green infrastructure, recreation and community facilities. Particular emphasis should be placed on improving connectivity between new development and the existing settlement, so that growth helps to support and strengthen local services rather than creating isolated development.

Infrastructure provision should be proportionate to the scale and location of growth and should make effective use of existing capacity, with improvements targeted where additional demand is identified. This is particularly important in rural areas, where relatively modest levels of growth can help sustain schools, shops, community facilities, public transport and other local services, while also helping to maintain the vitality of the settlement. The GNLP 2045 should therefore consider infrastructure alongside the location and scale of growth, ensuring that appropriate improvements can be delivered in step with development and that opportunities are taken to address existing connectivity or service deficiencies where these are directly related to planned growth.

The settlement hierarchy should continue to provide a clear framework for directing growth, but its application should recognise the different ways in which settlements function and their ability to accommodate sustainable development. In addition to settlement size and population, greater weight should be given to factors such as access to services and facilities, public transport, walking and cycling connections and the relationship between a settlement and its surrounding communities.

The review should also recognise the contribution that village clusters can make to meeting housing need. This is currently largely deferred to the VCHAP, but it would be valuable to acknowledge their value more robustly within the body of the Local Plan to build on the commitments made in the VCHAP. The experience of the adopted GNLP demonstrates that villages have made a greater contribution to housing delivery than originally anticipated, indicating that the existing hierarchy does not necessarily reflect the full capacity or role of these settlements. The GNLP 2045 should therefore ensure that the hierarchy is sufficiently flexible to recognise appropriately located development within and adjoining sustainable settlements, including where sites can contribute to housing delivery while supporting the vitality and long-term sustainability of the settlement.

The GNLP 2045 should seek to improve housing delivery by adopting a more diverse and resilient approach to the supply of housing land as discussed previously. The consultation appropriately recognises that Greater Norwich currently has a 4.85-year housing land supply and that delivery rates need to increase to ensure that current and future housing needs are met. The consultation also identifies a range of factors affecting delivery, including increased construction and labour costs, regulatory requirements, borrowing costs and wider market conditions. These challenges underline the importance of maintaining a broad portfolio of sites, so that the delivery of the housing requirement is not overly dependent on a limited number of large or complex developments that are often impacted more significantly by these matters.

A greater role should therefore be given to smaller and medium-sized sites as part of the overall housing supply. The consultation acknowledges that the draft NPPF requires a greater mix of site sizes, including provision for both small and medium-sized sites. This approach should be embraced not simply as a numerical requirement, but as an important means of improving the resilience of housing delivery. Smaller and medium-sized sites can come forward through a wider range of locations and ownerships and, although they remain subject to the same necessary planning, environmental and infrastructure considerations, they will often have fewer of the complex land assembly, strategic infrastructure and abnormal cost requirements associated with some larger schemes.

This is particularly relevant to the delivery of housing in existing towns and sustainable rural settlements. A greater diversity of site sizes would allow housing to be provided in locations where it is proportionate to the scale and character of the settlement and can make effective use of existing services, infrastructure and community facilities increasing the potential for investment. It can also provide opportunities for a wider range of housing types and tenures and enable smaller and medium-sized developers and builders to contribute to overall supply. The adopted GNLP itself recognised the value of allocating medium and smaller sites to provide choice, assist delivery and allow smaller-scale developers and builders into the market.

The GNLP 2045 should therefore provide a continuous and diverse pipeline of housing opportunities, with smaller and medium-sized sites complementing strategic allocations and helping to provide additional flexibility where delivery from larger schemes is delayed or subject to complex constraints. This would provide greater resilience and help ensure that the increased housing requirement can be met over the plan period.

The GNLP 2045 should aim to allocate a higher proportion of homes on small and medium-sized sites than the minimum 10% requirement. The minimum should be regarded as a starting point rather than a ceiling, particularly given the need to provide around 20,000 additional homes over the 2026–2045 period and the current challenges in maintaining housing delivery, particularly when delivering larger sites. A greater proportion of smaller and medium-sized allocations would help create a broader and more resilient portfolio of sites, reducing reliance on a relatively small number of large strategic developments and providing additional sources of housing delivery where larger schemes experience delays or longer lead-in periods. The consultation itself recognises that strategic sites, whilst valuable in delivery housing throughout the Local Plan period, generally take longer to deliver their first homes than smaller sites which can result in shortfalls in delivery.

There is also a strong case for locating a meaningful proportion of these sites within and adjoining existing towns and sustainable rural settlements. Smaller and medium-sized developments can be more readily integrated with the scale, character and existing pattern of settlements, while making use of established services, facilities and infrastructure. They can provide a range of housing types and tenures, support smaller and medium-sized builders, and contribute to the vitality and sustainability of existing communities. This would complement rather than replace strategic allocations, providing a more balanced supply of housing across different locations and delivery mechanisms.

A higher proportion of small and medium-sized sites would therefore support the wider objectives of the GNLP 2045 by improving choice and flexibility within the housing land supply and helping to maintain a continuous pipeline of delivery. This is particularly important where the plan needs to respond to a significantly increased housing requirement and where the timing and delivery of major strategic sites cannot be guaranteed due to the complex nature of externa variables that may impact their delivery as set out in the consultation material.

The plan should consequently seek to exceed the 10% minimum for both small and medium-sized sites, with the precise proportion informed by the evidence base and the capacity of suitable and sustainable locations. In doing so, it should ensure that smaller sites are not treated simply as a residual source of supply, but as an integral component of the overall growth strategy and an important means of improving the resilience and deliverability of housing provision.

The GNLP 2045 should provide an appropriate degree of local policy flexibility for housing and other development outside defined settlement boundaries, while ensuring a consistent approach with the current NPPF. Policy S5 of the NPPF sets out a broader range of circumstances in which development outside settlements may be acceptable, including the reuse, extension, alteration or replacement of existing buildings, redevelopment of previously developed land, limited infilling, exception sites and development which addresses an evidenced unmet need. The new GNLP provides an opportunity either to reflect these circumstances more fully through locally specific policy, where there is a clear local justification, or to rely directly on the exceptions as set out in Policy S5.

In either case, the approach should distinguish between isolated development in the open countryside and development which is physically and functionally well related to an existing settlement. The latter can make a useful contribution to housing delivery, particularly where sites are immediately adjoining a settlement, have good access to existing services and facilities, and can be accommodated without unacceptable impacts on the character or landscape of the area. This is clearly emphasised by the introduction of Policy S5 to national policy. The plan should therefore not treat the settlement boundary as an absolute barrier where a site is demonstrably well related to the existing built form and represents a sustainable and proportionate opportunity for growth in accordance with national policy.

The proposed evidence base provides an appropriate starting point, but it should ensure that the GNLP 2045 assesses not only the theoretical capacity for growth but also the realistic capacity and deliverability of different types of sites and locations. The Greater Norwich Local Housing Needs Assessment (LHNA) will be important in establishing the types, sizes and tenures of housing required, including affordable and specialist housing needs. Alongside this, the Housing Capacity Study should provide a robust assessment of how that need can realistically be accommodated, taking account not only of overall capacity but also housing completion rates, market strength, site sizes and the different characteristics and delivery potential of strategic, medium-sized and smaller sites. This evidence should help ensure that the Growth Strategy is based on a realistic portfolio of opportunities rather than relying to heavily on one form of development.

The Densification and Brownfield Opportunities plus Townscapes Study should also have a sufficiently broad scope to identify brownfield and previously developed land opportunities beyond the principal urban areas and market towns. The consultation currently proposes a focus on key brownfield sites across Norwich, the wider urban area and market towns, alongside consideration of policies to promote windfall development on unallocated brownfield sites. Given the proposed ‘brownfield first’ approach, it would be important that the evidence also considers the potential contribution of suitable brownfield and previously developed sites within smaller settlements and sustainable villages. This is particularly important if brownfield development sites are to form a meaningful and consistent component of the housing land supply.

More generally, the evidence base should examine the relationship between housing capacity and actual delivery under the adopted GNLP. This should include the contribution made by non-allocated sites, the lead-in times associated with strategic and smaller sites, and the extent to which infrastructure, viability, land assembly or other constraints have affected delivery. The Housing Capacity Study provides an opportunity to consider these factors collectively and to identify whether there is sufficient capacity across a range of site sizes and locations to provide a continuous supply of housing throughout the plan period.

A specific assessment of the capacity and potential contribution of sustainable rural settlements would also be valuable, including consideration of existing services, public transport, walking and cycling connections, schools, community facilities and opportunities to strengthen their role through proportionate growth. Taken together, this evidence should identify not simply where development could theoretically take place, but where a diverse range of sites can realistically contribute to meeting housing need over the plan period, including sites capable of earlier delivery and sites which can make effective use of existing infrastructure and services. This would provide a stronger basis for determining the appropriate balance between strategic allocations, smaller and medium-sized sites, brownfield opportunities and growth in sustainable settlements.