GNLP 2045 Regulation 20 Scoping Consultation

An additional opportunity should be identified within the SWOT analysis to highlight the opportunity to deliver additional development to meet local market and affordable housing needs in the area. Through this, the opportunity to provide growth which will support facilities and services in settlements will help to maintain their vitality and viability across the Greater Norwich area.

CODE are supportive of the broad structure for the GNLP 2045 in principle, which includes a more limited number of locally specific policies which do not repeat the contents of national decision-making policies. While we note the GNLP team’s preference for a digital document, this should not be instead of a PDF-based document. However, we consider that a digital map-based document, structured to contain clear points of reference such as policy, page and paragraph numbering to ensure clear reference to the relevant parts of the GNLP at the planning application stage would be a useful addition alongside the PDF-based document.

The progress update in table four, section four of the Scoping Consultation document demonstrates that the growth in the Norwich Urban Area and fringe parishes has not come forward as anticipated within the growth strategy. It notes that this is due in part to the reliance of larger strategic scale allocations and extensions being allocated in the urban area which have faced significant issues in relation to delivery and viability. As such, the reliance on the urban area of Norwich should be tempered in the new plan.

However, it also notes that the fringe parishes are starting to make significant progress in delivery and therefore have worked well within the existing growth strategy. This would accord with the fringe parishes’ ability to deliver high levels of growth in sustainable locations, earlier on in the plan period. Therefore, the fringe parishes should continue to be a focus for growth with a high proportion of the overall housing number being distributed to this category within the settlement hierarchy.

In light of the recognised housing land supply shortfall and increased housing need figure for the GNLP 2045, the existing growth strategy has not delivered sufficient quantum of development to meet local needs.

While the distribution of growth across the rest of the settlement hierarchy has exceeded the GNLP targets, the restriction to ‘limited, small-scale development’ in village clusters prevents development of sites that can deliver growth and benefits to maintain the vitality and viability of services in local communities alongside the potential to deliver improvements to local infrastructure distributed across the Greater Norwich area. Therefore, in the new plan this policy restriction needs to change. We suggest that a new ‘development type’ should be added to the growth strategy to facilitate allocations of up to 250 new homes in village clusters.

The GNLP 2045 should reflect the support provided to brownfield sites within the revised National Planning Policy Framework (NPPF) (August 2026). While the provision of brownfield sites should be supported where possible, it should be recognised that these sites face increased issues in relation to development viability and delivery which should be factored into the wider housing trajectory and growth strategy. This is demonstrated by the development of Anglia Square, which is only able to come forward with funding from Homes England. Additionally, in the context of the Greater Norwich area where, as the Scoping Consultation recognises, only 22% of the housing requirement can be delivered on brownfield land, it should be acknowledged that in order to meet housing needs, development will be required on greenfield sites, resulting in the loss of best most versatile agricultural land.

CODE are supportive of the development types which focus growth to sustainable locations. There should not be an over-reliance on strategic urban extensions and new settlements alone to meet housing needs, given the longer lead-in times and development constraints. Growth should be distributed appropriately across the settlement hierarchy including growth in the fringe parishes and villages. Such an approach would ensure a consistent supply of deliverable housing sites, providing a range of development sizes which can be delivered earlier on in the plan period. It would also ensure that the vitality of local services in villages is maintained or enhanced by the delivery of new homes that provide a choice in supply and encourage diversity in the demographic of village cohorts.

To facilitate this, we suggest that a new ‘development type’ should be inserted to the growth strategy to enable allocations of up to 250 new homes in village clusters.

Bullen Group Ltd have submitted various sites into the GNLP Call for Sites exercise across a range of scales and locations. These include sites within the fringe parish of Drayton (site references 25885, 25887, 25888 and 25889) which is recognised within the existing growth strategy as a sustainable location for growth, well-related to the urban area of Norwich. The settlement benefits from a range of facilities and services which could support development and the sites put forward are all well-related to the existing settlement, within walking distance of facilities and services and provide the opportunity to assist the GNLP in meeting its housing needs and delivering benefits to the local community. Site specific evidence documents are being prepared in relation to highways and education to demonstrate that additional growth can be accommodated within this area.

Bullen Group Ltd have also put forward residential and commercial sites in Horsford (site reference 25860, 25868, 25883 and 25884) which are considered to benefit from its connectivity to the Broadland Northway (A1270). Similarly, sites have been promoted in Little Plumstead (site reference 25849, 25852 and 25859), which as above benefit from the connectivity to the Broadland Northway and proximity to development at Broadland Business Park. Site specific evidence documents are being prepared to demonstrate that additional growth in these locations can be accommodated into the existing infrastructure or are able to provide appropriate mitigation to enable growth in these locations, to the benefit of supporting existing facilities and services.

While the broad principles of allocating the majority of development to the Norwich urban area and the fringe parishes is appropriate and should remain as the first tier of the settlement hierarchy. The adopted settlement hierarchy is currently based on an audit of facilities and services which does not provide villages and/or clusters of connected villages with the opportunity to receive additional growth with the potential to provide additional facilities and support to existing infrastructure and services in the area. CODE Development Planners agree with the suggested approach by the council to consider the transport connectivity of areas and recognise the potential benefit and support to local infrastructure that development in village clusters can provide, which is currently restricted and overlooked in the proportion of new homes that are allocated to this tier of the settlement hierarchy.

Therefore, a combination of the traditional and connectivity based approaches are considered to be appropriate to establish the settlement hierarchy, provided that the connectivity tool factors in mitigations that can come forward with development where there is an opportunity to improve the sustainability of settlements. This is combination with an additional development type of allocations for up to 250 new homes in village clusters would help achieve the delivery of the GNLP’s housing needs in a sustainable manner.

Allocating a range of sites across various different scales and locations to ensure that development can come forward early on in the plan period to maintain delivery rates ahead of larger strategic development such as new settlements and urban extensions.

The GNLP 2045 should include allocations across a range of sites and locations to deliver a consistent supply of housing over the whole plan period in order to deliver policy compliant provision of affordable, accessible, specialist and self-build housing. The GNLP 2045 should ensure that there is a suite of allocations (between 100-300 dwellings) which can come forward earlier on in the plan period to enable sites to make a meaningful contribution to meeting local needs while ensuring that there is not an over reliance on larger complex strategic extensions and new settlements that backload delivery to the latter part of the plan.

Following the publication of the revised NPPF in August 2026, Policy S5(1) outlines a number of circumstances where development would be acceptable in principle outside of settlements. This includes in Policy S5(1)(j) where development would address evidenced unmet needs where development is physically well-related to the existing settlement. Given the Greater Norwich authorities are seeking to address their housing need in the new local plan through a growth strategy that includes development types which we suggest is expanded to deal with village clusters as stated elsewhere within our representations, we do not consider that the GNLP 2045 needs to address the first bullet point in Question 11.

We have no particular view on the second bullet point contained within Question 11.

The GNLP 2045 should be informed by robust evidence which assesses the current and projected need for employment sites across the Greater Norwich area for the whole plan period up to 2045. Bullen Group Ltd have submitted land to the west of the A140 (reference 25868) in Horsford Parish which is adjacent to committed commercial development, which provides a logical extension to provide flexible additional commercial uses in a well-connected location to assist in meeting development needs towards the end of the plan period.

Alongside larger commercial growth and allocations, the GNLP 2045 should plan positively to support and maintain the vitality of local communities and stimulate economic growth in the local economy. This should be achieved through identification of opportunities for smaller-scale commercial development and retail development in and adjacent to existing settlements where they can provide local employment opportunities and offer services and facilities which enhance the sustainability of the settlement. Bullen Group Ltd have identified the site west of Holt Road, Horsford (site reference 25860) for this purpose and these sites should be provided with strengthened policy support and allocations to ensure that growth in these areas is delivered quickly alongside any residential development identified within the plan.

Bullen Group Ltd will be providing further evidence, following initial investigations across various disciplines which supports that these sites are accessible, sustainable and suitable for the proposed development types and quantum.