GNLP 2045 Regulation 20 Scoping Consultation

The Infrastructure Delivery Plan in support of the preparation of the GNLP 2045, should consider a joined-up approach, which considers how growth in particular locations would have impacts on the same physical and social infrastructure. This is in order to establish a holistic approach which pools contributions across various sites to ensure that funding is distributed fairly across sites to enable infrastructure delivery to be well co-ordinated in support of growth.

To improve accessibility in the GNLP 2045, new development should be focused in sustainable locations across the Greater Norwich area such as the sites put forward by Bullen Group Ltd in the fringe parish of Drayton and village clusters of Horsford and Little Plumstead which benefit from public transport connections into Norwich alongside wider road connections to the Broadland Northway/A1270.

National planning policy and legislation already establishes a high bar for development (such as the provisions of biodiversity net gain) and therefore it is considered that time should be given to work through the allocations and delivery of the growth strategy within the GNLP 2045 (particularly in light of the previous assumed delivery timescales under the adopted GNLP), before any increased standards are introduced through local planning policy. In relation to bullet point three, we consider that the current approach to green infrastructure provision on sites (within Policy 3 of the GNLP) which incorporates each development site’s SANG provision is working effectively and should therefore be retained within the new local plan.

Bullen Group Ltd are supportive of promoting high quality design which promotes sustainability and remains mindful of the natural and historical context. However, both are dealt with sufficiently through the revised NPPF, August 2026 (sections 19 and 20) for it not to be necessary to have separate policies in the GNLP 2045. It should be recognised that in the context of the housing requirement and availability of land in the area, that greenfield, agricultural land will be required to deliver growth in the district and therefore the alteration of, the rarity of and the importance of such views and landscape character on the edge of settlements should be considered in the wider context of the district and the local housing needs and therefore not preclude development coming forward in these areas.

Bullen Group Ltd are supportive of the topics that the GNLP 2045 has identified as needing evidence studies and consider that these should be prepared and published into the public domain as soon as they are available and no later than the Regulation 23 draft of the local plan to enable consideration alongside the policies and supporting text within the local plan. The Greater Norwich Infrastructure Needs Study should include consideration of both physical and social infrastructure to enable a clear understanding of development needs across the plan area (currently table 1 of section 11 of the Scoping Consultation only refers to ‘potentially’ including consideration of education, health and community facilities). Strategic Transport modelling should also include use of the Department for Transport’s connectivity tool to identify locations for growth in the context of the transport network.

In addition to the evidence commissioned to date, in light of the publication of the revised NPPF and the Scoping Consultation, further evidence and justification should be undertaken to establish the settlement hierarchy through a combination of an audit of settlements and the connectivity of settlements and consideration of planned/committed growth and developments needs to inform the location of new residential and commercial allocations.

In advance of the Regulation 23 Consultation, the GNLP 2045 should publish the Housing and Economic Land Availability Assessment of the sites submitted to date into the Call for Sites, inviting comments and responses to the matters assessed in accordance with planning practice guidance under the new local plan making system (Stage 3: Determining your draft allocations, Planning Practice Guidance, March 2026).

Bullen Group Ltd are supportive of the approach taken to date by the GNLP 2045 which aligns with the Planning Practice Guidance (March 2026) referenced elsewhere in our representations, which is set out under the new local plan making system to ensure that sites put forward are not sieved out too early in the process. Under Stage 2: Assessing sites, it states that, “You will need to include strong rationale in your evidence for any sites you decide to sift out at this stage.” It goes on to state, “Where sites might be suitable with certain mitigations, you should record these along with the suggested mitigation and take these forward into the next step of the process”. Under Stage 3: Determining your draft allocations it states, “Determining your draft allocations can be an iterative process. It’s likely you’ll revisit different stages and update previous assessments, particularly following consultation and engagement with stakeholders. You’ll refine your assessment and draft allocations, based on any new information you learn."