GNLP 2045 Regulation 20 Scoping Consultation

Attention is drawn to the fact that this representation to the Greater Norwich Scoping Consultation follows representations submitted during the Council’s previous ‘Call for Sites’ exercise (Ipswich Council ‘Call for Sites’ representation form ID refs. 25914, 25927, & 25911, all of which should be read in conjunction with this submission.

The delivery of new homes nationally is an important material consideration when preparing a new Local Plan. The National Planning Policy Framework (NPPF) places a strong emphasis on the provision of residential accommodation stating that housing applications should be considered in the context of the presumption in favour of sustainable development.
Currently, the UK has a significant housing crisis. The Government is proposing to address this issue through new legislation and guidance to make more land available for homes in the right places, by amongst other things, encouraging higher residential densities, where appropriate.

‘Policy HO4 – Land for Strategic Site Development of the National Planning Policy Framework (NPPF) notes the following:
1. The development plan should, where appropriate, identify suitable locations for strategic sites for housing-led development (such as new settlements, new urban quarters or significant extensions to existing settlements). These locations should:

a. Be capable of being supported by the necessary infrastructure and facilities at appropriate points in the development’s delivery (including complying with relevant aspects of policies TR1 and TR3, and taking advantage of any opportunities presented by existing or planned infrastructure investment);
b. Be capable of supporting a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access by sustainable transport modes; and
c. Address strategic environmental opportunities and safeguards, including those set out in Local Nature Recovery Strategies’.

This guidance is accompanied by guidance set out in the national Planning Practice Guidance (PPG) section on Housing and Economic Land Availability Assessments, which states:

‘What is the purpose of the assessment of land availability?
An assessment of land availability identifies a future supply of land which is suitable, available and achievable for housing and economic development uses over the plan period. The assessment is an important source of evidence to inform plan-making and decision-taking, and the identification of a 5-year supply of housing land. It can also inform as well as make use of sites in brownfield registers’
[Paragraph 001 Reference ID: 3-001-20190722]
‘What sizes of site or broad locations can be considered for assessment?
Plan-makers will need to assess a range of different site sizes from small-scale sites to opportunities for large-scale developments such as village and town extensions and new settlements where appropriate’. [Paragraph 009 Reference ID 3-009-20190722]

It is evident that one of the most significant and biggest challenges facing the Plan area, its local communities and local businesses is the fact that an insufficient amount of new additional and affordable housing of a variety of tenures is being delivered across the district.

As noted above, it is evident that there is a shortage of new housing within Norwich. The emerging Local Plan should be prepared in such a way to ensure a sufficient number of housing can be delivered to meet the shortfall in housing delivery. It is recognised that large parts of the Ipswich borough are rural in nature and character which are not served by public transport. Moreover, there are areas of the city which are recognised as high-value townscapes and identified as a variety of environmental and townscape designations, where proposals for new development are controlled and managed. These include areas of the town designated as Conservation Areas and buildings and structures identified as Listed Buildings and Scheduled Ancient Monuments (SAMs).

N/A - There appears to be enough sufficient and wide-ranging baseline data used as the Greater Norwich Authority has adopted its SWOT analysis. ahead of the preparation of the Greater Norwich Plan. All relevant Strengths, Weaknesses, Opportunities and Threats appear to have been considered.

N/A - There appears to be enough sufficient and wide-ranging baseline data used as the Greater Norwich Authority has adopted its SWOT analysis. ahead of the preparation of the Greater Norwich Plan.

The proposed broad structure of the emerging Greater Norwich Local Plan is agreed to in principle.

Development of brownfield sites should be prioritised ahead of greenfield sites in accordance with exiting planning policies and guidance.

Development of the three site locations within the built up area of Norwich (Land at Dereham Road and Heigham Road, Call for Sites 2026 ref. 25927), and along key road corridors along the A11 (Land at the Former GPSS Site, Land South of the Hethersett Bypass (A11), Norfolk - Call for Sites 2026 ref. 25911) and the A140 (Land at Plane View, Holt Road, Norwich, Call for Sites ref. 25914) will further strengthen Norwich's strategic importance, enabling future residents to access jobs, assist with sustaining the existing and future local retail/leisure and community assets offer, while supporting the local economy.

N/A - The existing settlement hierarchy is considered appropriate and in accordance with national planning policies and guidance. Development of all types and scale should continue to be directed towards the built-up area of Norwich and its surrounding area, and new commercial development should be located along key strategic road corridors, including the A11 and A140 (Holt Road, Norwich)

Attention is drawn to the fact that this representation to the Greater Norwich Local Plan Scoping Consultation follows representations submitted during the previous ‘Call for Sites’ exercise (‘Call for Sites’ representation form ID ref. 25927), which should be read in conjunction with this submission.

The delivery of new homes nationally is an important material consideration when preparing a new Local Plan. The National Planning Policy Framework (NPPF) places a strong emphasis on the provision of residential accommodation stating that housing applications should be considered in the context of the presumption in favour of sustainable development.
Currently, the UK has a significant housing crisis. The Government is proposing to address this issue through new legislation and guidance to make more land available for homes in the right places, by amongst other things, encouraging higher residential densities, where appropriate.

‘Policy HO4 – Land for Strategic Site Development of the National Planning Policy Framework (NPPF) notes the following:
1. The development plan should, where appropriate, identify suitable locations for strategic sites for housing-led development (such as new settlements, new urban quarters or significant extensions to existing settlements). These locations should:

a. Be capable of being supported by the necessary infrastructure and facilities at appropriate points in the development’s delivery (including complying with relevant aspects of policies TR1 and TR3, and taking advantage of any opportunities presented by existing or planned infrastructure investment);
b. Be capable of supporting a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access by sustainable transport modes; and
c. Address strategic environmental opportunities and safeguards, including those set out in Local Nature Recovery Strategies’.

This guidance is accompanied by guidance set out in the national Planning Practice Guidance (PPG) section on Housing and Economic Land Availability Assessments, which states:

‘What is the purpose of the assessment of land availability?
An assessment of land availability identifies a future supply of land which is suitable, available and achievable for housing and economic development uses over the plan period. The assessment is an important source of evidence to inform plan-making and decision-taking, and the identification of a 5-year supply of housing land. It can also inform as well as make use of sites in brownfield registers’
[Paragraph 001 Reference ID: 3-001-20190722]
‘What sizes of site or broad locations can be considered for assessment?
Plan-makers will need to assess a range of different site sizes from small-scale sites to opportunities for large-scale developments such as village and town extensions and new settlements where appropriate’. [Paragraph 009 Reference ID 3-009-20190722]

It is evident that one of the most significant and biggest challenges facing the Greater Norwich Plan area, including its local communities and local businesses, is the fact that an insufficient amount of new additional and affordable housing of a variety of tenures is being delivered across the district.

It is evident that there is a shortage of new housing within Norwich. The emerging Local Plan should be prepared in such a way to ensure a sufficient number of housing can be delivered to meet the shortfall in housing delivery. It is recognised that large parts of the Greater Norwich area are rural in nature and character which are not served by public transport. Moreover, there are areas of the Plan area which are recognised as high-value townscapes and landscapes and identified as a variety of environmental and townscape designations, where proposals for new development are controlled and managed. These include areas of the town designated as Conservation Areas and buildings and structures identified as Listed Buildings and Scheduled Ancient Monuments (SAMs).

The allocation of Land land at Dereham Road and Heigham Road for an appropriate scale and car free residential development, as a logical infill development can help meet the local housing need and address acute affordability issues (including if / as necessary, in Norwich and the wider area), while also locating development outside of sensitive national environmental designated areas providing enhanced transport modes/Active Travel options).

N/A

N/A – It is considered that the existing local plan policies concerning housing outside settlement limits, including self-build and custom build housing, conversions, etc. should be retained to restrict residential development in the countryside where possible.