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27th February 2018
Dear CPRE Norfolk members and supporters who live in Broadland, South Norfolk and Norwich
We are writing with regard to the recently launched consultation for the new Greater Norwich Local Plan (GNLP) which runs until 5.00pm on 15th March 2018 (now extended to 22nd March). We hope you will respond to this consultation as this is your opportunity to influence the future development of Broadland, South Norfolk and Norwich up to 2036. Topics include housing, infrastructure, the environment and the economy. The consultation documentation and how to respond are available online at: http://www.gnlp.org.uk/
Whilst you will have your own views on these topics, we thought it would be useful to circulate CPRE Norfolk’s position on a number of key points. We have met with members of the GNDP team on several occasions and are pleased to see that some of our thinking has emerged in the consultation document, but need continued pressure if any of these ideas are to be included in the final GNLP.
CPRE Norfolk wants to see sites allocated for housing in the existing plan (the Joint Core Strategy or JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. It will not be possible to prevent new sites being included in the plan, but we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the next 20 years. Here is a summary of our position relating to specific questions in the GNLP consultation.
- Question 4, Phasing. The problem with the consultation is that phasing is not specifically offered as an option within the documentation. Therefore, answers to questions 4, 5 and 6 will be crucial in this regard, in order that phasing is considered. It will take almost 24 years before the existing allocation of 35,665 houses is used up. In these circumstances we consider that there is no reason why new sites allocated in the GNLP should not be phased. They would then be available for development should building rates increase, but if house completions remain at existing rates these sites could stay on a reserve list and valuable countryside would be protected. We will be making this case in our answer to question 4.
- Question 5. We will be saying that we welcome the fact that windfalls will be counted towards the delivery buffer, but we note that when windfalls are added in, the buffer rises to 24%. Therefore, even allowing for NPPF requirements, this figure represents a 4% over-supply. For the reasons stated in our answer to question 4, this additional buffer allocation should be phased.
- Question 6. We do not agree that windfalls should be in addition to the 7,200 homes. The GNLP Authorities have to consider a 20% buffer because they failed to meet housing delivery targets set in the JCS. This has resulted in the absurd situation where because targets were set at too high a level in the past, they have to be increased to an even higher level in the future. Given that the likely rate of house completions will continue at around 1,500 per annum and current commitments will be sufficient to cover this, there really is no need for a 20% buffer.
- Question 9. CPRE Norfolk strongly favours option 1: concentration close to Norwich. Once again we will repeat the point that if new sites are phased, the development outlined in the growth options will not be required if build rates remain as at present.
- Question 10. The concentration option 1 would require the least amount of new infrastructure: another reason why we support this approach.
- Questions 11 and 12. Given the clear benefits of urban concentration, in terms of the environment, traffic and transport, housing being close to employment and services, and for the countryside, we will not be supporting any of the other strategic growth options. It is also worth repeating that if phasing is adopted, newly allocated sites will not need to be developed and therefore there is no need to build a new settlement. Furthermore, with phasing, the concentration option if chosen, would still not see the need for any new sites in parishes close to Norwich.
- Question 13. CPRE supports a Green Belt for Norwich. The consultation document contains three options for a green belt for Norwich. The establishment of a Green Belt in whatever form it would eventually take, in combination with a growth option which concentrates development in and close to Norwich, represents the most sustainable form of development. We are currently developing detailed proposals for a version of the “green wedges” option.
- Questions 23, 24 and 25. CPRE Norfolk considers it extremely important to maintain the existing JCS settlement hierarchy, which is almost the same as option SH1 on pages 54-55 of the consultation document. This hierarchy offers maximum protection to rural areas from estate development.
- Question 26. In the context of our support for a concentrated urban option, we strongly favour retention of the Norwich Policy Area. The existence of the Rural Policy Area has proved very beneficial in preventing large-scale estate development in rural parishes. This is another good reason to retain the present system, where the area is divided into the NPA and the RPA.
The consultation document covers many other aspects. This communication is intended to offer some guidance, as this is the best opportunity we have for our voices to be heard in helping to determine future housing in Greater Norwich and the remainder of Broadland and South Norfolk up to 2036. Do contact us if you wish to discuss these points further, or indeed other aspects of the GNLP consultation.
David Hook, Chair, Vision for Norfolk Committee, CPRE Norfolk
Michael Rayner, Planning Campaigns Consultant, CPRE Norfolk
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