What is a local plan?
Local plans are an essential part of the country’s land use planning system – they help to manage new development responsibly for the benefit of everyone and to make sure development happens in the right places. A local plan sets out a vision for the future growth of an area. It sets out what is going to be developed, where it will happen and how it will be achieved. Once adopted, a local plan is used when decisions on planning applications are made in the area it covers.
Local plans have to tie in with Government policy, along with regional and local strategies for the economy, transport, the environment and other issues. A local plan includes strategic planning policies to guide development, and identifies sites for new homes, jobs and infrastructure.
Who is making this local plan?
The Greater Norwich Local Plan (GNLP) is being produced by Broadland District Council, Norwich City Council and South Norfolk Council working together with Norfolk County Council through the Greater Norwich Development Partnership (GNDP). The Broads Authority is also part of the GNDP but produces a separate local plan.
Why are you making this local plan before the last ones run out?
Plans must be kept up to date and Government suggests a review is required at least every five years. Plans should also look ahead into the future at least 15 years. The current local plans, which include the Joint Core Strategy (JCS) and separate site allocations documents, were adopted at various times between 2011 and 2016. An early review of plans is often beneficial to reflect changing local circumstances or changing national planning policies.
The evidence supporting local plans goes out of date over time and needs reviewing as well. The current timetable is to have the local plan examined by an independent inspector in 2021 and for each local authority to adopt it in 2022. Whereas current plans look to 2026, the new Greater Norwich Local Plan will be to 2038.
What is in the Greater Norwich Local Plan?
The Greater Norwich Local Plan (GNLP) is in two parts - the Strategy and Sites Plan (the South Norfolk Villages Plan will be part of the development plan for Greater Norwich, but is being developed separately). The Strategy outlines the broad approach to housing and jobs growth, along with policies to ensure sustainability, protect our environment and provide infrastructure. The Sites Plan identifies the sites which we propose to allocate to meet housing and employment needs to 2038, as well as the allocations we propose to carry forward from the current Broadland, Norwich and South Norfolk local plans. At this point the Sites Plan excludes villages within South Norfolk which will be addressed through a separate housing sites allocation document and will form part of the development plan for the area.
What about other local plans and neighbourhood plans? What status will they hold?
When adopted, the GNLP will supersede the current JCS and the site allocations plans in each of the three districts, except for the smaller villages in South Norfolk that will be addressed through a new South Norfolk Village Clusters Housing Allocations Local Plan and the Diss, Scole and Burston area, for which a Neighbourhood Plan is being produced which will allocate sites.
The majority of the undeveloped allocations in the existing site allocations plans in Greater Norwich are re-allocated through the GNLP. The GNLP will not replace existing adopted Area Action Plans for Long Stratton, Wymondham and the Old Catton, Sprowston, Rackheath, Thorpe St Andrew Growth Triangle or neighbourhood plans, though in some cases additional allocations are made through the GNLP in these areas.
You have had consultations on the GNLP before. What were they about?
We have been preparing the GNLP since 2016. There have been several public consultations already, asking for comments on the sites we had received and the area-wide policies we wanted to include. Although the consultations are no longer open for comments, you can see the content of the consultations at the links below:
Stage A Regulation 18 Site Proposals and Growth Options (2018)
Stage B Regulation 18 New, Revised and Small Sites Consultation (2018)
Stage C Regulation 18 Draft Strategy and Site Allocations (2020)
All these consultations have been conducted under Regulation 18, the preparation stage of plan making. The comments (known as a representations) we received from these consultations (from members of the public, specialist organisations, town and parish councils, landowners and developers) have helped us to shape the GNLP.
What do the titles ‘Regulation 18’ and ‘Regulation 19’ mean?
The regulation numbers come from the Town and Country Planning (Local Planning) (England) Regulations 2012. This is one of the main laws controlling plan making, which dictates the processes we must follow to make a local plan. We also have to comply with the National Planning Policy Framework (NPPF) which sets out the government’s planning policies for England and how these are expected to be applied.
Where are we now and how do I comment?
We are now at Regulation 19, the publication stage of plan making, when we need to publish the version of the plan that we are going to submit to the Inspector. This gives you the chance to submit a representation if you think the plan is ‘unsound’ or does not comply with planning legislation (see below for details). Therefore, this is not a typical ‘consultation’. The form we have provided for your comments is structured around the regulations and we have provided some guidance to explain the form. Any anonymous submissions, or representations which make offensive comments will be removed. All other representations will be submitted for the Inspector to consider. Only those representations received by the deadline will be taken into account by the Inspector as part of the examination. The form allows you to request to ‘attend’ the examination (see Covid-19 section below), or alternatively to make your representations on paper only. The Inspector will consider all representations made on the publication version of the plan, regardless of whether or not those making the representations are invited to appear at a hearing session.
Why must I give my name? What about data protection?
It is important to comply with data protection responsibilities under the General Data Protection Regulations (GDPR) when exercising planning functions. Representations at Regulation 19 must be ‘made available’ in line with the regulations. This includes publication on the GNLP’s website, and we must make the names of anyone who comments at this stage available to the Planning Inspector. However, the address or other contact details of those who have made representations will not be published, but will be used by the Programme Officer to contact participants and administer the examination. In some cases, in order to run virtual events by means of video or telephone conference, the Planning Inspectorate may need to know the e-mail address and/or telephone number of those making representations.
What constitutes ‘legal and procedural requirements’?
The examiner will consider the first aspect, the legal requirements, as soon as the examination has commenced. This includes the Duty to Cooperate. The Examiner will need to be satisfied that, within reason, all the various bodies have been given an adequate opportunity to influence the plan and have not just been consulted on it.
The legislative requirements for plan making are contained in the Planning and Compulsory Purchase Act 2004 (as amended) and the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended).
What constitutes ‘soundness’ in local plans at Reg 19?
To be sound, plans need to be:
- Positively prepared: The plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent which achieving sustainable development.
- Justified: The plan should be the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence.
- Effective: The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
- Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies in the National Policy Framework.
What happens next?
After the publication period, we collect the representations received and submit them with the GNLP as well as the Sustainability Appraisal report, Habitat Regulations Assessments, the Consultation Statement, policies map and other supporting documents to the Secretary of State who will appoint a Planning Inspector to carry out an independent examination. The Planning Inspector’s first task is to consider whether the GNLP meets legal and procedural requirement and whether it is sound. At the same time, the Greater Norwich Development Partnership (GNDP) will appoint a Programme Officer to administer the examination. This role acts as an intermediary between the GNDP, the Inspector, and the people wishing to contribute to the examination. The examination is likely to happen between November and December 2021.
Before the hearing sessions take place, the appointed Inspector will issue a written guidance note to explain the procedures to be followed, and will publish the matters, issues and questions to be discussed.
How will the local plan process be affected by Coronavirus (Covid 19)?
In order to limit the spread of the Coronavirus (Covid-19), we are following Government advice on physical distancing and working from home as far as possible. We will need to be flexible as the situation changes. In addition, we need to take our lead from the Planning Inspectorate, which has published Guidance on How to Take Part in a Planning Inspectorate Virtual Event. Please see the weblink below for further information Planning Inspectorate virtual events: guide to participating - GOV.UK (www.gov.uk)
What needs to be done to formally adopt a local plan?
Once the examination process is complete, adoption is the final stage of putting a local plan in place. This requires confirmation by a full meeting of the local planning authority. On adopting a local plan, the local planning authority has to make publicly available a copy of the plan, an adoption statement and Sustainability Appraisal.
While the local planning authority is not legally required to adopt its local plan following examination, it will have been through a significant process locally to engage communities and other interested bodies in discussions about the future of the area, and it is to be expected that the authority will proceed quickly with adopting a plan that has been found sound. We expect the GNLP to be adopted by the partner authorities around September 2022.
Why do we need more housing?
More people move into the Greater Norwich area than move out. Additionally, people are living longer, there is a tendency for households to get smaller and young people are finding it increasingly difficult to establish their own home; so even if there were no population growth there is a need for more housing. If the housing that is needed is not planned for, the supply of homes will not meet demand and upward pressure on house prices and rents will make it even more difficult for people to get a home.
Housing is also linked to how the local economy performs. If there are not enough homes, businesses will suffer from a shortage of customers and employees. Therefore, a housing shortage could stop companies expanding and prevent new businesses from setting up.
Without a clear and detailed local plan to manage growth there is also a greater risk that housing developments will be allowed in unplanned and less suitable locations. Without an up to date local plan in place, national planning policy favours allowing development, potentially in locations that would not otherwise be preferred.
How much housing is being planned?
The GNLP covers the period 2018 – 2038. The Government publishes a standard methodology for determining housing need that it expects councils to follow. This method suggests a minimum local housing need of around 40,500 homes in the period 2018 to 2038. Also, to help determine housing needs in more detail, consultants undertook a Strategic Housing Market Assessment (SHMA) covering Central Norfolk – not only the Greater Norwich area but North Norfolk and Breckland councils as well.
There are lots of unbuilt sites with allocations from the last local plan, or planning permission. Collectively we call these already-planned homes ‘commitment’. Taking into account homes built since 2018 and existing commitment (including increased numbers on some existing sites) new allocations will need to provide at least 10,704 homes.
The overall housing figure in the draft plan of 49,492 homes includes a 22% buffer to ensure delivery, to accommodate the higher growth rates indicated by the government and to meet local housing need.
Does the Reg 19 GNLP contain all the new housing sites?
In addition to the site allocations in this plan, a minimum of 1,200 new homes will be allocated in the South Norfolk Village Clusters Housing Site Allocations document and 250 will be provided through allocations in the Diss and area Neighbourhood Plan.
Can’t you build a new settlement, and put all the growth there?
A new town or village would require a lot of investment in new roads, schools, shops, and doctors’ surgeries, amongst other things. New towns take many years to get started, so would only account for some of the growth needed in this plan period to 2038. However, it is recognised that one or more new settlements will be required in the longer term. Three sites for new settlements have already been proposed (at Honingham Thorpe, Silfield, and Hethel). These will be investigated along with other potential locations in the next plan, and comprehensive analysis of options will begin in 2021.
What about future employment?
In terms of employment, the target is 33,000 additional jobs from 2018 to 2038. Large areas of employment land are safeguarded in the GNLP, and additional employment sites totalling around 360 hectares (in a range of sizes and locations) are allocated for employment. Due to the changing nature of employment, this amount of land is considered to be more than enough to provide for expected and promoted growth. However, smaller scale employment sites are allowed for through ‘windfall’ sites, which come forward outside the local plan process.
Where are all the jobs coming from?
The Greater Norwich economy has grown significantly in recent years and has further strong growth potential. Between 2011-2018 total employment is estimated to have grown by 14.5% (29,100 jobs). Amongst the sectors that have grown are: accommodation and food services; IT and communications; professional, scientific and technical activities; education; and, health and social work. The outlook for the local economy is extremely positive, but not all sectors have grown: agriculture, manufacturing and insurance have all seen a fall in employment levels.
Over the next few years, the potential for growth will be enhanced by the recent opening of the Broadland Northway and planned improvements to the A47 and train services. The Greater Norwich authorities work with the New Anglia Local Enterprise Partnership (LEP) to help shape the economic growth and development of the area, and Greater Norwich has become one of the key ‘engines of growth’ in the region.
Our economic advisers believe that the economy can continue to grow strongly, particularly in ‘high value’ sectors. This is reinforced by the LEP’s industrial and economic strategies and other plans to attract growth in high tech and knowledge-based industries such as life sciences, biotechnology, agri-tech, food and drink, creative and digital industries, and high-value engineering. Growth in these industries mean that Greater Norwich is well placed to play a role in the development of a post carbon economy, both locally and more widely.
This growth is in addition to other locally important industries such as retail, tourism and financial services. The GNLP will support the creation of a range of employment opportunities, including high-quality, high-value jobs as well as local employment.
What will be the impact on the countryside?
The strategy maximises development on ‘brownfield’ sites, but not all new development can be accommodated on previously used land. This is the reality of planning for enough jobs and homes, but nevertheless, development can be planned so that it minimises impact on countryside landscapes. The local plan can do this by choosing development sites next to existing development, and not in remote open countryside. The local plan will also take care to avoid development on sites that are home to protected landscape, plants and wildlife.
It is also important that people have access to open green space. Residential development will be required to make appropriate provision for this. For example, as part of large-scale development proposals new country parks are proposed within the growth triangle around Beeston and Rackheath and at Horsford. Smaller developments will also be expected to contribute to overall provision of ‘green infrastructure’. Collectively, such projects will provide new wildlife habitats, open spaces for people to visit, or landscaping to improve countryside views. This will contribute to this plan’s new requirement that development must enhance the environment through “biodiversity net gain”.
How will infrastructure be improved to support new growth?
New development in the local plan will be supported by new and improved infrastructure, including schools, health facilities, roads, public transport and other community facilities. The Greater Norwich authorities are working with infrastructure providers to identify the likely infrastructure requirements to support the GNLP. Planning flexibly for a changing world will also mean that we are able to adapt to changes that are difficult to predict at present (for example, digital communication improvements and increasing use of electric vehicles).
Alongside the local plan is the Greater Norwich Infrastructure Plan (GNIP). Updated yearly, the GNIP covers education, transport, community and green infrastructure projects which will support the development scheduled to happen in the area. By working together, the Greater Norwich authorities have a stronger voice when negotiating with government. For example, working in partnership helped make the case for dualling the A11, constructing the Broadland Northway, and for planning improvements at the Thickthorn junction to link the A11 and A47.
The City Deal, agreed with government in 2013, gives the Greater Norwich authorities the ability to borrow up to £80 million at a reduced rate from the Public Works Loan Board. Within that, Greater Norwich authorities negotiated £20 million of borrowing for short-term loans to developers to provide infrastructure, known as the Local Infrastructure Fund. The remaining loan facility was split as a £40 million contribution to the Broadland Northway, with approximately £10 million set aside towards the Long Stratton by-pass and £10 million for works in the City Centre.
Funding for infrastructure also currently comes from Community Infrastructure Levy (CIL). Since 2014, the Greater Norwich Growth Board (GNGB) has overseen decisions on investment to support infrastructure and has contributed £13.6m from their pooled CIL towards projects that are strategically supporting growth. The Greater Norwich authorities pool CIL money together to deliver infrastructure improvements across the area in a co-ordinated way, which gives a better outcome for our residents.
Norfolk County Council has received formal confirmation from the Department of Transport (Dft) that a joint bid with Norwich City Council and district authorities of Broadland and South Norfolk has been accepted, triggering a combined investment in local infrastructure totalling £59m from the Transforming Cities Fund.
The funding will deliver vital infrastructure improvements to improve travel times for bus passengers on the most popular transit routes, giving city bus operator, First Eastern Counties, confidence to invest a further £18m in its fleet and local services.
All projects will be delivered through the Transport for Norwich partnership, with an additional £9m being allocated from local council and private contributions.
How will the transport system cope with growth?
In order to reduce environmental impact including contributions to climate change and air pollution, it is important that locations chosen for growth allow the opportunity to reduce the need to travel, promote walking and cycling and make best use of existing transport networks and planned improvements. As well as the work being done for the local plan, Norfolk County Council is looking at wider issues on our transport networks and is undertaking a review of the transport strategy for the Norwich area and network improvement strategies for market towns. These strategies are being developed alongside the emerging growth plans and look at the opportunities for wider improvements to the transport system.
There are not enough GPs at the local medical centre – how will they cope if more houses are built?
The NHS has programmes in place to address the current pressures on healthcare services. This includes new ways of working, use of new technology, and of course recruiting more doctors. Locally too, NHS organisations under the Norfolk and Waveney Sustainability and Transformation Partnership (STP), are finding ways to help keep people well, expand healthcare services, and to ensure services are better coordinated.
The Norfolk Health Protocol is a collaboration and engagement protocol between local planning authorities, the Norfolk and Waveney STP, clinical commissioning groups, health partners and Public Health Norfolk which seeks to plan for future growth and to promote wellbeing. By working together with local planning authorities NHS organisations can be clear about the locations and timing of new housing and jobs, and this enables informed decision-making about how and when to expand health facilities.
What evidence have you based your decisions on?
We have undertaken a wide range of evidence gathering, including evidence on housing need, economic growth, flood risk, caravans and houseboats needs, environmental assessments, green infrastructure, a power study, a water cycle study and a development viability study. We have asked for views from a variety of consultees on the suitability of sites proposed to us and have had meetings and workshops with stakeholders including transport, water, electricity, health and education providers, as well as developers. These are summarised into a statement of consultation, which we will also publish on our website. A sustainability appraisal, equalities impact assessment and statement of duty to cooperate are important parts of plan production, and these are published alongside the local plan. This evidence base is available on our website.
What does the Sustainability Appraisal (SA) Report Include?
The SA is an appraisal of the economic, environmental and social effects of a plan from the outset of the preparation process to allow decisions to be made that accord with sustainable development. We commissioned Lepus, a sustainability appraisal specialist, to conduct the appraisal and produce the findings in reports. Over an extended period, these findings contributed to the development of policies for sites and the strategic policies covering the whole plan area.
What is the Habitat Regulation Assessment (HRA)?
The Landscape Partnership was commissioned by the Greater Norwich Development Partnership to undertake a Habitat Regulations Assessment (HRA) of the Greater Norwich Local Plan (GNLP).
The objectives of the study were to identify European sites within and near the Greater Norwich Local Plan Area along with their qualifying features and to determine if these would be directly or indirectly affected by the Local Plan. Overall, the aim was to determine whether the plan would have a likely significant effect upon the integrity of any European site. The focus of the assessment is on direct and indirect effects of proposed housing although other matters such as transport and employment land were also assessed.
Impacts considered for the proposed distribution of housing include water cycles (use and disposal), air pollution especially from new roads and an increase or change in the pattern of distribution of road users, water pollution or enrichment resulting from discharge to water, and the impacts of increased visitors to protected habitat sites. In addition to considering the potential impacts of the growth proposed by the GNLP alone, a number of other plans or projects were identified that could have in-combination impacts.
What is the (HELAA) Housing Land Availability Assessment?
The purpose of this Housing and Economic Land Availability Assessment (HELAA) is to provide evidence on the range and extent of land which could be considered for development to meet the objectively assessed need (OAN) for housing and employment up to 2038 for the Greater Norwich authorities of Broadland, Norwich and South Norfolk. The HELAA is a key evidence document which supports the plan making process.
The inclusion of a site as potentially suitable for development within the HELAA DOES NOT confer any planning status on that site, or any commitment that it will be brought forward for development. In addition, sites excluded from the HELAA assessment can still be subject to more detailed site assessment and be considered for allocation through the local plan process. For more information see Site Assessment Booklets for each settlement.
What are the Site Assessment Booklets?
The Site assessment booklets show how we have assessed all the sites put forward and contain comments from key bodies with responsibilities for highways, education, conservation, flooding, minerals and waste. The booklets also consider all the public comments received from the various consultations held at Reg. 18 and the findings from other evidence documents and recommendations such as from the Sustainability Appraisal Report for the GNLP. The booklets are organised by settlement or village cluster, and illustrate not just the site assessment process but also how we have arrived at many of the site policies.
What is the Equalities Impact Assessment?
This is a process of considering the impact of our policies on various groups of people with ‘protected characteristics’, as defined by the Equalities Act 2010. The Greater Norwich authorities have a Public Sector Equality Duty to ensure that we play our part in making society fairer by tackling discrimination and providing equality of opportunity for all. We have produced a report to show how we have met this duty through Equalities Impact Assessment.
What is the Statement of Consultation?
This statement sets out:
- which bodies and persons were invited to make representations under Regulation 18,
- how those bodies and persons were invited to make such representations,
- a summary of the main issues raised by those representations, and
- how those main issues have been addressed in the plan
GNLP officer responses to significant policy content questions asked during the Regulation 19 Publication period.
These questions/information requests and responses are provided as they may assist people making representations. Please note that the questions and responses have been edited for clarity.
Table 6 (under Housing Growth Needs) does not explain the breakdown of new allocations does not differentiate between the 10% element above need, which and the additional uplift in numbers included in the plan as a consequence of the 2018 ONS household projections. It would be most useful for us to have the breakdown of allocations separated in to these 2 elements so that the sites (including brownfield sites like Colmans) identified to accommodate the additional 5,000 (or so) houses that have been included to accommodate the enhanced growth which might possibly occur if the 2018 ONS projections prove to be accurate are clearly differentiated from the 4,500 approx. (10%) uplift.
The GNLP housing requirement of around 41,500 homes is derived from the standard methodology and 2014-based household projections. The Plan allocates enough sites to provide a “delivery buffer” of approximately 10%. The delivery buffer is included to counteract any fallout of planning permissions or allocations that do not get built in the period up to 2038. In addition, the Plan identifies further provision of around 5,000 dwellings, to provide the opportunity to accommodate the higher 2018-based household projections should these materialise. This results in a total plan provision of around 49,500 homes.
While these are the steps we have taken to derive a total plan provision there is no differentiation of the allocations or allowances in terms of their ability to be delivered. No allocations or allowances are prioritised over any others; no allocations are identified as providing a buffer.
Similarly, the provision to address the additional 5,000 homes is incorporated within the overall policy and not differentiated. It was made up of sites previously identified in the Reg 18 consultation, through uplift on preferred sites and sites that had been identified as reasonable alternatives; plus, small sites delivered through policy 7.5 and an element of windfall. The breakdown for the additional growth is set out on page 15 of the GNDP Board agenda of 7 December 2020.