National planning policy
2.1 The Government published the National Planning Policy Framework (NPPF) in March 2012 which simplifies national planning policy and which supersedes all previous planning policy statements. The NPPF is part of a wider series of changes to the planning system that the government is introducing to both streamline and simplify the planning process and enable local communities and neighbourhoods to become more fully involved in it. These include the Localism Act (which provides for the abolition of regional spatial strategies and the housing growth and jobs targets contained within these plans), proposed amendments to the General Permitted Development Order to allow additional types of development and changes of use without the need to apply for permission. Alongside the NPPF the government has also published a new national policy statement Planning policy for traveller sites (2012)
2.2 The NPPF is strongly pro-development, and creates a presumption in favour of sustainable development. Local plans are considered to be the key to delivering sustainable development, and they must seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development. Local planning authorities are required to prepare local plans on the basis that objectively assessed development needs should be met, with sufficient flexibility to respond to rapid shifts in demand or other economic changes. Local plans should be aspirational but realistic.
2.3 Key NPPF requirements that are particularly relevant to this Site allocations plan are that local plans should:
allocate sites to promote development and flexible use of land, bringing forward new land where necessary, and provide detail on the form, scale, access and quantum of development where appropriate;
- deliver a wide choice of high quality homes that people want and need, and increase the supply of housing;
- create sustainable, inclusive and mixed communities, including through the regeneration and renewal of areas of poor housing;
- plan proactively to meet the development needs of business and support an economy fit for the 21st century;
- promote the vitality and viability of town centres, and meet the needs of consumers for high quality and accessible retail services; and
- ensure viability and deliverability of development.
2.4 The Government recently published the National Planning Policy Guidance (NPPG, March 2014) which provides guidance to local authorities and developers on interpretation of the NPPF.
2.5 The requirement to identify and maintain a rolling five year supply of deliverable housing sites and a longer-term supply of developable sites is retained from previous government guidance (Planning Policy Statement 3: Housing), as are its key tools and mechanisms to assess the local need for market and affordable housing and to calculate the sufficiency of the housing supply and delivery over time. When calculating this five year supply on an annual basis the council will normally seek to identify an additional buffer of 5% to ensure choice and competition in the market for land, in accordance with advice in the NPPF.
2.6 Strategic housing land availability assessments (SHLAAs), strategic housing market assessments (SHMAs) and housing trajectories within monitoring reports continue to be a key part of the council’s evidence base, both to monitor the implementation of housing policies and allocations in this plan and other local plans and to ensure that the delivery of new housing is keeping pace with plan requirements and meeting identified needs. The NPPF emphasises that the housing supply should come in the main from identifiable sites in the short and medium term and identified broad locations in the longer term. Windfall sites should not be allowed for in the first ten years of housing supply unless there is compelling evidence to show that specific sites cannot be identified.
2.7 National minimum density standards for housing development do not appear in the NPPF: instead local planning authorities are advised to “set out their own approach to housing density to reflect local circumstances”. The re-use for residential purposes of empty housing and other buildings is strongly supported (making use of empty homes strategies to identify opportunities and using compulsory purchase powers to acquire property where necessary).
2.8 The delivery of a wide choice of quality homes requires local planning authorities to plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community. Local planning authorities should identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand. In relation to affordable housing they should set policies for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified. Site specific policies for housing sites allocated in this plan require compliance with policy 4 of the adopted JCS and its affordable housing requirement of up to 33%, a target informed by evidence of affordable housing need in the greater Norwich area taking account of the economics of provision. Additionally particular sites in the plan make provision for family housing (for example in the NCCAAP area) where a need has been identified.
2.9 Planning positively and strategically to support business, ensuring an adequate supply of land and premises for economic growth and promoting inward investment and innovation (particularly in key sectors and clusters) are emphasised in the NPPF. The guidance advises against long term protection of employment allocations stating that “applications for alternative uses of designated land or buildings should be treated on their merits having regard to market signals such as land prices and housing affordability, and set out a clear strategy and the relative need for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities”. Allocation of land for development in this plan must take account of the strategic longer term needs and priorities in the JCS, including the need to support significant levels of job growth through identifying business development opportunities and (in particular) by retaining employment land for its designated purpose (JCS policy 5).
2.10 Evidence from the Greater Norwich gypsies and travellers accommodation assessment (published August 2012) suggests an immediate requirement in Norwich between 2011 and 2016 for a maximum of 11 additional pitches. This is part of an overall five year requirement across greater Norwich for 51 pitches, the remainder being distributed between Broadland and South Norfolk. Three pitches have already been provided in Norwich so the net additional requirement is 8 pitches to 2016. There is likely to be an on-going requirement for up to 30 additional pitches every five years in the greater Norwich area over the remainder of the plan period (i.e. a total of 60 additional pitches from 2016 to 2026), which equates to an additional 13 pitches in Norwich city (based on the same geographical distribution as the need to 2016), resulting in a total need for 21 pitches to 2026. The report indicates no requirement for additional plots for travelling showpeople.
2.11 Policy DM14 in the DM policies plan sets out the council’s approach to this issue. The policy states that the existing gypsy and traveller site at Swanton Road and the travelling showpeople’s site at Hooper Lane will be retained and reserved for those purposes, and that proposals for their upgrading over the plan period will be permitted where in accordance with other plan policies. In addition, the policy commits the council to meeting the identified need for 21 additional pitches to 2026, through grant applications in 2014 which may meet some or all of this need. However, if it is not possible to identify sites capable of meeting this need, the policy commits the council to producing a short focused local plan to identify and allocate additional sites for gypsy and traveller provision to meet the identified need. If required, this plan will be commenced within one year of the adoption of the Site allocations plan.
2.12 The JCS was developed by the Greater Norwich Development Partnership (GNDP), a partnership of the three councils of Broadland, Norwich and South Norfolk, working together with Norfolk County Council. The JCS was adopted in March 2011 and amended in January 2014 and sets out a strategy for growth of the Norwich policy area. Objective 2 of the plan is ‘to allocate enough land for housing, and affordable housing, in the most sustainable settlements’. It provides for at least 37,000 new homes in the plan area over the period 2008-2026 a level which demonstrably meets fully the objectively assessed housing needs of the wider area.
2.13 Although overall housing growth levels proposed in the JCS remain the same as adopted in March 2011 some amendments were made to the JCS to ensure consistency with the NPPF and particularly to ensure that adequate flexibility exists to promote housing delivery if necessary. JCS policy 22 requires that if there is a significant shortfall of housing supply affecting the Broadland part of the Norwich policy area (NPA) the local councils will produce a short, focussed local plan to identify additional locations within the NPA for immediate deliverable housing land to remedy the shortfall. If such a plan is produced priority will be given to sites in Norwich ahead of those elsewhere in the NPA in accordance with the settlement hierarchy set out in paragraph 6.2 of the JCS.
2.14 The JCS promotes the city centre as the main focus in the sub-region for retail, leisure and office development, with housing and educational development also adding to the vibrancy of the centre (policy 11).
2.15 As noted in paragraph 2.8 above, affordable housing requirements are set out in JCS policy 4; the proportion of affordable housing will vary dependent on the total number of homes proposed in a scheme, up to a maximum of 33%.
2.16 The JCS also states, in policy 8 (‘Culture, leisure and entertainment’), that development will be expected to provide for local cultural and leisure activities, including new or improved built facilities.
2.17 It identifies the Norwich policy area (defined as the Norwich urban area, the first ring of fringe villages surrounding Norwich but extending to Long Stratton and Wymondham) as the focus for major growth and development over the lifetime of the plan, with a requirement to deliver 21,000 new dwellings between 2008 and 2026. In the city of Norwich alone, policy 9 requires at least 3000 new dwellings to be delivered over the plan period to accommodate this level of growth.
2.18 The requirement for a minimum of 3,000 new dwellings for Norwich is in addition to the 5,592 dwellings which could have been built from housing commitments existing at 31st March 2008, this being the base date of the JCS. It is also the date from which overall housing provision figure in this Site allocations plan is initially calculated and provides the context for the level of allocations to be delivered through its policies, taking account of housing development which has already occurred in the period between 2008 and 2012.
2.19 The housing commitment figure of 5,592 dwellings at the March 2008 base date includes undeveloped sites which were already allocated in the 2004 Replacement local plan and sites where permission had been granted for housing before that date, but development had either not yet started or which was only partially complete.
2.20 JCS policy 11 deals specifically with Norwich city centre, proposing housing growth ‘to meet need and to further promote a vital and vibrant city centre community’. Taking account of committed development and new allocations, a minimum of 2,750 dwellings is required in the city centre between 2008 and 2026. It is expected that around a third of these would need to come from new city centre allocations brought forward through this plan.
2.21 The Strategic housing land availability assessment (SHLAA) demonstrates that there are sufficient deliverable and developable sites available to meet JCS housing requirements in the Norwich policy area, and in particular demonstrates the realistic capacity of Norwich to accommodate housing and thus minimise the need for greenfield development outside the city.
2.22 Policy 4 in the JCS also requires proposals for housing to contribute to the mix of housing required to provide balanced communities and meet local needs, addresses the need for affordable housing, housing with care, and provision for gypsies and travellers. Policy 6 promotes the concentration of development close to essential services and facilities to encourage walking and cycling as primary means of travel, and use of public transport for wider access.
2.23 As well as housing, it is important that business development is promoted within the city. Objective 4 promotes economic growth and diversity and provision of a wide range of jobs. Existing employment sites will be safeguarded and enough land for employment development will be allocated to meet the needs of inward investment, new businesses and existing businesses wishing to expand or relocate. Norwich city centre will continue to exert a powerful economic influence over the wider area. Its growth will be further encouraged, so that the centre remains one of the best in the country for retail and employment. Norwich International Airport is listed within a range of key locations in the Norwich policy area for strategic employment growth.
2.24 Policy 5 of the JCS sets out a number of separate policy strands to implement this objective and provide for the forecast need for 27,000 additional jobs in the period 2008-2026. This includes providing appropriately for the needs of (and maintaining a supply of premises for) small and medium sized businesses; allocating sufficient employment land in accessible locations to meet larger scale needs; overcoming constraints to the release and development of key sites and protecting land already identified for employment purposes only for uses which are ancillary to and supportive of their employment role. It also provides for the expansion of further and higher education and training; enterprise hubs in selected locations (including the University of East Anglia and Norwich Research Park) and support for tourism, leisure and the cultural and creative industries. Policy 9 requires that land be identified to deliver a net increase of 100,000 square metres of new office floorspace in the city centre by 2026.
2.25 The JCS aims to strike a balance between the need for additional jobs and housing growth in the city to 2026 with the need to protect the city’s environmental assets and high quality of life. The level of new development proposed in this plan reflects this consideration, and will provide for new growth to meet JCS targets (which are based on evidence such as the SHLAA and 2008 Employment growth and sites and premises study) whilst maximising the high quality of life that we currently enjoy and mitigating against any adverse impacts of growth.
2.26 The local policy context to this plan is also provided by the DM policies plan (prepared alongside this document) and the adopted NCCAAP. Both of these also form part of the local plan for Norwich and should be read in conjunction with this plan. The DM policies plan sets out general policies to guide development which apply across the city and contains policies to protect Norwich’s assets including its open spaces and historic buildings. Many of the policies in the DM policies plan are relevant to the site allocations, and are referred to in chapter 6 and 7 which introduce the site specific allocations.