How the plan has evolved
3.1 This section of this chapter shows how the plan has evolved and how it addresses the tests of soundness required of a development plan.
3.2 All the sites proposed in the Site allocations plan have gone through a selection process comprising a number of stages. This included several rounds of public consultation. These representations received through consultations form part of the evidence base for the site selection process.
3.3 All the allocations satisfy the following tests of soundness:
- They are in compliance with the JCS and with national policy, particularly the NPPF;
- They are based on a robust evidence base which has been determined both by research and through several stages of public consultation;
- They are considered to be the most suitable allocations when considered against a range of reasonable alternatives;
- They have undergone the processes of sustainability appraisal and appropriate assessment to test their suitability for development;
- They are considered capable of being delivered within the plan period.
The ‘call for sites’
3.4 The initial stage of the Site allocations plan was to identify potential sites for development. A ‘call for sites’ exercise was undertaken between February and April 2009. Developers, agents, community groups and the public were asked to suggest sites for possible development or change. The sites put forward, along with sites identified through the Replacement local plan and background studies, were all included in the initial list of sites published for public consultation. These sites were proposed for a variety of uses, including housing, employment and mixed uses.
First stage of consultation: potential development sites
3.5 In accordance with Regulation 25 of the local development regulations then in force, an initial round of public consultation took place between November 2009 and February 2010. This involved a wide range of consultees, including statutory and special interest bodies and residents across the city. Around 400 representations were received to this stage of consultation.
3.6 Following consideration of consultation responses to this first stage of consultation, all sites were then assessed against three key objectives - suitability, sustainability and availability.
3.7 Suitability assessment was undertaken by officers using a qualitative approach, and involved both desktop study and site visits. Full details of the methodology used are set out in the Site selection background document which forms part of the evidence base of the plan.
3.8 Sustainability assessment examines social, economic and environmental issues and was considered separately through the sustainability appraisal process (see paragraphs 3.34 - 3.37 below).
3.9 Ownership information was also gathered for sites, regarding their availability and likely timescale for delivery. This information reinforced the assessment process and helps to form a robust evidence base for the deliverability of the potential development sites.
3.10 As part of the assessment process, a number of sites which were included in the first round consultation were not carried forward into the second stage, or were carried forward but with amended boundaries. The reasons why particular sites were not carried forward into the next version of the plan are included in the Site Selection background document. In summary these are:
•Sites more appropriate for consideration in the DM policies plan (e.g. in cases where a site currently in employment use had been proposed for reallocation for the same purpose, the site was not included, since it would already be adequately covered under DM policy DM16 applying to all established employment areas in the city);
- Sites constrained by their size and/or shape which would be difficult to develop viably and beneficially on their own, but which would be acceptable if integrated into or combined with a larger neighbouring site to achieve a comprehensive scheme, thus avoiding piecemeal and stand-alone development;
- Sites assessed to be ‘unsuitable’ or ‘less suitable’ for development, on the basis of the suitability and sustainability criteria referred to above. A list of these sites and reasons for discounting them is attached at Appendix 1.
- Sites considered too small to allocate: the original minimum size threshold for a site to be allocated was set at 0.1 hectare in the city centre and 0.2 hectare in the rest of the city. However, because some smaller sites were assessed as capable of accommodating relatively high density development, the threshold has been relaxed to include any site that could reasonably deliver 10 or more dwellings even if it is smaller than the minimum threshold. Sites below the size threshold which are assessed as likely to provide fewer than 10 dwellings have not been carried forward; should proposals be brought forward on such sites they will be treated as windfall development.
Second stage of consultation – shortlisted sites
3.11 The second stage of statutory consultation on the plan narrowed the initial long list of potential development sites for inclusion down to a shortlist of preferred sites. This consultation on shortlisted sites took place between January and March 2011. All these sites were assessed as being appropriate for their intended purpose on the basis of the suitability, availability, and sustainability assessments referred to above. The council received approximately 100 responses to this stage of consultation.
Additional stage of consultation
3.12 Significant changes were proposed to a number of sites put forward for the consultation on shortlisted sites. These included requests for amendments to site boundaries to respond to various changes in planning circumstances and suggestions for consideration of possible alternative uses. A further round of consultation was then carried out on these sites (between July and September 2011). The sites in this additional stage have also been assessed against the criteria referred to above (suitability, sustainability and availability) and therefore have the same ‘preferred sites’ status as the sites originally shortlisted.
3.13 This further period of consultation ended on 30 September 2011. Over 200 responses were received on this consultation.
Soundness (pre-submission) consultation
3.14 The final stage of consultation on the plan (the Regulation 19 consultation) took place from August to October 2012. Individuals and organisations were able to comment on the soundness and legal compliance of the plan. It should be noted that prior to consultation on the Pre-submission plan, a decision was taken by members at cabinet in July 2012 to omit two sites from the plan: R6 (Former Lakenham Sports and Leisure Centre) and R45 (Land west of Bluebell Road). A further site CC09 (King Street Stores and adjacent Lincoln Ralphs Sports Centre) was amended by cabinet to remove the Lincoln Ralph Sports Centre from the allocation.
3.15 A total of 141 representations were received to this period of consultation. The representations and the council’s responses to them are set out in the Statement of consultation and publicity, which is part of the evidence base and is available on the council’s website.
The evidence base
3.16 It is important to ensure that this plan (and the local plan as a whole) is supported by up-to-date and relevant evidence and supporting information.
3.17 The Site allocations and DM policies plans have both been informed by evidence covering a wide range of environmental, housing, social and economic issues. Much of the evidence commissioned to inform and support the JCS relates specifically to the city council area.
3.18 The council has also produced a series of topic papers which provide information about the way that planning policies and proposals in the DM policies plan and Site allocations plan have been developed and how they respond to the JCS and national policy. These cover the following topic areas:
- Retail and town centre development
- Open space, sport and recreation
3.19 The full evidence base is set out on the council’s website
3.20 The evidence base also takes account of representations made at the various stages of consultation of the plan, as set out above. These are detailed in the council’s Statement of consultation and publicity, one of the background documents for this plan.
Deliverability and viability
3.21 Deliverability and viability are key elements of the planning process. The NPPF states that plans should be deliverable and therefore ‘the sites and scale of development identified in the plan “should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened”.
3.22 The Site allocations plan looks ahead to 2026, during which period many changes could take place in the property market and in the general economic outlook. It is important that the site specific policies in the Site allocations plan should not impose unrealistic burdens on developers that could stall the development process. However, it is equally important that the site proposals do not simply take a short term view with an undue focus on current market conditions, as these will change. It therefore follows that the plan must be realistic and flexible, and able to respond to changing economic circumstances. The evidence base also takes account of representations made at the various stages of consultation of the plan, as set out above. These are detailed in the council’s Statement of consultation and publicity, one of the evidence base documents as referred to above.
3.23 The viability studies undertaken to support the introduction of a Community Infrastructure Levy (CIL), adopted in July 2013, are key pieces of evidence to support the growth proposed in the JCS  and have helped shape the council’s approach to viability issues in the Site allocations and DM policies plans.
3.24 The viability study carried out in 2010  assessed the impact of the introduction of CIL on the viability of development on an area-wide basis, and concludes that CIL is achievable for the majority of future development schemes under normal market conditions. A wide range of local developers and agents inputted into this study through a series of workshops and other consultations.
3.25 The initial viability study is supplemented by a report setting out further evidence from local developers to test the impact of CIL on viability . Supplementary reports deal variously with viability issues around provision and build costs of flats in Norwich, the impact of garages on the sale price of new build housing and the viability of large scale convenience goods based retail development. The main report examined a range of local scenarios to illustrate the impact of various assumptions on residual land value. It concluded that in most cases the proposed residential CIL charges could be accommodated whilst still allowing the full requirement for affordable housing to be delivered and a viable residual land value retained. There is likely to be an early review of the CIL charges, after an initial operating period of two to three years, during which the CIL impacts can be further evaluated and any implications of changed market conditions incorporated.
3.26 The council published a further viability assessment in November 2013 which assessed the viability of different typologies of sites in the Site allocations plan and whether policies in the DM policies plan would adversely affect the viability of development of these sites. It concluded that the majority of the residential and mixed use allocations would be viable; the viability of high density residential development in the city centre would be more marginal (though increasingly viable with a small uplift in sales values), and that employment development would currently be unviable. However, this reflects the current national and regional picture and likely market improvements should greatly improve the viability of employment development. In addition, the study showed that policies in the DM policies plan would not adversely affect the viability of development proposed in the Site allocations plan.
3.27 The council has taken a realistic, albeit flexible, approach to viability and deliverability issues in the Site allocations plan and in the DM policies plan. Throughout the process of developing the Site allocations plan the council has liaised with developers, landowners and agents to gain an appreciation of realistic development aspirations for their sites and any potential barriers to development. This plan also stresses the importance of regular monitoring of development activity as a means to identify barriers to delivery (see Chapter 4, on monitoring).
3.28 Before CIL was introduced, the council took a flexible approach to the consideration of planning applications involving a planning obligation through its adopted planning obligations prioritisation framework. This set out the relative priorities for the delivery of planning obligations in the event that these, in combination, would have a significant impact on viability and deliverability . With the introduction of CIL this framework no longer applies. A realistic and responsible approach to viability and deliverability will be maintained, taking account of the principles applying to planning obligations as set out in the NPPF and reflected in policy DM33 of the DM policies plan.
3.29 In the interests of delivering sustainable and viable development, policy DM33 recognises that the requirements for planning obligations and the requirements of other policies within the DM policies plan may be relaxed in circumstances where the viability of a scheme is compromised. This will mainly impact on the level of affordable housing which can be delivered under JCS policy 4 and must be justified by an open book viability appraisal. Further information about CIL and planning obligations is set out in the supplementary text following policy DM33 of the DM policies plan.
3.30 This flexible approach aims to ensure that that planning obligations and policy requirements do not threaten the viability of individual sites. The approach acknowledges that development viability will vary over time; for this reason the site-specific policies are not based on individual site viability appraisals, although they are informed where possible by relevant evidence.
3.31 It is important to note that the plan-making process itself can improve viability for individual sites. In the current economic climate developers and agents may be very cautious about the development value that can be achieved in particular locations, which can lead to commercial caution to an extent that inhibits innovation and place-making. Through its site-specific policies, the Site allocations plan aims to strike a balance between the values on individual sites that are likely to be achieved based on current market performance, and the extent to which market perceptions can be altered by the plan-making process through a robust understanding of the local context and opportunities, maximising environmental improvements, co-location of uses, and general place-shaping.
3.32 To comply with European legislation, Appropriate Assessment (AA) under the Habitats Regulations 1994 is mandatory for all relevant local plans. This is to ensure that policies and proposals will avoid adverse effects on certain habitats of national and international significance, whether these are already protected by a formal designation or are sites proposed for such protection (candidate sites). The council may only adopt a plan after it has been shown that the plan will not adversely affect the integrity of the sites concerned.
3.33 An Appropriate Assessment screening report of the Site allocations plan has been undertaken by independent consultants. Their report  concluded that site proposals within the Site allocations plan either alone or in combination with other growth proposals identified by the JCS, would be unlikely to have an adverse effect upon the integrity of any European site, subject to the delivery of the necessary mitigation as set out in the Appropriate Assessment of the JCS.
3.34 As part of the plan making process it is necessary to carry out a sustainability appraisal (SA) in parallel with the development of the plan. SA is a process to ensure that environmental, economic and social impacts of preferred policies and proposals and any reasonable alternatives are fully documented and taken into account in plan making
3.35 A scoping report, setting out a proposed SA framework, was published by the city council for consultation in November 2009.
3.36 The city council has appointed and retained specialist planning consultants (Land Use Consultants - LUC) to undertake the SA exercise for both this plan and the DM policies plan. LUC’s independent appraisal follows the recommended SA process and best practice. A draft SA report (December 2010) was published alongside the draft Site allocations plan for consultation between January and March 2011. That report set out the outcome of the sustainability assessment of the draft policies for consultation and the alternative options. LUC produced a further SA report in July 2011 to accompany the additional sites consultation (July – September 2011)
3.37 A further stage of sustainability appraisal was undertaken by the same consultants to accompany the Pre-submission plan consulted upon between August and October 2012 and was further reviewed for submission in the light of the generally minor changes made to the plan in response to that consultation. An addendum to the Pre-submission SA report was produced following the public examination to take account of any main modifications to the plan, and an environmental statement summarising the input of the SA into plan making has been published alongside the adoption of the plan.
The proposed site allocations
3.38 The site selection process explained above has resulted in allocations for a total of 73 sites, many of which are for mixed use development and for housing, with a small number of sites allocated for employment, and for other uses. New allocations sufficient to accommodate 3,142 new houses and flats are proposed (927 of these in the city centre and 2,215 in the remainder of the city) together with an additional seven hectares of employment land. Total housing provision exceeds the JCS housing allocation target of 3,000, which allows for some flexibility should the practicality of achieving housing targets on individual sites need to be reappraised as a result of physical or market constraints.
3.39 Chapter 5 provides an introduction to the site specific policies; the policies themselves are set out in chapter 6 (city centre sites) and chapter 7 (sites in the remainder of the city). Appendix 1 lists sites which are not being carried forward into the plan. Appendix 2 is an implementation table setting out the likely phasing of delivery of all sites over the plan period, and is based on information about availability and delivery provided by landowners and developers.
3.40 The structure of this plan reflects the JCS’s emphasis in policy 11 on the promotion of Norwich city centre through an integrated approach to economic, social, physical and cultural regeneration to enable greater use of the city centre, including redevelopment of brownfield sites. The city centre will be the main focus of retail, leisure and office development in the sub-region during the plan period.
3.41 Each site schedule includes a site description and context, explanatory text covering the background to the policy and any site constraints, and a site allocation policy.
 Viability advice on CIL/ Tariff for Broadland, Norwich and South Norfolk, GVA Grimley, December 2010
 Supplementary evidence on residential viability, GNDP, December 2011
 Planning obligations prioritisation framework, Norwich City Council, May 2009 (revised February 2011)
 Appropriate assessment for Norwich City Council Site allocations development plan, The Landscape Partnership, November 2010