Alliance on Housing

January 25th, 2013

Dear…

Joint Core Strategy Housing Targets

I am writing to you on behalf of the CPRE Alliance to request that the GNDP carries out an immediate review of its Joint Core Strategy housing targets with a view to reducing them considerably.

CPRE Norfolk has consistently called for a reduction in these housing targets as they are incompatible with our core objectives to protect and enhance the rural environment. The high level of development envisaged, much of it on greenfield sites, will lead to a severe erosion of the features that make the countryside surrounding Norwich so special. Rural areas will be suburbanised and tranquility will diminish as population density, traffic congestion, light and noise pollution increase.

Anumber oflocal community campaign groups have formed to express their concerns about the impact that development proposals will have on their area. These groups together with several parish councils and other organizations have entered in to an alliance with CPRE Norfolk in pursuit of the following aims:

• a reduction in the housing targets included in the Joint Core Strategy of the Greater Norwich Development Partnership (GNDP)
• open and meaningful consultation by the GNDP, with opportunities for active public participation.

Although the Joint Core Strategy has been adopted, it will require regular review to remain relevant and fit for purpose up to 2026.

TheCPRE Alliance is calling on the Greater Norwich Development Partnership (GNDP)tobegin an immediate review of the Joint Core Strategy’s housing targets as provided for under the National Planning Policy Framework (NPPF). House building targets are not being met, and should be reduced to reflect demand more accurately. The outcome of the review is likely to show that, because of the changed economic climate, the quantity of land allocated in the current JCS is excessive to meet needs in the short to medium term.

We are also calling for:

• The introduction of a detailed site-specific phasing policy which prioritises regeneration/brownfield development, as allowed for under the NPPF. More damaging sites should be earmarked as longertermdevelopment.
• A short-term development control moratorium on the release of sites that are considered likely to cause the most environmentaldamage. This will protect against the tendency of landowners and developers to bring forward greenfield sites which are often the easiestand most financially advantageous places to develop.
• Inclusion of urban area windfalls. This is now an acceptable approach under the NPPF.

We appreciate that the requirement for local authorities to maintain a rolling 5-year deliverable supply of housing sites is putting pressure on councils togrant planning permission to greenfield sites outside the local plan. We urge South Norfolk District Council, Broadland District Council and Norwich City Council to strongly resist pressure from opportunistic developers, and refuse permission for such unsustainable development.In this context it is important to remember that local planning authorities are not absolutely required to give planning permission in these circumstances - the proposeddevelopment must demonstrate it is sustainable -and permission can still be refused on environmental and social grounds as has always been the case.

Local councillors can argue that ‘off plan’ sites are intrinsically more damaging and look for theevidence of specific harm to landscape and area character.

Furthermore a reduction in housing targets, as part of a review of the Joint Core Strategy, would reduce the 5-year supply required andreduce the risk of the housing supply being ruled out of date.

Shortly after the last general election Eric Pickles offered local authorities the chance to free themselves from previously imposed housing targets. Unfortunately Broadland, SNC and Norwich decided to stick with those targets but the Regional Spatial Strategies are in the process of being abolished and surely this will present an opportunity to conduct a sensible review of Joint Core Strategy housing targets.

I look forward to your response to the points raised in this letter and in particular to receiving your views on the likelihood of a policy review with respect to housing targets. You will see from the list of supporting organisations below that our concerns are shared by a large number of people ie voters, throughout your council areas.

Yours sincerely,

David Hook

Chairman CPRE / Norfolk Planning Group

On behalf of the CPRE / Norfolk Alliance on Housing namely:

CPRE Norfolk
Colney Parish Meeting
Caistor St Edmund Parish Council
Great & Little Plumstead Parish Council
Framingham Earl Parish Council
Stoke Holy Cross Parish Council
Trowse with Newton Parish Council
Weston Longville Parish Council
Friends of Thorpe Woodlands
Hethersett Our Way
Norfolk Anglers Conservation Association
Norfolk Association of Architects
Norwich and Norfolk Transport Action Group (NNTAG)
Realistic Reepham

Sprowston and Old Catton Residents Against Beyond Green
Stop Norwich Urbanisation (SNUB)
Wymondham Asks Why
Kettlestone Parish Council
Hillington Parish Council
Hainford Parish Council Hethersett Parish Council Salhouse Parish Council
Marlingford with ColtonParish Council Wroxham Parish Council Blofield Parish Council Rackheath Parish Council Issues Managers

Attached: CPRE / NORFOLK POLICY STATEMENT ON THE GNDP / JCS

Cc

CllrAndrewProctor, Broadland District Council, Leader of the Council

MrPhilCourtier, Broadland District Council, Head of Planning

MrShaunVincent, Broadland District Council, Cabinet Member for Planning

MsGillianMorgan, Broads Authority, Director of Planning and Development

MrBillBorrett, Norfolk County Council, Acting Leader of the Council

MrBevSpratt, Norfolk County Council, Cabinet Member for Planning & Transportation

MrMikeJackson, Norfolk County Council, Director of Environment , Transport and Development

CllrBrendaArthur, Norwich City Council, Leader of the Council

MrGrahamNelson, Norwich City Council, Head of Planning Service

CllrBertBremner, Norwich City Council, Cabinet Member for Environment and Development

CllrJohnFuller, South Norfolk District Council, Leader of the Council

CllrJoeMooney, South Norfolk District Council, Chair of the Development Management Committee (Planning)

MrTimHorspole, South Norfolk District Council, Director of Growth and Development

MsSandraEastaugh, GNDPPartnership Manager

MrGeorgeFreeman, MP for Mid Norfolk

MsChloeSmith, MP for Norwich North

MrRichardBacon, MP for South Norfolk

MrSimonWright. MP for Norwich South

MrKeithSimpson. MP for Broadland

Media

EDP
Radio Norfolk

BBC TV
Anglia TV