The HBF has submitted representations to Norwich City Council in relation to its draft Supplementary Planning Guidance (SPG) on flood risk and development.
Paragraph 2.4
The council states that the Association of British Insurers guidelines for assessing development proposals have been incorporated into the draft SPG. The HBF would point out, however, that the insurance industry and planning systems interests are unlikely to always coincide.
Paragraph 2.10
The text refers to PPG3 Housing which promotes the use of brownfield land instead of Greenfield sites. The HBF would point out that this is not in fact the case.
Government guidance sets out a sequential approach to the allocation of development sites, giving priority to suitable brownfield sites. However, it fully acknowledges that greenfield sites will often have an important role to play in meeting housing supply requirement. Hence if the brownfield target is 60 percent, a further 40 percent of provision will be on greenfield sites.
For further information please contact:
paul.cronk@hbf.co.uk(Paul Cronk)
Regional planner, HBF Eastern and East Midlands
0207 7960 1625 or 01206 303825