Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below respond to the Site Proposals Consultation Document.
The Site Proposals Consultation Document
SITES QUESTION 2 - PLEASE COMMENT ON ANY OF THE SITES ALREADY SUBMITTED
3 As identified in 5.22 of the Site Proposals Consultation Document, Costessey is identified in the JCS as a major growth location. It benefits from facilities in Norwich and residents have access to a wide range of shops, services and leisure facilities, medical centre, and strategic employment area.
Land North of Farmland Road, Costessey (GNLP0238)
4 The Site is actively being promoted by the landowner for residential development. This Site is identified in the Housing and Economic Land Availability Assessment (HELAA) as site reference GNLP0238. We support the conclusion of the HELAA that the site is considered suitable for residential development, and we agree with the Site Proposals Consultation document that the site would be an extension of existing development in New Costessey and is largely unconstrained.
5 The Site is not a "valued landscape" within the meaning of paragraph 9 of the National Planning Policy Framework ("NPPF"). For the purposes of paragraph 47 of the NPPF, the Site is deliverable:
5.1 it is available now;
5.2 offers a suitable location for development now;
5.3 is achievable with a realistic prospect that housing will be delivered on the site within five years and in particular the Site is viable.
6 The Site directly adjoins the built up boundary of Costessey, with the Site boundaries to the south and east being formed by soft landscaping, with residential development beyond. Open fields lie to the west, with the River Tud and a densely vegetated area lying to the north. The Site slopes in a southerly direction towards the north of the Site, from a highest point of 26.5m above sea level down to 18.5m.
7 Immediately to the south of the Site lies a series of residential properties on Farmland Road, which date from the 1980s and comprise 1.5 - 2 storey properties. Farmland Road leads onto Grove Avenue, in turn connecting to Dereham Road and then wider areas of Costessey and beyond.
8 The Sites position on the edge of Costessey provides a very sustainable location for new development, and it is available to come forward in the short term. There are strategic and local transport connections, plus easy access to nearby local amenities along with jobs, services, leisure and cultural facilities of the town centre.
9 It is recognised the Site Proposals Consultation Document considers that the Site ''would be an extension of existing development in Costessey - it would need mitigation to deal with surface water flood issues and avoid harmful impact on the adjacent CWS, but otherwise is largely constrained.''
10 The Site has been subject to two recent applications (application references: 2015/2927 and 2017/0420) and the proposed indicative masterplan demonstrates that a scheme of up to 83 dwellings could be accommodated on the Site, including 27 affordable dwellings, and the creation of areas of public open space, sustainable drainage systems and associated infrastructure. Both applications were supported by all of the relevant and necessary documents, and both applications were reported to committee with planning officer's full support, with a recommendation for approval. Importantly, there were no statutory objections to the applications in respect of matters such as wildlife and ecology; flooding and drainage; design; contamination; landscaping; and highways. Detailed viability work, accepted by the Council, demonstrated that the proposals represent a deliverable development.
Deliverability
11 The Site is being actively promoted by the landowner. As illustrated by the recent planning applications it can be seen that the Site has no significant constraints, is in single ownership and is available to come forward now. It is considered that this should be given considerable weight when assessing this Site for allocation within the GNLP against other potential sites, particularly in Costessey.
Flooding and Surface Water Drainage
12 Details relating to surface water drainage were found to be acceptable as part of the previous applications. This is supported by a Flood Risk Assessment ("FRA"), and it provides details on the surface water drainage strategy for the Site. The proposed built development would be located outside Flood Zones 2 and 3, and the development would not increase flood risk. The FRA confirmed the ground conditions are suitable for infiltration drainage, and will not result in any adverse harm to protected species, the CWS, or the River Tud. This was been agreed with both the Environment Agency and the Lead Local Flood Authority as part of the recent applications.


Highways and Access
13 Access to the Site would be from Farmland Road. The Transport Statement for the Site to support the recent applications confirms that the impact of the proposed development of 83 dwellings on the surrounding highways network, will be negligible. Whilst recognising the steepness of the road, the Highway Authority ("NCC") confirmed that Farmland Road is suitable for this scale of development and that the local highway network is considered to be able to safely cater for the additional traffic generated by the proposed development.
Landscape and Design
14 A Landscape and Visual Impact Assessment (LVIA) has been completed for the Site to support the recent applications which demonstrates that that the level of harm will not be significant and demonstrable on the surrounding landscape and character area.
15 In respect of visual impact, it is considered that the indicative layout responds to the visual assessment, restricting built area to the G1 Easton Fringe Farmland Local Character Area and making strategic provision for planting that will, as it matures, reduce the visual effects further. In the opinion of the officer who professionally considered the proposals, the new visualisations confirm this conclusion.
16 Whilst the Site is currently a field in agricultural use, it abuts existing residential areas and as such the Council's Landscape Architect did not consider that the proposal is detrimental to the overall character of landscape character G1, especially in light of the demonstrated limited long-term visual effect.
17 In relation to the most recent application, the Council's Landscape Architect confirmed that in his professional judgement it cannot be demonstrated that there will be significant and demonstrable harm in either visual or landscape terms for development carried out in accordance with the layout and scheme as presented by the illustrative masterplan.
Ecology & Arboriculture
18 The proposed development of the Site has also been supported by ecological studies. The mitigation and enhancement measures proposed are considered necessary to mitigate any impact on ecology. This has been confirmed acceptable by the County ecologist in response to the recent applications.
Contamination
19 A contamination report was also completed for the Site as part of the recent applications and the Environment Agency, the Lead Local Flood Authority, and Council's Environmental Protection Officer were satisfied that any matters relating to contamination would be dealt with a condition.

Open Space and Green Infrastructure
20 Open space is proposed at the core of the new development. The proposed central green would connect to two internal green corridors which link to the north east and north west of the Site respectively. These internal landscape corridors will also be integrated with the SuDs system to create a distinctive and attractive landscape that links seamlessly with the new perimeter GI corridors and the wider landscape context of the River Tud valley. Provision is also included for a footpath through the CWS, with provision of a ramped footpath.
Other Matters
21 As identified in the HELAA there are no constraints in relation to utilities infrastructure, contamination or ground stability, no loss of open space and no impact on heritage assets.
22 CIL funds raised by the proposed development will contribute towards infrastructure needs in Costessey, including education, and in addition there will be other site specific matters which will be dealt with in S106 obligations.
23 Additional land to the north of the Site has been offered by the applicant to provide an additional area of recreation land, with the provision of two circular walks, and enhancements to the landscape. This formed part of a separate application (ref 2017/0420). It would be accessible to those near the Site and existing users of the CWS. This could provide network of paths both in the CWS and also to the north of the Site along the River Tud.