Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 21249

Received: 16/03/2020

Respondent: Bright Futures Developments St Faiths Ltd

Agent: Mr Jon Jennings

Representation Summary:

The identification of this site as a preferred option should be rejected. If not a detailed assessment of the site should be made based upon the reduced area. This assessment should also demonstrate how the impact of the development is to be properly mitigated in relation to the wider landscape setting. At the same time other sites should be reassessed to confirm whether a smaller site area would render them suitable for development. This aspect of the plan is considered to be unsound and the evidence available does not justify the identification of this site as the preferred option.

Full text:

Preferred Site GNLP0125 – Land to the west of West Lane

My client wishes to raise concerns about Policy GNLP0125 – Land to the west of West Lane, Horsham St Faith which is proposed as the only new allocation within Horsham and Newton St Faiths. This is principally as a result of the allocation HNF1 Land to the east of Manor Road, Newton St Faith having full planning permission for 69 dwellings. Work on implementing developing this site has just commenced and it is apparent that this site will be developed early on in the plan period. In effect this means that only 25-30 additional dwellings will be allocated in Horsham and Newton St Faith up to 2035.

Therefore, at the current time the emerging local plan is only proposing one modest allocation, which fails to recognise the demand for housing in this part of the GNDP area, which is due to the completion of the northern distributor road increasing accessibility to Norwich.

In reviewing the documentation associated with the assessment of this site there are concerns as to the robustness of the assessment, especially as there are other clearly less constrained options which have been put forward which more closely relate to existing development.

In reviewing this proposed allocation against the rejected sites, in particular that at GNLP1054, there are questions as how this allocation fits in with the existing pattern of development and its compatibility with adjoining land uses. The site has limited screening on its southern boundary and if development is provided in this location the landscaping will take a significant time to become established. This emphasises the constraints associated with trying to retrofit a small site within an area, which was originally proposed for 400 dwellings, including highways improvements, public open space and community facilities. The site covers 14.85 hectares and the proposed allocation seeks to reduce this to only 1.44 hectares for 20-30 dwellings. This reduction in size will not allow the site to properly screened. It is also clear that the proposal is not expected to provide any community benefits over and above those which will be sought by the CIL regulations. Also, there will be no bio-diversity benefits arising from this site.

The allocation of this site will also undoubtedly lead to future proposals to increase the site, resulting in development proceeding in a piecemeal rather than a coordinated manner. The impact of development in this location being exacerbated by the lack of existing screening. This compares with other sites which have defined and defensible boundaries.

The site is also located immediately to the south of an the Abbey Farm Commercial Park and the potential noise impacts associated with this site need to be addressed to ensure that there is no conflict with paragraph 180 of the NPPF, which advises that “Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development”. Further information is required to address this issue and answer the question regarding the compatibility of residential development with neighbouring uses.

The site frontage and West Lane are demarcated by a significant tree belt and it is apparent that a considerable number of these will need to be removed to facilitate both access and to create the requisite visibility splays. This issue needs to be considered in more detail in terms of the impacts on the landscape and bio-diversity.

The basis of identifying this site for allocation appears flawed when the site is considered against the HELAA, as there are clearly significant constraints associated with the development of the site. There are also questions as to whether the small scale of development will be viable and besides affordable housing there will be no benefits arising from the site. The site is also a considerable distance from the Primary School and the community buildings when compared with other sites within both Newton and Horsham St Faiths. No works are sought to improve pedestrian access to this facility.

In view of the above it is considered that that the identification of this site as a preferred option should be rejected and consideration given to other sites which clearly have less constraints. If not a detailed assessment of the site should be made, based upon the significantly reduced area. This assessment should also look to demonstrate how the impact of the development is to be properly mitigated, particularly in relation to the wider landscape setting. At the same time other sites should be reassessed to confirm whether a smaller site area would render them more suitable for development. At the present time this aspect of the plan is considered to be unsound and the evidence available does not justify the identification of this site as the preferred option.

Particular notice should be made to the other sites in Horsham and Newton especially GNLP1054.