Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 21883

Received: 12/03/2020

Respondent: Persimmon Homes (Anglia Region)

Agent: John Long Planning

Representation Summary:

Conclusion
In conclusion, Persimmon Homes (Anglia) supports the Local Plan’s acknowledgement that the site EAS
1: Land south and east of Easton is capable of accommodating additional homes beyond those identified in the previous Site Allocations Plan (900 units) and as permitted by the outline consent (890 units) and likely to be permitted (64 units). However, further clarity on how the housing target of 1,044 units has been derived and what it consists of and any related assumptions should be provided.
Importantly, Persimmon Homes (Anglia) do not consider it appropriate for the Policy to be simply rolled
forward in its entirety without acknowledging that planning consent has been granted and that many of
the Policy’s requirements are met through the consenting process, as evidenced in the consent’s
planning conditions and the accompanying Section 106 agreement; and will be delivered through the
implementation of the scheme.
Persimmon Homes (Anglia) also suggests that the Policy’s housing figure should be expressed as a
minimum or ‘at least’ figure, in the event that through the consenting of reserved matters application(s)
making an efficient and best use of land, opportunities for further sustainable development within the
allocation boundary presents themselves in the future.
Persimmon Homes (Anglia) remain very happy to continue to work with the Authorities to clarify those
Policy EAS 1 requirements that remain relevant to any future planning applications, and those that are not, particularly those that have been/are being dealt with by the original consent’s conditions and s106
obligations package.

Full text:

Persimmon Homes (Anglia) Response to Greater Norwich Local Plan (Regulation
18) Policy EAS 1 Land South and East of Easton
I am instructed by Persimmon Homes (Anglia) to respond to the current Greater Norwich Local Plan
(Regulation 18) consultation specifically in relation to Policy EAS 1: Land south and east of Easton.
Persimmon Homes control the majority of the site (excluding an area of the allocation to the north of
Dereham Road, which is promoted separately by Orbit Homes) and which has the benefit of outline
planning permission.

Background
The original Easton outline application 2014/2611/O was consented on 1 November 2016. The original
outline application site (excluding an area of land to the north of Dereham Road, which is being promoted
by Orbit Homes for 64 homes) extends to approximately 45 hectares and the consent limits the total
number of homes to 890 units.
The original outline application requires compliance with approved parameter plans, including for layout,
land use and density and a Design Code. The Design Code for the site was approved on 16 December
2019. A reserved matters application for the first phase of the scheme is being prepared and will be
submitted for approval shortly.
Persimmon Homes (Anglia) aim to be efficient in the use of land (as required by the NPPF) as it prepares
its reserved matters applications and considers that there may be future opportunities to accommodate
addition sustainable residential development above that which is currently specified in the emerging
Local Plan policy (1,044 homes) and this potential opportunity should not be compromised by the Policy.
It is acknowledged that to secure any future additional ‘uplift’ in residential unit numbers a new consent would be required, which would need to take account of any new policies adopted since the outline
consent was granted; including contributions to CIL and providing ‘on-site’ requirements such as open
space, access, utilities infrastructure/capacity reinforcement etc. necessary to support the ‘uplift’.
It is also acknowledged that any application for an ‘uplift’ in unit numbers will need to be supported by
technical information to demonstrate that the scheme can be accommodated within infrastructure limits,
or mitigations can be put in place (i.e. utility reinforcements) and without having a residual significant
environmental impact. An EIA Addendum may also need to be prepared, to consider the environmental
impacts of the uplift, taking into account cumulative effects, including recent planning commitments not
considered at the outline stage; new legislation and changes in baseline information

Response to GNLP Consultation – Policy EAS 1: Land South and East of Easton
Persimmon Homes (Anglia) supports the Greater Norwich Local Plan’s acknowledgement that the site
EAS1 : Land south and east of Easton is capable of accommodating additional housing units beyond the
previous allocation figure of 900 units. This is evidenced by the fact that a scheme of 890 units has been
permitted and a further scheme for 64 units is pending. However, it is not altogether clear how the figure
of 1,044 homes has been derived and what it is comprised of or what assumptions have been made.
Persimmon Homes (Anglia) notes that the Policy EAS 1 is partially updated to reflect additional housing
numbers permitted through the determination of the outline planning application (ref:2014/2611/O) and it is assumed likely to be permitted through the determination of the Orbit Homes planning application but these two figures do not equate to the Policy’s suggested housing figure.
Also, Persimmon Homes (Anglia) note that the rest of the policy’s ‘requirements’ remain unchanged from
the previous policy and appear to ignore the fact that planning permission has been granted (in the case
of the Orbit scheme is likely to be likely granted), with conditions and a section 106 obligations package
which renders many of the policy ‘requirements’ superfluous or obsolete, as they are already addressed.
Persimmon Homes (Anglia) considers that the Policy should be redrafted to reflect the fact that planning
consent has been granted; and that many of the policy requirements have been met through the
determination of the planning application and are no longer relevant to any potential future application(s).
It is accepted that there may be reticence to do this until the scheme has been lawfully commenced, but
Persimmon Homes (Anglia) are confident that this will be done prior to the adoption of the Local Plan.
However, notwithstanding the above, the Local Plan should also acknowledge that the site may be
capable of accommodating more than the suggested 1,044 units in the Policy. Persimmon Homes
(Anglia)’s experience at Hethersett and other strategic sites is that the need to make the best and most
efficient use of land often results in the housing numbers controlled by outline consents being met by
using less land than anticipated by the outline consent, resulting in land being available within the red
line of consented sites, which could reasonably accommodate further sustainable development.
Persimmon Homes (Anglia) suggests that the emerging Local Plan should not rule this opportunity out in
Easton and therefore suggests that the Policy’s housing figure could be specified as minimum or an ’at
least’ figure.

Suggested changes
Persimmon Homes (Anglia) suggests that rather than simply roll forward the previous Local Plan
allocation and Policy EAS 1: Land south and east of Easton in its entirety, the Local Plan should
acknowledge that the ‘allocation’, is now a committed site (i.e. with planning permission); and should be
notated as such and included in the settlement boundary; and that the Local Plan Policy EAS 1 should
be redrafted to only include requirements that are relevant to any future planning applications, not
requirements that are addressed by the consent’s conditions and/or associated Section 106 package. It
should also specify the housing figure as a minimum or an ‘at least’ figure, in the event that opportunities
arise for additional sustainable development within the allocation boundaries. The policy should not
compromise this potential opportunity.

Conclusion
In conclusion, Persimmon Homes (Anglia) supports the Local Plan’s acknowledgement that the site EAS
1: Land south and east of Easton is capable of accommodating additional homes beyond those identified
in the previous Site Allocations Plan (900 units) and as permitted by the outline consent (890 units) and
likely to be permitted (64 units). However, further clarity on how the housing target of 1,044 units has
been derived and what it consists of and any related assumptions should be provided.
Importantly, Persimmon Homes (Anglia) do not consider it appropriate for the Policy to be simply rolled
forward in its entirety without acknowledging that planning consent has been granted and that many of
the Policy’s requirements are met through the consenting process, as evidenced in the consent’s
planning conditions and the accompanying Section 106 agreement; and will be delivered through the
implementation of the scheme.
Persimmon Homes (Anglia) also suggests that the Policy’s housing figure should be expressed as a
minimum or ‘at least’ figure, in the event that through the consenting of reserved matters application(s)
making an efficient and best use of land, opportunities for further sustainable development within the
allocation boundary presents themselves in the future.
Persimmon Homes (Anglia) remain very happy to continue to work with the Authorities to clarify those
Policy EAS 1 requirements that remain relevant to any future planning applications, and those that are not, particularly those that have been/are being dealt with by the original consent’s conditions and s106
obligations package.