Object

Representation ID: 22137

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Whilst the positivity of the site assessment is welcomed it is disappointing that the site is not a proposed allocation.

The modest development of 24 retirement living units would have a very limited impact on traffic in Diss. Notably as retirement units are proposed any traffic movements would be more likely to occur outside of the AM and PM peak hours and be at a reduced frequency. The development of the site would also enable the opening up of the site for public access, enhancing the value of the open space and increasing the biodiversity value of the land would be a significant benefit to the residents of Diss.

It is our contention that additional growth should be accommodated in the Main Towns within the proposed Local Plan period, and as such, sites such as this should be allocated to allow for this anticipated additional growth. Furthermore, there is a need to identify sites to meet the needs of an ageing population and more sites like our clients site need to be allocated to cater for this particular demographic need. The site is also considered to be the most centrally located site to have been put forward for consideration for development within Diss and as such has to be considered a highly sustainable location and will reduce the risks of coalescence.

the Local Planning Authority will need to consider the site’s existing designation as an ‘Important Local Open Space’. Currently, there is no public access to the space, and due to the site’s enclosure by the surrounding land uses, its contribution to visual amenity is not significant. It is normal for areas of land designated as open space to have a demonstrable public value that is often associated with a sporting or recreational use that provides the area with a more significant visual amenity role.

Whilst the current proposal at the site would result in a minor quantitative reduction in overall amount of open space in the town, in terms of a qualitative assessment, it would provide significant public benefits, especially by enabling public access to at least 50% of the existing area.

Further to the above, Scott Properties has prepared a scheme for the site that would see it developed for a modest development of 24 retirement bungalows, in a sensitive landscape setting whilst also enabling public access that is not currently available to a site that is considered an important local space. The development of 24 single storey dwellings would equate to the development of 45% of the site and will fulfil a specific housing need that is not being met by other sites proposed for allocation within Diss.

The development would also potentially allow residents to downsize and introduce a compatible built form which would respect the existing landscape features. It would also allow for a positive natural surveillance of the new publicly accessible space. In respect of the impact of the development on adjoining residential properties, being single story bungalows any adverse impacts through overshadowing or overlooking would be minimal.

The modest scale of development proposed in such a sustainable location, would also comply with the spirit of paragraph 68 of the NPPF which acknowledges the contribution that small and medium sized sites can play in meeting the housing requirement of an area. It is noted that the two new proposed allocations are for much larger sites of 200 homes, therefore the inclusion of this site would provide the plan with greater flexibility, noting that sites DIS1 and DIS2 were allocated in 2015 and are yet to be developed. Furthermore, the development of retirement living units would make an important contribution to meeting the needs of the ageing population. This proposed allocation represents truly sustainable development with significant social and environmental benefits.

Scott Properties has discussed their proposals with Diss Town Council, Diss and District Neighbourhood Plan Steering Group and the local community through a public consultation event in July 2019, and listened to their feedback. As noted in the Town Council’s consultation response, there has been a lot of local objection to the proposals on environmental grounds, however, this does not acknowledge that the site is currently in private ownership with no public access and as such the owners have a free hand over its future agricultural use and management. Furthermore, Scott Properties has been working with Natural England on the steering group for the Developing with Nature Toolkit for small and medium sizes sites, and early indications show that a significant increase in biodiversity net gain (20%+) could be achieved through sensitive development of the site alongside targeted new habitat creation.

The site is in a single ownership, it is therefore achievable as there are no complex land ownerships or legal issues to compromise its ability to come forward for development. It is available now and would represent a realistic and deliverable development in the current market conditions.

We believe that the Greater Norwich Local Plan should reconsider this site and include it as an allocation in the Regulation 19 version of the Plan. The site is deliverable, suitable, and achievable and will bring much needed new housing for older people in a central location in Diss.

(For full representation, please refer to attached document including agent's suggested policy wording, images and plans)