Object

Representation ID: 22261

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

Land off Townhouse Road, Costessey
Policy 7.1 contains the development strategy for the Norwich Urban Area and the fringe parishes. We object to the strategy for Costessey, in respect of the decision to make no allocations in the village and the sites identified as reasonable alternatives. A number sites have been identified as a reasonable alternative housing allocation at Costessey, including a strategic extension for +1,200 dwellings at land off Bawburgh Lane and New Road (Ref. GNLP0581) and land north of New Road and east of A47 (Ref. GNLP2043). The land off Townhouse Road in Costessey (Ref. GNLP0284R) is promoted for residential development, but it is considered that this site has been incorrectly identified as an unreasonable site in the GNLP Site Assessment document.
It is very unlikely that the strategic extension sites in Costessey identified as reasonable alternative would be delivered quickly enough to address a housing land supply shortfall in Costessey in the short term. The lead-in times for these types of developments are typically more than 5 years, largely because they are complex and require significant levels of primary infrastructure to be provided e.g. roads and drainage in advance of housing. On this basis, it is considered that the strategic extension sites in Costessey are not reasonable because they would not meet the purpose of a contingency site i.e. to meet non-delivery elsewhere. In addition, as set out in the representations to the Site Allocations document, there are identified constraints and uncertainties to development at the strategic extension sites in Costessey (Ref. GNLP0581 and GNLP2043), including access arrangements and proximity to the Norwich Southern Bypass. It has not yet been confirmed that these strategic extension sites are available or suitable for development, and as such they should not be identified as reasonable alternatives. Furthermore, the other identified reasonable alternative site in Costessey, at Roundwell Works (Ref. GNLP0593) would lead to the loss of employment land and the access arrangements have not been confirmed, and as such it may also not be a reasonable alternative site.
As set out in the representations to the Site Allocations document for Costessey sites, the promoted development at land off Townhouse Road in Costessey (Ref. GNLP0284R) is smaller than the strategic extension site, it is controlled by a housebuilder, and is available for development, and as such it could meet the requirements for a contingency site to meet non-delivery elsewhere. A number of technical reports and studies have been prepared for the site which demonstrate that there are no constraints to development and significant impacts can be mitigated, and concept plans have been prepared to identify different development options for the site i.e. 100, 130 and 200 dwelling options. The technical evidence demonstrates that landscape impacts can be mitigated by retaining existing trees and hedges, providing new areas of woodland and landscaping, and creating new areas of open space. The site is not affected by flood risk, and a drainage strategy would be prepared for the promoted development to manage surface water drainage. An area of open space would be created at the site frontage along Townhouse Road. Therefore, it is considered that land off Townhouse Road in Costessey (Ref. GNLP0284R) should be allocated in emerging GNLP or identified as a reasonable alternative site to meet future needs.