Comment

Representation ID: 22712

Received: 03/04/2020

Respondent: CODE Development Planners Ltd

Notwithstanding the support for the general approach and settlement hierarchy, (Policy 1) the distribution of new allocations with 1,400 at Tavenham and none at Hellesdon or directly adjacent to the built edge in the adjacent parish of Horsford is objected to. As demonstrated in our representations in relation to sites GNLP0332R and 0334R the conclusions to allocate sites for such a large proportion of the overall plan need is not justified as required by paragraph 35 of the NPPF.
Policy 7 also confirms a concentration of a further large proportion of the plan's new allocations (1,220) on three complex sites in the East Norwich Strategic Regeneration Area in addition to an existing as yet undelivered commitment (780). It is essential that the plan recognises the clear likelihood that suitable and deliverable urban edge sites within the hierarchy may be required to meet any shortfall in the delivery of such complex sites.
Reference accompanying Position Statement and appended reports
- Landscape and Visual Appraisal prepared by Robert Myers Associates (March 2020)
• Landscape Report (incorporating Illustrative development framework plan) prepared by Robert Myers Associates (March 2020)
• Heritage Desk Based Assessment prepared by Orion (May 2019)
• Tree Survey and Constraints Plan prepared by Hayden's (February 2020)
• Preliminary Ecological Appraisal prepared by Wild Frontier Ecology (June 2019)
• Bird Hazard Risk Assessment prepared by Airfield Wildlife Management Ltd (July 2019
• The Monitoring and Management of Gulls on Commercial and Industrial Buildings in the Vicinity of Norwich International Airport prepared by Airfield Wildlife Managements Ltd (July 2019)
• Surface Water Drainage Strategy prepared by Richard Jackson Engineering Consultants (March 2020)
• Access and Transportation Strategy prepared by Richard Jackson Engineering Consultants (March 2020)