Comment

Representation ID: 22870

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

WCP

SA Objective 1 – Air Quality and Noise notes that development at WCP could potentially expose site end users to higher levels of transport associated air and noise pollution. Traffic using the A47 and A146 would be expected to have a minor negative impact on air quality and noise at these sites. We propose that WCP is safeguarded for future country park-related development.

Railway Line: The north of Site GNLP3052 is located adjacent to a railway line. The proposed development at this site could potentially expose site end users to higher levels of noise pollution and vibrations associated with this railway. A minor negative impact would therefore be expected.

Air Pollution: The SA nots that WCP is proposed for non-residential end use and comprises 220.3ha. The proposed development at this site could potentially result in a significant increase in local air pollution; therefore, a major negative impact would be expected. However, this seems to assume that some form of high density commercial development is proposed, whereas we are proposing to safeguard the site for open space and leisure uses. The masterplanning for the site could achieve benefits in air pollution terms and the SA should therefore record a positive impact.

SA Objective 2 – Climate Change Mitigation and Adaptation. In terms of Fluvial Flooding, the SA notes that the north of the site is adjacent to Whitlingham Great Broad and located within Flood Zones 2, 3a and 3b, such that proposed development could potentially locate some site end users in areas at risk of fluvial flooding; therefore, a major negative impact would be expected. However, the extensive nature of the site means that any proposed leisure development can be located such that users are kept away from areas at risk of fluvial flooding. Therefore the SA should record a positive impact in relation to site GNLP3052.

Surface Water Flooding: Small areas within the site coincide with areas determined to be at low, medium and high risk of surface water flooding. Development would be expected to have a major negative impact on pluvial flood risk, as development would be likely to locate site end users in areas at high risk of surface water flooding, as well as exacerbate pluvial flood risk in surrounding locations. However, this assumes significant built development and significant ground coverage which is not the case. The appropriate design and management of the extensive green space will facilitate on-site flood attenuation, with knock-on reduction in risk to surrounding locations as a result of controlled run-off, such that the SA should record a major positive impact.

SA Objective 3 – Biodiversity, Geodiversity and Green Infrastructure. SSSI IRZ: This section of ‘The Broads’ SAC and ‘Broadland’ SPA and Ramsar is also designated as ‘Yare Broads and Marshes’ SSSI. The site is located within an IRZ which states that “all planning applications (except householder) outside or extending outside existing settlements/urban areas affecting greenspace, farmland, semi natural habitats” should be consulted on. The SA assumes a minor negative impact on the features for which these SSSIs have been designated would be expected, due to development on natural greenspace. However, our proposal is to safeguard the additional WCP land for country park use, which can only benefit biodiversity, both by providing / protecting it on site, and by providing space for leisure use, thus reducing human pressure on designated habitats elsewhere.

LNR: Site GNLP3052 coincides with ‘Whitlingham’ Local Nature Reserve. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park, which is coincident with this LNR. As this site is proposed for tourism and a Country Park, it is assumed that the developable area of the site will exclude the LNR itself, and therefore, a negligible impact on this LNR would be expected. We agree with this assessment.

CWS: Site GNLP3052 coincides with ‘Old Wood’, ‘Trowse Wood’ and ‘Trowse Meadows’ CWSs. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park, which is coincident with these CWSs. As this site is proposed for tourism use and a Country Park, it is assumed that the developable area of the site will exclude these CWSs, and therefore, a negligible impact on these CWSs would be expected. We agree with this assessment.

Priority Habitats: Site GNLP3052 coincides with deciduous woodland, coastal floodplain grazing marsh, and good quality semi-improved grassland priority habitats. The proposed development is considered by the SA to be likely to result in the partial loss of these habitats, and therefore, have a minor negative impact on the overall presence of priority habitats in the Plan area. However, the safeguarding of this site for additional country park usage means that habitats can both be safeguarded and created, leading to net gain.

SA Objective 4 – Landscape. National Park/Country Park: The majority of Site GNLP3052 coincides with The Broads National Park. A proportion of this area also coincides with Whitlingham Country Park. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park. The nature and exact location of the proposed development is unknown at this stage and therefore the impact on this National Park and Country Park is uncertain. Our proposal is to safeguard the site for country park usage, which can only benefit the country park as a whole.

Landscape Character: The majority of Site GNLP3052 is located within the LCA ‘Yare Valley Urban Fringe’. Some key characteristics of this LCA include the wide, flat floodplain, recreational landscape and green buffer between the river valley and Norwich City. Site GNLP3052 is proposed for recreation and tourism end use, and therefore, the proposed development at this site would be unlikely to be discordant with these key characteristics. We agree with this assessment.

Views from the PRoW Network: Site GNLP3052 coincides with a PRoW. Development could potentially alter the views experienced by users of the PRoW network; therefore, a minor negative impact on the local landscape would be expected by the SA. However, altered views are not necessarily altered in a negative way, and the impact should be recorded as neutral.

Views for Local Residents: Site GNLP3052 is located adjacent to the settlement of Trowse Newton. The SA considers that development would be likely to alter the views experienced by residents of surrounding dwellings to some extent, and therefore, a minor negative impact on the local landscape would be expected. However, as noted above, altered views are not necessarily altered in a negative way, and the impact should be recorded as neutral.

SA Objective 6 – Population and Communities. Local Services: The nearest local services WCP are Trowse Village Store in Trowse Newton, or Morrisons supermarket within Norwich City. The site is located outside the target distance to these services. The proposed development at these two sites could potentially have a minor negative impact on the access of site end users to local services. However, residential development is not proposed at this site, which is intended to be safeguarded for country park related development, thus a neutral impact should be recorded.

SA Objective 8 – Health. Main Road: the site is located adjacent to the A47, where development could potentially expose site end users to higher levels of traffic associated emissions, which would be likely to have a minor negative impact on the health of site end users. However, this assumes residential development, whereas we propose that the site is safeguarded for country park uses, and should therefore expected to have a minor positive impact on health.

GP Surgery: The closest GP surgery to the site is Lakenham Surgery, located approximately 1.5km to the north west, outside the target distance such that the SA assumes development would be expected to have a minor negative impact on the access of site end users to GP surgeries. However, the site is proposed for country park related uses, not residential development.

As the site is located outside the target distance to an NHS hospital, GP surgery and leisure centre, development would be expected to have a major negative impact on the health and wellbeing of site end users. However, the site is proposed for country park related uses, not residential development, such that these services would not be required on a day to day basis, and country park usage would have a positive impact on health in itself.

SA Objective 11 – Economy. Employment Floorspace: the site is proposed for tourism end use. This would be expected to result in the provision of employment opportunities in the local area, and therefore, a major positive impact on the local economy would be expected as a result of development at these four sites. Site GNLP3052 currently coincides with ‘Kingsley Farrington Boatyard’ and ‘Norfolk Snowsports Club’. Site GNLP3052 is proposed for tourism end use and it is assumed that the development will incorporate these existing facilities, and therefore, would be expected to result in a net gain in employment floorspace overall. We agree with this assessment.

SA Objective 12 – Transport and Access to Services. Bus Stop: the site is outside the target distance to a bus stop providing regular services. Therefore, the proposed development at these three sites could potentially have a minor negative impact on site end users’ access to bus services. However, this could change with the significant amount of development proposed for this part of Norwich and with the development of the Loddon P&R site we are promoting.

Railway Station: The closest railway station to the site is Norwich Railway Station, located approximately 3km to the north west. A large proportion of the site is situated outside the target distance to this station. Therefore, the proposed development at these two sites would be likely to have a minor negative impact on site end users’ access to rail services. However, we anticipate that the country park usage would be mainly beneficial for local users.

Pedestrian Access: The site is well connected to the existing footpath network. Development would be expected to have a minor positive impact on site end users’ access to the PRoW network and opportunities to travel by foot. We agree with this assessment.

SA Objective 13 – Historic Environment. Grade I Listed Buildings: The site is located approximately 40m from the Grade I Listed Building ‘Church of St Andrew’. The proposed development at this site could potentially alter the setting of this Listed Building, and therefore, a minor negative impact on the local historic environment would be expected by the SA. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Grade II* Listed Buildings: The site is located adjacent to the Grade II* Listed Building ‘Whitlingham Hospital Blocks 04, 05, 06’ and within 200m from several Listed Buildings along Yarmouth Road including ‘Thorpe Hall’ and ‘Walpole House’, but is separated from these Listed Buildings by the River Yare and woodland. Development at this site could potentially alter the setting of ‘Whitlingham Hospital Blocks 04, 05, 06’ and therefore a minor negative impact on the local historic environment would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Grade II Listed Buildings: Site GNLP3052 coincides with the Grade II Listed Building ‘Ruins of Trowse Newton Hall’ and is located adjacent to ‘Whitlingham Hospital Service Buildings, Block 03’, ‘Boundary wall and gateway at Whitlingham Hospital’, ‘Sunnydale’ and ‘Trowse Old Hall’. The proposed development at this site could potentially result in direct impacts on ‘Ruins of Trowse Newton Hall’ and therefore a major negative impact on the local historic environment would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Conservation Area: A small proportion of Site GNLP3052 coincides with Trowse with Newton Conservation Area. Therefore, the SA suggests development at this site could potentially alter the setting of this Conservation Area, and as such have a minor negative impact on the local historic environment. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Registered Park and Garden: Site GNLP3052 coincides with ‘Crown Point’ RPG. Development at this site could potentially have a direct impact on this RPG and therefore a major negative impact would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the RPG.

SA Objective 14 – Natural Resources, Waste & Contaminated Land. Previously Developed Land: All sites in this cluster comprise previously undeveloped land. Site GNLP3052 comprises 220.3ha of previously undeveloped land. The scale of development at this site is unknown at present, however, the proposed development could potentially result in a major negative impact on natural resources due to the loss of 20ha or more of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils. We disagree with this assessment, since our proposal relates to country park usage not extensive tracts of built development.

ALC: Site GNLP3052 is situated on ALC Grades 3 and 4 land. ALC Grade 2 and 3 are considered to be some of Greater Norwich’s BMV land. Therefore, a minor negative impact would be expected as a result of the proposed development at these four sites, due to the loss of this important natural resource. This assumes that the land would be built over, or would be available for agriculture, whereas we are proposing to safeguard the land for country park related uses, which are essentially reversible, such that a neutral impact should be recorded.

SA Objective 15 – Water B.52.15.1 SPZ: Sites GNLP3051, GNLP2069 and GNLP3049 coincide with the catchment (Zone III) of a groundwater SPZ. Site GNLP3052 coincides with the inner zone (Zone I), outer zone (Zone II) and catchment of a groundwater SPZ. The proposed development at these four sites could potentially increase the risk of groundwater contamination within this SPZ, and therefore, result in a minor negative impact on local groundwater resources

Watercourse: Site GNLP3052 is located adjacent to the River Yare, with a proportion of the site located within 200m of this watercourse. Development could potentially increase the risk of contamination of this watercourse, and therefore, a minor negative impact would be expected. However, contamination is unlawful, and planning controls exist to ensure any surface water drainage is carried through stages of filtration before any outfall into rivers. Given the proposed country park related uses, the SA should therefore record a neutral impact.