Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22983

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

Representation Summary:

ADDITIONAL HOUSING

Within the parish of Cringleford 1,200 homes were originally allocated through the Neighbourhood Plan 2014. At the base date of the Greater Norwich Local Plan 1,300 homes have been allocated, with consent granted for a further 61 homes. Cringleford was originally identified as a sustainable location to accommodate growth as there are good links to the University of East Anglia, Norfolk and Norwich University Hospital, and Norwich Research Park. As Cringleford is a fringe parish within the Norwich urban area it is at the top of the Sustainable Growth Strategy hierarchy identified in Policy 1 of the emerging Greater Norwich Local Plan. Therefore, the Part 2 - Site Allocations identifies an uplift in the number of homes allocated through the Cringleford Neighbourhood Plan of 360 dwellings across two existing site allocations (the balance of GNLP0307 and GNLP0327) to the southwest of the village.

BDW considers that it is right for the Sustainable Growth Strategy to focus development in areas around Norwich and it believes that Cringleford is an appropriate location for a proportion of this requirement. BDW’s site at Cringleford (GNLP0307) extends towards the A47 and includes the consented development site (identified above as phase one) and an additional 17.82ha of land (identified as phase two), that is mainly within the existing development boundary of the village.

The phase two land and the land to the southeast of site (GNLP0327), have been identified to accommodate the uplift of 360 additional homes that are proposed for Cringleford. BDW support the principle of the proposed uplift but believes that the uplift should be greater to reflect the development potential of its site. BDW believes that the phase two land will form a natural extension to the consented development and will assist in supporting and enhancing that new community by delivering a successful new and sustainable neighbourhood for Cringleford.

The Housing and Economic Land Availability Assessment 2017 (HELAA) that has been carried out confirms that there are no constraints to the development of the remainder of site GNLP0307, with it being identified as having utilities infrastructure and market attractiveness. Similarly, there are no constraints relating to sensitive townscapes, biodiversity, geodiversity and compatibility with neighbouring uses. The site is also seen positively with regards to open space and green infrastructure. Similarly, the adjacent site (GNLP0327) is also identified as having limited constraints to its delivery.

Given the positive assessment of our client’s site through the HELAA it is seen as an appropriate site to accommodate further development. However, our client is concerned that the number of homes allocated to their site is not based on a robust assessment of the capacity of the site. Moreover, it is unclear what the justification is for no more than 1,300 homes to be built within the Cringleford area prior to 2026. This approach does not appear to be based on any identified constraints in infrastructure capacity that would be resolved post 2026.

BDW believes that it would give greater flexibility to housing delivery across the Greater Norwich area if the uplift in the number of new homes proposed for Cringleford were increased and the arbitrary limit on the delivery the period was not applied. Especially as other allocations where greater infrastructure would be needed to enable housing to be built could suffer delays in the planning and delivery phases.

Given the significant number of new homes that the Greater Norwich Local Plan proposes to deliver our client is concerned that there has been insufficient assessment of the number of new homes that their site could deliver. On the approved development the 650 homes have been successfully planned at a density of 44dph. BDW has applied a similar density to the 11ha of net developable land that remains within site GNLP0327 and the Framework Plan shows that the most effective use of the land would be to accommodate approximately 500 dwellings. However, the proposed uplift in the allocation would result in the phase two site and the adjacent site GNLP0327 delivering the 360 additional homes at a density of approximately 26dph, including all the necessary road and drainage infrastructure, public open space and land to accommodate the primary school site.

The figure of 26dph falls well below the 40dph identified for sites in the Norwich urban area under Policy 2 of the emerging Greater Norwich Local Plan. The Norwich urban area is at the top of the hierarchy of the Councils’ Sustainable Growth Strategy and as such sites within it must maximise their development potential. The approach to increasing densities in sustainable locations is in accordance with the requirements of paragraphs 122 and 123 of the National Planning Policy Framework (NPPF) and has been accepted for other development sites in the Cringleford Neighbourhood Plan area.

In order to demonstrate the capacity of their site BDW has carried out additional work that confirms that any constraints to the delivery of the additional land can be overcome. Therefore, the site is an ideal location for the Greater Norwich Local Plan to focus further growth in order to limit the risk of homes to be allocated through other plan processes not coming forward.

Full text:

For full representation, please refer to the attached documents.