Comment

Representation ID: 22999

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

RESPONSE TO HELAA OUTCOMES

The HELAA identifies that there are no significant constraints to the delivery of our client’s site. Accordingly, a number of the constraints are labelled as ‘green’, whereas others are identified as ‘amber’ in the Stage 2 HELAA Comparison Table. Where a constraint has been identified as amber BDW has provided additional information to demonstrate how the constraint can be successfully mitigated.

Site Access
Whilst the HELAA identifies access as an amber there are alternative ways by which the phase 2 site could be accessed by vehicular traffic. The Framework Plan for the site includes access through the Kier land, off the Round House Way roundabout, and at two locations through phase one. The site would be within 1km of Cringleford Primary School with an access onto Round House Way and connection to Dragonfly Lane. There is likely to be a need for an improved crossing over Round House Way and the HELAA identifies that is could be feasible and viable depending on scale of development.

Access to Services
The HELAA acknowledges that the site is within walking distance of Cringleford and the Norwich Research Park, which is a significant employment area and is well connected by local bus services. Moreover, the wider site will also accommodate a new primary school to meet the needs of the developments in this area. This is in addition to the site being within 1km from the Cringleford Primary School and the Willow Centre once an access is provided onto Round House Way.

Utilities Capacity
The consented development on phase one of the Newfound Farm site, and other developments in the area, will result in enhancements to the capacity of existing utilities serving this part of the village. BDW has carried out initial, high-level assessments of the increases in capacity for utilities and do not consider that there are any abnormal costs that would result in a constraint to the delivery of the phase two site.

The HELAA identifies potential constraints relating to wastewater treatment work capacity and sewer capacity in particular. However, these can easily be resolved through infrastructure improvement works.

If the Councils consider the costs of utilities provision to be a potential constraint then this further reinforces our client’s view that the development potential of the sites needs to be maximised through increasing the density so that any costs of enabling works do not impact negatively on the level of affordable housing that is provided.

Contamination/Ground Stability
When considering the outline application for the phase one scheme conditions were attached to the planning consent to address matters relating to ground contamination. These conditions (nos. 32 and 34) required a scheme to deal with the risks associated with ground contamination and a long-term monitoring and maintenance plan to be submitted for approval in writing by the Local Planning Authority. A Phase 2 Geo-Environmental Assessment Report and a Contamination Monitoring and Maintenance Plan were subsequently submitted under ref. 2016/2695 and were approved on 16th November 2016. In addition to the conditions that required formal discharge before development commenced on site, Condition 35 requires a remediation strategy to be submitted for approval if contamination is found on site.

The above approach to dealing with issues of ground contamination through planning conditions on phase one would also be an acceptable and recognised approach for dealing with any such issues on the phase two land.

Flood Risk
There are no comments from the Lead Local Flood Authority to the HELAA. However, the HELAA identifies that whilst there are bands of surface water flood risk the majority of the site is free from any flood risk. The Environment Agency map for the area shows that the site falls within Flood Zone 1, which means that it is the lowest risk of flooding from watercourses. Notwithstanding this, the bands of surface water identified in the HELAA can be easily mitigated through the planning of the site and the Framework Plan accommodates space for SuDs features to be an integral part of the site’s development.

Significant Landscapes
Cringleford Parish Council object to allocation of the remainder of the site as it is constrained by the southern bypass protection zone and strategic gap between Hethersett and Cringleford. They also raise the issue of the high-tension electricity cables crossing the site on pylons. The Landscape Overview produced by CSA and the Framework Plan demonstrate how residential development with open space and associated infrastructure can be accommodated at the Site without giving rise to any significant landscape or visual effects. Moreover, the Framework Plan demonstrates how the site can successfully accommodate approximately 500 new homes whilst still maintaining the strategic gap between Hethersett and Cringleford. The Framework Plan also turns the constraint of the high-tension electricity cables crossing the site into an opportunity to accommodate public open space beneath the pylons.

As the proposed uplift area includes land within the existing settlement boundary of Cringleford the densification of the remainder of site GNLP0327 will not have a detrimental impact upon any significant landscape or reduce the strategic gap between Hethersett and Cringleford. In fact, the development of the site will ensure that the landscaped area adjacent to the A47 will be maintained in perpetuity for use as a public amenity area for new and existing Cringleford residents. This will help to secure the retention of this part of the strategic gap and maintain a green buffer to the edge of Cringleford.

The site is not covered by any statutory or non-statutory designations for landscape character or quality and the Landscape Overview considers it to be of medium/low landscape quality and value and of medium sensitivity. This Landscape Overview concludes that the Site is generally well contained in views from the surrounding landscape due to the combination of topography, built form and existing vegetation and that views of the site are generally restricted to the near distance. The Framework Plan illustrates how existing vegetation and new planting will form an integral part of the development and will play an important role in minimising any localised visual impacts. The Framework Plan also illustrates how the Site could accommodate residential development at a density of 44dph without materially impacting upon the landscape character of the immediate area.

Transport and Roads
With growth already being successfully accommodated at Cringleford there are improvements to sustainable travel routes that will ensure that future and existing residents’ reliance on the use of the private car will be reduced. This reduction in car dependency will also help reduce the negative impacts that unsustainable modes of travel have on climate change through increased greenhouse gas emissions. Moreover, through the promotion of walking, cycling and public transport residents will experience more positive interactions with each other and other residents of Cringleford and beyond than if they were reliant on private cars to meet their daily needs.

Our client supports the promotion of a greater shift towards non-car modes of travel in the Norwich urban area by focussing high density growth in locations with good access to sustainable transport networks. Cringleford is identified as a fringe parish that as part of the Norwich urban area is a location where higher densities should be promoted to help achieve this shift.

The Framework Plan that has been produced demonstrates how the development of the site will promote walking and cycling. The provision of a green corridor through the site towards the Norfolk and Norwich University Hospital will encourage this as a safe route for pedestrians and cyclists to this major employment site. The Framework Plan also demonstrates the potential for the site to safeguard land for a pedestrian footbridge over the A47.

In addition to the improvements to sustainable travel networks the Travel Plans required for new residential developments in the village will help promote sustainable travel for residents as they move into new homes. All the forms of mitigation, which have been used to mitigate the impacts of the phase one scheme, can be extended to the phase two area to ensure that the impacts upon existing roads are mitigated through the promotion of sustainable modes of travel.

Other matters
The HELAA states that ‘A significant part of the site (around 65%) already has planning consent.’ and considers that potential noise and pollution issues from proximity to the A47 would need to be considered. The additional work supplied with this representation has considered this and identified that there is an additional 11ha of net developable area of 11ha within site GNLP0307 that could be developed.

As already noted earlier, the phase one development produced a successful scheme at 44dph. This is in contrast to the 26dph that would be delivered if the uplift in the number of new homes were restricted to only 360 across the balance of site GNLP0307 and site GNLP0327. The net developable area that we have identified for the phase two of site GNLP0307 would deliver approximately 500 homes if it were developed at a density similar to that approved on phase one.

Whilst there is no evidence of statutory consultees carrying out any detailed assessment of noise or air quality BDW has taken this opportunity to clarify whether either of these matters would be a constraint to the development of the site and considers how they can be successfully mitigated.

Noise
As a result of the noise modelling that was been carried out for the Acoustic Assessment to support the discharge of condition 38 our client is confident that the majority of the new homes within the site will be subject to acceptable noise levels without the need of additional mitigation. To demonstrate this is the case the Technical Note produced by MLM confirms that the dwellings facing the A47 will provide mitigation for those dwellings and gardens behind them. In order to make acceptable living conditions for the dwellings facing the A47 additional mitigation will be required. This mitigation will be achieved either by improving the building envelope of these dwellings or the introduction of a noise barrier and/or bund within the landscaped area near to the A47. These forms of mitigation would be primarily in order to reduce night-time noise levels at first floor bedrooms. To make any bund and/or barrier most effective it would need to be as close to the A47 as possible, which can be achieved within the landscaped area to the southeast of the site. Given that any barrier and/or bund would be located within this landscaped area there is the potential for it to be softened with additional landscaping so that it maintains a rural edge to the village.

The strategy for the consented scheme on phase one also used the dwellings facing the A47 to act as mitigation for the dwellings and garden area behind them. These dwellings then require additional mitigation, which was considered acceptable. Therefore, by using this same approach for the phase two area the dwellings in the consented scheme would be protected from noise without the need for this additional mitigation.

In order to provide acceptable internal noise levels for the dwellings facing the A47 the most likely approach would be upgrading the building envelope and applying a strategy for the glazing and ventilation of these properties. The detailed design of these dwellings would still ensure that their private amenity areas were protected from noise and that the use of habitable rooms were not constrained by the issue of noise.

The use of the landscaped strip immediately adjacent to the A47 as a public space would benefit from the introduction of a noise barrier and/or bund to make it a more acceptable environment for residents’ recreational use. Notwithstanding this, the Framework Plan also includes an area of public open space between the phase one and phase two. This would allow residents to have an alternative public open space to use, where noise levels would be significantly less than those adjacent to the A47 if the noise barrier or bund were not necessary to mitigate noise impacts for the dwellings facing the A47.

The Technical Note produced by MLM demonstrates that noise from the A47 is unlikely to be a significant constraint for the development of the phase two area of site GNLP0327. Moreover, the proposed strategy to mitigating the impact would be the same whether the site was to accommodate a proportion of the proposed 360 uplift or the 500 homes that our client believes it can deliver. If as a result of further detailed noise work the preferred option is to provide a sensitively screened noise barrier and/or bund near to the A47 then this would have cost implications for the development. Therefore, by allocating additional homes on the site, and making the most efficient use of the land, it would also help to limit the impact upon viability of any potential strategies to mitigate the impact of noise.

Air Quality
BDW has instructed MLM to carry out a review of local authority monitoring data and Defra background data, which indicates that the existing concentrations of NO2, PM10 and PM2.5 are ‘well below’ the relevant NAQOs. In future years, air quality is anticipated to improve further due to improvements in vehicle emissions and it is therefore expected that the future air quality at the site would comply with all relevant NAQOs.

The Technical Note on air quality concludes that future residents and users of the phase two site will not be exposed to poor air quality and mitigation measures to reduce air pollution exposure, such as mechanical ventilation, are not considered to be necessary.

Ecology
Whilst not specifically raised as an issue in the HELAA a Preliminary Ecological Appraisal (PEA) of the site has been carried out to identify any potential ecological constraints to the development of the phase two site.

As part of the PEA, a desk study and extended Phase 1 Habitat survey of the site were undertaken in February 2020. As the site predominantly comprises arable fields the greatest ecological interest within the site is found within the hedgerows and a small area of semi-improved grassland between the arable fields. The retention, protection and enhancement of the ecological features is to be prioritised within the development proposals and the Framework Plan demonstrates how this can be achieved.

Primary School Site
The need to safeguard an area of land for a school is acknowledged and applications refs. 2013/1793 2018/1389 already accommodate a 1ha site for a new primary school. The Framework Plan shows a further 1ha to accommodate a logical expansion of the primary school site. Whilst the HELAA identifies that the additional growth planned for Cringleford means that the school site may need to increase in size, with a consequent reduction in the number of additional homes that could be accommodated on the GNLP0327 site, it also acknowledges that an equivalent alternative provision could be agreed with the education authority.

Our client does not believe that any additional land will be required for the expansion of the primary school over and above the 2ha that has been safeguarded. However, if additional capacity were required to accommodate the uplift in numbers on their site then BDW would be willing to have discussions with the education authority to agree how best to deliver the additional capacity.