In conclusion, with corrected scores for the land south of Le Neve Road (Site Ref. GNLP2143) and land at Fengate Farm (Site Ref. GNLP3035), the Fengate Farm site scores better or equivalent to the Le Neve Road site for most sustainability objectives, and substantially better for landscape and historic environment topics. In these circumstances, the SA should have recommended that the Fengate Farm site is allocated in Draft GNLP as an alternative to land south of Le Neve Road, and this should have been the outcome if the SA were to meet the aim of making Draft GNLP more sustainable. It is not clear why the SA has favoured a greenfield site (at land south of Le Neve Road) in preference to a vacant and unused site (at Fengate Farm) for allocation in Marsham.

Sustainability Appraisal

A key aim of the Sustainability Appraisal (SA) process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies. The main concern of Noble Foods Ltd with the SA process for Draft GNLP is that the findings of the assessment for some sites are not robust, including for land south of Le Neve Road in Marsham which is a proposed allocation (Site Ref. GNLP2143) and for land at Fengate Farm which is identified as an unreasonable alternative in the site assessment process (Site Ref. GNLP3035). The findings of the SA assessments and updated commentary for Site Ref. GNLP2143 and Site Ref. GNLP3035 are submitted with these representations.

GNLP2143 - Land south of Le Neve Road, Marsham

It is noted that the assessment of the site in the SA identified development at this site as having a ‘minor negative’ impact on landscape and a ‘negligible’ impact on historic environment.

Noble Foods Ltd instructed consultants to assess the heritage and landscape impacts of the proposed development at land south of Le Neve Road. The Heritage Report (prepared by Orion Heritage) and the Landscape Appraisal (prepared by FPCR) are submitted with the Noble Food Ltd representations to Draft GNLP.

It is concluded in the Landscape Appraisal that development at land south of Le Neve Road would have an unacceptable impact on the character and appearance of the open land that currently forms part of the setting of the village and the church, and it is unlikely that landscape mitigation would address the visual harm. Therefore, the ‘landscape’ score for this site is not correct and should be amended from ‘minor negative’ to ‘major negative’.

It is concluded in the Heritage Report that development at land south of Le Neve Road would adversely impact the setting and landmark qualities of the church tower at All Saints Church (Grade I Listed Building), and that even with landscape mitigation measures the proposed development would be perceived in key views of the church. Therefore, the ‘historic environment’ score for this site is not correct and should be amended from ‘negligible’ to ‘major negative’.

It is requested that the assessment of land south of Le Neve Road in Marsham (Site Ref. GNLP2143) in the SA is corrected, with ‘major negative’ scores identified for landscape and historic environment objectives. It is considered that with ‘major negative’ impacts for landscape and historic environment objectives, it should have been concluded in the SA that this site should not be allocated, particularly when an alternative site with no significant impacts is available. As set out above, a key aim of the SA process is to make Draft GNLP more sustainable, including to avoid significant environmental impacts.

Site Ref. GNLP3035 Fengate Farm, Marsham

The site contains vacant buildings and areas of hardstanding, and as such it does not reflect the landscape characteristics of the ‘Marsham and Hainford Wooded Estateland’ LCA. The area of woodland within the site and the trees and hedgerows at the site boundary would be retained as part of the promoted development. The promoted development would include a landscape buffer. The Landscape Report (prepared by FPCR) demonstrates that the Fengate Farm site makes a very limited contribution towards visual amenity of the village and the wider rural landscape. It is suggested that the promoted development would result in minimal harm to views from the wider landscape or the surrounding settlement. Therefore, the ‘landscape’ score for this site is not correct should be amended from ‘minor negative’ to ‘minor positive’.

There are listed buildings located on the High Street in Marsham, but the site has no relationship with the setting of these listed buildings, and in any event, it currently contains vacant buildings associated with the previous poultry unit. It has been assessed that development at the site would have a ‘negligible’ impact on the historic environment topic; it is noted that this score is substantially better than the ‘major negative’ score (as corrected) for the proposed allocated site at land south of Le Neve Road (Site Ref. GNLP2143).

The site is located close to local public footpaths and open spaces and it is not close to an AQMA. The promoted development would include open space and a playground. The SA methodology states that a site must exceed the distance thresholds for all the stated health facilities to score ‘major negative’. However, the Fengate Farm site is located approximately 200m from the Velocity gym and Mayhem soft play centre. Therefore, the ‘health’ score for this site is not correct and should be amended from ‘major negative’ to ‘minor negative’.

In conclusion, with corrected scores for the land south of Le Neve Road (Site Ref. GNLP2143) and land at Fengate Farm (Site Ref. GNLP3035), the Fengate Farm site scores better or equivalent to the Le Neve Road site for most sustainability objectives, and substantially better for landscape and historic environment topics. In these circumstances, the SA should have recommended that the Fengate Farm site is allocated in Draft GNLP as an alternative to land south of Le Neve Road, and this should have been the outcome if the SA were to meet the aim of making Draft GNLP more sustainable. It is not clear why the SA has favoured a greenfield site (at land south of Le Neve Road) in preference to a vacant and unused site (at Fengate Farm) for allocation in Marsham.