Object

Publication

Representation ID: 24350

Received: 22/03/2021

Respondent: Jarrold and Sons Ltd

Agent: CODE Development Planners Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Please see attachment for details of full representation.

These representations are submitted on behalf of Jarrolds & Sons the owners of land to the rear of Heath Crescent (identified in the Greater Norwich Local Plan (GNLP) evidence base documents as site GNLP2173). The site is bound to the north by Fifers Lane, an industrial
estate to the east and residential dwellings along Heath Crescent and Prince Andrew’s Road to the west, and Prince Andrew’s Close to the south.

The site at Heath Crescent has been assessed in the GNLP Site Assessment: Norwich and Urban Fringe - Hellesdon Booklet as a reasonable alternative site for residential development (reference GNLP2173).

4 Conclusions
4.1 Jarrold & Sons also considers the GNLP fails the test of soundness when assessing whether it is justified. In order to be justified the plan should be an appropriate strategy, taking into account the reasonable alternatives and based on proportionate evidence. There is insufficient evidence to justify decisions in the GNLP. Decisions that have been made are based on
inaccurate and misleading information.
4.2 These representations demonstrate that the GNLP is not legally compliant and fails the tests of soundness.
4.3 Currently the GNLP seeks in part to delegate decisions regarding the spatial representation of
the infrastructure requirements to support growth, principally sport, recreation and open space designations, to the development management DPDs. However, this fails the tests of soundness as it has impacted the GNLPs policy justifications and effectiveness. Furthermore,
it does not provide a strategy which seeks to meet the areas needs consistent with achieving sustainable development; the residential allocations are not supported by an up to date assessment of the need for sport, recreation and open space. The GNLP is therefore not positively prepared.
4.4 In order to remedy this the SA needs to be amended and reassess strategy and site allocation policies. The GNLP Site Assessment Booklets should be amended to follow and reference the SA assessment. These amendments will lead to amendments to the policies and supporting text contained in the GNLP. Consequently, further formal public consultation will be required.

Change suggested by respondent:

a) In order to remedy the legal failings the SA needs to be amended and reassess strategy and site allocation policies.
b) The GNLP Site Assessment Booklets should be amended to follow and reference the SA assessment.
c) These amendments will lead to amendments to the policies and supporting text contained in the GNLP. Consequently, further formal public consultation will be required.

Full text:

• Response form submitted on behalf of Jarrold & Sons in respect of land to the rear of Heath Crescent.
• Drawing CH17/LBA/455/LP-1-100: Location Plan
• Transport Appraisal (including proposed access drawing) (January 2020) prepared by WSP
• Preliminary Landscape and Visual Overview (March 2020) prepared by Tyler Grange
• Ecology Report (March 2020) prepared by Wild Frontier Ecology
• Drawing 60312-PP-003 revision A extracted from the Surface Water Drainage Strategy and Flood Risk (January 2020) prepared by Richard Jackson
• Initial Site Noise Risk Assessment (February 2020) prepare by Adrian James Acoustics
• Archaeological Desk-Based Assessment (January 2020) prepared by RPS
• Arboricultural Assessment (February 2020) prepared by Oakfield Arboricultural Services
• Drawing CH17/LBA/455/FL-1-100 revision A: Proposed Proving Layout – Option A
• Drawing CH17/LBA/455/FL-1-101 revision B: Proposed Proving Layout – Option B
• Email correspondence dated 16 December 2020 from GNLP officer
• Asset of Community Value (ACV) nomination refusal letter dated 16 May 2018
• Greater Norwich Growth Board agenda for meeting held on 24 September 2020 (including appendix 1, FMG Consulting’s report titled Strategic Outcomes Planning Guidance Scoping Exercise – Greater Norwich, June 2020)
• CODE Development Planners’ review of legal compliance in respect of GNLP’s Sustainability Assessment