Object

Publication

Representation ID: 24555

Received: 22/03/2021

Respondent: ClientEarth

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

It would appear that the adverse effects [identified in the SA report] have been exacerbated by the decision to plan for ….. development on greenfield land and in unsustainable locations.
The impact of this decision is clear from looking at a few examples of the Sustainability Appraisal’s assessment of allocations made in the plan:
• In respect of site GNLP0581R – for provision of more than 600 dwellings:
o “Sites GNLP0581R and GNLP4045 comprise previously undeveloped land and are located outside the existing settlements of Costessey and Bowthorpe. Therefore, the proposed development at these two sites could potentially contribute towards the urbanisation of the countryside.” (D.8.4.4)
o “The nearest local services, Co-op, Stafford Stores and Post Office, and Sainsbury’s, are located in and around Costessey. Sites GNLP0581R and GNLP4045 are located outside the target distance to these services.” (D.8.6.1)
o “The closest GP surgeries to this cluster are The Roundwell Medical Centre in Costessey and Taverham Surgery in Taverham. Sites GNLP0581R and GNLP4045 are located outside the target distance to these GP surgeries.” (D.8.8.5)
o “The closest leisure facility to Costessey is Riverside Leisure Centre, located approximately 8km south east of the cluster. Both sites in this cluster are located outside the target distance to this leisure facility …” (D.8.8.6)
o “The closest primary schools to this cluster include Chapel Break Infant School, St Michael’s Church of England Voluntary Aided Junior School and Queen’s Hill Primary and Nursery School. Sites GNLP0581R and GNLP4045 are situated outside the target distance to these schools.” (D.8.10.1)
o “Sites GNLP0581R and GNLP4045 are located outside the target distance to a bus stop providing regular services. … The closest railway station to Costessey is Norwich Railway Station, located approximately 8km to the south east of the cluster. This is outside the target distance … Site GNLP0581R currently has poor access to the surrounding footpath network.” (D.8.12.1-3)
o “The proposed development at Site GNLP0581R would be likely to result in a major negative impact on natural resources due to the loss of more than 20ha 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.” (D.8.14.2)

Change suggested by respondent:

Accordingly, on its own terms, the Sustainability Appraisal’s findings would appear to support a quite different approach to site allocation – one that avoids as far as possible new development on greenfield land and in unsustainable locations. The above allocations are an illustrative but not exhaustive list of instances of this problem in the plan.

Full text:

We regret that none of the issues raised in our response to the Regulation 18 consultation appears to have been addressed in the updated version of the plan. We therefore repeat our previous representations regarding non-compliance with section 19(1A) of the Planning and Compulsory Purchase Act 2004, with the SEA regulations including related requirements, and inconsistency with the NPPF, which we now supplement and update in respect o certain issues.

Attachments: