GNLP0377

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Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22203

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Representation Summary:

There are many sites within Norwich which are adjacent to the River Wensum (GNLP2137, GNLP0409R, GNLP0360, GNLP0377, GNLP0401, GNLP0068, GNLP3053), firstly we need to ensure that SuDS within the development are sufficient to protect the water quality of the River Wensum and secondly any opportunities to improve riparian habitat to mitigate against the impacts of the development would help us to secure improvements necessary to meet good WFD status and help ensure that the development does not cause any deterioration.

GNLP0377
The very east of the site allocation, adjacent to the river, lies in the present and future Flood Zones 2 and 3. Therefore there should be no development within this small section of flood zones, and the development should be sequentially sited in Flood Zone 1.
As with all development in Flood Zones, the development will need to be designed with floor levels raised 0.3m above the flood levels for the future 1% (1 in 100) annual probability flood event with 35% and ideally 65% allowances for climate change. Refuge will also need to be provided above the 0.1% (1 in 1000) annual probability 25% climate change flood levels. Compensatory flood storage will also need to be provided for any built development or land raising within the 1% (1 in 100) annual probability flood outline with 35% climate change to ensure no increase in flood risk elsewhere. This will require lowering of higher land in Flood Zone 1 to provide the compensatory flood storage.

Full text:

Please see attached for full submission

Attachments:

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 23209

Received: 21/12/2020

Respondent: Wensum Sports Centre Charitable Association

Representation Summary:

GNLP0377. Please see the following attached screenshots for the Call for Sites documents :

- GNLP0377 March 2018 Regulation 18 Site Proposals King Street Stores & Sports Hall POLICY
- GNLP0377 March 2020 Draft Local Plan-Part 2 Site Allocations King Street Stores & Sports Hall POLICY.
- GNLP0377 King Street Stores & Sports Hall PLAN

The title 'King Street Stores and Sports Hall' is incorrect. The King Street Stores is already allocated under CC8. If the site sponsers insist on including the Sports Hall site then I believe it should be correctly titled as Wensum Sports Centre and the dwelling numbers corrected to 20 or 30 dwellings (40 - 50 less the 20 in CC8). This has already been pointed out on previous occasions and not acted on.
Under the heading 'Reason for not Allocating', the wording has significantly altered since the regulation 18 submission. May I ask to know why this is? Is there a representation in the Regulation 18 documentation to support this? Also what justification is there for including the sentence 'any future proposals to develop the sports hall could be progressed through a planning application.' Does this 'leave the door open' for a future consent' contrary to policy?

And why is it listed under the heading 'Reasonable Alternative Sites' in the Introduction?

Full text:

This was a late representation received on 21st December 2020:

CC8 Please see the following attached screenshots for the Call for Sites documents :

- GNLP CC8 King Street Stores POLICY and GNLP CC8 King Street Stores PLAN

The original call for sites for the ultimately adopted 2014 Norwich Local Plan included 'an extended CC9 allocation' to include the King Street Stores and Wensum Sports Centre (formerly the Lincoln Ralphs Sports Hall). ref. REPORT ON THE EXAMINATION INTO THE NORWICH SITE ALLOCATIONS AND SITE SPECIFIC POLICIES LOCAL PLAN dated 13.10.14. See attached.
The inspector concluded that the proposal for the 'King Street Stores is soundly based' and that 'the extension of the allocation to include the Wensum Sports Centre is not justified'.
A total of 40 - 50 dwellings was proposed for the whole (extended) site. Only the King Street Stores site, for a total of 20 dwellings, was carried forward to the GNLP call for sites Regulation 18 document under the reference CC8. This has been carried forward to the Part 2 Site Allocations.

GNLP0377. Please see the following attached screenshots for the Call for Sites documents :

- GNLP0377 March 2018 Regulation 18 Site Proposals King Street Stores & Sports Hall POLICY
- GNLP0377 March 2020 Draft Local Plan-Part 2 Site Allocations King Street Stores & Sports Hall POLICY.
- GNLP0377 King Street Stores & Sports Hall PLAN

The title 'King Street Stores and Sports Hall' is incorrect. The King Street Stores is already allocated under CC8. If the site sponsers insist on including the Sports Hall site then I believe it should be correctly titled as Wensum Sports Centre and the dwelling numbers corrected to 20 or 30 dwellings (40 - 50 less the 20 in CC8). This has already been pointed out on previous occasions and not acted on.
Under the heading 'Reason for not Allocating', the wording has significantly altered since the regulation 18 submission. May I ask to know why this is? Is there a representation in the Regulation 18 documentation to support this? Also what justification is there for including the sentence 'any future proposals to develop the sports hall could be progressed through a planning application.' Does this 'leave the door open' for a future consent' contrary to policy?
And why is it listed under the heading 'Reasonable Alternative Sites' in the Introduction?

GNLP1011. Please see the following attached screenshots for the Call for Sites documents :

- GNLP1011 March 2018 Regulation 18 Site Proposals Wensum Lodge 169 King Street POLICY
- GNLP1011 March 2020 Draft Local Plan-Part 2 Site Allocations Wensum Lodge 169 King Street POLICY & PLAN

Under the heading 'Reason for not Allocating', the wording has significantly altered since the regulation 18 submission. Again I don't see anything in the Regulation 18 documentation to support this. And why is it now being said that the protection of individual community facilities is not a matter for the GNLP. Better considered in the context of a review of DM policies.? Does a GNLP policy not afford the same level of surety in relation to development as accorded to policies within the 2014 Norwich Local Plan? Also, under which particular DM policy would it be considered?
Please note, as indicated on the attached plan, the title 'Wensum Lodge King Street' does not equate to the description under the heading 'Reason for not Allocating'. Wensum Lodge Adult Education Centre King Street is outlined in blue. Wensum Sports Centre is described under GNLP0377 (however, as noted above, the title of 0377 is incorrect).

In summary
If it is intended that the Sports Centre site is to be taken forward and included for development in the final GNLP, then I believe the Wensum Sports Centre site should be correctly titled and described. It seems to me that the weakening of the wording to include the phrases 'any future proposals to develop the sports hall could be progressed through a planning application.' and 'protection of individual community facilities is not a matter for the GNLP' is designed to allow for the future consideration of the site for development.

On behalf of the trustees, members and staff of Wensum Sports Centre (WSC), I would strongly OBJECT to the continued inclusion of the sports centre site in the Greater Norwich Local Plan.

The sports hall is absolutely not surplus to requirements. The site should be excluded from the GNLP. Inclusion in any form with whatever restrictive wording, will always be open to interpretation and almost certainly to the benefit of the sponsor of the proposed inclusion.
The 2019 NPPF draws attention to the need to guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs.

WSC has worked extremely hard to ensure the viability of the centre and to promote sustainability. Grants in excess of £150,000.00 have been sought and obtained and the building has been re-roofed and insulated and with an all new air source heat pump heating installation.

The centre is very successful. There are over 2000 members and a total of 17 full and part time staff. The staff have been supported throughout the Covid restrictions and closures and salaries have been topped up to add to the government furlough payments.

The trustees, committee members and staff are resolutely determined to continue to provide affordable and good quality sports and community facilities to the City of Norwich residents and the wider community.