GNLP2173

Object

Representation ID: 20534

Received: 09/03/2020

Respondent: Mrs Victoria Reynolds

GNLP2173 I object to the proposal to build 30/50 properties on land at the rear of Heath Crescent and Prince Andrews Road.
Residents that live in the South East division - Fifers Lane/Cromer Road area to the ring road do not have any green spaces, parks or recreational areas. Therefore I support GNLP1021 as this will provide much needed green space for the local residents
To build more houses in this area will put even more traffic on to Cromer Road & Fifers Lane and also more pressure onto necessary services e.g schools & Hellesdon Medical Practice.

Object

Representation ID: 20568

Received: 07/03/2020

Respondent: Susan Gill

I feel most strongly we should protect as much of our green open spaces as possible so I am asking for the former Jarrold social & recreational site to remain a green open space.
Hellesdon is already well developed with enough housing, we need to protect our green open spaces for the sake of the limited wildlife in the area & for the well being of local residents.
We Do Not need more housing on the former Jarrold site.

Object

Representation ID: 20574

Received: 10/03/2020

Respondent: Mrs Tracey CORNWELL

I object to proposal GNLP2173. Instead, this site is much needed as green recreational space for residents, as this is lacking in Hellesdon, especially on this side of the Cromer Road. I am concerned that if more houses were built here, this would bring too much traffic onto the local roads, undoubtedly causing bottlenecks, and would also put more pressure on local services. Please consider promoting the use of this site for recreational open space (GNLP1021) and NOT for developing more houses (GNLP2173).

Object

Representation ID: 20726

Received: 12/03/2020

Respondent: Miss Claire Hall

I object strongly to this proposal for more housing in Hellesdon which is over developed and short of open spaces and services. We are already having over 1000 new homes on the golf course and hospital sites and it looks like every last piece of green is being built on. This will make air quality and transport issues worse and it’s time somebody stood up for the parish

Object

Representation ID: 20906

Received: 13/03/2020

Respondent: Mr Peter Hope

Sadly, his green space has never been accessible to residents. Play equipment for young children is located across major roads. Walkers, runners and dog-walkers have to use the streets.
GNLP 2173 proposes to take the larger part of the space for housing for a few and leave the smaller part for the well-being of the rest of the community!
This built-up area should not be further concretised. We want to breathe; we need recreational space. Local highways are congested and access to them is problematical. The proposed vehicular access to the land in question is an ill-considered solution.

Object

Representation ID: 21040

Received: 15/03/2020

Respondent: Mrs Shelagh Gurney

Objection. Hellesdon parish has a shortfall in formal and recreation space per head of population .With significant and planned house building we will see an expansion 25% + in the next ten years of residential dwellings. Infrastructure and services are already strained and struggling. We do not need any more house building. BDC has five year plus land supply already. Site should be used for residential amenity. Parish Council would like to acquire the site for the people of Hellesdon. Roads near site are unsuitable for any further traffic usage. This part of Hellesdon lacks recreational opportunities for its residents.

Object

Representation ID: 21062

Received: 15/03/2020

Respondent: Mr Simon Burroughs

This is our only green space this side of Hellesdon. We already have 1000+ houses on the site of the old golf course and Eversley Road. It would create a pinch point at the development site onto St Andrew's Rd, creating a traffic issue. Extra pollution would be caused by the new houses. Infrastructure would be negatively impacted by this development - schools, hospitals etc.

Object

Representation ID: 21146

Received: 15/03/2020

Respondent: Mrs Susan Walker

Hellesdon really needs more open spaces, which we are very short of, especially on this side of the busy Cromer Road. It would be good for everyone, especially elderly people and children. We are all encouraged to go out and keep fit. This area already has lots of buildings and is adjacent to a busy industrial estate and near the airport, which doesn't help with air quality. The roads here are very busy and even 35 houses would probably mean at least 60 more cars. Even with the new distributor road it is still difficult turning on to the A140.

Object

Representation ID: 21508

Received: 16/03/2020

Respondent: Mr David Britcher

Hellesdon does not have enough public access open space to satisfy the requirements of the residents of Hellesdon, let alone allowing more houses to built with all the extra residents that would cause. It needs to stay as green space, not housing as this proposal is suggesting to allow.

Object

Representation ID: 21826

Received: 13/03/2020

Respondent: Mrs Ursula Hope

For most of that time the land in question has been used by Jarrold’s for sports activities. Sadly we, the residents of the area, had no access - something that would have been appreciated with young children.
Now we are facing something worse. We lose green space and gain far more traffic on what are very narrow and bendy roads. Turning into Cromer Road from Heath Crescent and particularly from Brabazon Road (often up to 8 cars parked close to the junction) can be a challenge as it is, without the extra traffic from a new development

Object

Representation ID: 21879

Received: 16/03/2020

Respondent: Mrs Lisa Donaldson

I would like to see more leisure activities for the community to use.

There is a restriction in place on Heath Crescent to reduce traffic as this was previously causing infrastructure problems. To increase the volume of traffic and heavy building equipment could cause costly and potentially irreparable damage in the area.

The volume of housing planned would increase the volume of traffic in the immediate area which would cause a bottleneck to a small housing estate.

Many properties nowadays have at least 2 cars per household; there would be limited space for these to park and potentially many would park outside properties in the surrounding residential roads.

There are already sport pitches on this site which were once used; these could easily be adapted further to allow more and better sporting facilities.

There is potential for a cycle path/ pedestrian path around the circumference of the site, which would allow safe cycling in the area as Hellesdon is short of safe cycling routes.

This would also provide a better pedestrian leisure walking option rather than roads in the local area.

The current facilities could be adapted to create a coffee shop/ leisure area for local residents to use while walking, cycling or using other facilities.

A safe place for teenagers/ young people to spend time and let of steam without getting into trouble; BMX bike/ graffiti wall

Different sporting / other facilities to enable different family members to participate while at the same location.

There is a growing need for leisure spaces to facilitate and encourage wellbeing of individuals in our community, adapting the space to facilitate leisure facilities and quiet spaces is essential to this end.

Object

Representation ID: 21934

Received: 13/03/2020

Respondent: Mrs Jane Woods

I am objecting to the proposed buildings because both wild birds and wild mammals would lose their homes.
The surrounding roads are not suitable for a large increase in traffic
This site is currently used for football games, dog walking and general recreational purposes by local residents.
We do not want Hellesdon transformed into a concrete jungle.

Object

Representation ID: 21979

Received: 13/03/2020

Respondent: Tony Adams

Comment objects to proposal being reasonable
I am totally opposed to this being put forward as a reserve site for planning. This has to be in my view reclassified as open recreational space. Hellesdon is desperately short of open space only having approximately 12 acres when according to national guidelines we should have at least 56 acres. Also Hellesdon is already having more than its fair share of new housing with up to 1000 new homes being built on the old Norwich golf course and almost certainly at some time in the future a probable 200 new homes on the Hellesdon Hospital site. This proposal also does no favours to Hellesdon Parish Council (HPC)who are desperate to buy the Jarrolds site for the benefit of the residents of Hellesdon but have been rebuffed by Jarrolds who have made it clear they won't even consider selling the site for recreational purposes while they believe they can sell it as a development site. So while Jarrolds believe they have a sniff of a chance of doing this they will continue to flatly refuse to consider selling it at a reasonable price to HPC. By reclassifying this as open space removes this option completely from Jarrolds Additionally in HPC's Neighbourhood Plan the policy regarding the Jarrolds site is it becomes open space. The NPPF, Paragraph 14, states "In situations where the presumption (at Paragraph 11d) applies to applications involving the provision of housing, the adverse impact of allowing development that conflicts with the neighbourhood plan is likely to significantly and demonstrably outweigh the benefits". I would strongly argue building on this land would significantly and demonstrably out weigh the benefits as it robs the residents of Hellesdon of much needed open space of which there is a significant shortfall.

Object

Representation ID: 22011

Received: 13/03/2020

Respondent: Mr George John Quakley

Almost certainly most Hellesdon residents feel they have seen enough residential development - 'concreting over' as many term it.
So where 'green' space for recreation exists every effort should be made by planners to preserve it. This is particularly aposite(sic) to the former Jarrold site.
The existing adjacent residential area (Brabazon Rd/Prince Andrews Rd/Close/Heath Cl/Crescent) forms a pleasant 'oasis' bounded as it is by Norwich Airport, industrial sites & the A140, clearly a 'green' recreational space within this area would be a boon to residents especially perhaps for the elderly & children, sports England have an interest & I'm sure that organisation would welcome residents to some if not all their activities. The case for retaining the 'green' space appears overwhelmingly strong
A note on residential development, should this be approved clearly access should be via Fifers Lane, phased traffic lights (IE. rush hour) & road markings to prevent access being blocked should suffice. The completion of the NDR-A47 should reduce traffic pressure in Fifers Lane.

Support

Representation ID: 22707

Received: 16/03/2020

Respondent: CODE Development Planners Ltd

1. Introduction
1.1. These representations are submitted on behalf of Jarrolds & Sons the owners of land to the rear of Heath Crescent, 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. 1.2. The site comprises a single parcel of land with an area of 2.18ha and was previously used as a sports and social club for Jarrold’s employees. Due to dwindling membership and the facility running at a loss, the site closed in August 2016. Redevelopment of the unused site would support the provision of new homes to serve the needs of the local community. 1.3. These representations provide an update to the representations made at the Stage B Regulation 18 New, Revised and Small Sites consultation, March 2018. Since the previous submission a
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number of technical surveys and assessments have been undertaken by an appointed team of specialist consultants to identify potential constraints and opportunities to residential development and inform the quantum of new homes that are deliverable from the site.
1.4. In the context of the Hellesdon Neighbourhood Development Plan, December 2017, the time that has elapsed since the site closed and the timetable for the adoption of the Greater Norwich Local Plan (GNLP) (August/September 2022), these representations consider two scenarios; residential development of the site (35-40 homes) with retention of the bowls green; or residential development of the entire site (45-50 homes). Both scenarios would accord with the Recreational Provision in Residential Development SPD, April 2016 and other policies within the Broadland Development Management DPD, August 2015 (BDM-DPD). 2 Current status in GNLP 2.1 The site has been assessed in the Hellesdon Assessment Document as a reasonable alternative for both residential development following representations made on behalf of the land owner, Jarrolds & Sons (reference GNLP2173) and as an area for leisure following a submission by Hellesdon Parish Council (reference GNLP1021) during the GNLP Call for Sites consultation (date) and subsequent GNLP regulation 18 consultation (March 2018). 2.2 Paragraph 35 of the National Planning Policy Framework (NPPF) states that, “Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs19, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework”.
2.3 The GNLP as currently drafted does not include an allocation for the site; given the time sensitive nature of various contextual policy elements as set out in paragraph 1.4 above, it fails to satisfy two of the tests of soundness, notably “positively prepared” and “justified”. Jarrold & Sons contend that an assessment of the reasonable alternatives as presented by the two scenarios in this submission would conclude with the allocation of the site for residential development (with or without the bowls green is for further consideration through the local plan preparation process) thus providing a remedy to comply with the tests of soundness. The alternative would be for the site to come forward as a “windfall site” during the plan period.
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2.4 We understand that the evidence base, which will be prepared as part of the review of the BDM-DPD will include an update to the Greater Norwich Area Playing Pitch Strategy, October 2014. In the context of the preparation of the GNLP, this is required to assist consideration of the two scenarios. Jarrold & Sons acknowledges that within five years of the closure of the site a negotiated planning permission could secure the retention of the bowls green as part of the development of the site for 35-40 new homes. This would accord with Project 1: Enhanced parks and open spaces of the Hellesdon Neighbourhood Plan (HNP). The project seeks to improve the quality and diversity of existing parks and open spaces throughout Hellesdon which would include inter alia the parish council “securing the use of Jarrold’s Sport Ground/Heath Crescent for the local community”. 2.5 The Hellesdon site assessment document explains the site is considered to be a reasonable alternative if additional housing is needed in the urban area. This in itself would seem to be contrary to the proposed strategy for development in the GNLP. Policy 1 states, “that sustainable development and inclusive growth are supported by the delivery of 44,340 new homes between 2018 and 2038. In delivering these new homes growth is distributed in line with the settlement hierarchy: 1 Norwich urban area (Norwich and Norwich Fringe) 2 Main towns 3 Key service centres 4 Village clusters”
2.6 It goes on to state, “Growth is distributed in line with the settlement hierarchy to provide good access to services, employment and infrastructure. It is provided through urban and rural regeneration, along with sustainable urban and village extensions.” The site is located in the fringe parish of Hellesdon within the top tier of the settlement hierarchy and evidence within the assessment document has established that the site is well located within the built-up area and highways would support residential development subject to vehicular access via Prince Andrews Road, yet the site is considered a reasonable alternative and it is argued that the Local Plan fails the test of soundness with regards to the plan being positively planned. The evidence in support of the GNLP insufficiently explains why sites lower down the settlement hierarchy have been chosen as preferred sites for inclusion within the plan as allocations ahead of this top tier site. The GNLP contradicts itself and is therefore unsound. 2.7 An additional reason given for the site’s non allocation is Hellesdon Parish Council/HNP ambition to secure the site for community use. An assessment of the provisions of project 1 of the HNP identifies that it does not state the extent of community use or what the uses should be. 3 Evidence on deliverability 3.1 Jarrold & Sons has appointed a team of technical consultants to assess the constraints and opportunities presented by the site in relation to residential development. In doing so the principle for development has been established and no physical constraints have been identified that would prohibit development. In addition to the provision of a range and types of new homes, development of the site for residential provides opportunities to improve biodiversity, public access and the creation of circular walks.
3.2 The technical team included consultants specialising in; archaeology, arboriculture, ecology, landscape, noise and vibration, surface water drainage and utilities. Where constraints were identified, suitable mitigation has been identified to allow for sustainable development of the site. The following lists the technical reports that have been prepared and identifies those which are submitted in support of these representations (those not submitted directly with these representations are available for discussions with officers of the GNLP team ahead of the regulation 19 stage of plan preparation): • Transport Appraisal (including proposed access drawing) (January 2020) prepared by WSP Part of representation • Preliminary Landscape and Visual Overview (March 2020) prepared by Tyler Grange Part of representation • Ecology Report (March 2020) prepared by Wild Frontier Ecology Part of representation • Surface Water Drainage Strategy and Flood Risk (January 2020) prepared by Richard Jackson Available for discussion with officers • Utilities (January 2020) prepared by Richard Jackson Available for discussion with officers • Initial Site Noise Risk Assessment (February 2020) prepare by Adrian James Acoustics Part of representation • Archaeological Desk-based Assessment (January 2020) prepared by RPS Part of representation • Arboricultural Assessment (February 2020) prepared by Oakfield Arboricultural Services Part of representation 3.3 Noise, surface water drainage, easements, arboriculture and ecological constraints and the opportunities created by accommodating and seeking enhancements have been considered by an architect in preparing “proving” layouts. Recognising that there are different ways in which the layout of the site could be designed these are not submitted for consideration at this stage of preparation of the GNLP, however, the proving layouts give Jarrold & Sons confidence that residential development of the site for the number of new homes identified in paragraph 1.4 above is deliverable and viable. 3.4 The majority of the documents listed above identify how sustainable residential development of the site can be achieved. This applies to the preliminary landscape and visual overview report, however, this document also demonstrates that the green space designation of the site under policy EN2 of the BDM-DPD is out of date in respect of the site. No evidence has been put forward by the GNLP team as to why this current designation remains up to date. In 2018 the site was subject to an unsuccessful nomination as an asset of community value. Evidence presented by Winckworth Sherwood on behalf of Jarrold & Sons and accepted by Broadland District Council, combined with the preliminary landscape and visual overview report demonstrate why the site does not make a significant contribution towards defining the character of the area. Designation under EN2 is not justified and should not be considered a restriction to residential development.
3.5 Paragraph 33 of the NPPF states that local plans and development strategies should be reviewed to assess whether they need updating at least once every five years and should then be updated as necessary. As such, we would anticipate that Broadland District Council in reviewing the BDM-DPD, adopted five years ago in August 2020, would identify policies such as EN2 (and the associated policies map) as out of date in respect of the site and therefore require updating. Paragraph 31 of the NPPF also states the preparation and review of all policies should be underpinned by relevant and up-to-date evidence. To that end, the Playing Pitch Strategy, Greater Norwich Area Broadland Action Plan 2014 would also need to be updated. We believe due to the criteria for green space and the closure of the site in 2016 the site does not contribute to these criteria. 4 Conclusions 4.1 Jarrold & Sons contend that as currently drafted the GNLP is unsound due to the failure to identify the site as a preferred option, contrary to the preferred strategy with regard to the distribution of development and failing to include a wholly deliverable site which would contribute towards the delivery of housing and other community benefits. 4.2 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 demonstrate that the two scenarios put forward in these representations (paragraph 1.4 above) have been considered despite these being submitted during the stage B regulation 18 consultation during March 2018. 4.3 Jarrold & Sons contends that the remedy to the GNLP’s failure to satisfy the tests of soundness would be to allocate the site for residential development (the extent of community use as part of the allocation should be discussed with Jarrold & Sons ahead of the regulation 19 stage of plan preparation).