GNLP2161

Unlike other allocation policies there is no reference to water efficiency forming part of the design

Please also see comments relating to Policy 2 of the Sustainable Communities of the Strategy document.

Please see attached for full submission
There is clearly an error in the Notes of the section titled “Existing allocation to be carried
forward” which states:
“Notes
BLO1: The site was allocated in 2016 as part of the previous local plan but has not yet been
developed. The principle of development on the site has already been accepted and it is
expected that development will take place within the time-period of the new local plan up to
2038. The site is likely to accommodate at least 250 homes reflecting planning permission
20161066 which Planning Committee have resolved to grant outline approval subject to the
satisfactory completion of a Section 106 Agreement and appropriate conditions. More may be
accommodated, subject to an acceptable design and layout etc. being achieved. When BLO1
is completed it will be incorporated into the settlement limit.”
The planning reference and description refers to a site in Drayton, and not Blofield. The
correct reference is 2016/0488 and is for 163 dwellings which are currently under
construction. As such, it cannot be an “Existing allocation to be carried forward”. The number
of dwellings currently being provided is correctly identified in calculations but again
incorrectly listed as “Carried forward allocations”.
In particular, I note the comments and assessment made in relation to the land at Yarmouth
Road, Blofield (ref. GNLP0252) in the emerging draft Local Plan, which has been proposed for
residential development (undefined dwellings). This site is assessed as a “Unreasonable” in
the proposed Draft Plan, stating:
“This site is not considered to be suitable for allocation. Little additional growth is proposed in
Blofield due to substantial existing commitment and concerns about capacity of the A47
roundabout...”
It is noted that another site is identified as a proposed allocation (refs. GNLP2161), with text
stating:
“GNLP2161: Residential development in Blofield is limited due to the level of existing
commitment and capacity issues with the A47 roundabout however this site is considered to
be of a suitable size to allocate. The allocation is subject to provision of frontage footway and
possible 'de-engineering' of the former trunk road. The promoter would need to demonstrate
availability of appropriate visibility splay. Consideration will need to be given to how the site
relates to the existing delivery and service yard of Norwich Camping and Leisure.”
It is apparent that these assessments – both the reason for choosing GNLP2161 instead of the
GNLP0252 site, and for not proposing the allocation of the latter - is based on assumptions
not evidence.
The assessment accompanying the proposed allocation of GNLP2161 states that:
• “this site is likely to accommodate at least 15 homes, 33% of which will be affordable.
More homes may be accommodated, subject to an acceptable design and layout, as
well as infrastructure constraints.”
• “The design and layout of the scheme must mitigate amenity impacts relating to the
neighbouring business to the east, addressing in particular access to the service yard”
• “The allocation is subject to provision of frontage footway and possible ‘deengineering’
of the former trunk road. The promoter would need to demonstrate
availability of appropriate visibility splay”
It is clear from this that there are significant uncertainties in both scale of development,
deliverability, and viability.
In contrast, GNLP0252 is both demonstrably viable and capable of delivering new homes
quickly.
The area north of GNLP0252 (shown as 20141710 BLO2 on the accompanying map – Blofield
GNLP) is a recent development. That development is now complete and has provided 30
dwellings (20 open market and 10 affordable) all of which are now occupied. The rapid
construction and sale of this site (Newstead Gardens) shows both the deliverability of
development, and the attractiveness and demand for new homes in this location.
The development of 20141710 BLO2 was carefully designed and constructed to provide both
access and infrastructure to the boundary of GNLP0252. Consequently, there are no access
or infrastructure constraints to the rapid delivery of new homes on GNLP0252.
If it felt that an appropriate quantum of development for Blofield is “at least 15 homes” (text
from GNLP2161) then the northern section of GNLP0252 within the existing hedge boundary
would accommodate up to 25 dwellings with minimal visual impact and no intrusion into the
countryside:
These new homes would be located within an existing residential area and (unlike GNLP2161)
would not have their residential amenity compromised by an adjacent busy commercial use
or commercial traffic accessing an adjacent service yard.
Contrary to the above GNLP statements, there are no significant highways constraints (based
on current highways information) regarding capacity of the A47 roundabout. Transport
assessments have been carried out on behalf of multiple current larger developments (100+
dwellings) in the area and no required works have been put forward since the last works
carried out by Persimmon Homes in conjunction with their completed development of 150
dwellings on Cucumber Lane.
The proposal for (up to) 25 dwellings will have modest transport impacts and this is
acknowledged in the GNLP2161 allocation for “at least 15”. The proposed development will
not have any significant adverse impact upon the satisfactory functioning or safety of the
highway network.
In light of the above, it is clear that GNLP0252 represents a better located site, has existing
infrastructure and access already in place, and will therefore provide much needed new
homes faster and with more certainty when compared to GNLP2161. I would therefore
request that GNLP0252 is identified as a preferred allocation for Blofield.