GNLP2160

Comment

Representation ID: 22918

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Please note that we have previously promoted the site as having the capacity to accommodate 500 new homes,
not the 600 that has been recorded and is referenced in the Sites Assessment Booklet. However, following
further technical work, the site is now being promoted for c. 350 new homes, together with additional recreation
facilities, as outlined in the Vision Document that accompanies these representations.

Object

Representation ID: 22929

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Land to the south of Green Lane, Horsford (Site Ref. GNLP2160)
The Housing and Economic Land Availability Assessment (HELAA) for the Greater Norwich Area comprises three ‘volumes’:
• The December 2017 HELAA;
• The October 2018 HELAA Addendum I, and
• The January 2020 HELAA Addendum II.

There is no overlap between the three volumes – i.e. a site appearing in one does not appear in either of the other two.

As set out in Planning Practice Guidance (PPG) (ID: 3-001-20190722):
“An assessment of land availability identifies a future supply of land which is suitable, available and achievable for housing and economic development uses over the plan period.
…
However, the assessment does not in itself determine whether a site should be allocated for development. It is the role of the assessment to provide information on the range of sites which are available to meet the local authority’s … requirements, but it is for the development plan itself to determine which of those sites are the most suitable to meet those requirements.”

In each of the HELAA volumes, sites are assessed against a range of criteria and scored ‘red’, ‘amber’ or ‘green’. In each case, the site was scored based on the information available to the GNDP at the time the assessment was carried out. As set out in the original December 2017 HELAA (para. 2.20):
“The methodology states that if a site is assessed as red against any type of constraint or impact then it will be discounted and the site will not be considered suitable for development for the purposes of the HELAA assessment. Sites assessed as amber against any type of constraint or impact will be considered as potentially suitable providing that the constraint or impact could be overcome and the green category represents no constraint or impact.”

The HELAA goes on to state (para. 7.5), as do the Addenda:
“The HELAA presents a snapshot of the position at a particular point in time and will need to be updated regularly as plan preparation progresses.”

Our client’s site, known as Horsford Phase 3, (land south of Green Lane) (Site Ref. GNLP2160) was included in the Regulation 18 consultation carried out in late 2018 on ‘new, revised and small sites’. This consultation was essentially a consultation on the GNDP’s assessment of the 200+ sites submitted for consideration since December 2017 as contained in October 2018 HELAA Addendum I.

In that Addendum, our client’s site was scored as follows:

Constraints Analysis
• Access Amber
• Accessibility to Services Green
• Utilities Capacity Amber
• Utilities Infrastructure Amber
• Contamination and Ground Stability Green
• Flood Risk Amber
• Market Attractiveness Green

IMPACTS ANALYSIS
• Significant Landscapes Amber
• Townscapes Amber
• Biodiversity and Geodiversity Amber
• Historic Environment Amber
• Open Space and GI Green
• Transport and Roads Amber
• Compatibility with Neighbouring Uses Green

Savills submitted representations to the 2018 consultation and addressed each of the criteria on which the site had been scored ‘amber’ as set out below. To this has been added further comment in respect to ‘Significant Landscapes’ and ‘Townscapes’. Given that the studies submitted in 2018 identified the capacity to accommodate 500 new homes, there is clearly capacity to accommodate the 350 new homes now being promoted.

Access / Transport & Roads
The access to the promoted site would be from the existing adjacent development, with the access to the promoted site having capacity to serve an additional 500 homes (see Highway Capacity Assessment enclosed herewith); additional traffic surveys would be carried out prior to / as part of any future development proposal.

All of the access infrastructure required to serve the promoted site is thus already approved / in place or controlled by BDW. Additional pedestrian, cycle and emergency accesses would also be provided as indicated in the Vision Document enclosed herewith.

On this basis, it is suggested that the constraints analysis for ‘Access’ is re-categorised to ‘green’ in the suitability assessment of the site.

Accessibility to Services
Although the constraints analysis already categorises the site as ‘green’ in this regard, further work (see Education Report enclosed herewith) has been undertaken by BDW to confirm that there is capacity on the site of the existing primary for the school to be expanded to accommodate another form of entry.

That there is sufficient capacity to expand the school and that that the school is adjacent to the site, serves to further reinforce the ‘green’ categorisation already assigned, and reinforce the site’s sustainability credentials.


Utilities
(See Utilities and Drainage Review enclosed herewith.)
With regards to utilities (capacity and infrastructure), foul water drainage has been accommodated for as part of the existing adjacent development with an adoptable pumping station, with the ability to receive pumped flows from 500 homes.

With regard to electricity supply, the High Voltage Network was extended as part of the existing adjacent development to serve the new substation. This has again been designed to accommodate a further development of 500 homes.

There is also sufficient gas supply, with offsite works completed as part of the existing adjacent development, which can accommodate the supply for a further 500 homes.

On this basis, it is suggested that both the constraints analysis for ‘Utilities Capacity’ and ‘Utilities Infrastructure’ are both re-categorised to ‘green’ in the suitability assessment of the site.


Drainage / Flood Risk
With regard to flood risk, the promoted site is wholly located within Flood Zone 1 according to the Environment Agency Flood Mapping.
The maps also show that the site is not at risk from surface water flooding. Infiltration testing has taken place by BDW on both adjacent sites, with all studies to date indicating that the same approach could be taken to draining the promoted site (see Utilities and Drainage Review enclosed herewith).
On this basis, it is suggested that the constraints analysis for ‘Flood Risk’ is re-categorised to ‘green’ in the suitability assessment of the site.

Significant Landscapes / Townscapes
The Landscape and Visual Appraisal (LVA) (enclosed herewith) concludes that:
• The promoted site is not covered by any designations for landscape character or quality, nor is it identified in the existing Local Plan for its character or landscape quality. It is not publically accessible and does not contain or lie in proximity to any designated heritage assets.

• The promoted site could not be considered to form part of a Valued Landscape for the purposes of Paragraph 170 of the NPPF.

• The promoted site is very well contained by dense woodland to the north and east, and existing built form to the south and west, resulting in very few opportunities to view the site from its surroundings.

• Given the visual containment of the promoted site, public views of the new houses will be limited to filtered views from Mill Lane and Green Lane, with retained boundary vegetation and new structural planting to these boundaries increasingly filtering and screening these views as it matures.

Overall, the LVA concluded:
“The assessment found that the proposed development would be compatible with the surrounding and planned development on the northern edge of Horsford, set within an established landscape framework of mature trees and surrounding woodland. In summary, the Site is capable of accommodating development in line with that shown on the Concept Masterplan, without resulting in significant harm to the local landscape character, or views from the surrounding area.”

On this basis, it is suggested that the impact analysis for ‘Significant Landscapes / Townscapes’ is re-categorised to ‘green’ in the suitability assessment of the site.


Biodiversity and Geodiversity
The Vision Document shows how the development of the site could deliver a new Nature Park to the north of Green Lane to enhance the existing natural environment, whilst also creating new community public open space. There would be further opportunities to create a net gain in biodiversity through the creation of new habitats within and around the site.

With the knowledge of the site and surrounding area gleaned from the development of the two adjacent sites, and the Ecological Study undertaken by TMA in relation to the promoted site (see enclosed Ecological Report dated December 2018) there are no likely significant adverse impacts that would arise off-site, especially given the proposed creation of the new Nature Park.

On this basis, it is suggested that the impact analysis for ‘Biodiversity and Geodiversity’ is re-categorised to ‘green’ in the suitability assessment of the site.


Historic Environment
As set out in the Cultural Heritage Desk-Based Assessment (enclosed herewith), there are no World Heritage Sites, Historic Battlefield sites or Historic Wreck sites within the vicinity of the promotion site. The Scheduled Monument ‘Two round barrows on Horsford Heath’ (NHLE ref.1003164) lies a short distance north-west of the site, enclosed by a woodland. However, there is no inter-visibility between the site and the Scheduled Monument due to the extent of intervening woodland, and thus the site is not an element in how the significance of the Scheduled Monument is experienced. Overall, it is considered that the residential development of the site would represent an alteration of the extended rural setting of the Scheduled Monument, but an alteration that would not have the potential to alter its significance.

With regard to built heritage, there are no such assets located within the site and the site does not have a visual, functional or historical relationship with, not does it contribute to the setting, of any nearby assets.

On this basis, it is suggested that the impact analysis for ‘Historic Environment’ is re-categorised to ‘green’ in the suitability assessment of the site.


Transport & Roads
See ‘Access’ above.
On this basis, it is suggested that the constraints analysis for ‘Transport and Roads’ is re-categorised to ‘green’ in the suitability assessment of the site.
Summary
The re-categorisation of the site’s constraints / impacts analysis as discussed above would result in all of the constraints analysis criteria being ‘green’, with more of the impacts analysis criteria also now being ‘green’. The lack of any ‘red’ and a low number of ‘amber’ scores on the assessment, shows that the site is suitable for residential development.
In summary, based on the additional information that we provided to the 2018 consultation, the site should have been reappraised (subject to the potential for the GNDP disagreeing with the information provided) as follows:

• (Please refer to attached document: “Reps to R18 GNLP 16 03 20_FINAL”)

However, despite the HELAA explicitly recognising and stating that it only represents “…a snapshot of the position at a particular point in time and will need to be updated regularly as plan preparation progresses …” the GNDP has not sought to update any of the HELAA assessments carried out to date; in essence, the HELAA ignores all of the additional information submitted through previous consultations. On this basis alone, Savills would contend that the conclusions of the individual site assessments as contained in the HELAA cannot be relied upon as being accurate.

Instead, the Site Assessment Booklet states:
“This site is not considered to be reasonable for allocation as the scale of the proposal is a concern with a lack of safe walking / cycling route to the catchment high school. Development would require highway improvements and it is unlikely that a satisfactory access strategy would be able to be developed for the entire level of development. There are also ongoing concerns with the new B1149 roundabout. Smaller areas of the larger site were considered but dismissed as unsuitable due to the standard of Mill Lane and Green Lane.”
With regard to the issues raised in this commentary as being reasons to dismiss the site:
• It is stated that the scale of the proposal is stated as being a concern, yet no further comment on this is provided – why is it a concern?

• It is stated that there is a lack of a safe walking / cycling route to the catchment high school, yet this is a comment applicable to many existing commitments and proposed allocations and was not considered to be an issue in the granting of planning permission for some 429 new homes on land directly adjacent to the promotion site.

• It is stated that highway improvements would be required, that it is unlikely that a satisfactory access strategy could be devised, and that there are concerns with the new roundabout delivered as part of the adjacent development, yet evidence submitted to previous consultations (and enclosed herewith) refutes that suggestion and demonstrates that adequate highway access can be delivered without the need for any significant highway improvements.

• It is stated that smaller areas of the promotion site were considered but that these were dismissed as unsuitable due to the standard of Mill Lane and Green Lane, yet no evidence is provided to demonstrate what smaller areas were considered, why these were (incorrectly) considered to be reliant on either Green Lane and/or Mill Lane (access can be provided via the adjacent development), or why these ‘smaller areas’ were dismissed; the GNDP sought no input from BDW in respect of any smaller area despite BDW stating in previous representations a willingness to meet to discuss the site.

Delivery
BDW Homes (Eastern Counties) have a very good record of delivery within Horsford. Of the two sites adjacent to the promoted site, Phase 1 (125 dwellings) was completed June 2017 and Phase 2 (304 dwellings) is currently under construction with 87 units complete at the time of writing (see further details in the table below).
It is anticipated that Phase 2 will be completed by the end of 2023. BDW can also demonstrate successful delivery of other residential sites across the Greater Norwich area, including sites in Aylsham and Poringland.
The promoted site provides a logical and suitable opportunity for residential development in an established location with Horsford benefiting from both existing and planned infrastructure. Given the presence of BDW in Horsford, there is certainty that the site can be delivered within the early years of the plan, and moreover delivered in a quick and timely fashion without the usual delays associated with starting on site.
Delivery on the promoted site could commence as early as 2024 (i.e. within the first 5-years of the plan period, extending into the second 5-years), and would deliver c. 100 new homes a year.

(For additional information, please refer to attached document Reps to “R18 GNLP 16 03 20_FINAL”)