Tivetshall St Mary and St Margaret -GNLP2128

FCC has reviewed the Village Clusters Non-Residential Site Assessment Booklet, hereafter referred to as the Site Assessment Booklet, detailing how the site (GNLP2128) was assessed and has identified discrepancies between that and the HELAA 2018 addendum, which the site was originally assessed within.

The ‘Stage 2 – HELAA Comparison Table’ within the Site Assessment Booklet (page 4) has no supporting text, but it is assumed that the intention is to draw together the results of the RAG assessment undertaken within the HELAA 2017 and Addendums (2018 and 2020). The site was initially scored within the HELAA Addendum 2018 and was considered ‘Green’ for all constraints accept contamination. However, within the HELAA Comparison Table, referenced above, the site now scores ‘Amber’ on a number of factors, namely Site Access, Access to Services, Significant Landscapes, Historic Environment and Transport and Roads.

It is not clear whether this revised scoring is due to a clerical error but in any event FCC has reviewed the RAG assessment criteria as set out within the Norfolk Housing and Economic Land Availability Assessment Methodology (July 2016). Appendix A details the constraints and provides criteria for scoring in relation to each of the relevant constraints. FCC has considered those scored ‘Amber’ and comments as follows:

Access to Site: The site has an existing two-way bellmouth access junction built to adoptable standards which has historically been used for significant transport movements. The site provides direct access onto the B1334 with immediate access to the A140. The assessment criteria states that to score ‘Green’ access by all means should be possible; thus, given this existing access, the site should have scored ‘Green’.

Significant Landscapes: The assessment criteria dictates that sites should score ‘Amber’ where they would have a detrimental impact on sensitive or other landscapes which would be mitigated, whereas sites should score ‘Green’ where the development would have a neutral or positive impact on sensitive landscapes or their setting. The site is not located within any designated landscapes or a landscape which is considered to be sensitive. The site is a disused brownfield site which has no protected trees; redevelopment of the site would have a neutral impact on any sensitive landscapes and therefore the site should have scored ‘Green’.

Historic Environment: There are no designated or non-designated heritage assets within the site. The assessment criteria dictates that sites which will have either a neutral or positive impact on any designated or non-designated heritage assets should score ‘Green’ ; thus, it is considered this site should have scored ‘Green’.

Transport and Roads: The site assessment criteria dictates that to score ‘Green’ development of the site should not have a detrimental impact on the functioning of trunk roads or local roads. It states that consideration will be given to access to public transport, housing, traffic generation and capacity of local junctions. The site is located adjacent to the junction of the A140/B1334 which is a two lane roundabout and would have capacity to accommodate redevelopment of the site. A bus stop is located adjacent to the site boundary on the A140 and provides a regular bus service to Norwich and Diss. Therefore, it is considered that the site should have scored ‘Green’ for this criterion.

Para 5.10 of the HELAA 2017 states that technical consultees inputted into the RAG assessment and, whilst they were provided with a copy of the methodology, some took a more precautionary approach than is required. It states that “at this stage the assessment of the site is not sufficiently detailed to know whether particular issues can or cannot be resolved…hence the role of professional officer judgement”. It is not clear if, in instances where technical consultees have adopted an overly precautionary approach, this has followed through to the final RAG assessment or if they have been adjusted accordingly. FCC considers this should be more transparent and if the technical consultees have not applied the appropriate methodology then these scores should be adjusted.

Within the Site Assessment Booklet (page 8) the Parish Council have made comments in relation to the site, stating that a refuelling station had closed down in the 1990’s due to lack of trade and that a new refuelling station has been permitted at Scole roundabout. Their comments also made reference to a couple of farm/garden centre type retail outlets in the area. Within Stage 4 of the Site Assessment Booklet, whereby the sites are shortlisted, conclusions regarding the site state “This site is not considered to be suitable for allocation as to justify a local plan allocation in this location more evidence would be required to demonstrate need and the likely end-user businesses who would bring forward development”. Thus, it is inferred that the Council have some queries/concerns regarding the achievability of the site. Para 5.12 of the HELAA 2017 states that all proposers confirmed that their submitted sites are viable, and states that “since all site proposers have stated that their site is viable, we have not undertaken a site by site viability analysis”. In addition, the HELAA addendum 2018 suitability assessment proforma states that “further area-wide work on viability typologies will be done as plan-making progresses and will inform decisions on viability”. However, from a review of the available evidence base documents, this high level viability work has only been undertaken in relation to residential developments. The HELAA does not appear to have queried the developer stated viability of any other sites assessed and therefore it is not clear why this conclusion has been drawn for this site, nor is there any evidence to support this reason to discount the site.

FCC maintain that the redevelopment of this site is viable/achievable with sufficient market demand; there is a significant amount of growth permitted within Long Stratton, some 4.5km to the north of site straight up the A140, including ~1900 new houses and ~10 ha of employment land which is likely to generate significant additional traffic movements along the A140, past the site. FCC commissioned an independent specialist consultant to inform their development aspirations for the site, who undertook a viability assessment which concluded that there is demand for a variety of commercial uses including the proposed use.

Stage 4 of the Site Assessment Booklet also states the following in relation to the site: “An important consideration is GNLP2128 has brownfield land status as a former waste transfer station”. However, FCC question the level of consideration that has been given to the ‘brownfield land’ status of the site; paragraph 3.11 of the HELAA 2017 refers to an assessment of brownfield land capacity within Norwich and Main Towns and concludes that all relevant sites have been identified through the call for sites. However, it is not clear what level of precedence has been given to the redevelopment of brownfield sites over greenfield sites within the HELAA methodology; this did not form part of the RAG assessment criteria and, other this a comment of ‘importance’ within the published Site Assessment Booklet, it is not clear what consideration has been given to this, if any.

Paragraph 117 of the NPPF states “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land”, further, paragraph 118 states “planning policies and decisions should …support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land”. Paragraph 84 also states that “planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent or beyond existing settlement limits…The use of previously developed land…should be encouraged where suitable opportunities exist”. Given that there is no specific criteria relating to brownfield land within the HELAA assessment, it is unclear how the council can demonstrate that they have considered the use of previously developed land above greenfield development sites. Therefore, the soundness of the evidence base documents, and thus, the Local Plan is questioned.

FCC consider that the site is suitable, available and achievable for redevelopment, and would provide an opportunity to redevelop a redundant brownfield site, which national planning policy requires local plans to strive to achieve. Thus, the site should be allocated for development within the Local Plan.