Settlement Map

Object

Representation ID: 24248

Received: 22/03/2021

Respondent: Alfred Charles Homes Limited

Number of people: 2

Agent: Brown & Co

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

It is considered that the draft Plan is unsound, as the strategy proposed is neither justified nor effective. The site at Farmland Road, Costessey, offers an appropriate opportunity to deliver growth in a manner that is appropriate to the sustainable objectives of the emerging Local Plan and NPPF. By undertaking a limited form of development on this site in a sustainable manner it would support the emerging Local Plan in paving the way for the region to become the UK leader in clean growth whilst raising the standards for design and placemaking.

The GNLP in its current form is not considered to be sound as the strategy fails to adequately deliver on the overall purpose of the plan, in particular addressing the challenges of climate change and supporting ambitious local and national targets for carbon neutrality. The proposed distribution of growth is not thought to be suitably forward thinking to facilitate the transition to a post-carbon economy or to create truly beautiful places or spaces. The draft GNLP recognises the need to deal with the challenges of climate change and carbon neutrality and adapt accordingly, however it seeks to deliver growth through a traditional delivery model which perpetuates inappropriate development.

Additionally, the strategy is considered to be ineffective as there is a significant reliance upon sites which have failed to deliver during the current plan period, with some sites having been originally allocated in previous iterations of the Local Plan, dating as far back as 2004. Continuing to roll forward sites which have failed to deliver in line with the housing trajectory places the strategy for growth at risk and undermines the Plan led approach. Insufficient evidence has been provided to demonstrate the ability of
these, and other sites, to deliver within this plan period, with a number of sites having no promoter or developer on board.

A limited form of development led by the green credentials of the locality would result in tangible
benefits for the community and provide housing in a holistic and sustainable way in order to create a
vibrant and resilient community and support the move to a post-carbon economy. Government has recognised the role that residential development can have in achieving sustainability and creating communities, where there is no choice between quality and quantity and green spaces amount to more than token verges and squares. Provision of significant open space in the Tud river valley area, would create a significant area of green space, something which has become more important than ever in light of the pandemic. The relationship of the site with the existing services and facilities in the area will result in a sustainable form of development that will contribute significant benefits to the area

Please see attachment for full representation

Object

Representation ID: 24410

Received: 22/03/2021

Respondent: ClientEarth

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

It would appear that the adverse effects [identified in the SA report] have been exacerbated by the decision to plan for ….. development on greenfield land and in unsustainable locations.
The impact of this decision is clear from looking at a few examples of the Sustainability Appraisal’s assessment of allocations made in the plan:
• In respect of site GNLP0581R – for provision of more than 600 dwellings:
o “Sites GNLP0581R and GNLP4045 comprise previously undeveloped land and are located outside the existing settlements of Costessey and Bowthorpe. Therefore, the proposed development at these two sites could potentially contribute towards the urbanisation of the countryside.” (D.8.4.4)
o “The nearest local services, Co-op, Stafford Stores and Post Office, and Sainsbury’s, are located in and around Costessey. Sites GNLP0581R and GNLP4045 are located outside the target distance to these services.” (D.8.6.1)
o “The closest GP surgeries to this cluster are The Roundwell Medical Centre in Costessey and Taverham Surgery in Taverham. Sites GNLP0581R and GNLP4045 are located outside the target distance to these GP surgeries.” (D.8.8.5)
o “The closest leisure facility to Costessey is Riverside Leisure Centre, located approximately 8km south east of the cluster. Both sites in this cluster are located outside the target distance to this leisure facility …” (D.8.8.6)
o “The closest primary schools to this cluster include Chapel Break Infant School, St Michael’s Church of England Voluntary Aided Junior School and Queen’s Hill Primary and Nursery School. Sites GNLP0581R and GNLP4045 are situated outside the target distance to these schools.” (D.8.10.1)
o “Sites GNLP0581R and GNLP4045 are located outside the target distance to a bus stop providing regular services. … The closest railway station to Costessey is Norwich Railway Station, located approximately 8km to the south east of the cluster. This is outside the target distance … Site GNLP0581R currently has poor access to the surrounding footpath network.” (D.8.12.1-3)
o “The proposed development at Site GNLP0581R would be likely to result in a major negative impact on natural resources due to the loss of more than 20ha of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils.” (D.8.14.2)