GNLP0497

Development in the middle of this green zone would be obtrusive and visually damaging to an area with lots of natural beauty. The marshes and land adjacent to them are enjoyed by many people and animals and provide a beautiful respite from the city for everyone to enjoy. With so many more appropriate places to build identified it is unfathomable to damage this beautiful sport and build close to the protected area and yare valley.

This is a green zone why would you even think of building here.be This is an area with lots of natural beauty. The marshes and land adjacent to them are enjoyed by many people and animals and provide a beautiful respite and with so much Flood Plain being used there is a huge risk for flooding as we have seen in other parts of the country. With so many more appropriate places to build identified with less impact on flooding and wildlife it is unfathomable to damage this beautiful sport and build close to the protected area and yare valley.

Planning Application 2017/2794 - Land West of Ipswich Road, Keswick, Norfolk
At the south Norfolk Development Management Committee of Wednesday 21st June 2017 this application was firmly rejected by the Committee on the basis 'It is not considered that the material considerations of job creation or the delivery of the proposed highway works outweigh the identified policy conflict'. The availability of significant evidence from the GNLP Evidence Base now confirming that there is no need for this additional capacity for job creation, makes the case for rejection of this application overwhelming. The GNLP should respect the decision of South Norfolk.

GNLP 0497
Keswick and Intwood Parish Council believe GNLP 0497 should be refused for reasons already provided in response to Planning Application 2016/0764 and 2017/2794 (currently being considered) both being analogous to GNLP 0214.
Planning Application 2016/0764 was refused because the proposed development would have resulted in a significant adverse impact on the Norwich Southern Bypass Landscape Protection Zone (NSBLPZ), and the landscape setting of Norwich by virtue of the extent of the application site and the identified harm to the openness of the NSBPLZ when viewed from the west. This was deemed to be in conflict with Policy DM4.6 of the South Norfolk Local Plan 2015.
The Parish Council believes (in relation to the existing Application 2017/2794) and therefore identically by association that site GNLP 0214 should be refused for the following reasons:
Landscape Setting of Norwich.
The extent of the site goes well beyond the intention of South Norfolk Council's policy DM 4.6 of the South Norfolk Plan causing significant harm to the NSBLPZ.
Policy DM 4.6 - which was the basis of rejecting the previous Planning Application - states that: all development proposals will not harm and where possible should enhance the landscape setting of Norwich. The policy makes particular reference to any developments: not obstructing Key Views to and from the City; undermining the rural character of Undeveloped Approaches to Norwich; or undermine the Gateways as visual points of the landscape and townscape change marking the 'arrival' at and 'departure' from the city of Norwich.
The proposed development is contained within the boundaries of the A140 and B1113 both of which the Parish Council believes fall within the scope of requirements relating to Undeveloped Approaches to Norwich and Gateways to the City. The previous Application conflicted with this policy and the resubmitted Application destroys the existing nature of the B1113 approach (Gateway) to Norwich.
The additional screening proposed by the Developer to ameliorate damage to the pleasing local vista will, in the Parish Council's opinion: destroy the view from Keswick church; destroy the view from the byway linking the B1113 and Keswick Mill and the view from Marston Marsh.
Transport and Roads.
Overall (even allowing for the proposed junction improvement contained in the latest Planning Application) the proposed Development will have a negative impact on the local highway network and compromise the safety of vulnerable road users. This is contrary to the Inspector's report on the South Norfolk Plan which requires the Development to achieve a positive effect on the local highway network. Moreover, the increase in HGV's already using Low Road is contrary to Council Policy DM 3.13.
Furthermore, the housing developments at Cringleford and modifications to the Thickthorn junction will inevitably mean Low Road (through the village of Keswick) being increasingly used as a "rat run" between the A11 and A140. There are sections of Low Road where pedestrians (some with prams and buggies) must walk on the carriageway where there is already insufficient room for vehicles to comfortably pass. Furthermore, the road is used by horse riders and the wider safety issues for these and other vulnerable road users has long been a concern for the Parish Council.
Already, before any further development takes place, the Parish Council has photographic evidence of HGV's well in excess of the current load restrictions using Low Road thus discrediting assurances previously given that the load constraints would deter heavy vehicles. Arguably, the proposal for a short footpath to address the safety issue actually worsens matters by forcing users to return to walking along the carriageway at one of the most dangerous points.
As part of the first Planning Application the Developer suggested possible arrangements to restrict traffic using Low Road by prohibiting vehicles wishing to access or leave the proposed development. It was stated that such arrangements were in place at some locations around the country. The Parish Council's request for information about these locations was not met by the Developer.
Job Creation.
Keswick and Intwood Parish Council has always maintained there is no need for the additional capacity intended by the proposed site. This view is now supported by clear evidence from the Greater Norwich Local Plan (GNLP) which states: "There is no evidence to justify increasing the overall supply of employment land. Further increasing supply for which there is no demand increases uncertainty, risking investment to bring sites forward. It also increases the risk of encouraging uses that will be damaging to the city and town centres." (GNLP Growth and Options Document para. 6.19.)
The new Planning Application (now up to 12.7 hectares) is substantially larger than the original allocation in KES2 (4.7 hectares). Furthermore, the area is further increased (albeit to provide for additional screening) since the "extent of the site" was a reason for rejecting the original Application. The resubmitted Application is now more than three times the size of the original KES2 plan and the Parish Council has been unable to determine what assessments have been made to justify this scale of space. The Planning and Compulsory Purchase Act 2004 s38 (6) requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. Material considerations for a departure from policy of this scale should be open, transparent and in the public domain.
An absence of a credible viability assessment by the Developer makes it difficult for bodies such as the Parish Council to comment constructively on the submission, which does not meet the requirements of Nolan principles of openness and transparency. The Parish Council is aware of a number of industrial sites nearby with spare capacity. The Developer has patently not demonstrated the need for still more capacity.
Furthermore, the Parish Council has been unable to find evidence of significant current demand for commercial sites in the Norwich area where (it is believed) commercial rents are such that developers generally are not willing to invest in the infrastructure for new commercial estates.
Further clarity has now been brought to this matter by the GNLP, where the evidence base has demonstrated that there are currently around 340 hectares of underdeveloped employment land that is allocated and permitted (which includes the original KES 2 proposal for a B1 development). The Employment, Town Centres and Retail study has concluded that, even to support an advanced level of employment growth, the overall need for land is significantly less at 114 hectares.
Other Villages.
JCS Policy 16 states that Keswick falls within the "Other Villages" description. It therefore has defined development boundaries to accommodate infill or small groups of dwellings and small scale business services, subject to form and character considerations.
Such plans are not deemed suitable for significant new development which would not be supported by the local community. Exceptionally, larger scale development may be permitted where it would bring the facilities up to the level of a "Service Village" and is acceptable having regard to other policies in the JCS or any relevant subordinate plans. To meet the "Service Village" standard would typically mean including a primary school, food shop and improved public transport services.

Executive Summary
This submission is made in respect of Land West of Ipswich Road, East of B1113 (Ref: GNLP0497) on behalf of MAHB Capital the promoters of the site. The submission is made by Ian Douglass, Head of Planning, Lanpro Services, Brettingham House, 98 Pottergate, Norwich, NR2 1EQ ian@lanproservices.co.uk

In order to make our submission representation we have set out our response on this proforma. We have extracted the questions from the consultation document that are relevant to our site and the case for its allocation, and provided written answers supported by plans and other material contained in the Appendices where necessary.
The site presents the opportunity, in combination with an existing allocation (KES2), to provide land for additional employment floorspace in a sustainable location and contribute to the challenge of providing 45,000 jobs in the Greater Norwich Area over the plan period. It is considered that the site, in combination with KES2, would have the capacity to deliver in the region of 30, 000 sq. meters of employment floorspace. A development of this nature could deliver circa 1000 new jobs.
KES2 requires the delivery of a link road between the A140 and the B1113. An expanded KES2 allocation as envisaged by this submission, would facilitate the delivery of this link load (whereas in isolation, KES2 cannot deliver the link road). This has been established through a Viability Assessment (VA).
We note that the evidence base (Employment Land Review) supporting the Reg 18 consultation acknowledges that whilst on paper, there may be a large quantity of potential employment land for development, the quality of this supply is untested. We submit that, going forward, it should be recognised that there are weaknesses within the identified employment land supply pipeline across the Greater Norwich Area and as set out within the GNLP Reg 18 document, and the opportunity to capitalise on sustainably located and deliverable employment land, that can be
made available to the market promptly (such as the site subject of this submission), should not be lost.
An expanded KES2 allocation has been tested and would be viable and deliverable both in respect of delivering a link road between the A140 and the B1113 (providing wider public benefit); and the infrastructure necessary to provide servicing to the site. This means an expanded KES2 allocation could be made available to the market quickly and would not be fettered by infrastructure burdens (as other allocations experience).
In respect of demand, the promoter of the site has a had substantial interest in it from operators from within the B1, B2 and B8 use classes since 2014. The land is available for development and as such, we submit that the site should be included in the emerging local plan.

SEE ALSO ATTACHED REPORT