GNLP2125

On behalf of Pelham (South Wymondham) Ltd, (hereafter referred to as 'Pelham'), we wish to comment on the additional sites currently being considered as part of the latest Regulation 18 consultation. The representation should be read in conjunction with Pelham's site consultation comments of March 2018 that support the allocation of land within its ownership at South Wymondham (site reference GNLP0515).

Prior to commenting on the new sites, we would remind the authority that our client's site GNLP0515 is situated within a sustainable location close to Wymondham Railway Station with excellent links to the many facilities and amenities within the town.

It benefits from good access to core public transport hubs, the strategic road network, would integrate well with the existing ongoing expansion of the town and would represent a logical and sustainable area for future growth. Furthermore, the existing orientation of the settlement puts the heart of the town centre on the outer southern edge and so expansion immediately to the south of the town centre will place it in the centre of the expanded urban area, strengthening the appeal of the town centre and improving economic conditions as is the objective of a 'main town'.

A phase 1 development of 1230 houses is currently underway at South Wymondham and the proposed Phase 2 adjoining development could deliver a minimum of a further 1,375 more homes.

The land is approximately 78 ha, half of which is proposed for residential led mixed use development. Initial concepts suggest 39 ha could be utilised to deliver a minimum of 1,375 new homes, a new school and associated retail and commercial floorspace, all of which would complement the emerging area of growth and benefit existing residents. The residual 39ha could be retained as open space to enhance the wider green infrastructure network.

The scale of growth that could be provided is very much needed. In this regard, Broadland District Council, Norwich City Council and South Norfolk Council are working together with Norfolk County Council to prepare the Greater Norwich Local Plan (GNLP). Early evidence has been established by the Central Norfolk Strategic Housing Market Assessment (SHMA) 2017, which identified the OAN for Greater Norwich from 2015 to 2036 as 39,486 homes (1,880 per annum).

Given the context and the need for new housing, we provide comments on the associated new housing options for Wymondham below.

Site GNLP 0525R is an extension/enlargement of GNLP 00006 to the northern extent of Wymondham. It is therefore predicated on the assumption that the respective promoters are now advancing the site as a single opportunity.

In general terms we support the scale of growth that is being promoted, which is akin to that being advocated by our client. The 2018 updated Planning Policy Framework (NPPF) is clear (Para 72) that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities.

However, having regard to this latter point, we consider that location at north Wymondham is far less suitable than to the south. Development to the north/north east will inevitably have an adverse impact upon the separation of Wymondham and Herthersett and has the potential for causing the coalescence of the two settlements. Regard must also be had to lack of physical boundaries and the potential for unrestricted urban sprawl to the north. In contrast, expansion to the south is both sustainable and can be restricted to the hard boundary provided by the A11 and so providing an opportunity to prevent growth from sprawling beyond this natural barrier.

From a wider perspective, the existing orientation of the settlement puts the heart of the town centre and key transport hubs on the outer southern edge some distance away from this area in the north. In this regard, paragraph 85 of the NPPF is clear that planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. Promotion of growth to the north would do far less to support the town centre than if it were directed to the south.

Having regard to the above, whilst we support the principle of strategic growth, we consider our client's land represents a better and more sustainable and economically beneficial site option for the growth, with far superior links to public transport.

Site GNLP 2073 at Burnthouse Lane, Silfield is less than 1ha and has the capacity to deliver only circa 5 dwellings.

The scale of development would contribute little to the objective of meeting the compelling housing need for both market and affordable housing. Furthermore, it would be unlikely to offer anything by way of developer contributions to offset the pressure on local infrastructure.

Nevertheless, we do recognise that paragraph 68 of the NPPF provides some support for small and medium sized proposals and that 10% of the housing requirement should be delivered on sites of less than 1ha. A balance is therefore needed.

Notwithstanding the importance of smaller sites, GNLP 2073 is detached from the settlement boundary and rural in nature. It benefits from little by way of safe and accessible linkages. Burnthouse Lane lacks public footpaths and the site is not easily accessible to public transport opportunities. Whilst para 7 of the NPPF seeks to promote sustainable development in rural areas, it is also clear that housing should be located where it will enhance or maintain the vitality of rural communities, which would not be the case in this instance.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Site GNLP 2090 East of Field House is capable of delivering circa 50 units. However, it is detached from the main settlement of Wymondham and would fail to represent a suitable and logical natural expansion of Wymondham.

The site is rural in nature and benefits from poor accessibility. Silfield Street lacks public footpaths and the site is not easily accessible to public transport.

As set out above, para 7 of the NPPF seeks to promote sustainable development in rural areas, it is also clear that housing should be located where it will enhance or maintain the vitality of rural communities.

Given the characteristics of the site this would not enlarge or compliment an established rural community. Furthermore, there are wider heritage and ecological constraints.

Having regard to the above, we consider our client's land represents a more sustainable and economically beneficial site opportunity.

Site GNLP 2125 South of Norwich Common is less than 0.5 ha and has the capacity to deliver only circa 8 dwellings, which even then would be drastically out of character with the prevailing area.

We do, again, recognise that 10% of the housing requirement should be delivered on sites of less than 1ha. Nonetheless, the scale of development would provide little to meeting housing need. Furthermore, it would be unlikely to offer anything by way of developer contributions to offset the pressure on local infrastructure.

The site is also identified as being at risk of surface water flooding.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Site GNLP 2150 appears to be part of 0525R to the northern extent of Wymondham and it is unclear as to whether the site and its potential has been double counted. It is again predicated on the assumption that the larger parcel of land comes forward, as in isolation it would be detached from the settlement boundary.

As set out previously, development to the north of Wymondham is less suitable than to the south. It will inevitably have an adverse impact upon the separation of settlements and there is no hard physical barrier to development in the north.

The existing orientation of the settlement puts the heart of the town centre and key transport hubs on the outer southern edge rather than the north.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.


Site GNLP 2155 is located to the north of Wymondham. It contains the curtilage of Downham Grove House, lies to the west of recently developed housing in the north of Wymondham at Carpenters Close.

As set out above, development to the north is less suitable than to the south and there is no hard physical barrier to properly contain growth and the town centre and key transport hubs on the outer southern edge.

Some areas are at surface water flood risk; and, a pond, along with two wooded areas, that may trigger the need for an ecological assessment.

Having regard to the above, we consider the site appears unsuitable for a number of reasons and our client's land represents a better and more sustainable and economically beneficial site option for growth with far superior links to public transport.

Site GNLP 2157 is located to the south west of Wymondham.

The site is rural in nature and benefits from poor linkages. London Road lacks public footpaths and the site is not easily accessible to public transport opportunities.

It is detached from the settlement boundary and rural in nature. Whilst para 7 of the NPPF seeks to promote sustainable development in rural areas, it is also clear that housing should be located where it will enhance or maintain the vitality of rural communities, which would not be the case in this instance.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Site GNLP 2168 consists of 340 ha and is proposed for a new settlement of some 6,500 dwellings south of the A11.

Parts of the land are of Grade 2 agricultural value; there are wooded areas (some of which is ancient woodland); ponds and habitat on site are likely to require ecological investigation.

There are several options to approach meeting housing need, including proportionate growth, larger urban extensions or even the development of new garden villages. We favour the expansion of settlements like Wymondham given the existing infrastructure that can accommodate the growth. In contrast, the provision of a new garden settlement with its own identity and self-sustaining facilities is extremely challenging, albeit not unachievable.

The supply of large numbers of new homes can often be best achieved through planning for larger scale development. In terms of when garden villages become a suitable approach, the 2016 Locally-Led Garden Villages, Towns and Cities prospectus announced broad Government support for 'garden villages', defined as new settlements of a minimum of 1,500 homes and that must be embedded with the key garden city principles. To be a genuine garden village it must be a holistically planned and designed in such a way that development enhances the natural environment and offers high-quality affordable housing and locally accessible work in beautiful, healthy and sociable communities. Garden village principles are an indivisible and interlocking framework for delivery, and include:
* Community ownership of land and long-term stewardship of assets.
* Mixed-tenure homes and housing types that are genuinely affordable.
* A wide range of local jobs in the Garden City within easy commuting distance of homes.
* Beautifully and imaginatively designed homes with gardens, combining the best of town and country to create healthy communities, and including opportunities to grow food.
* Development that enhances the natural environment, providing a comprehensive green infrastructure network and net biodiversity gains, and that uses zero-carbon and energy-positive technology to ensure climate resilience.
* Strong cultural, recreational and shopping facilities in walkable, vibrant, sociable neighbourhoods.
* Integrated and accessible transport systems, with walking, cycling and public transport designed to be the most attractive forms of local transport.

Whilst it may be possible to meet these criteria, we have concern about whether such a level of masterplanning could be achieved within the emerging plan period. Accordingly, it is essential that further information is published to establish the deliverability and suitability of the site as a garden village location. Should the site come forward for development there would be a requirement for major infrastructure improvements, including a potential new junction from the A11, which would inevitably require use of land within our client's control and therefore early engagement would be needed.

Having regard to the above, we consider that a new settlement in this location may be feasible but is more of a longer term option that would be for subsequent plan periods. Should it be seen favourably, it should be designed in such a way that would not sterilise our client's land nor prohibit the sustainable future expansion of south Wymondham within the A11 boundary.

In summary, our client's land represents a better and more sustainable and economically beneficial site option for growth in line with the current draft strategy.

Site GNLP 2169 is located to the south of Wymondham within the heart of the existing phase1 commitments and as such care is needed to ensure against double counting.

In the event that the land is achievable, it represents a sustainable location for growth, albeit at an extremely limited scale.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Summary
Pelham (South Wymondham) Ltd is promoting land within its ownership at South Wymondham (reference GNLP0515) for sustainable residential led mixed use expansion.

Pelham has previously promoted and is delivering major growth to the west and east of Silfield Road (Phase 1). Our client directly obtained the relevant outline permission for the existing planned growth and the detailed phases of development are subsequently now being delivered on the ground by national housebuilders. Pelham therefore has a good track record of delivery. The land now being proposed amounts to what would logically be considered as a second phase of the development and therefore the ability to properly integrate new development makes site GNLP0515 the ideal location for growth.

The combined effect of the Phase 1 development of 1230 houses currently underway at South Wymondham and the proposed Phase 2 adjoining development of a minimum of 1,375 houses re-balancing the position of the town centre and enabling sustainable growth to be delivered, with significant economic benefits for the town centre.

Phase 2 could deliver a minimum of 1,375 new homes, a new school and associated retail and commercial floorspace, all of which would complement the emerging area of growth. The residual 39ha would be retained as open space to enhance the wider green infrastructure network.

Whilst detailed proposals are yet to be advanced and would be subject to meaningful dialogue with the LPA, the Local Community and key stakeholders, it is clear that the site is wholly suitable for residential development. From an environmental perspective, the land has extremely low landscape value and does not form any formal planning designation such as green belt or area of outstanding natural beauty. Furthermore, there are no overriding environmental constraints that would prevent development.

The site does not lie within or in immediate proximity to any nationally or European designated site such that development of the site would be contrary to the Habitat Regulations or adversely affect the integrity of any designated sites. The closest site of note is the Lower Wood Ashwellthorpe SSSI which is some 3km to the south east and will remain undisturbed.

The predominant land use within the site is agriculture the majority of which is arable in nature. There are no public records of any farming related Environmental Stewardship Schemes in existence within the site which confirms that the actively farmed areas of the site are likely to be of limited ecological value.

Arboriculture investigations will be required. However, we do not envisage tree impact to be an absolute constraint to development. The majority of trees on the site are in groups that can be maintained and incorporated into landscape and open space features. Furthermore, substantially increased levels of planting are likely to be achieved as a result of a comprehensive landscape led approach to the masterplanning process. There are no areas of ancient woodland.

The site falls within an area that does not directly impact the setting of any listed building. Furthermore, given the locality of the land, the relative distance to the nearest listed building and Scheduled Monuments, the archaeological potential of a site is considered to be low. However, the site consists of undeveloped land and therefore there remains some element of risk of an archaeological find and therefore a precautionary approach would be applied.

The site itself comprises a mixture of arable land and a number of perimeter trees. However, overall the site is considered to be of low or limited ecological value and this is not considered to represent a significant risk to its development potential.

Any development could be progressed immediately with approximately 300 new homes being capable for delivery in the immediate first five years of the plan period. The emerging Bovis and Taylor Wimpey scheme on the Phase 1 site delivers a new access link onto Park Lane which would form the principal access to the initial 300 units that can immediately be delivered to the west of Park Lane. A further emergency access could also be achieved adjacent to the Green Land/Park Lane junction but would not be reliant on this for any through traffic.

Subsequent phases will require upgrading of the highway network. The precise nature of the infrastructure upgrades will be subject to detailed discussions with key stakeholders as the plan making process progresses. However, we can confirm that all of the necessary upgrades are either already being delivered through the Phase 1 development or would be delivered through the Phase 2 scheme on land our client controls sufficient to deliver wider upgrades within and around the site if they prove necessary.

In respect of deliverability, the land has no planning history of relevance nor any history of unimplemented permissions and there are no known impediments to the site being phased for early commencement within the 0 -5 year period.

No unexpected financial restrictions are anticipated that would impact upon the viability of the site nor that would prohibit development coming through within the early stages of the plan period. To the contrary, we consider there to be an opportunity to deliver a high quality and exemplar scheme.

The site is in control of a single land owner and there are no legal agreements or covenants that would prohibit the ability to bring the site forward early in the plan period.

Taking all of the above into account and having regard to the new development options currently subject to consultation, we consider our client's site continues to represent the most suitable and economically beneficial location for the immediate and longer term growth and expansion of Wymondham and falls in line with our preferred growth options as set out in our representations of March 2018.