Site Proposals document

On behalf of Highcourt Developments Ltd, we strongly recommend that the proposed allocation of site GNLP0401 should be amended from office-led mixed use redevelopment as set out in Policy CC21 of the Adopted Development Plan to residential-led mixed use development, comprising approximately 400 dwellings, or a combination of residential and student accommodation, with retail and/or other appropriate city centre uses at ground floor level.

The site has already been recognised as suitable for residential-led redevelopment through the grant of planning permission under references 14/01103/F and 15/00916/F (both approved in 2015), and is capable of making a significant contribution towards satisfying the Councils' housing needs in the period to 2036, within the Norwich Urban Area.

The current allocation of site GNLP0401 under Policy CC21 is for office-led mixed use redevelopment, with approximately 30 dwellings; it is considered that the proposed amendment to the allocation would not have any detrimental impact on the supply of employment land within Greater Norwich. The Growth Options consultation document acknowledges at paragraph 6.2 that there may not be a need to retain all current employment land; paragraph 6.14 confirms that there is currently around 340ha of undeveloped allocated/permitted employment land, whereas the Employment, Town Centres and Retail study requires only 114ha, even with an enhanced level of employment growth.

Notwithstanding the above, the Growth Options consultation document also sets out a need for city centre office space in paragraphs 4.82 to 4.89, explaining that to enable the growth of a broad range of knowledge based and other businesses, both high quality grade A office space and more affordable and flexible "start-up" and "grow-on" facilities need to be provided in the city centre. The document identifies primary office development locations as Anglia Square, the St Stephens area, Barrack Street/Whitefriars, Barn Road, and the King Street/Rouen Road/Mountergate area. The site is located outside these key areas and is also outside the identified Office Development Priority Area. The site received planning permission for an office-led redevelopment scheme a decade ago, under planning reference 08/00743/F, but this proved unviable, and the current market for large-scale new build office space remains weak in Norwich; as acknowledged at paragraph 4.82 of the Growth Options document, there has been very little, if any, demand for speculative development of high quality offices in the city centre in the last decade. This, combined with the extant full planning permission for residential development, means that it is considered highly unlikely that the site will come forward for office-led redevelopment.

Given the significant oversupply of allocated/permitted employment land, the loss of site GNLP0401 from an allocated office-led reuse would have no adverse impact on the supply of land for office development within Norwich. The Growth Options document recognises at paragraph 6.5 that long term protection of sites allocated for employment use should be avoided where there is no reasonable prospect of a site being used for that purposes, which echoes the guidance contained within the National Planning Policy Framework. In this instance, residential-led redevelopment, or a combination of residential and student accommodation, is considered to be the most economically viable reuse of the site, and office-led redevelopment is unlikely to come forward.

The Greater Norwich Growth Board (GNGB) recognises that there is a lack of brownfield sites within the Norwich Urban Area, and emphasises the importance of identifying further such sites through this Local Plan process. Amending the allocation of site GNLP0401 would reduce the pressure on sites in less sustainable and more sensitive parts of the city and its environs, and those with ongoing delivery issues. In doing so, it would also help ensure that the GNGB is able to deliver the planned 'baseline' growth of 1500 dwellings within the Norwich Urban Area in the period to 2036.

In accordance with the National Planning Policy Framework's (NPPF) definition of 'deliverable', set out in footnote 11 to paragraph 47, the site represents a suitable location for the proposed nature and quantum of development now, is available immediately, is achievable with a realistic prospect of housing being delivered on the site, and is viable.

These points are addressed in further detail below.

In addition, we strongly disagree with the Housing and Employment Land Availability Assessment (HELAA) conclusion that, for the purposes of the HELAA capacity assessment, the site is unsuitable. This conclusion is predicated on the basis that the site is subject to an existing allocation for a 'similar form of development' and consequently will not contribute any additional development capacity. However, we disagree with this approach.

As detailed above, the site is currently allocated under policy CC21 for office-led mixed use development, including approximately 30 dwellings. The site has subsequently been put forward, through the Call for Sites process, for residential-led redevelopment, comprising approximately 400 dwellings. Whilst the site area remains the same, the development capacity of the site is markedly different in both nature and scale. Furthermore, the site has received full planning permission for residential development, which is extant.

Assessment of Deliverability

Suitable

The site is located within Norwich City Centre, and is consequently a highly sustainable location for residential development, with easy access to a full range of services and facilities. As previously described, the site's suitability for residential development has already been recognised by Norwich City Council through the grant of planning permission for 154 residential units on the site in 2015.
The City Centre location lends itself to high-density urban living, and the site is considered suitable for a significantly higher quantum of development, up to approximately 400 units, as part of a residential-led scheme for mixed use redevelopment, which would also include retail and/or other appropriate city centre uses at ground floor level. The consented schemes retain the principal office building, but it is considered that comprehensive redevelopment of the site, including demolition of the main building, which is envisaged in the current allocation, could enable the delivery of a higher quantum of residential units and/or student accommodation as well as delivering wider public benefits.

In terms of more detailed site-specific considerations, the Housing and Employment Land Availability Assessment (HELAA) confirms through a 'Green' rating, that there are no constraints or impacts anticipated in relation to access, accessibility to services, utilities capacity, utilities infrastructure or compatibility with neighbouring uses. Many of the constraints/impacts which have been given an 'Amber' rating, have been demonstrated through the previous planning permissions as not posing an obstacle to development, and should therefore be downgraded to 'Green'. These are addressed in more detail below.

Contamination and Ground Stability
In relation to Contamination and Ground Stability, a Geo-Environmental Desk Study was prepared by Geotechnics Ltd in support of the 2014/2015 planning applications, which concluded that the overall risk of contamination was low, and that further intrusive investigations secured through a planning condition would ensure that any isolated hotspots of contamination would be appropriately mitigated.

Flood Risk
A small area of the site is in Environment Agency Flood Zones 2 and 3. However, redevelopment of the whole site, including the part in Zones 2 and 3, has previously been established as acceptable, through the grant of full planning permission in 2015. An acceptable package of flood mitigation measures was identified, which included repair and heightening of the existing river wall, flood resilient design, and preparation and implementation of a flood warning and evacuation plan. In addition, the Environment Agency have confirmed that habitable floorspace at a minimum of 5.00m AOD will remain dry in all modelled flood events, including the 1:1000 year event (with climate change). Consequently, it is clear that Flood Risk does not represent a constraint to residential-led redevelopment of the site.

Market Attractiveness
The site is a key urban site, for which Highcourt Developments Ltd has received numerous and credible expressions of interest from parties in respect of purchasing the site or for a joint venture for a residential and/or student led mixed use development.

Biodiversity and Geodiversity
Survey work undertaken by Norfolk Wildlife Services in support of the 2014/2015 planning applications confirmed that the site has no features of value to local wildlife. The River Wensum offers potential for foraging and commuting bats, and the site offers minor potential for common nesting birds. A redevelopment scheme could offer significant ecological enhancements, increasing the biodiversity value of the site substantially, and providing opportunities for habitat creation.

Significant Landscapes/Townscapes/Historic Environment
The potential for any redevelopment scheme to impact on Significant Landscapes, Townscapes and the Historic Environment is acknowledged. The site is located within the City Centre Conservation Area and within the area of Main Archaeological Interest, and there are a number of Designated Heritage Assets in the vicinity of the site, including Listed Buildings and a Scheduled Monument, as well as other non-Designated Assets. It is therefore a sensitive location, and any redevelopment scheme would need to ensure, through good design, that no adverse impacts arise. Previous planning consents on the site have successfully demonstrated that it is possible to find an appropriate design solution for redevelopment of the site, with significant increases in the height and scale of built form, without detriment to the Landscape, Townscape and Historic Environment. Any future residential-led redevelopment scheme has the potential to significantly enhance the appearance of this prime city centre site.

Open Space and GI
Any residential-led redevelopment scheme would incorporate an element of Open Space/Green Infrastructure, and as previously described, would provide an opportunity to increase the biodiversity value of the site. Complete redevelopment of the site may also provide an opportunity for enhanced public access to the River Wensum, which would be of significant public benefit.

In conclusion, therefore, it is clear from the above that the site is entirely suitable for residential-led redevelopment and/or student accommodation. The technical reports submitted alongside previous planning applications and detailed above, demonstrates that there are no constraints to the delivery of the site.

Available

The site is within the ownership of a single landowner, who is committed to bringing forward a viable redevelopment of the site, which has been vacant since 1999.

Whilst the central part of the site is currently in use as a public car park, the consent for this use is only temporary and is due to expire on 17th August 2018. Even if further temporary consents are secured for ongoing use of the site for car-parking, these would be on a short-term basis, to ensure that it would not prejudice the ability of the landowner to commence redevelopment of the site.

Achievable

It is considered that residential redevelopment of the site within the first five years of the Greater Norwich Local Plan is entirely achievable. There are no known constraints to delivery of the site in terms of infrastructure requirements etc, and as detailed below, residential-led redevelopment comprising approximately 400 units is considered viable at this stage.

The landowner is committed to the delivery of housing on the site.

Viable

Development of the site for residential purposes is, based on the information available, considered viable, taking into consideration the various policy requirements. Further evidence on viability can be provided on a strictly private and confidential basis, should this be deemed necessary.

Summary

As outlined above, the site is suitable, available, achievable and viable, and is deliverable within the first five years of the Greater Norwich Local Plan period. On this basis, the site's allocation should be revised, and the site taken forward as an allocation for residential-led redevelopment, which could comprise student accommodation, in the emerging Local Plan. This would represent sustainable development in all dimensions.

The site occupies a highly sustainable city centre location, which has already been confirmed as suitable for residential-led redevelopment, through the grant of full planning permission for 156 dwellings. Through demolition of the existing buildings, it is possible to deliver a significantly greater quantum of units than previously consented.
Economically, the site represents the right land in the right place at the right time for residential-led development. Releasing the site from its current office-led allocation would have no detrimental impact on the supply of employment land in Norwich, given the substantial over-supply. Residential development in this location would help support the planned long-term economic growth of the Greater Norwich Area, offering high quality and desirable city-centre homes within easy reach of key employment area. Alternatively, a mixed used development including high-quality student accommodation would assist in attracting high calibre students to the City's tertiary education institutions, which in turn would help support the planned economic growth.
Socially, development of the site would assist in the creation of a high quality built environment, offering homes in an established community with highly accessible local services. A mix of dwelling types and tenures could be provided to meet local needs, or alternatively the site could be developed to provide high-quality student accommodation, for which there is a need.

Environmentally, redevelopment of the site would bring significant improvements to this vacant site. Not only would it significantly enhance the appearance of the area, it would also offer opportunities to enhance the biodiversity value of the site, and, potentially, improve public access to the River Wensum. In addition, the site is located close to a wide range of services and facilities, and residents would be able to meet their day-to-day needs easily and without the need to use their car, assisting in reducing pollution and minimising the contribution to climate change.

The GNLP Site Proposals consultation document recognises that only a limited number of brownfield sites have been put forward for residential development through the previous Call for Sites process, but acknowledges that these types of site offer maximum opportunity for sustainable development. Revising the allocation of site GNLP0401 would significantly improve the GNGB's ability to deliver the 1500 additional homes planned for Norwich in the period to 2036. The site has already been demonstrated to be entirely suitable for residential development, through the grant of full planning permission in 2015, is available for development within the plan period, and there are no constraints that would threaten its delivery.