New, Revised and Small Sites

GREATER NORWICH LOCAL PLAN REGULATION 18 CONSULTATION RESPONSE:
UNIVERSITY OF EAST ANGLIA
LAND ADJOINING THE SAINSBURY CENTRE (GNLP2123)
CONGREGATION HALL (GNLP2120)
These representations have been prepared by Bidwells on behalf of the University of East Anglia (UEA) in response to the Greater Norwich Local Plan Focussed Sites Stage B (Regulation 18) consultation.
On behalf of our client, we strongly recommend that both land adjoining the Sainsbury Centre and Congregation Hall are allocated for university-related uses, alongside the suite of sites already submitted as part of the Call for Sites Process in 2016. Both of the above sites were submitted within the January-March 2018 Stage A Regulation 18 consultation window, alongside additional representations to support the suite of UEA sites submitted as part of the initial Call for Sites process in 2016.
Subsequently, both sites have received preliminary suitability assessments within the October 2018 Addendum Housing and Economic Land Availability Assessment (HELAA), released as part of the current Regulation 18 consultation. The representations endeavour to address any potential constraints/uncertainties identified in the HELAA assessment for both of these sites. The representations also consider the implications of the revised NPPF in relation to the sites.
While the NPPF's definition of deliverable relates to housing sites, the criterion within that definition are applicable when demonstrating the deliverability of both sites within the Plan Period to 2036. These criteria have been divided into relevant headings as follows, to inform the structure of these representations:
● Suitable;
● Achievable;
● Available; and
● Viable.

Land Adjoining the Sainsbury Centre (GNLP2123)
The site was promoted in the Stage A Regulation 18 Consultation for University-related uses. Since then, further engagement with Historic England has identified that development on site GNLP2123 should comprise ancillary uses relating to the Sainsbury Centre.
Assessment of Deliverability
Suitable
The site comprises land to the south and west of the Sainsbury Centre, and is 1.675 hectares. The site constitutes previously undeveloped land and lies adjacent to the defined UEA Campus boundary, as set out by Policy DM26 of the current Development Plan, which broadly follows the built form of the Campus. The site has been assessed in the HELAA, with most suitability criteria achieving Green ratings. These are summarised below:
● Access, Accessibility to Services, Transport and Roads: all Green rated. The site benefits from an access route to Norfolk Drive, and the Highways Authority have expressed their support for the site in terms of its proximity to the existing Campus, and access opportunities.
● Utilities Capacity and Utilities Infrastructure: both Green rated.
● Contamination and Ground Stability: Green rated.
● Flood Risk: Green rated. The site lies entirely within Flood Zone 1, with no risk of surface water flooding.
● Significant Landscapes: Green rated. While the site lies within the Yare Valley Character Area (Policy DM6), the site is well screened from the surrounding context by tree cover. Development in this location is therefore not anticipated to have any adverse impact upon any landscape designations.
● Compatibility with Neighbouring Uses: Green rated. The site is well related to the existing academic uses on Campus, and the development of the site would be associated with the Sainsbury Centre.

Some suitability criteria within the HELAA assessment of the site received Amber ratings. These issues are explored in more detail below:
● Market Attractiveness. The site would be used principally for uses ancillary to the Sainsbury Centre. It is therefore contended that development in this location would only benefit the primary function of the Sainsbury Centre as an exhibition space. From this, Market Attractiveness should receive a Green rating.
● Townscapes. The site is screened from key views across the Campus. For example, the site is screened from the UEA Broad through dense tree cover, and from the wider context by the sloping topography of the site, and the Sainsbury Centre itself. Considering the green rating awarded to the 'Significant Landscapes' element of this site, Townscapes should also receive a Green rating due its low landscape impact.
● Biodiversity and Geodiversity. The Heronry County Wildlife Site (CWS) adjoins the site to the east, while Butterfly Meadow CWS lies to the south. The HELAA assessment notes that a small portion of the red line boundary overlaps The Heronry (0.17ha). The red line boundary of the site will be revised accordingly to exclude the CWS. The development of the site will not encroach upon either CWS, and will not engender any negative ecological impacts, while the marginal revision to the red line boundary will not influence the deliverability of the site. From this, it is apparent that Biodiversity and Geodiversity should receive a Green rating.

● Historic Environment. The site lies adjacent to the Sainsbury Centre, a Grade II* Listed Building. As discussed, engagement with Historic England has identified that the development of the site should comprise uses ancillary to the function of the Sainsbury Centre. Historic England, and other statutory bodies, will continue to inform any proposals for the site as they evolve, so the historic environment aspects of the site can be accommodated and, therefore, the site should receive a Green rating.
● Open Space and GI. The site currently forms amenity land, relating to The Hay Meadows grassland, as identified by the UEA Landscape Strategy (2010). The Landscape Strategy sets out that the key landscape objective for this area is the conservation of the open appearance of University Broad. The site is located to the extreme east of The Hay Meadows, and is enclosed by dense woodland cover to the south and west. The sloping topography of the site reduces the visual significance of the site, which is likely to be further screened by temporary art installations to the east of the Sainsbury Centre, and the Sainsbury Centre itself. The Primary Landscape Conservation objective of this area of the Campus will be not be prejudiced by development at this site. Open Space and GI should, therefore, receive a Green rating.

Similarly, from this analysis, it can be ascertained that the constraints on site can be mitigated through development with supporting technical evidence and good design.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenant on the site consequently, the site is readily available for development.
Achievable
If all planning constraints raised within the HELAA are addressed and suitably mitigated, then the
site can be considered achievable for development.

Viable
The development of the site is considered viable, taking into consideration the various policy requirements in relation to matters such as CIL contributions. Further evidence on viability can
be provided on a strictly private and confidential basis, should this be deemed necessary.

Summary
This site would form a sustainable extension to the Sainsbury Centre. As demonstrated by this representation, those issues raised by the HELAA assessment can be addressed through detailed design of a scheme on this site, as part of any planning application process.

Congregation Hall (GNLP2120)
The site was promoted in the Stage A Regulation 18 Consultation for University-related uses, to comprise the redevelopment of Congregation Hall. The site has been considered for redevelopment by the UEA for many years, with the repurposing of the Hall to become the Congregation Conference Centre proposed in the UEA's Development Framework Strategy (2010).
Assessment of Deliverability
Suitable
The site comprises the existing Congregation Hall, alongside the pocket garden to the north of the site, and comprises 0.337 hectares in total. The site constitutes previously developed land and lies within the defined UEA Campus boundary, as set out by Policy DM26 of the current Development Plan. The site has been assessed in the HELAA, with most suitability criteria achieving Green ratings. These are summarised below:

● Access, Accessibility to Services, Transport and Roads: all Green rated. The site benefits from existing access onto University Drive, with parking provided within Campus, and the Highways Authority have expressed their support for the site in terms of its proximity to the existing Campus, and access opportunities.
● Utilities Capacity and Utilities Infrastructure: both Green rated.
● Contamination and Ground Stability: Green rated.
● Flood Risk: Green rated. The site lies entirely within Flood Zone 1, with no risk of surface water flooding.
● Significant Landscapes and Open Space and GI: Green rated. The site is not located within any landscape designations.
● Compatibility with Neighbouring Uses: Green rated. The site is well related to the existing academic uses on Campus.

Some suitability criteria within the HELAA assessment of the site received Amber ratings. These issues are explored in more detail below:
● Market Attractiveness. The site would be redeveloped to form a key site within the Campus, for academic uses and events spaces. The redevelopment is therefore anticipated to form a substantial benefit in terms of attracting students to the UEA and in its function as an events space. From this, Market Attractiveness should receive a Green rating.
● Townscapes. It is anticipated that the redevelopment of the Hall would have a positive impact upon the townscape of the Campus. For this reason, Townscapes should receive a Green rating.
● Biodiversity and Geodiversity. Violet Grove County Wildlife Site is situated within 200m of the site. However, it is not anticipated that the redevelopment of the site will have any implications for the CWS. Furthermore, the closest SSSI to the site is the Eaton Chalk Pit, located approximately 2km south of the site, so the development of the site will have no impact upon this SSSI. Accordingly, the site should receive a Green rating for Biodiversity and Geodiversity.
● Historic Environment. The closest listed buildings to the site are the Library and the Teaching Wall (both Grade II). Both listed buildings are separated from Congregation Hall by existing buildings, such as Union House, which provide effective screening. Similarly, the site is not located within Earlham Conservation Area, and any development on site would not impact upon its setting. From this, it is apparent that the site should receive a Green rating in terms of Historic Environment.
From this analysis, it can be ascertained that the constraints on site can be mitigated through development with technical evidence and good design.
Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenant on the site Consequently, the site is readily available for development.
Achievable
If all planning constraints raised within the HELAA are addressed and suitably mitigated, then the
site can be considered achievable for development.
Viable
The development of the site is considered viable, taking into consideration the various policy requirements in relation to matters such as CIL contributions. Further evidence on viability can
be provided on a strictly private and confidential basis, should this be deemed necessary.

Summary
This site offers an exciting opportunity to redevelop Congregation Hall into a key re-development site for the University, given its central campus location. As demonstrated by this representation, those issues raised by the HELAA assessment can be addressed through the considered design of the site at a detailed planning application stage.

We trust that these representations will assist the Greater Norwich Local Plan team in progressing its Local Plan review towards the Preferred Options stage, the consultation for which we currently understand is programmed to commence in Autumn 2019.

As indicated within these representations, the UEA and Bidwells are both keen to
engage with the Greater Norwich Local Plan team to meet the challenges of growth, and look forward to discussing matters further in due course, as the development of the University's refreshed Development Framework Strategy continues throughout early 2019.

GREATER NORWICH LOCAL PLAN REGULATION 18 CONSULTATION RESPONSE:
UNIVERSITY OF EAST ANGLIA
LAND ADJOINING THE SAINSBURY CENTRE (GNLP2123)
CONGREGATION HALL (GNLP2120)
These representations have been prepared by Bidwells on behalf of the University of East Anglia (UEA) in response to the Greater Norwich Local Plan Focussed Sites Stage B (Regulation 18) consultation.
On behalf of our client, we strongly recommend that both land adjoining the Sainsbury Centre and Congregation Hall are allocated for university-related uses, alongside the suite of sites already submitted as part of the Call for Sites Process in 2016. Both of the above sites were submitted within the January-March 2018 Stage A Regulation 18 consultation window, alongside additional representations to support the suite of UEA sites submitted as part of the initial Call for Sites process in 2016.
Subsequently, both sites have received preliminary suitability assessments within the October 2018 Addendum Housing and Economic Land Availability Assessment (HELAA), released as part of the current Regulation 18 consultation. The representations endeavour to address any potential constraints/uncertainties identified in the HELAA assessment for both of these sites. The representations also consider the implications of the revised NPPF in relation to the sites.
While the NPPF's definition of deliverable relates to housing sites, the criterion within that definition are applicable when demonstrating the deliverability of both sites within the Plan Period to 2036. These criteria have been divided into relevant headings as follows, to inform the structure of these representations:
● Suitable;
● Achievable;
● Available; and
● Viable.

Land Adjoining the Sainsbury Centre (GNLP2123)
The site was promoted in the Stage A Regulation 18 Consultation for University-related uses. Since then, further engagement with Historic England has identified that development on site GNLP2123 should comprise ancillary uses relating to the Sainsbury Centre.
Assessment of Deliverability
Suitable
The site comprises land to the south and west of the Sainsbury Centre, and is 1.675 hectares. The site constitutes previously undeveloped land and lies adjacent to the defined UEA Campus boundary, as set out by Policy DM26 of the current Development Plan, which broadly follows the built form of the Campus. The site has been assessed in the HELAA, with most suitability criteria achieving Green ratings. These are summarised below:
● Access, Accessibility to Services, Transport and Roads: all Green rated. The site benefits from an access route to Norfolk Drive, and the Highways Authority have expressed their support for the site in terms of its proximity to the existing Campus, and access opportunities.
● Utilities Capacity and Utilities Infrastructure: both Green rated.
● Contamination and Ground Stability: Green rated.
● Flood Risk: Green rated. The site lies entirely within Flood Zone 1, with no risk of surface water flooding.
● Significant Landscapes: Green rated. While the site lies within the Yare Valley Character Area (Policy DM6), the site is well screened from the surrounding context by tree cover. Development in this location is therefore not anticipated to have any adverse impact upon any landscape designations.
● Compatibility with Neighbouring Uses: Green rated. The site is well related to the existing academic uses on Campus, and the development of the site would be associated with the Sainsbury Centre.

Some suitability criteria within the HELAA assessment of the site received Amber ratings. These issues are explored in more detail below:
● Market Attractiveness. The site would be used principally for uses ancillary to the Sainsbury Centre. It is therefore contended that development in this location would only benefit the primary function of the Sainsbury Centre as an exhibition space. From this, Market Attractiveness should receive a Green rating.
● Townscapes. The site is screened from key views across the Campus. For example, the site is screened from the UEA Broad through dense tree cover, and from the wider context by the sloping topography of the site, and the Sainsbury Centre itself. Considering the green rating awarded to the 'Significant Landscapes' element of this site, Townscapes should also receive a Green rating due its low landscape impact.
● Biodiversity and Geodiversity. The Heronry County Wildlife Site (CWS) adjoins the site to the east, while Butterfly Meadow CWS lies to the south. The HELAA assessment notes that a small portion of the red line boundary overlaps The Heronry (0.17ha). The red line boundary of the site will be revised accordingly to exclude the CWS. The development of the site will not encroach upon either CWS, and will not engender any negative ecological impacts, while the marginal revision to the red line boundary will not influence the deliverability of the site. From this, it is apparent that Biodiversity and Geodiversity should receive a Green rating.

● Historic Environment. The site lies adjacent to the Sainsbury Centre, a Grade II* Listed Building. As discussed, engagement with Historic England has identified that the development of the site should comprise uses ancillary to the function of the Sainsbury Centre. Historic England, and other statutory bodies, will continue to inform any proposals for the site as they evolve, so the historic environment aspects of the site can be accommodated and, therefore, the site should receive a Green rating.
● Open Space and GI. The site currently forms amenity land, relating to The Hay Meadows grassland, as identified by the UEA Landscape Strategy (2010). The Landscape Strategy sets out that the key landscape objective for this area is the conservation of the open appearance of University Broad. The site is located to the extreme east of The Hay Meadows, and is enclosed by dense woodland cover to the south and west. The sloping topography of the site reduces the visual significance of the site, which is likely to be further screened by temporary art installations to the east of the Sainsbury Centre, and the Sainsbury Centre itself. The Primary Landscape Conservation objective of this area of the Campus will be not be prejudiced by development at this site. Open Space and GI should, therefore, receive a Green rating.

Similarly, from this analysis, it can be ascertained that the constraints on site can be mitigated through development with supporting technical evidence and good design.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenant on the site consequently, the site is readily available for development.
Achievable
If all planning constraints raised within the HELAA are addressed and suitably mitigated, then the
site can be considered achievable for development.

Viable
The development of the site is considered viable, taking into consideration the various policy requirements in relation to matters such as CIL contributions. Further evidence on viability can
be provided on a strictly private and confidential basis, should this be deemed necessary.

Summary
This site would form a sustainable extension to the Sainsbury Centre. As demonstrated by this representation, those issues raised by the HELAA assessment can be addressed through detailed design of a scheme on this site, as part of any planning application process.

Congregation Hall (GNLP2120)
The site was promoted in the Stage A Regulation 18 Consultation for University-related uses, to comprise the redevelopment of Congregation Hall. The site has been considered for redevelopment by the UEA for many years, with the repurposing of the Hall to become the Congregation Conference Centre proposed in the UEA's Development Framework Strategy (2010).
Assessment of Deliverability
Suitable
The site comprises the existing Congregation Hall, alongside the pocket garden to the north of the site, and comprises 0.337 hectares in total. The site constitutes previously developed land and lies within the defined UEA Campus boundary, as set out by Policy DM26 of the current Development Plan. The site has been assessed in the HELAA, with most suitability criteria achieving Green ratings. These are summarised below:

● Access, Accessibility to Services, Transport and Roads: all Green rated. The site benefits from existing access onto University Drive, with parking provided within Campus, and the Highways Authority have expressed their support for the site in terms of its proximity to the existing Campus, and access opportunities.
● Utilities Capacity and Utilities Infrastructure: both Green rated.
● Contamination and Ground Stability: Green rated.
● Flood Risk: Green rated. The site lies entirely within Flood Zone 1, with no risk of surface water flooding.
● Significant Landscapes and Open Space and GI: Green rated. The site is not located within any landscape designations.
● Compatibility with Neighbouring Uses: Green rated. The site is well related to the existing academic uses on Campus.

Some suitability criteria within the HELAA assessment of the site received Amber ratings. These issues are explored in more detail below:
● Market Attractiveness. The site would be redeveloped to form a key site within the Campus, for academic uses and events spaces. The redevelopment is therefore anticipated to form a substantial benefit in terms of attracting students to the UEA and in its function as an events space. From this, Market Attractiveness should receive a Green rating.
● Townscapes. It is anticipated that the redevelopment of the Hall would have a positive impact upon the townscape of the Campus. For this reason, Townscapes should receive a Green rating.
● Biodiversity and Geodiversity. Violet Grove County Wildlife Site is situated within 200m of the site. However, it is not anticipated that the redevelopment of the site will have any implications for the CWS. Furthermore, the closest SSSI to the site is the Eaton Chalk Pit, located approximately 2km south of the site, so the development of the site will have no impact upon this SSSI. Accordingly, the site should receive a Green rating for Biodiversity and Geodiversity.
● Historic Environment. The closest listed buildings to the site are the Library and the Teaching Wall (both Grade II). Both listed buildings are separated from Congregation Hall by existing buildings, such as Union House, which provide effective screening. Similarly, the site is not located within Earlham Conservation Area, and any development on site would not impact upon its setting. From this, it is apparent that the site should receive a Green rating in terms of Historic Environment.
From this analysis, it can be ascertained that the constraints on site can be mitigated through development with technical evidence and good design.
Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenant on the site Consequently, the site is readily available for development.
Achievable
If all planning constraints raised within the HELAA are addressed and suitably mitigated, then the
site can be considered achievable for development.
Viable
The development of the site is considered viable, taking into consideration the various policy requirements in relation to matters such as CIL contributions. Further evidence on viability can
be provided on a strictly private and confidential basis, should this be deemed necessary.

Summary
This site offers an exciting opportunity to redevelop Congregation Hall into a key re-development site for the University, given its central campus location. As demonstrated by this representation, those issues raised by the HELAA assessment can be addressed through the considered design of the site at a detailed planning application stage.

We trust that these representations will assist the Greater Norwich Local Plan team in progressing its Local Plan review towards the Preferred Options stage, the consultation for which we currently understand is programmed to commence in Autumn 2019.

As indicated within these representations, the UEA and Bidwells are both keen to
engage with the Greater Norwich Local Plan team to meet the challenges of growth, and look forward to discussing matters further in due course, as the development of the University's refreshed Development Framework Strategy continues throughout early 2019.

The following documents submitted in support of Site GNLP2106 - Land South of Taverham Road:

*Highways Assessment and Access Proposal Drawing
*Flood Risk/Surface Water Drainage Strategy
*Foul Sewage and Utilities Drainage Strategy
*Strategic Ecological Assessment
*Indicative Site Plan

See attachments for further details

Please find attached a representation to support site GNLP2003 through the Greater Norwich Local Plan Regulation 18 Stage B Consultation.

The site was first submitted as part of the Regulation 18 Stage A consultation. Subsequently, the site received a suitability assessment within the October 2018 HELAA Addendum. To respond to points raised within the HELAA Addendum, a suite of technical reports were prepared to support our representation, comprising the following:
* Access Appraisal, prepared by Orari Transport Planning;
* Preliminary Ecological Assessment, prepared by The Ecology Consultancy: and
* Preliminary Flood Risk Assessment and Surface Water Drainage Strategy, prepared by BLI Consulting.

Our representation, supported by the attached technical information, demonstrates that site GNLP2003 should be allocated for residential redevelopment, comprising up to 30 dwellings.

See attachments

Please find attached a representation to support site GNLP2047 through the Greater Norwich Local Plan Regulation 18 Stage B Consultation, alongside revised red line plan.

Our representation demonstrates that site GNLP2047 should be allocated for residential redevelopment, comprising up to 5 dwellings.

See attached.

See attachments

Please find attached additional supporting information in relation to GNLP2124 - Model Farm, Stoke Holy Cross.