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New, Revised and Small Sites


Representation ID: 18288

Received: 12/12/2018

Respondent: Dacre Property Holdings

Agent: Bidwells


We strongly support site GNLP2159, which should be taken forward as a residential allocation.

There are a number of factual errors (site address and area) in the Council's documents which need to be rectified.

We disagree with the HELAA ratings for Townscape and Historic Environment, and believe these should be green.

We also disagree with some of the comments in the Site Proposals Addendum regarding highways and townscape constraints.

The site is highly sustainable and is suitable, available, achievable and viable, as well as deliverable within the first five years of the Greater Norwich Local Plan period.

Full text:

Regulation 18 Stage B Consultation Response - November 2018


This Representation has been prepared by Bidwells LLP on behalf of Dacre Property Holdings, in response to the Greater Norwich Local Plan Focussed Sites Stage B (Regulation 18) consultation.

On behalf of our client, we strongly recommend that the site is allocated for residential development. As previously demonstrated, the site occupies a highly sustainable location within Norwich City Centre, part of which is already allocated for residential development under PolicyCC2 of the Adopted Development Plan, and has previously benefitted from planning permission for residential development comprising 151 dwellings, under planning application reference 08/00940/F. Whilst that consent has subsequently lapsed, the site remains entirely suitable for residential development. There have been no material changes to the site or its surroundings that would alter the Council's previous conclusions.

The site has received a preliminary suitability assessment within the October 2018 Housing and Economic Land Availability Assessment (HELAA) Addendum, published as part of the current Regulation 18 consultation. This Representation endeavours to address the potential constraints identified in the HELAA assessment Site Proposals Addendum.
In addition, there are a number of errors within both the Site Proposals Addendum and the HELAA Addendum, which need to be rectified.

Factual Errors within the Consultation Documents

Within the Site Proposals Addendum, the site address is given as Mariners Lane Car Park, and the site area is given as 0.7 hectares. In fact, and as set out on the Call for Sites form submitted in March 2018, the site extends to 1.8ha and comprises 84-120 and 147-153 Ber Street. For clarity, we can confirm that the site has been correctly plotted on the map which accompanies the Site Proposals Addendum.

Within the HELAA Addendum, the site area is again incorrectly given as 0.7 hectares. The site address is also incorrect, as it omits Mariners Lane Car Park.

Comments on HELAA Addendum, October 2018

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.
● Utilities Capacity and Utilities Infrastructure: both green rated.
● Flood Risk: green rated.
● Market Attractiveness: green rated.
● Biodiversity and Geodiversity and Open Space and GI: both green rated.
● Compatibility with Neighbouring Uses: green rated.

Some criteria within the HELAA assessment have received Amber ratings. These issues are explored in more detail below:

● Contamination and Ground Stability: the amber rating, in accordance with the HELAA methodology (July 2016), indicates that there are potential issues with contamination and/or ground stability but that these could be mitigated. We would concur with this rating, given part of the site has been used historically as a petrol filling station, and that there is potential for former chalk workings to exist in proximity to the site. The investigations undertaken in support of the 2008 planning application were accepted by the Environment Agency and the Local Planning Authority to provide confidence that appropriate mitigation could be provided. Therefore, it can be concluded that contamination and ground stability do not represent a constraint to development, and the site is suitable for Local Plan allocation without any further detailed assessment.

● Townscape: the amber rating indicates that development of the site would have a detrimental impact on townscapes which could be mitigated. We disagree with this rating; the HELAA methodology identifies sensitive townscapes as including areas within and adjacent to National Parks, the Broads and Areas of Outstanding Natural Beauty as well as Conservation Areas where up to date appraisals have indicated a high level of townscape significance, where development may affect particular concentrations of listed or locally listed buildings with collective townscape value and any other areas identified as particularly sensitive in Local Plans, local townscape appraisals or historic character studies.

In the case of site GNLP 2159, the site is within the Ber Street Character Area of the City Centre Conservation Area, and close to a number of Grade II Listed Buildings as well as Locally Listed Buildings. The Conservation Area Appraisal identifies the area as one of townscape/landscape quality. Consideration of townscape in this instance therefore relates to the Conservation Area and Listed/Locally Listed Buildings.

The Conservation Area Appraisal identifies part of the site, No. 106-110, as a negative building, and identifies a key townscape element as the tight building line, which has been lost through twentieth century development. The site is identified within Norwich City Council's 'South City Centre Vision and Investment Plan, 2013' as suffering from a weak townscape that is at odds with the historic character of the area. Development would assist in reinstating a sense of enclosure along Ber Street, and as stated in the previous application's Committee Report, could "act as a catalyst for regeneration and promote vitality in the Ber Street area" and "result in the rebuilding of part of a fragmented section of the Ber Street frontage". Development would therefore have a positive impact on the sensitive townscape. Consequently, it is considered that the rating for Townscape should be green, which would indicate that, "development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact, on townscapes".

● Historic Environment: the amber rating indicates that development of the site could have a detrimental impact on a designated or non-designated heritage asset or the setting of a designated or non-designated heritage asset, but the impact could be reasonably mitigated. We disagree with this rating, for the same reasons set out above in relation to Townscape. The Council acknowledge that the site currently has a detrimental impact on the character and appearance of the area. By implication, this means that it has a negative impact on the Conservation Area and the setting of the nearby Listed and Locally Listed Buildings. Redevelopment of the site would, therefore, at worst, have a neutral impact on the heritage assets, and a well-designed scheme would have a positive impact. Consequently, it is considered that the rating for Historic Environment should be green, indicative of development that would, "Have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets".

It is also important to point out that the incorrect site area stated in the HELAA, will have resulted in a significant over-calculation of the likely density of any redevelopment scheme. The first line of the Site Suitability Conclusions states, "This is a 0.7 ha site proposed for a high-density residential development of 150 dwellings"; using the incorrect site area gives a density of approximately 215dph, whereas with the correct site area of 1.8ha, the density would be around 83dph.
The Site Suitability Conclusions also refer to the loss of commercial uses in the City Centre as a 'further factor' but concludes that the site is suitable for residential redevelopment. As set out in the Call for Sites Representation, the site is not located within a designated employment area, and the businesses which currently occupy the site intend to relocate to alternative premises within the city. For example, the current motorbike dealership is currently progressing pre-application proposals for a new location close by.

Comments on Site Proposals Addendum, October 2018

We also disagree with the conclusions set out in the Site Proposals Addendum, which states that, "Constraints include possible highways improvements, as well as townscape matters such as nearby listed buildings and the City Centre Conservation Area". Given that Access, Accessibility to Services, Transport and Roads are all rated green within the HELAA Addendum assessment, it is unclear why highways improvements are identified as a potential constraint. The previous consent established that the site could be developed without unacceptable impacts on nearby residential properties, and with the identified highway works would have no adverse impacts on highway safety or traffic flow. Some of these highway works have already been undertaken along Ber Street, and a number of other significant changes have been made to the traffic circulation in the surrounding area (such as the pedestrianisation of Westlegate), but there is nothing to suggest that redevelopment of the site would give rise to any highways issues, as signified by the green ratings.

For the reasons set out already, we also consider that townscape matters are not a constraint to development of this site.


The site is suitable, available, achievable and viable, and is deliverable within the first five years of the Greater Norwich Local Plan period. There are no constraints that would prevent it from coming forward for residential redevelopment.

On this basis, the site should be taken forward as an allocation for residential development of approximately 150 dwellings in the emerging Local Plan. It would meet all 3 objectives of sustainable development, and would make a meaningful contribution towards meeting housing need within the city centre.

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