Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22252

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

The topics included within the Vision and Objectives for GNLP are generally supported. However, it is considered that the objectives related to homes and delivery would not be achieved in full because in some instances inappropriate sites have been selected as preferred options or reasonable alternatives.

Object

Representation ID: 22253

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

We object to the approach to housing set out in the Delivery Statement in respect of the contingency locations for growth at Costessey to offset any non-delivery of housing elsewhere, and in particular the sites selected as reasonable alternatives/contingency locations in those settlements.

Support

Representation ID: 22254

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

The proposed settlement hierarchy and the proposed distribution of housing, as set out in Policy 1, is supported.

Comment

Representation ID: 22256

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

The standard method is used in emerging GNLP to determine the minimum number of houses needed during the plan period. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Firstly, Paragraph 010 identifies the circumstances where increases to housing need might be appropriate, including where there is a growth strategy, strategic infrastructure improvements are proposed, and to meet unmet needs from a neighbouring area. The consultation document for emerging GNLP refers to employment growth and infrastructure. It is Page 3 of 10 requested that the draft version of GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a have been taken into account for the housing requirement. Secondly, Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. It is not clear whether the housing requirement for emerging GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.

Comment

Representation ID: 22257

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

Policy 2: Sustainable Communities identifies a number of criteria to ensure the delivery of high quality development. Criteria 5 seeks to respect, protect and enhance landscape character.

Land at Green Lane West, Rackheath
A full Landscape and Visual Impact Assessment (LVIA) has been prepared for the proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) as part of the current planning application at the site. In summary, there are residential areas to the north, commercial development to the south, the Norwich Northern Distributor Road (A1270) to the west, and the proposed strategic development at North Rackheath Urban Extension would be located to the east. The site is enclosed by a dense hedgerow and hedgerow tree planting to the east. The majority of the existing vegetation within the site would be retained within the proposed development. The proposed residential areas will include landscaping and structural planting. The proposed development includes a substantial area to the east of the Norwich Northern Distributor Road for landscape enhancement and new wildlife habitats. The overall conclusion from the LVIA is that the site is a suitable location for residential development in terms of landscape and visual impacts, provided the landscape mitigation and enhancement measures are implemented. The case officer for the planning application accepted that the development would be visible in the immediate area, but concluded that the site would be well screened from long distance views and that the additional landscaping to be provided as part of the proposed development would reduce the visual impact. In addition, the case officer acknowledged the provision of open space, green infrastructure, highway access and an acoustic bund would ensure the delivery of a high quality development.

Land off Townhouse Road, Costessey
A draft Landscape & Visual Impact Assessment has been prepared for the land off Townhouse Road in Costessey (Ref. GNLP0284R), which is identified as an unreasonable site in the GNLP Site Assessment document for Costessey sites. The landscape impact was one of the reasons why the site was assessed as unreasonable. It is considered that landscape impacts can be mitigated. This site is well-related to the existing built-form in Costessey and represents a natural and logical continuation of the settlement. The majority of the existing vegetation at the site boundary will be retained within the promoted development. The promoted development will enhance the boundaries to the site, with new tree planting on the western boundary and a new woodland belt on the southern boundary, alongside green corridors, planting and areas of open space within the development. The significant green buffers and corridors are provided to mitigate the impact of new development at the site and integrate it into the landscape setting. Therefore, it is considered that the promoted development at the site would respect, protect and enhance the landscape character of the surrounding area and edge of Costessey, which is consistent with Criteria 5 of Policy 2.
In addition, the delivery of green infrastructure and landscaping at the Green Lane West site in Rackheath and Townhouse Road site in Costessey would contribute towards Criteria 3 of Policy 2.
Policy 2 includes a requirement for delivery statements to be prepared for developments of 100 dwellings or more, setting out a timetable for housing delivery at the site. The requirement for a delivery statement is appropriate, but the information provided in the statement needs to be robust, and a statement is no substitute for the allocation of deliverable sites in emerging GNLP. It is considered that a detailed assessment of housing delivery should be undertaken before sites are allocated for development or identified as reasonable alternatives, because discussions with developers on its own represents a limited and inadequate approach.
A detailed assessment of housing delivery would have highlighted that the proposed strategic extension contingency sites for +1,200 dwellings at land off Bawburgh Lane and New Road (Ref. GNLP0581) and land north of New Road and east of A47 (Ref. GNLP2043) cannot be delivered quickly enough to address non-delivery at allocations and commitments in Costessey in the short term. As set out in the representations to the Site Allocations document, land off Townhouse Road in Costessey (Ref. GNLP0284R) is deliverable, is controlled by a housebuilder, and should be allocated or identified as a reasonable alternative site.

Comment

Representation ID: 22258

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

Land at Green Lane West, Rackheath
It should be noted that national guidance expects planning decisions to contribute towards and enhance the natural environment, and to secure measurable net gains for biodiversity – see Paragraphs 170 and 174 of the NPPF. It should be acknowledged that development can deliver ecological enhancements and net biodiversity gains. The proposed allocation at Green Lane West in Rackheath would include ecological enhancements. The case officer for the planning application accepted that the site currently has limited ecological value and the open space is not managed, and concluded that the proposed development would lead to a net gain in biodiversity.
Land off Townhouse Road, Costessey
The promoted development at Townhouse Road in Costessey would include ecological enhancements. Where possible, hedgerows at the boundaries of the site should be retained and enhanced to create corridors and shelter/foraging areas for wildlife including birds, bats, badgers and hedgehogs. Planting of native hedgerow species in gaps, for example along the southern and eastern boundaries will provide further opportunities for these species and enhance their value as ecological corridors.
The addition of bat boxes to any new buildings or retained trees within the site would provide additional roosting opportunities. Schwegler bat boxes are recognised as being suitable for roosting bats and long lasting. Bat boxes should ideally be located south facing (between south-east and south-west) and above 5m. Boxes such as Schwegler 2F or integral bat tubes Schwegler 1FR suitable for pipistrelles would be suitable for this site.
Landscaping could incorporate native or wildlife attracting trees, shrubs, and wildflower areas as these would likely be of benefit to a variety of wildlife including, birds, bats and invertebrates. Such landscaping could also act as a receptor area should reptiles be recorded using the site and require translocation.
The incorporation of a reptile hibernaculum into the landscape design (preferably within any wildflower grassland) will enhance the area for reptiles in the future. Hibernacula can be created by partially burying piles of wood/rubble and covering with earth. Hibernacula in the form of log piles could also benefit hedgehogs.
The addition of a range of bird boxes would provide additional nesting opportunities. This could include house sparrow terraces on any new buildings on site providing additional nesting opportunities for this BoCC red listed species recorded on/over site. Further standard bird boxes sited on mature trees will help attract a greater diversity of birds to nest. Boxes should be located out of direct sunlight and close to, but not restricted by, vegetation. A suitably qualified ecologist should be consulted to determine the exact location and position of the bird boxes.
The addition of insect houses/hibernacula within retained or created wildflower grassland would retain shelter and hibernation opportunities for invertebrates using the grassland or boundary habitats.

Comment

Representation ID: 22260

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

The affordable housing requirements in Policy 5: Homes are noted, including that the affordable housing requirement is lower for development in Norwich compared with Broadland and South Norfolk. However, it is normal for strategic extensions and new settlements/garden villages to not provide policy compliant levels of affordable housing during the initial phases of development because of the costs of providing primary infrastructure e.g. roads, drainage, strategic landscaping, and community uses in advance of residential development. It is very unlikely, and potentially undesirable, for affordable housing requirements to be increased for later phases of development at strategic extensions and new settlements to address under-delivery in initial phases. Therefore, it is considered that the strategic extension identified as reasonable alternatives for housing allocations at Costessey would not meet the policy requirements for affordable housing. In these circumstances, other sites that can deliver policy compliant levels of affordable housing should be identified in emerging GNLP. The preferred allocation at land to the west of Green Lane West in Rackheath (Ref. GNLP0172) and the promoted development at land off Townhouse Road in Costessey (Ref. GNLP0284R) will both deliver affordable housing. The planning application for the proposed development at Green Lane West in Rackheath provided for 33% of the dwellings to be for affordable housing.

Object

Representation ID: 22261

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

Land off Townhouse Road, Costessey
Policy 7.1 contains the development strategy for the Norwich Urban Area and the fringe parishes. We object to the strategy for Costessey, in respect of the decision to make no allocations in the village and the sites identified as reasonable alternatives. A number sites have been identified as a reasonable alternative housing allocation at Costessey, including a strategic extension for +1,200 dwellings at land off Bawburgh Lane and New Road (Ref. GNLP0581) and land north of New Road and east of A47 (Ref. GNLP2043). The land off Townhouse Road in Costessey (Ref. GNLP0284R) is promoted for residential development, but it is considered that this site has been incorrectly identified as an unreasonable site in the GNLP Site Assessment document.
It is very unlikely that the strategic extension sites in Costessey identified as reasonable alternative would be delivered quickly enough to address a housing land supply shortfall in Costessey in the short term. The lead-in times for these types of developments are typically more than 5 years, largely because they are complex and require significant levels of primary infrastructure to be provided e.g. roads and drainage in advance of housing. On this basis, it is considered that the strategic extension sites in Costessey are not reasonable because they would not meet the purpose of a contingency site i.e. to meet non-delivery elsewhere. In addition, as set out in the representations to the Site Allocations document, there are identified constraints and uncertainties to development at the strategic extension sites in Costessey (Ref. GNLP0581 and GNLP2043), including access arrangements and proximity to the Norwich Southern Bypass. It has not yet been confirmed that these strategic extension sites are available or suitable for development, and as such they should not be identified as reasonable alternatives. Furthermore, the other identified reasonable alternative site in Costessey, at Roundwell Works (Ref. GNLP0593) would lead to the loss of employment land and the access arrangements have not been confirmed, and as such it may also not be a reasonable alternative site.
As set out in the representations to the Site Allocations document for Costessey sites, the promoted development at land off Townhouse Road in Costessey (Ref. GNLP0284R) is smaller than the strategic extension site, it is controlled by a housebuilder, and is available for development, and as such it could meet the requirements for a contingency site to meet non-delivery elsewhere. A number of technical reports and studies have been prepared for the site which demonstrate that there are no constraints to development and significant impacts can be mitigated, and concept plans have been prepared to identify different development options for the site i.e. 100, 130 and 200 dwelling options. The technical evidence demonstrates that landscape impacts can be mitigated by retaining existing trees and hedges, providing new areas of woodland and landscaping, and creating new areas of open space. The site is not affected by flood risk, and a drainage strategy would be prepared for the promoted development to manage surface water drainage. An area of open space would be created at the site frontage along Townhouse Road. Therefore, it is considered that land off Townhouse Road in Costessey (Ref. GNLP0284R) should be allocated in emerging GNLP or identified as a reasonable alternative site to meet future needs.