Draft Greater Norwich Local Plan – Part 1 The Strategy

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.

For example, a greenfield site at land south of Le Neve Road, Marsham (Ref. GNLP2143) is identified as a preferred housing allocation, when a site containing vacant and unused buildings/hardstanding associated with a former poultry unit at Fengate Farm, Marsham (Ref. GNLP3035) is available for development but is identified as an unreasonable alternative. This outcome would not make efficient use of land, which is part of the homes objective for GNLP. As set out in the representations to the GNLP Site Allocations document for the Marsham sites, there are no technical constraints to residential development at the Fengate Farm site and as a 2.6ha site with vacant buildings and having existing residential development on three sides it should have been preferred for housing ahead of any greenfield site.

The approach to housing delivery to direct development to the smaller villages is supported. However, as set out in the representations to the Site Allocations document, it is considered that a more suitable site should have been selected as a housing allocation in Marsham i.e. the former poultry unit at Fengate Farm Marsham (Ref. GNLP3035) which is a vacant developed site that is available for redevelopment for new housing.

The proposed settlement hierarchy and the proposed distribution of housing, as set out in Policy 1, is not wholly supported. As a single defined settlement, it seems contradictory to define Marsham as a Village Cluster. Marsham is a sustainable location for growth, having the following facilities:
• Marsham Primary School
• All Saints Church
• A village hall
• The Plough Public House
• Velocity Strength and Fitness gym
• Various employment units at Norwich Old Road

Furthermore, The Green bus stops (refs. NFODGDTM and NFODGDTP) provide very frequent bus services to Norwich, Sheringham, Reepham and Cromer (Service Nos. 3, 43, 43A, 43B, 44A, 56, X40 and X44). The X40 and X44 are express services providing excellent commuter connections to Norwich city centre.

We maintain that Marsham is a sustainable location with good levels of accessibility and connectivity. The development of circa 35-40 houses at the former Fengate Farm will help maintain existing village services and potentially support the introduction of new shops and services.

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 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.

Policy 2: Sustainable Communities identifies a number of criteria to ensure the delivery of high-quality development.

Criteria 4 seeks to make efficient use of land. However, this principle has not been applied to the selection of the preferred housing allocation in Marsham. In this case, a greenfield site at land south of Le Neve Road, Marsham (Ref. GNLP2143) is identified as a preferred housing allocation, when a site containing vacant and unused buildings/hardstanding associated with a former poultry unit at Fengate Farm, Marsham (Ref. GNLP3035) is available for development but is only identified as an unreasonable alternative. This outcome would be inconsistent with Criteria 4 of Policy 2 and would not make efficient use of land. As set out in the representations to the GNLP Site Allocations document for the Marsham sites, it is requested that land at Fengate Farm site should be identified as a housing allocation in emerging GNLP in preference to a greenfield site.

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 promoted development at land at Fengate Farm in Marsham would include ecological enhancements.

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. The promoted development at Fengate Farm in Marsham (Ref. GNLP3035) would deliver affordable housing for local people.

We object to the approach towards the preferred housing allocation at Marsham. In summary, land south of Le Neve Road, Marsham (Ref. GNLP2143) is identified as a preferred housing allocation, which is a greenfield site on the edge of the village. However, land at Fengate Farm (Ref. GNLP3035) is identified as an unreasonable alternative, despite the fact that it contains vacant and unused buildings/hardstanding associated with a former poultry unit, and there are no constraints to development at it is available.

The draft policy to allocate a greenfield site in preference to a vacant site containing buildings and areas of hardstanding is inconsistent with national guidance that seeks to promote the effective use of land to meet development needs – see Paragraph 117 of the NPPF. The land at Fengate Farm has been vacant for a number of years, the buildings have recently been damaged by fire and are due to be demolished, and it will not be reused as a poultry unit or for any other agricultural use.

If the council does not support residential redevelopment at Fengate Farm the landowners will then need to consider either the re-introduction of intensive agriculture or alternative commercial redevelopment proposals. Such redevelopment would re-introduce a non-conforming and potentially harmful form of development out of keeping with the housing that exists on three sides of the site. Should the council fail to support either the residential, agricultural or commercial redevelopment of the site this would represent planning blight.

As set out in the representations to the Site Allocations document for Marsham sites, there are existing accesses to the site and the vehicular access off Old Norwich Road would be used for the promoted development at the site. It should be noted that the 2014 appeal decision for residential development at the site did not raise any concerns about a vehicular access off Old Norwich Road (Appeal Ref: APP/K2610/A/14/2223121). There are no other technical issues that have been identified that would prevent development at the site. In these circumstances, it is requested that land at Fengate Farm in Marsham (Ref. GNLP3035) should be allocated for residential development in emerging GNLP for at least 35 dwellings.