Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 22862

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

We object to the reference in paragraph 340 to an arbitrary limit of 3 dwellings for windfall sites outside settlement boundaries. This suggests that 4 dwellings would be unacceptable, yet would clearly not undermine the settlement hierarchy or be out of character with a village edge, and neither would 5 houses or 10. The policy should relate to character and appearance, with sites referring to natural boundaries on the ground rather than contrived sites or sites that do not make the best use of land. We comment more fully on this point under question 47 below.

Object

Representation ID: 22864

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Poringland / Framingham Earl. The lack of new allocations in the policy fails to acknowledge the need for settlements to continue to grow. We are promoting Octagon Farm for mixed use development on the northern edge of Poringland. This will consolidate existing development in the vicinity, including Octagon Barn and the residential development on the opposite side of Bungay Road. The mixed use nature of the site will facilitate homes and employment that will contribute to the vitality of this high order sustainable settlement.

Without new site allocations, Poringland will be unable to meet ongoing needs for affordable housing and community-related contributions that arise from housing applications. Restricting new sites to 3 units (under the windfall policy) will not produce the contributions that would otherwise support the vitality of the community. The opportunity to allocate Octagon Farm for mixed use development should therefore be grasped.

Object

Representation ID: 22865

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Windfall sites are an important element of overall housing provision, and are often able to be provided quickly and by a variety of providers due to their smaller size in relation to major development sites. Policy 7.5 should omit the reference to 3 dwellings. The final sentence of the policy will ensure that development proposals respect the settlement hierarchy, the character and appearance of the area, and their relationship to site context and boundaries.

Restricting windfall sites to 3 units means that the threshold for affordable housing will not be able to be met, whereas encouraging larger developments within the parameters suggested above would yield genuine benefits to the communities that such sites are associated with.

Comment

Representation ID: 22866

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Appendix 1 Infrastructure Requirements (and by extension Greater Norwich Local Plan Infrastructure Needs Report).

It is disappointing that there is no discussion on the Park and Ride system, or infrastructure for buses in general. There is also no discussion of public charging infrastructure for electric vehicles. We note that the review of Park & Ride sites has yet to be published, but would point out that the allocation of the proposed Loddon P&R site will provide the opportunity to complete the ring of P&R sites to serve each radial road route towards the city, and will be able to facilitate electric vehicle charging points at construction stage rather than by retro-fitting.

Comment

Representation ID: 22867

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Greater Norwich Local Plan Infrastructure Needs Report

There is no discussion of Park and Ride facilities, or of plans for buses in general – whilst the contents page states section 5.2 Bus and Rail, the section itself only discusses rail. If Greater Norwich is to achieve its vision of sifting towards sustainable transport methods, the requirement for additional bus capabilities and the infrastructure to serve them is a key requirement which must be planned for. The exclusion of bus infrastructure, including P&R facilities, is therefore an oversight which requires addressing. It is our opinion that there is a clear need for an additional P&R along the A146 corridor, and the GNLPINR should therefore include an assessment of further P&R requirements to ensure the appropriate infrastructure can be brought forward.

Comment

Representation ID: 22868

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Loddon P&R
It is considered that the Sustainability Appraisal's (SA) assessment of the Loddon P&R site has been undertaken in an overly broad manner, resulting in negative impacts being stated for categories where this is not justified. The matters will be discussed here in the order taken by the SA.

Objective 1 'Air Quality', the SA states air and noise pollution concerns occur because of its location adjacent to the A146. Any minor negative impact on air and noise quality at the site fails to take account of the circumstances of the site’s proposed use and the bigger picture. A Park and Ride will by nature have users which are transitory – being on the site no more than 15 – 30 minutes, and more importantly, the provision of P&R facilities improves air quality within the city centre, by removing cars that would otherwise drive in. Air quality and noise pollution should therefore not be counted as negatives against the proposal.

Under Objective 2 'Climate Change Mitigation and Adaption', the location of the site in Flood Zone 1 should be a major positive impact (rather than minor positive) as the proposal will locate end users on a site with the least possible risk of fluvial and surface water flooding.

Under Objective 3 'Biodiversity', a minor negative impact is stated because of the site being located within 5km of The Broads SAC and Broadlands SPA and Ramsar, and within the IRZ of the Yare Broads and Marshes SSSI. The provision of a P&R site in this location will not add to direct pressure on those sites, and ecological impacts can be mitigated within the design. Impact should therefore be neutral at worst.

The section on Objective 4 'Landscape' states development of the site would have a minor negative impact on the local landscape character. While it is accepted that the introduction of a P&R would invariably alter the character of the site itself, it is considered that impact on the wider countryside character could be appropriately mitigated through careful, landscaping-led masterplanning of the site. A full Landscape and Visual Impact Assessment will be submitted at a later stage to demonstrate the landscape effects of the proposed P&R scheme.

It is unclear how the proposed development could have a negative impact on access to local services, as stated under Objective 6 'Population'. A P&R would actually have the opposite effect, allowing a greater range of users easier access to services via public transport.

In a similar vein, under Objective 8 'Health' it appears the site has been assessed for health purposes as if the proposal is for housing. The proposal would not restrict access to the Norfolk and Norwich University Hospital. The site being located outside of the target distance of the nearest GP surgery, hospital and leisure centre is not of relevance to the proposed use as a P&R and should therefore not be recorded as a major negative impact.

The major positive impact on the local economy stated under Objective 11 'Economy' is agreed with. As well as creating jobs through the construction and operation of the P&R itself, there will also be a positive impact on the Norwich economy as the P&R will make it easier and more convenient for workers and visitors to travel into the city centre.

Under Objective 12 'Transport', the SA has recorded minor negative impacts in terms of access to bus and rail services. This conclusion is entirely contradictory to the purpose of a Park and Ride which will improve access to bus services for a range of people, allowing access into the city centre in a more convenient and sustainable manner. This should therefore instead be recorded as a major positive impact.

Objective 13 'Historic Environment' states potential impacts to designated heritage assets identified as the setting of the Grade II Listed Bixley Mill, Crown Point Registered Park and Garden, and the Scheduled Remains of Medieval Settlement 380m south of Park Farm. As only a minor negative impact has been identified by the Council, the development of the P&R site is not considered to result in substantial harm to the heritage assets. However, to ensure that development of the site appropriately takes into account the setting of the identified heritage assets, a detailed assessment of the potential impacts will be undertaken to inform the masterplanning of the site. With these measures, it is considered that heritage impact is not an onerous constraint to the allocation of the site.

Under Objective 15 'Water', it is stated that the site is within the catchment (Zone III) of a groundwater SPZ, and minor negative impacts are recorded due to a risk of groundwater contamination. It is considered that this risk can be effectively mitigated through the implementation of a robust drainage strategy tied in with the use of appropriate hard surfacing across the site, and there would therefore be no negative impacts.

Comment

Representation ID: 22869

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Park Farm

Park Farm has not been assessed in the Sustainability Appraisal. However, we make the following points:

Objective 11 – Economy. Development proposals which would result in a net increase in employment floorspace would be expected to have a major positive impact on the local economy.

Objective 14 – Natural Resources, Waste and Contaminated Land. In accordance with the core planning principles of the NPPF, development on previously developed land will be recognised as an efficient use of land. Development of previously undeveloped land and greenfield sites is not considered to be an efficient use of land, but there are wider considerations as to the appropriate use of greenfield sites. Development of an existing brownfield site would be expected to contribute positively to safeguarding greenfield land in Greater Norwich and have a minor positive impact on this objective.

Comment

Representation ID: 22870

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

WCP

SA Objective 1 – Air Quality and Noise notes that development at WCP could potentially expose site end users to higher levels of transport associated air and noise pollution. Traffic using the A47 and A146 would be expected to have a minor negative impact on air quality and noise at these sites. We propose that WCP is safeguarded for future country park-related development.

Railway Line: The north of Site GNLP3052 is located adjacent to a railway line. The proposed development at this site could potentially expose site end users to higher levels of noise pollution and vibrations associated with this railway. A minor negative impact would therefore be expected.

Air Pollution: The SA nots that WCP is proposed for non-residential end use and comprises 220.3ha. The proposed development at this site could potentially result in a significant increase in local air pollution; therefore, a major negative impact would be expected. However, this seems to assume that some form of high density commercial development is proposed, whereas we are proposing to safeguard the site for open space and leisure uses. The masterplanning for the site could achieve benefits in air pollution terms and the SA should therefore record a positive impact.

SA Objective 2 – Climate Change Mitigation and Adaptation. In terms of Fluvial Flooding, the SA notes that the north of the site is adjacent to Whitlingham Great Broad and located within Flood Zones 2, 3a and 3b, such that proposed development could potentially locate some site end users in areas at risk of fluvial flooding; therefore, a major negative impact would be expected. However, the extensive nature of the site means that any proposed leisure development can be located such that users are kept away from areas at risk of fluvial flooding. Therefore the SA should record a positive impact in relation to site GNLP3052.

Surface Water Flooding: Small areas within the site coincide with areas determined to be at low, medium and high risk of surface water flooding. Development would be expected to have a major negative impact on pluvial flood risk, as development would be likely to locate site end users in areas at high risk of surface water flooding, as well as exacerbate pluvial flood risk in surrounding locations. However, this assumes significant built development and significant ground coverage which is not the case. The appropriate design and management of the extensive green space will facilitate on-site flood attenuation, with knock-on reduction in risk to surrounding locations as a result of controlled run-off, such that the SA should record a major positive impact.

SA Objective 3 – Biodiversity, Geodiversity and Green Infrastructure. SSSI IRZ: This section of ‘The Broads’ SAC and ‘Broadland’ SPA and Ramsar is also designated as ‘Yare Broads and Marshes’ SSSI. The site is located within an IRZ which states that “all planning applications (except householder) outside or extending outside existing settlements/urban areas affecting greenspace, farmland, semi natural habitats” should be consulted on. The SA assumes a minor negative impact on the features for which these SSSIs have been designated would be expected, due to development on natural greenspace. However, our proposal is to safeguard the additional WCP land for country park use, which can only benefit biodiversity, both by providing / protecting it on site, and by providing space for leisure use, thus reducing human pressure on designated habitats elsewhere.

LNR: Site GNLP3052 coincides with ‘Whitlingham’ Local Nature Reserve. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park, which is coincident with this LNR. As this site is proposed for tourism and a Country Park, it is assumed that the developable area of the site will exclude the LNR itself, and therefore, a negligible impact on this LNR would be expected. We agree with this assessment.

CWS: Site GNLP3052 coincides with ‘Old Wood’, ‘Trowse Wood’ and ‘Trowse Meadows’ CWSs. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park, which is coincident with these CWSs. As this site is proposed for tourism use and a Country Park, it is assumed that the developable area of the site will exclude these CWSs, and therefore, a negligible impact on these CWSs would be expected. We agree with this assessment.

Priority Habitats: Site GNLP3052 coincides with deciduous woodland, coastal floodplain grazing marsh, and good quality semi-improved grassland priority habitats. The proposed development is considered by the SA to be likely to result in the partial loss of these habitats, and therefore, have a minor negative impact on the overall presence of priority habitats in the Plan area. However, the safeguarding of this site for additional country park usage means that habitats can both be safeguarded and created, leading to net gain.

SA Objective 4 – Landscape. National Park/Country Park: The majority of Site GNLP3052 coincides with The Broads National Park. A proportion of this area also coincides with Whitlingham Country Park. The proposed development at this site is for recreation and tourism end use associated with Whitlingham Country Park. The nature and exact location of the proposed development is unknown at this stage and therefore the impact on this National Park and Country Park is uncertain. Our proposal is to safeguard the site for country park usage, which can only benefit the country park as a whole.

Landscape Character: The majority of Site GNLP3052 is located within the LCA ‘Yare Valley Urban Fringe’. Some key characteristics of this LCA include the wide, flat floodplain, recreational landscape and green buffer between the river valley and Norwich City. Site GNLP3052 is proposed for recreation and tourism end use, and therefore, the proposed development at this site would be unlikely to be discordant with these key characteristics. We agree with this assessment.

Views from the PRoW Network: Site GNLP3052 coincides with a PRoW. Development could potentially alter the views experienced by users of the PRoW network; therefore, a minor negative impact on the local landscape would be expected by the SA. However, altered views are not necessarily altered in a negative way, and the impact should be recorded as neutral.

Views for Local Residents: Site GNLP3052 is located adjacent to the settlement of Trowse Newton. The SA considers that development would be likely to alter the views experienced by residents of surrounding dwellings to some extent, and therefore, a minor negative impact on the local landscape would be expected. However, as noted above, altered views are not necessarily altered in a negative way, and the impact should be recorded as neutral.

SA Objective 6 – Population and Communities. Local Services: The nearest local services WCP are Trowse Village Store in Trowse Newton, or Morrisons supermarket within Norwich City. The site is located outside the target distance to these services. The proposed development at these two sites could potentially have a minor negative impact on the access of site end users to local services. However, residential development is not proposed at this site, which is intended to be safeguarded for country park related development, thus a neutral impact should be recorded.

SA Objective 8 – Health. Main Road: the site is located adjacent to the A47, where development could potentially expose site end users to higher levels of traffic associated emissions, which would be likely to have a minor negative impact on the health of site end users. However, this assumes residential development, whereas we propose that the site is safeguarded for country park uses, and should therefore expected to have a minor positive impact on health.

GP Surgery: The closest GP surgery to the site is Lakenham Surgery, located approximately 1.5km to the north west, outside the target distance such that the SA assumes development would be expected to have a minor negative impact on the access of site end users to GP surgeries. However, the site is proposed for country park related uses, not residential development.

As the site is located outside the target distance to an NHS hospital, GP surgery and leisure centre, development would be expected to have a major negative impact on the health and wellbeing of site end users. However, the site is proposed for country park related uses, not residential development, such that these services would not be required on a day to day basis, and country park usage would have a positive impact on health in itself.

SA Objective 11 – Economy. Employment Floorspace: the site is proposed for tourism end use. This would be expected to result in the provision of employment opportunities in the local area, and therefore, a major positive impact on the local economy would be expected as a result of development at these four sites. Site GNLP3052 currently coincides with ‘Kingsley Farrington Boatyard’ and ‘Norfolk Snowsports Club’. Site GNLP3052 is proposed for tourism end use and it is assumed that the development will incorporate these existing facilities, and therefore, would be expected to result in a net gain in employment floorspace overall. We agree with this assessment.

SA Objective 12 – Transport and Access to Services. Bus Stop: the site is outside the target distance to a bus stop providing regular services. Therefore, the proposed development at these three sites could potentially have a minor negative impact on site end users’ access to bus services. However, this could change with the significant amount of development proposed for this part of Norwich and with the development of the Loddon P&R site we are promoting.

Railway Station: The closest railway station to the site is Norwich Railway Station, located approximately 3km to the north west. A large proportion of the site is situated outside the target distance to this station. Therefore, the proposed development at these two sites would be likely to have a minor negative impact on site end users’ access to rail services. However, we anticipate that the country park usage would be mainly beneficial for local users.

Pedestrian Access: The site is well connected to the existing footpath network. Development would be expected to have a minor positive impact on site end users’ access to the PRoW network and opportunities to travel by foot. We agree with this assessment.

SA Objective 13 – Historic Environment. Grade I Listed Buildings: The site is located approximately 40m from the Grade I Listed Building ‘Church of St Andrew’. The proposed development at this site could potentially alter the setting of this Listed Building, and therefore, a minor negative impact on the local historic environment would be expected by the SA. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Grade II* Listed Buildings: The site is located adjacent to the Grade II* Listed Building ‘Whitlingham Hospital Blocks 04, 05, 06’ and within 200m from several Listed Buildings along Yarmouth Road including ‘Thorpe Hall’ and ‘Walpole House’, but is separated from these Listed Buildings by the River Yare and woodland. Development at this site could potentially alter the setting of ‘Whitlingham Hospital Blocks 04, 05, 06’ and therefore a minor negative impact on the local historic environment would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Grade II Listed Buildings: Site GNLP3052 coincides with the Grade II Listed Building ‘Ruins of Trowse Newton Hall’ and is located adjacent to ‘Whitlingham Hospital Service Buildings, Block 03’, ‘Boundary wall and gateway at Whitlingham Hospital’, ‘Sunnydale’ and ‘Trowse Old Hall’. The proposed development at this site could potentially result in direct impacts on ‘Ruins of Trowse Newton Hall’ and therefore a major negative impact on the local historic environment would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Conservation Area: A small proportion of Site GNLP3052 coincides with Trowse with Newton Conservation Area. Therefore, the SA suggests development at this site could potentially alter the setting of this Conservation Area, and as such have a minor negative impact on the local historic environment. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the setting.

Registered Park and Garden: Site GNLP3052 coincides with ‘Crown Point’ RPG. Development at this site could potentially have a direct impact on this RPG and therefore a major negative impact would be expected. However, the nature of the proposed safeguarding of the site for country park usage can accommodate preservation of the RPG.

SA Objective 14 – Natural Resources, Waste & Contaminated Land. Previously Developed Land: All sites in this cluster comprise previously undeveloped land. Site GNLP3052 comprises 220.3ha of previously undeveloped land. The scale of development at this site is unknown at present, however, the proposed development could potentially result in a major negative impact on natural resources due to the loss of 20ha or more of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils. We disagree with this assessment, since our proposal relates to country park usage not extensive tracts of built development.

ALC: Site GNLP3052 is situated on ALC Grades 3 and 4 land. ALC Grade 2 and 3 are considered to be some of Greater Norwich’s BMV land. Therefore, a minor negative impact would be expected as a result of the proposed development at these four sites, due to the loss of this important natural resource. This assumes that the land would be built over, or would be available for agriculture, whereas we are proposing to safeguard the land for country park related uses, which are essentially reversible, such that a neutral impact should be recorded.

SA Objective 15 – Water B.52.15.1 SPZ: Sites GNLP3051, GNLP2069 and GNLP3049 coincide with the catchment (Zone III) of a groundwater SPZ. Site GNLP3052 coincides with the inner zone (Zone I), outer zone (Zone II) and catchment of a groundwater SPZ. The proposed development at these four sites could potentially increase the risk of groundwater contamination within this SPZ, and therefore, result in a minor negative impact on local groundwater resources

Watercourse: Site GNLP3052 is located adjacent to the River Yare, with a proportion of the site located within 200m of this watercourse. Development could potentially increase the risk of contamination of this watercourse, and therefore, a minor negative impact would be expected. However, contamination is unlawful, and planning controls exist to ensure any surface water drainage is carried through stages of filtration before any outfall into rivers. Given the proposed country park related uses, the SA should therefore record a neutral impact.

Comment

Representation ID: 22878

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Octagon Farm

SA Objective 1 – Air Quality and Noise. Air Pollution: The sites are proposed for the development of dwellings. Development could potentially result in a significant increase in local air pollution and have a negative impact on air pollution in the local area.

We consider this to be inappropriate, since air quality issues depend upon the context of the site being proposed for development. In the case of Octagon Farm, the sites does not fall within an air quality management area, and is not proposed to be developed in a way that result in such designation.

SA Objective 2 – Climate Change Mitigation and Adaptation. Carbon Emissions: Development could potentially increase local carbon emissions, as a proportion of South Norfolk’s total, by more than 0.1%. Therefore, a minor negative impact on South Norfolk’s carbon emissions would be expected. In response we assert that the design of the development has yet to be finalised. There are opportunities through development management policies to ensure carbon emissions are minimised.

Surface Water Flooding: A proportion of the site coincides with areas determined to be at risk of surface water flooding which would have a major negative impact on pluvial flood risk, as development would be likely to locate site end users in areas at high risk of surface water flooding, as well as exacerbate pluvial flood risk in surrounding locations. However, the development of the Octagon Farm site (both site references) provides the opportunity to incorporate on-site surface water attenuation, which will not only ensure development can be protected from flood risk, but also protect the Listed Octagon Barn itself, and by reducing off-site flows will also control peaks of flooding beyond the site boundaries. This would therefore be recorded as a positive impact.

SA Objective 4 – Landscape. Landscape Character: All sites in this cluster are located within the LCA ‘Poringland Settled Plateau Farmland’. Some key characteristics of this LCA include large scale open arable fields, woodland, and densely settled core area. The sites comprise large areas of pasture and arable land and could potentially be discordant with these key characteristics and would be expected to have a minor negative impact on the local landscape character. In this case, the site is well enclosed by vegetation, especially woodland to the north, so any landscape impact would be very localised and should therefore be recorded as neutral.

SA Objective 5 – Housing. Net Gain: Development would be expected to result in a major positive impact on housing provision. We agree with this assessment.

SA Objective 6 – Population and Communities. Local Services: The nearest convenience stores to this cluster, including Premier Grocery Store, Budgens, and One Stop Shop, are located within Poringland. The site is located either partially or wholly outside the target distance to these shops. Development could potentially have a minor negative impact on the access of site end users to local services. However, the site is proposed for mixed use development, where there is the opportunity to incorporate some top-up provision, and there are also bus stops immediately adjacent to the site.

Local Landscape Designations: Poringland contains several local landscape designations including Poringland Community Woodland, All Saints Road Open Space, Poringland Village Green and Carol Close play area. The list of sites are located within 600m from one or more of these features. The proposed development at these 16 sites would be likely to provide site end users with good access to these local features, and as such, result in a minor positive impact on opportunities for integration with the local community. We agree with this assessment.

SA Objective 8 – Health. Green Network: The site is located partially or wholly over 600m from a PRoW or public greenspace, and therefore, the proposed development at these four sites could potentially have a minor negative impact on the access of some site end users to the local green network. However, the development site provides the opportunity to incorporate public open space and circular walks through the masterplanning process, resulting in a positive impact.

GP Surgery: Old Mill Surgery and Heathgate Surgery are both located within Poringland. The site is located outside the target distance to these GP surgeries, and therefore, the proposed development at these twelve sites would be expected to have a minor negative impact on the access of site end users to GP surgeries. However, there are bus stops immediately adjacent to the site, to enable access by public transport.

Leisure Centre: The closest leisure facility to Poringland, Framingham Earl and Framingham Pigot is Riverside Leisure Centre, located approximately 7.2km north of the cluster. All 21 sites in this cluster are located outside the target distance to this leisure facility, and therefore, a minor negative impact on the health and wellbeing of site end users would be expected. However, there are bus stops immediately adjacent to the site, such that access can be facilitated by public transport, thus resulting in a neutral or positive impact.

SA Objective 10 – Education. Primary School: Poringland Primary School and Nursery is located in the centre of Poringland. The site is situated partially or wholly outside the target distance to this school. Development could potentially result in a minor negative impact on some site end users’ access to primary education. However, bus stops immediately adjacent to the site would facilitate a choice of accessibility.

Secondary School: Framingham Earl High School is located in the north of Poringland. The site is located within the target distance to this school, and therefore, development would be likely to result in a minor positive impact on site end users’ access to secondary education. We agree with this assessment.

SA Objective 11 – Economy. Primary Employment Location: Poringland Town Centre is located in close proximity to the Poringland, Framingham Earl and Framingham Pigot cluster. Roseberry Business Park is also located within 3km from this cluster. These locations would be expected to provide a range of employment opportunities for site end users. Therefore, the proposed development at all 20 sites would be expected to have a minor positive impact on the local economy. Employment Floorspace: The site is proposed for mixed use development including employment, commercial and business end uses. This would be expected to result in the provision of employment opportunities in the local area, and therefore, a major positive impact on the local economy would be expected as a result of development at this site. We agree with these assessments.

SA Objective 12 – Transport and Access to Services. Bus Stop: The site is located within the target distance to bus stops providing regular services. Development would be likely to have a minor positive impact on site end users’ access to bus services. We agree with this assessment.

Pedestrian Access: Site GNLP0321 is well connected to the existing footpath network. Development would be expected to have a minor positive impact on site end users’ access to the PRoW network and opportunities to travel by foot. Site GNLP1032 currently has poor access to the surrounding footpath network. Development could potentially have a minor negative impact on local accessibility. However, we assert that the joint development of these 2 sites at Octagon Farm would mean both could benefit from and facilitate further access to the PROW network.

SA Objective 13 – Historic Environment. Scheduled Monument: GNLP1032 is located approximately 300m from ‘Remains of Bixley Hall and associated garden water features’ SM, and Site GNLP0321 is located approximately 520m from this SM. Development could potentially have a minor negative impact on the setting of these SMs. However, it is unlikely, given the intervening woodland to the north of the sites, and the ability to masterplan the development taking account of the significance of the heritage asset. Therefore, this impact should be recorded as neutral.

SA Objective 14 – Natural Resources, Waste & Contaminated Land. Waste: Development for dwellings would be expected to increase household waste production by more than 0.1% in comparison to current levels in South Norfolk and could potentially result in a minor negative impact on waste generation. However, all residential development results household waste irrespective of its location.

Previously Developed Land: All sites in this cluster comprise previously undeveloped land. Development would be likely to result in a minor negative impact on natural resources due to the loss of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils. The combined site (8.48ha), would indeed result in the loss of undeveloped land, as is the case for all sites that are not brownfield. Given the significant numbers of new dwellings required, this is inevitable, and must be balanced with the positive impacts of providing housing, including affordable housing, and supporting the local economy and community vitality.

ALC: All sites in this cluster are wholly or partially situated on ALC Grade 3 land. Sites GNLP1032 and GNLP0485 are also partially situated on ALC Grade 2 land. All sites are situated on some of Greater Norwich’s BMV land. Therefore, a minor negative impact would be expected as a result of the proposed development at these 21 sites, due to the loss of this important natural resource. We agree, but given the significant numbers of new dwellings required, this is inevitable, and must be balanced with the positive impacts of providing housing, including affordable housing, and supporting the local economy and community vitality.

SA Objective 15 – Water. All sites in this cluster coincide with the catchment (Zone III) of a groundwater SPZ. The proposed development at these 21 sites could potentially increase the risk of groundwater contamination within this SPZ, and therefore, result in a minor negative impact on local groundwater resources. We assert that the planning process prevents contamination from occurring, since the design and construction of the development will be required to ensure staged filtration of surface water prior to reaching the groundwater. Proposed uses would not include heavy industry.

Watercourse: Site GNLP1032 is located adjacent to The Beck, with the majority of the site located within 200m of this watercourse. The proposed development at this site could potentially increase the risk of contamination of this watercourse, and therefore, a minor negative impact would be expected. We assert that the planning process prevents contamination from occurring, since the design and construction of the development will be required to ensure staged filtration of surface water prior to discharge to local watercourses. Proposed uses would not include heavy industry.