Draft Local Plan-Part 2 Site Allocations

Object

Representation ID: 21801

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
We object to the omission of the GNLP2170 and GNLP2171 sites from the Site Allocations, and the identification of these sites as being ‘Unreasonable Sites’ for the following reasons:
a. At Stage 2 of the HELAA, both sites were given ‘Green’ ratings in respect of site access, open space/GI, and transport and roads, and as a result of this and their other ratings they passed the Stage 2 assessment and were considered to be ‘reasonable alternatives’ and therefore ‘suitable sites’;
b. Stage 4 concluded that both sites were still considered to be ‘reasonable alternatives’. In relation to GNLP2170 (Langley North) it was noted that access to the site was to be via the adjacent Pinebanks site which already benefits from an outline planning approval, and that subject to overcoming the Sport England objection in relation to loss of playing fields (and a requirement for replacement before development commences) the site is considered to be a reasonable alternative.
At this point we should refer to the comments made above in relation to Appendix 1 of the Draft Strategy, and the absence of an up-to-date Sports Facilities Strategy for the area. In addition, it should be noted that the 2018 Draft Playing Pitch Strategy concluded that whilst there was a shortfall of 6 rugby pitches in the GNDP area, that the significant spare capacity of football pitches could be utilised to make up this shortfall. It is also interesting and important to note that, having reviewed the playing pitch audits undertaken as part of the preparation of the Strategy, the Former Langley School pitches were not recorded. It is therefore considered that their loss would not result in any additional deficiency over and above that already referred to.
c. At Stage 6 of the HELAA, detailed assessments of the reasonable alternative sites were undertaken. In respect of both GNLP2170 and GNLP2171, Highways commented that both sites were acceptable subject to an access strategy. In other words, Highways did not object to the inclusion of the two sites. Development Management commented that:
▪They were not convinced that estate-scale development could be delivered due tothe site constraints, although these constraints weren’t identified;
▪Queried whether the allocation should be open-ended in terms of housing numbers;and
▪Identified the need for a masterplan and/or a Design Code to be prepared;It is not clear what the site constraints were to which Development Management referred, as no significant constraints or ‘showstoppers’ were identified by other consultees; and
d.At Stage 7, the preferred sites were identified, and both GNLP2170 and GNLP2171 were dismissed on highways and ecological/landscape grounds, despite there being no objections from Officers on those grounds. This exclusion of the sites from being identified as being preferred sites and therefore becoming site allocations does not reflect the conclusions of the earlier stages of assessment, and on those grounds, we object to the exclusion of these two sites from the Site Allocations.We do not believe that there are sufficient grounds on which to exclude these sites from the Allocations, for the following reasons:
Both sites are previously developed,
These sites either have an existing access in place, or can be accessed via land within our Client's control and via a site already benefitting from outline planning approval for residential development;
There is no up-to-date evidence available at this stage to suggest that the development of GNLP2170 will result in a loss of playing pitches, or any further deficiency in playing pitches;

Object

Representation ID: 21802

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
We object to the omission of the GNLP2170 and GNLP2171 sites from the Site Allocations, and the identification of these sites as being ‘Unreasonable Sites’ for the following reasons:
a. At Stage 2 of the HELAA, both sites were given ‘Green’ ratings in respect of site access, open space/GI, and transport and roads, and as a result of this and their other ratings they passed the Stage 2 assessment and were considered to be ‘reasonable alternatives’ and therefore ‘suitable sites’;
b. Stage 4 concluded that both sites were still considered to be ‘reasonable alternatives’.
In relation to GNLP2171 (Langley South) it as noted that access to the site would be via the previous Yarmouth Road access so there were ‘no obvious concerns’, and that subject to managing the constraint of the Ancient Woodland the site remains a ‘reasonable alternative’;
c. At Stage 6 of the HELAA, detailed assessments of the reasonable alternative sites were undertaken. In respect of both GNLP2170 and GNLP2171, Highways commented that both sites were acceptable subject to an access strategy. In other words, Highways did not object to the inclusion of the two sites. Development Management commented that:
▪They were not convinced that estate-scale development could be delivered due to the site constraints, although these constraints weren’t identified;
▪Queried whether the allocation should be open-ended in terms of housing numbers; and
▪Identified the need for a masterplan and/or a Design Code to be prepared;It is not clear what the site constraints were to which Development Management referred, as no significant constraints or ‘showstoppers’ were identified by other consultees; and
d.At Stage 7, the preferred sites were identified, and both GNLP2170 and GNLP2171 were dismissed on highways and ecological/landscape grounds, despite there being no objections from Officers on those grounds. This exclusion of the sites from being identified as being preferred sites and therefore becoming site allocations does not reflect the conclusions of the earlier stages of assessment, and on those grounds, we object to the exclusion of these two sites from the Site Allocations.We do not believe that there are sufficient grounds on which to exclude these sites from the Allocations, for the following reasons:
▪Both sites are previously developed, and in the case of GNLP2171, have a significant developed footprint;
▪These sites either have an existing access in place, or can be accessed via land within our Client’s control and via a site already benefitting from outline planning approval for residential development;
▪We note and are aware of the Ancient Woodland constraint on GNLP2171, but it is our view that this does not preclude the residential development of what is a previously-developed and sustainably located site on which the principle of development has been accepted.

Object

Representation ID: 22098

Received: 13/03/2020

Respondent: Quantum Land

Agent: Barton Willmore

In the “site assessment booklet for Brundall”, site GNLP0436 is land to the east of Links Avenue and the Memorial Hall. This site is subject to an on-going appeal. The site was recommended for approval by planning officers (July 2019). The committee report notes that no technical objections were received and Norfolk County Council and Highways England raised no objection to the scheme. No heritage or landscape concerns were identified. It was noted that significant benefit would be derived from the scheme for green infrastructure, including formal and informal open space, and habitat creation and enhancement of biodiversity. Planning committee refused the application, principle on the basis of a lack of need for additional housing, since they considered they could show a 5YHL supply. The appeal will be heard in April 2020 and a decision is expected by the end of June 2020.
It is noted that the assessment booklet confirms, under Stage 5, that the site is a “reasonable alternative” for “up to 250 dwellings, open space, recreation and leisure uses”.
Under Stage 6, “Detailed assessments of reasonable alternatives”, it is noted that the application is (it has now been) to go to planning committee with a likely recommendation to approve.
Under Stage 7, it is said:
“After further consideration, there are no sites preferred for allocation in the Brundall cluster. There remain high levels of existing commitments which are as yet undeveloped, and it has not been possible to find ways to overcome infrastructure constraints, including access to the A47. These constraints are considered to limit the potential for additional housing at this stage, meaning there are no reasonable alternative sites either.”
Cleary this is not the case in respect of Brundall. Site GNLP0436 is technically acceptable.