Draft Local Plan-Part 2 Site Allocations

Object

Representation ID: 21422

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

We object to the omission of GNLP1045 from the Regulation 18 GNLP and consider that Land at Nelson Road, as outlined in the attached representations should be included as an allocation for assisted living homes or new homes.

Object

Representation ID: 22185

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

7. THE SITES PLAN
Introduction
7.1 There is a Sites Plan which accompanies the GNLP which identifies the preferred new sites for allocation and allocations which are proposed to be carried forward from the existing Development Plan as well as sites which are considered to be reasonable and unreasonable alternatives.
7.2 The opportunities provided from the development of the site at Land at Rightup Lane, Wymondham are outlined below. Following which the way these have been considered in the site selection process which was undertaken through the Site Assessment Booklets and the Sustainability Appraisal, is considered.
Land at Rightup Lane, Wymondham
7.3 Wymondham is the largest settlement in South Norfolk and is strategically well placed for development being on the Cambridge/Norwich Tech Corridor with a wealth of services and facilities and access to sustainable transport infrastructure including two train stations. Wymondham is a highly sustainable settlement which is recognised as a Main Town in the GNLP.
7.4 Nevertheless, notwithstanding the obvious sustainability credentials of Wymondham to accommodate additional growth, only 100 additional homes are proposed to be allocated. This is notwithstanding the fact that there are sustainable small sites which are suitable for allocation including the Land at Rightup Lane which are likely to be required to ensure that 10% of the housing requirement is delivered on small or medium sized as required by paragraph 68a of the NPPF. The allocation of smaller deliverable sites will also support the ability of the Council to demonstrate a five-year land supply. 7.5 The Illustrative Site Layout in support of the Land at Rightup Lane has been designed to deliver a high-quality scheme including a landscape buffer along the eastern boundary to enhance the Green Infrastructure Corridor identified in the Wymondham Area Action Plan.
Site Assessment Booklets
7.6 The Site Assessment Process Methodology which has informed the Greater Norwich Local Plan Regulation 18 Consultation is set out in the Introduction and Methodology section of the Site Assessment Booklets. 7.7 The Site Assessment Process Methodology identifies a 7-stage process which was employed for the purposes of assessing sites:
• Stage 1- List of sites promoted in the settlement
• Stage 2 - Housing and Economic Land Availability Assessment (HELAA)
• Stage 3 - Summary of the consultation comments
• Stage 4 - Discussion of submitted sites
• Stage 5 - Shortlist of reasonable alternative sites for further assessment
• Stage 6 - Detailed site assessments of reasonable alternative sites
• Stage 7 - Settlement based appraisal of reasonable alternative sites and identification of preferred sites.
7.8 All of the sites analysed in the Housing Economic Land Availability Assessment (HELAA 2017) are also considered in the Sustainability Appraisal published in January 2020.
7.9 The way in which each of the sites in each settlement were considered is set out in the relevant Site Assessments Booklet.
Stage 1 - List of sites promoted in the settlement
7.10 This Stage identified all of the potential alternative sites in each settlement, including the Land at Rightup Lane, Wymondham. Stage 2 - Housing and Economic Land Availability Assessment (HELAA)
7.11 This site selection process then took account of the information which had been gathered for each site in the HELAA, which categorises the performance of each site as either ‘red’, ‘amber’ or ‘green’ against different criteria.
7.12 Whilst the HELAA only provides a high-level assessment, it assessed the Land at Rightup Lane as performing more favourably than one of the proposed allocations at Land at Johnson’s Farm.
7.13 The HELAA correctly concluded that the Land at Rightup Lane, Wymondham was suitable for development. Stage 3 - Summary of the consultation comments
7.14 All of the sites were subject to consultation in both January to March 2018 and October to December 2018. These consultation comments inform the next stage of the site selection process.
As recorded in the Site Assessment Booklet for Wymondham, the only comments received in relation to Land at Rightup Lane were supportive given that the development of this site would have a minimal impact and would form a natural extension to the current allocations.
Stage 4 - Discussion of submitted sites
7.15 The Introduction and Methodology report states that “in addition to the HELAA assessment and consultation responses a range of factors have been considered in order to establish whether a site should, or should not be, considered suitable for allocation and shortlisted as a reasonable alternative at this stage for further consideration”. In particular, it is identified that these additional factors include a consideration of the impact on heritage and landscape, on the form and character of the settlement, the relationship to services and facilities, environmental concerns including flood risk and the existence of a safe walking route to a primary school within 3km.
7.16 The Land at Rightup Lane was identified as reasonable alternative subject to identifying a suitable access.
7.17 Pigeon have engaged with the local highway authority regarding a proposed access strategy for the site. On the basis of these discussions a phased approach to ensure that a satisfactory access can be achieved is proposed. Norfolk County Council permit that a maximum of 8 No. units can be accessed off of a private drive. As such, the access strategy would comprise delivering Phase 1 for up to 8 homes off a private drive from Rightup Lane and then subsequently, following either improvement works to Rightup Lane or gaining access through the neighbouring development sites (identified in the Wymondham Area Action Plan), developing the remainder of the site.
Stage 5 - Shortlist of reasonable alternative sites for further assessment
7.18 The reasonable alternative sites were then shortlisted in Stage 5 including the Land at Rightup Lane, Wymondham. Stage 6 - Detailed site assessments of reasonable alternative sites
7.19 The reasonable alternatives were subject to further assessment by officers from the partner councils including Development Management, Conservation, Highways, Flood and Education colleagues. It is also identified that they were discussed at a series of workshop sessions where professional advice was received and that site visits were undertaken. The results of these further assessments are presented in Stage 6 of the Site Assessment Booklets.
7.20 No concerns were raised by Highways, Minerals & Waste or the Lead Local Flood Authority. Development Management officers identified that the site was considered suitable for allocation subject to highway constraints being addressed as part of recent allocations and/or upgrades to Rightup Lane, in accordance with the phased approach proposed by Pigeon in light of discussions with the local highway authority. Children’s Services also identified that there is pressure for pupil places and additional development would be dependent upon the provision of a new school.
7.21 The Infrastructure Needs Report identifies that a new 420 place Free School is due to open in September 2020 and that another 420 place primary school is planned to be delivered at Silfield as part of the neighbouring development. It is therefore likely that there will be sufficient educational provision to accommodate the proposed development of up to 27 homes.
Stage 7 - Settlement based appraisal of reasonable alternative sites and identification of preferred sites.
7.22 At Stage 7, the site selection process identifies 10 reasonable alternatives at Wymondham owing to the fact that these no major constraints had been identified. However, for some inexplicable reason, these did not include the Land at Rightup Lane notwithstanding the fact that the assessment had identified that this site was suitable for allocation.
7.23 The Site Assessment Booklet then proposes two allocations from the 10 reasonable alternatives based on “further discussion”. There is however no evidence as to what these further discussions entailed or demonstrated to justify the selection of these sites in preference to any others.
7.24 Stage 7 does not undertake any additional analysis but presents a summary based on the preceding analysis of why sites have been categorised as preferred options, reasonable alternatives or unreasonable alternatives.
7.25 It identifies that the Land at Rightup Lane is not considered to be suitable for allocation contrary to all of the preceding analysis and justifies this on the basis that the site is remote from the town, the potential for noise from the A11, highways constraints and access constraints.
7.26 Many of these alleged constraints have not been identified anywhere in the preceding assessment and appear to have been retrospectively identified to justify not allocating the site contrary to the recommendation of Development Management officers, including the following.
7.27 The Land at Rightup Lane is immediately adjacent to other developments which have been allocated and permitted indicating that the distance from the town has not acted as a constraint in the immediate locality.
7.28 A Noise Survey and Assessment of Impact has been undertaken and this has informed the Illustrative Site Layout which ensures that all dwellings are offset by at least 15m from the A11 carriageway edge which along with a 1.8m high acoustic bund/barrier and a landscaped buffer, will satisfactorily screen the proposed development from noise.
7.29 The identification of highways constraints is directly contrary to the preceding assessment within the Site Assessment Booklet. The local highway authority has not raised any concerns and so the suggestion that there are highways constraints is not supported by the evidence.
7.30 Whilst access constraints have been previously identified in the Site Assessment Booklet, as described above, discussions have been held with Norfolk County Council Highways regarding a proposed access for the site. On the basis of these discussions a phased approach to the Site is proposed, demonstrating that a satisfactory access solution can be provided.
7.31 Therefore, each and every one of the identified constraints which have been identified to justify not allocating the Land at Rightup Lane is either notsupported by the evidence, and/or new evidence is available that demonstrates that these can be satisfactorily addressed.

Sustainability Appraisal of the Greater Norwich Local Plan Regulation 18 published in January 2020
7.32 A Sustainability Appraisal (SA) has been carried out in support of the GNLP. This assesses Land at Rightup Lane, Wymondham as a reasonable alternative for a residential development of 33 homes. Accordingly, the SA does not assess the form of development now proposed at this site, namely a high-quality scheme providing up to 27 homes. It is therefore likely that the environmental impacts of the development of this site identified in the SA will overestimate the impacts of the proposed development.
7.33 SA Objectives 1-4 – Air Quality and Noise; Climate Change Mitigation and Adaptation; Biodiversity, Geodiversity and Green Infrastructure; and Landscape – the SA identifies that the Land at Rightup Lane performs equally as well as any other site in Wymondham or across the entire GNLP area under these objectives8.
7.34 In particular, the SA notes that the Land at Rightup Lane is wholly within Flood Zone 1 and would therefore be expected to have a minor positive impact. It also identifies that the Land at Rightup Lane is unlikely to be discordant with the key characteristics of the landscape character area.
7.35 SA Objective 5 – Housing – the SA indicates that as the Land at Rightup Lane provides less than 100 homes, it has only a minor positive impact under this objective. This is nevertheless a positive impact.
7.36 SA Objective 6 – Population and Communities – the SA assesses the majority of sites within Wymondham as having a minor negative impact under this objective including one of the proposed allocations at Land at Johnson’s Farm owing to the distance to a convenience store or a post office and this has not acted as a constraint to allocation.
7.37 The development of the neighbouring site includes the provision of retail floorspace, and whilst the precise use is not yet known, this may have implications for the accessibility of convenience foods and therefore for the SA assessment in the near future.
7.38 SA Objective 7 – Deprivation – whilst this is identified as an SA objective, no assessment has been undertaken of the potential effects of development upon deprivation and every site across the GNLP area is assessed as having no impact.
7.39 SA Objective 8 – Health – the SA assesses the Land at Rightup Lane as having a major negative impact under this objective owing to it being outside the target distance from a Hospital, a GP surgery and a leisure centre. The same conclusion is reached for 9 sites in Wymondham including one of the proposed allocations at Land at Johnson’s Farm and this has not acted as a constraint to allocation.
7.40 SA Objective 9 – Crime – whilst this is identified as an SA objective, no assessment has been undertaken of the potential effects of development upon crime and every site across the GNLP area is assessed as having no impact.
7.41 SA Objective 10 – Education – the SA assesses the Land at Rightup Lane as having a major negative impact under this objective owing to it being outside the target distance from a primary school and a secondary school. The same conclusion is reached for 7 sites in Wymondham including one of the proposed allocations at Land at Johnson’s Farm and this has not acted as a constraint to allocation.
7.42 The SA also does not appear to take into account the proposed development of a primary school as part of the development on the neighbouring site which would result in Land at Rightup Lane being assessed more favourably under this objective.
7.43 SA Objective 11 – Economy – the SA assesses the Land at Rightup Lane as having a minor positive impact under this objective.
7.44 SA Objective 12 – Transport and Access to Services – all of the sites at Wymondham are assessed as having a minor negative impact under this objective with one exception which is assessed as having a major negativeimpact. Therefore, the Land at Rightup Lane performs equally as well as the best performing sites in the town in this regard.
7.45 SA Objective 13 – Historic Environment – the SA assesses the Land at Rightup Lane as having a negligible effect under this objective, which is the joint most favourable assessment of any site in Wymondham or across the entire GNLP area.
7.46 SA Objective 14 – Natural Resources, Waste and Contaminated Land – the SA suggests that the development of housing will increase household waste. The waste which arises will be largely attributable to the population that would exist regardless of development rather than the number of dwellings. It is not clear that this has been taken into account when assessing the waste impacts.
7.47 The SA also suggests that the use of previously undeveloped land would necessarily be an inefficient use and land. As a result of the housing need and the capacity of previously developed sites, this is not a credible position as it will be necessary for some greenfield development to be forthcoming.
7.48 Nevertheless, the SA assesses the Land at Rightup Lane as performing equally as well as the least constrained sites in Wymondham under this objective.
7.49 SA Objective 15 – Water – the SA assesses all of the sites in Wymondham, and the majority across the GNLP area as providing a minor negative impact under this objective.
7.50 In summary, the SA has assessed the Land at Rightup Lane, and it has been identified as performing equally as well if not better than other sites within Wymondham under the majority of objectives. The site will perform even more favourably once the facilities proposed to be provided on the neighbouring development are delivered as this will increase the accessibility of the Land at Rightup Lane to such facilities
Conclusions on the Sites Plan
7.51 As identified throughout these representations, the site selection process (including the Site Assessment Booklets and the SA) which has informed the allocations proposed within the GNLP is flawed including because: • It is internally inconsistent with constraints such as highways being identified as a barrier to the development of Land at Rightup Lane notwithstanding the local highways authority having raised no concerns;
• It reaches conclusions on the basis of different evidence than that which has been considered such as identifying that noise impacts, the proximity to the town centre and highways as acting as a constraint to the development of Land at Rightup Lane notwithstanding that these had not been identified as issues throughout the assessments;
• It is based on a high-level assessment without the detailed work having been undertaken as has been done on behalf of Pigeon which demonstrates that the Land at Rightup Lane can be sustainably delivered.
7.52 Pigeon would welcome the opportunity to meet with officers to discuss the opportunities which can be provided through the delivery of the site at Land at Rightup Lane.

Support

Representation ID: 22316

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Site comprises (i) Land off Hethersett Road that is being promoted for a high-quality landscapeled scheme including around 400 homes; (ii) Land off Little Melton Road that is being proposed as employment land; (iii) Land off Burnthouse Lane that is being promoted for a sports and education campus and around 50 new homes; and (iv) Land off Station Lane that is being promoted for a high-quality landscape-led care home and assisted living homes.

Object

Representation ID: 22317

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Site comprises (i) Land off Hethersett Road that is being promoted for a high-quality landscapeled scheme including around 400 homes; (ii) Land off Little Melton Road that is being proposed as employment land; (iii) Land off Burnthouse Lane that is being promoted for a sports and education campus and around 50 new homes; and (iv) Land off Station Lane that is being promoted for a high-quality landscape-led care home and assisted living homes.

Object

Representation ID: 22318

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Site comprises (i) Land off Hethersett Road that is being promoted for a high-quality landscapeled scheme including around 400 homes; (ii) Land off Little Melton Road that is being proposed as employment land; (iii) Land off Burnthouse Lane that is being promoted for a sports and education campus and around 50 new homes; and (iv) Land off Station Lane that is being promoted for a high-quality landscape-led care home and assisted living homes.

Comment

Representation ID: 22319

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Site comprises (i) Land off Hethersett Road that is being promoted for a high-quality landscapeled scheme including around 400 homes; (ii) Land off Little Melton Road that is being proposed as employment land; (iii) Land off Burnthouse Lane that is being promoted for a sports and education campus and around 50 new homes; and (iv) Land off Station Lane that is being promoted for a high-quality landscape-led care home and assisted living homes.

Object

Representation ID: 22358

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Land at Walcot Green Lane, Diss provides the opportunity for a high-quality landscape-led scheme for around 120 new homes including bungalows, affordable homes and up to 10 self-build plots together with extensive areas of green infrastructure and public open space.

Comment

Representation ID: 22428

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Land at Dereham Road, Reepham provides the opportunity for a landscapeled scheme to provide the preferred site for the relocation of an existing local employer and land for the extension of the existing GP surgery (on land north of Dereham Road), and around 50 homes including bungalows, affordable housing and self-build homes (on land south of Dereham Road).

See attached for further details

Object

Representation ID: 23187

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The Site comprises (i) Land off Hethersett Road that is being promoted for a high-quality landscapeled scheme including around 400 homes; (ii) Land off Little Melton Road that is being proposed as employment land; (iii) Land off Burnthouse Lane that is being promoted for a sports and education campus and around 50 new homes; and (iv) Land off Station Lane that is being promoted for a high-quality landscape-led care home and assisted living homes.