Draft Local Plan-Part 2 Site Allocations

Persimmon Homes (Anglia) Response to Greater Norwich Local Plan (Regulation
18) Policy HEL 2 - Land at the Royal Norwich Golf Club, Hellesdon

I am instructed by Persimmon Homes (Anglia) to respond to the current Greater Norwich Local Plan
(Regulation 18) consultation specifically in relation to Policy HEL 2 - Land at the Royal Norwich Golf
Club, Hellesdon. Persimmon Homes (Anglia) control the site which has the benefit of planning
permission and is being developed.

Background
The original Royal Norwich Golf Club application 20151770 was consented by Broadland District Council
on 6 December 2015. Permission was granted for the demolition of the club house and the development
of up to 1,000 homes and associated infrastructure included a primary school site, community uses, and
open space; detailed consent was given for the first phase of 108 dwellings. In total the site extends to
45.7 hectares (split either side of the Drayton High Road). The original outline application requires
compliance with approved parameter plans, including for layout, land use and density and a Masterplan.
The Masterplan is currently being revised to take account of additional requirements imposed on the
consent not anticipated by the previous allocation policy.

Response to GNLP Consultation – Policy HEL 2: Land at the Royal Norwich Golf
Club, Hellesdon
Persimmon Homes (Anglia) notes that the Policy HEL 2 is partially updated from the version included in
the Broadland Site Allocations DPD. However, Persimmon Homes (Anglia) considers that the Policy
wording should be redrafted to better reflect the fact that planning consent has been granted and that
most of the policy requirements identified in the emerging policy have been/will be addressed through the
implementation of the planning consent and its associated conditions and the Section 106 legal
Agreement. For instance, the school site is secured through the masterplan and S106, the golf course
has been provided elsewhere; and the highways matters have been agreed.
Persimmon Homes (Anglia) are content for the land allocation to roll forward, but suggest that the Policy
is updated to acknowledge that it is a committed and implemented site and to reflect the implications of
additional requirements imposed on the scheme since the original policy was approved.

Suggested changes
Persimmon Homes (Anglia) suggests that rather than simply roll forward the previous Local Plan
allocation and a revised Policy HEL 2, the Local Plan should acknowledge that the ‘allocation’, is now a
committed site (i.e. a site with planning permission); and it should be notated as such and incorporated
within the Settlement boundary. The policy should also take account of the implications of the additional
requirements imposed on the site since the original policy was developed, such as the provision of
playing pitches and retention of significantly more trees than anticipated, which inevitably have an impact
on the capacity of the site to accommodate the level of dwellings specified in the Policy. The Policy’s
housing figure should therefore be expressed as an ‘up to’ figure in accordance with the planning permission; and particularly as it is currently by no means certain that 1,000 homes can be
accommodated on the site given the additional constraints and requirements.

Conclusion
In conclusion, Persimmon Homes (Anglia) supports the Local Plan’s acknowledgement that the site HEL
2: Land at the Royal Norwich Golf Club, Hellesdon is capable of accommodating homes and supports
the allocation’s roll forward. However, the accompanying policy should acknowledge the fact that
planning permission has been granted and the majority of the suggested policy requirements have been
met. It should also reflect the implications of the additional requirements imposed upon the scheme
since the original policy was approved, which potentially impacts on the ability of the site to meet the
numbers specified in the Policy (1,000 homes). For this reason, the housing requirement figure should
be expressed as an ‘up to’ figure.
Persimmon Homes (Anglia) remain very happy to continue to work with the Authorities to discuss the
revised masterplan and the ability of the scheme to meet the Policy’s expectations in terms of housing
numbers (market and affordable).

Persimmon Homes (Anglia) Response to Greater Norwich Local Plan (Regulation
18) Policy EAS 1 Land South and East of Easton
I am instructed by Persimmon Homes (Anglia) to respond to the current Greater Norwich Local Plan
(Regulation 18) consultation specifically in relation to Policy EAS 1: Land south and east of Easton.
Persimmon Homes control the majority of the site (excluding an area of the allocation to the north of
Dereham Road, which is promoted separately by Orbit Homes) and which has the benefit of outline
planning permission.

Background
The original Easton outline application 2014/2611/O was consented on 1 November 2016. The original
outline application site (excluding an area of land to the north of Dereham Road, which is being promoted
by Orbit Homes for 64 homes) extends to approximately 45 hectares and the consent limits the total
number of homes to 890 units.
The original outline application requires compliance with approved parameter plans, including for layout,
land use and density and a Design Code. The Design Code for the site was approved on 16 December
2019. A reserved matters application for the first phase of the scheme is being prepared and will be
submitted for approval shortly.
Persimmon Homes (Anglia) aim to be efficient in the use of land (as required by the NPPF) as it prepares
its reserved matters applications and considers that there may be future opportunities to accommodate
addition sustainable residential development above that which is currently specified in the emerging
Local Plan policy (1,044 homes) and this potential opportunity should not be compromised by the Policy.
It is acknowledged that to secure any future additional ‘uplift’ in residential unit numbers a new consent would be required, which would need to take account of any new policies adopted since the outline
consent was granted; including contributions to CIL and providing ‘on-site’ requirements such as open
space, access, utilities infrastructure/capacity reinforcement etc. necessary to support the ‘uplift’.
It is also acknowledged that any application for an ‘uplift’ in unit numbers will need to be supported by
technical information to demonstrate that the scheme can be accommodated within infrastructure limits,
or mitigations can be put in place (i.e. utility reinforcements) and without having a residual significant
environmental impact. An EIA Addendum may also need to be prepared, to consider the environmental
impacts of the uplift, taking into account cumulative effects, including recent planning commitments not
considered at the outline stage; new legislation and changes in baseline information

Response to GNLP Consultation – Policy EAS 1: Land South and East of Easton
Persimmon Homes (Anglia) supports the Greater Norwich Local Plan’s acknowledgement that the site
EAS1 : Land south and east of Easton is capable of accommodating additional housing units beyond the
previous allocation figure of 900 units. This is evidenced by the fact that a scheme of 890 units has been
permitted and a further scheme for 64 units is pending. However, it is not altogether clear how the figure
of 1,044 homes has been derived and what it is comprised of or what assumptions have been made.
Persimmon Homes (Anglia) notes that the Policy EAS 1 is partially updated to reflect additional housing
numbers permitted through the determination of the outline planning application (ref:2014/2611/O) and it is assumed likely to be permitted through the determination of the Orbit Homes planning application but these two figures do not equate to the Policy’s suggested housing figure.
Also, Persimmon Homes (Anglia) note that the rest of the policy’s ‘requirements’ remain unchanged from
the previous policy and appear to ignore the fact that planning permission has been granted (in the case
of the Orbit scheme is likely to be likely granted), with conditions and a section 106 obligations package
which renders many of the policy ‘requirements’ superfluous or obsolete, as they are already addressed.
Persimmon Homes (Anglia) considers that the Policy should be redrafted to reflect the fact that planning
consent has been granted; and that many of the policy requirements have been met through the
determination of the planning application and are no longer relevant to any potential future application(s).
It is accepted that there may be reticence to do this until the scheme has been lawfully commenced, but
Persimmon Homes (Anglia) are confident that this will be done prior to the adoption of the Local Plan.
However, notwithstanding the above, the Local Plan should also acknowledge that the site may be
capable of accommodating more than the suggested 1,044 units in the Policy. Persimmon Homes
(Anglia)’s experience at Hethersett and other strategic sites is that the need to make the best and most
efficient use of land often results in the housing numbers controlled by outline consents being met by
using less land than anticipated by the outline consent, resulting in land being available within the red
line of consented sites, which could reasonably accommodate further sustainable development.
Persimmon Homes (Anglia) suggests that the emerging Local Plan should not rule this opportunity out in
Easton and therefore suggests that the Policy’s housing figure could be specified as minimum or an ’at
least’ figure.

Suggested changes
Persimmon Homes (Anglia) suggests that rather than simply roll forward the previous Local Plan
allocation and Policy EAS 1: Land south and east of Easton in its entirety, the Local Plan should
acknowledge that the ‘allocation’, is now a committed site (i.e. with planning permission); and should be
notated as such and included in the settlement boundary; and that the Local Plan Policy EAS 1 should
be redrafted to only include requirements that are relevant to any future planning applications, not
requirements that are addressed by the consent’s conditions and/or associated Section 106 package. It
should also specify the housing figure as a minimum or an ‘at least’ figure, in the event that opportunities
arise for additional sustainable development within the allocation boundaries. The policy should not
compromise this potential opportunity.

Conclusion
In conclusion, Persimmon Homes (Anglia) supports the Local Plan’s acknowledgement that the site EAS
1: Land south and east of Easton is capable of accommodating additional homes beyond those identified
in the previous Site Allocations Plan (900 units) and as permitted by the outline consent (890 units) and
likely to be permitted (64 units). However, further clarity on how the housing target of 1,044 units has
been derived and what it consists of and any related assumptions should be provided.
Importantly, Persimmon Homes (Anglia) do not consider it appropriate for the Policy to be simply rolled
forward in its entirety without acknowledging that planning consent has been granted and that many of
the Policy’s requirements are met through the consenting process, as evidenced in the consent’s
planning conditions and the accompanying Section 106 agreement; and will be delivered through the
implementation of the scheme.
Persimmon Homes (Anglia) also suggests that the Policy’s housing figure should be expressed as a
minimum or ‘at least’ figure, in the event that through the consenting of reserved matters application(s)
making an efficient and best use of land, opportunities for further sustainable development within the
allocation boundary presents themselves in the future.
Persimmon Homes (Anglia) remain very happy to continue to work with the Authorities to clarify those
Policy EAS 1 requirements that remain relevant to any future planning applications, and those that are not, particularly those that have been/are being dealt with by the original consent’s conditions and s106
obligations package.