Draft Local Plan-Part 2 Site Allocations

Object

Representation ID: 22466

Received: 16/03/2020

Respondent: CODE Development Planners Ltd

We object to the allocation of 1.23ha of land at Station Hill for employment, retail and/or health and community facilities.
There is insufficient justification for such an allocation. The note contained in the draft Local Plan refers only to the proposal to carry forward the previous allocation from the South Norfolk Local Plan.
In the meantime, the local planning authority has granted planning permission on the site for residential development.

Support

Representation ID: 22707

Received: 16/03/2020

Respondent: CODE Development Planners Ltd

1. Introduction
1.1. These representations are submitted on behalf of Jarrolds & Sons the owners of land to the rear of Heath Crescent, bound to the north by Fifers Lane, an industrial estate to the east and residential dwellings along Heath Crescent and Prince Andrew’s Road to the west and Prince Andrew’s Close to the south. 1.2. The site comprises a single parcel of land with an area of 2.18ha and was previously used as a sports and social club for Jarrold’s employees. Due to dwindling membership and the facility running at a loss, the site closed in August 2016. Redevelopment of the unused site would support the provision of new homes to serve the needs of the local community. 1.3. These representations provide an update to the representations made at the Stage B Regulation 18 New, Revised and Small Sites consultation, March 2018. Since the previous submission a
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number of technical surveys and assessments have been undertaken by an appointed team of specialist consultants to identify potential constraints and opportunities to residential development and inform the quantum of new homes that are deliverable from the site.
1.4. In the context of the Hellesdon Neighbourhood Development Plan, December 2017, the time that has elapsed since the site closed and the timetable for the adoption of the Greater Norwich Local Plan (GNLP) (August/September 2022), these representations consider two scenarios; residential development of the site (35-40 homes) with retention of the bowls green; or residential development of the entire site (45-50 homes). Both scenarios would accord with the Recreational Provision in Residential Development SPD, April 2016 and other policies within the Broadland Development Management DPD, August 2015 (BDM-DPD). 2 Current status in GNLP 2.1 The site has been assessed in the Hellesdon Assessment Document as a reasonable alternative for both residential development following representations made on behalf of the land owner, Jarrolds & Sons (reference GNLP2173) and as an area for leisure following a submission by Hellesdon Parish Council (reference GNLP1021) during the GNLP Call for Sites consultation (date) and subsequent GNLP regulation 18 consultation (March 2018). 2.2 Paragraph 35 of the National Planning Policy Framework (NPPF) states that, “Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs19, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework”.
2.3 The GNLP as currently drafted does not include an allocation for the site; given the time sensitive nature of various contextual policy elements as set out in paragraph 1.4 above, it fails to satisfy two of the tests of soundness, notably “positively prepared” and “justified”. Jarrold & Sons contend that an assessment of the reasonable alternatives as presented by the two scenarios in this submission would conclude with the allocation of the site for residential development (with or without the bowls green is for further consideration through the local plan preparation process) thus providing a remedy to comply with the tests of soundness. The alternative would be for the site to come forward as a “windfall site” during the plan period.
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2.4 We understand that the evidence base, which will be prepared as part of the review of the BDM-DPD will include an update to the Greater Norwich Area Playing Pitch Strategy, October 2014. In the context of the preparation of the GNLP, this is required to assist consideration of the two scenarios. Jarrold & Sons acknowledges that within five years of the closure of the site a negotiated planning permission could secure the retention of the bowls green as part of the development of the site for 35-40 new homes. This would accord with Project 1: Enhanced parks and open spaces of the Hellesdon Neighbourhood Plan (HNP). The project seeks to improve the quality and diversity of existing parks and open spaces throughout Hellesdon which would include inter alia the parish council “securing the use of Jarrold’s Sport Ground/Heath Crescent for the local community”. 2.5 The Hellesdon site assessment document explains the site is considered to be a reasonable alternative if additional housing is needed in the urban area. This in itself would seem to be contrary to the proposed strategy for development in the GNLP. Policy 1 states, “that sustainable development and inclusive growth are supported by the delivery of 44,340 new homes between 2018 and 2038. In delivering these new homes growth is distributed in line with the settlement hierarchy: 1 Norwich urban area (Norwich and Norwich Fringe) 2 Main towns 3 Key service centres 4 Village clusters”
2.6 It goes on to state, “Growth is distributed in line with the settlement hierarchy to provide good access to services, employment and infrastructure. It is provided through urban and rural regeneration, along with sustainable urban and village extensions.” The site is located in the fringe parish of Hellesdon within the top tier of the settlement hierarchy and evidence within the assessment document has established that the site is well located within the built-up area and highways would support residential development subject to vehicular access via Prince Andrews Road, yet the site is considered a reasonable alternative and it is argued that the Local Plan fails the test of soundness with regards to the plan being positively planned. The evidence in support of the GNLP insufficiently explains why sites lower down the settlement hierarchy have been chosen as preferred sites for inclusion within the plan as allocations ahead of this top tier site. The GNLP contradicts itself and is therefore unsound. 2.7 An additional reason given for the site’s non allocation is Hellesdon Parish Council/HNP ambition to secure the site for community use. An assessment of the provisions of project 1 of the HNP identifies that it does not state the extent of community use or what the uses should be. 3 Evidence on deliverability 3.1 Jarrold & Sons has appointed a team of technical consultants to assess the constraints and opportunities presented by the site in relation to residential development. In doing so the principle for development has been established and no physical constraints have been identified that would prohibit development. In addition to the provision of a range and types of new homes, development of the site for residential provides opportunities to improve biodiversity, public access and the creation of circular walks.
3.2 The technical team included consultants specialising in; archaeology, arboriculture, ecology, landscape, noise and vibration, surface water drainage and utilities. Where constraints were identified, suitable mitigation has been identified to allow for sustainable development of the site. The following lists the technical reports that have been prepared and identifies those which are submitted in support of these representations (those not submitted directly with these representations are available for discussions with officers of the GNLP team ahead of the regulation 19 stage of plan preparation): • Transport Appraisal (including proposed access drawing) (January 2020) prepared by WSP Part of representation • Preliminary Landscape and Visual Overview (March 2020) prepared by Tyler Grange Part of representation • Ecology Report (March 2020) prepared by Wild Frontier Ecology Part of representation • Surface Water Drainage Strategy and Flood Risk (January 2020) prepared by Richard Jackson Available for discussion with officers • Utilities (January 2020) prepared by Richard Jackson Available for discussion with officers • Initial Site Noise Risk Assessment (February 2020) prepare by Adrian James Acoustics Part of representation • Archaeological Desk-based Assessment (January 2020) prepared by RPS Part of representation • Arboricultural Assessment (February 2020) prepared by Oakfield Arboricultural Services Part of representation 3.3 Noise, surface water drainage, easements, arboriculture and ecological constraints and the opportunities created by accommodating and seeking enhancements have been considered by an architect in preparing “proving” layouts. Recognising that there are different ways in which the layout of the site could be designed these are not submitted for consideration at this stage of preparation of the GNLP, however, the proving layouts give Jarrold & Sons confidence that residential development of the site for the number of new homes identified in paragraph 1.4 above is deliverable and viable. 3.4 The majority of the documents listed above identify how sustainable residential development of the site can be achieved. This applies to the preliminary landscape and visual overview report, however, this document also demonstrates that the green space designation of the site under policy EN2 of the BDM-DPD is out of date in respect of the site. No evidence has been put forward by the GNLP team as to why this current designation remains up to date. In 2018 the site was subject to an unsuccessful nomination as an asset of community value. Evidence presented by Winckworth Sherwood on behalf of Jarrold & Sons and accepted by Broadland District Council, combined with the preliminary landscape and visual overview report demonstrate why the site does not make a significant contribution towards defining the character of the area. Designation under EN2 is not justified and should not be considered a restriction to residential development.
3.5 Paragraph 33 of the NPPF states that local plans and development strategies should be reviewed to assess whether they need updating at least once every five years and should then be updated as necessary. As such, we would anticipate that Broadland District Council in reviewing the BDM-DPD, adopted five years ago in August 2020, would identify policies such as EN2 (and the associated policies map) as out of date in respect of the site and therefore require updating. Paragraph 31 of the NPPF also states the preparation and review of all policies should be underpinned by relevant and up-to-date evidence. To that end, the Playing Pitch Strategy, Greater Norwich Area Broadland Action Plan 2014 would also need to be updated. We believe due to the criteria for green space and the closure of the site in 2016 the site does not contribute to these criteria. 4 Conclusions 4.1 Jarrold & Sons contend that as currently drafted the GNLP is unsound due to the failure to identify the site as a preferred option, contrary to the preferred strategy with regard to the distribution of development and failing to include a wholly deliverable site which would contribute towards the delivery of housing and other community benefits. 4.2 Jarrold & Sons also considers the GNLP fails the test of soundness when assessing whether it is justified. In order to be justified the plan should be an appropriate strategy, taking into account the reasonable alternatives and based on proportionate evidence. There is insufficient evidence to demonstrate that the two scenarios put forward in these representations (paragraph 1.4 above) have been considered despite these being submitted during the stage B regulation 18 consultation during March 2018. 4.3 Jarrold & Sons contends that the remedy to the GNLP’s failure to satisfy the tests of soundness would be to allocate the site for residential development (the extent of community use as part of the allocation should be discussed with Jarrold & Sons ahead of the regulation 19 stage of plan preparation).

Object

Representation ID: 22708

Received: 03/04/2020

Respondent: CODE Development Planners Ltd

The conclusions which identify sites GNLP0332R and GNLP0334R as 'unreasonable' for development are not supported by adequate and consistent assessments.
The assessments undertaken for sites GNLP0332R and GNLP0334R are inconsistent with the approach employed with the preferred allocation site at Taverham (GNLP0337) and with the Reasonable Alternative sites at Costessey (GNLP0581 and GNLP2043).
In our view, the Partnership's approach and details of assessments fail to meet the requirements of the NPPF (paragraph 35) and PPG (paragraph 038). Given the large proportion of total new allocations being concentrated on a single site at Taverham and the very real prospect of Reasonable Alternative sites being required in the plan period due to likely low delivery of allocated housing sites the approach to assessments is likely to render the plan as a whole not justified and not effective.

Representations detailed in the accompanying Position Statement (dated 16 March 2020) and appended reports rebut the unsubstantiated statements/observations which appear to have led to the Partnership's conclusions.

Object

Representation ID: 22709

Received: 03/04/2020

Respondent: CODE Development Planners Ltd

The conclusions which identify sites GNLP0332R and GNLP0334R as 'unreasonable' for development are not supported by adequate and consistent assessments.
The assessments undertaken for sites GNLP0332R and GNLP0334R are inconsistent with the approach employed with the preferred allocation site at Taverham (GNLP0337) and with the Reasonable Alternative sites at Costessey (GNLP0581 and GNLP2043).
In our view, the Partnership's approach and details of assessments fail to meet the requirements of the NPPF (paragraph 35) and PPG (paragraph 038). Given the large proportion of total new allocations being concentrated on a single site at Taverham and the very real prospect of Reasonable Alternative sites being required in the plan period due to likely low delivery of allocated housing sites the approach to assessments is likely to render the plan as a whole not justified and not effective.

Representations detailed in the accompanying Position Statement (dated 16 March 2020) and appended reports rebut the unsubstantiated statements/observations which appear to have led to the Partnership's conclusions.

Object

Representation ID: 22710

Received: 03/04/2020

Respondent: CODE Development Planners Ltd

The landowners object to the allocation of 11.08hectares for recreational open space.
Firstly, we understand that the key to the relevant plan mistakenly includes reference to Burial Ground in addition to open space. We understand this will be corrected.
In any event, the landowners are unclear about the Partnership's evidence to support the draft allocation for the 11.08 hectares of recreational open space. The site Assessment booklet for Hellesdon explains simply:

"The site is the same as existing a/location HEL4 from the Broad/and Local Plan. HEL4 is allocated for recreational open space. Site GNLP1019 seeks to maintain this allocation in the new local plan to 2038".

The Local Plan evidence base includes the Greater Norwich Local Plan Infrastructure Needs Report (updated and author un-named). In the body of the report there is reference to the Greater Norwich Sports Facility Strategy 2015 which sets out demand increases for sports halls and swimming pools. There is no reference to recreational requirements for either formal or informal open space. The chapter headed 'Open Space and Green Infrastructure' contains only a plan showing the Greater Norwich green infrastructure corridors, a network which, as explained elsewhere in the accompanying Position Statement, could be given a major boost by encouraging development on sites GNLP0332R and GNLP0334R.
In our view, unless and until appropriate evidence is prepared, the draft allocation for recreational open space on 11. 08 hectares of land at Reepham Road should be deleted. The landowners continue to encourage dialogue with all relevant parties, including the parish councils in order to identify the most appropriate provision of recreational open space to meet the requirements of various forms of outdoor recreation.
Reference to accompanying Position Statement for further detail.