Draft Local Plan-Part 2 Site Allocations

Support

Representation ID: 22706

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd.]
55. Below is set out our response to relevant questions from the Draft Local Plan – Part 2 Site Allocations. This sets the preferred allocations and the respective draft policies for the new housing and employment sites proposed to be allocated for development to help implement the Draft Greater Norwich Local Plan strategy.
Policy GNLP2136 Land at Briar Farm, Harleston
56. We strongly support the inclusion of our client’s site, at Briar Farm, Harleston, which has been included within the Draft Greater Norwich Local Plan Sites document as a preferred option under site reference GNLP2136. It is one of two new sites identified to provide Harleston with an additional 450 new homes and is the only preferred mixed use allocation within the settlement.
57. The site comprises 27 hectares to the west of the A143. Policy GNLP2136 states that the site is ‘likely to accommodate at least 300 homes, 33% of which will be affordable as well as care, employment, retail, open space and community facilities.’ However, we consider that the site can deliver significantly more than 300 dwellings and care can be quantified.
58. A series of updated plans and supporting information including a site Masterplan has been provided with this consultation response. The Masterplan shows how the development proposals for the site have evolved in response to engagement with the Town Council and technical work since the submission of the earlier representations. The Masterplan shows how 330 dwellings could be delivered. It identifies a site of 2.5 ha for a 90 bed (Use Class C3) care block with circa 30 older persons housing units alongside. This would all be integrated with extensive areas of open space and landscaping along with 1.6 ha for community use and 0.9 ha potentially for allotments. While the policy suggests the mix of uses should include employment use, demand for employment space locally is limited and therefore the Masterplan has set aside an area of 0.8 ha for a potential retail use.
59. The policy wording for Policy GNLP2136 is outlined below:

POLICY GNLP2136 Land at Briar Farm, Harleston 27.00 ha is allocated for mixed-use development. The site is likely to accommodate at least 300 homes, 33% of which will be affordable as well as care, employment, retail, open space and community facilities.
More homes may be accommodated, subject to an acceptable design and layout being achieved and any infrastructure constraints addressed.
The development will be expected to address the following specific matters:
 Masterplan to identify the mix of uses on the site and the relationship between them, to be accompanied by a phasing and infrastructure plan;
 Access (vehicular and pedestrian) to be via Mendham Lane with further pedestrian and cycle access from Barley Close;
 A new footpath connection to the existing Public Right of Way to the north of the site, creating a new link to the proposed open space to Angles Way;
 Submission of a Transport Assessment;
 Safeguarding of existing Public Right of Way east of Mendham Lane;
 Design and layout to take account of the existing residential and employment development to the west, northwest and north of the site, to protect the amenity of existing and future residents;
 Layout and landscaping to take account of the River Valley location and the potential to mitigate noise from the adjacent A143;
 Contribution towards green infrastructure protection or enhancement along the Waveney valley corridor;
 Appropriate investigation works and mitigation measures to address the surface water flooding to the north east of the site will be required;
 A proportionate contribution towards a new public water supply to help meet the requirements of the development.
Notes GNLP2136: This site is preferred for allocation as it is well located in terms of the form and character of Harleston. The design of the development will need to overcome constraints including surface water flow path through the site, and the need for a sensitive approach to the river valley landscape. Development would require submission of a transport assessment and mitigation of any highway concerns.
60. Scott properties strongly supports the above policy however would recommend that the policy wording is amended to acknowledge the low demand for employment land locally. It is therefore suggested that the second sentence of the in introduction to the policy is amended to the following:

61. In response to the specific matters to be addressed in the draft policy, a Masterplan has been provided for the site, and the latest version of this has been included within this consultation response. Furthermore, it is anticipated that the residential element of the site will be delivered as a single phase, rather than through a phased development and as such, the need for a Phasing Plan is not considered to be necessary at this stage.
62. Detailed design of the proposed access to both Mendham Lane and Harvest Way (Barley Close) have been shown on the accompanying Masterplan and the accompanying highways drawings, and a new footpath has also been shown on the footpath links plan as requested by the policy. The safeguarding of the existing Public Right of Way is also clearly shown and provides a key pedestrian/cycleway with a reconfigurement to the existing vehicular access from Briar Farmhouse.
63. The Masterplan demonstrates that careful consideration has been taken to respect the surrounding residential development by providing attenuation and single-storey dwellings (bungalows) to the west and north of the site to reduce visual impact and harm on residential amenity. Furthermore, a large open space buffer has been provided to the east of the site, taking into consideration the landscape visual impact the development of the site may have on the River Waveney valley. A Noise Survey has also been carried out confirm the that noise from the A143 is not a constraint to development.
64. A draft Drainage Strategy has been prepared to address surface water flooding to the north-east of the site, which will include attenuation basins located and sized accordingly to provide appropriate mitigation. The client is also in the process of engaging with Anglian Water in respect of a new public water supply to help meet the requirements of the development and is confident this can be address at the planning application stage.
65. It is considered that the site would help maximise delivery in line with the recommendations of the Independent Review of Build Out, Final Report (Letwin Review) October 2018, delivering a more diverse range of product and thereby facilitating greater market absorption. The site can be brought forward through the submission of either an outline application with an Indicative Masterplan or as a detailed application on a subject to planning basis. Initial discussions have taken place with private housebuilders who have expressed an interest, and more detailed dialogue is ongoing with Saffron Housing regarding the proposed care accommodation. An updated planning and delivery strategy will be agreed following pre-application advice and public consultation.
66. Scott Properties are confident that respective development partners for the family housing, bungalows and care facilities can jointly bring forward reserved matters applications within two years or less of outline consent being obtained. A significant amount of technical work has already been undertaken which has confirmed there are no physical constraints to development. Scott Properties intends to submit a pre-application advice request in April 2020. The proposals will be amended as required by the pre-application advice and then taken forward for wider public and community consultation. This will centre around a public consultation event planned for Summer 2020 followed by an online and postal feedback exercise.
67. Assuming that a planning application is submitted following the Regulation 19 consultation in 2021, it is reasonable to expect that planning permission could be forthcoming before the end of 2021 allowing contractual arrangements to be completed with development partners before the end of the year (if not already concluded). Respective reserve matters applications could then be prepared and submitted in the early part of 2022 meaning that development on site could commence in 2022 via either route. Based on this assessment, it is anticipated that the first houses could be available for occupation in spring 2024. Assuming completions of 15 bungalows and 50 family houses per year, as set out in the table below (see attachment) the site could be completed in 2029.

68. Furthermore, as the site is in a single ownership, it is more achievable as there are no complex land ownerships or legal issues to compromise its ability to come forward for development. It is available now and would represent a realistic and deliverable development in the current market conditions. We further support the inclusion of the site within the Local Plan as it is located adjacent to the settlement boundary and as such would represent a logical expansion to the town. Our professional judgement is that this site could come forward with a viable residential housing scheme that is policy compliant.
69. As outlined within the National Planning Policy Framework 2019, to be considered ‘deliverable’, sites for housing should be ‘available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years.’ In summary, we consider that the is suitable for residential development, available within the next 5 years and achievable due to being in one ownership.
70. All this information confirms that the site is deliverable, suitable, and achievable and will bring much needed new housing, care, retail and recreational opportunities to Harleston.
Technical Work completed to date
71. The following additional technical work has been completed since the previous Reg 18 Consultation and our submission in December 2018, and the documents are included as appendices to this document.
a. Masterplanning
i. Proving Layout
ii. Parameter Plan
iii. Pedestrian Access Plan
b. Highways and Utilities
i. Highways Technical Note
ii. Vehicular Access Proposals
iii. Barley Close Pedestrian Link
iv. Utilities Assessment
c. Flood
i. Flood Risk Technical Note
ii. Infiltration Testing
iii. Preliminary Surface Water Attenuation Calculations
d. Ecology
i. Bat Scoping and Activity Survey
ii. Great Crested Newt and Amphibian Survey
iii. Reptile Survey
iv. Arboricultural Survey
e. Landscape and Heritage
i. Archaeological and Heritage Assessment
f. Environment
i. Noise Assessment

Support

Representation ID: 22796

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Our client’s site, Land west of Shelfanger Road and East of Heywood Road, Diss has been included within the Draft GNLP Sites document as a preferred option under site references GNLP0291 and GNLP0342 as part of a larger allocation forming Policy GNLP0250/0342/0119/0291 for ‘at least 200 homes, 33% of which will be affordable’ to the north of Diss. Since being submitted to the Call for Sites as only GNLP0342, my client has agreed heads of terms on the site known as West of Shelfanger Road under site reference GNLP0291. They are also actively engaging in discussions with the Landowner for the site known as GNLP0250 and it is their intention to bring forward the three sites as a whole with a joint masterplan.

Object

Representation ID: 22797

Received: 16/03/2020

Respondent: Strutt & Parker LLP

my client recommends that site reference GNLP0119 is excluded from the policy and is not put forward as an allocation or part of the wider site. The site has recently changed ownership and would not form a viable portion to bring forward with the wider site given its existing residential use and value. In addition to this, it is not possible to achieve sufficient visibility splays to achieve a separate vehicular access, which further impacts its viability to be brought forward.

Support

Representation ID: 22798

Received: 16/03/2020

Respondent: Strutt & Parker LLP

We support the requirement for a Masterplan to be provided for the site, showing a co-ordinated approach across the three sites. There is a definite need to ensure that the site comes forward in a deliverable way and that public benefits are realised. Scott Properties are actively engaging with the Landowners of GNLP0250 and have already agreed terms with GNLP0291.

Object

Representation ID: 22799

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The Policy requires for ‘at nil cost to the Town Council, safeguard land for an extension to the cemetery’. Obviously there is a value to land for burials and the inclusion of land for this type of community use will need to be off set against the provision of land for other community benefits, such as open space for sport and recreation. The exact location and extent of the cemetery extension will need to be agreed through the development of the Masterplan, but it is understood that there is a preference from the Town Council for this to be located on the east of the Site, to enable a new access from Heywood Road. In terms of current capacity, it has been confirmed that there are currently c. 1,800 plots available, equating to 40 years’ supply at the current rate of 45 burials per year. In February the Town Council resolved “To request that the extension of the Cemetery allows for an additional 60 years of burials/ashes at the current rate of burial”. This would provide a total of 100 years of land supply for the cemetery. We would suggest that the following work should be undertaken by the Town Council to substantiate and justify this request.
a. A Cemetery Risk Assessment – to ensure that the site is suitable in terms of the groundwater conditions.
b. A detailed Population Projection – to compare future death rates with population growth and religious groups.
c. A detailed assessment of future burial practice with reference to the move to a greater number of woodland/natural burials.

In any case, provision of an area of c. 3.4 acres (at 800 burial plots per acre) at nil cost to the Town Council could impact on the viability of the site and the ability of the site to deliver at least 200 dwellings as per the allocation wording. My client would question the extent to which projected future burial needs well into the next century and beyond the Local Plan period should be prioritised over the need to deliver housing to meet the identified needs during the Local Plan period. The Masterplan proposes an area of 1.2 acres which would provide an additional c. 20 years supply (as per the Local Plan period), and we would welcome further discussions with the Town Council and GNLP Team on this subject.

Comment

Representation ID: 22800

Received: 16/03/2020

Respondent: Strutt & Parker LLP

A Technical Note has been prepared by Atkins and provides transport and highways information to support this representation, including details on the site schematic plan on the associated road and pedestrian connections as well as the plans to retain and enhance the existing Public Rights of Way (PROW) to the north and west of the site. In conjunction with this Technical Note, a ‘proposed general arrangement and access plan’ and ‘swept-path analysis of proposed highway access’ have also been provided. A Transport Assessment will be prepared to follow on from this note and form part of the planning application at the site. The aim of providing a vehicular connection between Shelfanger Road and Heywood Road is supported, as it will improve connectivity to the north of the Diss and provide a degree of relief to Sunnyside from vehicle users who would otherwise need to take this route.

In addition, a Flood Risk Technical Note has been prepared by Atkins and accompanies this Representation. The Note identifies that the site is located within Flood Zone 1 and as such, flood risk at the site is considered to be low to negligible. However, it is noted that once the proposed development introduces new paved areas, the surface run off will increase and require management. Recommendations have been provided within the Technical Note which will inform future Flood Risk Assessments and Surface Water Drainage Strategies at the site forming part of any planning application.

A Tree Survey has been prepared by Geosphere Environmental and includes a Tree Constraints Plan at Appendix 2. This identifies Category A, B and C trees and root protection areas that will be considered throughout the development and detailed design of any proposed development. In addition to this, a Landscape Constraints and Opportunities Appraisal Plan has been prepared by Lockhart Garratt and provides an indicative landscape plan, outlining the location of retained PROW’s, developable areas within the wider allocation and potential access points.

A Constraints Plan has also been included as part of this representation, showing the location of the high pressure pipeline as referred to within the policy, located adjacent to the northern boundary of the site, and applicable the 14.3m Building Proximity Distance (confirmed by Cadent) where no buildings may be constructed. The Constraints Plan pulls together combined information from the above reports as well as showing the location of the excluded land within GNLP0291 and a water main which runs through the site (which it is proposed would be diverted).

A Concept Masterplan has been provided which shows a net developable area of 6.13ha. As proposed, it would be possible to achieve the target dwelling yield of 200 no. dwellings by applying a net density of 32.6 dph. This is considered achievable and feedback will be sought from Officers at South Norfolk District Council on this subject through the pre-application process.

Support

Representation ID: 22801

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The site can be brought forward through the submission of a joint Masterplan which could accompany an outline application. Initial discussions have taken place with private house builders who have expressed an interest in purchasing the site on either an unconditional (post planning) or subject to planning basis. An updated planning and delivery strategy will be agreed following pre-application advice and public consultation.

Scott Properties are confident that a respective development partner for the site will be identified to bring forward reserved matters applications within two years or less of outline consent being obtained. A significant amount of technical work has already been undertaken which has confirmed there are no overriding physical constraints to development of the site. Scott Properties intend to submit a pre-application advice request in May 2020. The proposals will be amended as required by the pre-application advice and then taken forward for wider public and community consultation. This will centre around a public consultation event planned for Autumn 2020 followed by an online and postal feedback exercise.

Assuming that a planning application is submitted following the Regulation 19 consultation in 2021, it is reasonable to expect that planning permission could be forthcoming before the end of 2021 allowing contractual arrangements to be completed with development partners before the end of the year (if not already concluded). Respective reserve matters applications could then be prepared and submitted in the early part of 2022 meaning that development on site could commence in 2022 via either route. Based on this assessment, it is anticipated that the first houses could be available for occupation in 2024. Assuming completions of 50 family houses per year, as set out in the table below the site could be completed in 2027.

While the site is in multiple ownerships, Scott Properties is working closely with the owners of all three parcels so that the site can be bought forward as one. As such, development of the site is achievable. It is available now and would represent a realistic and deliverable development in the current market conditions. We further support the inclusion of the site within the Local Plan as it is located adjacent to the settlement boundary and as such would represent a logical expansion to the town. Our professional judgement is that this site could come forward with a viable residential housing scheme that is policy compliant.

As outlined within the National Planning Policy Framework 2019, to be considered ‘deliverable’, sites for housing should be ‘available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years.’ In summary, we consider that there is suitable for residential development, available within the next 5 years and achievable.