Draft Local Plan-Part 2 Site Allocations

John Long Planning represents Hibbett & Key Ltd and they have asked me to respond in relation to land they are promoting for development in Framingham Earl/Pigot.

Hibbett&Key support the identification of Poringland/Framingham Earl as a Key Service Centre. However, they object to the decision not to allocate any further sites in this Key Service Centre. They suggest that the Local Plan should allocate land for development in Poringland/Framingham Earl(Pigot) and confirm their site(s) at Pigot Lane remain available for development.

John Long Planning is instructed by Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) to respond to the current Greater Norwich Local Plan (Regulation 18) consultation specifically in relation to Policy HET 1: Land North of Hethersett. Persimmon and Taylor Wimpey own the site, which has the benefit of planning permission and is implemented, with some early development phases already built out.

Background
The original Hethersett North outline application 2011/1804/O was consented on 22 July 2013. The original outline application site (excluding the park and ride extension) extends to approximately 83.6 hectares and limits the total number homes to 1,196 units.

The original outline application required compliance with approved parameter plans, including for layout, land use and density. The site developers (Persimmon Homes (Anglia) and Taylor Wimpey(East Anglia) have submitted and had approved a number of Reserved Matters (Phases 1 and 2). The Reserved Matters for the rest of the permitted units approved by the outline consent (1,196 units) will be submitted by early 2021. So far, approximately 320 units of the 1,196 units have been completed. The 1,196 units approved by the outline consent are anticipated to be completed by 2025. The Reserved Matters approvals have been consistent with the approved parameter plans (certain of the plans, such as density included density ranges, rather than set figures).

The Reserved Matters applications have been efficient in the use of land, with development densities approved towards the upper end of the density ranges. This has resulted in the housing total (1,196 units) being met, with additional land left undeveloped within the redline area and within the identified developable land as indicated on the land use parameter plan (Phase 4 on the phasing plan).

Sufficient open space land and other land uses required by the consent have been accommodated in
accordance with approved parameter plans without needing the undeveloped land. There are no other land use requirements of the outline consent that need to be accommodated within the undeveloped land (Phase 4).

An opportunity therefore exists to accommodate addition residential units within land already identified for residential development in the parameter plans supporting the outline consent and within the land allocated for development in the Local Plan.

It is acknowledged that to secure the additional ‘uplift’ in residential unit numbers a new consent will be required, which will 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. The technical work has been commenced and consists of :
• Highways
• Utilities
• FRA/drainage
• Ecology
• Arboricultural

An EIA Addendum (addendum to the original outline application (revised Environmental Statement) will also 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.

The current intention is to prepare and submit an outline application for the ‘uplift’ area later in 2020, once the technical work and EIA work has been completed.


Response to GNLP Consultation – Policy HET1: Land North of Hethersett

Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) support the Greater Norwich Local Plan’s acknowledgement that the site HET 1: Land north of Hethersett is capable of accommodating additional housing units beyond the previous allocation figures (1,080 units) and the information and evidence described above will give the Authorities confidence and comfort that the developers are actively progressing the existing consent’s build-out; and are pro-actively working to obtain consent for the uplift numbers. The aim is to have a continual pipeline of completions up to 2028 of around 125-150 units per year.

The work undertaken so far on the ‘uplift’ element of the site would suggest that an uplift of approximately 200 units over the original 1,196 units permitted by the outline consent is deliverable (around 1,400 units in total), and there may be scope for more units beyond 200 units to be accommodated within land and infrastructure/open space capacity limits. This additional amount (up to 250 units beyond the consented 1,196 units) is currently being tested.

However, Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) are concerned that the inference in the ‘Notes’ section accompanying Policy HET 1 suggests that the Policy provisions in Policy HET 1 should be addressed by the ‘uplift’ proposals, without acknowledging that many of the Policy’s provisions have already been met, or will be met through the discharge of conditions and S106 obligations already in place as part of the original outline consent and are therefore no longer applicable or relevant in terms of the ‘uplift’ element of the site. It is noted that the Policy HET 1 is updated to make reference to additional dwellings (1,369), but the rest of the Policy appears to be the same as the previous site allocations document, without acknowledging that some of the policy provision are not now relevant.

For instance, the Masterplan and Phasing Plan for the allocation has been submitted and approved (without site HET 2 which is not in Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) control; the improvements to Thickthorn are being delivered through S106 agreements; strategic gap matters are not relevant to the ‘uplift’ site; and access to Colney Lane and the footpath and cycle route to the NRP is already delivered etc.

Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) suggest therefore that it is not possible or appropriate for the ‘uplift’ proposals to take account of many of the policy requirements as set out in Policy HET 1, and the concern is that the simple roll forward of the policy requirements could render the uplift application undeliverable if they all need to be addressed.

Furthermore, past experience would suggest that Local Plan Inspectors generally prefer committed sites (i.e. those with planning permission) not to be identified as ‘allocations’ in Local Plans and rather that they should be shown with a specific ‘site with planning permission’ designation and with settlement/development boundaries extending around them.

Finally, it is not clear what is meant by the section in the ‘Notes’ section that “..the remainder of GNLP0177-A is not preferred for allocation..” .

Suggested changes
Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) suggest that rather than simply roll forward the previous Local Plan allocation and Policy HET 1 Land North of Hethersett in its entirety, the Local Plan should acknowledge that the ‘allocation’, is now a committed site (i.e. with planning permission) that has been implemented and is therefore extant in perpetuity and should be notated as such; and that the Local Plan Policy HET 1 should be updated to only include requirements that are relevant to the ‘uplift’ scheme and not development that is already consented or built.

Conclusion
In conclusion, Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) supports the Local Plan’s acknowledgement that the site HET 1: Land North of Hethersett is capable of accommodating additional residential units beyond those identified in the previous Site Allocations Plan (1,080 units) and permitted by the outline consent (1,196 units). Technical and design work undertaken so far suggests that a figure of at least an additional 200 units may be accommodated within existing land and infrastructure capacity limits and this design and technical information can be made available to the Authorities shortly.

However, Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) do not think it appropriate for the Policy HET 1 to be rolled forward in its entirety without acknowledging that planning consent has been granted and many of the Policy’s requirements are met through that process, as evidenced in planning conditions and the s106 agreement. Rather it should only include policy requirements that are relevant to the ‘uplift’ site proposals.

Persimmon Homes (Anglia) and Taylor Wimpey (East Anglia) remain very happy to continue to work with the Authorities to clarify those Policy HET 1 requirements that remain relevant to the ‘uplift’ site, and those that are not including those that have been/are being dealt with by the original consent (and associated reserved matters) conditions and s106 obligations related to the original implemented consent.

John Long Planning Ltd represents Hibbett & Key Ltd who are promoting land for development North and South of Pigot Lane, Framingham Earl/Pigot. ref: GNLP0589A&B.

Hibbett & Key Ltd object to the decision not to allocate any further sites in Poringland/Framingham Earl. This Key Service Centre should have additional land allocated for residential development. Hibbett & Key Ltd note that the assessment of site GNLP0589 A&B confirms the site is well related to the village and the only reasons for not allocating it, is because there are other commitments in the village and no new allocations are being made.

The other assessed sites in Poringland/Framingham Earl all have additional reasons for them not being allocated. Hibbett & Key Ltd suggest that if a decision is taken to allocate further sites in this Key Service Centre, site GNLP0589A&B appears to out perform the other promoted sites and should therefore be in prime position for allocation. Hibbett & Key Ltd confirm the site remains available for development should it be needed.

It is incorrect to suggest that the site GNLP 2149 cannot be accessed. An achievable access is possible as confirmed by NCC Highways (letter: Jonathan Hanner ref:9/5/18/1043-19/7/18): "...In order to cater for the additional traffic generated...widen the access to ensure a minimum width of 5m for the first 10 metres into the site. This can be simply achieved by relocating the kerb and resurfacing the grass verge (to coincide with the existing length of surfacing)." I can confirm the required minor works are in the public highway/landowners control and deliverable.