Draft Local Plan-Part 2 Site Allocations

Comment

Representation ID: 22918

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Please note that we have previously promoted the site as having the capacity to accommodate 500 new homes,
not the 600 that has been recorded and is referenced in the Sites Assessment Booklet. However, following
further technical work, the site is now being promoted for c. 350 new homes, together with additional recreation
facilities, as outlined in the Vision Document that accompanies these representations.

Object

Representation ID: 22928

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

The ‘Sites Assessment Booklet’ for Horsford states:
“HORSFORD, FELTHORPE AND HAVERINGLAND

The catchment of Horsford Primary School brings Horsford, Felthorpe and Haveringland into a village cluster. The school currently has limited capacity.

It is considered that as well as existing commitments and windfall development, approximately 20-50 new homes are appropriate for the Horsford cluster. In addition to the primary school, services include a shop, doctor’s surgery, village hall, library and public house.”

The introduction to the Site Assessment Methodology, states (para. 1.5):
“The scale of growth proposed within each ‘village cluster’ reflects school capacity or ability or grow, plus the availability of other accessible services. Taking account of the timescales for delivery and other uncertainties, such as pupil preference, it has been assumed that a minimum scale of allocation (12- 20 dwellings) can be accommodated in all clusters if appropriate sites are available. To guide development all village clusters have been rated ‘red’ (12- 20 dwellings), ‘amber’ (20-50 dwellings) or ‘green’ (50-60 dwellings) based on information provided by Children’s Services, although this is a starting point and there is flexibility within these ratings, depending upon the quality of sites and the circumstances of individual schools.”

As a methodology, this statement is distinctly insufficient and places undue and unjustified emphasis on unpublished advice from ‘Children’s Services’.

With the Booklet stating that ‘it is considered that … approximately 20-50 new homes are appropriate’ for Horsford, it is assumed that the village has been rated ‘amber’ “based on information provided by Children’s Services’.

There is no other justification as to how the GNDP has arrived at the figure of ‘20-50’ for Horsford.

Object

Representation ID: 22929

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Land to the south of Green Lane, Horsford (Site Ref. GNLP2160)
The Housing and Economic Land Availability Assessment (HELAA) for the Greater Norwich Area comprises three ‘volumes’:
• The December 2017 HELAA;
• The October 2018 HELAA Addendum I, and
• The January 2020 HELAA Addendum II.

There is no overlap between the three volumes – i.e. a site appearing in one does not appear in either of the other two.

As set out in Planning Practice Guidance (PPG) (ID: 3-001-20190722):
“An assessment of land availability identifies a future supply of land which is suitable, available and achievable for housing and economic development uses over the plan period.
…
However, the assessment does not in itself determine whether a site should be allocated for development. It is the role of the assessment to provide information on the range of sites which are available to meet the local authority’s … requirements, but it is for the development plan itself to determine which of those sites are the most suitable to meet those requirements.”

In each of the HELAA volumes, sites are assessed against a range of criteria and scored ‘red’, ‘amber’ or ‘green’. In each case, the site was scored based on the information available to the GNDP at the time the assessment was carried out. As set out in the original December 2017 HELAA (para. 2.20):
“The methodology states that if a site is assessed as red against any type of constraint or impact then it will be discounted and the site will not be considered suitable for development for the purposes of the HELAA assessment. Sites assessed as amber against any type of constraint or impact will be considered as potentially suitable providing that the constraint or impact could be overcome and the green category represents no constraint or impact.”

The HELAA goes on to state (para. 7.5), as do the Addenda:
“The HELAA presents a snapshot of the position at a particular point in time and will need to be updated regularly as plan preparation progresses.”

Our client’s site, known as Horsford Phase 3, (land south of Green Lane) (Site Ref. GNLP2160) was included in the Regulation 18 consultation carried out in late 2018 on ‘new, revised and small sites’. This consultation was essentially a consultation on the GNDP’s assessment of the 200+ sites submitted for consideration since December 2017 as contained in October 2018 HELAA Addendum I.

In that Addendum, our client’s site was scored as follows:

Constraints Analysis
• Access Amber
• Accessibility to Services Green
• Utilities Capacity Amber
• Utilities Infrastructure Amber
• Contamination and Ground Stability Green
• Flood Risk Amber
• Market Attractiveness Green

IMPACTS ANALYSIS
• Significant Landscapes Amber
• Townscapes Amber
• Biodiversity and Geodiversity Amber
• Historic Environment Amber
• Open Space and GI Green
• Transport and Roads Amber
• Compatibility with Neighbouring Uses Green

Savills submitted representations to the 2018 consultation and addressed each of the criteria on which the site had been scored ‘amber’ as set out below. To this has been added further comment in respect to ‘Significant Landscapes’ and ‘Townscapes’. Given that the studies submitted in 2018 identified the capacity to accommodate 500 new homes, there is clearly capacity to accommodate the 350 new homes now being promoted.

Access / Transport & Roads
The access to the promoted site would be from the existing adjacent development, with the access to the promoted site having capacity to serve an additional 500 homes (see Highway Capacity Assessment enclosed herewith); additional traffic surveys would be carried out prior to / as part of any future development proposal.

All of the access infrastructure required to serve the promoted site is thus already approved / in place or controlled by BDW. Additional pedestrian, cycle and emergency accesses would also be provided as indicated in the Vision Document enclosed herewith.

On this basis, it is suggested that the constraints analysis for ‘Access’ is re-categorised to ‘green’ in the suitability assessment of the site.

Accessibility to Services
Although the constraints analysis already categorises the site as ‘green’ in this regard, further work (see Education Report enclosed herewith) has been undertaken by BDW to confirm that there is capacity on the site of the existing primary for the school to be expanded to accommodate another form of entry.

That there is sufficient capacity to expand the school and that that the school is adjacent to the site, serves to further reinforce the ‘green’ categorisation already assigned, and reinforce the site’s sustainability credentials.


Utilities
(See Utilities and Drainage Review enclosed herewith.)
With regards to utilities (capacity and infrastructure), foul water drainage has been accommodated for as part of the existing adjacent development with an adoptable pumping station, with the ability to receive pumped flows from 500 homes.

With regard to electricity supply, the High Voltage Network was extended as part of the existing adjacent development to serve the new substation. This has again been designed to accommodate a further development of 500 homes.

There is also sufficient gas supply, with offsite works completed as part of the existing adjacent development, which can accommodate the supply for a further 500 homes.

On this basis, it is suggested that both the constraints analysis for ‘Utilities Capacity’ and ‘Utilities Infrastructure’ are both re-categorised to ‘green’ in the suitability assessment of the site.


Drainage / Flood Risk
With regard to flood risk, the promoted site is wholly located within Flood Zone 1 according to the Environment Agency Flood Mapping.
The maps also show that the site is not at risk from surface water flooding. Infiltration testing has taken place by BDW on both adjacent sites, with all studies to date indicating that the same approach could be taken to draining the promoted site (see Utilities and Drainage Review enclosed herewith).
On this basis, it is suggested that the constraints analysis for ‘Flood Risk’ is re-categorised to ‘green’ in the suitability assessment of the site.

Significant Landscapes / Townscapes
The Landscape and Visual Appraisal (LVA) (enclosed herewith) concludes that:
• The promoted site is not covered by any designations for landscape character or quality, nor is it identified in the existing Local Plan for its character or landscape quality. It is not publically accessible and does not contain or lie in proximity to any designated heritage assets.

• The promoted site could not be considered to form part of a Valued Landscape for the purposes of Paragraph 170 of the NPPF.

• The promoted site is very well contained by dense woodland to the north and east, and existing built form to the south and west, resulting in very few opportunities to view the site from its surroundings.

• Given the visual containment of the promoted site, public views of the new houses will be limited to filtered views from Mill Lane and Green Lane, with retained boundary vegetation and new structural planting to these boundaries increasingly filtering and screening these views as it matures.

Overall, the LVA concluded:
“The assessment found that the proposed development would be compatible with the surrounding and planned development on the northern edge of Horsford, set within an established landscape framework of mature trees and surrounding woodland. In summary, the Site is capable of accommodating development in line with that shown on the Concept Masterplan, without resulting in significant harm to the local landscape character, or views from the surrounding area.”

On this basis, it is suggested that the impact analysis for ‘Significant Landscapes / Townscapes’ is re-categorised to ‘green’ in the suitability assessment of the site.


Biodiversity and Geodiversity
The Vision Document shows how the development of the site could deliver a new Nature Park to the north of Green Lane to enhance the existing natural environment, whilst also creating new community public open space. There would be further opportunities to create a net gain in biodiversity through the creation of new habitats within and around the site.

With the knowledge of the site and surrounding area gleaned from the development of the two adjacent sites, and the Ecological Study undertaken by TMA in relation to the promoted site (see enclosed Ecological Report dated December 2018) there are no likely significant adverse impacts that would arise off-site, especially given the proposed creation of the new Nature Park.

On this basis, it is suggested that the impact analysis for ‘Biodiversity and Geodiversity’ is re-categorised to ‘green’ in the suitability assessment of the site.


Historic Environment
As set out in the Cultural Heritage Desk-Based Assessment (enclosed herewith), there are no World Heritage Sites, Historic Battlefield sites or Historic Wreck sites within the vicinity of the promotion site. The Scheduled Monument ‘Two round barrows on Horsford Heath’ (NHLE ref.1003164) lies a short distance north-west of the site, enclosed by a woodland. However, there is no inter-visibility between the site and the Scheduled Monument due to the extent of intervening woodland, and thus the site is not an element in how the significance of the Scheduled Monument is experienced. Overall, it is considered that the residential development of the site would represent an alteration of the extended rural setting of the Scheduled Monument, but an alteration that would not have the potential to alter its significance.

With regard to built heritage, there are no such assets located within the site and the site does not have a visual, functional or historical relationship with, not does it contribute to the setting, of any nearby assets.

On this basis, it is suggested that the impact analysis for ‘Historic Environment’ is re-categorised to ‘green’ in the suitability assessment of the site.


Transport & Roads
See ‘Access’ above.
On this basis, it is suggested that the constraints analysis for ‘Transport and Roads’ is re-categorised to ‘green’ in the suitability assessment of the site.
Summary
The re-categorisation of the site’s constraints / impacts analysis as discussed above would result in all of the constraints analysis criteria being ‘green’, with more of the impacts analysis criteria also now being ‘green’. The lack of any ‘red’ and a low number of ‘amber’ scores on the assessment, shows that the site is suitable for residential development.
In summary, based on the additional information that we provided to the 2018 consultation, the site should have been reappraised (subject to the potential for the GNDP disagreeing with the information provided) as follows:

• (Please refer to attached document: “Reps to R18 GNLP 16 03 20_FINAL”)

However, despite the HELAA explicitly recognising and stating that it only represents “…a snapshot of the position at a particular point in time and will need to be updated regularly as plan preparation progresses …” the GNDP has not sought to update any of the HELAA assessments carried out to date; in essence, the HELAA ignores all of the additional information submitted through previous consultations. On this basis alone, Savills would contend that the conclusions of the individual site assessments as contained in the HELAA cannot be relied upon as being accurate.

Instead, the Site Assessment Booklet states:
“This site is not considered to be reasonable for allocation as the scale of the proposal is a concern with a lack of safe walking / cycling route to the catchment high school. Development would require highway improvements and it is unlikely that a satisfactory access strategy would be able to be developed for the entire level of development. There are also ongoing concerns with the new B1149 roundabout. Smaller areas of the larger site were considered but dismissed as unsuitable due to the standard of Mill Lane and Green Lane.”
With regard to the issues raised in this commentary as being reasons to dismiss the site:
• It is stated that the scale of the proposal is stated as being a concern, yet no further comment on this is provided – why is it a concern?

• It is stated that there is a lack of a safe walking / cycling route to the catchment high school, yet this is a comment applicable to many existing commitments and proposed allocations and was not considered to be an issue in the granting of planning permission for some 429 new homes on land directly adjacent to the promotion site.

• It is stated that highway improvements would be required, that it is unlikely that a satisfactory access strategy could be devised, and that there are concerns with the new roundabout delivered as part of the adjacent development, yet evidence submitted to previous consultations (and enclosed herewith) refutes that suggestion and demonstrates that adequate highway access can be delivered without the need for any significant highway improvements.

• It is stated that smaller areas of the promotion site were considered but that these were dismissed as unsuitable due to the standard of Mill Lane and Green Lane, yet no evidence is provided to demonstrate what smaller areas were considered, why these were (incorrectly) considered to be reliant on either Green Lane and/or Mill Lane (access can be provided via the adjacent development), or why these ‘smaller areas’ were dismissed; the GNDP sought no input from BDW in respect of any smaller area despite BDW stating in previous representations a willingness to meet to discuss the site.

Delivery
BDW Homes (Eastern Counties) have a very good record of delivery within Horsford. Of the two sites adjacent to the promoted site, Phase 1 (125 dwellings) was completed June 2017 and Phase 2 (304 dwellings) is currently under construction with 87 units complete at the time of writing (see further details in the table below).
It is anticipated that Phase 2 will be completed by the end of 2023. BDW can also demonstrate successful delivery of other residential sites across the Greater Norwich area, including sites in Aylsham and Poringland.
The promoted site provides a logical and suitable opportunity for residential development in an established location with Horsford benefiting from both existing and planned infrastructure. Given the presence of BDW in Horsford, there is certainty that the site can be delivered within the early years of the plan, and moreover delivered in a quick and timely fashion without the usual delays associated with starting on site.
Delivery on the promoted site could commence as early as 2024 (i.e. within the first 5-years of the plan period, extending into the second 5-years), and would deliver c. 100 new homes a year.

(For additional information, please refer to attached document Reps to “R18 GNLP 16 03 20_FINAL”)

Comment

Representation ID: 22981

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

BDW's interest relates to the part of the preferred allocation identified as GNLP0307, which BDW has previously promoted through the GNLP process for additional housing and it is within this context that these representations are made.

In response to the proposed uplift BDW has carried out additional work to support the further development of their site. This work also demonstrates that the remainder of site GNLP0307 has the capacity to accommodate a greater number of dwellings than the uplift of 360 homes that are proposed across the balance of site GNLP0307 and site GNLP0327.

Object

Representation ID: 22982

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

CRINGLEFORD: PHASE TWO - FRAMEWORK PLAN

Phase one of the development at Cringleford relates to the consented scheme at Newfound Farm, which is being implemented. Phase two relates to the additional land that the GNLP now proposes for additional housing.

The Framework Plan prepared on behalf of BDW demonstrates how additional development can be delivered as a continuation to the consented scheme. It respects the existing allocation boundaries and the settlement boundary of Cringleford by retaining the strip of land adjacent to the A47 as an area of public open space. The Framework Plan also respects the existing landscape and ecological features on the site and has been informed by the work carried out by CSA and MLM. Some 11ha of net developable area has been identified, which has a capacity of approximately 500 dwellings based on an average density of 44 dwellings per hectare (dph).

The Framework Plan shows access to the site through two vehicular accesses points that would be accommodated through extensions of the road network of the consented phase one development. In accordance with the Neighbourhood Plan policy a further point of access is identified off the Round House Way roundabout and through an adjoining site (known as the Kier land) as a way of providing greater permeability.

The street hierarchy principles established on the phase one scheme have been continued into the phase two site. These include a 6.5m primary street through the heart of development, lined by 2x 2m wide verges with a 2m wide footway on one side and a 3m wide cycleway on the other side. The 6.5m width allows the primary street network to accommodate buses. Branching off from the primary street are secondary streets at 5.5m wide, followed by more informal shared surfaces and private drives as the development reaches the rural edges.

In accordance with the proposed site allocation, land has been reserved within the Framework Plan for additional school land. A 1ha area of land has been reserved in the northwest corner of the site for the school expansion. This is located adjacent to the school site that has already been secured through the consented phase one scheme.

All existing vegetation has been retained with ‘green fingers’ following the existing hedgerows through the site and into the residential areas. The ‘veteran’ tree along the southern boundary has also been respected with an additional 15m offset of any buildings from its centre.

Surface water attenuation features have been shown indicatively based on the topography of the site. The existing pylons and overhead wires have been respected with a minimum 30m clearance, creating a strong green corridor through the entirety of the site.

Comment

Representation ID: 22983

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

ADDITIONAL HOUSING

Within the parish of Cringleford 1,200 homes were originally allocated through the Neighbourhood Plan 2014. At the base date of the Greater Norwich Local Plan 1,300 homes have been allocated, with consent granted for a further 61 homes. Cringleford was originally identified as a sustainable location to accommodate growth as there are good links to the University of East Anglia, Norfolk and Norwich University Hospital, and Norwich Research Park. As Cringleford is a fringe parish within the Norwich urban area it is at the top of the Sustainable Growth Strategy hierarchy identified in Policy 1 of the emerging Greater Norwich Local Plan. Therefore, the Part 2 - Site Allocations identifies an uplift in the number of homes allocated through the Cringleford Neighbourhood Plan of 360 dwellings across two existing site allocations (the balance of GNLP0307 and GNLP0327) to the southwest of the village.

BDW considers that it is right for the Sustainable Growth Strategy to focus development in areas around Norwich and it believes that Cringleford is an appropriate location for a proportion of this requirement. BDW’s site at Cringleford (GNLP0307) extends towards the A47 and includes the consented development site (identified above as phase one) and an additional 17.82ha of land (identified as phase two), that is mainly within the existing development boundary of the village.

The phase two land and the land to the southeast of site (GNLP0327), have been identified to accommodate the uplift of 360 additional homes that are proposed for Cringleford. BDW support the principle of the proposed uplift but believes that the uplift should be greater to reflect the development potential of its site. BDW believes that the phase two land will form a natural extension to the consented development and will assist in supporting and enhancing that new community by delivering a successful new and sustainable neighbourhood for Cringleford.

The Housing and Economic Land Availability Assessment 2017 (HELAA) that has been carried out confirms that there are no constraints to the development of the remainder of site GNLP0307, with it being identified as having utilities infrastructure and market attractiveness. Similarly, there are no constraints relating to sensitive townscapes, biodiversity, geodiversity and compatibility with neighbouring uses. The site is also seen positively with regards to open space and green infrastructure. Similarly, the adjacent site (GNLP0327) is also identified as having limited constraints to its delivery.

Given the positive assessment of our client’s site through the HELAA it is seen as an appropriate site to accommodate further development. However, our client is concerned that the number of homes allocated to their site is not based on a robust assessment of the capacity of the site. Moreover, it is unclear what the justification is for no more than 1,300 homes to be built within the Cringleford area prior to 2026. This approach does not appear to be based on any identified constraints in infrastructure capacity that would be resolved post 2026.

BDW believes that it would give greater flexibility to housing delivery across the Greater Norwich area if the uplift in the number of new homes proposed for Cringleford were increased and the arbitrary limit on the delivery the period was not applied. Especially as other allocations where greater infrastructure would be needed to enable housing to be built could suffer delays in the planning and delivery phases.

Given the significant number of new homes that the Greater Norwich Local Plan proposes to deliver our client is concerned that there has been insufficient assessment of the number of new homes that their site could deliver. On the approved development the 650 homes have been successfully planned at a density of 44dph. BDW has applied a similar density to the 11ha of net developable land that remains within site GNLP0327 and the Framework Plan shows that the most effective use of the land would be to accommodate approximately 500 dwellings. However, the proposed uplift in the allocation would result in the phase two site and the adjacent site GNLP0327 delivering the 360 additional homes at a density of approximately 26dph, including all the necessary road and drainage infrastructure, public open space and land to accommodate the primary school site.

The figure of 26dph falls well below the 40dph identified for sites in the Norwich urban area under Policy 2 of the emerging Greater Norwich Local Plan. The Norwich urban area is at the top of the hierarchy of the Councils’ Sustainable Growth Strategy and as such sites within it must maximise their development potential. The approach to increasing densities in sustainable locations is in accordance with the requirements of paragraphs 122 and 123 of the National Planning Policy Framework (NPPF) and has been accepted for other development sites in the Cringleford Neighbourhood Plan area.

In order to demonstrate the capacity of their site BDW has carried out additional work that confirms that any constraints to the delivery of the additional land can be overcome. Therefore, the site is an ideal location for the Greater Norwich Local Plan to focus further growth in order to limit the risk of homes to be allocated through other plan processes not coming forward.

Comment

Representation ID: 22999

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

RESPONSE TO HELAA OUTCOMES

The HELAA identifies that there are no significant constraints to the delivery of our client’s site. Accordingly, a number of the constraints are labelled as ‘green’, whereas others are identified as ‘amber’ in the Stage 2 HELAA Comparison Table. Where a constraint has been identified as amber BDW has provided additional information to demonstrate how the constraint can be successfully mitigated.

Site Access
Whilst the HELAA identifies access as an amber there are alternative ways by which the phase 2 site could be accessed by vehicular traffic. The Framework Plan for the site includes access through the Kier land, off the Round House Way roundabout, and at two locations through phase one. The site would be within 1km of Cringleford Primary School with an access onto Round House Way and connection to Dragonfly Lane. There is likely to be a need for an improved crossing over Round House Way and the HELAA identifies that is could be feasible and viable depending on scale of development.

Access to Services
The HELAA acknowledges that the site is within walking distance of Cringleford and the Norwich Research Park, which is a significant employment area and is well connected by local bus services. Moreover, the wider site will also accommodate a new primary school to meet the needs of the developments in this area. This is in addition to the site being within 1km from the Cringleford Primary School and the Willow Centre once an access is provided onto Round House Way.

Utilities Capacity
The consented development on phase one of the Newfound Farm site, and other developments in the area, will result in enhancements to the capacity of existing utilities serving this part of the village. BDW has carried out initial, high-level assessments of the increases in capacity for utilities and do not consider that there are any abnormal costs that would result in a constraint to the delivery of the phase two site.

The HELAA identifies potential constraints relating to wastewater treatment work capacity and sewer capacity in particular. However, these can easily be resolved through infrastructure improvement works.

If the Councils consider the costs of utilities provision to be a potential constraint then this further reinforces our client’s view that the development potential of the sites needs to be maximised through increasing the density so that any costs of enabling works do not impact negatively on the level of affordable housing that is provided.

Contamination/Ground Stability
When considering the outline application for the phase one scheme conditions were attached to the planning consent to address matters relating to ground contamination. These conditions (nos. 32 and 34) required a scheme to deal with the risks associated with ground contamination and a long-term monitoring and maintenance plan to be submitted for approval in writing by the Local Planning Authority. A Phase 2 Geo-Environmental Assessment Report and a Contamination Monitoring and Maintenance Plan were subsequently submitted under ref. 2016/2695 and were approved on 16th November 2016. In addition to the conditions that required formal discharge before development commenced on site, Condition 35 requires a remediation strategy to be submitted for approval if contamination is found on site.

The above approach to dealing with issues of ground contamination through planning conditions on phase one would also be an acceptable and recognised approach for dealing with any such issues on the phase two land.

Flood Risk
There are no comments from the Lead Local Flood Authority to the HELAA. However, the HELAA identifies that whilst there are bands of surface water flood risk the majority of the site is free from any flood risk. The Environment Agency map for the area shows that the site falls within Flood Zone 1, which means that it is the lowest risk of flooding from watercourses. Notwithstanding this, the bands of surface water identified in the HELAA can be easily mitigated through the planning of the site and the Framework Plan accommodates space for SuDs features to be an integral part of the site’s development.

Significant Landscapes
Cringleford Parish Council object to allocation of the remainder of the site as it is constrained by the southern bypass protection zone and strategic gap between Hethersett and Cringleford. They also raise the issue of the high-tension electricity cables crossing the site on pylons. The Landscape Overview produced by CSA and the Framework Plan demonstrate how residential development with open space and associated infrastructure can be accommodated at the Site without giving rise to any significant landscape or visual effects. Moreover, the Framework Plan demonstrates how the site can successfully accommodate approximately 500 new homes whilst still maintaining the strategic gap between Hethersett and Cringleford. The Framework Plan also turns the constraint of the high-tension electricity cables crossing the site into an opportunity to accommodate public open space beneath the pylons.

As the proposed uplift area includes land within the existing settlement boundary of Cringleford the densification of the remainder of site GNLP0327 will not have a detrimental impact upon any significant landscape or reduce the strategic gap between Hethersett and Cringleford. In fact, the development of the site will ensure that the landscaped area adjacent to the A47 will be maintained in perpetuity for use as a public amenity area for new and existing Cringleford residents. This will help to secure the retention of this part of the strategic gap and maintain a green buffer to the edge of Cringleford.

The site is not covered by any statutory or non-statutory designations for landscape character or quality and the Landscape Overview considers it to be of medium/low landscape quality and value and of medium sensitivity. This Landscape Overview concludes that the Site is generally well contained in views from the surrounding landscape due to the combination of topography, built form and existing vegetation and that views of the site are generally restricted to the near distance. The Framework Plan illustrates how existing vegetation and new planting will form an integral part of the development and will play an important role in minimising any localised visual impacts. The Framework Plan also illustrates how the Site could accommodate residential development at a density of 44dph without materially impacting upon the landscape character of the immediate area.

Transport and Roads
With growth already being successfully accommodated at Cringleford there are improvements to sustainable travel routes that will ensure that future and existing residents’ reliance on the use of the private car will be reduced. This reduction in car dependency will also help reduce the negative impacts that unsustainable modes of travel have on climate change through increased greenhouse gas emissions. Moreover, through the promotion of walking, cycling and public transport residents will experience more positive interactions with each other and other residents of Cringleford and beyond than if they were reliant on private cars to meet their daily needs.

Our client supports the promotion of a greater shift towards non-car modes of travel in the Norwich urban area by focussing high density growth in locations with good access to sustainable transport networks. Cringleford is identified as a fringe parish that as part of the Norwich urban area is a location where higher densities should be promoted to help achieve this shift.

The Framework Plan that has been produced demonstrates how the development of the site will promote walking and cycling. The provision of a green corridor through the site towards the Norfolk and Norwich University Hospital will encourage this as a safe route for pedestrians and cyclists to this major employment site. The Framework Plan also demonstrates the potential for the site to safeguard land for a pedestrian footbridge over the A47.

In addition to the improvements to sustainable travel networks the Travel Plans required for new residential developments in the village will help promote sustainable travel for residents as they move into new homes. All the forms of mitigation, which have been used to mitigate the impacts of the phase one scheme, can be extended to the phase two area to ensure that the impacts upon existing roads are mitigated through the promotion of sustainable modes of travel.

Other matters
The HELAA states that ‘A significant part of the site (around 65%) already has planning consent.’ and considers that potential noise and pollution issues from proximity to the A47 would need to be considered. The additional work supplied with this representation has considered this and identified that there is an additional 11ha of net developable area of 11ha within site GNLP0307 that could be developed.

As already noted earlier, the phase one development produced a successful scheme at 44dph. This is in contrast to the 26dph that would be delivered if the uplift in the number of new homes were restricted to only 360 across the balance of site GNLP0307 and site GNLP0327. The net developable area that we have identified for the phase two of site GNLP0307 would deliver approximately 500 homes if it were developed at a density similar to that approved on phase one.

Whilst there is no evidence of statutory consultees carrying out any detailed assessment of noise or air quality BDW has taken this opportunity to clarify whether either of these matters would be a constraint to the development of the site and considers how they can be successfully mitigated.

Noise
As a result of the noise modelling that was been carried out for the Acoustic Assessment to support the discharge of condition 38 our client is confident that the majority of the new homes within the site will be subject to acceptable noise levels without the need of additional mitigation. To demonstrate this is the case the Technical Note produced by MLM confirms that the dwellings facing the A47 will provide mitigation for those dwellings and gardens behind them. In order to make acceptable living conditions for the dwellings facing the A47 additional mitigation will be required. This mitigation will be achieved either by improving the building envelope of these dwellings or the introduction of a noise barrier and/or bund within the landscaped area near to the A47. These forms of mitigation would be primarily in order to reduce night-time noise levels at first floor bedrooms. To make any bund and/or barrier most effective it would need to be as close to the A47 as possible, which can be achieved within the landscaped area to the southeast of the site. Given that any barrier and/or bund would be located within this landscaped area there is the potential for it to be softened with additional landscaping so that it maintains a rural edge to the village.

The strategy for the consented scheme on phase one also used the dwellings facing the A47 to act as mitigation for the dwellings and garden area behind them. These dwellings then require additional mitigation, which was considered acceptable. Therefore, by using this same approach for the phase two area the dwellings in the consented scheme would be protected from noise without the need for this additional mitigation.

In order to provide acceptable internal noise levels for the dwellings facing the A47 the most likely approach would be upgrading the building envelope and applying a strategy for the glazing and ventilation of these properties. The detailed design of these dwellings would still ensure that their private amenity areas were protected from noise and that the use of habitable rooms were not constrained by the issue of noise.

The use of the landscaped strip immediately adjacent to the A47 as a public space would benefit from the introduction of a noise barrier and/or bund to make it a more acceptable environment for residents’ recreational use. Notwithstanding this, the Framework Plan also includes an area of public open space between the phase one and phase two. This would allow residents to have an alternative public open space to use, where noise levels would be significantly less than those adjacent to the A47 if the noise barrier or bund were not necessary to mitigate noise impacts for the dwellings facing the A47.

The Technical Note produced by MLM demonstrates that noise from the A47 is unlikely to be a significant constraint for the development of the phase two area of site GNLP0327. Moreover, the proposed strategy to mitigating the impact would be the same whether the site was to accommodate a proportion of the proposed 360 uplift or the 500 homes that our client believes it can deliver. If as a result of further detailed noise work the preferred option is to provide a sensitively screened noise barrier and/or bund near to the A47 then this would have cost implications for the development. Therefore, by allocating additional homes on the site, and making the most efficient use of the land, it would also help to limit the impact upon viability of any potential strategies to mitigate the impact of noise.

Air Quality
BDW has instructed MLM to carry out a review of local authority monitoring data and Defra background data, which indicates that the existing concentrations of NO2, PM10 and PM2.5 are ‘well below’ the relevant NAQOs. In future years, air quality is anticipated to improve further due to improvements in vehicle emissions and it is therefore expected that the future air quality at the site would comply with all relevant NAQOs.

The Technical Note on air quality concludes that future residents and users of the phase two site will not be exposed to poor air quality and mitigation measures to reduce air pollution exposure, such as mechanical ventilation, are not considered to be necessary.

Ecology
Whilst not specifically raised as an issue in the HELAA a Preliminary Ecological Appraisal (PEA) of the site has been carried out to identify any potential ecological constraints to the development of the phase two site.

As part of the PEA, a desk study and extended Phase 1 Habitat survey of the site were undertaken in February 2020. As the site predominantly comprises arable fields the greatest ecological interest within the site is found within the hedgerows and a small area of semi-improved grassland between the arable fields. The retention, protection and enhancement of the ecological features is to be prioritised within the development proposals and the Framework Plan demonstrates how this can be achieved.

Primary School Site
The need to safeguard an area of land for a school is acknowledged and applications refs. 2013/1793 2018/1389 already accommodate a 1ha site for a new primary school. The Framework Plan shows a further 1ha to accommodate a logical expansion of the primary school site. Whilst the HELAA identifies that the additional growth planned for Cringleford means that the school site may need to increase in size, with a consequent reduction in the number of additional homes that could be accommodated on the GNLP0327 site, it also acknowledges that an equivalent alternative provision could be agreed with the education authority.

Our client does not believe that any additional land will be required for the expansion of the primary school over and above the 2ha that has been safeguarded. However, if additional capacity were required to accommodate the uplift in numbers on their site then BDW would be willing to have discussions with the education authority to agree how best to deliver the additional capacity.

Comment

Representation ID: 23002

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

CONCLUSION

BDW welcomes the proposal to accommodate further growth at Cringleford and supports the principle of an uplift in numbers for the Newfound Farm allocation. However, they disagree with the high-level assessment that only 35% of the site is suitable for further development or that the uplift numbers should be restricted to 360 homes for both the remainder of site GNLP0327 and site GNLP0327. Moreover, the arbitrary limit on the delivery period for new homes in Cringleford before 2026 has the potential to limit the supply of new homes.

The development of phase two of Newfound Farm has the potential to deliver 500 dwellings at a density that is accepted within the Norwich urban area, of which Cringleford parish is part of. The development of the phase two land would be the only way that a vehicular link from the consented phase one scheme to the roundabout on Round House Way could be achieved. Whilst we don’t believe that this link is essential for the phase two land to come forward, should this link be secured then there would also be the potential to deliver a pedestrian crossing point across Round House Way to further encourage pedestrian and cycle connectivity with the rest of Cringleford.

Our client will be opening two sales outlets under their different brands of Barratt and David Wilson Homes. This will result in an increase in the delivery of new homes on their Cringleford site. There will also be significant cost and time savings by the continuation of development from the consented scheme at the Newfound Farm site. The Councils should only be allocating housing sites where a reasonable prospect of delivery and there are doubts about the delivery strategy that is proposed in the emerging Local Plan, and whether it will deliver the most sustainable form of development. By increasing the proposed uplift in numbers for the Cringleford allocation the Councils will be providing greater certainty over the delivery of new homes compared to other allocations in the Greater Norwich Local Plan, which includes a reliance on allocation through the South Norfolk Village Clusters Housing Site Allocations document.

Draft Policy 2 of the emerging Greater Norwich Local Plan recognises the importance of ensuring the effective use of land in accordance with paragraphs 122 and 123 of the National Planning Policy Framework 2019. This document and the supporting reports and plan demonstrate that any constraints to the densification of the phase two land can be overcome and that it would be the most effective use of the land. The densification of the site would also deliver benefits to Cringleford and the wider Greater Norwich area through the delivery of new homes in this sustainable location, further enhancements to highways and social infrastructure and additional CIL payments to South Norfolk Council and Cringleford Parish Council. Therefore, the Councils need to ensure that the development of land at Cringleford accords with the Sustainable Growth Strategy for the Greater Norwich area by following the accepted approach to densities on the consented phase one development.

To overcome this objection, BDW request that the preferred allocation be amended to reflect the delivery of an additional 500 homes plus land for a primary school on the remainder of the GNLP0307 site that is not covered by the consented scheme.