Draft Local Plan-Part 2 Site Allocations
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Draft Local Plan-Part 2 Site Allocations
Representation ID: 20112
Respondent: RJ Baker & Sons
Whilst our clients support the allocation of land at Johnson's Farm for 50 dwellings (GNLP0354), we do have some concerns over the defined boundary and the detailed policy criteria set out in the policy. we have therefore set out a slightly alternative site allocation proposal which also has capacity for approximately 100 dwellings and we would be pleased to discus this idea with the Local Planning Authority.
Our clients own Site GNLP0354 (land at Johnson’s Farm) and we support the allocation of this land for residential development in the draft Plan. The land in question is in single ownership, it is free of physical or other constraints and it is available immediately. It is highly suitable for residential development and it can be delivered within 5 years thus contributing to the local 5-year housing land supply position. Our clients, the freehold owners of this site, are committed to ensuring its timely delivery.
We have a number of comments on the draft allocation and the Policy wording as follows and we would be pleased to discuss these further with the Local Planning Authority as we believe that an enhanced allocation is possible in this location:
In respect of the actual draft allocation for GNLP0354:
• The site area is defined as 2.34 ha and the allocation is for 50 dwellings. On a site of 2.34ha, we would normally expect a higher dwelling figure and it is unclear how the figure of 50 dwellings has been derived. We would expect that figure, typically, to be more like 80 dwellings on a site of this size;
• We note that the western and northern boundaries of the allocated land do not relate to any specific features on the ground (such as field boundaries, watercourses or other physical features);
• As a result, certain residual areas of land, which are currently in arable use, will not be capable of being farmed due to the resulting size and shape. Alternative boundaries could be considered; and
• In particular, the northern boundary of the allocation does not correspond with the northern garden boundaries of the adjacent housing to the east on Preston Avenue.
In respect of the draft wording of Policy GNLP0354:
• We note that the text refers to ‘more homes may be accommodated ….’. We support that statement and it is quite possible, at this stage, through a site planning exercise, to demonstrate that a higher level of development is possible and that the figure of 50 dwellings could be increased;
• We note the reference to ‘submission of a masterplan that does not prevent further development on the remaining field enclosure …’. We understand this point and it clearly recognises that the location in general, and this field in particular, has scope for a higher level of development;
• The above statement raises the question that, if it is recognised that the ‘remaining field enclosure’ has further development potential, then in the interests of good planning, it may be sensible to consider the allocation of that land now to ensure a comprehensive approach and to assist in assimilating development into the landscape at an early stage;
• The draft Plan suggests that access should be via Abbey Road or Preston Avenue subject to amenity impacts on existing residents. We believe that there is a third option which is access via Old London Road to the south – where, under other already permitted development, a new roundabout is to be constructed on the B1172 to serve development at Gunvil Farm, London Road further to the south;
• In order to minimise amenity impacts on existing residents we suggest that other means of access are considered and that access via Abbey Road or Preston Avenue is possibly limited to pedestrians, cyclists and emergency access (if needed);
• We support the idea of appropriate mitigation in relation to features to the north of the site;
• Existing boundary (east side) trees and hedgerows can be incorporated into a development scheme; and
• Considering possible alternative access arrangements and appropriate site layout planning would minimise any amenity impacts on existing dwellings to the east of the site.
In respect of the footnote to Policy GNLP0354, we agree with the comment that ‘development here would not adversely impact on views of Wymondham Abbey’. The Council has been provided with a copy of the applicant’s detailed Heritage Setting Appraisal (Atkins, August 2017) in the past. This assessment demonstrated that, even for a far higher level of development, potential adverse impacts on views of the Abbey can be mitigated and therefore, this area of Wymondham does offer scope to accommodate some of the contingency housing referred to in the draft Plan.
In the light of the above comments, and to comments on the overall strategy, the landowners are also suggesting a possible alternative approach. We have enclosed a conceptual master plan which shows this alternative approach and the main features of which are as follows:
• The site has been enlarged to the established boundaries of the existing field reflecting the longer-term growth referred to in the Policy;
• The capacity of the site is thus estimated to be approximately 100 dwellings of mixed type on a gross site area of 5.73ha;
• Access is via the Old London Road and thence to the approved roundabout (yet to be constructed) on the B1172;
• Access to Preston Avenue is limited to pedestrians and cyclists to protect residential amenity. No access via Abbey Road is proposed;
• Additional footpath access to the south (to Old London Road) is also proposed;
• The site layout and the primary access road, have been designed to afford views of Wymondham Abbey; and
• New public open space has been located so as to also offer views of the Abbey.
This concept is slightly different to that set out in the draft Plan under Policy GNLP0354, and we believe it builds on the attributes of the allocated site but with additional merit as follows:
1. It specifically responds to the Plans’ recognition that the allocated site should make provision for longer term growth within the ’remaining field enclosure’;
2. It retains and incorporates existing boundary features rather than the artificial boundaries of the draft allocation site;
3. It modestly increases the proposed level of housing (although not above the overall 100 dwelling draft allocations for Wymondham) in a Main Town which is earmarked for a contingency of 1,000 dwellings and where the total housing provision is a minimum;
4. It protects the amenity of existing dwellings through its access arrangements;
5. It utilises key views of the Abbey through design and layout; and
6. It incorporates soft western and northern edges to provide suitable buffers to the open countryside to the west and north.
We therefore conclude that this alternative proposal provides an enhanced allocation for residential development at Wymondham and we ask that this is given careful consideration through the local plan process.