Draft Local Plan-Part 2 Site Allocations

This is a greenfield site. It is noted that the assessment of this site in the Housing and Economic Land Availability Assessment concluded that it was unsuitable – HELAA Addendum October 2018 pg. 113 to 114. Therefore, it is not clear why a site that has been assessed as unsuitable is identified as a preferred housing allocation in emerging GNLP. The assessment of the site identifies some potential constraints to development that will need to be assessed, including the impact on heritage assets and landscape. It is likely that the site makes some contribution to the setting of Church of All Saints (Grade I Listed), and this matter should be assessed before a decision is made to allocate it for housing in draft GNLP. The site will contribute towards the landscape setting of the village, and this matter should be assessed in more detail and mitigation measures identified as appropriate. It is noted that Marsham Parish Council did not support housing at this site, on the basis that it was a greenfield site and previously developed sites were available in the village.

It is noted that the assessment of the site in the Sustainability Appraisal identified development at this site as having a ‘minor negative’ impact on landscape and a ‘major negative’ impact on heritage. As set out above, the impact of development on the setting of Church of All Saints should have been assessed before it was decided to identify the site as a preferred allocation. There are other potential development sites in the village which do not affect heritage assets e.g. land at Fengate Farm (Ref. GNLP3035).

Paragraph 146 of the GNLP Draft Strategy document states that the strategy is based on an extensive evidence base. That evidence base includes the Housing and Economic Land Availability Assessment, Site Assessments, and the Sustainability Appraisal and Strategic Environmental Assessment.

Paragraph 35 of the NPPF identifies how soundness will be determined for plan-making. The justified soundness test states: “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;…”. To be justified means that policies and site allocations in emerging GNLP should be based on robust and credible evidence.

It is considered that the findings of the site assessments for some of the preferred allocations and reasonable alternatives are not robust or credible, including those in Marsham. We have reassessed the findings for all of the allocated and reasonable alternative sites in Marsham, and the tables with commentary are attached to these representations.

This site is promoted on behalf of Noble Farms Ltd. It contains vacant and unused buildings and areas of hardstanding associated with a former poultry unit at Fengate Farm. The former poultry use ceased in 2011. The buildings have recently been damaged by fire and are due to be demolished. The site will not be reused as a poultry unit or for any other agricultural use unless the landowner is faced with no option but to reconsider these alternatives. There is an existing access to the site off Fengate and off Old Norwich Road. The main vehicular and pedestrian access to the promoted development would be from Old Norwich Road, and the access from Fengate would be used as a secondary/emergency access.

A planning application for 36 dwellings at the site was submitted in 2013, which was refused and dismissed at appeal (Appeal Ref: APP/K2610/A/14/2223121). The number of dwellings proposed in the application exceeded the limit for service villages that applied at the time. The application was submitted in full, and there was some concern raised about the proposed design and layout. There were no concerns about a vehicular access off Old Norwich Road raised at the appeal. There are no other technical issues that have been identified in the site assessment that would prevent development at the site. A contamination assessment would need to be undertaken because of the previous uses at the site.

The previous application at the site included open space, a playground and allotments, all of which would be a benefit for the village. The existing area of woodland in the southern part of the site would be retained. The existing trees and hedgerows at the site boundary would be retained and enhanced as part of the promoted development. A substantial landscape buffer would be provided at the northern and eastern boundaries of the site. A mix of house types, sizes and tenures would be provided within the promoted development including affordable housing.

This site has been assessed in the Sustainability Appraisal – see Section B.32 of the Sustainability Appraisal (January 2020). The commentary on the findings of the Sustainability Appraisal is attached to these representations. In summary, it is considered that the assessment of the site for the landscape and heritage topics are incorrect.

The site contains vacant buildings and areas of hardstanding, and as such it does not reflect the landscape characteristics of the ‘Marsham and Hainford Wooded Estateland’ LCA. The area of woodland within the site and the trees and hedgerows at the site boundary would be retained as part of the promoted development. The promoted development includes a landscape buffer. Therefore, it is requested that the landscape score for this site should be amended from ‘minor negative’ to ‘minor positive’.

There are listed buildings located on the High Street in Marsham, but the site has no relationship with the setting of these listed buildings, and in any event, it currently contains vacant buildings associated with the previous poultry unit. It has been assessed that development at the site would have a ‘minor negative’ impact on the heritage topic. It is considered that this score must be incorrect since the site does not affect the setting of any heritage assets. It is requested that the heritage score for this site should be amended from ‘minor negative’ to ‘negligible’.

For all of the above reasons, it is requested that land at Fengate Farm in Marsham (Ref. GNLP3035) should be allocated for residential development in emerging GNLP for 35 dwellings.