Draft Local Plan-Part 2 Site Allocations

Object

Representation ID: 22893

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The Part 1: Strategy document focusses very heavily on the growth of employment in high value, technical sectors. Policy 6 – The Economy states that sufficient land is allocated in accessible locations to meet need. The need arises from background evidence in an Employment Land Assessment, which does not consider the growth or support of low-tech business sectors, which have different needs and values. Policy 6 focusses allocations into strategic employment areas where new buildings are inappropriate and/or out of financial reach for the type of low-tech business attracted to locations such as Park Farm. This is contrary to the Plan’s objective of a broad-based economy, and to the reference in Policy 6 to the appropriate re-use of rural buildings.

We have therefore objected to Policy 6 and associated background documents and aspirations stated in the Plan, on the basis that the policy should include reference to the way that low value or low-tech business needs such as storage will be supported as part of the broad-based economy. Whilst this may well be served through criteria-based policies at the District Level, it is important to note that the lack of an allocation at Park Farm means that it may be difficult to rely on countryside-based policies for future consolidation of the uses, confidence from future occupiers, and confidence in related investment such as the access. Allocating the site in the Part 2 document will acknowledge its contribution to the range of businesses supported by the growth agenda. The plan acknowledges in the “alternative approaches” section of Policy 6 that detailed changes might be justified.

As noted elsewhere in this representation, Policy 6 should therefore include reference in section 2 to low-tech as well as smaller and start-up businesses, with additional or amended bullet points to refer to low-tech and low-value employment in appropriate locations such as Park Farm. On that basis, the formal allocation of Park Farm would be a natural conclusion.

Whilst the Part 2 assessment of the site suggests that there is simply no need for Park Farm to be allocated, as there is sufficient land already allocated, we object on the basis that the other land is high-value and not the right type of development for the type of user that is attracted to such locations as Park Farm.

Highway access is noted as a constraint. Please see the Transport Technical Note submitted with this representation, which includes visibility splays and swept path analysis and shows how accessibility is assured and safe.

Heritage is also noted as a constraint, associated with the setting of the Church of St Wandregelius. However, the site is proposed to utilise existing accesses and existing buildings, such that the setting of the listed church will remain largely unchanged in terms of character, and similar in appearance. Nevertheless, a heritage Statement will be provided in due course to support future stages of the GNLP preparation.

The site is within Flood Zone 1, low risk, for planning purposes and passes the sequential test. However, as it is greater than 1 ha, surface water is to be considered through a Flood Risk Assessment (FRA) as part of any future planning application. The FRA will demonstrate that the proposed development would be safe for the lifetime of the development without increasing flood risk elsewhere, and where possible, that the development will reduce flood risk overall.

The site should therefore be allocated for low-tech B1 development.

Object

Representation ID: 22897

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The two sites were promoted as mixed use development, but have been dismissed on the basis of extending linear development to the north of Poringland. However, we assert that the site represents the rounding-off of built form, given the extensive development on the opposite side of the road. The woodland to the north already sets a natural boundary to further extension of the village in a northwards direction.

The sites are sustainable in terms of location and accessibility by means of transport other than the car. As noted by the GNLP there is already a footway along the road, and the high school is a matter of a few minutes’ walk. There are also bus stops immediately adjacent to the site. The opportunity for small-scale employment would also contribute the sustainability of the settlement, as per the 4.3ha of land intended to be allocated for employment use. The sites were assessed as suitable for further consideration in the HELAA assessment.

The Part 2 assessment states that northern site (GNLP1032), suffers from surface water flood risk, and the southern site may affect the setting of Octagon Barn.

It is intended to provide a framework masterplan in due course to support the allocation of the joint site for mixed use development. This will show how development could be laid out, with particular emphasis on enhancing the setting of Octagon Barn and enhancing the site’s role as a local visitor destination through the appropriate design and siting of the commercial buildings. A supporting heritage statement would provide reassurance as to the ability to develop the site without undue harm to the significance of heritage assets.

Highway access is noted as a constraint. Please see the Transport Technical Note submitted with this representation, which includes visibility splays and swept path analysis and shows how accessibility is assured and safe.

The site is within Flood Zone 1, low risk, for planning purposes and passes the sequential test. However, as it is greater than 1 ha, surface water is to be considered through a Flood Risk Assessment (FRA) as part of any future planning application. The FRA will demonstrate that the proposed development would be safe for the lifetime of the development without increasing flood risk elsewhere, including improving the existing flood risk scenario associated with Octagon Barn.

The site should therefore be allocated mixed use development.

Object

Representation ID: 22898

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The two sites were promoted as mixed use development, but have been dismissed on the basis of extending linear development to the north of Poringland. However, we assert that the site represents the rounding-off of built form, given the extensive development on the opposite side of the road. The woodland to the north already sets a natural boundary to further extension of the village in a northwards direction.

The sites are sustainable in terms of location and accessibility by means of transport other than the car. As noted by the GNLP there is already a footway along the road, and the high school is a matter of a few minutes’ walk. There are also bus stops immediately adjacent to the site. The opportunity for small-scale employment would also contribute the sustainability of the settlement, as per the 4.3ha of land intended to be allocated for employment use. The sites were assessed as suitable for further consideration in the HELAA assessment.

The Part 2 assessment states that northern site (GNLP1032), suffers from surface water flood risk, and the southern site may affect the setting of Octagon Barn.

It is intended to provide a framework masterplan in due course to support the allocation of the joint site for mixed use development. This will show how development could be laid out, with particular emphasis on enhancing the setting of Octagon Barn and enhancing the site’s role as a local visitor destination through the appropriate design and siting of the commercial buildings. A supporting heritage statement would provide reassurance as to the ability to develop the site without undue harm to the significance of heritage assets.

Highway access is noted as a constraint. Please see the Transport Technical Note submitted with this representation, which includes visibility splays and swept path analysis and shows how accessibility is assured and safe.

The site is within Flood Zone 1, low risk, for planning purposes and passes the sequential test. However, as it is greater than 1 ha, surface water is to be considered through a Flood Risk Assessment (FRA) as part of any future planning application. The FRA will demonstrate that the proposed development would be safe for the lifetime of the development without increasing flood risk elsewhere, including improving the existing flood risk scenario associated with Octagon Barn.

The site should therefore be allocated mixed use development.

Comment

Representation ID: 22899

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

The Assessment Booklet considers the proposal for a Park and Ride at this site to be "a reasonable alternative for further consideration." This is welcomed. It is noted in the Assessment Booklet that the need for a new Park and Ride at this site is not yet certain, and will be clarified by the Transport for Norwich strategy which will become the long-term plan for the provision of park and ride facilities in the local area.

The HELAA Addendum has not assessed the Loddon Park and Ride site in detail – however, it does acknowledge that there are no absolute constraints to the site and the site is well-related to the strategic road network.

The current site (GNLP3051) was promoted through the Part 1 Regulation 18 consultation as an alternative to the site identified as TROW2 in the adopted Site Specific Allocations and Policies Documents for South Norfolk Council (2015). However, it is noted that TROW2 is not being carried forward as an allocation for P&R. It would therefore be logical to consider that the current site should now be allocated as a Park and Ride to make up for the loss of TROW2 (to meet existing identified need), rather than remaining as a reasonable alternative.

The Part 2 Local Plan states that the need for the site (GNLP3051) depends on the long-term plan for the provision of park and ride facilities to serve the local area, and the new Transport for Norwich Strategy which is currently under review. It would be prudent to carry out our own transport work to demonstrate the need for a Loddon Park and Ride in advance of the Transport for Norwich Strategy.

Our Park and Ride proposal also fits in with the Local Plan's aims to increase sustainable transport use (including Park and Ride use) to combat climate change, which will necessarily involve developing the role of the wider Park & Ride system around Norwich.

The GNLP Vision states that where journeys are still undertaken by car, this will increasingly be via electric vehicles. This favours our proposal, since it will be possible to incorporate electric vehicle charging infrastructure into the Park and Ride construction, for availability from day one.

The draft GNLP sets out an aim to increase travel via sustainable modes of transport. The allocation of the Loddon Park and Ride site is sound and fits in with the GNLP in terms of sustainable transport. Please see the Transport Technical Note submitted with this representation, which notes that Park and Ride is a cornerstone of Norfolk County Council’s transport policy. The proposed site represents a missing point on the major routes into Norwich, which all otherwise have P&R provision. The Transport Technical Note has reviewed collision data in the vicinity and concludes that there are no inherent highway safety issues associated with the alignment of the local highway network which could be exacerbated by the development proposals.

The Transport Technical Note includes access design proposals, where visibility splays and swept path analysis demonstrate how accessibility is achieved safely and in accordance with current standards.

We anticipate responding further on this matter once the County Council’s P&R review is published.

The site is also suitable in terms of landscape, heritage, drainage and ecology, which will be demonstrated by technical reports covering these matters to be submitted in due course to support the proposed allocation as the GBNLP process continues.

Comment

Representation ID: 22900

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

East Norwich, promoted under Policy 7 anticipates redevelopment of sites very close to WCP for 2,000 homes. Green infrastructure is therefore important in this location, and the 5th bullet points (2nd set) in the policy requires enhanced linkages to the Broads, including pedestrian and cycle links between WCP and the city centre.

We therefore assert that the additional land at WCP should be safeguarded so that it can be called upon to support the additional population arising from new development in the locality. Formally safeguarding the site for leisure and open space purposes through policy will provide confidence in investment within the Park, to support this increasing demand.

Policy 3 – Environmental Protection and Enhancement, refers to the possible establishment of new country parks and additional forms of green infrastructure, but should also refer to opportunities to enhance existing country parks to improve the environment and range of activities and facilities for their users.

The Policies of the Broads Authority referred to are local-level development control policies relating to the existing extent of the Park, so are not adequate to set out strategic level policy for safeguarding the extended area for country park related uses.