Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below are specific comments on the consultation on the Interim Sustainability Appraisal. However, more general comments on this are made in connection with our comments on the Site Proposals Consultation Document (Appendix 1) and the Growth Options Consultation document (Appendix 2). Please refer to these appendices for our general comments.
3 The Sites position on the edge of Costessey provides a very sustainable location for new development, and it is available to come forward in the short term. There are strategic and local transport connections, plus easy access to nearby local amenities along with jobs, services, leisure and cultural facilities of the town centre.
4 The Interim Sustainability Appraisal sets out that a delivery buffer of at least 20% should be used to minimise the risks of under delivery. It is noted that this include windfall sites, but given the risks in terms of unpredictability with windfall development it should not be included as part of the delivery buffer. In particular, the Interim Sustainability Appraisal identifies that further research and fact finding is need to confirm the sources of windfall housing, and therefore it cannot be reliable upon at this stage.
5 We would propose an approach that combines all growth options would be most suitable and in accordance with national planning policy. This would recognise the need for development to be within sustainable locations, such as Costessey, whilst also supporting the sustainable and organic growth of rural settlements to prevent stagnation.
6 In light of this, we suggest the Site would be in accordance with all options, and should therefore be considered for future development as part of the next stage of the Local Plan.
7 We support that the Norwich Urban Area includes Costessey and this is identified as the first tier in the settlement hierarchy. This reflects the sustainability benefits of the area, proximity to Norwich and the accessibility to services and facilities. We agree with the growth considerations for this tier and consider that it is appropriate for a significant proportion of future housing allocations.
 
Appendix 1 - Site Proposals Consultation Document
 
Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below respond to the Site Proposals Consultation Document.
The Site Proposals Consultation Document
SITES QUESTION 2 - PLEASE COMMENT ON ANY OF THE SITES ALREADY SUBMITTED
3 As identified in 5.22 of the Site Proposals Consultation Document, Costessey is identified in the JCS as a major growth location. It benefits from facilities in Norwich and residents have access to a wide range of shops, services and leisure facilities, medical centre, and strategic employment area.
Land North of Farmland Road, Costessey (GNLP0238)
4 The Site is actively being promoted by the landowner for residential development. This Site is identified in the Housing and Economic Land Availability Assessment (HELAA) as site reference GNLP0238. We support the conclusion of the HELAA that the site is considered suitable for residential development, and we agree with the Site Proposals Consultation document that the site would be an extension of existing development in New Costessey and is largely unconstrained.
5 The Site is not a "valued landscape" within the meaning of paragraph 9 of the National Planning Policy Framework ("NPPF"). For the purposes of paragraph 47 of the NPPF, the Site is deliverable:
5.1 it is available now;
5.2 offers a suitable location for development now;
5.3 is achievable with a realistic prospect that housing will be delivered on the site within five years and in particular the Site is viable.
6 The Site directly adjoins the built up boundary of Costessey, with the Site boundaries to the south and east being formed by soft landscaping, with residential development beyond. Open fields lie to the west, with the River Tud and a densely vegetated area lying to the north. The Site slopes in a southerly direction towards the north of the Site, from a highest point of 26.5m above sea level down to 18.5m.
7 Immediately to the south of the Site lies a series of residential properties on Farmland Road, which date from the 1980s and comprise 1.5 - 2 storey properties. Farmland Road leads onto Grove Avenue, in turn connecting to Dereham Road and then wider areas of Costessey and beyond.
8 The Sites position on the edge of Costessey provides a very sustainable location for new development, and it is available to come forward in the short term. There are strategic and local transport connections, plus easy access to nearby local amenities along with jobs, services, leisure and cultural facilities of the town centre.
9 It is recognised the Site Proposals Consultation Document considers that the Site ''would be an extension of existing development in Costessey - it would need mitigation to deal with surface water flood issues and avoid harmful impact on the adjacent CWS, but otherwise is largely constrained.''
10 The Site has been subject to two recent applications (application references: 2015/2927 and 2017/0420) and the proposed indicative masterplan demonstrates that a scheme of up to 83 dwellings could be accommodated on the Site, including 27 affordable dwellings, and the creation of areas of public open space, sustainable drainage systems and associated infrastructure. Both applications were supported by all of the relevant and necessary documents, and both applications were reported to committee with planning officer's full support, with a recommendation for approval. Importantly, there were no statutory objections to the applications in respect of matters such as wildlife and ecology; flooding and drainage; design; contamination; landscaping; and highways. Detailed viability work, accepted by the Council, demonstrated that the proposals represent a deliverable development.
Deliverability
11 The Site is being actively promoted by the landowner. As illustrated by the recent planning applications it can be seen that the Site has no significant constraints, is in single ownership and is available to come forward now. It is considered that this should be given considerable weight when assessing this Site for allocation within the GNLP against other potential sites, particularly in Costessey.
Flooding and Surface Water Drainage
12 Details relating to surface water drainage were found to be acceptable as part of the previous applications. This is supported by a Flood Risk Assessment ("FRA"), and it provides details on the surface water drainage strategy for the Site. The proposed built development would be located outside Flood Zones 2 and 3, and the development would not increase flood risk. The FRA confirmed the ground conditions are suitable for infiltration drainage, and will not result in any adverse harm to protected species, the CWS, or the River Tud. This was been agreed with both the Environment Agency and the Lead Local Flood Authority as part of the recent applications.


Highways and Access
13 Access to the Site would be from Farmland Road. The Transport Statement for the Site to support the recent applications confirms that the impact of the proposed development of 83 dwellings on the surrounding highways network, will be negligible. Whilst recognising the steepness of the road, the Highway Authority ("NCC") confirmed that Farmland Road is suitable for this scale of development and that the local highway network is considered to be able to safely cater for the additional traffic generated by the proposed development.
Landscape and Design
14 A Landscape and Visual Impact Assessment (LVIA) has been completed for the Site to support the recent applications which demonstrates that that the level of harm will not be significant and demonstrable on the surrounding landscape and character area.
15 In respect of visual impact, it is considered that the indicative layout responds to the visual assessment, restricting built area to the G1 Easton Fringe Farmland Local Character Area and making strategic provision for planting that will, as it matures, reduce the visual effects further. In the opinion of the officer who professionally considered the proposals, the new visualisations confirm this conclusion.
16 Whilst the Site is currently a field in agricultural use, it abuts existing residential areas and as such the Council's Landscape Architect did not consider that the proposal is detrimental to the overall character of landscape character G1, especially in light of the demonstrated limited long-term visual effect.
17 In relation to the most recent application, the Council's Landscape Architect confirmed that in his professional judgement it cannot be demonstrated that there will be significant and demonstrable harm in either visual or landscape terms for development carried out in accordance with the layout and scheme as presented by the illustrative masterplan.
Ecology & Arboriculture
18 The proposed development of the Site has also been supported by ecological studies. The mitigation and enhancement measures proposed are considered necessary to mitigate any impact on ecology. This has been confirmed acceptable by the County ecologist in response to the recent applications.
Contamination
19 A contamination report was also completed for the Site as part of the recent applications and the Environment Agency, the Lead Local Flood Authority, and Council's Environmental Protection Officer were satisfied that any matters relating to contamination would be dealt with a condition.

Open Space and Green Infrastructure
20 Open space is proposed at the core of the new development. The proposed central green would connect to two internal green corridors which link to the north east and north west of the Site respectively. These internal landscape corridors will also be integrated with the SuDs system to create a distinctive and attractive landscape that links seamlessly with the new perimeter GI corridors and the wider landscape context of the River Tud valley. Provision is also included for a footpath through the CWS, with provision of a ramped footpath.
Other Matters
21 As identified in the HELAA there are no constraints in relation to utilities infrastructure, contamination or ground stability, no loss of open space and no impact on heritage assets.
22 CIL funds raised by the proposed development will contribute towards infrastructure needs in Costessey, including education, and in addition there will be other site specific matters which will be dealt with in S106 obligations.
23 Additional land to the north of the Site has been offered by the applicant to provide an additional area of recreation land, with the provision of two circular walks, and enhancements to the landscape. This formed part of a separate application (ref 2017/0420). It would be accessible to those near the Site and existing users of the CWS. This could provide network of paths both in the CWS and also to the north of the Site along the River Tud.


 
Appendix 2 - Growth Options Consultation Document

 
Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below respond to the Growth Options Consultation Document.
The Growth Options Consultation Document
DRAFT VISION AND OBJECTIVES
1. DO YOU AGREE WITH THE DRAFT VISION AND OBJECTIVES FOR THE PLAN BELOW?
3 We support that the vision includes the delivery of homes, and that this is then reflected in the relevant objectives. However, we would suggest this could be strengthened to ensure it promotes the delivery of housing to meet the identified need.
Delivering jobs, homes and infrastructure
2. DO YOU SUPPORT THE BROAD STRATEGIC APPROACH TO DELIVERING JOBS, HOMES AND INFRASTRUCTURE SET OUT IN PARAGRAPHS 4.1 TO 4.7?
4 We support that 'the strategy will deliver the housing that is needed', and that this will go a long way to support housing growth in all towns and villages with a range of services. It is noted housing figures are discussed in para 4.4 and these are discussed in more detail below.
5 We support the fact that the plan seeks to include additional sites to provide a buffer to maximise the potential to deliver the housing to tackle the housing shortage and to support economic growth.
Housing Need
4. DO YOU AGREE THAT THE OAN FOR 2017-2036 IS AROUND 39,000 HOMES?
6 In paragraph 4.15 it is noted that reference is made to the wrong paragraph of the National Planning Policy Framework ("NPPF") at footnote 18 - it should be paragraph 14. We note that paragraph 47 of the NPPF requires, inter alia, for local planning authorities to boost housing and use their evidence base to ensure that their Local Plans meet the full, objectively assessed needs for market and affordable housing in the housing market area. In short the OAN should be used to identify housing need and, therefore, the number of sites which should be identified for housing to meet that need.
7 The 39,000 homes figure is established using the Government's proposed standardised methodology, which suggests the combined OAN for all of the Greater Norwich authorities is 2,052 homes per annum. The principle of using the Government's standardised methodology figure is welcomed. However we would question whether the proposed OAN is 'sound' in the first instance and we suggest that further clarification is required. In particular, the draft revised NPPF and NPPG have now been published, and it is clear that the need figure generated by the standard method should be considered as the minimum starting point in establishing a need figure for the purposes of the plan production. The OAN figure needs to be subject to careful scrutiny and consultation before it can be used as the basis for decisions on allocations and, indeed, in assessing whether five-year housing land supply requirements are being met.
8 Reference is made in the Growth Options document para 4.17 that the standard methodology can be rebased to the current monitoring year to give an OAN from 2017 to 2036 of 38,988 dwellings. It is not entirely clear why it is considered appropriate by the local planning authorities to rebase the OAN to 2017 given the extent of persistent under delivery in the years that have preceded that against figures in the JCS used to support housing allocations. In any event, the Government figure used is from 2016, which suggests an additional 2,052 dwellings is necessary to account for 2016-2017. Therefore increasing the OAN to 41,040 homes over the plan period as a minimum. Further adjustments may also be required to take account of any updated published affordability ratios or updated household projections. Therefore refinement may result a higher figure which would be the updated starting point in establishing a future need figure for the plan.
5. DO YOU AGREE THAT THE PLAN SHOULD PROVIDE FOR A 10% DELIVERY BUFFER AND ALLOCATE ADDITIONAL SITES FOR AROUND 7,200 HOMES?
9 It is supported that that the plan will seek to over-allocate against whatever the appropriate OAN is to maximise the potential to deliver the housing needed to tackle the housing shortage and to support economic growth. However, further clarification is required on the identified buffer and additional sites for the suggested 7,200 homes.
10 The Growth Options document para 4.16 outlines that the SHMA 2017 identifies that the OAN for Greater Norwich from 2015 to 2036 is 39,486 homes (1,880 per annum) excluding the City Deal Aspirations. Para 4.19 refers to the SHMA calculation of how many homes would be required to support enhanced growth in order to meet the 'City Deal'. It then continues that a 'simple recalculation of the SHMA assessment to rebase to 2017 suggests that around 40,700 dwellings would be needed to support potential jobs growth (forecast growth plus City Deal aspirations)'.
11 In principle, it is supported that the GNLP should allocate sufficient opportunities to support the City Deal and ensure economic growth can be met. This is also recognised by the draft NPPG that 'where additional growth...will occur over the plan period, an appropriate uplift may be applied to produce a higher figure that reflects that anticipated growth'. Figure 96 of the SHMA outlines 44,714 dwellings in response to the City Deal between 2015-2036. The figure in para 4.19 appears to omit the period from 2015-2017, with a shortfall of 4,014 homes and it is not entirely clear why this has been done. It is therefore unclear if this has sought to take into account delivery over these years.
12 The SHMA figures would suggest an additional 3,674 homes would be required to meet the City Deal aspirations, against the potential higher standard methodology figure. As a result the 10% buffer applied to the suggested 39,000 dwellings OAN figure would therefore not be sufficient to meet the City Deal aspirations. Applying the 10% buffer to the suggested 41,040 figure above, raises the plan provision to 45,144 homes which would be slightly above the SHMA City Deal figure. If the SHMA, as published is not sound as an evidence base, the figure could be higher in any event.
13 As such, there is concern that 10% is not sufficient to tackle the housing shortage, as this buffer would only seek to meet the City Deal aspirations. Given the shortfall in housing delivery in previous years it is considered an increased buffer is required to ensure sufficient housing sites are delivered over the plan period and meet the City Deal aspirations.
14 The Interim Sustainability Appraisal sets out that a delivery buffer of at least 20% should be used to minimise the risks of under delivery. It is noted that this include windfall sites, but given the risks in terms of unpredictability with windfall development it should not be included as part of the delivery buffer. In particular, the Interim Sustainability Appraisal identifies that further research and fact finding is need to confirm the sources of windfall housing, and therefore it cannot be reliable upon at this stage.
6. DO YOU AGREE THAT WINDFALL DEVELOPMENT SHOULD BE IN ADDITION TO THE 7,200 HOMES?
15 Yes, we consider that windfall development should be in addition to the 7,200 homes (or any subsequent updated figure). However for the reasons given above it should be in addition to the overall buffer of 20%. We also point out that there does not appear at this stage to have been any detailed analysis of the source of windfall housing. These are, by definition, unallocated sites and although paragraph 4.23 states that windfall development often takes place on small scale unallocated sites or as higher than expected numbers on commitments, there is no evidence to support this assertion. We would add that a number of sites have come forward on unallocated sites because of the inability of the local planning authority to demonstrate five-year housing land supply. We assume that these too will have contributed to windfall.
16 As identified in para 4.23 the actual sites that come forward and the precise scale of delivery is unpredictable and therefore would not provide any certainty in terms of the potential to maximise housing delivery.
8. IS THERE ANY EVIDENCE THAT THE EXISTING HOUSING COMMITMENT WILL NOT BE DELIVERED BY 2036?
17 We do not agree with the approach set out in para 4.40 that 'assumes that existing housing commitments can be delivered'. Given the current lack of five year housing land supply, it is clear the housing commitments are not coming forward as expected, particularly in the NPA. This is no evidence to suggest this would be any different for the existing housing commitments moving forward.
HOUSING GROWTH OPTIONS
9. WHICH ALTERNATIVE OR ALTERNATIVES DO YOU FAVOUR?
18 We would object to adopting any single one of the Options as currently set out. We agree that fringe locations should be supported as a broad location for growth, and in particular that Costessey is included in all Options as part of the western fringe to Norwich.
11. ARE THERE ANY OTHER STRATEGIC GROWTH OPTIONS THAT SHOULD BE CONSIDERED?
19 We would propose an approach that combines all growth options would be most suitable and in accordance with national planning policy. This would recognise the need for development to be within sustainable locations, such as Costessey, whilst also supporting the sustainable and organic growth of rural settlements to prevent stagnation.
20 In light of this, we suggest the Site would be in accordance with all options, and should therefore be considered for future development as part of the next stage of the Local Plan.
GREEN BELT
21 13. DO YOU SUPPORT THE ESTABLISHMENT OF A GREEN BELT? IF YOU DO, WHAT ARE THE RELEVANT "EXCEPTIONAL CIRCUMSTANCES", WHICH AREAS SHOULD BE INCLUDED AND WHICH AREAS SHOULD BE IDENTIFIED FOR GROWTH UP TO AND BEYOND 2036?
22 We do not support the establishment of a Green Belt. We strongly agree with para 4.73 that there is no evidence to meet the 'exceptional circumstances' required by the NPPF to justify the establishment of a Green Belt for Norwich.
Settlement Hierarchy
23. DO YOU AGREE WITH THE APPROACH TO THE TOP THREE TIERS OF THE HIERARCHY?
23 We support that the Norwich Urban Area includes Costessey and this is identified as the first tier in the settlement hierarchy. This reflects the sustainability benefits of the area, proximity to Norwich and the accessibility to services and facilities. We agree with the growth considerations for this tier and consider that it is appropriate for a significant proportion of future housing allocations.
The influence of the Norwich Urban Area
26. DO YOU SUPPORT A NORWICH CENTRED POLICY AREA AND, IF SO, WHY AND ON WHAT BOUNDARIES?
24 It is clear from the review of the SHMA that there is not a clear single HMA that encompasses Broadland, Norwich and South Norfolk boundaries only. Breckland and North Norfolk are within the Functional Housing Market Area. Furthermore, the long established NPA area serves an important purpose to focus development in and around the urban area, and promoting the economic strength of Norwich and its surrounding area. The Core Area in the SHMA is similar to the NPA, and is identified as having the strongest connections to the Norwich Urban Area. There has been no consideration of any implications for the removal of NPA. Therefore it is considered important to retain a Norwich centred policy area to direct growth appropriately.
25 It is not considered appropriate at this early stage to determine the retention of the NPA or a similar area for measuring five-year land supply is unreasonable. The draft revised NPPF and draft revised PPG have only recently published and the final versions once published will need to be taken into account as part of future stages of the GNLP. Further consideration of the new NPPF and NPPG would be required in order to assess the suggested approach in relation to the future of the Norwich centred policy area and the five-year housing land supply.
Shortfall in Housing Land Supply
65. WHICH OPTION DO YOU SUPPORT?
26 Further consideration is required to address any shortfall in housing land supply. Given the current lack of five-year housing land supply (accepted and acknowledged in paragraph 1.4 of the Executive Summary to the latest Annual Monitoring Review), we have suggested the proposed buffer to the overall housing requirement should be increased to ensure sufficient sites come forward. Every effort should be made at this point to identify sufficient and deliverable sites, and to help them come forward. This should identify additional sites for the short term, and also build in potential for reserve sites.
27 The draft NPPF and NPPG include a Housing Delivery Test, and also the requirement to prepare an action plan to reflect challenges and identify actions to address under-delivery against the housing requirement. This should be reflected in the GNLP.