GNLP0420R

Hare Road is not in a fit condition to take further traffic. The road is narrow and has permanent flooding which reduces the road down to one lane. The junction of Hare Road/Church Road has very poor visibility. The development is outside of the development boundary. There is no social, environmental or economical reason for the development. Drainage and absorption are a concern in the area. The area is only serviced by an hourly bus. There are no shops or schools in the village.

Please find attached a completed response form in relation to site reference GNLP0420R – Land at Hare Road, Great Plumstead on behalf of our client, Ingram Homes.

On behalf of our client, Ingram Homes, we submit comments in relation to the Stage C Regulation 18 Draft Strategy and Site Allocations consultation and housing allocations for Great and Little Plumstead. The consultation includes a Site Document that contains details of all the preferred sites for future development and Booklets that explain why certain sites were preferred over others. This representation is in support of the site reference GNLP0420R. Great and Little Plumstead form a village cluster in the emerging Greater Norwich Local Plan and contains services and facilities which include a Primary School, Village Hall and public transport. The Assessment Booklet for Great and Little Plumstead states it is considered that the village cluster could potentially accommodate

development of up to 50 – 60 more dwellings subject to the quality of the sites put forward. The Assessment Booklet shortlists the reasonable alternative sites for further assessment and includes the detailed site assessments, which includes the above site. Our client has an option agreement to purchase the land from the landowner. The Assessment is attached as Appendix 1. The site was originally put forward by the landowner as part of the Call for Sites consultation in 2016 as part of a larger site measuring 10.9 hectares (reference GNLP0420) and was considered within the Housing and Economic Land Availability Assessment (HELAA) 2017, which identifies sites that are available to meet the identified need for housing and employment over the Local Plan period. The Suitability Assessment states the site is well related to services and the character of the village and that constraints relating to access could be overcome through development. The assessment concludes the site is suitable for the purposes of the HELAA capacity assessment. A revision to the site was submitted as part of the Stage A Regulation 18 Consultation in March 2018 to reduce the site to the land adjoining Hare Road which has the potential to accommodate 10 – 15 dwellings and was given the reference GNLP0420R and was considered within the HELAA Addendum (October 2018). The Assessment states a linear (ribbon) development fronting onto Hare Road would broadly repeat the existing pattern of development on the opposite side of the road and landscape impacts are likely to be localised and do not impact significantly on Landscape Character sensitivities. The Assessment concludes whilst the site has some constraints it is considered suitable for the land availability assessment; however, as the site has already been assessed for the purposes of the original HELAA it will not contribute any additional capacity to the HELAA addendum, without double counting, and has therefore been marked as unsuitable. This does not mean that the site in itself is unsuitable for development, merely that it should not be double counted for calculation purposes in relation to the HELAA. This representation considers the Assessment of the site within the current Consultation documents and seeks to address the concerns raised and demonstrate that the site should be considered for allocation as part of the Greater Norwich Local Plan. To demonstrate that satisfactory access can be achieved to serve the development, a Highways Statement has been undertaken by Pritchard Civil Infrastructure Design Ltd and has been submitted in support of this representation.

Planning History An outline planning application is currently under consideration, reference 20191938, for the erection of ten single storey dwellings including access which relates to the majority of the proposed site allocation. As outlined within the applications supporting information, the proposal is considered to represent a sustainable form of development being well related to a designated service village within the adopted Local Plan and adjacent to existing residential development within Great Plumstead. The proposal would provide 7 open market dwellings and 3 affordable dwellings providing a significant economic and social benefits in accordance with the NPPF. The application is in outline form; however, it is considered the indicative layout shows how the site can accommodate development that reflects the prevailing character of development within this part of the village and represents a logical extension of development within Great Plumstead. The site is also available now and there are no financial or environmental reasons why the proposed development cannot be delivered within the next few years and provide a positive contribution to the five year housing land supply as a consequence, bolstering delivery in the very short term. Further, the scheme would provide a policy complaint level of affordable housing which is considered to be a significant benefit in this village location. It is considered for these reasons, highlighted in detail within the supporting planning information, the social, economic and environmental benefits associated with the development of the site outweigh any adverse impacts when assessed against sustainable development criteria as set out in the NPPF. Representation It is our clients view that Site Reference GNLP0420R is a suitable site which has the potential to accommodate 10 – 15 dwellings. The site is deliverable and developable. It is suitable for the proposed residential use and it is available and achievable within the next 5 years, making the site deliverable. The Local Plan covers the timeframe to 2038. Development of the site which is proposed to provide 10 – 15 dwellings is expected to commence in 2020/2021. Our client would propose a scheme of open market and affordable dwellings, in accordance with policy requirements as well as proposing policy compliant contributions towards off-site open space and green infrastructure and other relevant contributions. The site is well related to the Great Plumstead Settlement limit, which lies to the west and south of the application site. The site is located

adjacent to existing residential development to the west which fronts Hare Road and a recently constructed development (constructed by our client, Ingram Homes) to the south which fronts Church Road. The site could accommodate a linear pattern of development which would broadly repeat the existing pattern of development along the western side of Hare Road. The proposal would not extend development along Hare Road further north than the existing development along the western side and therefore would not extend development beyond the edge of the existing built form. It is therefore our clients view the proposal in terms of scale and form fits in with the built surroundings and represents a logical extension to existing development along Hare Road. In terms of vehicular access, a Highways Statement has been undertaken by Pritchard Civil Infrastructure Design Ltd and has been submitted in support of this representation to address the Highway Authority’s concerns and demonstrate that satisfactory access can be achieved to serve the development. Two options for improvement works are outlined within the Statement, which include re-arranging the junction of Hare Road and Middle Road to increase the visibility splay, widening along Hare Road to a minimum of 5.5m and traffic calming/speed reduction measures. Due to the overall reduction in vehicle trips in the area due to the NDR, the accident record and the improvement in visibility that is proposed, it is considered that these improvement works will result in an improvement to the current situation and therefore it is considered either option addresses the highway safety concerns raised. The Highways Authority were contacted for comment on both options; however, they have been unable to respond prior to the consultation deadline. New vehicular access points are proposed along Hare Road to serve the new dwellings and are considered to provide acceptable visibility. The proposed development would also provide sufficient parking facilities and adequate turning areas to allow vehicles to enter and egress the site in a forward gear within the site. It is noted within the HELAA Conclusion that it is stated Hare Road is narrow at only 5.5m wide. The Highways Authority have commented on the application for the development of the site currently under consideration and state Hare Road varies between 4.7 and 5.1 metres wide and should have a minimum of 5.5m in width to satisfactorily cater for any development. These comments contradict each other; however, it is considered the submitted Highways Statement demonstrates that the highway safety concerns can be addressed.

In terms of pedestrian access, the development would propose a footpath along the site frontage to connect to the existing footpath that was developed as part of Phase 1 to the south east of the site. The landowner has confirmed they would collaborate with this arrangement so there are no legal issues in this respect. The proposal would therefore provide a safe and continuous footpath connection between the application site and available services and facilities, including the Primary School for residents. This would be a benefit for all existing residents along Hare Road as currently there is no footpath provision, and this will also benefit the footpath improvements outlined within Community Aspirational Policy 2 of Plumsteads Neighbourhood Plan and is considered to provide a significant economic and social benefit. In terms of public transport, bus stops are located along Church Road to the south east of the site, which are served by a regular bus service linking the site with Norwich and a number of surrounding smaller settlements. These would be accessible from the development via the proposed footpath highlighted above which would connect with existing provision to the south of the site. This, together with the proposed footpath, represents a significant benefit which should be given significant weight. In terms of screening, views into the site are currently restricted by the hedgerow and trees which run along the front of the site. To facilitate the proposed footpath along the site frontage and the access points the majority of the existing roadside hedgerow would need to be removed, with the exception of an Oak Tree. An Arboricultural Impact Assessment and Method Statement has been submitted in support of the application, which is currently under consideration on the site, reference 20191938, states the vegetation to be removed is of low overall value and in poor form and condition. A detailed landscaping scheme would form part of any detailed application and would replace the lost vegetation and would result in an improved landscape in the longer term. Whilst the proposed development of the site would result in the loss of the existing vegetation it is considered the replacement planting, which would be of better form and condition, would make a positive contribution to the appearance of the area. In terms of flood risk, the site is located within Flood Zone 1 and does not lie within an area liable to flooding from other sources. Where possible, SUDs will be used throughout the development to provide an improvement over the current situation by reducing flood risk through the management of run off and on-site water storage. This would be explored and details provided as part of a detailed application. It should be noted that as part of the previous development to the southeast by our client (planning reference 20151517 and 20161151), which is nearing completion, the highway surface water drains were replaced along the entire length of that site within the newly constructed footpath. It was evident that the surface water pipes were inadequate and had become filled with roots and debris over the years. This resulted in frequent flooding of the highway at the lower end near to the junction between Water Lane and Church Road. This problem has been resolved now. The drains were installed so badly and were filled with so much debris they had no chance of working. As part of this proposed new development a new drain would be installed in a similar way along the new footpath. This is of particular relevance to a section of Hare Road which frequently floods in the location of plot 1 and 2 of the new development. The new drains will resolve and deal with this problem. As highlighted above this would be fully explored with details provided as part of any detailed application. In regard to utilities capacity, there are no known connection issues which would prevent the development of the site coming forward. It should be noted Anglian Water have commented on the current outline application under consideration and state ‘the foul drainage from this development is in the catchment of Whitlingham Trowse Water Recycling Centre that will have available capacity for these flows’ and therefore there are no issues with regard to foul water capacity. The NPPF advises that housing applications should be considered in the context of the presumption in favour of sustainable development and sites must be both deliverable and developable. The proposed development is both deliverable and developable for the following reasons: Deliverable According to NPPF guidance to be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable. The site is available now and there are no financial or environmental reasons why the proposed development cannot be delivered within the next five years and it is likely, as set out above, that the development would come forward within a much shorter timeframe and would go some way to meeting the required housing need for dwellings within Great and Little Plumstead.

Developable According to NPPF guidance to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. As set out above, the site is adjacent to existing residential development as well as new dwellings nearing completion and therefore forms a logical development site and extension to development within Great Plumstead. The site is considered to be a suitable location for new housing and its development for housing would bring significant planning benefits to the District. There are no known reasons to prevent a viable development from coming forward at the site. The site represents a suitable site for the development proposed and should be considered favourably as part of the ongoing assessment of sites for housing. The proposal represents organic growth of the village and would provide open market and affordable dwellings for members of the local community. The allocation of the site within the Greater Norwich Local Plan would go some way in meeting the required housing need for dwellings within Great and Little Plumstead. Assessment of Alternative Sites GNLP0328: Land east of Salhouse Road This site has been put forward for approximately 110 – 165 dwellings and measures 5.18 hectares. This site is not considered suitable for residential development due to the required highway improvements that would need to form part of the development at the Brick Kilns junction. The Highways Authority state that either junction realignment or a roundabout would be required. The site is also not well related to the existing services and facilities within Great and Little Plumstead to the south of the site. Other constraints include impact upon the surrounding landscape, flood risk, and loss of grade 1 and 2 agricultural land. The site is therefore not considered a suitable site for residential development. GNLP0330: Land west of Salhouse Road This site is located to the west site of Salhouse Road opposite the above site and has been put forward for 108 – 162 dwellings and measures 4.90 hectares. This also has the same constraints including impact upon the surrounding landscape, flood risk, loss of grade 1 and 2 agricultural land and the fact the site is not well related to the existing development and services and facilities within Great and Little Plumstead to the south of the site. Development of the site would also require significant highway improvements to the Brick Kiln junction. The site is not considered a suitable site for residential development.

GNLP0483: Land east of Salhouse Road This site has been put forward for 86 dwellings with 5.82 hectares of green infrastructure and new play equipment and measures 11.12 hectares. This site is also not considered a suitable site for residential development and it would also require significant highway improvements to the Brick Kiln junction to the north of the site. Further constraints include impact upon the surrounding landscape, loss of high quality agricultural land, and impact upon trees and ecology. The site is therefore not considered a suitable site for residential development. GNLP2040: South of Broad Lane This site has been put forward for residential development (unspecified number) and measures 7.6 hectares. This site is remote from the main development of Great and Little Plumstead and lacks safe pedestrian access to the existing services and facilities. Further constraints include flood risk and landscape impact. The site is not considered suitable for residential development. GNLP3007: East of Salhouse Road, South of Belt Road This site has been put forward for 8 – 10 dwellings and measures 2.05 hectares. Given its location this site would also be required to undertake significant highway improvements to the Brick Kiln junction to the north of the site. Further constraints include impact upon the surrounding landscape and therefore the site is not considered a suitable site for residential development. GNLP3014: Home Farm, Water Lane This site has been put forward for 300 dwellings and measures 14.26 hectares. This represents a significant extension of development to the south of the former Little Plumstead hospital and has the potential to cause significant impact upon the character and surrounding landscape. It is also not clear whether a satisfactory access can be achieved onto Water Lane to serve the proposed allocation. Further constraints include flood risk and loss of Grade 2 agricultural land. The site is not considered suitable for residential development. Summary As set out above the land at Hare Road provides a suitable site for residential development within Great Plumstead, which is deliverable and developable and relates well to the existing defined settlement limit. The site would provide a minimum of 10 dwellings which would go some way in ensuring the housing need in Great and Little Plumstead is met.

It is considered the site is suitable for the residential use proposed and should be considered favourably as part of the ongoing assessment and consideration of housing allocations with Great and Little Plumstead.

For full representation, please refer to the attached document.