GNLP0132

On behalf of a consortium of developers formed of Persimmon Homes, Hopkins Homes and Taylor Wimpey (hereafter referred to as 'the Consortium'), we strongly recommend that site GNLP 0132 should be allocated for residential development, comprising approximately 1350 dwellings, with associated open space and infrastructure including a primary school. The site is considered to be entirely developable, and capable of making a significant contribution towards satisfying the Councils' housing needs during the period to 2036, as set out in the accompanying Vision and Delivery Document, which draws on technical evidence prepared in support of this Representation.

In accordance with the National Planning Policy Framework's (NPPF) definition of 'developable', set out in footnote 12 to paragraph 47, the site represents a suitable location for housing development, and there is a reasonable prospect that the site is available and development could begin within 8-12 years. These points are addressed in further detail below, and within the Vision and Delivery Document that accompanies this Representation.

Assessment of Developability

Suitable

The site is located within Sprowston, one of the fringe parishes identified in Policy 9 of the Joint Core Strategy, and is also within the Broadland Growth Triangle, an important location for growth within Greater Norwich. The Joint Core Strategy identifies the Growth Triangle as a key focus for sustainable development, due to its easy access to strategic employment opportunities, particularly at Broadland Business Park and Norwich Airport Industrial Estate, as well as local employment at Rackheath and Salhouse Road, the opportunities it provides for high quality public transport links into Norwich City Centre, and its good relationship to existing services and facilities in the Norwich fringe. It is evident, therefore, that Sprowston is a suitable location for further growth, based on current policy, and that this site can accommodate a significant proportion of the growth planned for Norwich and the fringe parishes in the period to 2036, in 3 of the 6 potential growth options.

Whilst the site is currently detached from the built form of Sprowston, it is immediately adjacent to existing allocations - GT20 to the west, and GT7 to the south. It will ultimately, therefore, be immediately adjacent to residential development to the west and south and consequently represents a logical extension to the planned growth in this area, and would create a clear and defensible boundary to the edge of the urban area of Norwich.

In terms of more detailed site-specific considerations, the Housing and Employment Land Availability Assessment (HELAA) identifies the site as a suitable location for residential development. It confirms through a 'Green' rating, that there are no constraints or impacts anticipated in relation to access, accessibility to services, utilities capacity, utilities infrastructure, market attractiveness, townscapes, historic environment or compatibility with neighbouring uses. Issues which are given an 'Amber' rating, or specifically referred to within the text of the Site Proposals consultation document, which include contamination and ground stability, flood risk, significant landscapes, biodiversity and geodiversity, open space and green infrastructure and transport and roads are addressed in more detail below.

Significant Landscapes
The majority of the site is situated on the Norwich side of the identified landscape buffer within the Growth Triangle Area Action Plan, whose purpose is to provide the landscape setting to the future built edge of Norwich, ensuring separation between the edge of the Norwich urban area and adjacent villages. Only a small parcel of land in the south-eastern corner of the subject site encroaches into the designated landscape buffer; this is an area of Ancient Woodland, known as Bulmer Coppice, which would be retained in its entirety as part of any development, as demonstrated on the indicative Masterplans contained within the Vision and Delivery Document. Development in this location will, therefore, ensure that the important elements of the landscape structure of the area, such as Bulmer Coppice are maintained, and built development will not erode the identified landscape buffer.

The Vision and Delivery Document includes a Visual Assessment and establishes a Zone of Theoretical Visibility. This establishes that the site is visible from a relatively confined area, with views primarily from areas to the west and south. The retention of existing landscape features, together with the proposed additional planting, should result in minimal landscape and visual impacts.

Biodiversity and Geodiversity
Retention and enhancement of the existing landscape framework in and around the site will also assist in ensuring that there are no adverse impacts on biodiversity. Bat Corridors will be retained and/or created, in accordance with the existing Area Action Plan, and existing areas of high quality foraging habitat, such as the eastern boundary and the north-western and northern hedgerows, will be retained and kept suitable for foraging with minimal lighting and screening as necessary. There is scope to provide a substantial area of new, higher quality foraging habitat to mitigate the loss of existing low-quality foraging habitat from the centre of the site. Bulmer Coppice can also be substantially enhanced as a foraging habitat.

The Ecological Appraisal and Strategic Assessment undertaken by Hopkins Ecology in support of this Representation, confirms that Great Crested Newts were not recorded on site, and the closest breeding pond is over 300m to the east. Consequently, the erection of exclusion fencing along the eastern boundary of the site to prevent colonisation once farming ceases, should ensure that the site remains free of Great Crested Newts. Full assessments for a range of species including breeding birds and reptiles will be undertaken in advance of submitting any planning application, and will ensure that any development has no adverse impacts on Protected Species.

The impact of additional numbers of residents and the potential for recreational disturbance to The Broads and its international sites will be managed through the provision of on-site mitigation as an integral part of the development. Provision of on-site greenspace with walking routes that are attractive to local residents, particularly dog walkers, will assist in preventing any increased pressure on The Broads. This approach has been accepted on the first phase of the White House Farm development.

Transport and Roads
Vehicular access to the site would be achieved principally from Salhouse Road, with a secondary access from the adjacent existing spine road, Mallard Way. These accesses would provide safe, effective, vehicular access and egress in accordance with current highway design standards. Work undertaken by Richard Jackson Engineering Consultants in support of this Representation demonstrates that development of the site would not have any severe impact on junctions located to the south-west of the site (towards the city) and traffic can be accommodated on the local road network once the Northern Distributor Road (NDR) is fully operational, which is programmed for Easter 2018.

The site enjoys easy access to the planned Bus Rapid Transit Corridor on Salhouse Road, and it is envisaged that either an existing bus service could be diverted into the site, or a new service provided along Salhouse Road to serve the development. The site will also benefit from connections into the existing cycle route network, which provides access to various destinations in the City Centre, including the Railway Station.

Flood Risk
The HELAA identifies that small sections of the site are at low risk of surface water flooding. A report undertaken by Richard Jackson Engineering Consultants in August 2017, and submitted in support of this Representation, demonstrates that there are minimal risks of existing natural surface water flooding of the site. The Ground Investigations undertaken on the nearby land within Phase 1 of White House Farm have shown that the ground is likely to be suitable for infiltration drainage techniques. There is sufficient space within the site to incorporate all necessary SuDS requirements, and consequently there is negligible risk to the site or others in the local area.

Contamination and Land Stability
The Site Proposals consultation document refers to the need to consider mitigation for nearby filled ground. A Preliminary Geo-Environmental Risk Assessment has been prepared by Delta Simons in support of this Representation. This confirms that there are limited potential sources of contamination, which comprise the agricultural use of the site, potential localised Made Ground deposits and an historic gravel pit and landfill located to the east of the site. There is considered to be a low to moderate risk of soil/groundwater contamination and hazardous ground gas at the site. Any risks can be alleviated through intrusive investigation, and the implementation of suitable mitigation measures as appropriate.

Summary
In conclusion, therefore, it is clear from the above that the site is entirely suitable for residential and associated development. The technical evidence submitted alongside this Representation, together with the Vision and Delivery Document, demonstrates that there are no constraints to the delivery of the site.

Available

The site is currently in agricultural use, and is under option to the White House Farm Developer Consortium of Persimmon Homes, Hopkins Homes and Taylor Wimpey. It is anticipated that it would become available for development in 8-12 years i.e. between 2026 and 2030, following completion of the development of the existing allocation adjacent (GT20).

The Consortium are committed to the delivery of the site, and have a proven track-record of delivering housing in the area. The rate of delivery for the first phase of development at White House Farm has been 150 dwellings per year since 2014 (affordable and market) with all three consortium members delivering a consistent supply.

Viable

Development of the site for residential purposes is considered viable, taking into consideration the various policy requirements in relation to matters such as affordable housing provision and CIL contributions, as well as the provision of strategic landscaping, the potential requirement for a primary school, and infrastructure upgrades/reinforcement.

Further evidence on viability can be provided on a strictly private and confidential basis, should this be deemed necessary at subsequent stages of the process.

Summary

As outlined above, the site is suitable, available and viable, and is therefore developable. Development in this location would represent sustainable development, as defined within the National Planning Policy Framework. Sprowston, as one of the Norwich Fringe Parishes and within the Growth Triangle, is already acknowledged as a highly sustainable location, and a preferred location for growth. The foregoing text demonstrates that this specific site is a suitable location for further development in all respects.

Economically, the site represents the right land in the right place at the right time. Residential development here in the period 2026-2030 and beyond would help support the planned long-term economic growth of the Greater Norwich Area, particularly in the strategic employment locations such as the Norwich Airport area and Broadland Business Park/Broadland Gate. |This would provide high-quality and desirable homes within easy reach of these key employment areas.

Socially, the scale of development envisaged is such that it will enable the creation of a strong, vibrant and healthy community, with easy access to existing and planned local services and facilities, as well as on-site provision of a primary school and extensive Green Infrastructure. A wide mix of dwelling types, sizes and tenures will be provided to meet local needs, and CIL payments will ensure the provision of the necessary health and cultural facilities. The site is located in close proximity to established communities on the north-eastern edge of Norwich, which should assist in achieving social integration between the existing and new residents.

Environmentally, the site is located close to a wide range of employment opportunities, and enjoys excellent access to a range of sustainable transport options providing easy access to the extensive array of facilities and services available within Norwich city centre. Development in this location will assist in further enhancing the sustainable transport options available in the area, including the aspiration to create a Bus Rapid Transport corridor along Salhouse Road. Residents will be able to meet their day-to-day needs easily and without the need to use their car, assisting in reducing pollution and minimising the contribution to climate change.

On this basis, the site should be taken forward as an allocation, and is capable of making a significant contribution to the planned growth of Norwich in the period to 2036.

General comments:
All allocations need to be considered in relation to the Greater Norwich GI Strategy and the emerging Norfolk GI maps, in relation to both opportunities and constraints.
As for previous consultations, our comments on site allocations relate to information that we hold. This relates mainly to impacts on CWS. These comments are in addition to previous pre-consultation comments on potential allocations. However, we are not aware of all impacts on priority habitats and species, or on protected species and further constraints may be present on some proposed allocations. Similarly, we have flagged up impacts on GI corridors where this is related to CWS but there should be an assessment of all proposed allocations against the emerging GI maps for Norfolk, which should consider both locations where allocations may fragment GI and areas within allocations that could enhance GI network. As a result, lack of comment on sites does not necessarily mean that these are supported by NWT and we may object to applications on allocated sites, if biodiversity impacts are shown to be present?

We are aware that the GNLP process will be taking place at the same time as Natural England work on licensing with regard to impacts of development on great-crested newt. This work will include establishment of zones where development is more or less likely to impact on great-crested newt. We advise that this ongoing work is considered as part of the evidence base of the GNLP, if practicable to do so in the time scale.

Broadland
Coltishall:
0265 There is a substantial block of mature trees within this proposed allocation which we understand provides nesting site for common buzzard and is part of wooded ridge. Although not protected under schedule 1 of the Wildlife & Countryside Act, in our view this should be seen as a constraint on development and wooded ridge should be protected.

Drayton
0290: In our view development within the Drayton Woods CWS is not acceptable and this site should not be allocated.
We agree with constraints due to proximity to CWS that are assessed for other proposed allocations in Drayton

Frettenham:
0492 we are pleased to see that impact on CWS is recognised as a major constraint and the need for area within CWS to be recognised as GI, if there is any smaller development outside of CWS

Hevingham:
Adjacent CWS represents a potential constraint as has been recognised.

Honingham:
We note that the presence of CWS and river valley are recognised as constraints, although assessment is that impacts on these areas can be avoided by becoming green space in a larger development. If taken forward, plans would need to include a buffer to all CWS and assessment of biodiversity value of each CWS to establish whether they have particular sensitivity. At this stage, NWT take view that 0415 should not be allocated, even if part of a large development.

Horsford:
0469 and 0251 should be recognised as having CWS or priority habitat constraint. There should be no development on CWS and should be a buffer to CWS.

Postwick:
0571 This would be a new settlement and we are pleased to see that a biodiversity constraint is recognised. However, Witton Run is a key GI corridor linking to Broads National Park. It is essential that impacts on GI corridors, such as Witton Run, are recognised even when not made up of designated sites, if the Greater Norwich GI strategy is to have any value.

Reepham:
1007: This is STW expansion. If expansion is necessary at this STW, there will need to be mitigation and/or compensation with regard to impacts on CWS
1006: There are potential impacts on CWS 1365, which need to be considered

Sprowston:
0132 We are pleased to see that GI constraints and opportunities are recognised. However, need to ensure that allocation allows for protection and enhancement of GI corridor.

Taverham:
0563: Recognition of impact on CWS is recognised but need to ensure no development within CWS, plus buffer to the CWS, if this is taken forward.
0337: Buffer to Marriott's Way CWS needs to be recognised

Thorpe St Andrew:
0228 and 0442: Pleased to see that the impact on CWS 2041 and GI corridor seen as a major constraint and that all sites proposed will have an adverse impact. These sites should not be allocated.

Norwich:
Deal ground 0360: Previous permissions allow for protection and enhancement of Carrow Abbey Marsh CWS. There is great potential for restoration of this CWS as a new nature reserve, associated with the development and a key area of GI linking the city with Whitlingham Park. This aim should be retained in any renewal of the allocation and new permissions

0068: Development should not reach up to riverside but allow for creation of narrow area of natural bankside semi-natural vegetation to link with similar between adjacent river and Playhouse. This will help to deliver the (Norwich) River Wensum Environment Strategy

South Norfolk

Barford:
0416: We are pleased to see that biodiversity constraints are recognised but there is a need to mitigate for impacts on adjacent CWS 2216 though provision of buffer.
1013: There are potential biodiversity constraints, with regard to semi-natural habitats
 
Berghapton:
0210: We are pleased to see that impacts on CWS, existing woodland and protected species seen as major constraint.

Bixley:
1032: There may be biodiversity constraint in relation to habitats on site

Bracon Ash:
New settlement 1055: We are pleased to see that affects CWS and priority habitats are recognised. There is potential for significant additional impact on Ashwellthorpe Wood SSSI. This site is open to the public but is sensitive and not suitable for increased recreational impacts, owing to the wet nature of the soils and the presence of rare plants, which are sensitive to trampling. We are also concerned about increased recreational impacts on of a new settlement on Lizard and Silfield CWS and on Oxford Common. These sites are already under heavy pressure owing to new housing in South Wymondham. Unless impacts can be fully mitigated we are likely to object to this allocation if carried forward to the next stage of consultation.

Broome:
0346: We are pleased to see recognition of constraints relating to adjacent Broome Heath CWS

Caistor
0485: see Poringland

Chedgrave:
1014: There may be biodiversity constraints with regard to adjacent stream habitats

Colney
0253: Constraints relating impacts on existing CWS 235 and impacts on floodplain may be significant and should also be recognised as factors potentially making this allocation unsuitable for the proposed development

Costessey
0238: We are pleased to see constraints in relation to CWS and flood risk are recognised.
0266: We are pleased to see constraints recognised. The value of parts of this porposed allocation as a GI corridor need to be considered.
0489: We are pleased to see that constraints relating to river valley CWS recognised. This site should not be allocated

Cringleford
0461: The whole of 0461 consists of semi-natural habitat, woodland and grazed meadow and should not be allocated for development. In addition adjacent land in the valley bottom is highly likely to be of CWS value and should be considered as such when considering constraints
0244: This site is currently plantation woodland and part of the Yare Valley GI corridor. It should not be allocated, for this reason

Diss:
We support the recognition that constraints regarding to biodiversity need to be addressed. Contributions to GI enhancement should be considered. 1004, 1044 & 1045 may cause recreational impact on CWS 2286 (Frenze Brook) and mitigation will be required.

Hethersett
0177: We are concerned that constraints with regard to impacts on CWS 2132 and 233 are not recognised. These two CWS require continued grazing management in order to retain their value and incorporation as green space within amenity green space is not likely to provide this. Development of the large area of 0177 to the south of the Norwich Road would provide an opportunity for habitat creation and restoration

Marlingford:
0415: We are concerned with the biodiversity impacts of development along Yare Valley and on CWS and habitats on the valley slopes (including CWS in Barford parish). If this area is allocated it should only be as a semi-natural green space that is managed as semi-natural habitat

Poringland:
0485: We are pleased to see recognition of constraints relating to CWS. Any country park development should ensure continued management and protection of

Roydon
0526: There is potential for recreational impacts on Roydon Fen CWS. This impact needs to be considered for all proposed allocations in Roydon and if taken forward mitigation measures may be required. We are also concerned about water quality issues arising from surface water run-off to the Fen from adjacent housing allocations and these allocations should only be taken forward if it is certain that mitigation measures can be put in place. Roydon Fen is a Suffolk Wildlife Trust nature reserve and SWT may make more detailed comments, with regard to impacts.
Although appearing to consist mainly of arable fields this 3-part allocation contains areas of woodland and scrub, which may be home to protected species. These areas should be retained if this area is allocated and so will represent a constraint on housing numbers.

Toft Monks:
0103: We are pleased to see that a TPO constraint recognised and value as grassland habitat associated with trees should be considered.

Woodton
0150: Buffer to CWS could be provided by GI within development if this allocation is taken forward.
1009: Impacts on CWS 94 may require mitigation.

Wymondham:
Current allocations in Wymondham have already led to adverse impacts on CWS around the town, through increased recreational pressure. Although proposals for mitigation are being considered via Wymondham GI group, further development south of town is not possible without significant GI provision. This applies particularly to 0402. Similarly, there is very limited accessible green space to the north of the town and any development will require significant new GI. 0354 to north of town includes CWS 215, which needs to be protected and buffered from development impacts and CWS 205 needs to be protected if 0525 is allocated.