GNLP1061

It would therefore put pressure on facilities and amenities and add to already congested roads on Hellesdon

Development will put pressure on the facilities and amenities of Hellesdon and add to the already severe traffic congestion in the area.

This site's proximity to Norwich airport and poor transport links to the wider city make it inappropriate for anything other than employment land. My concern with allocating this land is that it would not be accessible by sustainable transport. I would therefore suggest that any site-specific policy requires a demonstration of how units within this development would be accessible by sustainable transport.

This site's proximity to Norwich airport and poor transport links to the wider city make it inappropriate for anything other than employment land. Our concern with allocating this land is that it would not be accessible by sustainable transport. We would therefore suggest that any site-specific policy requires a demonstration of how units within this development would be accessible by sustainable transport.

GNLP1019
To develop this area, will make the existing road traffic levels and pollution to an unacceptable level. Also the pressure on doctors and schools will be unbearable. GNLP0381, GNLP0500 and GNLP1061.
These developments will also make traffic and pollution levels to an unacceptable levels.

SITE REF: GNLP0289, 0290, 0301, 0302, 0329, 0332, 0333, 0334, 0381, 0419, 0500, 1019, 1020, 1021, 1061.
These areas are not suitable for the proposed buildings because they would put pressure on Hellesdon medical practice and other facilities in Hellesdon.
They would cause traffic problems for the already busy roads of Hellesdon and would be dangerous for vehicles joining the main roads. The loss of habitat for wildlife should also be considered before building on our countryside.

Norwich area sites
GNLP1061 - This site's proximity to Norwich airport and poor transport links to the wider city make it inappropriate for anything other than employment land. Our concern with allocating this land is that it would not be accessible by sustainable transport. We would therefore suggest that any site-specific policy requires a demonstration of how units within this development would be accessible by sustainable transport.
GNLP1011/GNLP0377 - We support Lesley Grahame's proposal to retain this site as a community sports facility, and that it should be protected by a designation that specifies this site as a strategic site for leisure use. Reason: to prevent the over-intensification of residential use in this part of Norwich, and to ensure that the existing sports facility has the land available to it to expand and improve.
GNLP0133 - UEA campus sites:
We have no comment on sites A, B and C.
We feel that some development of site D would be appropriate, but the site-specific policy should be written to restrict development only to that which will not unduly impact upon the character of the river valley, and the setting of the listed UEA campus. Building scales, particularly towards the lake, should be smaller in scale, and should be landscaped appropriately to reduce the impact on the lake's ecosystem and provide biodiversity.
We object to site E being allocated for accommodation or any other intensive development. We feel that the character of the river valley should be maintained, and therefore this site should not be intensified beyond its current level, which includes significant amounts of greenery and the river valley beyond. We believe that the university could make good use of this land without intensifying the use by only building small individual units, of one, perhaps two stories, with plenty of open space between.
We object to the allocation of site F. This should be retained as a strategic gap between Norwich's built up area and the Yare Valley.
GNLP0184 - We object to the allocation of this site for residential development. We feel that any further encroaching on the river valley at this point would threaten the biodiversity and character of the river. We would like this site to be part of the protected river valley and Norwich "Green Belt".
GNLP0360 - We consider the principle of redeveloping this brownfield site to be appropriate, but, due to site constraints, development should not be overly intense. A biodiversity buffer should be provided along the river banks and any development should not hinder this site's ability to serve as a functional flood plain, as well as to replenish water supplies. This site's function from this point of view should be explicitly required within the policy text.
R10 - Utilities Site - We would like to recommend that the conditions within the current site allocation R10 are amended to remove the phrase "including the provision of district wide heating and CHP". We feel that this clause is unnecessarily prescriptive, and practically rules out the possibility of this site being used for larger scale solar power generation, for example.
GNLP0409 - We do not support deallocation of this site, which has clearly been suggested only so that the developers will not have to consider site-specific policy when they want to develop this site. This site should be allocated for residential-led mixed use development. The development should also include office uses, as well as a small amount of retail to support the office and residential uses. The development should also include public spaces, particularly near the river, to enhance the visitor experience. The development should also make provision for sustainable transport measures, including the provision of a bus stop, so that employment uses at this site become more accessible.
GNLP0506 - We consider 1500 dwellings to be too intensive a form of development for this site. However, we do consider that an allocation at this site for mixed-use development along similar lines to that within the NCCAAP is appropriate.
GNLP1010 - We support Lesley Grahame's suggestion of maintaining existing use as community garden.
We feel that many of the existing allocations for employment use in Norwich should be retained for employment use. However, we do feel that a thorough review should be done of these allocations to ensure that these are still the most appropriate uses for these sites, and it may be that several of these sites should be re-allocated for residential or mixed use. The GVA report on Employment Land Assessment identifies a number of sites which may also provide potential for further residential and/or community use through mixed-use development.
Broadland/South Norfolk area sites
Colney:
GNLP0253 and GNLP0158 (land within Yare Valley N of Watton Road) - We consider this land should be part of a Norwich Greenbelt and therefore protected from significant development so that it is retained as protected green space.
GNLP0140 (Rugby club site) - This should be protected green space. Any further status of this site as a development site beyond what has already been granted would be inappropriate for a site which is characterised by being a large open space near to the river. This land also contributes to flood protection of other Norwich sites by acting as a functional floodplain.
Cringleford:
GNLP 0244 and 0461 - We consider that the allocation of these sites for dvelopment would be inappropriate. The existing woodland should be protected, and green space protected by a Greenbelt policy. This also forms part of the strategic gap between Norwich and Cringleford that we feel is necessary for them to be seen as separate settlements.

1. introduction

These representations are submitted by Barton Willmore LLP ("Barton Willmore") on
behalf of Regional and City Airports, in respect of land known as Site 4, Norwich Airport. A site location plan is provided at Appendix 1. These representations are provided in response to the Greater Norwich Local Plan Regulation 18 Consultation (January 2018).The aim of this document is to assist the Greater Norwich Development Partnership (GNDP) in formulating their Local Plan, having particular regard to the provision of suitable employment land. These representations should be read in conjunction with the attached initial Objective Evidence Report (Appendix 2).

2. Site Description

2.1 Site 4 is approximately 46 ha in size and is located to the north-east of Norwich Airport, within its operational boundary. The Site is located approximately 7km north of Norwich city centre. To the east, west and north lie predominantly agricultural land and villages. To the south of the Airport is the Airport Industrial Estate (NAIE) and other commercial land uses.
2.2 The Site is classed as 'brownfield' land. It comprises managed grass, disused taxiway and apron. To the west of the apron, there is a fire training ground, which is proposed to be relocated to another location in the airport. Along the western boundary of the Site there are a number of buildings and structures, comprising Petans Offshore Fire Training and Britannia Fire Limited, which are accessed via Bullock Hill to the north.
2.3 The Site is located within the administrative boundaries of Norwich City Council (NCC) and Broadland District Council (BDC).

Planning History
2.4 In 2013, NCC and BDC granted permission for the following development:
"(1) Full Planning Permission for development of the
Northern Apron to include detailed planning permission to
provide 15,035 sqm of Aviation related B1(c), B2 and B8
floorspace including associated access to Holt Road,
Security Hut, Storage Building, Parking and Landscaping
and
(2) Outline Planning Permission for up to 80,000 sqm of
Aviation related B1(b), B1(c), B2, B8 and D1 use floorspace
with permission for access sought in detail and all other
matters reserved.)"
2.5 The pre-let occupier (Maintenance, Repair, Overhaul, MRO, company, Air Livery) that formed the first phase of the development and which was required to enable the upfront site-wide infrastructure, subsequently pulled out.
2.6 In 2016, permission was amended to change the point of access to the site from the NDR and remove the pre-let detail. A new permission was granted but without an aviation occupier / enabler. The site therefore remains undeveloped.

Vision for the Site
2.7 Regional and City Airports is seeking to provide around 100,000 sqm of high quality general employment floorspace (B1(c), B2, B8, D1 with ancillary, A1-A3 Use Classes) to serve the growing East Anglia economy with direct access from the new NDR.
2.8 The Airport has struggled to attract occupiers to the Site due to an aviation-related occupier restriction which has left it undeveloped and underused.
2.9 A more flexible allocation is sought that would allow general employment uses to come forward, without precluding potential aviation occupiers, that benefit from the NDR and to bring Site 4 back in to economic use. The employment offer would provide a unique opportunity for businesses that wish to be located close to the airport or that benefit from direct access onto the NDR. Whilst there is not considered to be a need for aviation related development on Site 4 given the considerable land available to the south of the runway, it has been determined by Aviation specialist York Aviation (Appendix 2) that a strip of
land to the south of approximately 20% of the total site area should be set aside for
future airport related expansion.
2.10 The flexibility between aviation and non-aviation uses is sought so that it is an
employment destination for occupiers that benefit from:
* Direct access onto the NDR and the wider strategic network; or
* A strategic location suitable for regional distribution that requires a certain size
of plot and building combined with strategic highway access; and/or
* Close proximity to the airport for business convenience / travel requirements;
and /or
* Synergistic clustering (that may or may not be aviation-related) with other
businesses that are on the Site or close by.
2.11 The Site benefits from an outline planning permission which has established the principle for employment development on the site, albeit for aviation-related uses. It has direct access off the NDR, which is due to be fully opened in March 2018, increasing connectivity to the wider Greater Norwich region. The Site is large enough to accommodate strategic B2 and B8 Uses (warehouse and distribution) for which there is a proven demand and a lack of comparable space in the region (Appendix 2).

Further evidence attached