GNLP2169

On behalf of Pelham (South Wymondham) Ltd, (hereafter referred to as 'Pelham'), we wish to comment on the additional sites currently being considered as part of the latest Regulation 18 consultation. The representation should be read in conjunction with Pelham's site consultation comments of March 2018 that support the allocation of land within its ownership at South Wymondham (site reference GNLP0515).

Prior to commenting on the new sites, we would remind the authority that our client's site GNLP0515 is situated within a sustainable location close to Wymondham Railway Station with excellent links to the many facilities and amenities within the town.

It benefits from good access to core public transport hubs, the strategic road network, would integrate well with the existing ongoing expansion of the town and would represent a logical and sustainable area for future growth. Furthermore, the existing orientation of the settlement puts the heart of the town centre on the outer southern edge and so expansion immediately to the south of the town centre will place it in the centre of the expanded urban area, strengthening the appeal of the town centre and improving economic conditions as is the objective of a 'main town'.

A phase 1 development of 1230 houses is currently underway at South Wymondham and the proposed Phase 2 adjoining development could deliver a minimum of a further 1,375 more homes.

The land is approximately 78 ha, half of which is proposed for residential led mixed use development. Initial concepts suggest 39 ha could be utilised to deliver a minimum of 1,375 new homes, a new school and associated retail and commercial floorspace, all of which would complement the emerging area of growth and benefit existing residents. The residual 39ha could be retained as open space to enhance the wider green infrastructure network.

The scale of growth that could be provided is very much needed. In this regard, Broadland District Council, Norwich City Council and South Norfolk Council are working together with Norfolk County Council to prepare the Greater Norwich Local Plan (GNLP). Early evidence has been established by the Central Norfolk Strategic Housing Market Assessment (SHMA) 2017, which identified the OAN for Greater Norwich from 2015 to 2036 as 39,486 homes (1,880 per annum).

Given the context and the need for new housing, we provide comments on the associated new housing options for Wymondham below.

Site GNLP 0525R is an extension/enlargement of GNLP 00006 to the northern extent of Wymondham. It is therefore predicated on the assumption that the respective promoters are now advancing the site as a single opportunity.

In general terms we support the scale of growth that is being promoted, which is akin to that being advocated by our client. The 2018 updated Planning Policy Framework (NPPF) is clear (Para 72) that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities.

However, having regard to this latter point, we consider that location at north Wymondham is far less suitable than to the south. Development to the north/north east will inevitably have an adverse impact upon the separation of Wymondham and Herthersett and has the potential for causing the coalescence of the two settlements. Regard must also be had to lack of physical boundaries and the potential for unrestricted urban sprawl to the north. In contrast, expansion to the south is both sustainable and can be restricted to the hard boundary provided by the A11 and so providing an opportunity to prevent growth from sprawling beyond this natural barrier.

From a wider perspective, the existing orientation of the settlement puts the heart of the town centre and key transport hubs on the outer southern edge some distance away from this area in the north. In this regard, paragraph 85 of the NPPF is clear that planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. Promotion of growth to the north would do far less to support the town centre than if it were directed to the south.

Having regard to the above, whilst we support the principle of strategic growth, we consider our client's land represents a better and more sustainable and economically beneficial site option for the growth, with far superior links to public transport.

Site GNLP 2073 at Burnthouse Lane, Silfield is less than 1ha and has the capacity to deliver only circa 5 dwellings.

The scale of development would contribute little to the objective of meeting the compelling housing need for both market and affordable housing. Furthermore, it would be unlikely to offer anything by way of developer contributions to offset the pressure on local infrastructure.

Nevertheless, we do recognise that paragraph 68 of the NPPF provides some support for small and medium sized proposals and that 10% of the housing requirement should be delivered on sites of less than 1ha. A balance is therefore needed.

Notwithstanding the importance of smaller sites, GNLP 2073 is detached from the settlement boundary and rural in nature. It benefits from little by way of safe and accessible linkages. Burnthouse Lane lacks public footpaths and the site is not easily accessible to public transport opportunities. Whilst para 7 of the NPPF seeks to promote sustainable development in rural areas, it is also clear that housing should be located where it will enhance or maintain the vitality of rural communities, which would not be the case in this instance.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Site GNLP 2090 East of Field House is capable of delivering circa 50 units. However, it is detached from the main settlement of Wymondham and would fail to represent a suitable and logical natural expansion of Wymondham.

The site is rural in nature and benefits from poor accessibility. Silfield Street lacks public footpaths and the site is not easily accessible to public transport.

As set out above, para 7 of the NPPF seeks to promote sustainable development in rural areas, it is also clear that housing should be located where it will enhance or maintain the vitality of rural communities.

Given the characteristics of the site this would not enlarge or compliment an established rural community. Furthermore, there are wider heritage and ecological constraints.

Having regard to the above, we consider our client's land represents a more sustainable and economically beneficial site opportunity.

Site GNLP 2125 South of Norwich Common is less than 0.5 ha and has the capacity to deliver only circa 8 dwellings, which even then would be drastically out of character with the prevailing area.

We do, again, recognise that 10% of the housing requirement should be delivered on sites of less than 1ha. Nonetheless, the scale of development would provide little to meeting housing need. Furthermore, it would be unlikely to offer anything by way of developer contributions to offset the pressure on local infrastructure.

The site is also identified as being at risk of surface water flooding.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Site GNLP 2150 appears to be part of 0525R to the northern extent of Wymondham and it is unclear as to whether the site and its potential has been double counted. It is again predicated on the assumption that the larger parcel of land comes forward, as in isolation it would be detached from the settlement boundary.

As set out previously, development to the north of Wymondham is less suitable than to the south. It will inevitably have an adverse impact upon the separation of settlements and there is no hard physical barrier to development in the north.

The existing orientation of the settlement puts the heart of the town centre and key transport hubs on the outer southern edge rather than the north.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.


Site GNLP 2155 is located to the north of Wymondham. It contains the curtilage of Downham Grove House, lies to the west of recently developed housing in the north of Wymondham at Carpenters Close.

As set out above, development to the north is less suitable than to the south and there is no hard physical barrier to properly contain growth and the town centre and key transport hubs on the outer southern edge.

Some areas are at surface water flood risk; and, a pond, along with two wooded areas, that may trigger the need for an ecological assessment.

Having regard to the above, we consider the site appears unsuitable for a number of reasons and our client's land represents a better and more sustainable and economically beneficial site option for growth with far superior links to public transport.

Site GNLP 2157 is located to the south west of Wymondham.

The site is rural in nature and benefits from poor linkages. London Road lacks public footpaths and the site is not easily accessible to public transport opportunities.

It is detached from the settlement boundary and rural in nature. Whilst para 7 of the NPPF seeks to promote sustainable development in rural areas, it is also clear that housing should be located where it will enhance or maintain the vitality of rural communities, which would not be the case in this instance.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Site GNLP 2168 consists of 340 ha and is proposed for a new settlement of some 6,500 dwellings south of the A11.

Parts of the land are of Grade 2 agricultural value; there are wooded areas (some of which is ancient woodland); ponds and habitat on site are likely to require ecological investigation.

There are several options to approach meeting housing need, including proportionate growth, larger urban extensions or even the development of new garden villages. We favour the expansion of settlements like Wymondham given the existing infrastructure that can accommodate the growth. In contrast, the provision of a new garden settlement with its own identity and self-sustaining facilities is extremely challenging, albeit not unachievable.

The supply of large numbers of new homes can often be best achieved through planning for larger scale development. In terms of when garden villages become a suitable approach, the 2016 Locally-Led Garden Villages, Towns and Cities prospectus announced broad Government support for 'garden villages', defined as new settlements of a minimum of 1,500 homes and that must be embedded with the key garden city principles. To be a genuine garden village it must be a holistically planned and designed in such a way that development enhances the natural environment and offers high-quality affordable housing and locally accessible work in beautiful, healthy and sociable communities. Garden village principles are an indivisible and interlocking framework for delivery, and include:
* Community ownership of land and long-term stewardship of assets.
* Mixed-tenure homes and housing types that are genuinely affordable.
* A wide range of local jobs in the Garden City within easy commuting distance of homes.
* Beautifully and imaginatively designed homes with gardens, combining the best of town and country to create healthy communities, and including opportunities to grow food.
* Development that enhances the natural environment, providing a comprehensive green infrastructure network and net biodiversity gains, and that uses zero-carbon and energy-positive technology to ensure climate resilience.
* Strong cultural, recreational and shopping facilities in walkable, vibrant, sociable neighbourhoods.
* Integrated and accessible transport systems, with walking, cycling and public transport designed to be the most attractive forms of local transport.

Whilst it may be possible to meet these criteria, we have concern about whether such a level of masterplanning could be achieved within the emerging plan period. Accordingly, it is essential that further information is published to establish the deliverability and suitability of the site as a garden village location. Should the site come forward for development there would be a requirement for major infrastructure improvements, including a potential new junction from the A11, which would inevitably require use of land within our client's control and therefore early engagement would be needed.

Having regard to the above, we consider that a new settlement in this location may be feasible but is more of a longer term option that would be for subsequent plan periods. Should it be seen favourably, it should be designed in such a way that would not sterilise our client's land nor prohibit the sustainable future expansion of south Wymondham within the A11 boundary.

In summary, our client's land represents a better and more sustainable and economically beneficial site option for growth in line with the current draft strategy.

Site GNLP 2169 is located to the south of Wymondham within the heart of the existing phase1 commitments and as such care is needed to ensure against double counting.

In the event that the land is achievable, it represents a sustainable location for growth, albeit at an extremely limited scale.

Having regard to the above, we consider our client's land represents a better and more sustainable and economically beneficial site option for growth.

Summary
Pelham (South Wymondham) Ltd is promoting land within its ownership at South Wymondham (reference GNLP0515) for sustainable residential led mixed use expansion.

Pelham has previously promoted and is delivering major growth to the west and east of Silfield Road (Phase 1). Our client directly obtained the relevant outline permission for the existing planned growth and the detailed phases of development are subsequently now being delivered on the ground by national housebuilders. Pelham therefore has a good track record of delivery. The land now being proposed amounts to what would logically be considered as a second phase of the development and therefore the ability to properly integrate new development makes site GNLP0515 the ideal location for growth.

The combined effect of the Phase 1 development of 1230 houses currently underway at South Wymondham and the proposed Phase 2 adjoining development of a minimum of 1,375 houses re-balancing the position of the town centre and enabling sustainable growth to be delivered, with significant economic benefits for the town centre.

Phase 2 could deliver a minimum of 1,375 new homes, a new school and associated retail and commercial floorspace, all of which would complement the emerging area of growth. The residual 39ha would be retained as open space to enhance the wider green infrastructure network.

Whilst detailed proposals are yet to be advanced and would be subject to meaningful dialogue with the LPA, the Local Community and key stakeholders, it is clear that the site is wholly suitable for residential development. From an environmental perspective, the land has extremely low landscape value and does not form any formal planning designation such as green belt or area of outstanding natural beauty. Furthermore, there are no overriding environmental constraints that would prevent development.

The site does not lie within or in immediate proximity to any nationally or European designated site such that development of the site would be contrary to the Habitat Regulations or adversely affect the integrity of any designated sites. The closest site of note is the Lower Wood Ashwellthorpe SSSI which is some 3km to the south east and will remain undisturbed.

The predominant land use within the site is agriculture the majority of which is arable in nature. There are no public records of any farming related Environmental Stewardship Schemes in existence within the site which confirms that the actively farmed areas of the site are likely to be of limited ecological value.

Arboriculture investigations will be required. However, we do not envisage tree impact to be an absolute constraint to development. The majority of trees on the site are in groups that can be maintained and incorporated into landscape and open space features. Furthermore, substantially increased levels of planting are likely to be achieved as a result of a comprehensive landscape led approach to the masterplanning process. There are no areas of ancient woodland.

The site falls within an area that does not directly impact the setting of any listed building. Furthermore, given the locality of the land, the relative distance to the nearest listed building and Scheduled Monuments, the archaeological potential of a site is considered to be low. However, the site consists of undeveloped land and therefore there remains some element of risk of an archaeological find and therefore a precautionary approach would be applied.

The site itself comprises a mixture of arable land and a number of perimeter trees. However, overall the site is considered to be of low or limited ecological value and this is not considered to represent a significant risk to its development potential.

Any development could be progressed immediately with approximately 300 new homes being capable for delivery in the immediate first five years of the plan period. The emerging Bovis and Taylor Wimpey scheme on the Phase 1 site delivers a new access link onto Park Lane which would form the principal access to the initial 300 units that can immediately be delivered to the west of Park Lane. A further emergency access could also be achieved adjacent to the Green Land/Park Lane junction but would not be reliant on this for any through traffic.

Subsequent phases will require upgrading of the highway network. The precise nature of the infrastructure upgrades will be subject to detailed discussions with key stakeholders as the plan making process progresses. However, we can confirm that all of the necessary upgrades are either already being delivered through the Phase 1 development or would be delivered through the Phase 2 scheme on land our client controls sufficient to deliver wider upgrades within and around the site if they prove necessary.

In respect of deliverability, the land has no planning history of relevance nor any history of unimplemented permissions and there are no known impediments to the site being phased for early commencement within the 0 -5 year period.

No unexpected financial restrictions are anticipated that would impact upon the viability of the site nor that would prohibit development coming through within the early stages of the plan period. To the contrary, we consider there to be an opportunity to deliver a high quality and exemplar scheme.

The site is in control of a single land owner and there are no legal agreements or covenants that would prohibit the ability to bring the site forward early in the plan period.

Taking all of the above into account and having regard to the new development options currently subject to consultation, we consider our client's site continues to represent the most suitable and economically beneficial location for the immediate and longer term growth and expansion of Wymondham and falls in line with our preferred growth options as set out in our representations of March 2018.

GNLP 2168
On behalf of J. Alston & Sons Ltd, we set out below our further comments on the additional sites submitted for consideration as part of the Regulation 18 Consultation that closed in March 2018.
The new National Planning Policy Framework was published in July 2018, since the Reg 18 process closed. It is considered relevant to refer to ii in the context of site GNLP2168 about which we previously submitted representations. Certain other aspects have also changed or advanced which are described below.
Our comments with regard to site GNLP 2168 reiterate what we believe to be the attributes of the proposal, as follows:-
* It is consistent with increasing central government support for new garden settlements, as set out in a paper published by the Department for Communities and Local Government in March 2016 titled "Locally Led Garden Villages, Towns and Cities".
* This is further expanded upon in the updated NPPF in which there is specific reference to new settlements (the relevant aspects of which are outlined in further detail below).
* It would allow comprehensive maslerplanning to incorporate all required facilities.
* And would avoid the further need for continuing piecemeal development of the suburbs of Norwich and surrounding market towns, locations that have absorbed their fair share of recent growth and where further substantial growth would be unsustainable, unrealistic and would meet increasingly fierce resistance from the local population who will lake the view their locations have accepted more than enough development.
* The site is discrete.
* It is also in single ownership, which removes the potential obstacle to delivery that multiple ownership can create.
* It has a range of natural amenities, including various wooded areas, some of which is ancient woodland, mature trees and watercourses, all of which would complement a major development.
* The proposed development would enable important and much needed infrastructure improvements to be delivered, including a new connection to the south of Wymondham, off the A 11 and the possible extension of Spooner Row station to enable more frequent usage.
* Development to the south of Wymondham would avoid the need for consideration of any further sites to the north/north east that would compromise the integrity of the strategic gap between Wymondham and Hethersett and would also preserve the natural environment around the historic Kells Oak.

The Reg 18 process that concluded in March 2018 outlined 6 options for consultation. Site GNLP 2168 is consistent with:-

* Options 3 & 5 which refer to a new garden settlement.
* Option 2 which highlights the importance of established transport corridors. Site GNLP 2168 is very compliant with this option, being close to the A 11 and within easy walking distance of two railway stations.
* Option 3 which focuses on the increasingly significant Norwich to Cambridge hi-tech corridor (the A 11 and railway line connect Norwich to Cambridge). The profile of Norwich Research Park continues to rise - it was recently given an outstanding achievement award at the Eastern Daily Press Business awards. The importance of NRP as a major driver of economic growth in Norwich will grow and this can be accelerated by forging ever closer links to Cambridge.
* The ready availability of a range of housing types and tenures on the route of the corridor will encourage footloose organisations to consider Norwich Research Park as a viable location at which to move or establish their business.

Further relevant guidance is contained in the revised National Planning Policy Framework published in July 2018 post the closure of the Reg 18 process.

The NPPF defines sustainable development, the principles of which can be embodied in new garden settlements.

The economic objective requires that sufficient land of the right types is available. The scale of a new garden village achieves that objective.

The social objective focuses on the requirement to support strong, vibrant and healthy communities by ensuring a sufficient number and range of houses can be provided to meet the needs of present and future communities. The social objective also refers to a well designed and safe built environment with accessible services and open spaces that support communities health, social and cultural well being.

It is hard to see how the continuing piecemeal development of "bolt on" sites can deliver the overarching principles underpinning this objective of sustainable development. The evidence is that services are not comprehensively delivered through piecemeal development of the type recently experienced in the GNDP area. On the contrary, undue and unsustainable pressure has been exerted on existing services which local communities have found challenging.

However, once again, the scale of a new garden village will ensure the effective delivery of a genuine, vibrant and fully functioning community.

The environmental objective requires the protection and enhancement of the built and natural environments. Again, effective masterplanning of new settlements can deliver high quality public realm and in respect of site GNLP2 l 68, can provide accessibility to a range of existing features including historic woodlands, mature trees and watercourses.

The built environment the NPPF is seeking to encourage could be created as a consequence of the scale of development proposed at site GNLP2168. Best practice in masterplanning, design, sustainability, carbon reduction and minimisation of waste & pollution can be viably incorporated. Piecemeal development which lacks required scale will find it very difficult if not impossible to deliver the environmental objective laid out in the NPPF.

The delivery of these three fundamental objectives is enshrined in the presumption of sustainable development. It is believed our above comments demonstrate the substantial benefits of a new garden settlement on site GNLP2168 in a way that is entirely consistent with the principles underpinning the NPPF. Of more significance is that GNLP2 l 68 satisfies a number of key criteria of the GNDP in planning for future growth. It is difficult to see how an alternative location proposed within the GNLP area could deliver on these key specific objectives.

Paragraph 72 in the NPPF clearly states the "supply of new homes can often be best achieved through planning for larger scale developments, such as new settlements or significant extensions to existing villages & towns provided they are well localed and designed and supported by the necessary infrastructure and facilities".

In our above comments, we have demonstrated compliance with paragraph 72 a) in respect of taking opportunities presented by existing infrastructure, the area's economic potential and the scope for net environmental gains. The size of the development would ensure consistency with 72 b) and 72 c).

Section 8 of the NPPF applies to "Promoting Healthy and safe communities" Such a principle would be at the heart of maslerplanning and design of a new garden settlement on site GNLP2168.

Section 9 applies to sustainable transport. Again, existing infrastructure enables this to be provided at site GNLP2168 but equally, a development at the site could facilitate investment to further improve the existing networks as outlined above.

It is completely accepted by J. Alston & Sons Ltd and Harvey & Co that large settlements such as a new garden village can be challenging to deliver. Justifiable concerns have been raised in this respect and we recognise the essential requirement to provide the necessary confidence of delivery. With this in mind, a short list of prospective partners with the experience, resources and expertise required to deliver the project has been drawn up since the Reg 18 process closed. Negotiations are presently underway with a view to concluding a promotion agreement with the preferred partner in early 2019.

In summary, It Is because of all the points mentioned above that we believe site GNLP 2168 would be suitable to accommodate the long term housing growth of the Norwich Polley Area. There are many aspects of the guidance set out in the recently published NPPF with which new garden settlements In general and site GNLP2168 specifically are consistent.

Furthermore, site GNLP2168 is far more compliant with the options consulted on by the GNLP than other proposed new garden settlements which do not benefit from comparable transport connections, or the strategically important location on the Norwich
-Cambridge hi-tech corridor
And the essential need to give appropriate confidence of delivery is fully understood. Measures have been taken to ensure a reliable and effective delivery mechanism is in place

GNLP2169
The following comments are made on behalf of J. Alston & Sons Ltd in respect of site reference GNLP 2169, about which we submitted representations as part of the Regulation 18 process that closed in March 2018.

The response to our submission is that this site is situated within an area allocated by the last local plan for 1,230 dwellings (Policy WYM3) and would therefore not be suitable for inclusion in the next round of allocated sites.

The current allocation is acknowledged to be correct. However, the site is small, at 1.36 hectares. It is outside the control of the consortium of landowners and their promoter who is responsible for the delivery of the 1 ,230 houses. That number could therefore be delivered on land that excludes site GNLP 2169.

Should this be the case, site GNLP 2169 would remain undeveloped and would not be allocated for further development, even though it would be surrounded by new development.

Provision, therefore, needs to be made for the development of site GNLP 2169 in the event that the 1,230 houses associated within the current local plan are delivered on surrounding land and leave site GNLP 2169 undeveloped.