Object
Publication
Representation ID: 24199
Received: 22/03/2021
Respondent: Barratt David Wilson Homes
Number of people: 2
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Please see attached letter
In summary: The HELAA assessment is factually incorrect and there is no remaining evidence or justification for the non-allocation of Site Ref. GNLP2160. As such, the Pre-Submission Plan has not been positively prepared, is not justified, will not be effective, and is not consistent with national policy.
Please see attached letter
In summary: Site Ref. GNLP2160 should be allocated for approximately 350 homes and supporting uses.
These representations comprise the following:
• Letter dated 22 March 2021 (Savills) (which includes the full representations on all 10 points and should thus be seen as accompanying / attached to all 10 representations)
The following enclosures to this letter (these are being sent by emails 2 and 3 of 3):
o Vision Document (Savills), March 2020
o Highway Capacity Assessment and Public Transport Provision Review for Phase 3 Development (Richard Jackson), 6 December 2018
o Education Report: Land at North Horsford (Phase 3) (EFM), December 2018
o Utilities and Drainage Review (BDW), 29 November 2018
o Ecological Report (TMA), December 2018
o Cultural Heritage Desk-Based Assessment (RPS), March 2020
o Landscape and Visual Appraisal (CSA), February 2020
Object
Publication
Representation ID: 24252
Received: 22/03/2021
Respondent: Samantha / Guy Simpson / Watts
Number of people: 2
Agent: Sequence (UK) Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Sequence has been instructed to act for the Owners of Firbank, Green Lane, Horsford. The property has recently been acquired through probate and therefore no previous representations have been made to the Greater Norwich Local Plan. Firbank is a detached dwelling on a plot of 0.28ha. This includes a separate access to the east to a redundant workshop building to the south of Firbank. Removal of the workshop building would provide a sustainable site for up to 3 new homes. A Site Location Plan is enclosed (drawing reference 2021.03.22.Site.Location.Plan).
Sequence consider that the Draft Sites Plan for Horsford is not 'sound' as the approach is not justified or effective under paragraph 35, parts b&c of the National Planning Policy Framework (NPPF).
Specifically the position of the Settlement Boundary is not considered to be an appropriate strategy taking into account the reasonable alternatives.
The Horsford proposals map demonstrates an inconsistent approach to the inclusion of land within the Settlement Boundary.
Land to the east of Mill Road between Mill Lane to the south and Green Lane to the north benefits from various planning permissions and has been significantly constructed, to the extent that the majority of these properties appear on the base map for Horsford. However the status of this land is not reflected on the Draft Sites Plan, either by reference to a housing commitment, inclusion within the Settlement Boundary, or definition as a Housing Allocation. Sequence would consider that with full planning permission having already been granted, and the majority of houses constructed, an appropriate strategy would be to include this land within the Settlement Boundary. The plan is effectively already out-of-date before it has been submitted for examination and is not an appropriate strategy.
A suggested alternative to the Settlement Boundary is shown on the enclosed plan (drawing reference 2021.02.15.BR0001-1.Horsford.Amended.Settlement.Boundary).
There are a number of examples of inconsistencies throughout the Part 2 Pre-Submission Draft Sites Plan in terms of the treatment of sites with planning permission / under construction and whether they are included within the Settlement Boundary. There are a number of examples of sites under construction that are included within the Settlement Boundary such as the Draft Sites Plans for Hethersett, Poringland and Thorpe St Andrew and given that the Horsford scheme is largely complete, the sound and justified approach is to also include it within the Settlement Boundary as shown on the enclosed drawing.
As a general point, to ensure the plan is sound and based on an appropriate strategy, a consistent approach should be taken throughout the plan both to allocations and sites that have planning permission and/or are under construction. As set out under these representations for Horsford, Sequence would contend that an appropriate strategy is to include all allocations and those sites with planning permission and under construction within the Settlement Boundary. Similar representations have been made by Sequence in this regard with reference to the Draft Sites Plan for Redenhall with Harleston but there are inconsistencies throughout the Part 2 Plans.
Sequence contend that the current inconsistent approach is not an appropriate strategy - it is therefore not justified, nor effective and accordingly is not sound.
Sequence consider that the Settlement Boundary for the Horsford Draft Sites Plan should be redrawn to include the developments that have planning permission and indeed are under construction and largely completed to the east of Holt Road. The revisions will provide a robust and defendable boundary that will endure over the plan period, reflecting the actual extent of the built up area of Horsford marked by Green Lane to the north.
These suggested revisions are shown on the enclosed drawing reference 2021.02.15.BR0001-1.Horsford.Amended.Settlement.Boundary.
This revision will ensure an appropriate strategy and therefore a justified and sound approach. The current approach is not justified, as it is not an appropriate strategy given the inconsistent treatment of both draft allocations and sites with planning permission and under construction with respect to their inclusion within the Settlement Boundary, as detailed further within the response to Question 5 above.
The revisions shown on drawing ref. 2021.02.15.BR0001-1.Horsford.Amended.Settlement.Boundary will deliver an appropriate strategy with respect to the Horsford Draft Sites Plan but similar revisions will need to be made to other Part 2 Draft Sites Plans to ensure the plan is sound overall.
The submissions comprise the following:-
- Response to Part 1 Policy 7.5;
- Response to Part 2, Horsford Sites Plan;
- Site Location Plan; and
- Suggested amendment to the Settlement Boundary for the Horsford Sites Plan – Option 1.
Object
Publication
Representation ID: 24396
Received: 22/03/2021
Respondent: Carl Palmer
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Comments regarding Horsford in relation to sites GNLP0283 and GNLP0283R.
Please see attachment for full representation
Please see attachment for full representation
See attachments for full submission containing information regarding the strategy document and Horsford.
These representations are made in connection with site GNLP0283 and GNLP0283R - land at Holt Road, Horsford on behalf of Mr Carl Palmer.