Publication

A hybrid application is currently being prepared for the delivery of this employment site in accordance with the extant HNF2 policy and emerging policy.

The landowners/promoters fully support carrying forward the allocation and the removal of the restriction in the HNF2 allocation for employment uses benefitting from an airport location to an allocation for unrestricted employment.

The rewording allows for a full range of employment uses and is supported by market interest in plots.

The landowners/promoters maintain their view that the current boundary of the allocation does not properly represent the developable land. Policy HNF2 allowed for land safeguarded (and not subsequently used) for the construction of Broadland Northway (i.e. land to the north of the road) to be incorporated into the allocated area. For the avoidance of doubt, it is considered that the allocation boundary should be extended to the highway boundary to the south to incorporate this land.

This site should be omitted.

Response to GNLP Regulation 19
Submitted on behalf of Diggens Farmhouse

Background

Diggens Farmhouse, Aylsham is located to the east of proposed residential allocation GNLP0596R in the emerging GNLP.

It is noted that six reasonable alternative sites were considered and identified at Stage 5 of the settlement based appraisal of reasonable sites.

In addition to these sites, two further sites are considered to be reasonable alternatives (including GNLP0596) if more growth is required in the towns. It is stated in the appraisal that both sites would need to satisfy highway concerns regarding access and footpaths. Furthermore, a school would need to be delivered on one of the sites.

It is noted that the preferred site is land to the south of Burgh Road, the allocation of which is supported.

This proposed reasonable alternative site (GNLP0596) was not considered at the Regulation 18 stage of the plan making process. Instead, it is proposed at the Regulation 19 stage when representations are meant to be restricted to matters of legal compliance and soundness.

Diggens Farmhouse

Key issues of land use planning concern to the occupiers of Diggens Farmhouse are impact on setting and amenity by virtue of the following:
1. Diggens Farmhouse is a listed building (Grade 2) and, as such, its setting is afforded protection.
2. There is an existing well at the property. There are concerns surrounding surface water management and ability to provide a surface water drainage solution that does not impact on the farmhouse, its surrounds, the existing well and ground water level.
3. Foul water considerations and other utilities matters that may affect the farmhouse or its surrounds.
4. Noise relating to the proposed development.
5. Landscape and visual impacts that could affect the farmhouse setting or amenity.
6. General development layout, height, style and other impacts that may affect the farmhouse or its immediate surrounds.
7. Access to site, noting that two access points would be required to accommodate 250 dwellings.
8. Prospective school, catchment and additional traffic.

• Aylsham Town Council, the residents of the town and the District Councillors were consulted on Regulation 18 when there was one site put forward for Aylsham with 300 homes.
• There has been no consultation with Aylsham Town Council or the residents on the changes regarding the content of the sites section of Regulation 19. There are two sites in Regulation 19 with 550 homes, an increase of 83% on the homes consulted upon in Regulation 18.
• There was no consultation on Regulation 19 with Aylsham Town Council or residents in regard to the infrastructure as it was assumed by the GNLP board that Regulation 18 consultation was sufficient, despite the significant changes in the two plans.
• The GNLP suggested that the feedback for Reg 18 gave ‘confidence to the deliverability of new residential development in Aylsham’. The only supportive responses came from the developers. Therefore, the understanding of the response is inadequate and therefore both not legally compliant and unsound.


Soundness of the Plan and Legal Compliance

This site did not feature in the Regulation 18 consultation. As a consequence, the residents of Diggens Farmhouse, and other residents in the locality were not afforded an opportunity to comment upon its inclusion.

It is not appropriate, or legally compliant, to introduce a further site at this stage without the level of scrutiny afforded to other sites in the plan. To that extent, it is not considered that this element of the plan meets the test of being justified.

Furthermore, it is not clear how the addition of this site, in combination with the other proposed site would impact on existing infrastructure and services and the extent to which improvements would be required. This is more piecemeal than a sustainable approach to future place making, contrary to the objectives of National Policy.

A hybrid application is currently being prepared for the delivery of this employment site in accordance with the extant HNF2 policy and emerging policy.

The landowners/promoters fully support carrying forward the allocation and the removal of the restriction in the HNF2 allocation for employment uses benefitting from an airport location to an allocation for unrestricted employment.

The rewording allows for a full range of employment uses and is supported by market interest in plots.

The landowners/promoters maintain their view that the current boundary of the allocation does not properly represent the developable land. Policy HNF2 allowed for land safeguarded (and not subsequently used) for the construction of Broadland Northway (i.e. land to the north of the road) to be incorporated into the allocated area. For the avoidance of doubt, it is considered that the allocation boundary should be extended to the highway boundary to the south to incorporate this land.

Background
This representation is submitted on behalf of xx in connection with a proposed site at xx.

With reference to paragraph 3.55 of the Regulation 19 Publication Plan, it is noted that there are two site allocations identified in Rackheath for approximately 220 new homes. It is also noted that there are two additional planning permissions for two dwellings on small sites.
Furthermore

Extant Policy GT16 advocates a masterplanned approach to the development of the allocation. A masterplanning exercise was undertaken and endorsed by Broadland Council in 2018.

North Rackheath
Taylor Wimpey fully supports the retention of the Growth Triangle Area Action Plan allocations and the aspirations for growth in this part of the District.
The proposed North Rackheath development is both viable and deliverable and will provide at least 3,000 residential units in the main part of the allocation, with a further 1,000 units in a later phase.
The endorsed Masterplan for the site is currently being refreshed and work has commenced on updating baseline surveys for the necessary assessment work to accompany forthcoming planning applications.
The planning strategy is likely to comprise:
1. An outline application, with means of access for the whole site;
2. An initial infrastructure application to enable the first phase of infrastructure to commence as soon as possible, and
3. A first phase residential development of up t 300 units to run alongside the outline application.
It is anticipated that a request for a formal Screening Opinion, to inform the accompanying Environmental Impact Assessment, will be submitted shortly and the above planning applications will be submitted late 2021/early 2022.

The Plan should be updated to reflect recent planning permissions.

Proposed site GNLP0478 should also be carried forward as an allocation.

It is noted that there are two site allocations identified in Rackheath for housing providing for approx. 220 new homes. There are two additional dwellings with planning permission on small sites. This gives a total deliverable housing commitment for Rackheath of 222 homes between 2018 – 2038 in this plan (not including commitments and allocations carried forward from the Growth triangle Area Action Plan).
It is also noted that further planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath.
The Plan’s supporting text and annotated Settlement Map is not an accurate reflection of proposed development in Rackheath and particularly along Green Lane West.
Further land off Green Lane West (GNLP0478) was put forward for development as a strategic housing site to deliver circa 300 dwellings, consistent in location with other proposals on Green Lane West which have been supported.
The proposal has been designed to reflect its edge of settlement location next to the NDR and would facilitate the delivery of a new Rackheath Country Park (circa 32 ha).
This is considered to be a sustainable and deliverable development that responds well to the delivery of biodiversity and environmental net gain through the promotion of public access.
The Rackheath Booklet identifies the settlement hierarchy and the potential for significant growth in this urban fringe parish.
GNLP 0478 was considered at Stage 1 assessment.
GNLP 0478 was considered at Stage 2 and faired favourably when viewed alongside the other proposed sites, particularly on utilities, market attractiveness, townscape, biodiversity/geodiversity, historic environment and open space and GI.
The Stage 3 consultation responses centred around the need for extra infrastructure. The proposed North Rackheath development is set to deliver essential infrastructure and it would be a missed opportunity if this site on Green West Lane (one of the few areas remaining uncommitted for development) was not brought forward given its low-density proposition and green infrastructure credentials.
Stage 4 of the Rackheath Booklet discusses the site and notes the potential to consider this site in combination with other sites put forward for development on Green Lane West. Some constraints are identified (e.g., noise from the industrial estate and impact on landscape character and Rackheath Hall). There is the potential to adequately mitigate these constraints as evidenced by the GT 16 allocation and recent planning permissions granted for development. The location of the industrial estate or Rackheath Hall is not considered an impediment to future development.
The site was considered on the shortlist of reasonable alternatives (Stage 5) with a reduced number of dwellings (142 and a combination of market and affordable along with 31,78 ha of green infrastructure).
Stage 6 presents the site assessment and raises comments on site constraints, highways, landscape impact and minerals safeguarding.
It is noted that the site received no red flags during its assessment and was comparable to other sites considered in terms of potential constraints. It is considered that an access solution can be engineered, there is sufficient ‘green space’ with the proposed site area to more than adequately address landscape mitigation and most of the land in the locality is underlain by sand and gravel which is not an impediment to development.
Stage 7 of the Assessment deems the site ‘unreasonable’. The ONLY reason it is deemed so relates to site access. In the event that an access can be delivered through an appropriate design, the site would be then at best be deemed a reasonable alternative and should be carried forward as an allocation. It is noted that there is no highways objection per se.
The site sits immediately adjacent to the proposed allocated site (GNLP 0172). Its context is no different to that when viewed against the NDR or wider allocations such as GT 16.
It is considered that the only perceived constraint preventing its allocation as a reasonable site is highways and access, for which an engineered solution is possible.

Proposed site GNLP0478 should be allocated.

It is noted that there are two site allocations identified in Rackheath for housing providing for approx. 220 new homes. There are two additional dwellings with planning permission on small sites. This gives a total deliverable housing commitment for Rackheath of 222 homes between 2018 – 2038 in this plan (not including commitments and allocations carried forward from the Growth triangle Area Action Plan).
It is also noted that further planning permission has now been granted for 322 no. dwellings on land off Green Lane West, Rackheath.
The Plan’s supporting text and annotated Settlement Map is not an accurate reflection of proposed development in Rackheath and particularly along Green Lane West.
Further land off Green Lane West (GNLP0478) was put forward for development as a strategic housing site to deliver circa 300 dwellings, consistent in location with other proposals on Green Lane West which have been supported.
The proposal has been designed to reflect its edge of settlement location next to the NDR and would facilitate the delivery of a new Rackheath Country Park (circa 32 ha).
This is considered to be a sustainable and deliverable development that responds well to the delivery of biodiversity and environmental net gain through the promotion of public access.
The Rackheath Booklet identifies the settlement hierarchy and the potential for significant growth in this urban fringe parish.
GNLP 0478 was considered at Stage 1 assessment.
GNLP 0478 was considered at Stage 2 and faired favourably when viewed alongside the other proposed sites, particularly on utilities, market attractiveness, townscape, biodiversity/geodiversity, historic environment and open space and GI.
The Stage 3 consultation responses centred around the need for extra infrastructure. The proposed North Rackheath development is set to deliver essential infrastructure and it would be a missed opportunity if this site on Green West Lane (one of the few areas remaining uncommitted for development) was not brought forward given its low-density proposition and green infrastructure credentials.
Stage 4 of the Rackheath Booklet discusses the site and notes the potential to consider this site in combination with other sites put forward for development on Green Lane West. Some constraints are identified (e.g., noise from the industrial estate and impact on landscape character and Rackheath Hall). There is the potential to adequately mitigate these constraints as evidenced by the GT 16 allocation and recent planning permissions granted for development. The location of the industrial estate or Rackheath Hall is not considered an impediment to future development.
The site was considered on the shortlist of reasonable alternatives (Stage 5) with a reduced number of dwellings (142 and a combination of market and affordable along with 31,78 ha of green infrastructure).
Stage 6 presents the site assessment and raises comments on site constraints, highways, landscape impact and minerals safeguarding.
It is noted that the site received no red flags during its assessment and was comparable to other sites considered in terms of potential constraints. It is considered that an access solution can be engineered, there is sufficient ‘green space’ with the proposed site area to more than adequately address landscape mitigation and most of the land in the locality is underlain by sand and gravel which is not an impediment to development.
Stage 7 of the Assessment deems the site ‘unreasonable’. The ONLY reason it is deemed so relates to site access. In the event that an access can be delivered through an appropriate design, the site would be then at best be deemed a reasonable alternative and should be carried forward as an allocation. It is noted that there is no highways objection per se.
The site sits immediately adjacent to the proposed allocated site (GNLP 0172). Its context is no different to that when viewed against the NDR or wider allocations such as GT 16.
It is considered that the only perceived constraint preventing its allocation as a reasonable site is highways and access, for which an engineered solution is possible.