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Object

Publication

Representation ID: 24523

Received: 12/03/2021

Respondent: Welbeck Strategic Land III Ltd

Number of people: 2

Agent: James Bailey Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

GNLP SECTION 1 – INTRODUCTION
2.1 The plan has a serious responsibility which is to determine the pattern and level of development
in the plan area till 2038.
2.2 It is imperative that such a pattern and level of growth is compatible and compliant with the NPPF and therefore the imperative must be on ensuring a sustainable spatial strategy.

Change suggested by respondent:

It is considered that the spatial strategy of the GNLP would be better suited to following a more traditional and sustainable approach to the distribution of growth through the agreed settlement hierarchy.

In the case of South Norfolk, Welbeck Land strongly suggest the site on land north of Tuttles Lane East, Wymondham (GNLP00006), should become an allocated site.

The site on land north of Tuttles Lane East, Wymondham (GNLP00006), has the ability to deliver more suitable and sustainable growth, whilst addressing the identified infrastructure issues and requirements of one of the GNLP's largest settlements.

Please see the full representations made by James Bailey Planning Ltd. on behalf of Welbeck Land in the accompanying document.

Full text:

1. EXECUTIVE SUMMARY

1.1 These representations have been prepared by James Bailey Planning Ltd. on behalf of Welbeck Strategic Land III Limited (Welbeck Land), with input from BasfordPowers, Sterling Transport Consultancy Ltd, Waterman Group, and Cannon Consulting Engineers. James Bailey Planning Ltd. are now instructed to represent Welbeck Land in this matter having inherited the instruction from Bidwells.

1.2 Welbeck Land have substantial interests in Wymondham in which they seek to promote large
scale development on the basis that the land represents a highly sustainable and suitable site for development.

1.3 These representations relate to the Greater Norwich Local Plan (GNLP), Regulation 19 PreSubmission Draft Plan document, February 2021.

1.4 They relate to the two parts of the plan, together with submissions on the legal compliance and soundness of the GNLP, both in terms of how it has been prepared and if it meets the prescribed tests of soundness.

1.5 While these representations consider all aspects of the GNLP, there is a specific focus on Section 5 – The Strategy, and particularly Policy 7 – Strategy for areas of growth. The representations concentrate specifically on the proposed growth for the Main Town of Wymondham.

1.6 In essence, the spatial growth strategy as currently being proposed by the GNLP Reg 19 is seriously questioned.

1.7 There are long standing sites that continue to be allocated that have failed to deliver over a number of years, and there is an unjustified growth being proposed towards ‘Village Clusters’.

1.8 The distribution of housing associated with the approach being taken in the GNLP Reg 19 document does not seem proportional or well considered or compatible with the requirement to promote a sustainable spatial strategy.

1.9 In essence, Welbeck Land consider that rather than solving any problems, this policy change creates additional new ones, notwithstanding the obvious difficulty of trying to judge whether the new “Cluster” allocations will be successful or not, when there is no indication where a significant proportion of them will actually be located.

1.10 Welbeck Land have continued to promote land to the north of Tuttles Lane East in the town of Wymondham (ref: GNLP0006) over a number of years, through the ‘Call for Sites’ requests, and then through previous stages of the emerging Local Plan.

1.11 It is suggested that the previous representations and submissions made to the earlier stages of the emerging GNLP, notably those at Reg. 18(c) stage previously submitted by Bidwells, remain relevant and should therefore still be considered as the document moves forward towards Examination by an Independent Inspector.

1.12 The Wymondham Area Action Plan (WAAP) was adopted by South Norfolk Council in October 2015. It identified a series of sites for the growth of housing, employment, and infrastructure. Delivery of some of the allocated housing sites remains a problem.

1.13 In March 2020, Wymondham Town Council submitted a Neighbourhood Area application,
designating the whole civil parish, which South Norfolk Council has confirmed. Progress on the Neighbourhood Plan remains unclear at the time of preparing these representations.

1.14 In summary, it is considered there is insufficient growth being proposed by the GNLP for Wymondham during the plan Period up to 2038. As an identified ‘Main Town’, there is also a weight of expectation that an appropriate level of growth will be ascribed to Wymondham, which has failed to materialise through the GNLP Reg 19 document.

1.15 It is believed that there are also mixed messages coming from the GNLP process. During the Reg 18(c) stage, Wymondham had a contingency identified for 1,000 new homes, however this has now been removed at the current Reg 19 stage. Conversely, Costessey (without comparable linkages or connections to Wymondham) had a contingency site identified at Reg 18(c) stage, which has carried through to an 800-unit contingency site in the Reg 19 document. This approach appears wholly unjustified and inconsistent.

1.16 There is also a large reliance on existing strategic sites being retained as allocations within the latest GNLP Reg 19 document, which have failed to be delivered over a number of years, such as the site at North Rackheath. This casts serious doubt not only of the delivery of these sites, but on the growth over the plan period. If allocated sites are not brought forward, then it will not be long before ‘hostile applications’ are made.

1.17 What is clear is that GNLP Reg 19 document appears to place an overreliance on delivery coming
forward through ‘windfall sites’, with a significantly disproportionate amount of housing growth being directed to the ‘Village Clusters’.

1.18 However, the South Norfolk Village Clusters Housing Site Allocations Local Plan is yet to be produced. Therefore, it is surely unjustified to place a reliance on a document that itself has yet to be tested.

1.19 The impact of Covid-19, and the knock-on effect of change in people’s habits, such as working arrangements and commuting patterns, is also considered within these representations. It is suggested that the current global pandemic is likely to have an impact on future housing growth, which the GNLP still has time to properly consider.

1.20 It is therefore believed that, although being positively prepared, the approach being taken to the spatial growth strategy across the Greater Norwich area is fundamentally flawed, and on this basis is therefore ‘unsound’ as it is neither justified nor effective.

1.21 To modify part of this deficiency, Welbeck Lane request that the land north of Tuttles Lane East, previously identified as a “reasonable alternative” in the Reg 18(c) document, be recognised as a formal allocation at Wymondham for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wymondham High School.

1.22 It is considered that identifying sites, such as land north of Tuttles Lane East at Wymondham, will help to provide a robust and proper planning approach to spatial growth. Allocating sites that prove their suitability; availability; and deliverability, in the most sustainable locations, will also enable the necessary infrastructure to be properly costed, programmed, and implemented.

1.23 In summary, the GNLP:-
• Over relies on long standing strategic site proposals, despite the knowledge from past history that some of them are unlikely to come to fruition within the Plan period;
• Introduces a change in policy direction to significantly increase reliance on development of small Village Cluster sites;
• Reduces the clear benefit to be gained from developing sustainable and available Main Town sites;
• Actually reduces proposals for certain Main Towns despite there being a clear expectation of new development;
• Is inconsistent in proposing certain Main Town sites to the detriment of other clearly more sustainable Main Town sites; and
• Proposes a spatial growth strategy that is fatally flawed, and therefore “unsound”.

1.24 Welbeck Land asks the Inspector to propose allocation of land to the north of Tuttles Lane
East for up to 700 new dwellings, a care home, a local centre and a sixth form centre to serve Wyndham High School. This action would go a long way to clarifying the clear deficiencies of the Plan as currently proposed and could easily be achieved without any need to delete other
current proposals.

1.25 The latest version of the Illustrative Masterplan for the site has been included as Appendix One.

1.26 A draft Statement of Common Ground has also been prepared to accompany these
representations and is attached as Appendix Two.

1.27 A Transport Working Note has been prepared to support these representations and is included
as Appendix Three.

THE NEXT SECTION OF THIS SUBMISSION IS SET OUT IN CHRONOLOGICAL ORDER AGAINST
THE GREATER NORWICH LOCAL PLAN (GNLP) REGULATION 19 PRE-SUBMISSION DRAFT PLAN
DOCUMENT FEBRUARY 2021.

See full representation attached.

Attachments:

Full Representation (9.62 MB)

Object

Publication

Representation ID: 24524

Received: 12/03/2021

Respondent: Welbeck Strategic Land III Ltd

Number of people: 2

Agent: James Bailey Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Education and Social Mobility
3.11 It is noted that the GNLP will need to make provision for additional schools and school places
to serve future growth. This approach is supported by Welbeck Land.

Please see full representation attached

Change suggested by respondent:

Full text:

Attachments:

Full Representation (9.62 MB)

Object

Publication

Main Towns Assessment Booklets

Representation ID: 24525

Received: 12/03/2021

Respondent: Welbeck Strategic Land III Ltd

Number of people: 2

Agent: James Bailey Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

6.1 The Wymondham Assessment Booklet documents all of the comments collected from the Reg 18(c) public consultation period. To accompany this, there were also detailed site assessments carried out of the ‘reasonable alternative’ sites for Wymondham.

6.2 Of particular interest to these representations is site GNLP0006 Land to the north of Tuttles Lane east, Wymondham. The site was deemed to be a ‘reasonable alternative’, despite being found to be both suitable and viable. The site was also described as being within easy access of a range of services, and therefore should be considered sustainable.

6.3 Additionally, sites should be considered highly acceptable if they were part of a comprehensive
approach to the development of the area, which then help to deliver strategic infrastructure. As part of the Cambridge-Norwich Tech Corridor and key growth area, it would be rightly assumed that GNLP0006 would be a key site that would sustainably contribute to the expansion
and allocated growth for Wymondham.

6.4 It is further noted within the Reg 18(c) Site Assessment Booklet for Wymondham page 35, that
there is an identified total deliverable housing commitment for Wymondham of between 2,563
and 3,563 homes between 2018- 2038. These previous figures include for an additional 1,000 homes on GNLP0006, as a reasonable alternative site. A contingency figure of 1,000 units was therefore identified for Wymondham, although no sites were identified.

6.5 The question therefore must be what has changed in Wymondham since the GNLP Reg 18(c) document? Why has the contingency of 1,000 units no longer being included? And what formal planning process was used to support and sustain the decision to dismiss the reasonable alternative sites?

6.6 It will be interesting to understand how these decisions have been reached, when considered
against the infrastructure requirements in the key growth areas, that will aid the provision of creating sustainable communities. For example, Norfolk County Council have made it clear that there is considerable pressure at Wymondham for secondary pupil places, which would not be able to cope with further growth without new school provision.

6.7 Welbeck Land have held discussions with Norfolk County Council Education and Wymondham
High School. GNLP0006 can successfully provide and implement the relocation and enhancement of the Secondary School and Sixth Form Education Facility. This invaluable infrastructure provision could cater for the required growth within Wymondham, which would
aid successful growth within the Key Growth Areas, as identified within Policy 1 of the GNLP.

6.8 It is noted that HELAA allocated site (GNLP3013) sits well within the settlement form. However, it is suggested that the site would start to protrude out into the countryside, if brought forward in isolation as per the current allocation in Reg 19. It would sit far better by being carefullyconsidered and brought forward as part of a wider sustainable expansion for Wymondham.

6.9 Welbeck Land do not agree with the absence of “reasonable alternative sites” for Wymondham,
and especially the reluctance of the GNLP to provide reserve sites for further additional growth towards the end of the plan period. Development at Norwich and along the Tech Corridor will create an increasingly strong and economically attractive region, thereby driving the availability of funding as per Policy 1 for new infrastructure that caters for further strategic development.

See attachment for full representation particularly section 6 - Greater Norwich Local Plan Evidence Base

Change suggested by respondent:

Full text:

Attachments:

Full Representation (9.62 MB)

Object

Publication

Strategic Flood Risk Assessment (SFRA) Level 2

Representation ID: 24526

Received: 12/03/2021

Respondent: Welbeck Strategic Land III Ltd

Number of people: 2

Agent: James Bailey Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Flooding and Drainage

6.14 Cannon Consulting Engineers have considered the evidence base provided to support the GNLP Reg 19 document, in relation to the site on land north of Tuttles Lane East, Wymondham. This includes the Strategic Flood Risk Assessment (SFRA) that accompanies the Reg 19 document.

6.15 When discussing the sites at Wymondham, the SFRA refers to identifying areas for flood management measures to help reduce flows into the River Tiffey. Welbeck Land’s site on land north of Tuttles Lane East is very well location to help reduce the rate of runoff being discharged into the Tiffey.

6.16 Anglian Water sewer plans and online mapping show that the adopted surface water sewers serving an area to the south of Tuttles Lane discharge to the watercourse which flows (westwards) through the north-east section of the site. Due to this, the site is well placed to provide some attenuation of stormwater flows from part of the urban catchment of Wymondham.

6.17 The inclusion of a flood alleviation basin or basins along the northern bank of the watercourse will make space for water being discharged from Wymondham. Combined with the potential diversion of the watercourse through the area (to create a sinuous channel), the alleviation basin also offers the opportunity to treat the runoff from Wymondham as well as ecological
benefits associated within the channel and its banks.

6.18 Providing such attenuation accords with the suggestion in section 6.3.1.2 of the Greater
Norwich Level 2 Strategic Flood Risk Assessment (SFRA) that development sites should include
additional water, and that Local Planning Authority (LPA), Environment Agency (EA), and Lead Local Flood Authority (LLFA) should work together to identify areas for providing flood alleviation features.

6.19 It is noted that the sub-heading of section 6.3.1.2 is “Tiffey Upstream of Wymondham” whereas
the land north of Tuttles Lane East, lies downstream of Wymondham. However, as the SFRA discusses the aspiration for flood alleviation measures is in the context of the wider Tiffey catchment, (which is upstream of Norwich).

6.20 As the proposed (developer funded) flood alleviation feature will help attenuate runoff generated from Wymondham before it reaches the River Tiffey, developing land north of Tuttles Lane East will therefore provide off-site benefits in line within the GNLP evidence base.

See attachment for full representation, particularly section 6 - Greater Norwich Local Plan Evidence Base

Change suggested by respondent:

Full text:

Attachments:

Full Representation (9.62 MB)

Object

Publication

Viability Study

Representation ID: 24527

Received: 12/03/2021

Respondent: Welbeck Strategic Land III Ltd

Number of people: 2

Agent: James Bailey Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Viability Appraisal

6.21 It is noted that further viability work has been undertaken as part of the evidence base to support the GNLP Reg 19 document.

6.22 Turner Morum LLP previously provided Welbeck Land with an assessment of the “Interim Viability Study” prepared by NPS group (November 2019) as part of the evidence base to support the Reg 18(c) GNLP document. It is noted that a further “Viability Appraisal” was
carried out by NPS group (December 2020) to support the Reg 19 GNLP document.

6.23 However, there appears to have been limited changes made between the Interim Viability Study
(Nov 19) and the Viability Study (Dec 20), so on this basis the majority of the points previously raised by Turner Morum LLP still remain relevant, and unaddressed.

6.24 Whilst there is general support for the approach being adopted, there remains concerns regarding the assumptions being made within the Viability Appraisal. It is still suggested that the sales values; build costs; and benchmark land values, are too generic and not backed up by comparable evidence.

6.25 It remains the view that larger sites being identified in the GNLP are likely to require the more significant infrastructure obligations i.e., primary schools and health centres, so an assessment of viability and the implications for deliverability is key.

6.26 Consideration should also be given to whether it remains viable for some of the larger identified strategic sites, to pay both the Community Infrastructure Levy in addition to the policy requirements of the Local Plan. The use of Section 106 planning obligations to secure
infrastructure costs should be properly explored by the GNLP. This approach continues to work well in other parts of East Anglia, with such an approach being successfully adopted and implemented by Mid Suffolk District Council, which is entirely consistent with the Community Infrastructure Regulations (2019).

6.27 It remains unclear if the general comments previously raised by Turner Morum LLP with the
Interim Viability Study (Nov 19) have been adequately addressed, so they are reiterated below:
• The document has adopted average market revenues of £279 per ft2 for Wymondham, which is considered too high.
• Based on market evidence the figure should be £250 per ft2. The affordable rent values are included at 60% of Open Market Values (OMV) averaging £168 per ft2,
which is believed to be too high. Based on recent evidence it is suggested that this figure should be between 45%/50% of open market value.
• The intermediate units (Affordable Homes Ownership) are included at 75% of OMV averaging £212 per ft2, which is believed to be too high. Based on recent evidence it is suggest that assuming a shared ownership model, the figure should be between 65% of open market value.
• The Interim Viability Study document is vague about what the Affordable Housing units are intended to be. However, the GNLP Viability Assessment Paper (2018) is clear that standard intermediate housing are the intended units.
• A figure of only £193,000 per net acre for strategic infrastructure is included whereas, based on experience of similar viability assessments, this should be approximately double. The approach is to include 20% on-top of BCIS for all external and strategic
infrastructure costs, although 10% (as a minimum) would be required for plot externals costs – which leaves the remaining 10% for strategic infrastructure costs.
• The GNLP analysis does not apply contingency or professional fees to the externals works of strategic infrastructure costs – which is a significant figure that would be further increased if strategic infrastructure cost were included
• The allowance for finance costs, which are equivalent to juts 1.0% of GDV/ 1.3% of scheme costs, is very low. Based on comparable viability assessments, these costs
should be double.

6.28 The identification of Wymondham as a Main Town within the settlement hierarchy is supported.

6.29 In the interests of ensuring that the Local Plan targets are met in relation to housing growth,
and to avoid any ambiguity with the policies of the Greater Norwich Local Plan in terms of forecast growth and how it will be met, it is recommended that Land at Tuttles Lane East, Wymondham (GNLP00006) should be allocated for housing development.

6.30 Allocating site GNLP00006 will provide certainty for a range of stakeholders, not least the local education facilities at Wymondham, and ensure that development and infrastructure can be delivered in a planned and coordinated manner.

6.31 It is at this point it is important to reiterate the matters previously made in the representations
that were submitted to the Reg 18 (c) document by Bidwells on behalf of Welbeck Land. In particular, these relates to the “Assessment of Deliverability” section, pages 16-22 of those previously submitted representations, which relate to the site’s “suitability”; “availability”; and “viability”. (These are detailed in the previous submissions).

6.32 It is recommended that the contingency numbers previously identified within the Reg 18 stage be reinstated and allocated appropriately, in order to prevent ambiguity in where development may or may not be located. By continuing to retain a contingency site at Costessey, it is clear that the GNLP acknowledge they are placing an overreliance on their allocated sites coming forward and being delivered in a timely fashion. Therefore, should one or more sites fail to deliver in the manner or timeframes expected, then the ability to deliver the plan in a
coordinated and sustainable manner is undermined.

6.33 The allocation of strategic and contingency sites would help to provide certainty for the likes of Norfolk County Council Education, to identify a clear strategy in relation to future infrastructure provision.

6.34 The quantum of growth directed towards both the Norwich Urban Area and the Village Clusters in South Norfolk cannot be relied upon without the provision of clear evidence.

6.35 The reliance on existing strategic site allocations to deliver is also questionable. For example, the major site at North Rackheath has been allocated since 2010 and earmarked in the AMR (2010-11), for delivery in 2013-14. Since the Reg 18 stage, yet more growth has been forecast for North Rackheath. However, development of the initial allocation is yet to start. It is acknowledged that “commencement is now behind the milestone” and is expected to start delivering houses from 2024, (Joint Core Strategy for Broadland, Norwich and South Norfolk,
AMR 2018-19, Appendices and Statements, 5th February 2020, p.187).

6.36 This clearly reiterates the importance of providing contingency sites in alternative suitable locations, such as Land at Tuttles Lane East, Wymondham (GNLP0006), which is genuinely deliverable within 4 years of the adoption of the Greater Norwich Local Plan.

See attachment for full representation, particularly section 6 - Greater Norwich Local Plan Evidence Base

Change suggested by respondent:

Full text:

Attachments:

Full Representation (9.62 MB)

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