Publication

No specific modifications are required to the Vision and Objectives. However, it is requested that modifications are made to the housing requirement in Policy 1 to ensure consistency with national guidance, and that Site Allocation GNLP2143: Land south of Le Neve Road in Marsham is deleted to be consistent with objectives to protect the natural and historic environments.

The Vision and Objectives for the pre-submission draft Greater Norwich Local Plan (Draft GNLP) refers to meeting housing and affordable housing needs, and to protecting the environment including minimising the loss of greenfield land and protecting the natural and historic environment.
The topics and aspirations contained in the Vision and Objectives are generally supported. However, it is considered that unless changes are made to other parts of Draft GNLP, including policies and allocations, then the Vision and Objectives would not be delivered. In summary, Noble Foods Ltd objects to the proposed residential allocation GNLP2143: Land south of Le Neve Road in Marsham on the basis that it is a greenfield site and development in this location would have a significant impact on heritage assets and landscape character. Noble Foods Ltd request that an alternative site is allocated at Fengate Farm in Marsham (Site Ref. GNLP3035) because the site contains vacant and unused buildings and areas of hardstanding associated with a former poultry unit, and there are no significant constraints to development at this site. An allocation at Fengate Farm would be much more consistent with the Vision and Objectives of Draft GNLP compared with the proposed allocation at land south of Le Neve Road.
As set out in the representations on the housing requirement contained in Policy 1: Sustainable Growth Strategy, it is not clear whether the proposed buffer in the local housing need figure fully reflects national guidance in terms of considering adjustments for economic growth and affordable housing needs. In the representations to Policy 1 it is requested that the circumstances identified in Paragraphs 010 and 024 of Id.2a of the Planning Practice Guidance are considered for the housing requirement in Draft GNLP.
It is noted that Paragraph 148 of Draft GNLP refers to minimising the loss off greenfield land, and the ‘homes’ objective at Paragraph 151 seeks to make efficient use of land. The proposed residential allocation GNLP2143: Land south of Le Neve Road in Marsham is a greenfield site. It acknowledged that to meet the housing requirement will involve the use of greenfield land. However, in the case of Marsham a vacant and unused site containing fire damaged buildings is available on the edge of the village at Fengate Farm (Site Ref. GNLP3035), and this site should have been allocated in preference to a greenfield site. Therefore, it is considered that the decision to allocate the greenfield site at land south of Le Neve Road in Marsham for residential development is inconsistent with Vision and Objectives of Draft GNLP, particularly when a vacant and unused site is available.
It is noted that the ‘environment’ objective at Paragraph 151 seeks to protect and enhance the natural and historic environments. The Noble Foods Ltd representation to Site Allocation GNLP2143: Land south of Le Neve Road in Marsham is accompanied by a heritage report and landscape appraisal. In summary, it is concluded in the heritage report that development at land south of Le Neve Road would adversely impact the setting and landmark qualities of the church tower at All Saints Church (Grade I Listed Building), and that even with landscape mitigation measures the proposed development would be perceived in key views of the church. It is concluded in the landscape appraisal that development at the site would have an unacceptable impact on the character and appearance of the open land that currently forms part of the setting of the village and the church, and it is unlikely that landscape mitigation would address the visual harm. Therefore, it is considered that the decision to allocate land south of Le Neve Road in Marsham for residential development is inconsistent with the Vision and Objectives of Draft GNLP in terms of protecting the natural and historic environments.

No specific modifications are required to the Delivery Statement. Vision and Objectives. However, it is requested that modifications are made to the housing requirement in Policy 1 to ensure consistency with national guidance, and that land at Fengate Farm in Marsham (Site Ref. GNLP3035) is specifically allocated in Draft GNLP or is incorporated into the village boundary to enable the delivery of affordable housing.

The housing section of the Delivery Statement at Paragraph 155 of Draft GNLP refers to the flexibility included in the proposed housing target and to additional housing being provided through small scale growth at villages.
As set out in the representations on the housing requirement contained in Policy 1: Sustainable Growth Strategy, it is not clear whether the proposed flexibility and buffer in the housing target is consistent with national guidance in terms of considering adjustments for economic growth and affordable housing needs. In the representations to Policy 1 it is requested that the circumstances identified in Paragraphs 010 and 024 of Id.2a of the Planning Practice Guidance are considered for the housing requirement in Draft GNLP.
As set out in the representations to Policy 7.4: Village Clusters and Policy 7.5: Small Scale Windfall Housing Development, there are likely to be limited infill development opportunities within villages and schemes of no more than five dwellings are permitted on small sites immediately adjacent village boundaries, which means that affordable housing is unlikely to be delivered in the villages because any suitable developments will fall below the threshold where affordable housing is actually required. It is requested in representations by Noble Foods Ltd that land at Fengate Farm in Marsham (Site Ref. GNLP3035) is specifically allocated as an alternative site to the preferred allocation, or as an alternative the village boundary is amended to incorporate the Fengate Farm site to enable residential development to be brought forward as a windfall site; both these options would deliver additional affordable housing for Marsham.

The Climate Change Statement at Paragraph 157 of Draft GNLP identifies a range of measures that development could deliver to address climate change, including measures related to the location of development, design, energy use and biodiversity net gain. The promoted development by Noble Foods Ltd on land at Fengate Farm in Marsham (Site Ref. GNLP3035) would be designed to meet low carbon and resource efficiency standards. Marsham contains some facilities including a primary school, but there are additional services and facilities including convenience stores in Aylsham which is 2km to the north and accessible by bus services, and as such additional development at Marsham could reduce the need to travel. The preliminary ecological appraisal prepared for the promoted development at Fengate Farm demonstrates that ecological enhancement measures can be delivered at the site to contribute towards biodiversity net gain. Therefore, it is considered that the promoted development at Fengate Farm would deliver measures to address climate change if the site were selected as an alternative allocation.
No changes are requested to the Climate Change Statement.

It is requested that Policy 1 includes confirmation that the circumstances identified in Paragraphs 010 and 024 of Id.2a of the Planning Practice Guidance are included in the housing target for Draft GNLP e.g. adjustments for economic growth, strategic infrastructure and to meet affordable housing needs.
No modifications are required to the settlement hierarchy in respect of Marsham.

Policy 1 sets out the proposed housing target for the period between 2018 and 2038 and defines the settlement hierarchy and distribution strategy for Draft GNLP.
It is acknowledged that the proposed housing target in Policy 1 is derived from the standard method for calculating local housing needs, as required by Paragraph 60 of the NPPF. The proposed housing target includes a 22% buffer above the figure derived from the standard method. However, what is not certain is whether how the buffer has been calculated is consistent with national guidance.
Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows:
• Where there is a growth strategy in place to promote and facilitate additional growth;
• Where strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and
• Where an authority has agreed to accommodate unmet housing needs from a neighbouring area.
Greater Norwich is within the Cambridge Norwich Tech Corridor and there is a Greater Norwich City Deal, which indicates that that two of the circumstances – growth strategy and infrastructure improvements – apply to the housing target for Draft GNLP, and adjustments should have been considered and assessed. It is not clear that these factors have been considered for the housing target in Policy 1. It is requested that Draft GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a are included in the housing target in Policy 1.
Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. The latest published Annual Monitoring Report (January 202) includes data on the delivery of affordable housing. The affordable housing completions data shows that delivery is below targets in both percentage and absolute terms overall. The data shows that across Greater Norwich there is a shortfall in the delivery of affordable housing of 449 dwellings. Paragraph 3.26 in the AMR notes some of the challenges of delivering affordable housing, including that affordable housing is not required from non-major developments and the redevelopment of vacant buildings or prior approval of office buildings, and it also notes that viability is an issue for some sites. The representations to Policies 7.4 and 7.5 highlight that infill development sites and small scale development at villages are unlikely to deliver any affordable housing. It is not clear whether the housing requirement for Draft GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.
Marsham contains a primary school, church, village hall and public house. There are businesses within the village that provide employment opportunities for local residents. The village is on a bus route providing frequent bus services to Norwich, Sheringham, Reepham and Cromer. Marsham is located approximately 2km to the south of Aylsham. In these circumstances, it is appropriate for Marsham to be defined as a village cluster in the settlement hierarchy.

No specific modifications are required to Policy 2. However, it is requested that modifications are made to the allocations in Marsham to ensure consistency with Policy 2 in terms of protecting landscape and heritage assets i.e. that Site Allocation GNLP2143: Land south of Le Neve Road in Marsham is deleted and land at Fengate Farm (Site Ref. GNLP3035) is identified as an alternative allocation for residential development.

Policy 2 identifies some key principles to ensure the delivery of high quality development, and refers to accessibility, the efficient use of land, the delivery of green infrastructure, impacts on the environment including landscape and heritage, and the delivery of low carbon and resource efficient buildings. These principles are supported.
However, it is considered that high quality development would not be delivered at Marsham, and in accordance with Policy 2, because of the proposed allocation at GNLP2143: Land south of Le Neve Road in Marsham on the basis that development in this location would have a significant impact on heritage assets and landscape character. The Noble Foods Ltd representation to Site Allocation GNLP2143 is accompanied by a heritage report and landscape appraisal. In summary, it is concluded in the heritage report that development at land south of Le Neve Road would adversely impact the setting and landmark qualities of the church tower at All Saints Church (Grade I Listed Building), and that even with landscape mitigation measures the proposed development would be perceived in key views of the church. It is concluded in the landscape appraisal that development at the site would have an unacceptable impact on the character and appearance of the open land that currently forms part of the setting of the village and the church, and it is unlikely that landscape mitigation would address the visual harm. Therefore, it is considered that the decision to allocate land south of Le Neve Road in Marsham for residential development would not comply with the requirements in Policy 2 for development to protect, preserve and enhance the landscape and historic environment.
Noble Foods Ltd is promoting an alternative site for a residential allocation in Marsham, at Fengate Farm (Site Ref. GNLP3035). The Fengate Farm site contains vacant and unused buildings and areas of hardstanding associated with a former poultry unit. The site is visible from the High Street and neighbouring properties. It would substantially enhance the townscape of Marsham if the fire damaged buildings at Fengate Farm were removed and replaced by residential development. There are no significant heritage, landscape, or ecological constraints to development at the Fengate Farm site. The transport and access assessment of the Fengate Farm site demonstrates that suitable vehicular and pedestrian accesses are available to support the proposed development, and that a safe and convenient walking route is available from the site to the primary school that avoid the High Street. In addition, the promoted development at Fengate Farm would meet design, low carbon, and resource efficiency standards. It is considered that the promoted development at Fengate Farm would be compliant with Policy 2, unlike the proposed allocation at land south of Le Neve Road.

No specific modifications are required to Policy 3. However, it is requested that the site assessment is corrected, and modifications are made to the proposed allocation in Marsham, including that Site Allocation GNLP2143: Land south of Le Neve Road is deleted, so that the requirements of Policy 3 can be achieved.

Policy 3: Environmental Protection and Enhancement

Policy 3 seeks to protect and enhance the historic and natural environment including landscapes. However, it is considered that the requirements of Policy 3 would not be met because of the proposed allocation at GNLP2143: Land south of Le Neve Road in Marsham, on the basis that development in this location would have a significant impact on heritage assets and landscape character. The heritage report and landscape appraisal submitted with the Noble Foods Ltd representation to Site Allocation GNLP2143 demonstrate that development at this site would adversely impact the setting and landmark qualities of the church tower at All Saints Church, and it would have an unacceptable impact on the character and appearance of the open land that currently forms part of the setting of the village and the church. As set out in the representations to Site Allocation GNLP2143, the findings of the landscape and heritage assessment for this site are not correct and the impacts would be more harmful and significant than predicted. Therefore, it is considered that the decision to allocate land south of Le Neve Road in Marsham for residential development would not comply with the requirements in Policy 3 for development to protect and enhance the historic and natural environment.

Policy 4 deals with infrastructure, including local infrastructure that could be delivered on site or via the provision of land or planning obligations. It is anticipated that the promoted development at land at Fengate Farm in Marsham (Site Ref. GNLP3035), if identified as an alternative allocation, would make appropriate planning obligations for infrastructure including education, and could also include open space and allotments if required. The requirement for planning obligations in conjunction with development is appropriate, and no changes to Policy 4 are required.

Policy 5 deals with affordable housing and specifies that 33% of housing should be affordable from major residential sites. The affordable housing requirements are supported. The promoted development at land at Fengate Farm in Marsham (Site Ref. GNLP3035) would provide policy compliant levels of affordable housing if it is identified as an alternative allocation in Draft GNLP. As set out in the representations to Policy 7.4: Village Clusters and Policy 7.5: Small Scale Windfall Housing Development, the policy approach of limited infill sites and small scale development sites only at villages is likely to fall below the threshold where affordable housing is required and means that none will be delivered at the smaller villages. No changes to Policy 5 are required.

It is requested that land at Fengate Farm in Marsham (Site Ref. GNLP3035) is specifically allocated in Draft GNLP as an alternative to Site Allocation GNLP2143: Land south of Le Neve Road, or Fengate Farm should be incorporated into the village boundary to enable the delivery of housing at this vacant and unused site.

Policy 7.4 identifies the contribution that the village clusters in Broadland are expected to make to meeting the overall housing requirement. The housing requirement at village clusters would be met by site allocations, infill development and affordable housing-led development.
As set out in the representations to Site Allocation GNLP2143: Land south of Le Neve Road in Marsham, the findings of the landscape and heritage assessment for this site are not correct, the impacts would be more harmful and significant than predicted, and as such this allocation should be deleted. Noble Foods Ltd is promoting an alternative site for a residential allocation in Marsham, at Fengate Farm (Site Ref. GNLP3035), which has no significant constraints to development, and is a vacant and unused site adjacent to the village boundary. Therefore, the site allocations in village clusters will contribute towards meeting the housing requirement, but the most suitable sites within villages also need to be allocated e.g. Fengate Farm in Marsham.
The strategy for housing in the village clusters does not consider the circumstances that exist at particular villages. For example, the site is promoted on behalf of Noble Farms Ltd at Fengate Farm in Marsham contains vacant and unused buildings and areas of hardstanding associated with a former poultry unit. The former poultry use ceased in 2011. The buildings were damaged by fire in early 2020. The site is located outside but immediately adjacent to the village boundary. In all respects the site at Fengate Farm is suitable for redevelopment, it was promoted through the GNLP process, and yet has not been allocated. It is considered that land at Fengate Farm should be specifically allocated in Draft GNLP or be incorporated into the village boundary to enable the delivery of housing and affordable housing.
The policy approach of infill development within settlement boundaries at cluster villages is likely to provide a very limited amount of housing. It is likely that most infill development opportunities where they exist would deliver no more than one or two additional dwellings and would fall below the threshold where affordable housing is required. In these circumstances, it is unlikely that any affordable housing would be delivered from infill sites within village clusters.

It is requested that land at Fengate Farm in Marsham (Site Ref. GNLP3035) is specifically allocated in Draft GNLP, or Fengate Farm should be incorporated into the village boundary to enable the delivery of housing and affordable housing at this vacant and unused site.

Policy 7.5 supports small scale windfall housing development in all villages and allows for developments on sites adjacent to the defined village boundaries for up to 3 dwellings at small parishes and up to 5 dwellings at large parishes. Paragraph 023 (ID: 23b) of the Planning Practice Guidance identifies the circumstances where contributions through planning obligations should not be sought from development. Paragraph 023 states in parts that “Planning obligations for affordable housing should only be sought for residential developments that are major developments”; major development is defined as developments of 10 or more dwellings or with a site area of 0.5 hectares or more. Therefore, the scale of development anticipated by Policy 7.5 falls below the threshold where affordable housing would normally be required. As set out the representations to Policy 7.4, any infill development opportunities within village boundaries will also be small and fall below the threshold for affordable housing. As such, it is very unlikely that any affordable housing will be delivered at the small and large parishes that do not have an allocation in Draft GNLP. If affordable housing will not be delivered from small scale windfall sites on the edge of villages or from infill sites within villages, it is considered that additional allocations are needed that can deliver affordable housing.
As set out in these representations, Noble Foods Ltd is promoting a vacant and unused site located immediately adjacent to the village boundary at Marsham - land at Fengate Farm (Site Ref. GNLP3035). The promoted site does not qualify as an infill development site and is too large to be a small scale windfall sites. However, the site is suitable for residential development and it would be beneficial to redevelop this vacant and unused sites containing fire damaged buildings which are visible from the High Street.