Publication

The Vision and Objectives for the pre-submission draft Greater Norwich Local Plan (Draft GNLP) refers to meeting housing and affordable housing needs. The topics and aspirations contained in the Vision and Objectives are supported.
Taylor Wimpey control land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172), which is identified as a proposed allocation in Draft GNLP for approximately 205 dwellings. This site has a resolution to grant planning permission for the provision of 205 homes (App Ref. 20172208) including 68 affordable dwellings. There are no constraints to development at the site, and it is controlled by a housebuilder which means it is deliverable. As explained in the representations to the Site Allocations document, this site is suitable for development and should be retained as a proposed allocation. It is considered that Site Ref. Policy GNLP0172 would contribute towards the GNLP objectives related to housing, affordable housing, and delivery.
No modifications are required to the Vision and Objectives.

The housing section of the Delivery Statement at Paragraph 155 of Draft GNLP refers to a proactive approach to the delivery of housing, the allocation of sites which are deliverable, and to work with developers to deliver housing sites. The housing section of the Delivery Statement is supported.
Taylor Wimpey control land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172), which is identified as a proposed allocation for housing in Draft GNLP. A planning application has been submitted for the proposed development, which has a resolution to grant planning permission (App Ref. 20172208). The site is controlled by a housebuilder and is deliverable. The proposed allocation at Site Ref. Policy GNLP0172 is consistent with the aims of the Delivery Statement.
No modifications are required to the Delivery Statement.

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 proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172), as promoted by Taylor Wimpey, would be consistent with the identified climate change measures.
Rackheath is located within the Norwich Urban Area and Fringe Parishes area, which is identified as the main focus for growth in Draft GNLP. Rackheath currently contains a good range of services and facilities and employment sites, and additional facilities and employment will be delivered as part of the major growth commitments in the area. There are bus services in Rackheath that provide fast and convenient access to Norwich and other higher order settlements. The proposed allocation at Site Ref. GNLP0172 is well related to the services and facilities and employment sites in the village, it is accessible to those locations by walking and cycling, and the site is accessible to bus services. A travel plan has been prepared for the planning application at the site to encourage the use of sustainable transport choices. Therefore, the proposed allocation would be consistent with the climate change measures that seek to reduce the need to travel and to encourage the use of sustainable modes of transport.
The quantum of development provided for in the proposed allocation at Site Ref. GNLP0172 has been informed by the need to reinforce local distinctiveness and to take into account the open countryside adjacent to the site. The proposed development would be based on urban design principles to achieve high quality development, including a legible and permeable environment, suitable densities, appropriate building heights consistent with the surrounding area, active street frontages, and suitable garden sizes. Therefore, the proposed development would be consistent with the design related climate change measures.
The proposed development will incorporate ecological enhancement measures to recreate areas of heathland on the western side of the Norwich Northern Distributor Road. The new heathland habitat would improve local biodiversity and provide a habitat for protected species, and lead to a biodiversity net gain. Therefore, the proposed development would be consistent with the climate change measures to deliver biodiversity net gain.
The proposed development will be designed to meet low carbon, resource efficiency and water conservation standards.
No changes are requested to the Climate Change Statement.

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.
Rackheath is located within the Norwich Urban Area and Fringe Parishes area, which is identified as the main focus for growth in Draft GNLP. The settlement hierarchy and the strategy directing growth to the Norwich Urban Area and Fringe Parishes area including Rackheath is supported.
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 allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) would contribute towards the housing target and the delivery of housing in the short term to maintain a sufficient land supply. No other comments are made on the housing target in respect of the proposed allocation.
No changes are requested to Policy 1.

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, and the delivery of low carbon and resource efficient buildings. These principles are supported.
A planning application has been submitted for the proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172). The proposed allocation, as promoted by Taylor Wimpey, would be consistent with the key principles for high quality development. The proposed allocation is accessible to the services and facilities and employment sites in Rackheath by sustainable modes of transport. The site area and quantum of development at the proposed allocation would deliver a suitable density of development, which is consistent with the characteristics of the site and surrounding area and would achieve an efficient use of land. The proposed allocation includes open space and areas of heathland on the western side of the Norwich Northern Distributor Road, in order to provide new green infrastructure for the area and to provide a habitat for protected species. The proposed development will be designed to meet low carbon, resource efficiency and water conservation standards. Therefore, it is considered that the proposed allocation at Site Ref. GNLP0172 would achieve the key principles of high quality development as identified in Policy 2.
No modifications are required to Policy 2.

Policy 3 seeks to protect and enhance the historic and natural environment including landscapes.
The proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) does not contain any listed buildings and is not within a conservation area. The proposed area of open space is located within Rackheath Park, which is the grounds associated with Rackheath Hall (Grade II Listed Building), but no buildings would be located within this area. The site has high archaeological potential associated with the medieval period, but the geophysical survey undertaken for the planning application identified no archaeological features, and for the planning application it has been recommended that a condition is attached to the planning permission requiring a programme of archaeological mitigation work.
There are no statutory or non-statutory landscape designations that affect the site, and there is no evidence to indicate that the site is valued for its landscape qualities. A full Landscape and Visual Impact Assessment (LVIA) has been prepared for the proposed development site and was submitted with the planning application. To the north of the site is a residential area at Trinity Close and Sir Edward Stacey Road. To the south is commercial uses. The proposed strategic development at the North Rackheath Urban Extension is located to the east of the site. The site is enclosed by a dense hedgerow and hedgerow tree planting to the east, which forms a natural green boundary and screens the site in views from the east. The Norwich Northern Distributor Road is located to the west of the site. The majority of the existing vegetation within the site will be retained within the proposed development. The proposed residential areas will include landscaping and structural planting. The proposed development includes a substantial area to the east of the new NNDR for landscape enhancement and new wildlife habitats. It is concluded in the LVIA is that the site is a suitable location for residential development in terms of landscape and visual impacts, provided the landscape mitigation and enhancement measures are implemented. Therefore, it is considered that the proposed allocation would be consistent with the requirements of Policy 3.
No modifications are required to Policy 3.

Policy 4 deals with infrastructure, including local infrastructure that could be delivered on site or via the provision of land or planning obligations. In the planning application for the proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) it was recommended that planning obligations were required for affordable housing, open space, landscape and ecological enhancement, and management of the open space. In addition, the proposed development would be liable for Community Infrastructure Levy payments, which would support the delivery of infrastructure.
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 latest published Annual Monitoring Report (January 2020) 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, and 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. Therefore, sites that are capable of delivering policy compliant levels of affordable housing need to be identified in Draft GNLP, to address the current shortfall in the delivery of affordable housing and to
As set out in the planning application for the proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) this development would deliver 33% affordable housing, which equates to 68 affordable dwellings. The fact that the proposed development would deliver affordable housing supports the decision to allocate this site in Draft GNLP.
No modifications are requested to Policy 5.

Policy 7.1 sets out the development strategy for the Norwich Urban Area and the Fringe Parishes. This area is identified as the main focus for growth in Draft GNLP, and it is the key location for existing and planned employment growth and is a sustainable location in terms of accessibility by walking, cycling and public transport. Rackheath is located within the Norwich Urban Area and Fringe Parishes area, and the strategy of directing growth to this area is supported. The proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) would contribute towards the delivery of the housing target for the Norwich Urban Area and the Fringe Parishes.

No modifications are required to Policy 7.1.

Paragraph 163 of Draft GNLP indicates that the strategy and site allocations are based on an extensive evidence base. That evidence base includes the Housing and Economic Land Availability Assessment (HELAA), Site Assessment Booklets, and the Sustainability Appraisal (SA).

Paragraph 35 of the NPPF identifies how soundness will be determined for plan-making. The justified soundness test states: “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;…”. To be justified means that policies and site allocations in Draft GNLP should be based on robust and credible evidence.

Taylor Wimpey supports the decision to allocate land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) for residential development, and requests that this allocation and the associated policy are retained in Draft GNLP unchanged.
In order to confirm that the decision to make the allocation at Policy GNLP0172 is robust and credible, it is suggested that the findings of the site assessment for this site in the HELAA and SA are corrected as set out below.

Allocation - Land west of Green Lane West, Rackheath (Site Ref. GNLP 0172)

Taylor Wimpey control land to the west of Green Lane West in Rackheath. The site is identified as a preferred allocation in GNLP for up to 205 dwellings. This allocation is supported and should be retained.
An outline planning application for 205 dwellings has been submitted for the promoted development (Ref. 2017/2208). This site is has a resolution to grant planning permission and the S106 Agreement has been signed. The decision on the application demonstrates that the site is suitable for the promoted development, that proposed mitigation measures can address any significant constraints associated with the development, and conditions can be used to make the development acceptable. The site is controlled by a housebuilder and is deliverable.

The Taylor Wimpey representations to the Regulation 18 Growth Strategy consultation in March 2018 requested amendments to the assessment of the site in the HELAA, and in particular to those topics that scored ‘amber’. Those topics also need to be updated to reflect progress with the planning application for the proposed development. The topics that scored ‘amber’ and should be amended to ‘green’ relate to access, access to services, utilities capacity, contamination, flood risk, significant landscapes, and compatibility with neighbouring uses. The requested amendments to the HELAA assessment where the score should be amended from ‘amber’ to ‘green’ are as follows:
• Access: The main site access to the proposed development will be provided off Green Lane West, with a secondary access also off this road for emergency vehicles and pedestrians and cyclists. A new pedestrian/cycle access point on Newman Road will provide access to the surrounding pedestrian network. It is noted that Policy GNLP0172 includes requirements relating to the delivery of a suitable vehicular access and pedestrian and cycle connections. It is requested that the access score for this site should be changed to ‘green’.
• Access to Services: The Site is within close proximity of the existing facilities within Rackheath, which are accessible by walking and cycling. The proposed strategic development at the North Rackheath Urban Extension, located to the east of the site, will provide additional services and facilities in the future. The site is served by existing bus services along Green Lane West, providing connections to Wroxham, Norwich City Centre, and the Norfolk and Norwich University Hospital. Salhouse Station is approximately 1.5km from the site, providing rail services to Norwich. The site is well-related to the employment opportunities at Rackheath Industrial Estate. The close proximity of the primary school, employment opportunities, bus services, and the future new facilities at North Rackheath including healthcare facilities, should be taken into account in the assessment of the site. The new facilities at North Rackheath would be located opposite the site on Green Lane West. The site would score ‘green’ for this topic in the near future.
• Utilities Capacity: The existing residential and commercial areas in Rackheath are connected to utilities services, and the proposed development at the site will also connect to those services. As such it is requested that the utilities capacity score for this site should be changed to ‘green’.
• Contamination: A Phase 1 and 2 Ground Investigation Report has been undertaken of the site and was submitted with the planning application. The Report identifies the potential for asbestos containing materials within the vicinity of the small structures in the southern portion of the site. A draft condition was recommended for the planning application to ensure that further assessment and investigation work is completed in advance of development.
• Flood Risk: The site lies within Flood Zone 1 and as such it is at low risk of flooding. A Flood Risk Assessment and Drainage Strategy has been prepared for the proposed development and was submitted with the planning application. The site has no history of flooding. The proposed development includes attenuation ponds to create a sustainable drainage system and control surface water drainage at the site. It is requested that the flood risk score for the site is changed to ‘green’.
• Significant Landscapes: A full Landscape and Visual Impact Assessment (LVIA) has been prepared for the proposed development site and was submitted with the planning application. To the north of the site is an area of residential development at Trinity Close and Sir Edward Stacey Road. To the south is an area of existing commercial development. The proposed strategic development at the North Rackheath Urban Extension is located to the east of the site. The site is enclosed by a dense hedgerow and hedgerow tree planting to the east, which forms a natural green boundary and screens the site in views from the east. The Norwich Northern Distributor Road is located to the west of the site. The majority of the existing vegetation within the site will be retained within the proposed development. The proposed residential areas will include landscaping and structural planting. The proposed development includes a substantial area to the east of the Norwich Northern Distributor Road for landscape enhancement and new wildlife habitats. It is concluded in the LVIA that the site is a suitable location for residential development in terms of landscape and visual impacts, provided the landscape mitigation and enhancement measures are implemented. It is requested that the landscape score for this site is changed to ‘green’.
• Compatibility with Neighbouring Uses: The site is located between an existing residential area to the north and an established commercial area to the south. The proposed development includes new planting at the northern and southern boundary to protect residential amenity and provide privacy. As such the proposed development would be compatible with the neighbouring uses. A woodland buffer will be provided on either side of the Norwich Northern Distributor Road. The proposed development will include a landscape bund and acoustic fence on the western boundary to provide an additional buffer between the new road and residential uses. It is noted that Policy GNLP0172 includes a requirement to manage compatibility between the proposed development and neighbouring residential and industrial uses. Therefore, the proposed development includes mitigation measures to address the relationship between existing uses and proposed residential uses. It is requested that the compatibility with neighbouring uses score is changed to ‘green’.

The assessment of the site in the SA identified some objectives where the score was ‘minor negative’ – see Table F.1.1: SA Impact Matrices for Site Policies Assessed in this Report (in SA Volume 3: Appendices). There are ‘minor negative’ scores for the following objective: Air Quality & Noise; Climate Change Mitigation & Adaptation; Landscape; and, Health. It is suggested that the findings for these objectives need to be updated to reflect progress with the planning application for the proposed development, and are as follows:
• Air Quality & Noise: The proposed development will include a landscape bund and acoustic fence on the western boundary to provide an additional buffer between the Norwich Northern Distributor Road and residential uses. For the planning application it has been recommended that conditions are imposed requiring a noise assessment and air quality impact assessment are submitted, in order to ensure that standards are met for these matters at the proposed development. It is considered that noise and air quality impacts will be addressed for the proposed development, and it is requested that the score for these matters is changed to ‘negligible’ – no impacts anticipated.
• Climate Change Mitigation & Adaptation: The site is well related to the services and facilities and employment sites in the village, it is accessible to those locations by walking and cycling, and the site is accessible to bus services. The proposed development will be designed to meet low carbon, resource efficiency and water conservation standards. The site lies within Flood Zone 1 and as such it is at low risk of flooding. The proposed development includes attenuation ponds to create a sustainable drainage system and control surface water drainage at the site. It is considered that the proposed development would be consistent with climate change mitigation and adaptation objectives, and would meet policy requirements, and as such it is requested that the score for this matter is changed to ‘negligible’ – no impacts anticipated.
• Landscape: As set out above, a full Landscape and Visual Impact Assessment (LVIA) has been prepared for the proposed development site and was submitted with the planning application. The majority of the existing vegetation within the site will be retained within the proposed development. The proposed residential areas will include landscaping and structural planting. The proposed development includes a substantial area to the east of the new Norwich Northern Distributor Road for landscape enhancement and new wildlife habitats. It is concluded in the LVIA that the site is a suitable location for residential development in terms of landscape and visual impacts, provided the landscape mitigation and enhancement measures are implemented. It is noted that Policy GNLP0172 includes a requirement that the proposed development avoids adverse impact on views through the valley of Beck Brook.
• Health: It should be acknowledged that the proposed strategic development at the North Rackheath Urban Extension, located to the east of the site, will provide additional services and facilities in the future, including healthcare facilities. As such, in the near future the residents of the proposed development would have access to health care facilities. In addition, the proposed development includes open space and the site is accessible by walking and cycling, which would enable residents to undertake outdoor exercise and to lead healthy lifestyles. It is considered that the score for health objectives should be changed to ‘negligible’ – no impacts anticipated.

Taylor Wimpey supports the proposed allocation at land west of Green Lane West, Rackheath (Site Ref. GNLP 0172). An outline planning application for 205 dwellings has been submitted for the promoted development (Ref. 2017/2208). The application has a resolution to grant planning permission and the S106 Agreement has been signed. There are no significant constraints to development, and all matters have been considered through the application process. The findings of the assessments in the HELAA and SA site could be adjusted for some topics and objectives, in order to reconfirm that the site is suitable for the proposed development and the most appropriate option for allocation when considered against the alternatives.

It is requested that land to the west of Green Lane West in Rackheath (Policy GNLP0172) is retained as an allocation in Draft GNLP and no changes are required to this policy.

In due course a Statement of Common Ground could be prepared with the Council to confirm the suitability and deliverability of the proposed allocation.