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Statement for Breckland Bridge

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Statement for Breckland Bridge Hearing Statement Breckland Bridge Ltd Sarah Hornbrook 26 March 2018 BRECKLAND LOCAL PLAN HEARING STATEMENT MATTER 14 – STRATEGIC URBAN EXTENSIONS, HOUSING SITE ALLOCATIONS & SETTLEMENT BOUNDARIES: KENNINGHALL Hearing Statement – Matter 14: Strategic Urban Extensions, Housing Site Allocations & Settlement Boundaries Quality Assurance Client name: Breckland Bridge Ltd Type of report: Hearing Statement Prepared by: Sarah Hornbrook MA(Cantab)MSc MRTPI Signed Date 26 March 2018 Reviewed by: Iain Hill BSc Hons DipTP MRTPI Signed Date 26 March 2018 Page i Hearing Statement – Matter 14: Strategic Urban Extensions, Housing Site Allocations & Settlement Boundaries Table of Contents 1.0 Background 1 2.0 Response to Inspector’s Issues 1 3.0 Conclusion 3 Appendix 1 RICHARD JACKSON ENGINEERING’S LETTER DATED 14 MARCH 2018 Page ii Hearing Statement – Matter 14: Strategic Urban Extensions, Housing Site Allocations & Settlement Boundaries 1.0 Background 1.1 This Hearing Statement has been prepared on behalf of Breckland Bridge Ltd, in support of representations to the Breckland District Local Plan (2011-2036) Pre-Submission Draft (August 2017). This Statement seeks to address Issues and Questions raised by the Inspector, specifically Issues 14.50-14.52, which relate to proposed site allocations in Kenninghall. 2.0 Response to Inspector’s Issues 14.50 - Is there sufficient evidence to demonstrate that the development of the site allocation would not unacceptably affect highway and pedestrian safety? 2.1 Richard Jackson Engineering Consultants have prepared a report, which takes the form of a letter dated 14th March 2018, and assesses the likely access and transportation implications of the proposed site allocation. The report is submitted as Appendix 1 to this Hearing Statement. 2.2 The report considers a potential development of 17 dwellings, which is in excess of the 15 envisaged within the proposed Kenninghall Housing Allocation 1. It confirms that site access is likely to constitute a continuation of School Close, and that the minimum standard of the road between the site and Garboldisham Road is consistent with a Type 3 road, and consequently capable of serving up to 100 dwellings. The road currently serves approximately 70 dwellings, the primary school and village hall, and the proposed allocation would bring the total housing numbers to approximately 85, below the 100 unit threshold for a Type 3 road. 2.3 Access to the wider highway network would be via the junction between School Close and Garboldisham Road, and the Richard Jackson report confirms that the required visibility splays of 2.4m x 90m are already in place. 2.4 Whilst the site does not abut the existing highway, a right exists to connect to the highway across the third-party land, to an Adoptable standard, and for the road to be Adopted. 2.5 The report confirms that footway connections can be made to link with existing provision, to ensure that future residents are able to access the services and facilities in the village centre safely. Other than the doctors’ surgery and facilities on Church Street, all other facilities are accessible via existing footways in the village. However, these facilities are on roads with designs that induce low speeds and are, therefore, safely accessible. 2.6 The report includes a Parking Survey, undertaken due to the proximity of the site to the Primary School, and in response to a comment made by a local resident during the Pre-Submission Consultation, raising concerns about parking congestion in the area at each end of the school day. The survey demonstrates that whilst School Close is used by parents for parking, the number of parked cars and their general locations means that the proposed development is unlikely to have a detrimental effect on the highway network of School Close/Powell Close in terms of trips or capacity. It is worth noting that there are two entrances to the primary school Page 1 Hearing Statement – Matter 14: Strategic Urban Extensions, Housing Site Allocations & Settlement Boundaries which parents are able to use; the main entrance is on Lopham Road where there is a car park, and the School Close entrance is a secondary entrance. 2.7 Likely vehicle trip generation has been calculated from the TRICS database, and is likely to be 0.547 trips per dwelling in the peak hour. For a development of 15 units, this would equate to approximately 8 trips in the peak hour. The Richard Jackson report advises that Census data indicates that most traffic is likely to travel west, away from the centre of the village, and there would therefore be minimal impacts on traffic flows through the village. 2.8 In light of the above, it is evident that Kenninghall Housing Allocation 1 can be delivered without causing harm to either highway or pedestrian safety. 14.51 Is Criterion 1. consistent with national policy? 2.9 Criterion 1 of proposed policy Kenninghall Housing Allocation 1 states that “The scheme design, whilst preserving and enhancing, is complementary to the special interest of the designated heritage assets and the Conservation Area. The scheme design proposal will be informed via a detailed appraisal of the assets' significance.” 2.10 This wording is considered to require amendment for two reasons. First, the reference to ‘designated’ heritage assets is erroneous; the NPPF and draft NPPF require consideration of both designated and non-designated heritage assets, which are referred to collectively as just ‘heritage assets’. 2.11 Second, the requirement for the scheme design to be ‘complementary’ to the special interest of the assets and Conservation Area is not consistent with the requirements of the NPPF, or the draft revised NPPF, in relation to the Historic Environment. Whilst the general duty for Local Planning Authorities to pay special attention to the desirability of ‘preserving or enhancing’ Conservation Areas, set out in the Planning (Listed Buildings and Conservation Areas) Act 1990, is acknowledged and understood, the NPPF provides further guidance on how applications affecting heritage assets should be dealt with. Paragraph 128 sets out a requirement for any applicant to describe the significance of any heritage assets affected by a proposal. The Local Planning Authority must then weigh up the likely harm that would be caused to the significance of the identified assets, attaching great weight to the asset’s conservation (para 132). Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal (para 134). Where a proposal affects a non-designated asset, a balanced judgement is required having regard to the scale of any harm or loss of significance. 2.12 Consequently, the current requirement of criterion 1 for any development to be complementary to the special interest of the designated heritage assets is not entirely consistent with national policy, as required by paragraph 182 of the NPPF, and is therefore not sound. 2.13 We would suggest that criterion 1 is reworded, as set out in paragraph 5.2 below, to require the development to have regard to heritage assets, in accordance with the NPPF, for consistency with national policy. Page 2 Hearing Statement – Matter 14: Strategic Urban Extensions, Housing Site Allocations & Settlement Boundaries 14.52 To be effective, should the criteria of Kenninghall Housing Allocation 1 refer to the need to have regard to heritage assets? 2.14 Please see paragraphs 2.9 - 2.13 above. 3.0 Conclusion 3.1 It is clear from the evidence provided above, that Kenninghall Housing Allocation 1 can be brought forward without causing any harm to pedestrian or highway safety. 3.2 In addition, with amendments to the wording of the policy, it is clear that the Allocation can also be brought forward in line with national policy in relation to heritage assets. We propose that the wording of Kenninghall Housing Allocation 1 is revised as follows (text which has been struck through indicates text to be deleted, and text in red represents new text to be inserted): Kenninghall Housing Allocation 1 Land off Powell Close (LP[051]003) Land amounting to approximately 0.6 hectares is allocated for a residential development of at least 15 dwellings. Development will be subject to compliance with adopted Local Plan policies and: 1. The scheme design, whilst preserving and enhancing, is complementary to the special interest of the designated heritage assets and the conservation area. The scheme design proposal will be informed via a detailed appraisal of the assets' significance; Development shall maximise opportunities to preserve, enhance, or better reveal the significance of designated heritage assets and that of any other heritage assets subsequently identified through the development process; 2. Provision of safe highway access onto Powell Close; 3. The layout and design of the site will provide an appropriate response to the established pattern of development at Powell Close; 4. The site is underlain by a defined Mineral Safeguarding Area for sand and gravel. As the site is under 1hectare it is exempt from the requirements of Norfolk Minerals and Waste Core Strategy Policy CS16 – ‘safeguarding’, in relation to mineral resources. If the site area is amended in the future to make the area over 1 hectare CS16 will apply; and 5. A pre-application enquiry with Anglian Water Services is required for this site in accordance with the Water Cycle Study to demonstrate that sufficient capacity is available to transfer wastewater for treatment. Where insufficient capacity within the wastewater network is identified, financial contributions may be sought. Page 3 Hearing Statement – Matter 14: Strategic Urban Extensions, Housing Site Allocations & Settlement Boundaries APPENDIX 1 RICHARD JACKSON ENGINEERING’S LETTER DATED 14 MARCH 2018 Page 4 Our Ref: 47182/JP/MJD Your Ref: 14 March 2018 Breckland Bridge Limited c/o Mrs S Hornbrook Bidwells 16 Upper King Street Norwich NR3 1HA Dear Mrs Hornbrook Re: Land at Powell Close, Kenninghall I refer to our instructions to complete an overview of access and transportation matters in respect of the above site.
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