APPENDIX 1
OFFICERS’ REPORTS TO
DEVELOPMENT COMMITTEE – 21 AUGUST 2014
Each report for decision on this Agenda shows the Officer responsible, the recommendation
of the Head of Planning and in the case of private business the paragraph(s) of Schedule
12A to the Local Government Act 1972 under which it is considered exempt. None of the
reports have financial, legal or policy implications save where indicated.
PUBLIC BUSINESS – ITEMS FOR DECISION
1.
PLANNING APPLICATIONS ON BEHALF OF GRESHAMS SCHOOL FOR
RESIDENTIAL DEVELOPMENTS IN HOLT
This report concerns three outline planning applications for residential development
in Holt on land associated with Greshams School. The report provides an overview of
planning policy related issues and precedes individual reports on each application.
Note
This report is for informative purposes only. It is intended to assist members of the
committee in their understanding of the principal issues relating to the planning
applications which are subject to individual reports later on this agenda. Members are
invited to ask questions of officers regarding the contents of the report, but it is not
subject to public speaking. The opportunity for public speaking will take place when
the individual reports on each planning application are considered.
Introduction
Three outline planning applications for residential development have been submitted
for separate parcels of land owned partly by Greshams School and partly by the
Worshipful Company of Fishmongers with which the school has historic ties. Each
application approximates the number of dwellings proposed, and in the case of two of
the applications, details of access are included at this stage.
The applications are as follows:
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Ref: PO/14/0283 (referred to as Site 1) - Residential development for a maximum
of 126 dwellings - Land south of Cromer Road and east of Grove Lane, Holt.
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Ref: PO/14/0284 (referred to as Site 2) - Residential development for a maximum
of 19 dwellings - Land south of Cromer Road and west of Grove Lane, Holt
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Ref: PO/14/0274 (referred to as Site 3) Residential development for a maximum
of 8 dwellings - Land to the north of Grove Lane, Holt.
Each application represents a departure from the current development plan in that all
three sites lie outside the development boundary for Holt. The Council will need to
reach a separate decision in relation to each application.
The case put forward in support of the applications is that with the benefit of planning
permission, the revenue received from the sale of the sites will go towards funding
new development and refurbishment improvements to the school.
The purpose of this report is to draw attention to recent planning history relevant to
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the current proposals and to address certain issues which are common to all three
proposals, namely:
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The case being put forward in support of the applications
The main planning policy implications of the proposals
Development viability
Proposed S.106 Obligation – Heads of Terms
In addition as part of considering the current planning applications officers have
sought Counsel‟s advice on a number of legal issues which are referred to in this
report. A summary of Counsel‟s advice is attached in Appendix 1.
Individual reports and recommendations for each application follow on from this
report.
The Case for Development put forward by the Applicants
As referred to above, the reason put forward in support of the three applications is to
provide funding for improvements at Greshams School. These specifically comprise:
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A new sixth form centre building (planning permission approved - 22 November
2013 - ref PF/13/1116)
Improvements to boarding facilities (both internal and extensions).
It is stated that the combined current cost of both of these projects is £9.541m
(£4.412m for the 6th form centre and £5.129m for the boarding improvements).
The applicants place great emphasis on the importance of these two projects for
ensuring the successful future of the school, citing in particular the following factors:
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Greshams School has existed for over 450 years and occupies a key position in
Holt's built form, its social history and local economy.
It is one of the top private schools in the country, providing education for children
between the ages of 3 - 18.
The school employs 375 people in Holt and is the town's largest employer
(including a £11m spend on wages)
The school contributes significantly to the economy of Holt.
Public consultation exercises show that the continued success of the school is
viewed as important locally.
The school contributes to the cultural life of North Norfolk.
Private education is a highly competitive market and the school cannot stand still
in such circumstances. It has to invest in new facilities in order to retain pupil
numbers in the short to medium term and to increase numbers in the longer term.
Compared to its competitors the school is in danger of falling behind in terms of
new facilities.
The school is unable to fund the necessary investments other than through the
sale of land for development.
A confidential Viability Assessment has been submitted in support of the applications.
The applicants claim this demonstrates that the sale of the three sites, plus a limited
amount of borrowing will just cover the £9.541m cost of the two projects along with
the associated legal, planning and master planning fees and the 10% promoter‟s
return. This is based on a maximum of 10% affordable housing being provided as a
proportion of the total number of dwellings proposed.
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Draft Heads of Terms (S.106 Planning Obligation) included with the applications
include the 'ring-fencing' of funds from the sale of the three sites towards the capital
works of the new 6th form building and boarding house improvements.
The applicants contend that securing the future of Greshams School is a significant
material consideration in determining the applications which outweighs the fact that
approval would represent a departure from current development plan policy.
In addition the applicants consider that the granting of permission in these cases
would assist the Council in rectifying a shortfall in the district‟s five year land supply.
A full version of the applicants' case („The Context for the Submission of the
Applications‟) is attached in Appendix 2.
Given that the principal reason put forward in support of these applications is to
provide funds to facilitate development and improvements at Greshams School it is
important to be clear on the legitimacy in planning terms of such „facilitating‟
development. The advice of Counsel (which is based on case law) is that the
provision of finance towards enabling other development can be material to the
determination of a planning application, provided that there is a relevant and
sufficient connection between the two developments, and that real public benefits will
flow from the linked development.
Relevant Planning History Background
Site 1 (ref: PO/14/0283) comprises an area of land (5.8 ha) of which a smaller portion
(4.0 ha) was previously promoted as a site for residential development as part of the
Draft North Norfolk Site Allocations Development Plan Document (DPD). Under draft
Policy H15 the site was proposed for approximately 120 dwellings. Subsequently,
following the public examination into the DPD, the Inspector in his report (December
2010) recommended that Site H15 be deleted in favour of another site in Holt (Site
HO1 land to the west of Woodfield Road). The Inspector concluded that "... H15's
peripherality to the town, its distance from the town centre, its inferior sustainability
score, and its lack of advantages in terms of both landscape impact and traffic and
transport considerations, make it an inferior choice compared with the similarly sized
but better located and more sustainable site HO1".
Regarding the rationale which was put forward for site H15 (which was in part its
potential financial contribution to the future of Greshams School), the inspector
commented as follows; " While no one doubts the longstanding and continuing
contribution of this famous school to the economy and life of the town, that does not
put it in a privileged position (vis a vis) other prospective developers) when seeking
planning permission for non-education related development".
In August 2010 an outline planning application was submitted by Greshams School
for residential development on Draft Allocation Site H15, but was subsequently
withdrawn following publication of the Inspector's report.
The adopted version of the Site Allocations DPD includes two sites for residential
development in Holt. These are:
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Site HO1 – Land west of Woodfield Road. (Outline planning permission granted
for up to 85 dwellings of which 45% are to be affordable dwellings).
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Site HO9 – Land at Heath Farm / Hempstead Road. An approved development
brief provides for up to 290 dwellings plus commercial / employment uses.
(Development Committee resolved on 17th April 2014 to grant outline planning
permission on a large part of the site for up to 215 dwellings of which 24% are to
be affordable dwellings).
The question arises as to the status of the Inspector‟s report with specific reference
to the determination of the current application on Site 1. Counsel has advised that the
binding report does not form part of the development plan, but is potentially relevant
as an “other material consideration” when reaching a decision in relation to the
current proposals. In short, the decision maker is not bound by the previous
comments of the inspector but should give them appropriate consideration (weight)
alongside the other considerations which are relevant to the determination of the
application.
Development Plan Considerations
Planning law requires that applications for planning permission must be determined
in accordance with the development plan unless material considerations indicate
otherwise. The development plan for North Norfolk comprises:
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The North Norfolk Core Strategy (adopted 2008), and
The North Norfolk Site Allocations Development Plan Document (adopted 2011)
As part of considering the current planning applications officers have sought
Counsel‟s advice with regard to the primacy of the development plan, specifically in
relation to the relevant policies on housing development. The advice received centres
around guidance contained in the National Planning Policy Framework (NPPF) and in
particular paragraph 14 which provides for a presumption in favour of sustainable
development. In relation to decision-making, this requires that proposals which
accord with the development plan should be approved without delay, and that
permission should be granted where the “development plan is absent, silent or
relevant policies are out-of-date”, unless “any adverse impacts of doing so would
significantly and demonstrably outweigh the benefits, when assessed against the
policies of this Framework taken as a whole".
The relevance of this to the determination of the current planning applications is that
if the Core Strategy housing policies are considered to be out of date then there is a
presumption in favour of granting planning permission provided that a proposed
development does not run contrary to the policies of the NPPF as a whole.
The Council's Core Strategy (2008) pre-dates the publication of the NPPF (2012).
The NPPF however makes it clear that the mere fact that policies in a local plan (I.e.
Core Strategy) were adopted prior to the publication of the NPPF does not mean that
they should be considered out of date (para. 211).
In April 2012 the Council‟s Planning Policy & Built Heritage Working Party considered
a report on the NPPF and its consequences upon the Core Strategy. Cabinet
subsequently agreed the Working Party‟s resolution that pending further
consideration of three specific policy areas the Council should continue to apply full
weight to the adopted Core Strategy policies. These policy areas did not affect the
principal housing policies relevant to the current applications.
It is considered therefore that the relevant Core Strategy policies in relation to
housing development in the district are not out of date and therefore the
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circumstances where departures from adopted policies might be justified in
paragraph 14 of the NPPF does not apply in the case of these applications. The
primacy of the development plan prevails and to quote the NPPF: "Proposed
development that accords with an up-to-date Local Plan should be approved, and
proposed development that conflicts should be refused unless other material
considerations indicate otherwise".
The following therefore is an assessment of the current applications in relation to the
housing policies of the Core Strategy:
Core Strategy Policy SS3 (Housing) spells out the Council's strategy to provide for
at least 8000 new dwellings during the plan period (2001-2021). In the case of Holt
700 new dwellings are proposed (also referred to in Policy SS9 – Holt). This figure is
to be achieved by a combination of past and existing planning permissions, future
windfall sites and land allocations.
To date 304 new dwellings have been built in Holt since the start of the plan period1.
The two allocations (sites HO1 and HO9) will provide up to a further 375 dwellings.
With the addition of windfall sites coming forward during the remainder of the plan
period and sites which already have planning permission but are yet to be built., it is
predicted that the 700 new dwellings in Holt by 2021 should be easily achieved,
without the addition of further large scale developments needing to come forward.
It is important to note that dwelling numbers which are included with the adopted
policies are expressed as minimums to be provided rather than upper limits which
should not be exceeded.
The sites subject to the current three applications are all outside of the development
boundary for Holt. They are situated in the 'Countryside' policy area. Core Strategy
Policy SS2 (Development in the Countryside) states that proposals which do not
fall within a specified list of development types which require a rural location will not
be permitted. The only types of housing developments which fall within this list are
'exception' affordable housing schemes and the re-use of existing buildings. Hence
the three applications do not accord with the development plan.
Notwithstanding the above or the case for Greshams School being put forward by the
applicants, it is important to focus on the fact that these are applications for housing
development and so they also need to be considered in terms of the key Core
Strategy housing policies.
Core Strategy Policy HO1 (Dwelling Mix and Type) requires on schemes of five or
more dwellings, at least 40% of the dwellings incorporate 2 bedrooms or fewer. The
purpose of this policy is to help re-balance a higher than average proportion of larger
house types in the district and to help meet the demand for smaller, more affordable
properties in all tenure types.
Although the current applications are in outline form with full details reserved for
future submission, in each of their supporting documents, a breakdown of the
expected house types is provided. As these are also included as part of the
submitted Viability Assessment it is both reasonable and relevant to consider the
issue at this stage. The viability has been based on 126 dwellings on Site 1, 19
dwellings on Site 2 and 6 dwellings on Site 3.
1
North Norfolk Residential Land Availability Statement 2014
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Site 1 is the only application to include properties with 2 or less bedrooms. 59 such
dwellings are indicated which corresponds to 46%, which more than meets the policy
requirement. Sites 2 and 3 however do not include any properties with 2 or less
bedrooms. Site 2 is exclusively for 4/5 bedroom units and Site 3 for 4 bedroom units.
Across all three sites, properties with 2 or less bedrooms represent 39% of the total.
Core Strategy Policy HO2 (Provision of Affordable Housing) requires on all
schemes of 10 or more dwellings or sites of more than 0.33 hectares, that not less
than 45% of the total number of dwellings are affordable (subject to viability). This
policy is applicable to all three applications. The applications fail significantly to
accord with this requirement with just 10% (i.e. 15 dwellings) being proposed as
affordable, with all of these being proposed on Site 1. The applicants contend that
any increase on this level would not provide the land sale value which they are
seeking to achieve.
Core Strategy Policy HO7 (Making the Most Efficient Use of Land) states that
residential developments should optimise the density of the site in a manner that
protects or enhances the character of the area. It goes on to state that densities in
main settlements should not be less than 40 dwellings per hectare. The proposed
densities of the three sites are as follows (dw/ha = dwellings per hectare):
Site 1 - 29 dw/ha (the developable area excluding a surrounding tree belt which
forms part of the application site).
Site 2 - 12.4 dw/ha
Site 3 – 12,5 dw/ha
Whilst to achieve developments of 40 dw/ha may be challenging in balancing the
efficient use of land with creating attractive and well-designed new communities (and
several recently approved major housing developments in the district have densities
more in the region of 30-35 dw/ha), the proposed densities for Sites 2 and 3 are
particularly low. In this respect the failure to comply with Policies HO1 and HO7 are
inter-related.
Development Viability
As referred to above a confidential development viability report has been submitted in
support of the applications. The applicants have provided an Executive Summary of
their viability report which is attached in Appendix 3. The report does not however
adopt the conventional approach to assessing development viability. Specifically it
does not accord with guidance provided by the Royal Institute of Chartered
Surveyors guidance or the guidance which accompanies the NPPF relating to how
land values should be established as part of considering development viability.
In brief, a conventional development viability report will firstly assess all the costs
involved in completing a housing development. These costs will in the main include
construction, infrastructure, exceptional costs (such as land de-contamination), fees
and S.106 contributions. Secondly an assessment will be made of sales values of the
completed dwellings. A „residual‟ land value is then calculated by deducting the costs
(which will also include a developer profit) from the total sales value.
Issues often arise when the residual land value is below a level which the landowner
is willing to sell. In these circumstances a developer will look at ways in which to
reduce costs and increase values. This is usually the point when the developers will
look at reducing the proposed amount of affordable housing provision and will submit
a viability assessment in an attempt to justify this. In such circumstances the local
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planning authority should be satisfied that the submitted viability report accurately
reflects the financial variables of the development, is reasonable in terms of land
value and developer profit, and does not unreasonably prejudice the level of
affordable housing provision and other community related contributions.
The significant difference with the viability report submitted with these applications is
that the land value has been set as a starting point to reflect the costs associated
with the building of the new sixth form centre (£4.412m) and refurbishment of the
school boarding facilities (£5.129m). The need to generate this level of land value
with the addition of planning fees, legal fees (£0.49m) and a 10% promoter‟s return
(£1.03m), has resulted in a viability assessment which shows that it is only viable to
provide 10% of the proposed number of dwellings as affordable dwellings.
The Council has commissioned an external consultant to comment on the submitted
viability report. The conclusions reached are as follows:
 The sales values used for the proposed market dwellings are too cautious.
 The agent fees were out of kilter with the market.
 The planning and master planning fees are high in relation to what would be
expected.
 The promoter‟s fee of 10% of the net land value (after planning, master planning
and legal fees are deducted from the receipt from the sale of the three sites) is
not a standard cost.
 Increasing the sales values increases the land value as a result there should be a
strong argument to increase the percentage of affordable housing. Allowing for
45% social (affordable housing), would provide a positive capital receipt to the
land owners – notwithstanding the specific issues relating to Gresham‟s School
and their requirement to build new teaching and housing blocks.
Subsequently following this initial consideration of the viability, the applicant
submitted a revised viability assessment which increased the sales income to reflect
sales values at June 2014 and also updated the build costs to reflect costs at June
2014 as the original viability assessment had used build costs for June 2013. The
external consultant has commented further as follows:
 There remain issues with the planning and master planning fees.
 The achieved land value is favourable for its location.
 The promoter‟s return of 10% is not unrealistic.
It should be noted however, that in using a promoter, a land owner would expect their
return from the sale of the land to be reduced by the promoter‟s return, as the
promoter has taken on the risk of not securing planning consent. In this case, the
methodology used for the calculation of the land value, includes the promoter‟s return
as a cost which the receipt from the sale of the land must cover and has served to
increase the receipt which is required to be received.
It is clear that the most notable factor affecting the viability of the three sites to
provide more than 10% affordable housing is the land value, which is considered to
be significantly higher than if a standard methodology for assessing land value had
been used.
For a further commentary on the viability issue the committee‟s attention is drawn to
the comments of the Council‟s Housing Team Leader - Strategy in each of the
application reports.
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Five Year Land Supply
The National Planning Policy Framework (NPPF) confirms that proposed
development which accords with an up-to-date plan should be approved, and
proposed development which conflicts should be refused unless other material
considerations indicate otherwise. Where a development plan is out of date the
NPPF requires that development proposals should be approved unless the adverse
impacts of doing so would significantly and demonstrably outweigh the benefits or the
proposals would be contrary to the policies of the NPPF. The guiding principle of the
NPPF is that there should be a presumption in favour of sustainable development.
The NPPF states that relevant policies for the supply of housing should not be
considered up-to-date if the local planning authority cannot demonstrate a five-year
supply of deliverable housing sites. In other words there is a presumption in favour of
approving applications for housing development where there is an absence of a five
year land supply and where the proposals represent a sustainable form of
development.
The applicant‟s Planning Statement refers to the Council‟s published Statement of
Five Year Land & Housing Trajectory (April 2013) which indicated a supply
equivalent to 4.68 years. On this basis it is contended that the Council should be
granting planning permission to make up this shortfall.
However the Council has recently published its Statement of Five Year Land &
Housing Trajectory as of April 2014. This demonstrates a supply equivalent to 5.4
years. The Council has obtained legal advice from Counsel confirming that the
relevance of the five year land supply position should be considered at the time of
determining a planning application rather than at the time of the application‟s
submission. On this basis it is not considered that there is currently a case to be
made in terms of five year land supply, for the Council to permit new housing
developments which do not accord with the development plan.
Section 106 Heads of Terms
The applicants have submitted draft heads of terms for a S.106 Obligation in the
event of all three applications being granted permission (see Appendix 4).These
include financial contributions towards the following:
Education
Libraries
Health Service
Visitor pressure mitigation
Travel Planning
Local „hopper‟ bus service
Bus shelter maintenance
Off-site public open space
Also included would be an obligation to „ring fence‟ funds received from the land
sales towards the capital works for the sixth form academic block and the boarding
house refurbishments. This would be after deduction of the costs of obtaining
planning permission and 10% promoters return. The monies are to be spent on these
projects within 5 years.
With reference to the provision of affordable housing the following terms are
proposed:
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1) Timed phasing of the 10% affordable dwellings on Site 1 during that site‟s
development.
2) An „uplift‟ clause specifying that in the event of there being a surplus of funds
from the final sale of land (i.e. not spent or committed on the capital works) this
would be split 50/50 between affordable housing provision and bursaries for local
children to attend Greshams School.
3) An additional „uplift‟ clause to provide a share of any gross development value
uplift in the event of an overage mechanism agreed through land sales.
4) A requirement to ring fence money from the sale of Sites 2 and 3 equivalent to
the value of providing 3 affordable dwellings until a similar number of affordable
dwellings are delivered on Site 1. If after a (unspecified) period the 3 dwellings
have not been delivered on Site 1, the monies to be paid to the Council for
affordable housing elsewhere in the district.
With reference to the above it should be made clear that (2) does not represent the
normal form of development uplift as it is related to land sales as opposed to
completed development sales. Whilst there is always a risk that uplift clauses linked
to development sales will not deliver any funding towards affordable housing, this risk
is increased with the form of uplift clause being proposed. Similarly with (3) the
likelihood that this would bring forward any funding towards affordable housing is
questionable.
Summary and Conclusions
The three planning applications under consideration all represent departures from the
development plan. They depart from the plan not only in terms of their location but
also with regard to key policies on the type and mix of housing development
proposed, in particular with regard to the provision of affordable housing.
Putting aside their location and momentarily supposing that the sites were allocated
for residential use, it is more than likely that the applications would be recommended
for refusal in view of the method of development viability used and the consequent
significantly low proportion of affordable housing being proposed. This under
provision is highlighted in comparison with what has been proposed elsewhere in the
district and on the two allocated sites in Holt in particular.
Because the development plan is regarded as up to date in relation to housing
policies the presumption is that planning permission should be refused, unless there
are material considerations to justify the grant of permission.
The material considerations which can be taken into account in determining the
applications are:
 The inspector's 2012 report with reference to site 1
 Any public benefits perceived to arise from the facilitating development
 Policies of the NPPF where they are relevant to the proposed development
 Any other considerations relating to the use and development of land in the
public interest
The key issue is what level of weight should be attached to each of these material
considerations, bearing in mind that they do not all pull in the same direction. The
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weight to be attributed to a material consideration is entirely for the decision maker
(subject to a possible challenge through the courts). Advice from Counsel is that the
Council may reasonably attach weight to the facilitating development case but in
doing so this should be assessed in terms of the real public benefits which will flow
from the linked development.
The view of officers is that first and foremost these applications are for housing
development and the primary consideration should therefore be that they are
assessed on this basis. Whilst weight may legitimately be attached to the facilitating
development argument, it is considered that, as proposed, there is an imbalance
between the interests of the school against the housing policies of the development
plan and the overall public interest which should reasonably flow from housing
developments of this nature.
PLANNING APPLICATIONS
2.
HOLT - PO/14/0283 - Residential development for a maximum of 126 dwellings;
Land South of Cromer Road and East of Grove Lane for Endurance Estate
Strategic Land Ltd and Gresham's School
Major Development
- Target Date: 10 June 2014
Case Officer: Mr J Williams
Outline Planning Permission
CONSTRAINTS
Countryside
C Road
Within 60m of Class A road
Controlled Water Risk - Medium (Ground Water Pollution)
Archaeological Site Public Rights of Way Footpath
RELEVANT PLANNING HISTORY
PO/10/0921 PO
Residential development
Withdrawn by Applicant 07/12/2010
THE APPLICATION
The application is to develop an open field which is surrounded on two sides by a
substantial woodland belt (5.8 ha. in total). The only detail applied for at this stage is
for access.
The site which is triangular in shape borders Cromer Road to the north and Grove
Lane to the west. The woodland belt extends the whole of the Cromer Road frontage
and over half of the Grove Lane frontage. The site's curved south/eastern boundary
backs onto the A148 (Holt by-pass) and land which is reserved for the potential
extension of the North Norfolk steam railway.
Vehicle access is proposed from approximately midway along the Cromer Road
frontage. A new 1.8m wide footway is proposed between the site entrance and the
junction of Cromer Road with Grove Lane. Further sections of new footway would
extend further along Cromer Road to connect with an existing footway leading
towards the town centre and along Grove Lane. 'Build-out' features are also
proposed on Grove Lane intended as traffic calming measures.
An indicative layout plan submitted with the application shows an estate style layout
of 126 dwellings. The dwellings are based on a mix of 16 one/two bedroom
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apartments, 42 two bedroom houses/bungalows, 38 three bedroom
houses/bungalows and 29 four bedroom houses. Small pockets of public open space
are indicated within the housing development and the surrounding woodland belts
are proposed for public access. Two points of pedestrian / cycle / emergency vehicle
access are shown linking with Cromer Road and Grove Lane respectively.
Amended plans have been submitted with references to 'no dig' methods of footpath
construction to protect tree roots.
The applicants have confirmed in writing that the following financial contributions are
being offered by means of a S.106 Planning Obligation:
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SPA/SAC visitor pressure
Bus shelter maintenance
Off-site public open space
Healthcare (NHS)
Education
Libraries
Hopper bus service
Travel Planning
- £50 per dwelling
- £7,500
- £51,000
- £44,200
- £383,566 (approx)
- £60 per dwelling
- £35,000
- £20,000 (max)
The application is supported by the following documents:
Air Quality Assessment
Arboricultural Impact Assessment
Archaeological Assessment
Design and Access Statement
Ecological Appraisal
Reptile Survey
Bat Survey
Energy Assessment
Flood Risk Assessment
Services Report
Heritage Statement
Noise Assessment
Planning Statement
Statement of Community Involvement
Site Waste Management Report
Ground Investigation Report
Transport Assessment
Sustainable Travel Report
Travel Plan
Cost Models for school capital works
Viability Assessment (confidential)
REASONS FOR REFERRAL TO COMMITTEE
The application is a significant major development which represents a departure from
current policy. A Committee site visit was held on 8th May.
TOWN COUNCIL
Supports with the following conditions: That the number of low cost properties i.e affordable homes is negotiated and
increased
 Town Centre car parking is introduced. As a number of these new householders
could potentially drive to Holt, car parking must be made available i.e extend the
parking at Greshams Old School House.
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A contribution to the 'hopper bus' to encourage residents to use this facility.
Grove Lane is made access only, to allow residents and their visitors usage of
the road, but restrict other traffic which should complement the proposed pinch
points.
To address the problem of the second half of Grove Lane having no
pavement. NCC recently withdrew the scheme to make a footway at this point,
but we feel some measures must be introduced, preferably a footway, or some
other scheme to protect pedestrians.
That the maximum number of dwellings on this site should never exceed 126
properties
That the development should create new, safe and accessible environments
which are visually attractive as a result of good architecture and appropriate
landscaping.
That the clustering of low cost (affordable) properties as illustrated on the
indicative layout is avoided and that they are integrated throughout the site
That the indicative additional tree line shown running between the site and the
proposed Orbital Railway Line and Holt bypass should be substantially increased
to provide a belt of appropriate landscaping to screen the site and act as a noise
barrier.
Consideration of a care home facility on this site
Street lights on Cromer Road leading down to Station Road
Street lights as required on Grove Lane
REPRESENTATIONS
39 letters of objection received which are summarised as follows:
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Contrary to the development plan.
The suitability of the site for housing has previously been rejected by a
government inspector and there have been no subsequent changes in
circumstances.
The funding of Greshams School should not be a planning consideration and
should not influence local housing decisions.
The needs of Greshams School should not override the legality and merits of the
application in planning terms.
Modernisation of Greshams School should not be to the detriment of the local
community.
The housing growth for Holt as identified in the Local Development Framework
has been satisfied by the two allocated sites in the town. Any further development
should be based on a particular need and adequate infrastructure to support it.
Need should be related to housing, not to achieve substantial private profit.
Inadequate local infrastructure to cater for additional housing (e.g. schools,
doctor's surgeries, car parks and sewage treatment).
Holt has no secondary school and limited capacity at the primary school.
Unsustainable development for Holt in terms of state schooling, health provision,
local employment, transport and recreation.
Lack of local employment opportunities to support additional housing.
The housing is not planned for local people.
Would result in the over-development of the town.
Loss of farmland, woodland and open green space.
Site is detached from the town and would result in an isolated estate.
Site not within reasonable walking distance to the town centre.
Site is remote from the town centre and primary school and would result in
dependence on car use.
Would exacerbate Holt's parking problems.
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Adverse effect upon character of Holt.
Represents urban sprawl.
The attractive surroundings to Holt are important to retain.
Development would be visible from the Holt bypass.
Would join up Holt and High Kelling, changing their identities.
Adverse impact upon local flora and fauna.
Local traffic safety.
Grove Lane is unsuitable to cater for further traffic.
Would lead to increased traffic using Grove Lane as a 'rat run', which has a lack
of continuous footpaths, resulting in a danger to pedestrians.
Proposals assume footpath improvements to southern side of Grove Lane by
Norfolk County Council, which have now been cancelled.
Footpaths along Cromer Road are in many places narrow.
Misleading statements made about local services available - Greshams School
(private), Holt railway station (tourist), Kelling Hospital (mainly rehabilitation).
Site better suited for employment or mixed use related development.
Understand that the number of additional houses required for Holt has already
been met.
30 signed copies of an identical letter received. The letter objects to the application
on the following grounds:
 Over-development - site not allocated in the Local Development Framework.
Would be larger than many Norfolk villages without any additional public services
to make it sustainable.
 Inspector's decision - The 2010 decision by the Government Inspector made it
clear that safeguarding Greshams School was not a planning consideration.
 Local identity - The development would join up Holt with High Kelling, changing
the identity of the local area for ever. Road features to Grove Lane would change
its semi-rural nature.
 Sustainability - Not sustainable in terms of state schooling, local employment
opportunities, transport and recreation. Site is remote from the town centre and
local services. Would increase dependency on the car.
 Road safety (Grove Lane) - Increased use as a rat run. Lack of footpaths /
pedestrian safety.
 Green space - Loss of.
Letter received from the RSPB objecting to the application on grounds that the
potential for recreational impacts on the North Norfolk Coast SPA/SAC and Ramsar
site has not been assessed. Quote:
"The Appropriate Assessment (AA) of the Site Allocations DPD concluded that
Adverse Effects on the Integrity (AEOI) of these sites as a result of increased visitor
pressure from housing developments could not be ruled out without a scheme of
mitigation in place. As a result, all housing allocations in the Holt area have a
requirement for a scheme of mitigation in the relevant policies of the Site Allocations
DPD. The RSPB consider that it is not possible to demonstrate that there is no AEOI
from this site in combination with those in the Site Allocations DPD, and that a
scheme of mitigation should therefore be required for this site." The letter concludes
by recommending that an Appropriate Assessment is carried out, and that "prior
approval of a scheme of mitigation" will be required.
CONSULTATIONS
Anglian Water - Confirms that there is at present available capacity in the foul
sewerage network and at Holt Sewage Treatment Works to cater for the
development.
Requests a surface water drainage strategy is conditioned in the event of planning
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approval.
Environment Agency - No objection in terms of flood risk issues, subject to a
condition requiring the submission of a surface water scheme to be submitted with
any applications for reserved matters.
In terms of sewage disposal comments as follows:
'Under the Water Framework Directive (WFD) both the Agency and local authorities
have a duty to ensure there is no deterioration of a watercourse, in this case the
River Glaven which currently has ‘very good’ status. To be compliant with the
Directive a scheme must not cause deterioration in a waterbody’s status or prevent
its achievement of good ecological status in the future.
The additional loading on Holt Sewage Treatment Works from this and other new
developments within the catchment may individually or cumulatively necessitate
Phosphate removal at the works in order to maintain the very good status of that
waterbody. As such there may be an issue with accommodating the full quantum of
growth proposed for Holt in the LDF over the longer term. This site was not allocated
in the LDF and so these housing figures could be over and above those considered
at that time - these extra houses could therefore limit the number of allocated houses
that can be built.'
Recommends a condition requiring that no development shall begin until a report
demonstrating that there is sufficient foul water capacity for the development has
been submitted and approved by the local planning authority. Where necessary the
report should include a scheme for improvement of the sewerage system and the
condition should require that no dwellings shall be occupied until the scheme as
approved has been implemented.
County Council (Highways) - No objection subject to a number of conditions
including the prior submission and approval of detailed plans for both on-site and offsite highway works, as well a financial contribution towards future maintenance of the
proposed bus shelter to be secured as part of a S.106 Obligation.
County Council (Planning Obligations Co-Ordinator) - Requires the following
financial contributions to be secured via a section 106 Obligation:
£465,760 towards primary education (a combined sum relating to Sites 1,2 & 3).
£2,676 for 4 fire hydrants
£60 per dwelling for library provision.
County Council (Minerals and Waste) - No objection subject to a condition
requiring the prior submission and approval of a Materials Management PlanMinerals (MMP-M), the purpose of which will be to establish the extent to which onsite materials which could be extracted and used during the course of development.
County Council (Historic Environment Service) - If planning permission is
granted, requests a condition requiring an agreed archaeological investigation to be
undertaken on the site.
County Council (Public Rights of Way) - Holt footpath no.9 is within the
development site. The submitted plan states that the short east-west section of this
route from Grove Lane into the proposed development is to be a shared pedestrian
and cycle access. As this is designated as a public footpath, there is no public right
for cycling on this section. The status of this short section of the footpath will need to
be appropriately upgraded to accommodate cycles.
The north-south section of footpath currently has unobstructed views eastwards
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across the field. This view will be restricted by the development, and presumably by
fences at the rear of the houses. It is not clear from the plans how wide the area with
the public footpath will be between the existing hedge and the rear gardens. The
width will need to be discussed with a public rights of way officer .
NHS England (NHSE) - Raises a 'holding objection'.
Comments that: "a residential development of up to 126 dwellings is likely to have a
significant impact on the NHS funding programme for the delivery of healthcare
provision within the local area, and specifically within the health catchment area of
the development. NHSE would therefore expect these impacts to be fully assessed
and mitigated by way of a developer contribution secured through a Section 106
planning obligation. The planning application does not include an assessment of the
likely healthcare impacts arising from the proposed development. A Healthcare
Impact Assessment (HIA) has therefore been prepared by NHSE to provide the basis
for a developer contribution towards capital funding to increase capacity within the
GP Catchment Area".
On the above basis NHSE request that a developer contribution of £44,200 should
be secured by a S.106 Planning Obligation. This calculation is based on an optimum
capacity of 1800 patients per GP. There are currently 8 GPs at the Holt practice
equating to an overall optimum capacity of 14,400 patients. This number is currently
exceeded by 163 patients and the additional estimated number arising from 126 new
homes is a further 312 patients. The sum of £44,200 equates to the addition of 0.17
of a GP and 22.1 sqm floorspace to respond to this additional demand.
Environmental Health - Recommends conditions in respect of surface water,
sewage disposal, noise insulation measures (traffic noise) and land contamination.
Strategic Housing Comments relate to the three applications submitted on
behalf of Greshams School and the single submitted development viability
assessment:
There is a need for affordable housing in Holt with 100 households on the Housing
Register and in addition there are a further 109 households on the Transfer Register
and 646 households on the Housing Options Register who have stated that they
require housing in Holt. The proposed development would therefore assist in meeting
some of the proven housing need.
It is noted that all three sites are outside of the settlement boundary for Holt. The
applicants are seeking planning permission on the basis that a material consideration
is the need for Gresham‟s School to expand its education provision and the
associated benefits to the economic prosperity of Holt of this.
The submitted viability assessment adopts a non-standard approach, as the land
value used in the viability assessment reflects Gresham‟s School‟s requirement that it
receives a receipt from the sale of the three sites which will fund (with some
borrowing) the construction of a new sixth form academic block (£4,412,000),
improvements to its boarding houses (£5,129,000) and the costs of planning, master
planning, legal costs and the promoters fee, totalling £11,062,215. The need to
generate this level of land value has resulted in a viability assessment which shows
that it is only viable to provide 10% of the proposed number of dwellings as
affordable dwellings. The approach taken to the assessment of what is an
appropriate land value for the three sites conflicts with the Royal Institute of
Chartered Surveyors guidance and Planning Practice Guidance on financial viability
in planning on how land values should be established.
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The proposal that the affordable housing is only be provided on site 1 is reflective of
the desire to maximise the land value across all three sites.
Gresham‟s School has stated that they are not able to borrow to fully fund the cost of
the construction of the sixth form block and improvements to boarding houses and
are only able to borrow part of the cost.
A review of the financial information
submitted by Gresham‟s School in the viability assessment has concluded that
school can only borrow a proportion of the costs of the proposed works.
The submitted viability assessment was considered internally and by an external
consultant. The initial consideration of the submitted viability by the external
consultant showed that:
 The sales values used for the proposed market dwellings are too cautious.
 The agent fees were out of kilter with the market.
 The planning and master planning fees are high in relation to what would be
expected.
 The promoter‟s fee of 10% of the net land value (after planning, master planning
and legal fees are deducted from the receipt from the sale of the three sites) is
not a standard cost.
 The land value can increase and there should be a strong argument to increase
the percentage of affordable housing. Allowing for 45% social (affordable
housing), would provide a positive capital receipt to the land owners –
notwithstanding the specific issues relating to Gresham‟s School and their
requirement to build new teaching and housing blocks.
It was therefore clear that all of the factors identified above are impacting negatively
on the viability of the three sites and the amount of affordable housing which they can
support. In addition there was concern that site 3, which the outline application
proposes is developed to provide up to 8 dwellings was not maximising the value of
this site. 6 larger dwellings would be more beneficial to the viability.
These views were discussed with the applicant who subsequently submitted a
revised viability assessment to reflect the sales values identified by the external
consultant. As these sales values reflected values at June 2014, the applicant also
updated the build costs within the viability assessment to reflect build costs at June
2014, as the original submitted viability assessment used June 2013 build costs. In
addition site 3 was amended to reflect 6 larger dwellings and the total number of
dwellings across the three sites reduced to 151. The revised viability assessment
however, still showed that it was only viable to provide 10% of the total number of
dwellings as affordable (15 dwellings).
The external consultant has considered the revised viability assessment and stated
that:
 The promoters return at 10% is not unrealistic to reflect the risk associated with
the scheme and the uncertainty that planning consent will be granted.
 Further clarification is needed of the planning and master planning fees which are
excessive.
 The increase in build costs has countered the increase in sales values, however,
the achieved land value per acre is favourable for its location.
 The argument put forward is looking at viability in reverse, as X {the cost of the
works and associated costs - £11,062,215} is needed to make it work. If the
school had no capital expenditure to make, the discussion would be different.
It should be noted, that whilst the promoter‟s fee at 10% of the net land receipt is not
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considered to be unrealistic, in normal practice this fee would be deducted from the
landowner‟s receipt for the land and so would reduce the return they receive. This is
not the case here. The sum the applicants need to achieve from the sale of the three
sites has been calculated as the cost of the proposed works to the school plus the
planning, master planning and legal fee and the promoters return. Therefore, the
total sum needed to be received from the sale of the three sites has been increased
by the requirement to pay the promoter‟s return of 10% of net land value. The
revised viability assessment shows that with 10% affordable housing, this sum is
almost achieved, leaving only a small amount which the applicant would need to fund
through a loan.
It is clear that had a standard approach been used in the viability assessment to the
value of the land for each of the three sites that it would be viable to provide more
than 10% affordable housing or 15 out of 151 new dwellings. The fact that
Gresham‟s School require such an extensive receipt from the sale of the site has
significantly affected the viability of these sites. In addition the issue around the
planning and master planning costs and the promoters return are contributing to the
viability issue. If a standard approach to the valuing of these three sites had been
used, it would be viable to provide more affordable housing.
It is proposed that if these three sites are granted planning permission, that there will
be a Section 106 Agreement which will contain an uplift arrangement to provide for a
possible contribution for affordable housing. The proposed uplift arrangement is not
the standard affordable housing uplift which the Council has used elsewhere.
Affordable housing uplifts are used where the Council has accepted a lower
percentage of affordable housing due to viability issues at the point of application in
order to capture any increase in viability once the site is developed. The Council‟s
standard wording captures increases in viability due to changes in costs and
increases in the sales values achieved for the completed market dwellings where this
results in more profit for the developer. The proposal for the three sites is instead,
that the receipt from the sale of the three sites will be placed into a ring fenced pot for
the works to build a sixth form college and remodel the boarding houses. After 5
years from the receipt of the final payment, the applicants will submit a viability
statement showing how the land receipt has been spent on the works and associated
on costs. Any funding left over would then be split 50/50, with the Council receiving
50% up to a cap of £2,000,000 for affordable housing and the remaining 50% being
used to support bursaries for local people to attend Gresham‟s School. This
proposal would limit the uplift available for a financial contribution for affordable
housing, as it is dependent on an increase in the receipt from the sales of the three
sites beyond what is shown in the viability assessment as required. In addition the
ability to receive a payment for affordable housing would be dependent on the costs
of the construction of the sixth form college and improvement works to the boarding
houses not increasing above the cost currently shown by the applicant. There is
always a risk that the Council will not receive any funding for affordable housing
through the operation of an Affordable Housing Uplift, however, the proposed
arrangement for this site does increase that risk as the uplift does not relate to the
costs of the development of the site, but instead to the land receipt and costs
incurred by the applicant on works to Gresham‟s School.
The applicants have also offered an additional affordable housing uplift clause which
would enable a share of any uplift in the sales income from the completed dwellings
to be provided to the Council. The share the Council would receive is not stated and
the exact detail of what is proposed is not known. However, this offer is reliant on the
applicants negotiating the inclusion of this clause as part of the sale of the three sites
with the purchaser(s). It is therefore, not possible to comment on whether this would
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be a more acceptable uplift clause to the Council or whether this would increase the
likelihood of receiving monies to provide additional, offsite, affordable housing.
To conclude, assessment of the original and revised viability assessments has
shown that the viability of the site has been constrained by the non-standard
methodology used to establish the land values for the three sites and has resulted in
a lower level of affordable housing than it would otherwise be possible to provide.
The applicant‟s proposal for an affordable housing uplift is again non-standard and
would increase the risk that the Council would not receive a financial contribution for
affordable housing. Strategic Housing therefore objects to the approval of the
planning applications as they will not deliver the viable amount of affordable housing.
Conservation, Design Officer - No substantive comments at this stage on the
basis that the proposed development would; a) not impact upon any designated
heritage assets, and b) is in outline form with only access to be considered.
Nonetheless makes the following two points:
1. If the illustrative layout is intended to be a demonstration that any future scheme
would be locally distinctive and provide a strong sense of place, it appears less than
successful in its aims. Instead, the impression given is of a fairly conventional
suburban layout with rows of standard house types laid out in less than imaginative
ways.
2. As existing, Cromer Road marks the transition out of the town into the
countryside. It therefore seems rather unfortunate to introduce a new footway all the
way along the southern side of the road. Particularly with alternatives available on the
northern side of the road and within the boundaries of the site, the further
suburbanisation of this rural route is not something that should be encouraged.
Landscape Officer - Comments are divided into four issues: landscape/visual
impact, trees (arboriculture), ecology and cumulative impact:
Landscape and Visual Impact
The site lies within the „Wooded with Parkland‟ landscape as defined in the North
Norfolk Landscape Character Assessment. Any development in this location should
seek to retain the wooded character which is so distinctive of this part of Holt. This
woodland edge to the town reflects its Anglo-Saxon origins (the word Holt means
„wooded‟). The proposals appropriately retain the 40m wide woodland strip along the
north and west boundaries of the site.
The illustrative layout proposes a high density settlement that is not typical of this
part of Holt.
The tree and shrub belt along the southern boundary would require substantial
enhancement and widening if it is to provide an effective visual and noise screen
from the by-pass. A lower density allowing for much more tree and shrub planting
within the site reflecting the mature woodland surrounds and a higher proportion of
open space would be a more appropriate solution.
The proposed footway along Cromer Road will reduce the semi-rural character that
typifies this part of the outskirts of Holt. It will probably require the removal of trees.
Given that there is an existing footway on the other side of the road, the requirement
for another footpath is questioned.
Arboricultural Issues
The proposed access off Cromer Road will require the loss of a number of trees.
Given the density and extent of the mature woodland belts making up this site, this
loss can be accommodated, so long as there is extensive replacement planting within
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the whole scheme.
The area within the woodland proposed for the public open space does give rise to
concern. This will inevitably necessitate the loss of more trees in a prominent part of
the site where the mature woodland presently provides important and effective
screening. It is suggested that the open space could be accommodated elsewhere
within the site, perhaps adjacent to the inner edge of the woodland belt, providing a
part wooded, part open public landscape.
The loss of trees from the woodland belt would have to be mitigated by substantial
planting within the proposed development. This would be an opportunity for the
developer to provide a quality scheme that would blend in with the surrounding area.
In the event of outline planning permission being granted, any subsequent detailed
application would need to include an updated arboricultural method statement, a long
term management plan and details of supporting funding for managing the northern
tree belt as recreational open space, plus a landscaping plan with details of
establishment and longer term management.
Ecological Issues
The application is accompanied by an Ecological Appraisal, a Bat Survey, and a
Reptile Survey. The reports have been prepared by qualified ecologists in
accordance with recognised standards and procedures.
The Ecological Appraisal indicates that the strip of plantation woodland on the
Cromer Road (and to a lesser degree Grove Lane) has the greatest ecological value
on the site. The woodland has significant potential for bats (specifically Barbastelle)
as both a roosting location but also for commuting and foraging. The grassland holds
some potential for reptiles.
The Bat Survey report records a variety of six species of bat using the woodland for
foraging and commuting. The report concludes that the trees within the woodland
area affected by the proposed access route did not at the time of survey hold any
significant bat roosts (i.e. maternity colonies). However, the transient nature of the
species means that it remains a possibility that an individual tree could potentially
have a roost at any given time.
The importance of the woodland belt along the Cromer Road for foraging bats is
significant. Some foraging activity was observed along the northern side of the belt
(under the canopy alongside the road), whilst other foraging activity was observed to
the south of the belt up to 20m into the field. There is the possibility that by opening
up the woodland canopy (creation of the access road and open space) the activity of
the bats will be disrupted. However, the report suggests that most bat species will
habituate to small gaps if left unlit.
Barbastelle bats are particularly sensitive to light and are locally listed as a Priority
Species; therefore mitigation will be required to ensure that the site remains an
attractive foraging and commuting area for them. The report recommends that no
artificial lighting is directed towards the woodland belt along the west and northern
boundaries. In addition the report recommends that no artificial light is used to
illuminate the new access roads and that excessive light spill from the new dwellings
is kept to a minimum.
Whilst such mitigation measures are in theory possible, the indicative layout leaves
very little room for a buffer strip to be provided along the woodland belt to the north.
A marginal strip of land adjacent to the woodland is shown to be given over to an
access road, which is likely to be required to be lit for safety reasons. Therefore the
recommended levels of light reduction would not be achievable on the basis of the
indicative layout. If the number of dwellings were reduced then it may be possible to
develop the site without impacting upon bats using the woodland. Otherwise it is
considered that it would be difficult to conclude that the development would achieve a
net gain in biodiversity as per the requirements of the NPPF.
The site is within 1.5km of the Holt Lowes Site of Special Scientific Interest (SSSI)
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which is part of the Norfolk Valley Fens Special Area of Conservation (SAC) and just
over 5km from the North Norfolk Coast Special Area of Conservation (SAC) and the
North Norfolk Coast Special Protection Area (SPA). These sites are under extreme
pressure and risk of disturbance from increasing numbers of visitors, which is having
a negative impact on some of the conservation interests of those sites. As the
proposed development is not located on one of the site allocations in the Local
Development Framework it has not previously been subject to a Habitats Regulations
Assessment. Accordingly an Appropriate Assessment has been undertaken by the
Council (as a 'competent authority' under the Conservation of Habitats and Species
Regulations 2010) in respect of the current proposals.
The Appropriate Assessment has concluded that the proposed development would
not adversely affect the integrity of the Norfolk Valley Fens SAC; however, without
mitigation, the development would adversely affect the integrity of the North Norfolk
Coast sites. The applicants are offering a financial contribution towards a scheme of
monitoring and mitigation to minimise impacts on the North Norfolk Coast SPA/SAC
arising as a result of increased visitor pressure, similar to that achieved on sites
which have been allocated for residential development. This together with on-site
comprehensive green infrastructure/public open space, will ensure that adverse
effects on the integrity of the North Norfolk Coast sites are avoided.
Cumulative Impact
This is one of three sites proposed for residential development in close proximity to
one another. Their combined cumulative effect will be extend the built form of the
town eastwards into its woodland setting.
Given that these sites are all outside the defined settlement boundary and are
therefore contrary to policy, there should be greater design emphasis than that
already demonstrated on retaining the „edge of town‟, woodland character and thus
to minimise the „suburban‟ effects of the three adjacent developments.
Natural England - Initial comments received referred to the proximity of the
proposed sites to both national and international designated habitat sites which are
afforded protection under the 'Habitats Regulations', namely the Holt Lowes Site SSSI (national) and the North Norfolk Coast Special Protection Area (international),
and the issue of visitor pressure from new residential developments which may
impact upon the sensitivity of these sites. The advice received was that it is not
possible to conclude that the proposals are unlikely to result in significant effects
upon these sites. Accordingly Natural England advised that the District Council
should not grant permission before, in its role as competent authority under the
Habitats Regulations, it has received sufficient information to screen the proposals
for the likelihood of significant effects.
Following the applicants subsequent response and offer to contribute £50 per
dwelling towards a scheme of mitigation for impacts upon these sensitive sites in
combination with those of allocated sites within the wider area Natural England have
commented as follows:
"I have reviewed the documents that the applicant has provided and am pleased with
the approach that they have taken. It is my view that it is still not possible to
determine no Likely Significant Effect at the initial stage of Habitats Regulation
screening; whilst we accept that the application is only a relatively small proportion of
development planned for the District, recreational disturbance and therefore its
effects are a cumulative issue. Whilst it is for you as the competent authority to
determine whether or not you have the information needed to complete a Habitat
Regulations Assessment, my advice is that the proposed mitigation is likely to be
sufficient to enable a conclusion of no adverse effect on integrity to be reached. I
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would suggest, should you be minded to grant consent, that you include an
appropriately worded planning condition (and possibly S1.06 agreement) which
ensures the mitigation measures, including the contribution towards delivery of
strategic green infrastructure are secured."
Countryside and Parks Manager - Advises that a development of 126 dwellings
generates an open space requirement of 0.92ha. This requirement is satisfied as the
developers are proposing about 1.3Ha if both the woodland and open space land
within the development is included.
In terms of children's play provision the areas indicated within the development itself
are too small. Play areas need to be of sufficient size to allow recreational use
without adjacent residents being inconvenienced through noise and disturbance
generated by users. As the development proposes few affordable houses (and as
such there will be low numbers of children), it would make sense for an off-site
contribution to be made rather than implementing play provision on-site. The 126
dwelling site would generate a contribution of £51,000 which could be used in
improving the Peacock lane recreation ground and play area in Holt.
The Council‟s approach to the future management and maintenance of public open
space relates to its likely future use. Where open space is of benefit to the new
residents only, then the Council would not normally adopt the land. Where the open
space has a greater potential use in that it would provide an amenity and resource for
the wider community, then the Council would be prepared to adopt the land. In this
case the open space and woodland is likely to be used by residents of the
development only. Therefore, should the scheme proceed, the developer should
make arrangements for the woodland and open space to be managed independently
of the Council.
HUMAN RIGHTS IMPLICATIONS
It is considered that refusal of this application as recommended may have an impact
on the individual Human Rights of the applicant. However, having considered the
likely impact and the general interest of the public, refusal of the application is
considered to be justified, proportionate and in accordance with planning law.
CRIME AND DISORDER ACT 1998 - SECTION 17
The application raises no significant crime and disorder issues.
POLICIES
North Norfolk Core Strategy (Adopted September 2008):
Policy SS2: Development in the Countryside (prevents general development in the
countryside with specific exceptions).
Policy SS 3: Housing (strategic approach to housing issues).
Policy SS 9: Holt (identifies strategic development requirements).
Policy CT 5: The transport impact on new development (specifies criteria to ensure
reduction of need to travel and promotion of sustainable forms of transport).
Policy CT 2: Development contributions (specifies criteria for requiring developer
contributions).
Policy EN 2: Protection and enhancement of landscape and settlement character
(specifies criteria that proposals should have regard to, including the Landscape
Character Assessment).
Policy EN 9: Biodiversity and geology (requires no adverse impact on designated
nature conservation sites).
Policy HO 1: Dwelling mix and type (specifies type and mix of dwellings for new
housing developments).
Policy HO 2: Provision of affordable housing (specifies the requirements for provision
of affordable housing and/or contributions towards provision).
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Policy HO 7: Making the most efficient use of land (Housing density) (Proposals
should optimise housing density in a manner which protects or enhances the
character of the area).
MAIN ISSUES FOR CONSIDERATION
1. Development plan policy.
2. Landscape and ecological impacts / settlement character.
3. Dwelling mix, density and affordable housing.
4. Access.
APPRAISAL
This report should be read in conjunction with the preceding report on this agenda
which relates both to this application and the other two applications submitted on
behalf of Greshams School (refs: 14/0284 & 14/0274).
The application site is located beyond the eastern built up fringe of Holt. The main
part of the site comprises a single open field. It also includes woodland belts on two
sides bordering with Cromer Road and Grove Lane.
A smaller part of the site was proposed as a housing allocation at the draft version
stage of the North Norfolk Site Allocations Development Plan Document (DPD).
However following the examination in public the inspector rejected the site in favour
for an alternative site off Woodfield Road (Site HO1). In coming to this decision the
inspector described the site and compared it to site HO1 in the following terms:
'.... the site is about 1 km. from Holt town centre, and is located within a peripheral,
semi-rural area which is detached from the main built-up parts of Holt. It is largely
surrounded by other farmland, woodland, and school playing fields. As a result it has
a significantly lower sustainability score in the Sustainability Appraisal compared with
site HO1. It is much less well integrated with the town, and the proposed 120
dwellings would appear as a somewhat detached, even anomalous outlying
residential estate.'
The site lies within the 'countryside' policy area where under Policy SS2 of the Core
Strategy housing development is not permitted (apart from 'exception' affordable
housing developments and the re-use of existing buildings). The application therefore
represents a departure from the development plan.
Core Strategy Policy EN2 which is applicable to this application states that
development proposals should protect, conserve and, where possible enhance,
amongst other issues, settlement character and distinctive landscape features (such
as watercourses, woodland and ecological corridors for wildlife).
In terms of the physical impact of housing development in this location, the site is
well screened by the woodland belts on two sides and to a lesser extent by trees /
hedgerows around its remaining borders, so it would not be visible in the wider
landscape. However the comments of the previous inspector are still relevant in that
the proposed development '... would appear as a somewhat detached, even
anomalous outlying residential estate'.
Furthermore the indicative layout plan submitted with the application provides little
confidence that development of the site would provide sufficient quality or mitigation
to counter the loss of this part of Holt's undeveloped rural fringe. For example the
plan makes no suggestion that any tree planting would be integrated within the
development itself to soften what, as shown, would otherwise resemble a fairly
characterless suburban estate. In addition the absence of any significant landscaping
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buffer along the boundary with the A148 Holt by-pass would result in the existing
landscaped approach to the town taking on a much more urban appearance, as well
as raising amenity issues to future residents of the site. The layout would also appear
to contradict the recommendations of the submitted bat survey in terms of avoiding
artificial lighting towards the woodland. In terms of open space the layout shows no
practical provision within the housing development itself, but rather relies on this
being provided within the surrounding woodland including an area where trees are
indicated to be removed for this purpose. These factors only add to the more
fundamental misgivings regarding the proposal, although this is not to say that a
more acceptable form of layout could not be designed.
In terms of the specific housing policies of the Core Strategy, Policy HO2 requires
that on schemes of 10 dwellings or more, not less than 45% of the total number of
dwellings should be in the form of affordable housing (subject to viability). The
proposal falls well short of this requirement. The applicants are proposing that 10% of
the combined total of dwellings on both this site and Sites 2 & 3 (refs: 14/0284 &
14/0274) are delivered solely on this site. As proposed this would equate to a
maximum of 15 affordable dwellings. This maximum offer of affordable housing is
derived from the submitted development viability assessment which assumes a total
land value from the three sites in the region of £11.067m. The committee's attention
is drawn to the comments of the Council's Strategic Housing Officer (above) with
specific reference to the submitted viability assessment, the conclusions reached by
the Council's independent consultant regarding development viability and the
consequences upon the low provision of affordable housing.
Core Strategy Policy HO1 requires that new housing developments should comprise
at least 40% of dwellings with no more than one or two bedrooms. Whilst details of
the house types are not applied for at this stage the submitted design and access
statement (revised) refers to a housing mix comprising 46% properties with two
bedrooms or less which would more than meet the policy requirement.
Core Strategy HO7 advocates housing densities of not less than 40 dwellings per
hectare (dw/ha) in Principal Settlements such as Holt, but this is subject to the
proviso that the density of a site 'protects or enhances the character of an area'.
Maximum densities approved on allocated greenfield sites over the last year or so
have tended to be more in the region of up to 35 dw/ha. On this site, excluding the
area of woodland belt which borders it, 126 dwellings would equate to a density of 29
dw/ha. Whilst this is not a particularly high density, as referred to above, the
submitted indicative layout plan fails to provide any particular comfort that 126
dwellings would result in a development which would respect the landscape
character of the area, provide adequate relief between the housing and adjacent
main road, properly address issues of wildlife mitigation and provide a reasonable
amount and type of public open space.
Core Strategy EN9 states that development proposals that would cause a direct or
indirect adverse effect to nationally designated sites or protected species will not be
permitted unless the benefits of the development clearly outweigh the adverse
impacts and suitable prevention, mitigation and compensation measures are
provided. The issue relates to increased visitor pressure arising from new residential
development in the district, in particular upon the North Norfolk Coast SAC/SPA.
Natural England has subsequently advised that the applicants' offered payment of
£50 per dwelling (secured by S.106 Obligation) towards measures to mitigate against
the effects of increased visitor pressure should be sufficient to address this particular
concern. Similarly the Appropriate Assessment (Conservation of Habitats and
Species Regulations 2010) undertaken by the Council has reached the same
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conclusion.
Finally the only physical detail being applied for at this stage relates to the access
arrangements to serve the proposed development. These involve both the road
access onto Cromer Road as well new footway provision along lengths of Cromer
Road and Grove Lane. Technically these details are acceptable to the highway
authority, although visually they will have an impact upon the wooded character of
this approach into the town, including the loss of certain trees. In the case of the
footway along the Cromer Road frontage, there is the possibility that an alternative
route could be directed within the development site, subject to it meeting the highway
authority's adoption standards.
Conclusions
Planning law requires that applications for planning permission must be determined
in accordance with the development plan unless material considerations indicate
otherwise. The principle of housing on this site does not accord with the development
plan (Policy SS2 - Development in the Countryside). Neither does the proposal
accord in terms of specific housing policy (Policy HO2 - Provision of affordable
housing). In addition it is considered that the site is a far from ideal one to develop
for housing (a fact concluded by the previous planning inspector), one which would
have a potentially negative effect upon the rural character of the area and ecology of
the site (Policies EN2 and EN9). Whilst these latter impacts represent the sort of
compromises which sometimes have to be made in circumstances where there is a
recognised need to provide new sites for housing or other forms of development, this
is not currently the case with this site.
The submission put forward by the applicants (referred to in detail in the preceding
report) is that the interests of Greshams School (and in turn the benefits which
accrue from the school to the economy of Holt) represent a material consideration
sufficient enough to outweigh the development plan in this case. Notwithstanding the
arguments put forward by the applicants, first and foremost this is a planning
application for residential development and as such it should be determined on that
basis. For the reasons referred to both in this report and the preceding report it is not
considered that the case put forward by the applicants is sufficient to outweigh the
significant departures from the development plan which this application represents.
Accordingly the application is recommended for refusal.
RECOMMENDATION: Refusal for the following reasons:
The District Council adopted the North Norfolk Core Strategy on 24 September 2008
for all planning purposes. The following policy statements are considered relevant to
the proposed development:
SS 1 - Spatial Strategy for North Norfolk
SS 2 - Development in the Countryside
SS 3 - Housing
SS 9 - Holt
HO 2 - Provision of affordable housing
EN 2 - Protection and enhancement of landscape and settlement character
The proposal would result in an unsustainable form of development which would be
contrary to the development plan in the following respects:
(a) The application site lies outside of the development boundary for Holt in an area
designated as 'countryside' in the adopted Core Strategy. Housing development
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(apart from 'exception' affordable housing developments and the conversion of
existing buildings) is not a use permitted in the countryside policy area under Core
Strategy Policy SS 2. The proposal would lead to the creation of an outlying
residential estate detached from the existing built up area of Holt and most of the
town's services and facilities.
(b) The proposal fails to provide for an appropriate proportion of affordable housing,
contrary to the objectives of Core Strategy Policy HO 2.
(c) Contrary to the objectives of Core Strategy Policy EN 2, the applicants have failed
to demonstrate that the proposed development would not result in an adverse impact
upon the character and appearance of the rural fringe to Holt, and in particular the
approach into the town along the A148.
In the opinion of the Local Planning Authority there are no material considerations or
public benefits associated with the proposed development, of sufficient weight, to
indicate that the application should be determined other than in accordance with the
development plan.
3.
HOLT - PO/14/0284 - Residential development for a maximum of 19 dwellings;
Land South of Cromer Road and West of Grove Lane for Endurance Estates
Strategic Land Ltd and Greshams School
Major Development
- Target Date: 10 June 2014
Case Officer: Mr J Williams
Outline Planning Permission
CONSTRAINTS
Countryside
Unclassified Road
C road
Tree Preservation Order
Controlled Water Risk - Medium (Ground Water Pollution)
RELEVANT PLANNING HISTORY
PLA/20001224 PF
Change of use from agricultural land to school playing field
Approved 29/01/2001
THE APPLICATION
The application is to develop an existing school playing field (1.53ha) for 19
dwellings. The only detail applied for at this stage is for access.
The site which is rectangular in shape has road frontages to three sides (Cromer
Road to the north and Grove Lane to the east and south) and its western boundary
borders the grounds of a listed building (The Grove).
Vehicle access is proposed from the eastern side of the site onto Grove Lane. New
1.8m wide footways are proposed alongside the site‟s three road frontages,
extending beyond the site‟s Cromer Road frontage linking with an existing footway
beyond the western boundary of The Grove. Similarly the footway would be extended
along Grove Lane to link with the footway proposed along the frontage of site 3
(application ref: 14/0274). 'Build-out' features are also proposed on Grove Lane
intended as traffic calming measures. Amended plans have been submitted with
references to 'no dig' methods of footpath construction to protect tree roots.
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Illustrative plans submitted with the application indicate 19 detached dwellings served
from an access road running north/south centrally within the site. The dwellings are
based on a mix of six 4 bedroom properties and thirteen 4/5 bedroom properties. No
public open space is indicated.
The applicants have confirmed in writing that the following financial contributions are
being offered by means of a S.106 Planning Obligation:
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SPA/SAC visitor pressure
Off-site public open space
Education
Libraries
- £50 per dwelling
- £7,000
- £57,839 (approx)
- £60 per dwelling
The application is supported by the following documents:
Arboricultural Impact Assessment
Archaeological Assessment
Design and Access Statement
Ecological Appraisal
Energy Assessment
Flood Risk Assessment
Services Report
Heritage Statement
Noise Assessment
Planning Statement
Statement of Community Involvement
Site Waste Management Report
Ground Investigation Report
Transport Assessment
Sustainable Travel Report
Travel Plan
Cost Models for school capital works
Viability Assessment (confidential)
REASONS FOR REFERRAL TO COMMITTEE
The application is a significant major development which represents a departure from
current policy. A Committee site visit was held on 8th May.
TOWN COUNCIL
Supports with the following conditions: That the maximum number of dwellings on this site should never exceed 19
properties
 That the development should create new, safe and accessible environments
which are visually attractive as a result of good architecture and appropriate
landscaping.
 That the garage blocks for Plot 1, Plot 4, Plot 10 and Plot 14 as shown on the
indicative layout, are repositioned away from the extreme edges of the site to
enable a substantial belt of appropriate landscaping to screen and fully
encompass the site.
 That all existing trees are retained.
 The number of affordable homes should be negotiated and increased.
REPRESENTATIONS
24 letters of objection received which are summarised as follows:
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Contrary to the development plan.
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The funding of Greshams School should not be a planning consideration and
should not influence local housing decisions. (As per inspectors decision).
The needs of Greshams School should not override the legality and merits of
the application in planning terms.
Consent has been granted for approximately 700 new houses in Holt under
the strategic plan. Holt has not got the infrastructure to cope with even more
houses.
Modernisation of Greshams School should not be to the detriment of the local
community.
The housing growth for Holt as identified in the Local Development
Framework has been satisfied by the two allocated sites in the town. Any
further development should be based on a particular need and adequate
infrastructure to support it. Need should be related to housing, not to achieve
substantial private profit.
Inadequate local infrastructure to cater for additional housing (e.g. schools,
doctor's surgeries, car parks and sewage treatment).
Limited capacity at the primary school.
Unsustainable development for Holt in terms of state schooling, health
provision, local employment, transport and recreation.
Lack of local employment opportunities to support additional housing.
The housing is not planned for local people.
Would result in the over-development of the town.
Loss of open green space which should be retained for sport.
Site is detached from the town and would result in an isolated estate.
Site not within reasonable walking distance to the town centre.
Site is remote from the town centre and primary school and would result in
dependence on car use.
Would exacerbate Holt's parking problems.
Adverse effect upon character of this part of Holt.
Represents urban sprawl.
The attractive surroundings to Holt are important to retain.
Would join up Holt and High Kelling, changing their identities.
Local traffic safety.
Grove Lane is unsuitable to cater for further traffic.
Would lead to increased traffic using Grove Lane as a 'rat run', which has a
lack of continuous footpaths, resulting in a danger to pedestrians.
Footpaths along Cromer Road are in many places narrow.
Loss of sports field.
Loss of attractive open space.
Insensitive impact upon adjacent listed building.
30 signed copies of an identical letter received. The letter objects to the application
on the following grounds:
 Over-development - site not allocated in the Local Development Framework.
 Inspector's decision - The 2010 decision by the Government inspector made
it clear that safeguarding Greshams School was not a planning
consideration.
 Local identity - Road features to Grove Lane would change its semi-rural
nature.
 Sustainability - Not sustainable in terms of state schooling, local employment
opportunities, transport and recreation. Site is remote from the town centre
and local services. Would increase dependency on the car.
 Road safety (Grove Lane) - Increased use as a rat run. Lack of footpaths /
pedestrian safety.
 Green space - Loss of.
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CONSULTATIONS
County Council (Highways) - No objection subject to a number of conditions
including the prior submission and approval of detailed plans for both on-site and offsite highway works.
Anglian Water - Confirms that there is at present available capacity in the foul
sewerage network and at Holt Sewage Treatment Works to cater for the
development.
Requests a surface water drainage strategy is conditioned in the event of planning
approval.
Environment Agency - No objection in terms of flood risk issues, subject to a
condition requiring the submission of a surface water scheme to be submitted with
any applications for reserved matters.
In terms of sewage disposal comments as follows:
'Under the Water Framework Directive (WFD) both the Agency and local authorities
have a duty to ensure there is no deterioration of a watercourse, in this case the
River Glaven which currently has „very good‟ status. To be compliant with the
Directive a scheme must not cause deterioration in a waterbody‟s status or prevent
its achievement of good ecological status in the future.
The additional loading on Holt Sewage Treatment Works from this and other new
developments within the catchment may individually or cumulatively necessitate
Phosphate removal at the works in order to maintain the very good status of that
waterbody. As such there may be an issue with accommodating the full quantum of
growth proposed for Holt in the LDF over the longer term. This site was not allocated
in the LDF and so these housing figures could be over and above those considered
at that time - these extra houses could therefore limit the number of allocated houses
that can be built.'
Recommends a condition requiring that no development shall begin until a report
demonstrating that there is sufficient foul water capacity for the development has
been submitted and approved by the local planning authority. Where necessary the
report should include a scheme for improvement of the sewerage system and the
condition should require that no dwellings shall be occupied until the scheme as
approved has been implemented.
County Council (Planning Obligations Co-Ordinator) - Requires the following
financial contributions to be secured via a section 106 Obligation:
£465,760 towards primary education (a combined sum relating to Sites 1,2 & 3).
£892 for 1 fire hydrant
£60 per dwelling for library provision.
County Council (Minerals and Waste) - No objection subject to a condition
requiring the prior submission and approval of a Materials Management PlanMinerals (MMP-M), the purpose of which will be to establish the extent to which onsite materials which could be extracted and used during the course of development.
County Council (Historic Environment Service) archaeological work.
Confirms no requirement for
Sport England Objects on grounds that the proposal would result in the
permanent loss of an existing playing field without being replaced by a new playing
field. Accordingly it is considered that the proposal would not satisfy Sport England's
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policy on the loss of playing fields, or the advice contained within para. 74 of the
National Planning Policy Framework.
Should the Council be minded to grant planning permission the application should be
referred to the Secretary of State in accordance with the Town and Country Planning
(Consultation) (England) Direction 2009.
Environmental Health - Recommends conditions in respect of surface water,
sewage disposal and land contamination.
Strategic Housing
- Comments relate to the three applications submitted on
behalf of Greshams School and the single submitted development viability
assessment:
There is a need for affordable housing in Holt with 100 households on the Housing
Register and in addition there are a further 109 households on the Transfer Register
and 646 households on the Housing Options Register who have stated that they
require housing in Holt. The proposed development would therefore assist in meeting
some of the proven housing need.
It is noted that all three sites are outside of the settlement boundary for Holt. The
applicants are seeking planning permission on the basis that a material consideration
is the need for Gresham‟s School to expand its education provision and the
associated benefits to the economic prosperity of Holt of this.
The submitted viability assessment adopts a non-standard approach, as the land
value used in the viability assessment reflects Gresham‟s School‟s requirement that it
receives a receipt from the sale of the three sites which will fund (with some
borrowing) the construction of a new sixth form academic block (£4,412,000),
improvements to its boarding houses (£5,129,000) and the costs of planning, master
planning, legal costs and the promoters fee, totalling £11,062,215. The need to
generate this level of land value has resulted in a viability assessment which shows
that it is only viable to provide 10% of the proposed number of dwellings as
affordable dwellings. The approach taken to the assessment of what is an
appropriate land value for the three sites conflicts with the Royal Institute of
Chartered Surveyors guidance and Planning Practice Guidance on financial viability
in planning on how land values should be established.
The proposal that the affordable housing is only be provided on site 1 is reflective of
the desire to maximise the land value across all three sites.
Gresham‟s School has stated that they are not able to borrow to fully fund the cost of
the construction of the sixth form block and improvements to boarding houses and
are only able to borrow part of the cost.
A review of the financial information
submitted by Gresham‟s School in the viability assessment has concluded that
school can only borrow a proportion of the costs of the proposed works.
The submitted viability assessment was considered internally and by an external
consultant.
The initial consideration of the submitted viability by the external
consultant showed that:
 The sales values used for the proposed market dwellings are too cautious.
 The agent fees were out of kilter with the market.
 The planning and master planning fees are high in relation to what would be
expected.
 The promoter‟s fee of 10% of the net land value (after planning, master
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planning and legal fees are deducted from the receipt from the sale of the
three sites) is not a standard cost.
The land value can increase and there should be a strong argument to
increase the percentage of affordable housing. Allowing for 45% social
(affordable housing), would provide a positive capital receipt to the land
owners – notwithstanding the specific issues relating to Gresham‟s School
and their requirement to build new teaching and housing blocks.
It was therefore clear that all of the factors identified above are impacting negatively
on the viability of the three sites and the amount of affordable housing which they can
support. In addition there was concern that site 3, which the outline application
proposes is developed to provide up to 8 dwellings was not maximising the value of
this site. 6 larger dwellings would be more beneficial to the viability.
These views were discussed with the applicant who subsequently submitted a
revised viability assessment to reflect the sales values identified by the external
consultant. As these sales values reflected values at June 2014, the applicant also
updated the build costs within the viability assessment to reflect build costs at June
2014, as the original submitted viability assessment used June 2013 build costs. In
addition site 3 was amended to reflect 6 larger dwellings and the total number of
dwellings across the three sites reduced to 151. The revised viability assessment
however, still showed that it was only viable to provide 10% of the total number of
dwellings as affordable (15 dwellings).
The external consultant has considered the revised viability assessment and stated
that:
 The promoters return at 10% is not unrealistic to reflect the risk associated
with the scheme and the uncertainty that planning consent will be granted.
 Further clarification is needed of the planning and master planning fees which
are excessive.
 The increase in build costs has countered the increase in sales values,
however, the achieved land value per acre is favourable for its location.
 The argument put forward is looking at viability in reverse, as X {the cost of
the works and associated costs - £11,062,215} is needed to make it work. If
the school had no capital expenditure to make, the discussion would be
different.
It should be noted, that whilst the promoter‟s fee at 10% of the net land receipt is not
considered to be unrealistic, in normal practice this fee would be deducted from the
landowner‟s receipt for the land and so would reduce the return they receive. This is
not the case here. The sum the applicants need to achieve from the sale of the three
sites has been calculated as the cost of the proposed works to the school plus the
planning, master planning and legal fee and the promoters return. Therefore, the
total sum needed to be received from the sale of the three sites has been increased
by the requirement to pay the promoter‟s return of 10% of net land value. The
revised viability assessment shows that with 10% affordable housing, this sum is
almost achieved, leaving only a small amount which the applicant would need to fund
through a loan.
It is clear that had a standard approach been used in the viability assessment to the
value of the land for each of the three sites that it would be viable to provide more
than 10% affordable housing or 15 out of 151 new dwellings. The fact that
Gresham‟s School require such an extensive receipt from the sale of the site has
significantly affected the viability of these sites. In addition the issue around the
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planning and master planning costs and the promoters return are contributing to the
viability issue. If a standard approach to the valuing of these three sites had been
used, it would be viable to provide more affordable housing.
It is proposed that if these three sites are granted planning permission, that there will
be a Section 106 Agreement which will contain an uplift arrangement to provide for a
possible contribution for affordable housing. The proposed uplift arrangement is not
the standard affordable housing uplift which the Council has used elsewhere.
Affordable housing uplifts are used where the Council has accepted a lower
percentage of affordable housing due to viability issues at the point of application in
order to capture any increase in viability once the site is developed. The Council‟s
standard wording captures increases in viability due to changes in costs and
increases in the sales values achieved for the completed market dwellings where this
results in more profit for the developer. The proposal for the three sites is instead,
that the receipt from the sale of the three sites will be placed into a ring fenced pot for
the works to build a sixth form college and remodel the boarding houses. After 5
years from the receipt of the final payment, the applicants will submit a viability
statement showing how the land receipt has been spent on the works and associated
on costs. Any funding left over would then be split 50/50, with the Council receiving
50% up to a cap of £2,000,000 for affordable housing and the remaining 50% being
used to support bursaries for local people to attend Gresham‟s School. This
proposal would limit the uplift available for a financial contribution for affordable
housing, as it is dependent on an increase in the receipt from the sales of the three
sites beyond what is shown in the viability assessment as required. In addition the
ability to receive a payment for affordable housing would be dependent on the costs
of the construction of the sixth form college and improvement works to the boarding
houses not increasing above the cost currently shown by the applicant. There is
always a risk that the Council will not receive any funding for affordable housing
through the operation of an Affordable Housing Uplift, however, the proposed
arrangement for this site does increase that risk as the uplift does not relate to the
costs of the development of the site, but instead to the land receipt and costs
incurred by the applicant on works to Gresham‟s School.
The applicants have also offered an additional affordable housing uplift clause which
would enable a share of any uplift in the sales income from the completed dwellings
to be provided to the Council. The share the Council would receive is not stated and
the exact detail of what is proposed is not known. However, this offer is reliant on the
applicants negotiating the inclusion of this clause as part of the sale of the three sites
with the purchaser(s). It is therefore, not possible to comment on whether this would
be a more acceptable uplift clause to the Council or whether this would increase the
likelihood of receiving monies to provide additional, offsite, affordable housing.
To conclude, assessment of the original and revised viability assessments has
shown that the viability of the site has been constrained by the non-standard
methodology used to establish the land values for the three sites and has resulted in
a lower level of affordable housing than it would otherwise be possible to provide.
The applicant‟s proposal for an affordable housing uplift is again non-standard and
would increase the risk that the Council would not receive a financial contribution for
affordable housing. Strategic Housing therefore objects to the approval of the
planning applications as they will not deliver the viable amount of affordable housing.
Conservation and Design Officer
The site lies well outside the Holt Conservation Area and there is no apparent
archaeological interest in the area. Therefore the only heritage asset which needs to
be considered is the Grade II Listed building 'The Grove' which borders the western
1.31
boundary of the site. This is an early 19th century building which mixes Tudor and
Gothic detailing to create an attractive and elegant end result. Despite the college
buildings having encroached to the northwest, it still stands in relative isolation within
its own grounds – a fact which is clearly pertinent given the development now
proposed on both sides.
Looking at historic maps, it would appear that the Grove has always had a relatively
insular existence based upon its well defined curtilage. Certainly there is no
suggestion of it having ever addressed the wider landscape to either the west or
east. Hence, Conservation & Design concur with the submitted heritage statement
which states that “the open character of the asset‟s wider surroundings is therefore
an incidental part of the setting rather than a designed aspect”.
However, there has always been a narrower tree belt on the eastern side of The
Grove (which has been further thinned recently). Hence existing views towards and
out from The Grove would clearly be affected by the proposed scheme. Whilst these
views may well be incidental and intermittent, they have nonetheless now opened
The Grove up to wider appreciation and have helped it establish new connections
with the countryside beyond. With the proposed development potentially creating two
banks of housing, it is probable that these views would be largely lost with the new
build taking centre stage and affectively hemming in the heritage asset on its eastern
side. On this basis it is concluded that the scheme would result in “less than
substantial harm” being caused to the setting of the heritage asset (as defined by the
NPPF).
More generally, as the application is in outline form with only access to be
considered, it is not necessary at this stage to delve too deeply into the illustrative
layout. This said, it is certainly worth noting that the indicative scheme presents a far
from convincing case for the development sitting comfortably within its semi-rural
setting. Instead it appears to depict an essentially suburban layout where the
buildings have been laid out less than imaginatively around a central roadway and a
pair of hammerheads.
Therefore, should the public benefits accruing from the scheme be considered to
outweigh the heritage harm (and any other material considerations), Conservation
and Design would certainly look for a more informal layout which befits its location.
This should provide for greater variations in built form and grouping, and should be
based around a more informal arrangement of private drives and courtyards.
Finally, it is considered unfortunate that the informal verge and semi-rural character
of Grove Lane should be sacrificed in order to provide a new footpath around the
perimeter of this development. . Re-routing these paths through the development
would be much preferred - as would deleting the two artificial islands within the
carriageway which would have a similarly damaging impact upon the rural feel of the
area.
Landscape Officer - Comments that the site has a distinctly rural character, by
virtue of the surrounding mature woodland and soft road verges which along Grove
Lane create a „country lane‟ appearance. Retention of this distinct character should
be a key aim of any development proposals in this area. The submitted proposals fail
to emulate this and offer a rather suburban development by virtue of the layout and
the highway elements. The eastern end of Grove Lane currently works well as a
shared surface. The inclusion of footpaths, kerbing, associated gullies and traffic
calming measures would seem to be unnecessary and expensive elements that
would have a negative impact on the semi-rural character of this part of Holt.
The development proposes the removal of the eastern and southern hedgerows
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which is regrettable. This is a positive feature of the site and should be retained to
give established character to any finished scheme. It provides a soft boundary that is
in keeping with this area on the outskirts of Holt and is of ecological value. It would
be difficult to replicate this with replacement planting. The loss of a section of the
hedgerow and grassed verge to accommodate visibility splays is acceptable,
however there should be extensive soft landscape planting within the site in
recognition of the woodland nature of the area. Trees on the site have been
described as important in the arboricultural report and their retention as part of the
proposed development is welcomed. Suburban close board fencing would not be
appropriate in this location.
Design details should reflect the edge of settlement location and pick up on local
building vernacular from buildings in the locality, such as the former agricultural
buildings on Cromer Road and the older dwellings at the eastern end of Grove Lane.
The illustrative layout submitted presents a somewhat suburban arrangement
inappropriate for this setting. A more mixed approach based on clusters of dwellings
within a landscape setting would be more fitting.
The site is within 1.5km of the Holt Lowes Site of Special Scientific Interest (SSSI)
which is part of the Norfolk Valley Fens Special Area of Conservation (SAC) and just
over 5km from the North Norfolk Coast Special Area of Conservation and the North
Norfolk Coast Special Protection Area (SPA). These sites are under extreme
pressure and risk of disturbance from increasing numbers of visitors, which is having
a negative impact on some of the conservation interests of those sites. As the
proposed development is not located on one of the site allocations in the Local
Development Framework it has not previously been subject to a Habitats Regulations
Assessment. Accordingly an Appropriate Assessment has been undertaken by the
Council (as a 'competent authority' under the Conservation of Habitats and Species
Regulations 2010) in respect of the current proposals.
The Appropriate Assessment has concluded that the proposed development would
not adversely affect the integrity of the Norfolk Valley Fens SAC; however, without
mitigation, the development would adversely affect the integrity of the North Norfolk
Coast sites. The applicants are offering a financial contribution towards a scheme of
monitoring and mitigation to minimise impacts on the North Norfolk Coast SPA/SAC
arising as a result of increased visitor pressure, similar to that achieved on sites
which have been allocated for residential development. This will ensure that adverse
effects on the integrity of the North Norfolk Coast sites are avoided.
Natural England Initial comments received referred to the proximity of the
proposed sites to both national and international designated habitat sites which are
afforded protection under the 'Habitats Regulations', namely the Holt Lowes Site SSSI (national) and the North Norfolk Coast Special Protection Area (international),
and the issue of visitor pressure from new residential developments which may
impact upon the sensitivity of these sites. The advice received was that it is not
possible to conclude that the proposals are unlikely to result in significant effects
upon these sites. Accordingly Natural England advised that the District Council
should not grant permission before, in its role as competent authority under the
Habitats Regulations, it has received sufficient information to screen the proposals
for the likelihood of significant effects.
Following the applicants subsequent response and offer to contribute £50 per
dwelling towards a scheme of mitigation for impacts upon these sensitive sites in
combination with those of allocated sites within the wider area Natural England have
commented as follows:
" I have reviewed the documents that the applicant has provided and am pleased
with the approach that they have taken. It is my view that it is still not possible to
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determine no Likely Significant Effect at the initial stage of Habitats Regulation
screening; whilst we accept that the application is only a relatively small proportion of
development planned for the District, recreational disturbance and therefore its
effects are a cumulative issue. Whilst it is for you as the competent authority to
determine whether or not you have the information needed to complete a Habitat
Regulations Assessment, my advice is that the proposed mitigation is likely to be
sufficient to enable a conclusion of no adverse effect on integrity to be reached. I
would suggest, should you be minded to grant consent, that you include an
appropriately worded planning condition (and possibly S.106 agreement) which
ensures the mitigation measures, including the contribution towards delivery of
strategic green infrastructure are secured."
Countryside and Parks Manager As the site does not include any on-site
provision of open space suggests that a contribution of £7,000 is made towards off
site play provision.
HUMAN RIGHTS IMPLICATIONS
It is considered that the proposed development may raise issues relevant to
Article 8: The Right to respect for private and family life.
Article 1 of the First Protocol: The right to peaceful enjoyment of possessions.
It is considered that refusal of this application as recommended may have an impact
on the individual Human Rights of the applicant. However, having considered the
likely impact and the general interest of the public, refusal of the application is
considered to be justified, proportionate and in accordance with planning law.
CRIME AND DISORDER ACT 1998 - SECTION 17
The application raises no significant crime and disorder issues.
POLICIES
North Norfolk Core Strategy (Adopted September 2008):
Policy SS2: Development in the Countryside (prevents general development in the
countryside with specific exceptions).
Policy SS 3: Housing (strategic approach to housing issues).
Policy SS 9: Holt (identifies strategic development requirements).
Policy CT 1: Open space designations (prevents inappropriate development and loss
of open space).
Policy CT 2: Development contributions (specifies criteria for requiring developer
contributions).
Policy CT 5: The transport impact on new development (specifies criteria to ensure
reduction of need to travel and promotion of sustainable forms of transport).
Policy EN 2: Protection and enhancement of landscape and settlement character
(specifies criteria that proposals should have regard to, including the Landscape
Character Assessment).
Policy EN 8: Protecting and enhancing the historic environment (prevents insensitive
development and specifies requirements relating to designated assets and other
valuable buildings).
Policy EN 9: Biodiversity and geology (requires no adverse impact on designated
nature conservation sites).
Policy HO 1: Dwelling mix and type (specifies type and mix of dwellings for new
housing developments).
Policy HO 2: Provision of affordable housing (specifies the requirements for provision
of affordable housing and/or contributions towards provision).
Policy HO 7: Making the most efficient use of land (Housing density) (Proposals
should optimise housing density in a manner which protects or enhances the
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character of the area).
MAIN ISSUES FOR CONSIDERATION
1. Development plan policy.
2. Dwelling mix, density and affordable housing.
3. Landscape and ecological impacts / settlement character.
4. Loss of playing field
5. Setting of listed building.
6. Access.
APPRAISAL
This report should be read in conjunction with the preceding report on this agenda
which relates both to this application and the other two applications submitted on
behalf of Greshams School (refs: 14/0283 & 14/0274).
The application site is located just beyond the eastern built up fringe of Holt. It
comprises a rectangular playing field surrounded on three sides by Cromer Road and
Grove Lane, and borders 'The Grove' on its remaining side.
The site lies within the 'countryside' policy area where under Policy SS2 of the Core
Strategy housing development is not permitted (apart from 'exception' affordable
housing developments and the re-use of existing buildings). The application therefore
represents a departure from the development plan.
In terms of the specific housing policies of the Core Strategy, Policy HO2 requires
that on schemes of 10 dwellings or more, not less than 45% of the total number of
dwellings should be in the form of affordable housing (subject to viability). The
proposal falls well short of this requirement. The applicants are proposing that 10% of
the combined total of dwellings on both this site and Sites 1 & 3 (refs: 14/0283 &
14/0274) are delivered solely on Site 1. As proposed this would equate to a
maximum of 15 affordable dwellings. This maximum offer of affordable housing is
derived from the submitted development viability assessment which assumes a total
land value from the three sites in the region of £11.067m. The committee's attention
is drawn to the comments of the Council's Strategic Housing Officer (above) with
specific reference to the submitted viability assessment, the conclusions reached by
the Council's independent consultant regarding development viability and the
consequences upon the low provision of affordable housing.
Core Strategy Policy HO1 requires that new housing developments should comprise
at least 40% of dwellings with no more than one or two bedrooms. Whilst detailed
house types are not applied for at this stage, it is clear from the submitted indicative
layout plan and accompanying documentation, that this is a proposal wholly
comprising 4/5 bedroom detached dwellings.
Core Strategy HO7 advocates housing densities of not less than 40 dwellings per
hectare (dw/ha) in 'Principal Settlements' such as Holt, but this is subject to the
proviso that the density of a site 'protects or enhances the character of an area'.
Maximum densities approved on allocated greenfield sites over the last year or so
have tended to be more in the region of up to 35 dw/ha. This proposal is for a very
low density development equating to approximately 12 dw/ha. This low density
reflects the type of housing proposed and absence of smaller more affordable
properties.
Core Strategy Policy EN2 which is also applicable to this application states that
development proposals should protect, conserve and, where possible enhance,
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amongst other issues, settlement character and distinctive landscape features. The
site at present provides an attractive open transition between the eastern built up
perimeter of Holt and the adjoining countryside. Grove Lane which borders the site
on two sides has a distinctly semi-rural character. This will irrevocably change as a
result of the proposed development, not just as a result of the housing development
itself, but also as a result of the engineered highway works (including formalised
footways) which are proposed and are a requirement of the highway authority.
The proposed development will result in the loss of an existing sports field which has
been used as a senior size football pitch. Formerly in agricultural use the field was
granted planning permission for the change of use to a school playing field in 2001.
The committee will note the objection raised by Sport England to the loss of this
playing field. In terms of planning policy Core Strategy Policy CT1 states that the
whole or partial loss of open space will not be permitted unless the space does not
contribute to the character of the settlement and is surplus to requirements (in terms
of its function), or where provision of equal or greater benefit is provided in the
locality. Similarly the NPPF states that sports land should not be built on unless it is
demonstrated that the land is surplus to requirements; or the loss is replaced by
equivalent or better provision; or the development is for alternative sports / recreation
provision.
The applicants have responded to Sport England's objection by stating that the
playing field is surplus to requirements having regard to its location on the "wrong
side" of Cromer Road to the school's main campus and other sports facilities. They
have also demonstrated that the pitch can be capable of being provided within the
school's main playing fields area (doubling up with cricket pitches). Sport England
have however maintained their objection on the basis of the net loss of playing field
provision and they point out the requirement to refer the application to the Secretary
of State in the event of the Council being minded to grant planning permission.
Core Strategy EN9 states that development proposals that would cause a direct or
indirect adverse effect to nationally designated sites or protected species will not be
permitted unless the benefits of the development clearly outweigh the adverse
impacts and suitable prevention, mitigation and compensation measures are
provided. The issue relates to increased visitor pressure arising from new residential
development in the district, in particular upon the North Norfolk Coast SAC/SPA.
Natural England has subsequently advised that the applicants' offered payment of
£50 per dwelling (secured by S.106 Obligation) towards measures to mitigate against
the effects of increased visitor pressure should be sufficient to address this particular
concern. Similarly the Appropriate Assessment (Conservation of Habitats and
Species Regulations 2010) undertaken by the Council has reached the same
conclusion.
The site borders with the eastern boundary of 'The Grove' a grade 2 listed building.
The conclusions of the Council's Conservation and Design Officer (see above) are
that when considered against the advice provided in the National Planning Policy
Framework (NPPF) the scheme would result in 'less than substantial harm' upon the
setting of the listed building. The NPPF makes a distinction between proposed
developments which would lead to 'substantial harm' to a heritage asset and those
which would result in 'less than substantial harm'. In the case of the latter the NPPF
advises that the harm caused should be weighed against the public benefits of the
proposal. The implication being that planning permission can legitimately be refused
where the public benefits of a proposal are considered to be of lesser 'weight' than
the harmful impact upon a heritage asset.
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Finally the only physical detail being applied for at this stage relates to the access
arrangements to serve the proposed development. These involve the road access
onto Grove Lane, the provision of visibility splays, new footways along the three
roadside boundaries of the site (and extending beyond the site along Grove Lane
and Cromer Road), together with small sections of 'build outs' on Grove Lane with
the effect of reducing the carriageway width at these points to single lane only.
Technically these details are acceptable to the highway authority, although visually
they will have an impact upon the semi-rural character of Grove Lane. At present this
section of Grove Lane gives the impression of a relatively quietly trafficked, partcountry lane where vehicles and pedestrians use the carriageway in relative
harmony. The resulting highway works will create a much more urban environment.
Conclusions
Planning law requires that applications for planning permission must be determined
in accordance with the development plan unless material considerations indicate
otherwise. The principle of housing on this site does not accord with the development
plan (Policy SS2 - Development in the Countryside). Neither does the proposal
accord in terms of specific housing policies (Policies HO1, HO2 and HO7).
In addition it is considered that the proposed development would adversely impact
upon the existing semi-rural character of the area (Policies EN2). Whilst such an
impact represents the sort of compromise which sometimes has to be made in
circumstances where there is a recognised need to provide new sites for housing or
other forms of development, this is not currently the case with this site. The impact on
the adjacent listed building is less measurable. When balanced against the public
benefits provided by new housing development per se and the fact that an
appropriately designed development on the site could mitigate any harmful impacts
upon the listed building, it is not considered that this particular aspect represents a
sufficient objection to the application.
The submission put forward by the applicants (referred to in detail in the preceding
report) is that the interests of Greshams School (and in turn the benefits which
accrue from the school to the economy of Holt) represent a material consideration
sufficient enough to outweigh the development plan in this case. Notwithstanding the
arguments put forward by the applicants, first and foremost this is a planning
application for residential development and as such it should be determined on that
basis. For the reasons referred to both in this report and the preceding report it is not
considered that the case put forward by the applicants is sufficient to outweigh the
significant departures from the development plan which this application represents.
Accordingly the application is recommended for refusal.
RECOMMENDATION: Refusal for the following reasons:
The District Council adopted the North Norfolk Core Strategy on 24 September 2008
for all planning purposes. The following policy statements are considered relevant to
the proposed development:
SS 1 - Spatial Strategy for North Norfolk
SS 2 - Development in the Countryside
SS 3 - Housing
SS 9 - Holt
HO 1 - Dwelling mix and type
HO 2 - Provision of affordable housing
HO 7 - Making the most efficient use of land (Housing density)
EN 2 - Protection and enhancement of landscape and settlement character
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CT 1 - Open space designations
In the opinion of the Local Planning Authority the proposal would result in an
unsustainable form of development which would be contrary to the development plan
in the following respects:
(a) The application site lies outside of the development boundary for Holt in an area
designated as 'countryside' in the adopted Core Strategy. Housing development
(apart from 'exception' affordable housing developments and the conversion of
existing buildings) is not a use permitted in the countryside policy area under Core
Strategy Policy SS 2. The proposed development (together with the associated
highway works) would have an adverse impact upon the existing open appearance of
the site and the semi-rural character of the immediate area contrary to the objectives
of Core Strategy Policies EN 2 and CT 1.
(b) The proposal fails to provide for an appropriate proportion of affordable housing,
contrary to the objectives of Core Strategy Policy HO 2.
(c) The proposal would result in a low density development of relatively large dwelling
types, contrary to Core Strategy Policies HO 1 and HO 7.
In the opinion of the Local Planning Authority there are no material considerations or
public benefits associated with the proposed development, of sufficient weight, to
indicate that the application should be determined other than in accordance with the
development plan.
4.
HOLT - PO/14/0274 - Residential development for a maximum of eight
dwellings; Land north of Grove Lane for Endurance Estates Strategic Land Ltd
and Greshams School
Minor Development
- Target Date: 06 May 2014
Case Officer: Mr J Williams
Outline Planning Permission
CONSTRAINTS
Countryside
Unclassified Road
Listed Building Grade II - Consultation Area
Controlled Water Risk - Medium (Ground Water Pollution)
Tree Preservation Order
THE APPLICATION
The application is to develop a linear strip of land (0.48ha) which fronts on to the
northern side of Grove Lane. The site is currently part of a larger recreational field
within school grounds. All matters of detail are reserved at this stage. An illustrative
plan submitted with the application indicates eight detached dwellings each with
individual driveways onto Grove Lane. Subsequently the applicants have indicated
that they envisage a more likely layout would involve six 4 bedroom dwellings. Plans
also indicate a new 1.8m wide footway along the frontage of Grove Lane with the
corresponding section of Grove Lane widened to 5.5m. A number of trees are shown
to be removed. Amended plans have been submitted with references to 'no dig'
methods of footpath construction to protect tree roots.
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The applicants have confirmed in writing that the following financial contributions are
being offered by means of a S.106 Planning Obligation:
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SPA/SAC visitor pressure - £50 per dwelling
Education
- £24,353 (approx)
Libraries
- £60 per dwelling
The application is supported by the following documents:
Arboricultural Impact Assessment
Archaeological Assessment
Design and Access Statement
Ecological Appraisal
Energy Assessment
Flood Risk Assessment
Services Report
Heritage Statement
Planning Statement
Statement of Community Involvement
Site Waste Management Report
Transport Statement
Sustainable Travel Report
Travel Plan
Cost Models for school capital works
Viability Assessment (confidential)
REASONS FOR REFERRAL TO COMMITTEE
The application represents a significant departure from current policy. A Committee
site visit was held on 8th May.
TOWN COUNCIL
Supports subject to the following conditions: That the maximum number of dwellings on this site should never exceed 8
properties.
 That the development should create, new safe and accessible environments
which are visually attractive a s a result of good architecture and appropriate
landscaping.
 That the dwelling shown as Plot 7 on the indicative layout is repositioned to
prevent the loss of a category A tree described as “ a significant loss” in the
Arboricultural impact assessment report.
 That prior to the site being sold for development a substantial belt of appropriate
landscaping is provided by Gresham‟s School along the entire length of the North
boundary to screen the proposed properties from Cromer Road and to mitigate
for the loss of category A, B and C trees and hedges scheduled for removal from
Grove Lane.
REPRESENTATIONS
14 letters of objection received which are summarised as follows:
 Contrary to the development plan.
 The funding of Greshams School should not be a planning consideration and
should not influence local housing decisions. As per inspectors decision.
 Modernisation of Greshams School should not be to the detriment of the local
community.
 The housing growth for Holt as identified in the Local Development Framework
has been satisfied by the two allocated sites in the town. Any further development
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should be based on a particular need and adequate infrastructure to support it.
Need should be related to housing, not to achieve substantial private profit.
Inadequate local infrastructure to cater for additional housing (e.g. schools,
doctor's surgeries, car parks and sewage treatment).
Holt has limited capacity at the primary school.
Lack of local employment opportunities to support additional housing.
Loss of open green space. Should be kept for sport.
Site not within reasonable walking distance to the town centre.
Site is remote from the town centre and primary school and would result in
dependence on car use.
Would exacerbate Holt's parking problems.
Adverse effect upon character of this part of Holt in combination with the other
two applications.
Local traffic safety.
Grove Lane is unsuitable to cater for further traffic.
Would lead to increased traffic using Grove Lane as a 'rat run', which has a lack
of continuous footpaths, resulting in a danger to pedestrians.
Proposals assume footpath improvements to southern side of Grove Lane by
Norfolk County Council, which have now been cancelled.
Loss of trees.
Loss of outlook.
Should be retained for sports/recreation field.
30 signed copies of an identical letter received. The letter objects to the application
on the following grounds:
 Site not allocated in the Local Development Framework. Would be larger than
many Norfolk villages without any additional public services to make it
sustainable.
 The 2010 decision by the Government inspector made it clear that safeguarding
Greshams School was not a planning consideration.
 Road safety along Grove Lane.
 Road features along Grove Lane would change it‟s rural identity.
 Sustainability - Not sustainable in terms of state schooling, local employment
opportunities, transport and recreation. Site is remote from the town centre and
local services. Would increase dependency on the car.
 Road safety (Grove Lane) - Increased use as a rat run. Lack of footpaths /
pedestrian safety.
 Loss of green space.
CONSULTATIONS
County Council (Highways) - No objection subject to a number of conditions
including the prior submission and approval of detailed plans for both on-site and offsite highway works.
Environment Agency - No objection in terms of flood risk issues, subject to a
condition requiring the submission of a surface water scheme to be submitted with
any applications for reserved matters.
In terms of sewage disposal comments as follows:
'Under the Water Framework Directive (WFD) both the Agency and local authorities
have a duty to ensure there is no deterioration of a watercourse, in this case the
River Glaven which currently has „very good‟ status. To be compliant with the
Directive a scheme must not cause deterioration in a waterbody‟s status or prevent
its achievement of good ecological status in the future.
The additional loading on Holt Sewage Treatment Works from this and other new
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developments within the catchment may individually or cumulatively necessitate
Phosphate removal at the works in order to maintain the very good status of that
waterbody. As such there may be an issue with accommodating the full quantum of
growth proposed for Holt in the LDF over the longer term. This site was not allocated
in the LDF and so these housing figures could be over and above those considered
at that time - these extra houses could therefore limit the number of allocated houses
that can be built.'
Recommends a condition requiring that no development shall begin until a report
demonstrating that there is sufficient foul water capacity for the development has
been submitted and approved by the local planning authority. Where necessary the
report should include a scheme for improvement of the sewerage system and the
condition should require that no dwellings shall be occupied until the scheme as
approved has been implemented.
County Council (Planning Obligations Co-ordinator) - Requires the following
financial contributions to be secured via a section 106 Obligation:
£465,760 towards primary education (a combined sum relating to Sites 1,2 & 3).
£60 per dwelling for library provision.
County Council (Historic Environment Service) - Confirms no requirement for
archaeological work.
Environmental Health - Recommends conditions in respect of surface water and
sewage disposal.
Strategic Housing - Comments relate to the three applications submitted on behalf
of Greshams School and the single submitted development viability assessment:
There is a need for affordable housing in Holt with 100 households on the Housing
Register and in addition there are a further 109 households on the Transfer Register
and 646 households on the Housing Options Register who have stated that they
require housing in Holt. The proposed development would therefore assist in meeting
some of the proven housing need.
It is noted that all three sites are outside of the settlement boundary for Holt. The
applicants are seeking planning permission on the basis that a material consideration
is the need for Gresham‟s School to expand its education provision and the
associated benefits to the economic prosperity of Holt of this.
The submitted viability assessment adopts a non-standard approach, as the land
value used in the viability assessment reflects Gresham‟s School‟s requirement that it
receives a receipt from the sale of the three sites which will fund (with some
borrowing) the construction of a new sixth form academic block (£4,412,000),
improvements to its boarding houses (£5,129,000) and the costs of planning, master
planning, legal costs and the promoters fee, totalling £11,062,215. The need to
generate this level of land value has resulted in a viability assessment which shows
that it is only viable to provide 10% of the proposed number of dwellings as
affordable dwellings. The approach taken to the assessment of what is an
appropriate land value for the three sites conflicts with the Royal Institute of
Chartered Surveyors guidance and Planning Practice Guidance on financial viability
in planning on how land values should be established.
The proposal that the affordable housing is only be provided on site 1 is reflective of
the desire to maximise the land value across all three sites.
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Gresham‟s School has stated that they are not able to borrow to fully fund the cost of
the construction of the sixth form block and improvements to boarding houses and
are only able to borrow part of the cost.
A review of the financial information
submitted by Gresham‟s School in the viability assessment has concluded that
school can only borrow a proportion of the costs of the proposed works.
The submitted viability assessment was considered internally and by an external
consultant. The initial consideration of the submitted viability by the external
consultant showed that:
 The sales values used for the proposed market dwellings are too cautious.
 The agent fees were out of kilter with the market.
 The planning and master planning fees are high in relation to what would be
expected.
 The promoter‟s fee of 10% of the net land value (after planning, master planning
and legal fees are deducted from the receipt from the sale of the three sites) is
not a standard cost.
 The land value can increase and there should be a strong argument to increase
the percentage of affordable housing. Allowing for 45% social (affordable
housing), would provide a positive capital receipt to the land owners –
notwithstanding the specific issues relating to Gresham‟s School and their
requirement to build new teaching and housing blocks.
It was therefore clear that all of the factors identified above are impacting negatively
on the viability of the three sites and the amount of affordable housing which they can
support. In addition there was concern that site 3, which the outline application
proposes is developed to provide up to 8 dwellings was not maximising the value of
this site. 6 larger dwellings would be more beneficial to the viability.
These views were discussed with the applicant who subsequently submitted a
revised viability assessment to reflect the sales values identified by the external
consultant. As these sales values reflected values at June 2014, the applicant also
updated the build costs within the viability assessment to reflect build costs at June
2014, as the original submitted viability assessment used June 2013 build costs. In
addition site 3 was amended to reflect 6 larger dwellings and the total number of
dwellings across the three sites reduced to 151. The revised viability assessment
however, still showed that it was only viable to provide 10% of the total number of
dwellings as affordable (15 dwellings).
The external consultant has considered the revised viability assessment and stated
that:
 The promoters return at 10% is not unrealistic to reflect the risk associated with
the scheme and the uncertainty that planning consent will be granted.
 Further clarification is needed of the planning and master planning fees which are
excessive.
 The increase in build costs has countered the increase in sales values, however,
the achieved land value per acre is favourable for its location.
 The argument put forward is looking at viability in reverse, as X {the cost of the
works and associated costs - £11,062,215} is needed to make it work. If the
school had no capital expenditure to make, the discussion would be different.
It should be noted, that whilst the promoter‟s fee at 10% of the net land receipt is not
considered to be unrealistic, in normal practice this fee would be deducted from the
landowner‟s receipt for the land and so would reduce the return they receive. This is
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not the case here. The sum the applicants need to achieve from the sale of the three
sites has been calculated as the cost of the proposed works to the school plus the
planning, master planning and legal fee and the promoters return. Therefore, the
total sum needed to be received from the sale of the three sites has been increased
by the requirement to pay the promoter‟s return of 10% of net land value. The
revised viability assessment shows that with 10% affordable housing, this sum is
almost achieved, leaving only a small amount which the applicant would need to fund
through a loan.
It is clear that had a standard approach been used in the viability assessment to the
value of the land for each of the three sites that it would be viable to provide more
than 10% affordable housing or 15 out of 151 new dwellings. The fact that
Gresham‟s School require such an extensive receipt from the sale of the site has
significantly affected the viability of these sites. In addition the issue around the
planning and master planning costs and the promoters return are contributing to the
viability issue. If a standard approach to the valuing of these three sites had been
used, it would be viable to provide more affordable housing.
It is proposed that if these three sites are granted planning permission, that there will
be a Section 106 Agreement which will contain an uplift arrangement to provide for a
possible contribution for affordable housing. The proposed uplift arrangement is not
the standard affordable housing uplift which the Council has used elsewhere.
Affordable housing uplifts are used where the Council has accepted a lower
percentage of affordable housing due to viability issues at the point of application in
order to capture any increase in viability once the site is developed. The Council‟s
standard wording captures increases in viability due to changes in costs and
increases in the sales values achieved for the completed market dwellings where this
results in more profit for the developer. The proposal for the three sites is instead,
that the receipt from the sale of the three sites will be placed into a ring fenced pot for
the works to build a sixth form college and remodel the boarding houses. After 5
years from the receipt of the final payment, the applicants will submit a viability
statement showing how the land receipt has been spent on the works and associated
on costs. Any funding left over would then be split 50/50, with the Council receiving
50% up to a cap of £2,000,000 for affordable housing and the remaining 50% being
used to support bursaries for local people to attend Gresham‟s School. This
proposal would limit the uplift available for a financial contribution for affordable
housing, as it is dependent on an increase in the receipt from the sales of the three
sites beyond what is shown in the viability assessment as required. In addition the
ability to receive a payment for affordable housing would be dependent on the costs
of the construction of the sixth form college and improvement works to the boarding
houses not increasing above the cost currently shown by the applicant. There is
always a risk that the Council will not receive any funding for affordable housing
through the operation of an Affordable Housing Uplift, however, the proposed
arrangement for this site does increase that risk as the uplift does not relate to the
costs of the development of the site, but instead to the land receipt and costs
incurred by the applicant on works to Gresham‟s School.
The applicants have also offered an additional affordable housing uplift clause which
would enable a share of any uplift in the sales income from the completed dwellings
to be provided to the Council. The share the Council would receive is not stated and
the exact detail of what is proposed is not known. However, this offer is reliant on the
applicants negotiating the inclusion of this clause as part of the sale of the three sites
with the purchaser(s). It is therefore, not possible to comment on whether this would
be a more acceptable uplift clause to the Council or whether this would increase the
likelihood of receiving monies to provide additional, offsite, affordable housing.
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To conclude, assessment of the original and revised viability assessments has
shown that the viability of the site has been constrained by the non-standard
methodology used to establish the land values for the three sites and has resulted in
a lower level of affordable housing than it would otherwise be possible to provide.
The applicant‟s proposal for an affordable housing uplift is again non-standard and
would increase the risk that the Council would not receive a financial contribution for
affordable housing. Strategic Housing therefore objects to the approval of the
planning applications as they will not deliver the viable amount of affordable housing.
Conservation and Design Officer - The site lies well outside the Holt Conservation
Area and there is no apparent archaeological interest in the area. Therefore the only
heritage asset which needs to be considered is the nearby Grade II Listed building
'The Grove'. which borders the western boundary of the site. Part of the application
site comprises a section of garden land which appears originally to have been a
discrete, enclosed space within the landscaped surroundings of this listed building.
The Grove is an early 19th century building which mixes Tudor and Gothic detailing to
create an attractive and elegant end result. Despite the college buildings having
encroached to the northwest, it still stands in relative isolation within its own grounds
– a fact which is clearly pertinent given the developments now proposed on both
sides.
Historic maps indicate that the Grove has always had a relatively insular existence
based upon its well defined curtilage. Certainly there is no suggestion of it having
ever addressed the wider landscape to either the west or east. Hence, Conservation
& Design concur with the submitted heritage statement which states that “the open
character of the asset‟s wider surroundings is therefore an incidental part of the
setting rather than a designed aspect”. Therefore, in this particular case, with the tree
belt providing strong visual separation between the application site and The Grove, it
is not considered that development here would result in any demonstrable harm
being caused to the setting and significance of the heritage asset.
As the application is in outline form with all matters reserved, no substantive
comments need be made on the illustrative layout at this stage. This said, it is
certainly worth noting that the regimented row of building-drive/building-drive, etc
presents a far from convincing case for the development sitting comfortably within its
context. Whilst there may well be a precedent for ribbon development along Grove
Lane, it is for more incremental in nature and generally lacks the kind of suburban
rhythm shown in the submitted layout plan.
Should the principle of development ever be accepted here, Conservation and
Design would look for a more informal layout which befits this rural part of the lane;
i.e. by introducing some shared drives and greater variations in built form. There
would also be a preference for any future development respecting the original
western boundary of The Grove rather than cutting through it as shown on the
indicative plan. Currently defined by a low hedge, this space may have been a walled
garden in the past and would in theory better support an individual property within it.
Finally, it is considered unfortunate that the informal verge and semi-rural character
of Grove Lane should be sacrificed in order to provide a new footpath past the
development.
Landscape Officer - Refers to the fact that a tree preservation order (TPO) was
recently served on the site. Whilst it would be acceptable to fell some of the trees
which front onto Grove Lane it would not be acceptable to fell an oak tree within the
site which is shown to be removed on the submitted plan.
The defined garden area at the eastern end of the site should remain as a feature
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and accommodate a single plot. Detailed proposals should include soft landscaping
(trees and hedging) along the rear (northern) boundary.
As with Site 2 (ref:14/0284) further along Grove Lane, the issue of suburbanisation
through highway features such as footpaths, kerbing and traffic calming measures is
an issue and should be minimised. Every effort should be made to retain the informal
semi-rural character of this part of Grove Lane.
In terms of ecology the oak tree shown to be removed may well have bat roosting
potential which is another reason for its retention. Any detailed proposals for the site
should be informed by a bat survey on this tree.
The site is within 1.5km of the Holt Lowes Site of Special Scientific Interest (SSSI)
which is part of the Norfolk Valley Fens Special Area of Conservation (SAC) and just
over 5km from the North Norfolk Coast Special Area of Conservation and the North
Norfolk Coast Special Protection Area (SPA). These sites are under extreme
pressure and risk of disturbance from increasing numbers of visitors, which is having
a negative impact on some of the conservation interests of those sites. As the
proposed development is not located on one of the site allocations in the Local
Development Framework it has not previously been subject to a Habitats Regulations
Assessment. Accordingly an Appropriate Assessment has been undertaken by the
Council (as a 'competent authority' under the Conservation of Habitats and Species
Regulations 2010) in respect of the current proposals.
The Appropriate Assessment has concluded that the proposed development would
not adversely affect the integrity of the Norfolk Valley Fens SAC; however, without
mitigation, the development would adversely affect the integrity of the North Norfolk
Coast sites. The applicants are offering a financial contribution towards a scheme of
monitoring and mitigation to minimise impacts on the North Norfolk Coast SPA/SAC
arising as a result of increased visitor pressure, similar to that achieved on sites
which have been allocated for residential development. This will ensure that adverse
effects on the integrity of the North Norfolk Coast sites are avoided.
Natural England - Initial comments received referred to the proximity of the
proposed sites to both national and international designated habitat sites which are
afforded protection under the 'Habitats Regulations', namely the Holt Lowes Site SSSI (national) and the North Norfolk Coast Special Protection Area (international),
and the issue of visitor pressure from new residential developments which may
impact upon the sensitivity of these sites. The advice received was that it is not
possible to conclude that the proposals are unlikely to result in significant effects
upon these sites. Accordingly Natural England advised that the District Council
should not grant permission before, in its role as competent authority under the
Habitats Regulations, it has received sufficient information to screen the proposals
for the likelihood of significant effects.
Following the applicants subsequent response and offer to contribute £50 per
dwelling towards a scheme of mitigation for impacts upon these sensitive sites in
combination with those of allocated sites within the wider area Natural England have
commented as follows:
" I have reviewed the documents that the applicant has provided and am pleased
with the approach that they have taken. It is my view that it is still not possible to
determine no Likely Significant Effect at the initial stage of Habitats Regulation
screening; whilst we accept that the application is only a relatively small proportion of
development planned for the District, recreational disturbance and therefore its
effects are a cumulative issue. Whilst it is for you as the competent authority to
determine whether or not you have the information needed to complete a Habitat
Regulations Assessment, my advice is that the proposed mitigation is likely to be
sufficient to enable a conclusion of no adverse effect on integrity to be reached. I
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would suggest, should you be minded to grant consent, that you include an
appropriately worded planning condition (and possibly S1.06 agreement) which
ensures the mitigation measures, including the contribution towards delivery of
strategic green infrastructure are secured."
HUMAN RIGHTS IMPLICATIONS
It is considered that the proposed development may raise issues relevant to
Article 8: The Right to respect for private and family life.
Article 1 of the First Protocol: The right to peaceful enjoyment of possessions.
It is considered that refusal of this application as recommended may have an impact
on the individual Human Rights of the applicant. However, having considered the
likely impact and the general interest of the public, refusal of the application is
considered to be justified, proportionate and in accordance with planning law.
CRIME AND DISORDER ACT 1998 - SECTION 17
The application raises no significant crime and disorder issues.
POLICIES
North Norfolk Core Strategy (Adopted September 2008):
Policy SS2: Development in the Countryside (prevents general development in the
countryside with specific exceptions).
Policy SS 3: Housing (strategic approach to housing issues).
Policy SS 9: Holt (identifies strategic development requirements).
Policy CT 1: Open space designations (prevents inappropriate development and loss
of open space).
Policy CT 2: Development contributions (specifies criteria for requiring developer
contributions).
Policy CT 5: The transport impact on new development (specifies criteria to ensure
reduction of need to travel and promotion of sustainable forms of transport).
Policy HO 1: Dwelling mix and type (specifies type and mix of dwellings for new
housing developments).
Policy HO 2: Provision of affordable housing (specifies the requirements for provision
of affordable housing and/or contributions towards provision).
Policy HO 7: Making the most efficient use of land (Housing density) (Proposals
should optimise housing density in a manner which protects or enhances the
character of the area).
Policy EN 2: Protection and enhancement of landscape and settlement character
(specifies criteria that proposals should have regard to, including the Landscape
Character Assessment).
Policy EN 8: Protecting and enhancing the historic environment (prevents insensitive
development and specifies requirements relating to designated assets and other
valuable buildings).
Policy EN 9: Biodiversity and geology (requires no adverse impact on designated
nature conservation sites).
MAIN ISSUES FOR CONSIDERATION
1. Development plan policy.
2. Dwelling mix, density and affordable housing.
3. Landscaping / trees / settlement character.
APPRAISAL
This report should be read in conjunction with the preceding report on this agenda
which relates both to this application and the other two applications submitted on
behalf of Greshams School (refs: 14/0283 & 14/0284).
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The application site fronts on to Grove Lane and comprises a linear section of land,
which forms the periphery to an existing school playing field and a small part of which
is a former garden area.
The site lies within the 'countryside' policy area where under Policy SS2 of the Core
Strategy housing development is not permitted (apart from 'exception' affordable
housing developments and the re-use of existing buildings). The application therefore
represents a departure from the Development Plan.
In terms of the specific housing policies of the Core Strategy, Policy HO2 requires
that on schemes of 10 dwellings or more or sites of more than 0.33ha (the latter
applies in this case), not less than 45% of the total number of dwellings should be in
the form of affordable housing (subject to viability). No affordable housing is
proposed as part of this application. The applicants are proposing that 10% of the
combined total of dwellings on both this site and Sites 1 & 2 (refs: 14/0283 &
14/0284) are delivered solely on Site 1.
Core Strategy Policy HO1 requires that new housing developments should comprise
at least 40% of dwellings with no more than one or two bedrooms. Whilst detailed
house types are not applied for at this stage, it has been established through the
revised viability assessment and revisions to the design and access statement that a
total of six 4 bedroom dwellings are now proposed.
Core Strategy HO7 advocates housing densities of not less than 40 dwellings per
hectare (dw/ha) in 'Principle Settlements' such as Holt, but this is subject to the
proviso that the density of a site 'protects or enhances the character of an area'.
Maximum densities approved on allocated greenfield sites over the last year or so
have tended to be more in the region of up to 35 dw/ha. This proposal is for a low
density development equating to approximately 16 dw/ha. This low density reflects
the type of housing proposed and absence of smaller more affordable properties.
Such a density would be comparable to existing housing development on the
opposite side of Grove Lane to the site.
Core Strategy Policy EN2 which is also applicable to this application states that
development proposals should protect, conserve and, where possible enhance,
amongst other issues, settlement character and distinctive landscape features. This
part of Grove Lane marks a transition from the denser suburban part of Holt and the
semi-rural edge of the town. In order for residential development on the site to
sensitively relate to the character of the area, it would need to avoid the regimented
linear layout and loss of existing landscape features which the submitted indicative
plan presents.
Core Strategy EN9 states that development proposals that would cause a direct or
indirect adverse effect to nationally designated sites or protected species will not be
permitted unless the benefits of the development clearly outweigh the adverse
impacts and suitable prevention, mitigation and compensation measures are
provided. The issue relates to increased visitor pressure arising from new residential
development in the district, in particular upon the North Norfolk Coast SAC/SPA.
Natural England has subsequently advised that the applicants' offered payment of
£50 per dwelling (secured by S.106 Obligation) towards measures to mitigate against
the effects of increased visitor pressure should be sufficient to address this particular
concern. Similarly the Appropriate Assessment (Conservation of Habitats and
Species Regulations 2010) undertaken by the Council has reached the same
conclusion.
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Conclusions
Planning law requires that applications for planning permission must be determined
in accordance with the development plan unless material considerations indicate
otherwise. The principle of housing on this site does not accord with the development
plan (Policy SS2 - Development in the Countryside). The proposal also does not
accord in terms of specific housing policies (Policies HO1, HO2 and HO7).
The submission put forward by the applicants (referred to in detail in the preceding
report) is that the interests of Greshams School (and in turn the benefits which
accrue from the school to the economy of Holt) represent a material consideration
sufficient enough to outweigh the development plan in this case. Notwithstanding the
arguments put forward by the applicants, first and foremost this is a planning
application for residential development and as such it should be determined on that
basis. For the reasons referred to both in this report and the preceding report it is not
considered that the case put forward by the applicants is sufficient to outweigh the
significant departures from the development plan which this application represents.
Accordingly the application is recommended for refusal.
RECOMMENDATION: Refusal for the following reasons:
The District Council adopted the North Norfolk Core Strategy on 24 September 2008
for all planning purposes. The following policy statements are considered relevant to
the proposed development:
SS 1 - Spatial Strategy for North Norfolk
SS 2 - Development in the Countryside
SS 3 - Housing
SS 9 - Holt
HO 1 - Dwelling mix and type
HO 2 - Provision of affordable housing
HO 7 - Making the most efficient use of land (Housing density)
The proposal would result in an unsustainable form of development which would be
contrary to the development plan in the following respects:
(a) The application site lies outside of the development boundary for Holt in an area
designated as 'countryside' in the adopted Core Strategy. Housing development
(apart from 'exception' affordable housing developments and the conversion of
existing buildings) is not a use permitted in the countryside policy area under Core
Strategy Policy SS 2.
(b) The proposal fails to provide for an appropriate proportion of affordable housing,
contrary to the objectives of Core Strategy Policy HO 2.
(c) The proposal would result in a low density development of relatively large dwelling
types, contrary to Core Strategy Policies HO 1 and HO 7.
In the opinion of the Local Planning Authority there are no material considerations or
public benefits associated with the proposed development, of sufficient weight, to
indicate that the application should be determined other than in accordance with the
development plan.
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(Appendix 1 to report
21 August 2014)
IN THE MATTER OF SECTION 70 OF THE TOWN AND COUNTRY PLANNING ACT 1990
AND
IN THE MATTER OF SECTION 38(6) OF THE PLANNING AND COMPULSORY PURCHASE
ACT 2004
RE: The Three Outline Applications for Planning Permission for Residential
Development on Sites in Holt
________________________________
ADVICE
________________________________
Introduction
1.
This matter concerns three outline applications for planning permission for
residential development on sites in Holt (“the Applications”), made on behalf of
Endurance Estates Strategic Land Ltd and Gresham’s School (“the School”). The
land is partly owned by the School and partly by the Worshipful Company of
Fishmongers, with which the School has close historic ties. The Applications are
supported by statements that the revenue generated by the sales of the sites with
planning permission will fund new development and refurbishment improvements
to the School.
2.
I am asked by North Norfolk District Council (“the Council”) to advise on the
following issues:
(a)
(b)
(c)
(d)
Whether the position in relation to the Council’s five-year housing land
supply is to be considered as at the date of submission of the Applications, or
as at the date of determination;
Whether the Inspector’s Binding Report falls to be considered as part of the
Development Plan or as an “other material consideration” for the purposes
of section 38(6) of the Planning and Compulsory Purchase Act 2004;
The approach that the Council should adopt to the primacy of the statutory
Development Plan, specifically in relation to the relevant policies on housing
in the Core Strategy;
What weight the Council may reasonably attach to the facilitating
development case advanced in support of the applications in light of the
proposals being significant departures from the Development Plan?
1
-1
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1
3.
For the reasons given below, my view is that:
(a)
The position in relation to the Council’s five-year housing land supply is to be
(b)
The Inspector’s Binding Report is an “other material consideration”;
(c)
considered as at the date of determination of the Applications;
The approach that the Council should adopt to the primacy of the statutory
Development Plan, specifically in relation to the relevant policies on housing
in the Core Strategy, is that is the statutory presumption lies in favour of the
statutory development plan, such that development which does not accord
with CS policies should not be permitted unless material considerations
indicate otherwise. National planning policy is a material consideration, and
the extent to which the CS policies accord with the NPPF and are thus up to
date will go to the weight that should be accorded to this material
consideration. Only if the CS policies are considered to be out-of-date should
the balancing exercise in §14 of the NPPF be carried out. In assessing
whether the CS policies are out-of-date or whether they accord with the
NPPF, the age of the policies is not a determining factor, nor is the mere fact
that they seek to permit only certain types of development in the
(d)
countryside;
The weight the Council may reasonably attach to the facilitating
development case is a matter of planning judgment for the Council to
determine, given that the weight to be attributed to a material consideration
is entirely for the decision-maker (subject to review by the courts on
Wednesbury grounds). The case law in relation to enabling development
shows that a financial contribution whose purpose is to enable other
development may be material, so long as there is sufficient connection
between the proposal and that other development. In deciding whether that
is the case, it is relevant for the Council to consider whether the enabling
development is, as a matter of fact and degree, necessary to enable the linked
development. If so, consideration must be given to whether there is a
relevant and sufficient connection between the two developments, and
whether real public benefits will flow from the linked development.
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2
Appendix 2 to report
21 August 2014
The Context for the Submission of the Applications
Introduction
1.
The following text sets out the context for the submission of the applications by the School. It
identifies the vital role that Gresham’s School fulfils within Holt and the surrounding area. This
is followed by a brief description of the Academic Block which has the benefit of planning
permission. It then sets out the strategy being employed by the School to raise the necessary
funds for the construction of the Academic Block and for the improvements to the existing
Boarding Houses, explaining the importance to the school of a positive determination of the
outline applications for residential development. The text also sets out the benefits to Holt that
will arise should the application be favourably determined, including a brief description of the
main s106 contributions.
The History of Gresham’s School in Holt and how it is organised
2.
Gresham’s School has been located in Holt for over 450 years. It occupies a key position in
the town’s built form, its social history and the local economy. The School is one of the top
private educational establishments in the country with almost 800 pupils ranging from 3 to 18
years of age. The School is organised into three distinct parts the Pre-Prep School for
children aged 3 – 9, the Prep School for children aged 9 – 13 and the Senior School for
students up to 18 years of age.
3.
The School was founded in 1555 by Sir John Gresham, who converted Holt’s Manor House
into a Free Grammar School to give local children access to education. Sir John had been
Lord Mayor of London in 1547 and forged close ties with the Worshipful Company of
Fishmongers, leaving the School in their care upon his death in 1556. The School remained
within the centre of Holt for 350 years, surviving the Great Fire of 1708 which destroyed most
of medieval Holt. The original School building was extensively enlarged and refurbished in
Victorian times. Renamed ‘Old School House’ it currently serves as home to the Pre-Prep
School.
4.
At the turn of the twentieth century, Gresham’s was re-founded under the direction of the new
and innovative Headmaster George Howson. Under George Howson, the School moved to
the existing site on the edge of Holt on the northern side of Cromer Road and adopted a
progressive curriculum which embraced the sciences, encouraging independent thought and
creativity amongst its pupils. This was revolutionary in its day and marked the start of the
School’s reputation for being at the forefront of educational innovation. This modern approach
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to education produced such famous creative former pupils as W.H. Auden, Benjamin Britten
and Sir James Dyson. This trend continued when the School became one of the earliest
boarding schools to adopt co-education, which continues to this day with the School in the
forefront of the introduction and development of the International Baccalaureate alongside A
Levels.
5.
Gresham’s expanded considerably during the twentieth century, yet has retained a reputation
as a warm community with highly commended levels of pastoral care which are central to the
School’s ethos. It continues to embrace new technologies and follows a modern approach to
education and remains committed to offering a high standard of education and promoting
personal growth, shaping generations of confident and enquiring young people.
Gresham’s as part of the North Norfolk Economy
6.
Gresham’s has been and will continue to be a vital economic driver in the growth of Holt. It is
a major employer employing 375 people. As well as the £11 million spent on wages, a large
proportion of which is spent in the local economy, the School spends a significant amount of
money purchasing goods and services locally. The town also benefits from trips by parents
and pupils as shoppers to local stores and other facilities. The School is by some way the
largest employer in Holt and one of the largest non-public sector employers in the whole of
North Norfolk. It is a significant contributor to the local economy.
7.
Having regard to the length of time the School has been in Holt, together with the visual
presence of its buildings, open spaces, staff and pupils, there is no doubt that Gresham’s
remains a major part of the fabric of the town. Indeed, the public consultation exercises
undertaken in respect of the current project have reinforced the view that residents support,
in principle, the need for the School to have a strong presence in the town, a recognition that
the vitality and success of Gresham’s School is vital to the local economy, and that
encouragement should be given to provide new School buildings to maintain its
competitiveness. Details of these events are enclosed within the submitted Statement of
Community Involvement.
Gresham’s as part of the cultural life of North Norfolk
8.
The School opens its existing facilities for use by local clubs and residents as follows:
1. Swimming Pool – the pool is used by local schools, clubs and charities, such as Thornage
Hall, kayaking, sub aqua and life saving courses, etc.
2. Squash Courts – the courts are used by local clubs and individuals. The School wishes to
start up a Holt Squash Club for local residents.
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3. Tennis Courts – the courts are used by local clubs and individuals. The School has started up
the Holt Grasshopper Tennis Club but wants to develop this into a separate club for Holt
residents.
4. Sports Hall – the Hall is used by various clubs for badminton, cricket practice and charities
such as the Holt Youth Project.
5. Astro pitches – the pitches are used by local clubs over the winter and spring for football and
hockey and for hosting a major hockey festival for schools around the country.
6. Woods / grounds – used for cross country races and sports events, as well as sports camps
during the holidays.
7. Big School Hall – used for local charity events, meetings of the Holt Society, lectures where
the public are invited, fashion shows, weddings receptions, etc,
8. Auden Theatre – used for theatrical and musical productions for the public. During term time
each Thursday there is music and snacks for the public.
9. Chapel – including musical events and services for the public.
10. Holt Festival – the School provides its grounds and facilities to the Festival. Without the
School the Festival would have to find other facilities. The Pre Prep, Prep and Senior School
are all used. The Theatre in the woods is a key location for the headlining acts.
9.
In addition, the School runs music and sports camps for local children during the summer
holidays. The School also contributes to the Holt Christmas Lights Appeal, and provides the
choir to sing at this event and many more throughout North Norfolk. The proposed Sixth Form
Centre will also provide the largest lecture theatre in the area. Such a facility is essential for
the School but importantly it also provides an opportunity for such facilities to be used out of
term time for summer schools and evening classes. The Sixth Form Centre will complement
the existing community use of the School, as detailed above.
10.
The School offers bursaries to local children where they feel they would benefit from the
opportunities offered by Gresham’s. The awards are up to 100% of the fees. The School is
not wholly boarding and roughly 60% of the pupils are day pupils who live locally. It, therefore,
plays an important role in relieving pressure on the local school system as well as widening
educational choice and provision.
11.
It is the case that the world of independent education is becoming ever more competitive and
changing fast, both in terms of the demands and expectations of prospective parents and
from a fast-changing educational environment. Gresham’s must therefore move with the times
to remain a leading educational establishment attracting children not just from all over Norfolk
but from around the UK and the world to its North Norfolk campus.
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The commercial threats to Gresham’s position
12.
Gresham’s is faced with a highly competitive market and therefore needs to differentiate itself
from its competitors and offer something different. In the UK it is estimated that there are
approximately 2,600 independent schools which educate around 628,000 children
representing 7% of all British children and 18% of pupils over the age of 16.
13.
Whilst it is difficult to be exact about the overall market, according to the Crowe Clark
Whitehall 2013 Benchmarking Survey, pupil numbers declined by 0.6% in 2012 at
Independent Schools in the UK. Whilst this does not appear significant, a reduction of this
size is the largest recorded in a single year in the 17 year history of the surveys and the
reduction is spread very widely across most types and sizes of school and across most parts
of the UK.
Only in the area of Sixth Form education are numbers improving in the
independent sector.
14.
The School cannot afford to stand still in such circumstances. It must look to invest in new
facilities and strategies that look to retain student numbers in the short to medium term and, in
the longer term, it must continue to look to investigate measures to increase its attractiveness
to the market and ultimately increase its numbers.
15.
It is absolutely critical that the School remains relevant and up to date in its provision of
facilities. In looking at some of the School’s closest competitors, it can be seen that they are
investing in their schools:
King’s Ely
-
Refurbishment of the Old Bishop’s Palace for the Sixth Form and
administrative functions.
Oakham
-
New All Weather Pitches
A School of Design
A Faculty of Science
Oundle
-
A new running track
A SciTec Science Centre
Library refurbishment
Uppingham
-
A new Sports Centre
A new Science Centre and an extension to the Arts Centre
And at state boarding schools:
Wymondham -
An International Centre with eight classrooms, a media studio, an ICT suite
College
and a student lounge.
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16.
All of the above additions at these competitor Schools have been completed within the last six
years. To put this in context, the last major (>£0.5million) new building at the Gresham’s
Senior School was the Auden Theatre in 1998 and the Butterwick Building in 2002 at the Prep
School. Without doubt, Gresham’s is in danger of falling behind its competitors in terms of
new facilities. Doing nothing is therefore not an option and will only lead to a decline in the
position and strength of the School.
The Proposed New Academic Block (Sixth Form Centre) and improvements to the
Boarding Houses
17.
The School has identified a number of key projects that it wants to deliver over the longer
term (i.e. within next 10 years), the most important being the provision of a new Academic
Block as part of a Sixth Form Centre and improved boarding accommodation.
18.
A new Sixth Form Centre is absolutely vital as the provision of Sixth Form education is one
area where the independent sector is growing. Market research by the School shows this is
not just driven by demand from international students but also from local students who have
been educated by the State up to the Sixth Form age but who are looking now for the sort of
highly focused education with greater choice of options that the independent sector can offer.
The Academic Block
19.
nd
The Academic Block has the benefit of planning permission issued on 22
November 2013
(planning application reference no PF/13/1116). The detailed plans for the Academic Block
propose a two storey block with a total gross floor space of 1240m² split over 2 floors on land
north of the Auden Theatre. The form of the building comprises a long western spine which
runs the length of the building separated from the Theatre by a large new landscaping area.
20.
The long western spine of the planned new Academic Block addresses the adjacent playing
fields and the formal school campus. The main entrance to the building will be on its southern
facade, which satisfactorily addresses the relationship with the main school. The building is
10m tall at its ridge and measures 50m by 20m at its widest points and constitutes a
restrained proportion incorporating a more traditional roof slope having regard to the scale
and character of the surrounding School buildings.
21.
The ground floor includes 2 seminar rooms seating 15 students each, administrative offices, a
reception room, a careers library and a lecture theatre seating some 117 students. There is
also a large cafe area seating 102 students which, when not being used, is capable of being
transformed into an extension to the lecture theatre which is then able to accommodate 240
seated students.
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22.
The first floor includes 4 further seminar rooms and 2 study rooms for 22 and 36 students.
Toilets and storage facilities are also incorporated within the building. The Academic Block
and the improvements to the existing Boarding Houses, together, are regarded as essential
components to securing the future of Gresham’s. It is intended that the Academic Block (in
terms of the lecture theatre and study rooms) could be available out of term time for external
bodies and organisations which would add to the community role that the School already has
within Holt.
23.
Students leaving school these days need to have the skills to adapt to a changing workplace
where multiple careers will be standard and international flexibility essential. Increasingly,
students will seek out international universities; and Gresham’s needs to provide them with a
Sixth Form experience that gives them the confidence, knowledge and ability to take on these
new challenges and succeed.
24.
Gresham’s new Sixth Form Centre will therefore take its place as an increasingly distinct
entity within the Gresham’s family of schools. It will focus on key aspects of the pastoral and
academic provision as a direct response to a review of the existing Sixth Form provision. The
new Sixth Form Centre will provide students with the opportunity to assume greater
responsibility and to experience greater independence that serve as recognition of their
developing maturity and the value placed upon them.
25.
The Sixth Form Centre will be at the heart of the School, but also apart, something to strive
towards through earlier years at the School. It will be a learning building, but also one to relax
in, to develop personal skills and relationships, all requirements for the student who wishes to
have the choice either of A Levels or the International Baccalaureate, an internationally
recognised qualification that promotes independent learning and physical, intellectual,
emotional and ethical development.
26.
The availability of and the activities within the Sixth Form Centre are intended to form a bridge
between school life, university and/or the workplace. The Academic Block will be a place
where students want to go to study. It will also make a statement for the School that it wants
to continue to adapt to the changing world, encourage an international perspective in North
Norfolk, attract local students, but also encourage other students from the UK and overseas
to see Gresham’s as a wonderful place to come to learn. The School, appropriately, has
admirably high expectations for their new facilities both in terms of the architecture and build
quality and the standard of facility they intend to create.
27.
Furthermore, a new Sixth Form Centre will be seen as a major step forward in the marketing
of the School and it is extremely important that the Centre looks exciting, modern and inviting.
1.56
It needs to inspire and motivate students. It should be an exciting conclusion to their
education at Gresham’s and a stepping stone to university and the workplace.
Boarding facilities
28.
Part of an earlier strategy to maintain the School’s competitiveness included proposals to
build a new free standing Boarding House for the pupils in the final year of the School; and an
indicative location for this new building was identified in the planning application for the new
Academic Block now granted planning permission. Subsequently, a number of factors have
caused the School to reassess this part of the strategy. In summary, they are:
1. The suggested location for a new free standing Boarding House adjacent to the
Academic Block, located within in the fringes of the woods, was the subject of strong
reservations expressed during the planning application consultation period by the
Council’s Landscape officer. Accordingly, the School considered that such a building in
that particular location could be subject to significant risk in terms of securing an early
planning permission.
2. There was considerable concern from the existing Boarding House communities that
losing the upper Sixth Form students to a new free standing Boarding House would be to
the detriment of their Houses, and, to the ethos of the School. The unfortunate retirement
of the Headmaster due to ill health provided a context for a re-assessment of the issue of
new boarding facilities.
3. The School has recently been inspected by the ISI, the Independent Schools equivalent
of Ofsted. The inspectors were reviewing the boarding provision and have raised
concerns on the level of accommodation, washroom facilities and space for boarders.
These concerns must be addressed.
4. The School conducted a Parents’ survey just prior to Christmas 2013 and the findings
indicate that whilst Parents have no strong desire for new boarding buildings they wanted
improvements to the existing Boarding Houses.
29.
As a result, the School decided to put on hold a new boarding house and re-evaluate the
costs of improving the existing Boarding Houses.
30.
Accordingly, detailed assessments of the existing boarding facilities have been undertaken to
identify the required improvements to provide up to date, high quality boarding
accommodation.
1.57
31.
Such improvements identified are:
·
Reconfiguration of areas of boarding provision including improved washing facilities
·
Extensions to provide additional boarding accommodation
·
Extensions to provide increased social and gathering spaces
·
Extensions to replace sub standard accommodation for pastoral staff
·
Remodeling of Oakeley to bring up to acceptable standards including adequate washing
facilities, pastoral accommodation and social spaces.
32.
These improvements have been costed and at present currently stand at £5.129 million.
33.
Both the new build Academic Block and the improvements to the existing Boarding Houses
will position the School at the forefront of junior and senior sixth form education, reestablishing Gresham’s as a forward looking and forward thinking School that is judged
among the very best in the country. This way the School will secure its long-term future and
its position as a leading employer and stakeholder in Holt and the wider North Norfolk
community.
Funding Issues
34.
The Governors have taken the considered decision that because of the School’s particular
charitable status, and in view of the difficulties of available funding from financial institutions,
the Academic Block and the Boarding House improvements must be funded from the sale of
surplus land, which of course is subject to successful future planning applications.
The
School is an educational charity and is thus non profit making. It is not a commercial
developer looking for a profitable return. Therefore, this application must be considered in the
context of a charitable body that is obliged to raise funds which must be especially prudent in
its extent of borrowing.
35.
The School has identified the provision of a new Academic Block and the improvements of
existing Boarding House facilities as the priority project; and it is the case that the School
does not have the internal resources available to it to fulfil this project. The School itself is a
charity and it only makes a small surplus each year, certainly not enough to embark on such
an ambitious capital investment project. The Academic Block is currently costed at £4.412m
and the improvements to the boarding facilities are currently costed at £5.129m. Both projects
total £9.541m. The costings for each of the projects have been provided in separate
documents to the Council in support of the planning application.
1.58
36.
Many fee paying schools have ‘foundations’. Gresham’s, with the assistance of the Worshipful
Company of Fishmongers, established the Gresham’s Foundation in 2006 although it did not
really start to take shape until 2009. The Gresham’s Foundation is, therefore, still in its infancy
compared with the foundations of competitor schools. The twin purposes of the Gresham’s
Foundation are to foster links with the potential supporters of the School and to raise money,
predominantly for bursaries and scholarships but also for small scale capital works e.g. the
new sports pavilion. It is not a vehicle for funding major capital projects. Most of its current
funds are ‘restricted funds’ under charity law and therefore unavailable to the School for the
Sixth Form Centre project.
37.
Borrowing from financial institutions has been investigated by the School Governors; but
given the current economic climate and the uncertainties in the independent fee paying sector
within East Anglia exacerbated by the competitor schools, they feel it is too risky to take on
large amounts of debt. Indeed, institutions are not keen to lend and have stipulated that the
School should not over- extend itself to minimise risk of default. Therefore, the School is only
able to borrow small sums and nothing close to the capital sum needed to build even the
Academic Block.
38.
In these circumstances, the School Governors have looked at what assets the School holds
that are surplus to the proper operational running of the School. Three sites have been
identified south of Cromer Road that could be sold without affecting the School’s operations.
Viability work in relation to these three sites will form an important part of the separate
planning applications and will be the subject of separate representation.
39.
The reason that the School is obliged to promote this way of raising funds is because there is
no other viable alternative. Without being bold and striving both to build the new Academic
Block and improve its Boarding Houses significantly, the School will struggle against its
competitor schools and risks significant decline. Not only would this affect the School, but, in
our view, would lead to an adverse change in the historic health and vitality of Holt as a
thriving market town.
40.
Outline planning permissions are therefore being sought for these three residential
development sites, the subject of the current applications. It is envisaged that the granting of
these applications will include the necessary legal mechanisms to ensure that the funds from
the sale of the housing sites are ring fenced for the capital works for school improvements
and expansion on the Senior School site.
1.59
The benefits arising from the development proposals
41.
There are a range of wider benefits associated with the construction of the new Sixth Form
Centre and improvements to the Boarding Houses:
·
The new Sixth Form Centre is intended to be used for community use during non-term time
and will provide a lecture theatre venue for evening classes and summer schools
·
The improvements to boarding accommodation will provide over 400 bed spaces for use for
summer schools
·
The new Sixth Form Centre together with the improvements to the Boarding Houses will
support the future of the School and in turn the economic vitality of Holt in terms of new
spending and investment
·
The construction phase will provide new job opportunities within the town
·
New residential development will increase spending power of local people and assist in
maintaining and improving the vitality of services and facilities within Holt.
42.
Economic and social benefits relating to the proposed residential developments would be :
·
Improvements to Grove Lane footpath provision and doctors layby
·
Traffic calming measures along Grove Lane
·
Improved links along Cromer Road between High Kelling Hospital and Holt town centre
·
Provision of affordable housing
·
Creation of new managed Public Open Space on Site 1
·
The opportunity to secure a new range of residential development of differing styles and
tenure for local residents and the market in general
·
New residential development in a sustainable location in one of the largest market towns
within the District
·
Safeguarding any future use of the North Norfolk railway line which lies to the east of Site 1
·
Any uplift arising from the sale of the sites will go toward affordable housing and provision of
local bursaries for local children to go to Gresham’s.
43.
There are also a number of financial contributions which, whilst mitigating the impacts of the
proposed residential developments, will also be of benefit to the wider public. These are
summarised below and are also included in more detail within the S.106 Heads of Terms.
1.60
Residential development for a maximum of 126 dwellings (PO/14/0283) (approximate contributions
based on provision of 126 dwellings) –
£6,300
Norfolk Coast Visitor Pressure - towards monitoring and mitigation of impacts
on the North Norfolk Coast and ensuring compliance with the requirements of
the Habitat Regulations.
£7,500
NCC Highways - for the maintenance of a new bus shelter proposed along
Cromer Road.
£51,000
NNDC Countryside and Parks – an off-site contribution to be used in
improving the Peacock Lane recreation ground and play area in Holt.
£44,200
NHS – to mitigate the ‘capital costs’ to the NHS for the provision of additional
healthcare services arising directly as a result of the development proposal.
Approx. £383,566
Primary Education – towards enabling the Primary School to expand to a
1.5FE which would meet the needs generated by the development.
£7,560
Libraries – to increase the capacity of Holt library in terms of stock, such as
books and information technology.
£2,676
Fire services – for the provision of additional hydrants
£35,000
Contribution towards Hopper Bus service – a proposed new, additional bus
route travelling through the town, past the proposed new developments as
well as the Hempstead Road new development, via the Doctors Surgery and
Hospital.
Up to £20,000
A sum of money payable by the owner of the site to the County Council (up to
£20k) in the event that traffic surveying shows that more vehicles have been
generated over a five year period when compared with an initial survey
carried out when the site is fully occupied.
Residential development for a maximum of 19 dwellings (PO/14/0284) – (approximate contributions
based on provision of 19 dwellings)
£950
Norfolk Coast Visitor Pressure – towards monitoring and mitigation of impacts
on the North Norfolk Coast and ensuring compliance with the requirements of
the Habitat Regulations.
£7,000
Countryside and Parks -– an off-site contribution to be used in improving the
Peacock Lane recreation ground and play area in Holt.
Approx. £57,839
Primary Education – towards enabling the Primary School to expand to a
1.5FE which would meet the needs generated by the development.
£1,140
Libraries – to increase the capacity of Holt library in terms of stock, such as
books and information technology.
£892
Fire Services – for the provision of additional hydrants
1.61
Residential development for a maximum of 8 dwellings (PO/14/0274) – (approximate contributions
based on provision of 8 dwellings)
£400
Norfolk Coast Visitor Pressure – towards monitoring and mitigation of impacts
on the North Norfolk Coast and ensuring compliance with the requirements of
the Habitat Regulations.
Approx. £24,353
Primary Education – towards enabling the Primary School to expand to a
1.5FE which would meet the needs generated by the development.
£480
Libraries – to increase the capacity of Holt library in terms of stock, such as
books and information technology
Conclusion
44.
It is the case that in the 459 years of Gresham’s School, this is probably now the most
important time in its history. The School has reached a point where it is essential that it
invests in itself and its only remaining source of funds is from the sale of these three sites.
Decisions at this Planning Committee will have a major bearing on the School’s future . The
granting of residential planning permissions for these three sites will allow the School to reposition itself in an increasingly competitive market to ensure that the School has a healthy
future for generations to come and continue to play its part in the prosperity of Holt and the
wider North Norfolk economy. Accordingly, it is vitally important that Officers and Members
fully understand all of the issues in coming to those decisions.
1.62
Appendix 3 to report
21 August 2014
August 2014
EXECUTIVE SUMMARY
Sites 1 to 3, Cromer Road, Holt
Prepared for:
Greshams School
Prepared by:
Ciara Arundel BSc (Hons) FRICS
Director
For and on behalf of:
Savills (UK) Ltd
Hardwick House
Agricultural Hall Plain
Norwich
NR1 3FS
1.63
Contents
Contents ................................................................................................................................................ 2
1.
Introduction ............................................................................................................................... 3
2.
Methodology ............................................................................................................................. 4
3.
Assumptions ............................................................................................................................. 6
4.
Results ....................................................................................................................................... 8
5.
Summary and Conclusion ....................................................................................................... 9
Viability Executive Summary
Page 2 of 9
1.64
1.
Introduction
1.1
This Executive Summary is submitted to the North Norfolk District Council on behalf of
Greshams School, (‘the Applicant’) for use in the public domain. It summarises the Viability
Report dated 11 April 2014 and subsequent Viability Side letter, both of which support the
three outline planning applications for land known as Sites 1 to 3, Holt.
1.2
None of the sites fall within the settlement boundary of Holt. The applications are made
having regard to Section 38(6) of the Planning and Compulsory Purchase Act 2004, as it is
considered that the material considerations in respect of the applications are significant
enough to support a departure from the development plan. Greshams School has a need to
expand its education provision in order that it may continue to be key to employment
opportunities and investment and the economic prosperity of Holt. Please refer to the
“Greshams – The Context for the Submission of the Applications” document, which forms part
of this application for further information.
Viability Executive Summary
Page 3 of 9
1.65
2.
Methodology
2.1.
The financial viability of a development proposal is determined using the residual land value
method. The costs of the development are deducted from the Gross Development Value
(GDV), which is the total value of the completed dwellings. A summary of this residual
valuation process is shown below.
Built Value of
Proposed Private
Dwellings
+
-
GDV
Built Value of
Affordable Housing
Build Costs +
Finance Costs +
Section 106
Contributions + Fees
+ Abnormal Costs +
Developer’s Profit
=
GDV
=
Residual Land
Value
2.2.
The residual land value is then compared to the benchmark land value of the site to assess if
the proposed development is viable. The benchmark land value, in normal circumstances is
assessed in one of a number of ways including Market Value (the value of comparable sites,
with or without planning permission, traded in the open market), Existing Use Value (the value
of the land on the special assumption that it continues in its existing use) and Alternative Use
Value (the value based on an alternative, higher value use, which is acceptable in planning
terms).
2.3.
Greshams School is seeking to obtain planning permission on these three sites to fund the
development of a new Academic Block and the refurbishment of the boarding houses plus
ancillary costs, including fees. The sum of the development and ancillary costs/fees, in this
instance, forms the benchmark land value, as follows:
Item
Cost
Academic Block
£4,412,000
Improvements to Boarding Houses
£5,129,000
Build Cost Total
£9,541,000
Viability Executive Summary
Page 4 of 9
1.66
2.4.
Planning
£350,000
Masterplanning
£90,000
Legal Fees
£50,000
Ancillary Costs Total
£490,000
Promoter’s Return (10% of Net Receipt)
£1,036,701
Total
£11,067,701
It is hereby stated that based upon the potential planning obligations contained in the draft
Section 106 Agreement, in the current climate and allowing for current revenues and costs,
the development of this land is unable to provide sufficient revenue from the sale of sites 1 to
3 to fund the development of the Academic Block and the improvements to the boarding
houses plus the associated costs, at the planning policy level of 45% affordable housing
provision.
Viability Executive Summary
Page 5 of 9
1.67
3.
Assumptions
3.1
We set out below the headline data that makes up our residual land valuation, in line with the
summary at Section 2.4 above. The assumptions adopted have been considered by council
officers and independent consultants appointed on the Council’s behalf.
3.2
The three sites are described briefly below. The areas provided are the net developable part
of each site and excludes roads, open space etc.
Site 1
This been masterplanned with up to 126 dwellings over a net developable area of 3.95
hectares (9.75 acres). This shows a density of about 32 dwellings per hectare (13 dwellings
per acre), which is suitable for standard family housing. The accommodation ranges from 1
bed apartments to 4 bed detached houses, most of which has garaging but otherwise
designated parking. The dwelling size range is between 46 and 120 sq m (495 and 1,292 sq
ft). The viability appraisal has regard to the current housing need for smaller dwellings.
Site 2
This has capacity for up to 19 detached 4/5 bed houses with double garages in large plots,
accessed off a central estate road. The size range is between 140 and 230 sq m (1,507 and
2,476 sq ft). The net developable area of this site is 1.30 hectares (3.22 acres). The viability
has been assessed against the full capacity of 19 units.
Site 3
This is a shallow site with a net developable area of 0.30 hectares (0.74 acres). It has been
masterplanned for up to eight detached, two storey dwellings with double garages, all fronting
Grove Lane and each accessed off it via separate driveways. In order to maximise the value
on this site for the purposes of the viability, it has been appraised on the basis of six detached
dwellings, each with 4/5 bedrooms and with an internal area of 230.03 sq m (2,476 sq ft).
3.3
From the above, it can be seen that we have appraised a total of 151 units. In order to
achieve the maximum land values possible, we have assumed that the full affordable
provision would be developed on Site 1 but that the percentage would be derived from the
total number of units across the three sites, i.e. 151 units at 10% = 15 affordable units.
3.4
North Norfolk District Council has taken advice from an independent agency in relation to the
GDV. We have adopted these figures in our appraisal.
3.5
In accordance with the report by Sir John Harman entitled Viability Testing Local Plans,
issued in 2012, we have adopted current (June 2014) BCIS build costs. For Sites 2 and 3, it
is assumed these will be built to a high specification in order to maximise the value of the
completed dwellings. We have therefore adjusted the BCIS figures upwards to allow for
these additional cost incurred in a high end development.
Viability Executive Summary
Page 6 of 9
1.68
3.6
Discussions with the Council to date around the draft Section 106 Agreements indicate that
the following contributions will be payable:
Contribution
Site 1
Site 2
Site 3
Primary Education
£383,556
£57,839
£24,353
Library
£7,560
£1,140
£480
Fire
£2,676
£892
£0
Countryside / Parks
£51,000
£7,000
£0
Norfolk Coast Visitor Pressure
£6.300
£950
£400
NCC Highways
£7,500
£0
£0
NHS
£44,200
£0
£0
Hopper Bus
£35,000
£0
£0
Total
£537,792
£67,821
£25,233
3.7
In our appraisals we have allowed for the provision of photovoltaic panels to fulfil the
requirement to secure at least 20% of the energy of the developments from decentralised and
renewable or low-carbon energy sources. We have also allowed for the affordable homes to
be built to a minimum Code Level 3 rating in accordance with the requirements of the Code
for Sustainable Homes: Technical Guide.
3.8
All of our other inputs are within the parameters indicated as acceptable in both the Viability
Testing Local Plans report and the RICS guidance issued in August 2012. As stated above
however, the benchmark land value has been derived in a non-standard manner.
Viability Executive Summary
Page 7 of 9
1.69
4.
Results
4.1
We have run our appraisal using Argus Developer software, which is an industry accepted
toolkit.
4.2
At an affordable provision of 10%, the resulting land value is marginally less than the cost of
the proposed development and ancillary costs, i.e. the benchmark land value. Greshams
School will therefore need to fund the shortfall and has confirmed that the gap funding can be
achieved via a loan from a commercial lender.
.
Viability Executive Summary
Page 8 of 9
1.70
5.
Conclusion & Summary
5.1.
It is felt that the information and figures adopted within the viability appraisal and report are in
line with the costs we would expect to see for developments of this nature. The revenue
adopted is that advised by the Council’s independent agents and sits at the top end of the
range of current values.
5.2.
The build costs used are on a comparable timeline (June 2014) to the GDV.
5.3.
The schemes would only be able to sustain the proposed level of Section 106 contributions,
including affordable housing if the residual land value derived was in excess of the benchmark
land value. In this instance Greshams School needs to realise a value aligned with the
proposed development and ancillary costs.
5.4.
Our appraisals indicate that, at 10% affordable provision, the benchmark land value is
marginally lower than the residual value of the land which would require Greshams School to
fund the remainder through borrowing. The level of borrowing is within the scope of the
School and we therefore consider that the three sites can support 10% affordable housing
plus the other Section 106 contributions as set out above.
5.5.
From the total of 151 units appraised across the three sites, a total of 15 affordable units will
be provided. All of the provision for affordable housing will be on Site 1.
5.6.
In order to catch any uplift in the receipts over the benchmark land value received by
Greshams School upon the final sale of the three sites, there will be a “clawback” provision
within the Section 106 Agreement. 100% of any surplus land receipts will form an additional
contribution and can be utilised by the Council and the School and will be split 50/50 between
the provision of affordable housing and for bursaries to offer an education at Greshams
School for local pupils. Please see the submitted Heads of Terms for the Section 106
Agreement for further detail on this.
Viability Executive Summary
Page 9 of 9
1.71
Appendix 4 to report
21 August 2014
Heads of Terms
Section 106 Agreement (under Town and Country Planning Act 1990)
The following areas are proposed for inclusion within a legal agreement to be entered into between
the School, the other trustee landowners, the District Council and the County Council which will cover
all 3 sites but with severable obligations relating to each as follows:
Site 1:
Key principles;
·
·
The “ring fencing” of funds from the sale of the site with the benefit of planning permission
towards the capital works for the Academic Block and the improvements to the boarding
houses on the School’s campus (the “Approved Project”).
Monies from land sale will be spent on Approved Projects with five years.
Affordable housing;
·
·
·
·
·
·
·
The provision of 10% on-site affordable housing plus affordable housing elements from Sites
2 and 3 (total of 15 affordable units).
Provision of necessary uplift clauses in any agreement which would provide for the sharing
between the School and the District Council of all net receipts over and above the cost of the
new Academic Block and improvements to the existing Boarding Houses when the sites are
sold with the benefit of planning permission
This uplift provision will be split 50/50 between additional affordable housing and bursaries for
local children seeking an education at Gresham’s.
An additional uplift clause will be provided to deliver a share of any GDV uplift the School
receives if such an overage mechanism is agreed and secured through the land sales
process (which would be a matter of negotiation on a site by site basis)
Scheme for provision of affordable housing to be provided to the Council alongside reserved
matters application for Site 1
50% of affordable housing to be provided on Site 1 by occupation of 50% of market units on
site 1. The last market unit on site 1 will not be occupied until the provision of the last
affordable housing unit.
A mechanism to ensure provision of the affordable elements relating to Sites 2 and 3 (three
units) will be secured. This will seek the ring fencing of certain monies (of equivalent value)
from the sale of sites 2 and 3 until such time as three affordable units are delivered on site 1.
Beyond a longstop of [x] years, if such units have not been delivered on Site 1, such monies
will be passed to the Council for the provision of 3 units in the District.
Contributions/mitigation;
·
·
·
·
Provision of a financial contribution of £51,000 to the Council prior to occupation of 50% of the
dwellings to be used in improving the Peacock Lane recreation ground and play area in Holt.
A financial contribution will be paid to Norfolk County Council in accordance with the provision
of the NCC Planning Obligations SPD taking into account need/spare capacity on education
provision. This totals approximately £383,566 and will go towards enabling the Primary
School to expand to a 1.5FE which would allow it to meet the needs of additional dwellings in
the village. Payments will be made in 3 equal tranches after 20%, 40% and 60% occupation
of the dwellings.
The securing of a Travel Plan to encourage modal shift away from the private motor car
including a sum of money payable by the owner of the site to the County Council (up to £20k)
in the event that traffic surveying shows that more vehicles have been generated over a five
year period when compared with an initial survey carried out when the site is fully occupied.
A financial contribution of £7,560 will be paid to Norfolk County Council prior to first
occupation regarding specific matters relating to library provision. This will contribute towards
1.72
·
·
·
·
·
increasing the capacity of Holt library in terms of stock, such as books and information
technology.
A financial contribution of £6,300 to the Council prior to 50% occupation towards monitoring
and mitigation of impacts on the North Norfolk Coast and ensuring compliance with the
Habitat Regulations.
A financial contribution of £7,500 to NCC Highways prior to 50% occupation for the
maintenance of a new bus shelter proposed along Cromer Road.
A financial contribution of £44,200 to the Council prior to 50% occupation to enable the NHS
to mitigate the ‘capital costs’ to the NHS for the provision of additional healthcare services
arising directly as a result of the development proposal.
A financial contribution of £35,000 to the Council prior to 50% occupation towards the Hopper
Bus service – a proposed new, additional bus route travelling through the town, past the
proposed new developments as well as the Hempstead Road new development, via the
Doctors Surgery and the Hospital.
Provisions securing on site open space and a woodland buffer zone around the north and
west of the site.
Section 278 Agreement (under Highways Act 1980)
The following areas are proposed for inclusion within any legal agreement:
·
Proposed highway works to construct identified build-outs and new footpaths.
Heads of Terms
Site 2:
Key principles;
·
·
The “ring fencing” of funds from the sale of the site with the benefit of planning permission
towards the capital works for the Academic Block and the improvements to the boarding
houses on the School’s campus (the “Approved Project”).
Monies from land sale will be spent on Approved Projects with five years.
Affordable housing;
·
·
·
·
·
Provision whereby 10% of affordable housing on this application site is provided off-site (on
Site 1 – south of Cromer Road and east of Grove Lane)
Provision of necessary uplift clauses in any agreement which would provide for the sharing
between the School and the District Council of all net receipts over and above the cost of the
new Academic Block and improvements to the existing Boarding Houses when the sites are
sold with the benefit of planning permission
This uplift provision will be split 50/50 between additional affordable housing and bursaries for
local children seeking an education at Gresham’s.
An additional uplift clause will be provided to deliver a share of any GDV uplift the School
receives if such an overage mechanism is agreed and secured through the land sales
process (which would be a matter of negotiation on a site by site basis)
A mechanism to ensure provision of the affordable elements from Sites 2 and 3 (three units)
will be secured. This will seek the ring fencing of certain monies (of equivalent value) from the
sale of sites 2 and 3 until such time as three affordable units are delivered on site 1. Beyond a
longstop date of [x] if such units have not been provided on site 1, such monies will be passed
to the Council for the provision of 3 units in the District.
1.73
Contributions/mitigation:
·
·
·
·
·
A financial contribution of approximately £57,839 will be paid to Norfolk County Council prior
to first occupation in accordance with the provision of the NCC Planning Obligations SPD
taking into account need/spare capacity on education provision. This contribution will go
towards Primary Education, to enable the Primary School to expand to a 1.5FE which would
meet the needs of additional dwellings in the village.
Provision of a financial contribution of £7,000 to the Council prior to occupation of 50% of the
dwellings to be used in improving the Peacock Lane recreation ground and play area in Holt.
A financial contribution of £950 to the Council prior to 50% occupation towards monitoring and
mitigation of impacts on the North Norfolk Coast and ensuring compliance with the Habitat
Regulations.
A financial contribution of £1,140 will be paid to Norfolk County Council prior to first
occupation regarding specific matters relating to library provision. This will contribute towards
increasing the capacity of Holt library in terms of stock, such as books and information
technology.
Provisions to secure on site open space
Section 278 Agreement (under Highways Act 1980)
The following areas are proposed for inclusion within any legal agreement:
·
Proposed highway works to construct build out, new layby and new footpaths along Grove
Lane and Cromer Road.
Heads of Terms
Site 3:
Key principles;
·
·
The “ring fencing” of funds from the sale of the site with the benefit of planning permission
towards the capital works for the Academic Block and the improvements to the boarding
houses on the School’s campus (the “Approved Project”).
Monies from land sale will be spent on Approved Projects with five years.
Affordable housing:
·
·
·
·
·
·
Provision whereby 10% of affordable housing on this application site is provided off-site (on
Site 1 – south of Cromer Road and east of Grove Lane)
Provision of necessary uplift clauses in any agreement which would provide for the sharing
between the School and the Council of all net receipts over and above the cost of the new
Academic Block and improvements to the existing Boarding Houses when the sites are sold
with the benefit of planning permission
This uplift provision will be split 50/50 between additional affordable housing and bursaries for
local children seeking an education at Gresham’s.
An additional uplift clause will be provided to deliver a share of any GDV uplift the School
receives if such an overage mechanism Is agreed and secured through the land sales
process (which would be a matter of negotiation on a site by site basis)
Scheme for provision of affordable housing to be provided to the Council alongside reserved
matters application for Site 1
A mechanism to ensure provision of the affordable elements relating to Sites 2 and 3 (three
units) will be secured. This will seek the ring fencing of certain monies (of equivalent value)
from the sale of sites 2 and 3 until such time as three affordable units are delivered on site 1.
1.74
Beyond a longstop date of [x], if such units have not been delivered on site 1, such monies
will be passed to the Council for the provision of 3 units in the District.
Contributions/mitigation:
·
·
·
A financial contribution of approximately £24,353 will be paid to Norfolk County Council prior
to first occupation in accordance with the provision of the NCC Planning Obligations SPD
taking into account need/spare capacity on education provision. This contribution will go
towards Primary Education, to enable the Primary School to expand to a 1.5FE which would
meet the needs of additional dwellings in the village.
A financial contribution of £400 to the Council prior to 50% occupation towards monitoring and
mitigation of impacts on the North Norfolk Coast and ensuring compliance with the Habitat
Regulations.
A financial contribution of £480 will be paid to Norfolk County Council prior to first occupation
regarding specific matters relating to library provision. This will contribute towards increasing
the capacity of Holt library in terms of stock, such as books and information technology.
Section 278 Agreement (under Highways Act 1980)
The following areas are proposed for inclusion within any legal agreement:
·
Proposed highway works to construct new footpath along the site frontage on the north side
of Grove Lane.
1.75
APPENDIX 2
21 AUGUST 2014
Minutes of a meeting of the DEVELOPMENT COMMITTEE held in the Council Chamber,
Council Offices, Holt Road, Cromer at 9.30 am when there were present:
Councillors
Mrs S A Arnold (Chairman)
R Reynolds (Vice-Chairman
M J M Baker
Mrs L M Brettle
Mrs P Grove-Jones
P W High
J A Wyatt
J H Perry-Warnes
R Shepherd
B Smith
Mrs A C Sweeney
Mrs A Claussen-Reynolds (substitute for Mrs A Green)
Mrs B McGoun (substitute for Mrs V Uprichard)
N Smith (substitute for Miss B Palmer)
B Cabbell Manners – Cabinet Member for Planning
T FitzPatrick - observing
Officers
Mrs N Baker – Head of Planning
Mr R Howe – Planning Legal Manager
Mr J Williams – Team Leader (Major Developments)
Mrs N Turner – Housing Team Leader - Strategy
Mrs C Batchelar – Landscape Officer
Mr C Skinner – Solicitor, NP Law
Mr A Willard – Norfolk County Council (Highways)
(62)
APOLOGIES FOR ABSENCE AND DETAILS OF SUBSTITUTE MEMBERS
Apologies for absence were received from Councillors Mrs A R Green, Miss B
Palmer and Mrs V Uprichard. Three substitute Members attended the meeting as
shown above.
(63)
ITEMS OF URGENT BUSINESS
The Chairman stated that there were no items of urgent business which she wished
to bring before the Committee.
(64)
DECLARATIONS OF INTEREST
The following interests were declared in all applications to be discussed:
Councillor J H Perry-Warnes
Personal, non-pecuniary interest as his
grandson attended the school.
Personal, non-pecuniary interest as he
owned a holiday let in Holt.
Personal, non-pecuniary interest in the
following applications as he had come to
the end of his fixed term appointment as
a Governor in June.
Councillor R Reynolds
Councillor M J M Baker
2.1
Councillor Mrs A Claussen-Reynolds
Personal, non-pecuniary interest as she
was the co-owner of property in Holt.
Knew many people who were attending
the meeting.
Councillor P W High
(65)
PROCEDURAL MATTERS
The Head of Planning reported that a request had been received from the applicant
to consider all three applications together given the facilitating development issues.
Having taken advice on this request, the introductory report would be presented first,
upon which there would be no public speaking, followed by the presentation, public
speaking and debate on each application in turn. No proposals would be sought
from the Committee until all three applications had been presented and debated and
Members had an understanding of the interrelationship between the proposed
developments. Members would then be invited to make proposals on each
application in turn.
PLANNING APPLICATIONS
Where appropriate the Planning Officers expanded on the planning applications;
updated the meeting on outstanding consultations, letters/petitions received objecting
to, or supporting the proposals; referred to any views of local Members and
answered Members’ questions.
Background papers, including correspondence, petitions, consultation documents,
letters of objection and those in support of planning applications were available for
inspection at the meeting.
Having regard to the above information and the Officers’ report, the Committee
reached the decisions as set out below.
Applications approved include a standard time limit condition as condition number 1
unless otherwise stated.
(66)
PLANNING APPLICATIONS ON BEHALF OF GRESHAMS SCHOOL FOR
RESIDENTIAL DEVELOPMENTS IN HOLT
The Team Leader (Major Developments) presented an introductory report which
outlined the principal issues to assist the Committee in making an informed decision.
He presented an aerial photograph showing all three sites. Detailed comments on
the Officer’s reports had been received from the applicants and circulated to the
Committee.
The Team Leader (Major Developments) referred to the case put forward by the
applicants for funding of improvements to school facilities and the principal reasons
given in the applicants’ report which was appended to the report.
The Team Leader (Major Developments) referred to Counsel’s advice regarding
facilitating developments, a summary of which was appended to the report.
Provision of finance could be material provided there was a relevant and sufficient
connection between the two developments and real public benefit would flow from
the linked development.
2.2
The Team Leader (Major Developments) referred to the planning history of the sites,
particularly in relation to site 1 (PO/14/0283) and issues relating to site allocations
and enabling development. The Inspector’s binding report did not form part of the
Development Plan but could be taken into account as an “other material
consideration”.
In respect of Development Plan considerations, the Team Leader (Major
Developments) stated that legal advice had been sought as to the current primacy of
the Core Strategy, given its publication prior to the National Planning Policy
Framework (NPPF). In the view of Officers, the Council’s housing policies were not
out of date and Officers were confident that the housing figure for Holt could be
achieved without the need to approve other large scale developments. He referred
to the relevant policies in the Core Strategy.
The Team Leader (Major Developments) referred to a confidential report in respect of
viability which had been submitted by the applicants, an executive summary of which
was appended to the report. He explained the difference between the conventional
method of assessing viability based on residual land value and the method which had
been adopted by the applicants.
Whilst the applicants now appeared to be questioning the methodology used in
calculating the five year land supply, previously they had indicated that this was not
the main point in arguing their case for approval.
The Team Leader (Major Developments) referred to the Heads of Terms of the
Section 106 Obligation in the event of permission being granted, and in particular, to
issues concerning the uplift clause being proposed by the applicants, which was not
the normal form of uplift and carried an increased risk that there would be no
additional funding for affordable housing.
In conclusion, all applications were departures from Development Plan policy, not
only in their location but also in terms of some of the Council’s key housing policies.
(67)
HOLT - PO/14/0283 - Residential development for a maximum of 126 dwellings;
Land South of Cromer Road and East of Grove Lane for Endurance Estate
Strategic Land Ltd and Gresham's School
The Committee considered item 2 of the Officers’ reports.
Public Speakers
Mr B Payne (Holt Town Council)
Mr B Whiffen (objecting)
Mr M Burnham (objecting)
Mr I Furness (supporting)
Mr D Jenkins (supporting)
Mr N Flower (supporting)
Mr J Morgan (supporting)
The Team Leader (Major Developments) displayed photographs of the site, including
an aerial photograph and outlined the main concerns. The recent submission by the
applicants had argued that the site was sustainable. He reminded the Committee that
the planning applications were first and foremost for housing development. He
recommended refusal of this application as stated in the report.
2.3
Councillor B Cabbell Manners, Cabinet Member for Planning, stated that this was a
very important application, not only for Gresham’s School, but for North Norfolk and
Norfolk as a whole. The benefits to the school were huge, but he considered that
everyone would gain from its economic growth. There was a need to support this
important facility.
Councillor P W High, a local Member, considered that all public speakers had raised
valid points. He was aware of the economy of Holt and the economic benefits the
school brought to the town. He considered that the school should be supported, but
the application had to be considered on planning grounds and not the viability of the
school. There were planning grounds on which to refuse the application. He referred
to affordable housing issues, access to Grove Lane and existing housing allocations.
Councillor M J M Baker, the local Members, stated that he wished to hear from other
Members before making comments.
Councillor J Perry-Warnes stated that Grove Lane was narrow and it was difficult to
manoeuvre. He considered that traffic from the development should not use Grove
Lane. He considered that the 10% affordable housing being offered was unfair and
requested clarification as to how any surplus would be spent. He referred to car
parking in the town. He considered that the footpath should be improved
immediately and commented that the Highway Authority supported the application.
He considered that green space should not be lost and that the school should
provide additional playing fields to compensate for those being lost.
The Team Leader (Major Developments) stated that site 1 had access onto Cromer
Road and he anticipated that the majority of traffic would use Cromer Road rather
than Grove Lane. There were no proposals to prevent the use of Grove Lane, but
there were proposals for traffic calming. Car parking in the town was not an issue
related to this application.
The Housing Team Leader - Strategy explained the form of affordable housing uplift
which the applicants were proposing. It provided less certainty than the standard
form of affordable housing uplift.
The Landscape Officer stated that the proposals represented development in the
Countryside and would result in a net loss of green space to the town of Holt.
The Highways Officer stated that whilst there would be some traffic from the site
turning into Grove Lane, he considered that the increase would be minimal and that
children from the site would walk to school.
Councillor R Reynolds stated that both the school and tourism were important to Holt.
The school was important in terms of employment and revenue. He stated that the
proposals were very important to the school but had to be within the planning laws.
He considered that small one and two bedroom houses and apartments could be
considered to be affordable and therefore he was not too concerned that 10%
affordable housing was being proposed.
Councillor Mrs B McGoun stated that she understood that all the applications were
departures from policy, but had come forward as there were other possible
considerations. She had researched Gresham’s school, and the Fishmongers’
Company, which appeared to be a property company. She referred to the NPPF
which appeared to smooth the way for challenging sites. She stated that Greshams
needed to remain relevant and increase its attractiveness to its market, and consider
2.4
all ways of raising funds. However it was a balancing act. She referred to the
sustainability score and questioned whether any real public benefits would flow from
this application. She was very disappointed at the low percentage of affordable
dwellings. She expressed concern that the proposed dwellings, in addition to the
proposed dwellings on the allocated sites, would put too much pressure on
infrastructure.
The Team Leader (Major Developments) explained that the current proposal
envisaged 150 dwellings in addition to those proposed on the allocated sites. He
referred to the infrastructure contributions the applicants had agreed as set out in the
report, as requested by the Norfolk County Council and the NHS.
Councillor Mrs A Claussen-Reynolds asked how the developers had arrived at the
mix of housing on each site and how quickly the houses would be delivered. She
also asked if the school facilities would remain available to the public, eg. theatre and
swimming. She requested the exact number of employees and the wages bill. She
requested an explanation of the difference between “planning fees” and
“masterplanning fees”.
The Team Leader (Major Developments) explained that planning fees related to the
cost of submitting a planning application. Masterplanning was a wider concept which
he considered did not apply in this case as it related to land use and phasing on
larger sites.
At the invitation of the Chairman, Mr Furness, on behalf of the applicant, explained
that planning also took into account other costs such as energy assessment advice
and agent’s fees. Advice had been sought from Savills as to the most appropriate
house types and it had been suggested that there was a need for larger houses.
There had been a strong interest from housebuilders and, if approved, reserved
matters applications could be submitted by the end of the year, with completion
towards the end of 2015. A representative of the School gave details of the payroll
and number of employees.
The Chairman referred to the Officer’s report which stated that facilities would remain
available.
Councillor N Smith stated that businesses needed to update and raise funds, but the
houses would still be there in 100 years’ time, whereas there was no guarantee that
the school would remain in 10 years’ time.
Councillor B Smith stated that he was aware of the importance of Gresham’s to Holt
and the surrounding area, but the Committee was concerned with the planning
issues and not a financial proposition. Site 1 was outside the Development Plan, did
not conform to Core Strategy policies and he was concerned that approval would set
a precedent.
Councillor Mrs L Brettle stated that although the site was in designated Countryside,
it was adjacent to the Development Boundary, was not isolated, and not far from the
town centre. The proposal would provide housing, and she hoped that there would
be more emphasis on affordable housing.
Councillor R Shepherd expressed concern at the impact approval of this application
would have on the Council’s policies and planning law, impact on Grove Lane, loss of
Holt’s identity and destruction of green space and countryside.
2.5
Councillor P W High referred to a previous scheme to deal with traffic issues which
had been put forward by the Highway Authority. Whilst this did not proceed, he
considered that it was proof that the Highway Authority had concerns.
The Highway Officer explained the reasons why the previous scheme had not
proceeded. He did not dispute the lack of footpath provision along parts of Grove
Lane. He stated that the access to Cromer Road was in accordance with normal
requirements for a development of this type and the increase of traffic on Grove Lane
would be minimal. He had no reason to dispute the findings of the traffic statement.
Councillor M J M Baker, a local Member, stated that Holt was a lovely town and
people wanted to live there. People were drawn to the town by the school and
everything North Norfolk had to offer. The Committee was making a decision about
the most important employer in the area. He disputed comments which had been
made that only the school and the Fishmongers Company would benefit. He stated
that money would go back into the school, which was not in itself wealthy. He
referred to the employment issues and stated that £10m worth of building jobs would
be created. He stated that the school was central to North Norfolk and it was very
important that it was allowed to progress and remain competitive.
Councillor R Shepherd raised a point of order that Councillor Baker should declare
an interest as a major businessman in Holt. The Chairman stated that Councillor
Baker had taken legal advice on this matter.
Councillor P W High stated that Councillor Baker had spoken about Gresham’s
School rather than the planning issues.
(68)
HOLT - PO/14/0284 - Residential development for a maximum of 19 dwellings;
Land South of Cromer Road and West of Grove Lane for Endurance Estates
Strategic Land Ltd and Greshams School
The Committee considered item 3 of the Officers’ reports.
Public Speakers
Mr B Payne (Holt Town Council)
Mr D Jenkins (supporting)
Mr J Stronach (supporting)
Mr T Holmes (supporting)
Mrs Prior (supporting)
The Team Leader (Major Developments) presented photographs of the site and
surrounding area, including an aerial photograph. He stated that the proposals would
result in a change in the character of the area, not only from the change of use but
also because of the formal footpaths which were proposed. He presented an
illustrative plan showing the possible layout of the site. He recommended refusal of
this application.
Councillor B Cabbell Manners stated that the site was surrounded by housing or a
school campus. It was in the centre of an urban area. He considered that if the
access were designed properly, all traffic would use Cromer Road and it would be
possible to make Grove Lane one-way with traffic going away from the school. He
considered that the Inspector had not said that this site should not be developed,
only that H01 was a better site. He referred to the support by Holt Town Council and
the Chamber of Trade. He stated that this application was very important, not only to
Holt but to the surrounding area.
Development Committee
21 August 2014
2.6
Councillor P W High referred to the comments he had made on the previous
application regarding planning. He considered that planning policy outweighed the
running of the school. He referred to the site allocations and previous applications
submitted by Gresham’s School prior to the Inspector’s binding report.
Councillor M J M Baker stated that the long term benefit to the area was a planning
issue and this application should therefore be supported.
Councillor R Reynolds considered that the securing of contributions towards primary
school education and library provision through a Section 106 Obligation was a
material consideration which should be taken into account.
Councillor Mrs B McGoun asked for advice regarding precedent.
The Planning Legal Manager stated that in legal terms there was no precedent in
planning, however in practical terms it was likely that other developers would
consider the decisions taken at this meeting. He referred to a request on the agenda
to undertake a site inspection on another site in Holt. He referred to other
developments in Holt where the proportion of affordable housing had been much
higher.
The Head of Planning stated that whilst other developers would be paying attention
to these decisions, the applicants had put forward an argument on the basis of
facilitating development.
Councillor N Smith stated that jobs would be created whilst the houses were being
built, and then those jobs would move elsewhere. He asked if there was any
provision for additional employment in the area, as it seemed to be lacking.
The Team Leader (Major Developments) stated that this application did not provide
for employment but there was mixed development on the larger, allocated sites. This
application was purely for housing development.
Councillor M J M Baker considered that the sixth form centre and upgraded
accommodation would enable the facilities to be used outside the school term as a
conference venue and to support events for children during the summer holidays. He
considered that this would create a large number of jobs and employment was
therefore an important part of the overall scheme.
(69)
HOLT – PO/14/0274 – Residential development for a maximum of eight
dwellings; Land north of Grove Lane for Endurance Estates Strategic Land Ltd
and Greshams School
The Committee considered item 4 of the Officers’ reports.
Public Speakers
Mr B Payne (Holt Town Council)
Mr B Whiffen (objecting)
Mr D Jenkins (supporting)
The Team Leader (Major Developments) presented photographs of the site, including
an aerial photograph. The site was outside the development boundary, but adjacent
to it. Whilst the application referred to a maximum of eight dwellings, viability had
been based on six dwellings. A Tree Preservation Order had been served on trees
2.7
on the boundary but the Landscape Officer had accepted that some of the trees
could be removed. An illustrative layout had been received. An off-site footpath was
proposed. He recommended refusal of this application.
Councillor B Cabbell Manners stated that the site was surrounded by dwellings and
he considered it was difficult to argue that the site was unsustainable.
Councillor M J M Baker considered that there was an opportunity to address the
traffic problems associated with Grove Lane by the provision of a link between Grove
Lane to the left hand side of the site to Cromer Road. This would provide an
opportunity to make Grove Lane one-way.
In response to a question by Councillor P W High, the Landscape Officer explained
that a Tree Preservation Order had been served on a line of trees abutting Grove
Lane. It would be necessary to lose some of the trees but it was hoped that this
could be mitigated by other planting. There were concerns regarding an Oak tree
which would need to be felled, but as there was no layout submitted with this
application it was hoped that this could be resolved at a later stage. It would be
difficult to maintain the rural feel of Grove Lane. Councillor Baker expressed concern
that the trees abutting Grove Lane were not native species. The Landscape Officer
stated that this line of trees contained some broad leaved species.
Councillor Mrs B McGoun referred to the overall amenity value of the trees, the
removal of which would leave a large gap.
The Team Leader (Major Developments) stated that unlike the previous applications,
this application was recommended for refusal purely on housing policy grounds.
(70)
DECISIONS ON APPLICATIONS PO/14/0283, PO/14/0284 AND PO/14/0274
The Planning Legal Manager introduced Mr C Skinner, Solicitor, NP Law, who was
representing the Monitoring Officer.
The Solicitor stated that the applicant’s case was that money was needed from all
three developments to undertake improvements to the school, which was an enabling
argument. He advised that the enabling argument carried the greatest and most
significant weight if all three applications were approved. If one application was
refused, it would no longer be possible to undertake the work and therefore the
weight to be attached to enabling development diminished significantly. If one
application were refused, a similar decision could be expected on the other two
applications.
The Head of Planning referred to the need to weigh the issues in determining these
applications. The viability and enabling argument were material, as was planning
policy, traffic, impact on the economy and jobs. The Committee could give weight to
those issues as it saw fit.
Site 1 – PO/14/0283
It was proposed by Councillor M J M Baker, seconded by Councillor R Reynolds that
this application be approved.
Councillor P W High stated that this was a very difficult application to discuss, but he
considered that all the planning issues went against approval and he supported the
Officer’s recommendation.
2.8
The Chairman advised the Committee that, if it were minded to approve this
application, further discussions would be required in respect of the uplift.
The Head of Planning advised the Committee that it if were minded to approve, the
decision should be delegated to the Head of Planning subject to prior completion of a
S106 agreement to include:
 Amend uplift clause (to reflect the Council’s standard uplift)
 Amended affordable housing terms to reflect our standard terms
 Satisfactory time scale for completion of the enabling works including the
construction of the 6th form block
 Amended triggers to ensure that detailed information is submitted at the
reserved matters stage
 Phasing mechanism to ensure the provision of affordable housing on site 1 in
advance of the completion of development on site 2 and 3
 And all other commuted sums referred to in the Heads of terms attached as
Appendix 4; and
 Conditions as considered to be appropriate by the Head of Planning.
It was proposed by Councillor M J M Baker, seconded by Councillor R Reynolds and
RESOLVED
That the Head of Planning be authorised to approve this application
subject to prior completion of a S106 agreement to include:
 Amend uplift clause (to reflect the Council’s standard uplift)
 Amended affordable housing terms to reflect our standard terms
 Satisfactory time scale for completion of the enabling works
including the construction of the 6th form block
 Amended triggers to ensure that detailed information is
submitted at the reserved matters stage
 Phasing mechanism to ensure the provision of affordable
housing on site 1 in advance of the completion of development
on site 2 and 3
 And all other commuted sums referred to in the Heads of terms
attached as Appendix 4; and
Conditions as considered to be appropriate by the Head of
Planning.
At the request of Councillor M J M Baker, voting was recorded as follows:
For the proposal
Councillors:
Mrs S A Arnold
M J M Baker
Mrs L M Brettle
Mrs A Claussen-Reynolds
J H Perry-Warnes
R Reynolds
N Smith
(7)
Against the proposal
Abstentions
Mrs P Grove-Jones
P W High
Mrs B McGoun
R Shepherd
Mrs A C Sweeney
J A Wyatt
B Smith
(6)
(1)
2.9
Reasons:
The facilitating development through a S106 obligation will secure the
delivery of the 6th form block and refurbishment of accommodation,
which will enable continuation of Greshams School with the wider
economic benefits to Holt of 375 jobs and additional jobs which will be
created through the additional facilities which are going to be built,
£11m salaries bill, the majority of which would be spent in Holt, with the
benefits as listed in Appendix 2 of the report at paragraphs 4.1 - 4.3.
Site 2 – PO/14/0284
It was proposed by Councillor M J M Baker, seconded by Councillor R Reynolds that
this application be approved.
The Head of Planning requested delegated authority to approve this application
subject to the provisos agreed under PO/14/0283. This application would also be
subject to referral to the Secretary of State in accordance with the Town & Country
Planning (Consultation) (England) Direction 2009 as it related to the loss of a playing
field.
It was proposed by Councillor M J M Baker, seconded by Councillor R Reynolds and
RESOLVED
That the Head of Planning be authorised to approve this application
subject to no objections being raised following referral to the Secretary
of State in accordance with the Town & Country
Planning
(Consultation) (England) Direction 2009 and to prior completion of a
S106 agreement to include:






Amend uplift clause (to reflect the Council’s standard uplift)
Amended affordable housing terms to reflect our standard terms
Satisfactory time scale for completion of the enabling works
including the construction of the 6th form block
Amended triggers to ensure that detailed information is
submitted at the reserved matters stage
Phasing mechanism to ensure the provision of affordable
housing on site 1 in advance of the completion of development
on site 2 and 3
And all other commuted sums referred to in the Heads of terms
attached as Appendix 4; and
Conditions as considered to be appropriate by the Head of
Planning.
2.10
At the request of Councillor M J M Baker, voting was recorded as follows:
For the proposal
Councillors:
Mrs S A Arnold
M J M Baker
Mrs L M Brettle
Mrs A Claussen-Reynolds
J H Perry-Warnes
R Reynolds
R Shepherd
B Smith
N Smith
(9)
Against the proposal
Abstentions
Mrs P Grove-Jones
P W High
Mrs B McGoun
Mrs A C Sweeney
J A Wyatt
(5)
(0)
Reasons:
The facilitating development through a S106 obligation will secure the
delivery of the 6th form block and refurbishment of accommodation,
which will enable continuation of Greshams School with the wider
economic benefits to Holt of 375 jobs and additional jobs which will be
created through the additional facilities which are going to be built,
£11m salaries bill, the majority of which would be spent in Holt, with the
benefits as listed in Appendix 2 of the report at paragraphs 4.1 – 4.3.
Site 3 – PO/14/0274
It was proposed by Councillor M J M Baker that 1) this application be approved, and
2) that negotiations take place for a link between Grove Lane and Cromer Road, with
a one-way system being introduced on Grove Lane.
The Head of Planning stated that Officers could use their best endeavours to achieve
the latter part of the proposal.
Councillor R Shepherd requested that the oak tree be protected.
Councillor Baker stated that whilst he was happy to add such a proviso, the tree was
already protected by a Tree Preservation Order.
Councillor R Reynolds seconded the proposal.
The Head of Planning requested delegated authority to approve this application
subject to the provisos agreed under PO/14/0283. This application would also be
subject to referral to the Secretary of State in accordance with the Town & Country
Planning (Consultation) (England) Direction 2009 as it related to the loss of a playing
field, in the event of an objection being raised by Sport England.
It was proposed by Councillor M J M Baker, seconded by Councillor R Reynolds and
RESOLVED
1.
That the Head of Planning be authorised to approve this application
subject to no objections being raised following referral to the Secretary
of State in accordance with the Town & Country Planning (Consultation)
2.11
(England) Direction 2009 and to prior completion of a S106 agreement to
include:






Amend uplift clause (to reflect the Council’s standard uplift)
Amended affordable housing terms to reflect our standard terms
Satisfactory time scale for completion of the enabling works
including the construction of the 6th form block
Amended triggers to ensure that detailed information is
submitted at the reserved matters stage
Phasing mechanism to ensure the provision of affordable
housing on site 1 in advance of the completion of development
on site 2 and 3
And all other commuted sums referred to in the Heads of terms
attached as Appendix 4; and
Conditions as considered to be appropriate by the Head of
Planning.
2.
That Officers use their best endeavours to negotiate a link between
Grove Lane and Cromer Road, with a one-way system being introduced
on Grove Lane.
At the request of Councillor M J M Baker, voting was recorded as follows:
For the proposal
Councillors:
Mrs S A Arnold
M J M Baker
Mrs L M Brettle
Mrs A Claussen-Reynolds
Mrs P Grove-Jones
P W High
J H Perry-Warnes
R Reynolds
R Shepherd
B Smith
N Smith
Mrs A C Sweeney
(12)
Against the proposal
Abstentions
Mrs B McGoun
J A Wyatt
(1)
(1)
Reasons:
The facilitating development through a S106 obligation will secure the
delivery of the 6th form block and refurbishment of accommodation,
which will enable continuation of Greshams School with the wider
economic benefits to Holt of 375 jobs and additional jobs which will be
created through the additional facilities which are going to be built,
£11m salaries bill, the majority of which would be spent in Holt, with the
benefits as listed in Appendix 2 of the report at paragraphs 4.1 - 4.3.
2.12
APPENDIX 3
bc
16 January 2015
CAPL248666/A3/HH
Mr John Williams - Major Developments Team Leader
Planning Policy Team
North Norfolk District Council
Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
Garth Hanlon BSc (Hons) MRTPI
E: ghanlon@savills.com
DL: +44 (0) 1223 347252
F: +44 (0) 1223 347111
Unex House
132-134 Hills Road
Cambridge CB2 8PA
T: +44 (0) 1223 347 000
savills.com
Dear Mr Williams
PLANNING APPLICATION REFERENCE PO/14/0274 – LAND TO THE NORTH OF GROVE LANE, HOLT
(SITE 3).
Savills (UK) Ltd act on behalf of Endurance Estates Strategic Land Limited and Gresham’s School, who are
the applicant for the above planning applications.
st
As you are aware, at the Development Committee of the 21 August 2014, Members resolved to approve the
planning application for the ‘residential development for a maximum of eight dwellings on land north of Grove
Lane’ on behalf of Endurance Estates Ltd and Greshams School.
During this Committee, Councillor Baker considered that there was an opportunity to address the traffic
problems associated with Grove Lane by the provision of a link road connecting Grove Lane to the west of
the application site through to Cromer Road. He suggested that this could provide an opportunity to make
Grove Lane one-way.
It was formally proposed by Councillor Baker that “1) this application be approved, and 2) that negotiations
take place for a link between Grove Lane and Cromer Road, with a one-way system being introduced on
st
Grove Lane” (Minutes from Development Control Committee 21 August 2014). It was then resolved,
alongside other matters, that Officers use their best endeavours to negotiate a link between Grove Lane and
Cromer Road, with a one-way system being introduced on Grove Lane.
th
I refer to your email of the 8 January 2015 which requests my clients response in relation to the willingness
of the provision of such a link road.
I can confirm that my clients are not willing to provide this link road for a number of reasons.
I refer to the consultation responses received from Norfolk County Council Highways Development
th
th
Management Officer on the 25 March 2014, and further comments received on the 9 May 2014. These
confirm that County Highways had no objection to the proposed scheme, subject to the conditions listed
within the consultation response (i.e. details of visibility splays, access arrangements, parking and turning
areas, a detailed scheme for off-site highway improvement works as indicated on drawing numbers 44406-C104B, and completion of highway works to written satisfaction of the LPA).
The proposed development was therefore considered to be acceptable in highways terms without the
proposed link road suggested by Councillor Baker. There is no demonstrable highways safety issue, no
justified need, and no insistence from the County Council that a link road is necessary in this location or at
any other new location between Cromer Road and Grove Lane.
Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.
3.1
Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138.
Registered office: 33 Margaret Street, London, W1G 0JD
a
st
It is our understanding that the idea for this link road was raised at the Development Committee on the 21
August 2014, due to the requirement to reduce the amount of CPO land needed by Norfolk County Council,
and to reduce the vehicle circulation time if the County Council were to make Grove Lane one-way. In any
case, the benefit of reducing the length of the one way diversion is questionable in our opinion. None of these
matters were, or should be, considerations as part of the submitted planning application and the provision of
the link road is therefore not an essential requirement as part of our submitted scheme.
We also consider that the provision of a link road in this location is difficult to achieve. The proposed link road
would most likely run along side 49 Grove Lane, along the back of the properties fronting Barrett Road, and
between Oakeley Boarding House and Gresham’s School Library. This could create significant amenity
issues for the neighbouring properties, as well as the School. This stretch of Cromer Road is a major
pedestrian link along its length, and is effectively part of the School network, and having road traffic along this
route could compromise the safety of students and staff.
A link road in this location could also affect the level of provision of formal playing pitches and playing fields
i.e. the tennis court which fronts Cromer Road, as well as requiring significant hedge removal and some tree
removal. All of the above matters would require a new planning application.
Furthermore, we consider that not only would a fresh planning application would be required, procedurally a
Traffic Regulation Order would also be needed. There is no evidence that one way would be supported and
that this would be successful.
th
As confirmed by the County Council’s Highways Officers in your email dated 8 January 2015, “…it wouldn’t
be an essential requirement to implement such an order, which is only being promoted in order to bring
forward the footpath scheme without the need for land”. We agree that this road is not essential.
In our opinion the link road is unnecessary and the delivery of it would be questionable in practical,
procedural and financial terms. We consider that a one way scheme could still come forward in the future,
without the provision of this link road. There is no justification for the proposed link, and therefore, our clients
are not willing to fund this proposal.
For these reasons, and those outlined above, our clients are not willing to move forward with this proposal.
Should you have any queries concerning the above, please do not hesitate to give me a call.
Yours sincerely
Garth Hanlon BSc (Hons) MRTPI
Director
16th January 2015
CAPL248666/A3/HH
Page 2
3.2
APPENDIX 4
JW
NORTH NORFOLK DISTRICT COUNCIL
HOLT ROAD CROMER NORFOLK NR27 9EN
Telephone 01263 513811
Fax 01263 515042
www.northnorfolk.org
e-mail planning@north-norfolk.gov.uk
Mr Hanlon
Savills (UK) Ltd
Unex House
132-134 Hills Road
Cambridge
Cambridgeshire
CB2 8PA
Application Number
PO/14/0283
Date Registered
11 March 2014
DRAFT DECISION NOTICE
Town and Country Planning Act 1990
The Town and Country Planning (Development Management Procedure) (England)
Order 2010
Location: Land South of Cromer Road and East of Grove Lane, Holt
Proposal: Residential development for a maximum of 126 dwellings
Applicant: Endurance Estate Strategic Land Ltd and Gresham's School
NORTH NORFOLK DISTRICT COUNCIL, in pursuance of powers under the above
mentioned Act hereby PERMIT the above mentioned development in accordance with the
accompanying plans and subject to the conditions specified hereunder:
1
Application for approval of all reserved matters must be made not later than the
expiration of one year beginning with the date of this permission. Approval of these
reserved matters (referred to in condition 2) shall be obtained from the Local
Planning Authority in writing before any development is commenced. The
development hereby permitted shall be begun not later than the expiration of one
year from the final approval of the reserved matters, or in the case of approval on
different dates, the final approval of the last such matter to be approved.
Reason:
The time limit condition is imposed in order to comply with the requirements of
Section 92 of the Town and Country Planning Act 1990 as amended by Section 51
of the Planning and Compulsory Purchase Act 2004. In addition the time limits
hereby imposed are intended to ensure early delivery of the development in
accordance with the case put forward in support of the application.
2
These reserved matters shall relate to the appearance, landscaping, layout and
scale of the proposed development and this condition shall apply notwithstanding
any indications as to these matters which have been given in the current
application.
Reason:
The application is submitted in outline form only and the details required are
pursuant to the provisions of Article 4(1) to the Town and Country Planning
(Development Management Procedure) (England) Order 2010.
4.1
3
In association with the requirements of Condition number 2, a scheme for
landscaping and site treatment to include grass seeding, planting of new trees and
shrubs, specification of materials for fences, walls and hard surfaces, and the
proposed maintenance of amenity areas, shall be submitted to and approved as
part of the application for reserved matters.
The scheme shall include details of a mixed tree and shrub landscaping belt, a
minimum width of 7m, inside and along the whole boundary of the site where it
borders with the A148 Cromer Road.
The scheme shall also include indications of all existing trees and hedgerows on
the land, and details of any to be retained (which shall include details of species
and canopy spread), together with measures for their protection during the course
of development. These details shall be supported by an updated Arboricultural
Method Statement.
The scheme as approved shall be carried out not later than the next available
planting season following the commencement of development or such further
period as the Local Planning Authority may allow in writing.
Reason:
To protect and enhance the visual amenities of the area, in accordance with the
requirements of Policy EN 4 of the adopted North Norfolk Core Strategy.
In association with Condition 3, a Landscape Management and Maintenance Plan
shall be submitted to and approved in writing by the Local Planning Authority as
part of the application for Reserved Matters. This shall set out how the approved
soft landscape proposals shall be managed and maintained for a period of ten
years from date of planting. Details shall include replacement of all plant failures
during this period, annual maintenance schedules and management proporsals for
all existing vegetation on the site.
Reason
To protect and enhance the visual amenities of the area, in accordance with the
requirements of Policy EN4 of the adopted North Norfolk Core Strategy.
4
No works shall commence on the site until such time as detailed plans of the roads,
footways, cycleways, foul and surface water drainage have been submitted to and
approved in writing by the Local Planning Authority in consultation with the Highway
Authority. All construction works shall be carried out in accordance with the
approved plans.
Reason:
To ensure satisfactory development of the site and a satisfactory standard of
highway design and construction, in accordance with Policy CT 5 of the adopted
North Norfolk Core Strategy.
5
No works shall be carried out on roads, footways, cycleways, foul and surface
water sewers otherwise than in accordance with the specifications of the Local
Planning Authority in consultation with the Highway Authority.
Reason:
To ensure satisfactory development of the site and to ensure estate roads are
constructed to a standard suitable for adoption as public highway, in accordance
with Policy CT 5 of the adopted North Norfolk Core Strategy.
6
Before any dwelling is first occupied the roads and footways shall be constructed to
binder course surfacing level from the dwelling to the adjoining County road in
accordance with the details to be approved
in writing by the Local Planning
4.2
Authority in consultation with the Highway Authority.
Reason:
To ensure satisfactory development of the site, in accordance with Policy CT 5 of
the adopted North Norfolk Core Strategy.
7
Development shall not commence until a scheme detailing provision for on site
parking for construction workers for the duration of the construction period has
been submitted to and approved in writing by the Local Planning Authority. The
scheme shall be implemented throughout the construction period.
Reason:
To ensure adequate off street parking during construction in the interests of
highway safety, in accordance with Policy CT 6 of the adopted North Norfolk
Core Strategy.
8
Notwithstanding the details indicated on the submitted drawings no works shall
commence on site until a detailed scheme for the off-site highway improvement
works as indicated on drawing numbers 44406-C-100D & 44406-C-101B have
been submitted to and approved in writing by the Local Planning Authority in
consultation with the Highway Authority.
Reason:
To ensure that the highway improvement works are designed to an appropriate
standard in the interest of highway safety and to protect the environment of the
local highway corridor, in accordance with Policy CT 5 of the adopted North Norfolk
Core Strategy.
9
Prior to the first occupation of the development hereby permitted the off-site
highway improvement works referred to in condition number 8 shall be completed
to the written satisfaction of the Local Planning Authority in consultation with the
Highway Authority.
Reason:
To ensure that the highway network is adequate to cater for the development
proposed, in accordance with Policy CT 5 of the adopted North Norfolk Core
Strategy.
10
Prior to, or concurrent with the submission of application(s) for reserved matters, a
surface water drainage scheme shall be submitted to the Local Planning Authority,
and no development shall take place on the site prior to approval of the scheme, in
writing, by the Local Planning Authority. The scheme shall be fully implemented and
subsequently maintained in accordance with the timing / phasing arrangements
embodied within the scheme, or within any other period as may subsequently be
agreed in writing by the Local Planning Authority.
(See note 3)
Reason:
To prevent flooding by ensuring the satisfactory storage and disposal of surface
water from the site for the lifetime of the development. in accordance with Policy
EN10 of the adopted North Norfolk Core Strategy.
11
No development approved by this permission shall be commenced until a report
demonstrating that there is sufficient foul water capacity to cater for the
development has been submitted to and approved in writing by the Local Planning
Authority. Where appropriate the report should include a scheme for the
improvement and/or extension of the existing sewerage system. Any such scheme
4.3
for the improvement and/or extension of the existing sewerage system shall be
implemented in accordance with the approved details prior to the occupation of any
dwellings on the site unless an alternative timescale is first agreed in writing by the
Local Planning Authority.
Reason:
To ensure that there is sufficient capacity at the Water Recycling Centre and to
protect the water environment in accordance with Policy EN13 of the adopted North
Norfolk Core Strategy.
12
Prior to the commencement of development a Materials Management PlanMinerals (MMP-M) for the purpose of extracting viable mineral resources from the
site, shall be submitted to and approved in writing by the Local Planning Authority in
consultation with the Local Minerals Planning Authority. Development of the site
shall be undertaken in full accordance with the approved MMP-M.
(See Note 4)
Reason:
To establish whether there are mineral resources which can be extracted viably at
the site in accordance with Policy CS16 of the Norfolk Minerals and Waste Core
Strategy and Development Management Policies Development Plan Document.
:
13
A) Prior to the commencement of development a Written Scheme of Archeaological
Investigation shall be submitted to and approved in writing by the Local Planning
Authority. (See Note 5)
B) No development shall take place other than in accordance with the Written
Scheme of Investigation approved under part (A) of this condition.
C) The development shall not be occupied until the site investigation and post
investigation assessment (see Note***) has been completed in accordance with the
programme set out in the Written Scheme of Investigation approved under
condition (A) and the provision to be made for analysis, publication and
dissemination of results and archive deposition has been secured.
Reason:
In the interests of archeaology in accordance with Policy EN8 of the adopted North
Norfolk Core Strategy.
14
Prior to the commencement of development, an investigation and assessment into
the presence of possible contaminants affecting the site shall be carried out in
accordance with details which shall have first been approved in consultation with
the Local Planning Authority. The findings of the assessment shall then be
submitted to the Local Planning Authority in writing. Unless otherwise approved in
writing by the Local Planning Authority, no development shall take place on those
areas of the site which have been identified as potentially containing contaminants
until a scheme to protect the exposure of future users of the site from hazards
4.4
associated with the contaminants has firstly been approved in writing by the Local
Planning Authority, and secondly implemented in full.
Reason:
In the interests of public health and safety, and in accordance with Policy EN 13 of
the adopted North Norfolk Core Strategy, as amplified by paragraphs 3.3.71-3.3.72
of the explanatory text.
15
Construction work shall not begin until a scheme for protecting the proposed
dwellings from traffic noise from the A148 (Cromer Road) has been submitted to
and approved in writing by the Local Planning Authority. The development shall be
completed in full accordance with the approved scheme.
Reason:
In the interests of residential amenity in accordance with Policy EN13 of the
adopted North Norfolk Core Strategy.
16
A minimum of 46% of the total number of dwellings shall comprise dwellings with a
maximum of two bedrooms or less.
Reason:
In order to provide a significant number of more affordable smaller dwellings in
accordance with the details submitted with the application and in accordance with
Policy HO1 of the adopted North Norfolk Core Strategy.
17
Concurrent with the application(s) for reserved matters, a Lighting Design Strategy
for Biodiversity shall be submitted to and approved in writing by the Local Planning
Authority.
All external lighting shall be installed in accordance with the specifications and
locations set out in the approved Strategy, and these shall be maintained thereafter
in accordance with the approved Strategy. No other external lighting shall be
installed without prior consent of the Local Planning Authority.
(See Note 6).
Reason:
In the interests of biodiversity in accordance with Policy EN9 of the adopted North
Norfolk Core Strategy.
18
No development shall take place (including ground works or vegetation clearance)
until a Construction Environmental Management Plan (CEMP: Biodiversity) has
been submitted to and approved in writing by the Local Planning Authority. The
CEMP (Biodiversity) shall include the following.
The approved CEMP shall be adhered to and implemented throughout the
construction period strictly in accordance with the approved details, unless
otherwise agreed in writing by the Local Planning Authority.
(See Note 7).
Reason:
In the interests of biodiversity in accordance with Policy EN9 of the adopted North
Norfolk Core Strategy.
4.5
NOTES TO APPLICANT
1.
The application site is the subject of an Obligation under Section 106 of the Town
and Country Planning Act 1990.
2.
It is an offence to carry out any works within the Public Highway, which includes a
Public Right of Way, without the permission of the Highway Authority This
development involves work to the public highway that can only be undertaken within
the scope of a legal Agreement between the applicant and the County Council.
Please note that it is the applicant’s responsibility to ensure that, in addition to
planning permission, any necessary Agreements under the Highways Act 1980 are
also obtained. Advice on this matter can be obtained from the County Council’s
Highways Development Control Group based at County Hall in Norwich. Please
contact Darren Mortimer telephone (01263) 516145.
Public Utility apparatus may be affected by this proposal. Contact the appropriate
utility service to reach agreement on any necessary alterations, which have to be
carried out at the expense of the developer.
If required, street furniture will need to be repositioned at the applicants own
expense.
3.
The applicant developer is advised that the surface water drainage scheme required
pursuant to condition 10 should include:




4.
Infiltration testing at regular intervals across the site, repeated three times in
accordance with BRE365, and the lowest infiltration test used in the design of the
system.
Modelling, design and siting, of the soakaways and swales to contain the 1 in 100
year rainfall event including climate change, with an appropriate half drain time.
Modelling of the contributing pipe network to show it contains at least the 1 in 30
year rainfall event including climate change, and modelling of the 1 in 100 year
rainfall event to show the volumes of flooding and details of where the water
would flow and be stored to prevent flooding of buildings or offsite flows.
Details of who will adopt and maintain the surface water scheme for the lifetime of
the development, and provision of the maintenance schedule.
The applicant/developer is advised that MMP-M (required persuant to condition 12
should:

Consider; through the findings of the letter from Richard Jackson Ltd on behalf of
the applicant (Ref MJD/TER/44406) and the ground investigation reports which
accompany it, the extent to which onsite materials could be extracted during the
proposed development and would meet specifications for use on site.

Outline the amount of material to be extracted, the amount which could be reused
on site; and for extracted material which cannot be used on-site its movement, as
far as possible by return run, to an aggregate processing plant.

Include proposals for keeping a record of the amounts of material obtained from
on-site resources which are used onsite and the amount of material returned to
an aggregate processing plant together with the provision of an annual return of
these amounts to be submitted to the Local Planning Authority and the Mineral
Planning Authority.
4.6
5.
The applicant/developer is advised that the Written Scheme fof Investigation
(Archeaology) referred to in condition 13 should include an assessment of
significance and research questions; and
1. The programme and methodology of site investigation and recording
2. The programme for post investigation assessment
3. Provision to be made for analysis of the site investigation and recording
4. Provision to be made for publication and dissemination of the analysis and records
of the site investigation
5. Provision to be made for archive deposition of the analysis and records of the site
investigation
6. Nomination of a competent person or persons/organization to undertake the works
set out within the Written Scheme of Investigation
The Historic Environment Service Norfolk County Council) advise that they will
provide a brief for these works on request. Contact: Mr Ken Hamilton (01362) 869275
or 07748 761354 (mobile). E-mail : ken.hamilton@norfolk.gov.uk
6.
7.
The applicant/developer is advised that the Lighting Design Strategy for Biodiversity
persuant to condition 17 should:

Identify those areas/features on site that are particularly sensitive for bats and
that are likely to cause disturbance in or around their breeding sites and resting
places or along important routes used to access key areas of their territory, for
example, for foraging; and

Show how and where external lighting will be installed (through provision of
appropriate lighting contour plans and technical specifications) so it can be clearly
demonstrated that areas to be lit will not disturb or prevent the above species
using their territory or having access to their breeding sites and resting places.
The applicant/developer is advised that the CEMP (Biodiversity) pursuant to condition
18 should address the following:
a) Risk assessment of potentially damaging construction activities.
b) Identification of “biodiversity protection zones”.
c) Practical measures to avoid or reduce impacts during construction (may be
provided as a set of method statements).
d) The location and timing of sensitive works to avoid harm to biodiversity
features.
e) The times during construction when special ecologists need to be present on
site to oversee works.
f) Responsible persons and lines of communication.
g) The role and responsibilities on site of an ecological clerk of works (ECoW) or
4.7
similarly competent person.
h) Use of protective fences, exclusion barriers and warning signs.
This permission relates only to that required under the Town and Country Planning Acts and
does not include any consent or approval under any other enactment or under the Building
Regulations. Any other consent or approval which is necessary must be obtained from the
appropriate authority.
Decn. Date
Acting under Delegated Authority
On Behalf of the Council
4.8
JW
NORTH NORFOLK DISTRICT COUNCIL
HOLT ROAD CROMER NORFOLK NR27 9EN
Telephone 01263 513811
Fax 01263 515042
www.northnorfolk.org
e-mail planning@north-norfolk.gov.uk
Mr Hanlon
Savills (UK) Ltd
Unex House
132-134 Hills Road
Cambridge
Cambridgeshire
CB2 8PA
Application Number
PO/14/0284
Date Registered
11 March 2014
DRAFT DECISION NOTICE
Town and Country Planning Act 1990
The Town and Country Planning (Development Management Procedure) (England)
Order 2010
Location: Land South of Cromer Road and West of Grove Lane, Holt
Proposal: Residential development for a maximum of 19 dwellings
Applicant: Endurance Estates Strategic Land Ltd and Greshams School
NORTH NORFOLK DISTRICT COUNCIL, in pursuance of powers under the above
mentioned Act hereby PERMIT the above mentioned development in accordance with the
accompanying plans and subject to the conditions specified hereunder:
1
Application for approval of all reserved matters must be made not later than the
expiration of one year beginning with the date of this permission. Approval of these
reserved matters (referred to in condition 2) shall be obtained from the Local
Planning Authority in writing before any development is commenced. The
development hereby permitted shall be begun not later than the expiration of one
year from the final approval of the reserved matters, or in the case of approval on
different dates, the final approval of the last such matter to be approved.
Reason:
The time limit condition is imposed in order to comply with the requirements of
Section 92 of the Town and Country Planning Act 1990 as amended by Section 51
of the Planning and Compulsory Purchase Act 2004. In addition the time limits
hereby imposed are intended to ensure early delivery of the development in
accordance with the case put forward in support of the application.
2
These reserved matters shall relate to the appearance, landscaping, layout and
scale of the proposed development and this condition shall apply notwithstanding
any indications as to these matters which have been given in the current
application.
4.9
Reason:
The application is submitted in outline form only and the details required are
pursuant to the provisions of Article 4(1) to the Town and Country Planning
(Development Management Procedure) (England) Order 2010.
3
In association with the requirements of Condition number 2, a scheme for
landscaping and site treatment to include grass seeding, planting of new trees and
shrubs, specification of materials for fences, walls and hard surfaces, and the
proposed maintenance of amenity areas, shall be submitted to and approved as
part of the application for reserved matters.
The scheme shall also include indications of all existing trees and hedgerows on
the land, and details of any to be retained (which shall include details of species
and canopy spread), together with measures for their protection during the course
of development.
The scheme shall also include proposals for ecological protection and mitigation.
The scheme as approved shall be carried out not later than the next available
planting season following the commencement of development or such further
period as the Local Planning Authority may allow in writing.
Reason:
To protect and enhance the visual amenities of the area, in accordance with the
requirements of Policy EN 4 of the adopted North Norfolk Core Strategy.
4
No works shall commence on the site until such time as detailed plans of the roads,
footways, cycleways, foul and surface water drainage have been submitted to and
approved in writing by the Local Planning Authority in consultation with the Highway
Authority. All construction works shall be carried out in accordance with the
approved plans.
Reason:
To ensure satisfactory development of the site and a satisfactory standard of
highway design and construction, in accordance with Policy CT 5 of the adopted
North Norfolk Core Strategy.
5
No works shall be carried out on roads, footways, cycleways, foul and surface
water sewers otherwise than in accordance with the specifications of the Local
Planning Authority in consultation with the Highway Authority.
Reason:
To ensure satisfactory development of the site and to ensure estate roads are
constructed to a standard suitable for adoption as public highway, in accordance
with Policy CT 5 of the adopted North Norfolk Core Strategy.
6
Before any dwelling is first occupied the roads and footways shall be constructed to
binder course surfacing level from the dwelling to the adjoining County road in
accordance with the details to be approved in writing by the Local Planning
Authority in consultation with the Highway Authority.
4.10
Reason:
To ensure satisfactory development of the site, in accordance with Policy CT 5 of
the adopted North Norfolk Core Strategy.
7
Development shall not commence until a scheme detailing provision for on site
parking for construction workers for the duration of the construction period has
been submitted to and approved in writing by the Local Planning Authority. The
scheme shall be implemented throughout the construction period.
Reason:
To ensure adequate off street parking during construction in the interests of
highway safety, in accordance with Policy CT 6 of the adopted North Norfolk
Core Strategy.
8
Notwithstanding the details indicated on the submitted drawings no works shall
commence on site until a detailed scheme for the off-site highway improvement
works as indicated on drawing numbers 44406-C-102D & 44406-C-103B have
been submitted to and approved in writing by the Local Planning Authority in
consultation with the Highway Authority.
Reason:
To ensure that the highway improvement works are designed to an appropriate
standard in the interest of highway safety and to protect the environment of the
local highway corridor, in accordance with Policy CT 5 of the adopted North Norfolk
Core Strategy.
9
Prior to the first occupation of the development hereby permitted the off-site
highway improvement works referred to in condition number *** shall be
completed to the written satisfaction of the Local Planning Authority in consultation
with the Highway Authority.
Reason:
To ensure that the highway network is adequate to cater for the development
proposed, in accordance with Policy CT 5 of the adopted North Norfolk Core
Strategy.
10
Prior to, or concurrent with the submission of application(s) for reserved matters, a
surface water drainage scheme shall be submitted to the Local Planning Authority,
and no development shall take place on the site prior to approval of the scheme, in
writing, by the Local Planning Authority. The scheme shall be fully implemented and
subsequently maintained in accordance with the timing / phasing arrangements
embodied within the scheme, or within any other period as may subsequently be
agreed in writing by the Local Planning Authority.
(See note 3)
Reason:
To prevent flooding by ensuring the satisfactory storage and disposal of surface
water from the site for the lifetime of the development. in accordance with Policy
EN10 of the adopted North Norfolk Core Strategy.
4.11
11
No development approved by this permission shall be commenced until a report
demonstrating that there is sufficient foul water capacity to cater for the
development has been submitted to and approved in writing by the Local Planning
Authority. Where appropriate the report should include a scheme for the
improvement and/or extension of the existing sewerage system. Any such scheme
for the improvement and/or extension of the existing sewerage system shall be
implemented in accordance with the approved details prior to the occupation of any
dwellings on the site unless an alternative timescale is first agreed in writing by the
Local Planning Authority.
Reason:
To ensure that there is sufficient capacity at the Water Recycling Centre and to
protect the water environment in accordance with Policy EN13 of the adopted North
Norfolk Core Strategy.
12
Prior to the commencement of development a Materials Management PlanMinerals (MMP-M) for the purpose of extracting viable mineral resources from the
site, shall be submitted to and approved in writing by the Local Planning Authority in
consultation with the Local Minerals Planning Authority. Development of the site
shall be undertaken in full accordance with the approved MMP-M.
(See Note 4)
Reason:
To establish whether there are mineral resources which can be extracted viably at
the site in accordance with Policy CS16 of the Norfolk Minerals and Waste Core
Strategy and Development Management Policies Development Plan Document.
13
Prior to the commencement of development, an investigation and assessment into
the presence of possible contaminants affecting the site shall be carried out in
accordance with details which shall have first been approved in consultation with
the Local Planning Authority. The findings of the assessment shall then be
submitted to the Local Planning Authority in writing. Unless otherwise approved in
writing by the Local Planning Authority, no development shall take place on those
areas of the site which have been identified as potentially containing contaminants
until a scheme to protect the exposure of future users of the site from hazards
associated with the contaminants has firstly been approved in writing by the Local
Planning Authority, and secondly implemented in full.
Reason:
In the interests of public health and safety, and in accordance with Policy EN 13 of
the adopted North Norfolk Core Strategy, as amplified by paragraphs 3.3.71-3.3.72
of the explanatory text.
NOTES TO APPLICANT
1.
The application site is the subject of an Obligation under Section 106 of the Town
and Country Planning Act 1990.
2.
It is an offence to carry out any works within the Public Highway, which includes a
Public Right of Way, without the permission of the Highway Authority This
development involves work to the public highway that can only be undertaken within
4.12
the scope of a legal Agreement between the applicant and the County Council.
Please note that it is the applicant’s responsibility to ensure that, in addition to
planning permission, any necessary Agreements under the Highways Act 1980 are
also obtained. Advice on this matter can be obtained from the County Council’s
Highways Development Control Group based at County Hall in Norwich. Please
contact Darren Mortimer telephone (01263) 516145.
Public Utility apparatus may be affected by this proposal. Contact the appropriate
utility service to reach agreement on any necessary alterations, which have to be
carried out at the expense of the developer.
If required, street furniture will need to be repositioned at the applicants own
expense.
3.
The applicant developer is advised that the surface water drainage scheme required
pursuant to condition 10 should include:
Infiltration testing at regular intervals across the site, repeated three times in
accordance with BRE365, and the lowest infiltration test used in the design of the
system.
 Modelling, design and siting, of the soakaways and swales to contain the 1 in 100
year rainfall event including climate change, with an appropriate half drain time.
 Modelling of the contributing pipe network to show it contains at least the 1 in 30
year rainfall event including climate change, and modelling of the 1 in 100 year
rainfall event to show the volumes of flooding and details of where the water
would flow and be stored to prevent flooding of buildings or offsite flows.
Details of who will adopt and maintain the surface water scheme for the lifetime of the
development, and provision of the maintenance schedule.

4.
The applicant/developer is advised that MMP-M (required persuant to condition 12
should:
(i) Consider; through the findings of the letter from Richard Jackson Ltd on behalf of
the applicant (Ref MJD/TER/44406) and the ground investigation reports which
accompany it, the extent to which onsite materials could be extracted during the
proposed development and would meet specifications for use on site.
(ii) Outline the amount of material to be extracted, the amount which could be reused
on site; and for extracted material which cannot be used on-site its movement, as far
as possible by return run, to an aggregate processing plant.
(iii) Include proposals for keeping a record of the amounts of material obtained from
on-site resources which are used onsite and the amount of material returned to an
aggregate processing plant together with the provision of an annual return of these
amounts to be submitted to the Local Planning Authority and the Mineral Planning
Authority.
This permission relates only to that required under the Town and Country Planning Acts and
does not include any consent or approval under any other enactment or under the Building
Regulations. Any other consent or approval which is necessary must be obtained from the
appropriate authority.
4.13
Decn. Date
Acting under Delegated Authority
On Behalf of the Council
4.14
NORTH NORFOLK DISTRICT COUNCIL
HOLT ROAD CROMER NORFOLK NR27 9EN
JW
Telephone 01263 513811
Fax 01263 515042
www.northnorfolk.org
e-mail planning@north-norfolk.gov.uk
Mr Hanlon
Savills (UK) Ltd
Unex House
132-134 Hills Road
Cambridge
Cambridgeshire
CB2 8PA
Application Number
PO/14/0274
Date Registered
11 March 2014
DRAFT DECISION NOTICE
Town and Country Planning Act 1990
The Town and Country Planning (Development Management Procedure) (England)
Order 2010
Location: Land north of Grove Lane Holt
Proposal: Residential development for a maximum of eight dwellings
Applicant: Endurance Estates Strategic Land Ltd and Greshams School
NORTH NORFOLK DISTRICT COUNCIL, in pursuance of powers under the above
mentioned Act hereby PERMIT the above mentioned development in accordance with the
accompanying plans and subject to the conditions specified hereunder:
1
Application for approval of all reserved matters must be made not later than the
expiration of one year beginning with the date of this permission. Approval of these
reserved matters (referred to in condition 2) shall be obtained from the Local
Planning Authority in writing before any development is commenced. The
development hereby permitted shall be begun not later than the expiration of one
year from the final approval of the reserved matters, or in the case of approval on
different dates, the final approval of the last such matter to be approved.
Reason:
The time limit condition is imposed in order to comply with the requirements of
Section 92 of the Town and Country Planning Act 1990 as amended by Section 51
of the Planning and Compulsory Purchase Act 2004. In addition the time limits
hereby imposed are intended to ensure early delivery of the development in
accordance with the case put forward in support of the application.
2
These reserved matters shall relate to the access, appearance, landscaping, layout
and scale of the proposed development and the means of access thereto and this
condition shall apply notwithstanding any indications as to these matters which
have been given in the current application.
Reason:
The application is submitted in outline form only and the details required are
pursuant to the provisions of Article 4(1) to the Town and Country Planning
4.15
(Development Management Procedure) (England) Order 2010.
3
In association with the requirements of Condition number 2, a scheme for
landscaping treatment to include the planting of new trees and shrubs, specification
of materials for fences, walls and hard surfaces, shall be submitted to and approved
as part of the application for reserved matters.
The scheme shall also include indications of all existing trees and hedgerows on
the land, and details of those to be retained (which shall include details of species
and canopy spread), together with measures for their protection during the course
of development.
The scheme shall also include proposals for ecological protection and mitigation.
The scheme as approved shall be carried out not later than the next available
planting season following the commencement of development or such further
period as the Local Planning Authority may allow in writing.
Reason:
To protect and enhance the visual amenities of the area, in accordance with the
requirements of Policy EN 4 of the adopted North Norfolk Core Strategy.
4
Prior to the commencement of the development hereby permitted full details, in the
form of scaled plans and/or written specifications, shall be submitted to and
approved in writing by the Local Planning Authority in consultation with the Highway
Authority to illustrate the following:
i)
ii)
iii)
iv)
Visibility splays.
Access arrangements.
Parking provision in accordance with adopted standards.
Turning areas.
Reason:
To ensure satisfactory development of the site and a satisfactory standard of
highway design and construction, in accordance with Policy CT 5 of the adopted
North Norfolk Core Strategy.
5
Notwithstanding the details indicated on the submitted drawings no works shall
commence on site until a detailed scheme for the off-site highway improvement
works as indicated on drawing number 4406-C-104C have been submitted to and
approved in writing by the Local Planning Authority in consultation with the Highway
Authority.
Reason:
To ensure that the highway improvement works are designed to an appropriate
standard in the interest of highway safety and to protect the environment of the
local highway corridor, in accordance with Policy CT 5 of the adopted North Norfolk
Core Strategy.
6
Prior to the first occupation of the development hereby permitted the off-site
highway improvement works referred to in condition number 5 shall be completed
to the written satisfaction of the Local Planning Authority in consultation with the
Highway Authority.
Reason:
To ensure that the highway network is4.16
adequate to cater for the development
proposed, in accordance with Policy CT 5 of the adopted North Norfolk Core
Strategy.
7
Prior to, or concurrent with the submission of application(s) for reserved matters, a
surface water drainage scheme shall be submitted to the Local Planning Authority,
and no development shall take place on the site prior to approval of the scheme, in
writing, by the Local Planning Authority. The scheme shall be fully implemented and
subsequently maintained in accordance with the timing / phasing arrangements
embodied within the scheme, or within any other period as may subsequently be
agreed in writing by the Local Planning Authority.
(See note 4)
Reason:
To prevent flooding by ensuring the satisfactory storage and disposal of surface
water from the site for the lifetime of the development. in accordance with Policy
EN10 of the adopted North Norfolk Core Strategy.
8
No development approved by this permission shall be commenced until a report
demonstrating that there is sufficient foul water capacity to cater for the
development has been submitted to and approved in writing by the Local Planning
Authority. Where appropriate the report should include a scheme for the
improvement and/or extension of the existing sewerage system. Any such scheme
for the improvement and/or extension of the existing sewerage system shall be
implemented in accordance with the approved details prior to the occupation of any
dwellings on the site unless an alternative timescale is first agreed in writing by the
Local Planning Authority.
Reason:
To ensure that there is sufficient capacity at the Water Recycling Centre and to
protect the water environment in accordance with Policy EN13 of the adopted North
Norfolk Core Strategy.
9
Before the development hereby permitted is begun, all the existing trees identified
on the approved plan to be retained shall be protected from damage during the
course of the development by means of protective fencing in accordance with the
details specified in BS5837 'Trees in Relation to Construction' to the satisfaction of
the Local Planning Authority.
The protective fencing shall be maintained during the period of construction works
on the site to the reasonable satisfaction of the Local Planning Authority. Within the
fenced area(s) no soil, fuel, chemicals or materials shall be stored, temporary
buildings erected plant or vehicles parked or fires lit.
Reason:
In order to protect trees on the site, in accordance with the requirements of Policy
EN 4 of the adopted North Norfolk Core Strategy.
NOTES TO APPLICANT
1.
The application site is the subject of an Obligation under Section 106 of the Town
and Country Planning Act 1990.
2.
The application site is the subject of a tree preservation order (ref: TPO/14/0882).
4.17
3.
It is an offence to carry out any works within the Public Highway, which includes a
Public Right of Way, without the permission of the Highway Authority This
development involves work to the public highway that can only be undertaken within
the scope of a legal Agreement between the applicant and the County Council.
Please note that it is the applicant’s responsibility to ensure that, in addition to
planning permission, any necessary Agreements under the Highways Act 1980 are
also obtained. Advice on this matter can be obtained from the County Council’s
Highways Development Control Group based at County Hall in Norwich. Please
contact Darren Mortimer telephone (01263) 516145.
Public Utility apparatus may be affected by this proposal. Contact the appropriate
utility service to reach agreement on any necessary alterations, which have to be
carried out at the expense of the developer.
If required, street furniture will need to be repositioned at the applicants own
expense.
4.
The applicant developer is advised that the surface water drainage scheme required
pursuant to condition 7 should include:
Infiltration testing at regular intervals across the site, repeated three times in
accordance with BRE365, and the lowest infiltration test used in the design of the
system.
 Modelling, design and siting, of the soakaways and swales to contain the 1 in 100
year rainfall event including climate change, with an appropriate half drain time.
 Modelling of the contributing pipe network to show it contains at least the 1 in 30
year rainfall event including climate change, and modelling of the 1 in 100 year
rainfall event to show the volumes of flooding and details of where the water
would flow and be stored to prevent flooding of buildings or offsite flows.
Details of who will adopt and maintain the surface water scheme for the lifetime of the
development, and provision of the maintenance schedule.

This permission relates only to that required under the Town and Country Planning Acts and
does not include any consent or approval under any other enactment or under the Building
Regulations. Any other consent or approval which is necessary must be obtained from the
appropriate authority.
Decn. Date
Acting under Delegated Authority
On Behalf of the Council
4.18
APPENDIX 5
Habitats Regulations Assessment for residential development of up to 153
dwellings over three sites in Holt, North Norfolk.
Article 6 of the ‘Habitats’ Directive 92/43/EEC, transposed into UK law by the
Conservation of Habitats and Species Regulations 2010 (as amended)
1.
Executive Summary
1.2
This report:




Addresses the concerns raised by Pegasus Group in their letter dated 30th September
2014;
Provides clarification on the terminology and the justification behind the appropriate
assessment for the residential development of up to 153 dwellings in Holt, ‘the project’;
Updates the appropriate assessment for the project to include the in-combination
effects of the proposed development for the erection of 170 dwellings on land south of
Lodge Close, Holt;
Provides a further update on the appropriate assessment for the project to incorporate
the information and advice received following the completion of the initial appropriate
assessment in August 2014.
1.3
This constitutes a comprehensive Habitats Regulations Assessment for the project as
required of the Competent Authority, North Norfolk District Council.
1.4
North Norfolk District Council concludes that the project will not adversely affect the
integrity of the North Norfolk Coast European Sites or the Norfolk Valley Fens European Site
either alone or in-combination with other plans or projects.
2.
Introduction and Context
2.2
On 6th August 2014 North Norfolk District Council undertook an appropriate assessment and
integrity test on the implications of three concurrent planning applications for the erection
of up to 153 dwellings (the project) on the conservation objectives of the nearby North
Norfolk Coast and Norfolk Valley Fens European Sites (also known as Natura 2000 sites).
2.3
The three planning applications (ref. PO/14/0283, PO/14/0284, PO/14/0274) were
subsequently brought before the Development Committee (on 21st August 2014) and
granted approval (subject to conditions).
2.4
An outline planning application (ref. PO/14/0846) was received from Gladman
Developments Limited on 7th July 2014 for the erection of up to 170 dwellings on land south
of Lodge Close, Holt. On 1st October 2014 North Norfolk District Council received a letter
from Pegasus Group, representing Gladman Developments Limited, suggesting that the
appropriate assessment for the 153 dwellings was flawed and that the appropriate
assessment should be reviewed and the three planning applications be taken back to
Development Committee for further consideration.
1
5.1
2.5
This document seeks to review and update the previous appropriate assessment and
integrity test for the project to clarify the process taken and justify the reasoned statements
made to allow the Development Committee to make an informed judgement in view of the
Councils duties as a competent authority under the Habitats Regulations.
2.6
Further to the August 2014 appropriate assessment for the three planning applications ref.
PO/14/0283, PO/14/0284, PO/14/0274, and relevant to the Habitats Regulations
Assessment for the project, the planning application for the 170 dwellings on Land South of
Lodge Close (ref. PO/14/0846) was brought before the Development Committee (2nd
October 2014) and refused. This refusal is now the subject of an appeal by the developer
(ref. APP/Y/2620/W/14/3000517), and currently undecided.
2.7
In addition, Gladman Developments Limited submitted an identical application to
PO/14/0846, for the erection of up to 170 dwellings on Land South of Lodge Close, to North
Norfolk District Council on 9th December 2014 (ref. PO/14/1603). This was supported by a
Habitats Regulations Assessment prepared by FCPR dated September 2014 which was
formally adopted by North Norfolk District Council. The application PO/14/1603 was
brought before the Development Committee on 26th February 2015 and refused.
3.
August 2014 Appropriate Assessment for residential development for up to 153 dwellings
3.2
North Norfolk District Council received three outline planning applications on 4th March
2014 for residential development for up to 153 dwellings. Endurance Estates Strategic Land
Limited and Greshams School submitted all three applications. The applications were spread
out over three sites centred on Grove Lane, Holt and the Greshams School site.
3.3
On the 29th April 2014, the Conservation, Design and Landscape Section of the Council
raised concerns that the three planning applications were “not necessary for the
management” of the nearby European sites and that the advice of Natural England should be
sought regarding the Habitats Regulations Assessment implications.
3.4
Natural England responded to the planning application consultation, dated 9th May 2014,
and concluded that likely significant effects on the nearby European Sites could not be ruled
out and that further information from the developer was required. This additional
information was requested from Savills, acting on behalf of Endurance Estates Strategic Land
Limited and Greshams School, and a response was received dated 12th June 2014. Natural
England were re-consulted (18th June 2014) with the additional information provided by
Savills, and responded (via email, dated 10th July 2014) indicating that “it is still not possible
to determine no Likely Significant Effect” however, the mitigation proposed the developer is
“sufficient to enable a conclusion of no adverse effect on integrity”. Using the additional
information submitted by Savills and the advice received from Natural England as well as
information from the Site Allocations DPD Appropriate Assessment, an appropriate
assessment and integrity test was undertaken by North Norfolk District Council (6th August
2014) for the three applications.
2
5.2
3.5
The assessment determined that the likely effects of the project on “international nature
conservation interests” would be indirect effects arising from “in-combination recreational
disturbance impacts”. The integrity test concluded that the project would not adversely
affect the integrity of the Norfolk Valley Fens SAC, however that the project would adversely
affect the integrity of the North Norfolk Coast Natura 2000 sites. The appropriate
assessment further states that the adverse effect on the North Norfolk Coast Natura 2000
sites could be avoided through a scheme of on-going monitoring and mitigation secured
through developer contributions and provision of green infrastructure.
4.
Pegasus Group Letter – 30th September 2014 and response by The Landscape Partnership,
Review of Habitats Regulations Assessments, dated February 2015
4.2
On the 30th September 2014, Pegasus Group wrote to North Norfolk District Council
indicating that they disagreed with findings of the ‘appropriate assessment’ for the 153
dwellings. Three concerns were raised, these being:
1. That the ‘appropriate assessment’ failed to take into consideration the in-combination
effects of the proposed development for up to 170 dwellings at Land to the South of Lodge
Close, Holt (ref. PO/14/0846), as required by the Regulations.
2. That the ‘appropriate assessment’ failed to take into consideration the concerns raised by
Natural England in their response to the Gladman Developments Limited application (ref.
PO/14/0846). The concerns of Natural England relating to the increase in use of Holt
Country Park as a result of the proposed development, the potential damaging effects of
such use, and the effects of such damage on visitation levels to the Country Park and the
ability of the Country Park to function “as an alternative to nearby designated sites”.
3. The conclusion reached by the ‘appropriate assessment’ that “any disturbance and
associated effects would be minimal” was flawed given the relatively small distances of the
combined developments from Holt Country Park, with indication from Visitor Surveys that
nearby development would likely lead to an increase in visitor numbers to the Park and the
likelihood that this would result in specific consequences as highlighted by Natural England.
4.3
In response to the Pegasus Group letter and notification that the three applications would
be referred back to the Development Committee, Endurance Estates Strategic Land Limited
and Greshams School instructed The Landscape Partnership to review the Council’s
Appropriate Assessment of the three applications. As a result the document ‘Review of the
Habitats Regulations Assessment’ dated February 2015 was subsequently submitted to the
Council.
4.4
The Review concluded that “North Norfolk District Council’s ‘Appropriate Assessment’ of
August 2014… lacked clarity in explaining the reasons for its conclusion” and advised that the
assessment be expanded to “enable third parties to better understand the reason for its
conclusions”, and that the terminology in the assessment should be made consistent with
the Regulations. However, the Review concluded that the assessment followed legal
precedent and accepted Natural England’s advice with no reasons stated for not following
that advice. Furthermore, that “despite the lack of clarity, there is no evidence to suggest
that the Council came to the wrong conclusion in its assessment”.
3
5.3
4.5
The following text therefore seeks to address the previous shortcomings of the ‘Appropriate
Assessment’ of August 2014 as highlighted by The Landscape Partnership in their review, and
provide comment on the concerns raised by the Pegasus Group in their letter dated 30th
September 2014 as well as updating the assessment in light of the additional information
received by the Council since the previous assessment and with respect to the planning
decisions made. This document does not replace the August 2014 ‘Appropriate Assessment’
by North Norfolk District Council but should be seen as supplementary to that ‘Appropriate
Assessment’ and form part of the Habitats Regulations Assessment process for the three
planning applications which jointly form the ‘project’ in question.
5.
Pegasus Letter, point 1 - In-combination effects
5.2
It is acknowledged that the August 2014 ‘Appropriate Assessment’ failed to take into
consideration the potential in-combination effects of the proposed development at Land
South of Lodge Close, Holt (ref. PO/14/0846) as required of Article 6(3) of the Directive
(92/43/EEC) and Regulation 61(a) of the Regulations.
5.3
In the August 2014 assessment, the likely effects were summarised as “development related
indirect effects from in-combination recreational disturbance impacts”. This was based on
an objective assessment of the implications for the European Sites conservations objectives
using best available evidence and knowledge received from the developer and Natural
England, details of which were appended to the assessment.
5.4
In reaching this conclusion North Norfolk District Council referred to the Council’s own
Appropriate Assessment of the Site Allocations Development Plan Document (DPD), written
by Royal Haskoning on behalf of the Council and dated February 2010, as well as the
information received from the developer to address the impacts specified by Natural
England in their consultation response. The Site Allocations DPD Appropriate Assessment
concluded that the proposed allocated development could indirectly impact on European
Sites through a number of mechanisms, and suggested a number of measures to ensure that
any adverse effect is avoided. The Site Allocations DPD and Appropriate Assessment was
subject to Examination in Public and not challenged in the High Court and subsequently
adopted.
5.5
With respect to the allocated development for Holt, of which approximately 300 new
dwellings have been allocated, the DPD Appropriate Assessment acknowledged the relative
distances of the settlement from the Norfolk Valley Fens Special Area of Conservation (SAC),
1km, and the North Norfolk Coast SAC/Special Protection Area (SPA)/Ramsar sites, 5.5km. It
then concluded that the Norfolk Valley Fens SAC, the closest site to Holt, had no “interest
features” that would be affected by an increase in visitor numbers. This was due to the
nature of the site (i.e. the qualifying features and how those features would be affected) and
the limited visitation that the site received (and the relationship with the Conservation
Objectives of the site), ensuring that “any disturbance will be minimal”.
5.6
The DPD Appropriate Assessment is clear that is did not consider that the allocations in Holt
would have a significant adverse effect on the Norfolk Valley Fens SAC. The conclusion
reached by the DPD Appropriate Assessment formed the primary reasoning behind the
4
5.4
assessment conclusion that there would be no Likely Significant Effect on the Norfolk Valley
Fens European Site for the additional development sites in Holt. Supplemented by the fact
that there was no additional information from the developer to suggest otherwise, and no
concerns raised by Natural England in their consultation responses thus far.
5.7
Furthermore, the DPD Appropriate Assessment concluded that at the North Norfolk Coast
designated sites there was potential for “disturbance to otter, bird populations (breeding,
overwintering, migrant, and wetland assemblage) perennial vegetation, and petalwort,
including by trampling. The exact amount of disturbance is dependent on the exact location
of interest features, and whilst development could lead to increased visitation, access to
these features is not easy. An adverse effect from disturbance could not be ruled out”. This
conclusion is consistent with qualifying features of the sites and the Conservation Objectives
as determined by Natural England.
5.8
The DPD Appropriate Assessment refers to ‘interest features’, these are taken to mean the
Qualifying Features of the European Sites as documented in the Annexes to the August 2014
Appropriate Assessment, and subsequently referred to in the Habitats Regulations
Assessment process.
5.9
From the evidence and documentation described above, it is reasonable to conclude that
any new residential development of considerable size in Holt has the potential to result in a
Likely Significant Effect on the North Norfolk Coast designated sites arising from incombination recreational disturbance impacts. This conclusion can be reasonably
extrapolated to include the proposed 170 dwellings at Land south of Lodge Close, Holt and
should therefore be considered in-combination with the 153 dwellings applications (the
project).
5.10
At this stage, and with the previously stated information available, the ‘appropriate
assessment’ for the Endurance Estates Strategic Land Limited and Greshams School
applications was prepared. There was nothing to infer from the information available or
from the consultation responses received from Natural England that;
a) the development related indirect effects on the North Norfolk Coast designated sites
arising from in-combination recreational disturbance impacts was not considered likely,
or that these impacts could not be mitigated for through a strategy of monitoring and
mitigation (secured through developer contributions);
b) or, recreational disturbance impacts on the Norfolk Valley Fens SAC (Holt Lowes) was
considered likely as a result of either the three Greshams School applications or the
land south of Lodge Close application.
5.11
The potential in-combination effects of the Lodge Close application could be mitigated
through developer contributions and provision of adequate green infrastructure should the
application be successful.
5.12
It is recognised that there is some ambiguity over the terminology used in the assessment
dated 6th August 2014. However, it is not considered that the overall conclusions of the
assessment are wrong.
5
5.5
5.13
In their consultation response to the Gladman Developments Limited application (ref.
PO/14/0846) dated 6th August 2014, Natural England reached a similar conclusion regarding
the potential impacts on the North Norfolk Coast and suggested that the same strategy to
mitigate those impacts, as recommended in the DPD Appropriate Assessment, should be
secured to ensure no adverse effect on integrity of the North Norfolk Coast Natura 2000
sites. This could be implemented through a Section 106 agreement to secure developer
contributions of £50 per dwelling to implement a monitoring and mitigation strategy.
5.14
However, Gladman Developments Limited indicated that they would not contribute a
financial sum to mitigate the impacts on the North Norfolk Coast, stipulating that the
provision of green infrastructure on site would provide alternative green space to offset the
impact on the coastal sites. As a result additional concerns were raised by Natural England
in their 6th August 2014 consultation response (received by the Council on 14th August
2014) regarding the impact on Holt Country Park and the adequacy of suitable green
infrastructure on the site.
6.
Pegasus Letter, point 2 – Natural England advice regarding PO/14/0846, letter dated 6th
August 2014
6.2
The second concern raised by Pegasus Group, in their letter dated 30th September 2014,
related to the consultation response to the Gladman Developments Limited application
(PO/14/0846) from Natural England, dated 6th August 2014, and whether North Norfolk
District Council took that information into account in the habitats regulations assessment for
the Endurance Estates and Greshams School applications.
6.3
The appropriate assessment for the three planning applications ref. PO/14/0283,
PO/14/0284, PO/14/0274 was completed on 6th August 2014 in preparation for
consideration at the Development Committee on 21st August 2014. Following legal
precedent the appropriate assessment took into consideration the two consultation
responses received from Natural England regarding the proposals, dated 9th May 2014 and
10th July 2014 respectively, and which were appended to the original document. At this
point in time no additional information was available from Natural England or otherwise to
indicate that the appropriate assessment and integrity test would result in a different
conclusion to the one made.
6.4
It is acknowledged that subsequent to the appropriate assessment being prepared and prior
to the Development Committee, further comments were received from Natural England
regarding the Gladman Developments Limited application that potentially may have had an
impact on the assessment conclusions for the Greshams sites regarding in-combination
effects. However, although the response from Natural England raised concerns regarding
the impact on nearby designated sites, and the ability of the adjacent Holt Country Park to
act as an attractive alternative visitor destination to designated sites, the concern centred on
the refusal of Gladman Developments Limited to contribute to the monitoring and
mitigation strategy to mitigate for the impacts to the North Norfolk Coast European Sites
and the poor quality submission of Green Infrastructure for the development and the refusal
to contribute to the upkeep and maintenance to Holt Country Park.
6
5.6
7.
Pegasus Letter, point 3 – Natural England advice regarding PO/14/0846, letter dated 6th
August 2014
7.2
The final concern raised by Pegasus Group, in their letter dated 30th September 2014,
related to the appropriate assessment conclusion that “any disturbance and associated
effects would be minimal” regarding the impacts on Holt Lowes SSSI, the component part of
the Norfolk Valley Fens SAC that is adjacent to Holt Country Park.
7.3
North Norfolk District Council had reached this conclusion based on the information
contained in the Site Allocations DPD Appropriate Assessment, the guidance provided by
Natural England and the developer, and based on the condition assessment and qualifying
features of the Norfolk Valley Fens SAC. There is nothing to suggest that this conclusion was
not reached through a reasonable assessment of the potential impacts based on the
information available.
7.4
Pegasus Group suggested that Visitor Survey data for Holt Country Park (2006) implied that
visitor numbers for the park were increasing and that this would consequently result in
potential impacts to the Norfolk Valley Fens SAC (as highlighted by Natural England).
However, there is nothing to infer from the Natural England consultation responses received
thus far that they had concerns about the impact on the qualifying features of the Norfolk
Valley Fens SAC as a result of the Endurance Estates and Greshams School applications.
8.
Update on the appropriate assessment and integrity test for the project following the
submission of the FCPR HRA and additional Natural England comments
8.2
Following the original ‘appropriate assessment’ in August 2014 for the three planning
applications for the erection of up to 153 dwellings, additional information and further
planning applications have been received and decisions made. These can be summarised as
follows:
Date
Planning reference Information/comments
no.
22/09/2014 PO/14/0846
Habitats Regulations Assessment received, prepared
by FPCR (dated September 2014)
02/10/2014 PO/14/0846
Application refused at Development Committee
14/10/2014 PO/14/0846
Natural England Comments returned regarding FPCR
HRA
09/12/2014 PO/14/1603
Identical planning application received from Gladman
Developments Limited for the erection of up to 170
dwellings on land south of Lodge Close, Holt.
Supported by a Habitats Regulations Assessment
prepared by FPCR (dated September 2014)
06/01/2015 PO/14/1603
Initial comments received from Natural England
09/01/2015 PO/14/1603
Further comments received from Natural England
(these being duplicate comments as sent for
PO/14/0846, dated 14/10/2014)
09/02/2015 PO/14/1603
North Norfolk District Council adopts the findings of
the FPCR HRA.
20/01/2015 PO/14/0846
Appeal received (ref. APP/Y/2620/W/14/3000517)
26/02/2015 PO/14/1603
Application refused at Development Committee
7
5.7
PO/14/0274
PO/14/0283
PO/14/0284
“Review of Habitats Regulations Assessment for
planning applications PO/14/0274, PO/14/0283,
PO/14/0284” dated February 2015 prepared by The
Landscape Partnership received.
8.3
This is relevant as it provides further clarification regarding the impact of the three
Greshams School applications on the European Sites, specifically the Norfolk Valley Fens
SAC, and the in-combination effects of the proposed development on land south of Lodge
Close for the appropriate assessment and integrity test.
8.4
In order to inform the Habitats Regulations Assessment process, further information is
presented below for the Norfolk Valley Fens SAC, as this information was not included in the
August 2014 ‘appropriate assessment’.
8.5
Holt Lowes Site of Special Scientific Interest (SSSI) is a component part of the Norfolk Valley
Fens SAC. The majority of the Norfolk Valley Fens SAC component sites are outside of North
Norfolk District, however three sites are within the District of which Holt Lowes is one. Holt
Lowes is directly adjacent to, and linked with, Holt Country Park.
8.6
Norfolk Valley Fens is one of two sites selected in East Anglia where the main concentrations
of lowland Alkaline Fens occur. The sites comprise a series of valley-head spring-fed fens,
these being very rare in the lowlands. The individual fens vary in their structure according to
the intensity of management and provide a wide range of variation. The Alkaline fens are
generally small in area and surrounded by intensively farmed land. They are vulnerable to
reductions on the water tables and a decrease in the volume of spring flows arising from
groundwater abstraction (North Norfolk Site Specific Proposals Appropriate Assessment –
Final Report, 2010). The Qualifying Features and Conservation Objectives of the Norfolk
Valley Fens SAC are provided in Appendix ?. The Qualifying Features can be summarised as:









8.7
H4010 – North Atlantic wet heaths with Erica tetralix
H4030 – European dry heath
H6210 – Semi natural dry grasslands and scrubland facies: on calcareous substrates
(Festuco-Brometalia)
H6410 – Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion
caerulaea)
H7210 – Calcareous fens with Cladium mariscus and species of the Caricion davallianae
H7230 – Alkaline fens; Calcium-rich spring water-fed fens
H91E0 – Alluvial forests with Alnus glutinosa and Fraxinous excelsior
S1014 – Vertigo angustior; Narrow-mouthed whorl snail
S1016 – Vertigo moulinsiana; Desmoulin’s whorl snail
The conservation objectives for the site are to “ensure that the integrity of the site is
maintained or restored as appropriate, and ensure that the site contributes to achieving the
Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;
8
5.8






The extent and distribution of qualifying natural habitats and habitats of qualifying
species,
The structure and function (including typical species) of qualifying natural habitats,
The structure and function of the habitats of qualifying species,
The supporting processes on which qualifying natural habitats and the habitats of
qualifying species rely,
The populations of qualifying species, and,
The distribution of qualifying species within the site”.
8.8
Although SSSI interest features are not part of the formal Habitats Regulations Assessment
process, where SSSI sites are component parts of European Sites and the interest features
mirror the Qualifying Features of the European Site the ‘condition status’ of the SSSI is a
useful indicator in informing the process. The interest features for Holt Lowes SSSI are
similar to the Qualifying Features of the Norfolk Valley Fens SAC, and the latest condition
assessment for Holt Lowes SSSI is ‘unfavourable recovering’. The main issues for the
condition of the SSSI centre on the management of the heath, scrub and woodland and the
hydrological sensitivities of the site of which measures are in place to secure improvements
to the site.
8.9
In addition to the SSSI condition monitoring programme, Natural England have provided Site
Improvement Plans (SIPs) for the majority of England’s Natura 2000 sites as part of a
Countrywide improvement programme to support the network. The plans provide a high
level overview of the issues affecting the condition of the Natura 2000 features on the site.
The SIP for Norfolk Valley Fens SAC is provided in the Appendix ??. Twelve priority issues are
listed in the SIP of which the top five are: inappropriate water levels, inappropriate scrub
control, hydrological changes, water pollution and inappropriate cutting/mowing. None of
the twelve issues for the Norfolk Valley Fens SAC improvement plan involve impacts related
to increased pressure from recreational disturbance.
8.10
The HRA prepared by FPCR provided the required assessment under the Habitats
Regulations for the Gladman Developments Limited application, and “considered all of the
available information to establish the potential for any LSE [Likely Significant Effect] on the
Holt Lowes component site of the Norfolk Valley Fens SAC and North Norfolk Coast
SAC/SPA/Ramsar and mitigation proposals, which if implemented, would be expected to
either completely off-set any LSE or to minimise them so that they would not be considered
significant”.
8.11
With respect to Norfolk Valley Fens SAC (Holt Lowes SSSI) the HRA concluded that an impact
is possible, due to the potential for increased visitation that may lead to trampling and
erosion of the qualifying habitat, increasing the likelihood of a significant adverse effect on
the integrity of the European Site. To off-set this impact mitigation is proposed by FPCR, this
includes the provision of high quality alternative greenspace within the development site
which will essentially extend Holt Country Park and absorb some of the anticipated
increased usage of the park. Further mitigation is also proposed in the form of a developer
contribution towards the maintenance of paths, interpretation and increased wardening of
9
5.9
the Country Park to be secured through a Section 106 agreement. This mitigation should
ensure that visitors would be attracted to, and contained within, the Country Park and not
stray into the adjacent SSSI/SAC.
8.12
The potential for in-combination effects as a result of the Site Allocations development, the
153 dwellings from the Greshams School application and the 170 dwellings from the
Gladman Developments Limited application were also considered by the FPCR HRA. The
HRA identified a potential effect on the North Norfolk Coast SPA/SAC/Ramsar European
sites, but suggested this could be mitigated for through developer contributions toward the
strategic monitoring and mitigation strategy. This would therefore mitigate the potential
impact resulting in no Likely Significant Effect on the European Sites or Adverse Effect on the
Integrity of the European Sites, alone or in-combination.
8.13
For the Norfolk Valley Fens SAC, the HPCR HRA identified that alone the Gladman
Developments Limited application for 170 dwellings may result in a LSE however suggesting
that this could be mitigated for resulting in no Adverse Effect on the Integrity of the
European Site. The HRA further considers the potential impact of the Holt Site Allocation
developments (as provided for in the Site Allocations DPD) and the three Greshams School
developments for the erection of up to 153 dwellings. The HRA did not identify, through the
review and consideration of other development proposals, any “residual adverse impacts on
the qualifying features for any European Site arising from other plans or projects which
when combined with the proposed Lodge Close development would cumulatively represent
a significant adverse effect on the integrity of any European Site”.
8.14
In their consultation response for the Lodge Close application (PO/14/1603) dated 14 th
October 2014, Natural England state that they concur with the findings of the HRA produced
by FPCR, that the proposal “will not result in adverse effects on the integrity of any of the
sites in question”. This is subject to securing all of the mitigation measures proposed for any
permission given.
8.15
The Review of the HRA prepared by the Landscape Partnership provides further evidence as
to why the integrity of the Norfolk Valley Fens SAC will not be adversely affected by the incombination effects of the Greshams School applications and the Gladman Developments
Limited applications.
8.16
Having taken the above into consideration, North Norfolk District Council therefore
concludes that the Endurance Estates Strategic Land Limited and Greshams School
applications for the erection of up to 153 dwellings at three sites within Holt will not
adversely affect the integrity of the North Norfolk Coast European Sites or the Norfolk Valley
Fens European Site either alone or in-combination with the Site Allocation development in
Holt or the development for the erection of up to 170 dwellings at Land south of Lodge
Close, Holt, subject to the imposition of conditions and restrictions on the way the project is
to be carried out.
10
5.10
APPENDIX 6
Assessment of Economic
Benefits Associated with
Gresham's School
February 2015
6.1
Assessment of Economic Benefits Associated with Gresham's School`
Contents
Executive Summary .................................................................................................................. i
1. Introduction .......................................................................................................................... 1
2. Economic benefits of Gresham’s School to Holt ............................................................. 2
3. Economic benefits of the proposed residential development ........................................ 4
4. Economic benefits of the proposed school development ............................................... 9
Contact:
Helen Dias / Vivek Seth
Tel:
Approved by:
Helen Dias
Date:
020 7391 4105 /
020 7391 4114
email:
hdias@sqw.co.uk
vseth@sqw.co.uk
18th February 2015
Director
6.2
www.sqw.co.uk
Assessment of Economic Benefits Associated with Gresham's School`
Executive Summary
1.
Gresham’s School is a major local employer and a fundamental part of the local economy and
many of the businesses in and around Holt rely heavily on the spending by the school, by
visiting parents and the pupils.
2.
Education is a more substantial source of employment in Holt compared to other towns in
North Norfolk, in the County and the UK as a whole. Gresham’s employs 394 full time and part
time workers and around 40% of these also live in Holt. This emphasises the centrality of the
school in the local economy.
3.
Every two pupils at the school supports one person in employment in Holt, in line with the
average for all other independent schools in the UK.
4.
Both the proposed residential development and development that will be enabled at the
school will have a substantial beneficial effect on the economy of Holt and more widely
throughout North Norfolk.
5.
The proposed residential development at the three application sites will generate:

223 construction job years, estimated to be worth £7.4 million to the local economy

67 permanent full time equivalent (FTE jobs) worth £1.7 million annually to the local
economy
6.
The monies released by the sale of sites for residential development will be used to fund
school expansion – primarily a new Sixth Form Centre and improvements to boarding
facilities. These improvements are planned to help the school maintain its attractiveness to
parents and pupils in the future, in what is an increasingly competitive private educational
market.
7.
The proposed development of the Sixth Form Centre and the boarding facilities improvements
will:

help maintain and enhance the reputation Gresham’s School and secure the long-term
future of the school in Holt

generate an estimated 102 construction job years, worth £3.4 million to the local
economy

support the existing wider local economic benefits through spend by students and
their parents and expenditure by the school administration on local goods and
services.
6.3
i
Assessment of Economic Benefits Associated with Gresham's School`
1. Introduction
1.1
SQW has been asked by Gresham’s School and Endurance Estates Strategic Land Limited to
assess the local economic benefits associated with the proposed developments at Gresham’s
School, Norfolk. This report is submitted in support of the three applications for the enabling
(residential) development which will provide funds for the investment into school facilities.
1.2
Three outline residential applications were submitted in March 2014 for the following sites:
1.3
1.4

Site 1: south of Cromer Road, east of Grove Lane, Holt, and north of the A128 Holt
bypass – maximum 126 dwellings (planning reference PO/14/0283)

Site 2: south of Cromer Road and West of Grove Lane – maximum 19 dwellings
(planning reference PO/14/0284)

Site 3: north of Grove Lane – maximum 8 dwellings (planning reference PO/14/0274)
The aim of the proposed residential development for which permission is sought is to facilitate
development of new school facilities encompassing a Sixth Form Centre and improvements to
boarding facilities. Although our report is primarily concerned with the benefits associated
with the residential development, we also consider the likely effects of the school on the local
economy. More specifically, this report examines:

the school’s current economic benefits to Holt (Chapter 2)

the economic benefits derived from the construction and subsequent occupation of
the residential developments (Chapter 3)

the likely economic benefits of the proposed school expansion which will be enabled
by fund released from the sale of the development sites (Chapter 4)
The report examines each of these in turn, with each chapter outlining the methodology used
for the respective analyses.
6.4
1
Assessment of Economic Benefits Associated with Gresham's School`
2. Economic benefits of Gresham’s School to
Holt
2.1
In undertaking this assessment we have relied on information provided by the School’s
administration on: their pupil numbers; the numbers and types of staff they employ; their
expenditure on salaries and wages; and their estimates of expenditure on goods and services
from businesses within the local area (North Norfolk).
2.2
We have not carried out a detailed survey of local businesses to identify the proportion of
their income derived from spending by the school’s administration, pupils, parents and other
visitors. However we have had regard to the findings of the report on the economic impact of
independent schools throughout England1 and, where appropriate, drawn on the generic
findings to provide context for the assessment of the school’s local economic effect.
Employment
2.3
In absolute terms education is an important source of employment in Holt. Gresham’s School
is the major employer in Holt’s education sector, and the biggest employer in Holt. The school
employs a total of 394 full time and part time staff: teaching staff (202), management and
administration staff (41) and support staff (151). The school have estimated that this equates
to 279 full time equivalent (FTE) staff - 133 teachers, 26 managers and administrative staff
and 120 support staff.
2.4
In relative terms education is also an important source of employment to Holt. Table 2-1
below shows the total number of people working in education and the proportion of those in
work that are employed in education in identified locations.2 We have compared Holt with
other nearby towns of a similar size (Cromer, Sheringham and Walsham).
2.5
In Holt almost 600 people (17% of those employed in the town) work in education. This is
notably higher than other nearby towns, other than Sheringham, which is home to two
medium sized schools, - Beeston Hall Preparatory School and Sheringham Woodfields Special
School - in addition to the local education authority’s schools. Gresham’s is a major source of
Holt’s education employment with the school accounting for two-thirds of all education
employment in Holt. Furthermore, of the c.600 people with education jobs in Holt, just over
one third of these are Holt residents working at Gresham’s.
2.6
In Holt the proportion of those in employment who work in education is almost double both
the North Norfolk and the national averages.
2.7
A total of 159 school employees (roughly 40% of all the school’s employees, and 5% of those
working in Holt) live in the postcode areas NR25 6 and NR25 7 which encompass Holt and the
immediately surrounding areas.3 This employment analysis emphasises the reliance of Holt’s
local economy on the effective running of the school. It demonstrates the importance of
The impact of independent schools on the British economy, a report prepared for the Independent Schools Council by
Marsh and Oxford Economics (April 2014)
2 Those of working age (16 to 74) that were in employment in the geographical area the week before the 2011 Census.
3 These two postcode areas when taken together also provide the closest fit to MSOA North Norfolk 004 which we use in
the analysis of Holt employment presented in Table 2-1.
1
6.5
2
Assessment of Economic Benefits Associated with Gresham's School`
supporting and maintaining the functioning and attractiveness of the school and thereby Holt
itself, in the medium and long term
Table 2-1: Employment in education by area
Education
employment
All
employment
Education
employment
as % of total
Spatial area
Notes
North Norfolk 004
(MSOA)4
Proxy for Holt
597
3,515
17.0%
North Norfolk 003
(MSOA)
Proxy for Cromer
221
3,810
5.8%
North Norfolk 001
(MSOA)
Proxy for
Sheringham
337
2,597
13.0%
North Norfolk 010
(MSOA)
Proxy for North
Walsham
464
4,793
9.7%
North Norfolk LA
-
3,712
39,632
9.4%
South Norfolk LA
-
4,760
54,367
8.8%
East of England
-
271,625
2,650,835
10.2%
England
-
2,485,775
25,087,843
9.9%
Source: 2011 Census workplace population statistics
Local Income
2.8
The total number of pupils at Gresham’s School in 2014-2015 academic year is 776, of which
463 day pupils and 313 are boarders. Last year the total income to the school from fees and
lettings was £17,860,000.
2.9
A substantial proportion of this income is paid in annual remuneration to staff working at the
school - in 2014 this was £10,381,000. SQW’s analysis of the findings of the ISC Report also
indicates that on average in the UK one job is created for every £43,750 of expenditure in the
independent school sector. If only 10%5 of the staff’s total remuneration is spent within North
Norfolk, this local income is estimated to generate a further 50 jobs in local services within
the area.
2.10
When looking at the economic impact of the school we have not considered the amount of
money spent by parents of boarders and other visitors to the school in local businesses
(hotels, bed and breakfast, cafes, restaurants and pubs). Nor have we considered the income
derived from overseas boarders, or the wider tax revenues.
Local jobs created through the school’s purchase of good and
services
2.11
The school have estimated that they spend between £500,000 and £750,000 per annum with
local businesses for the supply of good and services. Using the estimate of 1 job created for
every £43,750 spent (see above), we estimate that between 11 and 14 further FTE jobs in local
supplies are directly supported by the schools’ expenditure.
Middle Super Output Areas (MSOAs) are statistical geographies developed by the Office for National Statistics. We use
them here as proxies for some of Norfolk’s towns
5 As guided by HCA guidance on multiplier effects (2014). We have not undertaken a detailed survey to determine what
proportion of school employees’ wages are spent in Holt and North Norfolk.
4
6.6
3
Assessment of Economic Benefits Associated with Gresham's School`
3. Economic benefits of the proposed
residential development
3.1
3.2
3.3
The proposed residential development will produce three main strands of economic benefit:

temporary employment in the construction industry

permanent employment generated by the increased demand for local services that
new residents bring

the gross value added (GVA) impact of the created employment
In this section we examine the likely benefits the development will bring under each of these
headings. In preparing these assessment we have drawing on data relating to the proposed
residential development and the academic development from a variety of sources:

Residential floorspace and construction details taken from the submitted planning
applications and Planning Statements

Estimated residential construction costs from Savills(dated 4th August 2014),

Additional development and costing details provided by the architects
The analyses also utilise Office of National Statistics (ONS) published datasets and a series of
guidance relating to employment benchmarks, and the effects of construction.
Employment generated in the construction industry
Gross effects
3.4
The new development will have a gross internal area (GIA) of 20,187 sq.m.6 and the total
estimated build cost is £18,692,041(in June 2013 prices). We have therefore calculated that
the average construction cost is £926 per sq.m.
3.5
Guidance issued by the Homes and Communities Agency (HCA) estimates that for every £1
million of new housing construction, 21 job years are created (i.e. the equivalent of 21
temporary jobs, each lasting one year).7 We therefore have estimated that the construction of
the three residential estates will create 323.8 gross construction job years.
Additionality and net effects
3.6
We have estimated the new net employment created, taking account of:

6
7
“displacement” - jobs already in the local economy which as displaced by the new
development
Based on GIA being 17.5% larger than the gross internal floor area figures provided in the accommodation schedule
OffPAT Paper 4b – Construction Jobs (2009)
6.7
4
Assessment of Economic Benefits Associated with Gresham's School`

“multiplier effects” - indirect jobs created in the supply chain, and induced jobs- those
created by the local spending of the people who take the new jobs.
Displacement
3.7
There is no pre-existing on-site construction employment for this new employment to
displace. However, if the construction work were to be overseen by local contractors then it
might direct resources away from other projects in the area. Nevertheless, given the transient
nature of the construction labour market at present, construction displacement is likely to be
relatively low. HCA guidance (2014)8 is that low displacement stands at 25% and medium
displacement at 50%. Our analysis assumes low to medium displacement (37.5%)
Multiplier effects
3.8
All new job creation has some multiplier benefits. The scale of benefits depends on
assumptions about the proportion of the additional spend that is local. HCA guidance is that
local multipliers should be in the range 1.05 to 1.15. Taking the mid-point of this range
assumes an effect of 1.10 which we have used in our calculations.
Net employment generated
3.9
Using the assumptions made above, we estimate the creation of 222.6 construction job years.
Table 3-1: Gross to net conversion of residential construction employment
Gross
employment
Total
residential
323.8
Less employment
displaced on site
Less wider local
displacement
(37.5%)
323.8
202.4
With
multiplier
(1.10)
222.6
Source: SQW analysis
Permanent employment through increased demand for local good
and services from new residents
3.10
The new homes will lead to increased demand by the additional residents for local goods and
services, which in turn will generate further jobs in local businesses. The economic
assessment requires an estimate of the total number of new residents who will occupy the
new houses.
Estimating the additional population – assumptions
3.11
We have used the proposed total number of dwelling and dwelling mix shown in the
accommodation schedule. To estimate the likely total future population we have applied a
series of assumptions set out below:
8
Homes and Communities Agency (2014), Additionality Guide: Fourth Edition
6.8
5
Assessment of Economic Benefits Associated with Gresham's School`
3.12

Occupancy levels will be in line with the Holt average. According to the 2011 Census,
occupancy levels stand at 14% (287 of 2,094 households having no usual residents9)

Some of 1 and 2 bed dwellings will be single person households but none of the others
will be

In Holt, 33% of households are single person (696 in 2,094 households as per 2011
Census). However, single person households are more likely to live in 1 or 2 bedroom
homes than larger ones. We therefore conservatively estimate that 38% of the
occupied 1 and 2 bed dwellings will be single person

A study of 2011 Census data shows that non-single person households in Holt have
on average 1.99 residents. However, with over two-thirds of the development (68%)
being 3 bed or larger, we expect the average number of residents per non-single
person household to be much larger, as reflected in the table below.
Drawing on these assumptions, we forecast the new development to house 407 residents, as
shown below.
Table 3-2: Estimated total population for the development
Occupied
dwellings
with only
1 person
Occupied
dwellings
with 1+
persons
Approx.
average
residents
in
dwellings
with 1+
persons
Total
residents in
1+ person
dwellings
Total
estimated
residents
1.5
4
8
13
2.5
34
56
0
33
3.25
107
107
46
0
46
4
183
183
13
11
0
11
4.75
53
53
153
121
26
95
380
407
No.
of
beds
No.
being
built
1 bed
8
7
4
3
2 bed
41
35
22
3 bed
38
33
4 bed
53
5 bed
Total
No.
occupied
Source: Census data and report
Total gross jobs created
3.13
HCA and OffPAT guidance is that 150 permanent jobs in personal and other consumer services
are created for every 1,000 increase in population. Drawing on this and the information in the
table above, we estimate the proposed development will create 61 FTE gross jobs in the wider
economy.
For 2011 Census purposes, a usual resident of the UK is anyone who, on census day, was in the UK and had stayed or
intended to stay in the UK for a period of 12 months or more, or had a permanent UK address and was outside the UK and
intended to be outside the UK for less than 12 months.
9
6.9
6
Assessment of Economic Benefits Associated with Gresham's School`
Additionality and net effects
3.14
Given that these jobs generated in local and consumer services are serving extra population
in the local area, all the employment will be additional (i.e. there is no displacement).10
Multiplier effects still apply however, and we once again assume these to be 1.10. As shown
below, on this basis we have estimated that 67.1 FTE permanent jobs will be created in local
businesses and services by the new residents.
Table 3-3: Gross to net conversion of permanent employment in local and consumer services
Gross employment
Local and consumer
services
Less
employment
displaced on site
Less wider
local
displacement
61.0
61.0
61.0
With
multiplier
(1.10)
67.1
Source: SQW analysis
GVA impact of the created employment
3.15
There are several ways of estimating annual gross valued added (GVA) for a development. A
conservative approach is to use information on net jobs created, and salaries associated with
them. They are conservative because there are other elements of GVA, particularly company
profits that are not considered.
3.16
For this development, we have estimated the GVA impact by using the net jobs created in
construction and in local and consumer services (as per Table 3-1 and Table 3-3), and data
on average salary by sector from the Annual Survey of Hours and Earnings (ASHE). We also
account for the extra components of GVA by applying a conservative working estimate of 15%.
Our calculations are shown below in Table 3-4.
Table 3-4: Estimated GVA impact for the residential development
Net employment
Residential
construction
Local and
consumer
services
Gross annual
salary
estimate
Salary based
GVA11
222.6 job years
£29,018
£6,460,560
67.1 FTE
£21,659
£1,452,960
Total GVA
(including wider
components)
£7,429,644
£1,670,905
Source: SQW analysis
3.17
As shown above, the construction job years will generate nearly £8 million additional GVA,
which would benefit the local economy during the construction period. Based on planned
phasing and timescales, residential construction will last for around 56 months, giving a rough
average of £1.6 million GVA per annum.
Even if occupants of the new dwellings are already residents of Holt, we assume they will vacate their existing
dwellings to move to the development. These vacated dwellings would then be filled by non-Holt residents. There will
therefore be a net increase to the Holt population meaning that all the employment generated in local and consumer
services (by the new residents) will be additional.
11 These use estimates in the provisional 2014 Annual Survey of Hours and Earnings (ASHE). Construction salaries are
derived from the median annual wage for ‘Construction’ in the East of England; and local and consumer services uses the
annual median wage for ‘All services and industries’ in the East of England.
10
6.10
7
Assessment of Economic Benefits Associated with Gresham's School`
3.18
The additional GVA from new employment in local and consumer services would be in the
form of an uplift sustained over time, as it would be related to the on-going occupation of the
dwellings. On the basis that 27 dwellings will be constructed and sold each year (as per
planned phasing and timescales), jobs in local and consumer services will produce worth GVA
worth £1.7 million annually once all the dwellings are built and occupied by year 6 of the
project.
Summary of benefits
3.19
We estimate the residential development will lead to:

222.6 temporary job years (net) in construction, generating GVA worth £7.4 million
in total (roughly £1.6 million per annum) during the construction phase

Approximately 67 FTE (net) permanent employment in local and consumer services,
generating annual GVA worth £1.7 million annually upon occupation of all the
dwellings
6.11
8
Assessment of Economic Benefits Associated with Gresham's School`
4. Economic benefits of the proposed school
development
4.1
The proposed development of the Sixth Form Centre and improvements to boarding facilities
at the school will also bring economic benefits to the local economy both during the
construction phase (i.e. temporary employment and associated GVA), and through new
activity taking place at the school. These will be contingent on the residential development
taking place and therefore releasing monies to fund the additional work on the school site.
This section considers these benefits in brief.
4.2
In preparing this assessment we have relied on the construction costs

contained in AECOM’s Report and Construction Cost Plans (2014) for the proposed
Sixth Form Centre and improvements to boarding facilities

additional cost estimates provided by the architect
Economic benefits – construction phase
4.3
There are two elements to consider: the sixth form centre and the improvements to the
boarding houses.
Gross employment
Sixth Form Centre
4.4
Based on information provided by Gresham’s School,12 we understand the new sixth form
centre, which includes music and study rooms, will have gross internal floorspace of 1,423
sq.m. The construction costs for the centre have been estimated by AECOM to be £4.412
million.
4.5
HCA and OffPAT guidance is that for every £1 million spend on private commercial space, 17.6
construction job years are created.13 Using this, plus standard methodological approaches to
construction costs, we have estimated that construction of the Sixth Form Centre will generate
will generate 58.1 construction job years.
Boarding House
4.6
The improvements to the boarding house facilities will have an area of 2,481 sq.m. (gross).14
The construction cost estimates prepared by Aecom in February 2014, show a total
construction cost of £5.129 million.
Email from James Stronach, Director of Finance, Gresham’s School dated 06.02.2015
OffPAT Paper 4b – Construction Jobs (2009)
14 Total net floorspace is 2,047 sq.m. HCA and OffPAT guidance (2010) is that gross space is typically 15-20% higher than
net. We have assumed that the gross is 17.5% higher than net in this case.
12
13
6.12
9
Assessment of Economic Benefits Associated with Gresham's School`
4.7
Based on the HCA and OffPAT guidance that a £1 million spend on new housing creates 21 job
years in construction,15 we have estimated that the construction of the boarding house will
create 90.4 construction job years.
Additionality and net effects
4.8
4.9
When converting gross to net employment figures, we have used the same assumptions as for
the residential development:

that there will be no on-site construction employment to displace

wider local displacement will be 37.5%

a multiplier effect of 1.10.
As shown below, we have therefore estimated the proposed school development will create a
102.1 net job years in construction.
Table 4-1: Gross to net conversion of school level developments
Gross
employment
(job years)
Less wider local
displacement
(37.5%)
Less employment
displaced on site
With
multiplie
r (1.10)
Sixth Form Centre
58.1
58.1
36.3
39.9
Boarding House
90.4
90.4
56.5
62.1
148.4
148.4
92.8
Total School
102.1
Source: SQW analysis
GVA impact of the generated employment
4.10
We calculated the GVA effect of this construction employment, using the same assumptions as
for residential development. We have assumed that construction workers would earn the
regional median wage, and made an adjustment for the other components of GVA that this
does not capture (as we have explained in para 3.13). The calculations are shown below:
Table 4-2: Estimated GVA impact for the school development
Net employment
(job years)
School total
102.1
Gross annual
salary estimate
£29,018
Salary based
GVA
£2,961,655
Total GVA
(including wider
components)
£3,405,903
Source: SQW analysis
4.11
The construction employment created by the school redevelopment will produce over £3.4
million additional GVA in total. We are aware that construction will take around six years, so
the GVA effect equates to around £568,000 per year.
15
OffPAT Paper 4b – Construction Jobs (2009)
6.13
10
Assessment of Economic Benefits Associated with Gresham's School`
Economic benefits – new activity on the school site
4.12
Once the new site is operational, one will expect to see some other ‘softer’ benefits which will
nevertheless be expected to have a positive overall effect on the local economy. These are
likely to include:

Additional income to the school: the school will benefit not only from increased
capacity to take more fee paying day students and boarders, but also by being able to
let the new sixth form and music centre outside of school hours. This additional
income provides the school with the potential to buy additional local goods and
services going forward

Spend on local supplies: even once the construction phase is complete, the school
will need to draw on local suppliers for aspects such as the servicing and upkeep of
facilities, provision of goods and services for boarders, and ongoing school supplies.
These will naturally have positive effects on the local economy

Reputational benefits to the town: the new facilities will help to re-assert
Gresham’s credentials as a good school. This makes Holt a more attractive place to live
and as such, the increased house prices will continue to encourage providers of high
end goods and services to locate in the area. Given the centrality of the school to the
local economy, we expect any improvement to Gresham’s School’s reputation would
also improve the attractiveness of Holt more generally.
Summary of benefits for the new school

We estimate that the construction of the new school facilities will generate a net 102
construction job years. This in turn will generate roughly £3.4 million total GVA, or
roughly £570,000 per annum

There will be a series of wider benefits to the local economy coming from additional
income from new students, parents and visitors (which we have not attempted to
quantify), the school’s spend on local supplies, and the retention of the school’s
reputation to attract pupil numbers and sustain, maintain and enhance the position
of Gresham’s in the independent school sector.
6.14
11