This is an objection to the proposed site GNLP0531 - Site west of Lower Road and south of New Inn Hill, Rockland St Mary (the site). I want this to be considered as a response to the consultation. A short summary of these comments has been put on the consultation website www.gnlp.org.uk

Introduction

This is a speculative proposal for a large scale residential housing development on a very elevated, elongated and irregular shaped site in a sensitive rural area.

The scale and impact of the site is out of context with the historic linear growth, size and design of the existing village. Development at this height would negatively impact the wider rural landscape including views to and from two river valleys, sensitive internationally important environmental/ecological areas and the setting of nearby listed buildings. It would also create further pressure for subsequent "infill" development around the proposed site in the future.

Planning and policy context

The site is significantly outside the village development boundary.

It is not contiguous, adjacent or relevant to any previous development in the village and is surrounded by existing farmland, a conservation area and river valley, smallholdings, listed buildings and The Broads Authority area.

The South Norfolk Place-Making Guide defines the area as "Rockland Tributary Farmland" with a presumption against large development. Characteristics are "small nucleated settlements inland including Rockland St Mary" and "Important views towards.... The Broads which provide a sense of place". Key design principles for any development (none of which the proposed site meets) are;

- Respect the existing characteristic pattern of linear settlements at The Broads fringe
- Ensure the rural quality is maintained
- Ensure that the integrity of important landmarks is respected
- Consider the impact of development on the skyline of open areas

Under the National Planning Policy Framework (NPPF) this site does not meet the three specific criteria for sustainable development as follows;

- Economic - there would be no local employment provided or supportable in the local area.
- Social - new houses would be provided but the volume is excessive and unnecessary for the need in this location being at least equal to the current allocation of houses for Loddon.
- Environmental - there would be major negative environmental impacts including traffic movements, light and noise pollution to sensitive landscape.

Ideally NPPF requires developments to achieve all these criteria but the proposed site meets none.

It would be appropriate for this site allocation to be considered by The Broads Authority as parts of Lower Road and some of the dwellings are within The Broads Authority Boundary.



Situation and location

The site is uniquely situated prominently between two sensitive environmental/ecological areas with a very high aspect and views stretching several miles. It is in an entirely rural area, adjacent to a semi-rural area, which in turn is an extension of the village that developed in a linear fashion over the last century providing a mix of ages and styles of housing giving it a specific form and character.

The proposed site boundary has been drawn within existing fields broadly parallel to the line of an existing footpath which would "carve up" the open rural landscape.

The site location (especially for the provision of any retirement accommodation) does not encourage interconnectivity with the existing village. It would be an unduly isolated settlement and separate community preventing inclusion of residents and access to local services.

Landscape impact

The significant height of the site (15 metres above sea level at its highest points) provides the highest land on the eastern side of the village. It overlooks sensitive RSPB reserves, marsh, woodland, meadows, a conservation area and the River Yare and The Beck river valleys which include sites of special scientific interest (SSSI)/areas of outstanding natural beauty (AONB). Land adjacent is the Mid-Yare National Nature Reserve (NNR) which is a Ramsar site - a wetland of international importance and a European Union Natura 2000 site.

It would cause the loss of good quality (grade 3) agricultural land and views of any new development would clearly be seen from all areas around the River Yare, Rockland Broad and The Beck as well as local roads and footpaths. The skyline, for several miles, would be affected by any development becoming out of context with the surrounding landscape.

It should be noted that any (much older) development in this vicinity has been very limited, almost entirely of bungalows, on existing road frontages and at lower height levels.

Scale and need

There is no need for additional provision of c 62% to the existing housing stock (325 dwellings at 2001 census) on a site equivalent to c 75% of the already developed village area. At a density of 12-14 houses per acre there is potential for the allocation of c 460-540 dwellings on the whole site. There are also sufficient new sites for development with planning permission already allocated.

FW Properties (www.fw-properties.com) are currently progressing the planning permission for the development of 21 new homes in Bee Orchid Way, Rockland St Mary. "The scheme will provide a variety of three, four and five bedroom homes". This site is adjacent to existing residential areas with infrastructure and all utilities existing and providing sufficient further housing capacity. It is also at a lower level than surrounding areas, on a sloping gradient with less impact on the landscape.

Natural water courses and additional flooding risk

This area is a natural source of water drainage into Rockland and Claxton marshes, Rockland Broad and The Beck hence development could lead to pollution of the natural water system impacting water quality. DEFRA have previously issued guidelines in this area as a Nitrate Vulnerable Zone (NVZ) to bring about improvements in water quality which may be threatened by any development.

There are existing houses in this locality that have their water supply from boreholes not Anglian Water mains. There would be a risk of contamination (as has recently occurred at Coldham Hall Surlingham) or diversion of natural water away from these private supplies.
The Environment Agency (EA) classifies the Norwich and Broads Water Resource Zone (WRZ) as an area of "serious water stress". The EA Flood Map for Planning shows the areas to the east and south (including Lower Road and The Beck) are designated Flood Zone 3 which are areas at most serious risk of flooding in the UK.

The land (and the site access) falls to c 0-5 metres above sea level at Lower Road to the east. A large development and diversion of surface water provides potential for "knock on effect" flooding of Lower Road and areas such as Rockland and Claxton marshes which are also areas in Flood Zone 3. The River Yare is higher than the adjacent marsh and farmland. A single pumping station on the River Yare at Claxton irrigates farmland and marshes. In autumn 2017 the pump failed requiring emergency repairs. Significant risks occur after snowfalls. Anglian Water, EA, The Broads Authority and landowners need to be consulted on this risk.

Highways and access

The A146 Norwich/Beccles road is the only main road around Norwich NOT classified as a "growth corridor. The Kirby Road to Rockland St Mary is inadequate to cope with the additional level of traffic. Particularly unsuitable sections of carriageway exist in Bramerton, entering Rockland St Mary as well as south through Claxton. Poor road features include narrow carriageway width without central line marking, right angle blind bends, hills and tyre worn verges.

Any development would create additional traffic movement through the whole of the village where there is already much on street parking causing congestion, potential hazards and disruption. It would also impact other much smaller rural settlements such as Claxton, Carlton-St-Peter and Ashby St Mary where roads are inadequate e.g.; Church Lane, Claxton which is the closest road to the proposed site, a narrow single lane road with high hedges and blind corners.

Lower Road is on the Sustrans National Cycle Network Route 1 and is "a series of quiet, on road-cycling and walking routes". There are only footpaths on one side of the road at this point in the village where a site entrance is proposed and these would be inadequate for highway safety of pedestrians.

No existing formal road access currently exists into the proposed site. Any access points would encourage additional development, provide poor visibility and would lead to excessive traffic on green belt land encouraging additional vehicular movements on The Broads Boundary. The vehicle access point is toward Claxton breaking up the rural landscape adjacent to The Broads. The road into the site that is proposed is c300-350 metres long and c50% of the whole estate road. Tree planting to the access would create a false feature reminiscent of a golf course or hotel entrance and would be an inadequate "buffer zone".

Services and utilities capacity

The village school would suffer additional congestion being situated within a small cul-de-sac.

Any potential development would require significant utility investment. Those such as water and electricity have suffered regular disruption. All utilities are a significant distance away from the proposed site with insufficient capacity for a proposed development of this scale.

It is not clear how suitable foul and surface water drainage could be achieved to mains sewers.

Existing brownfield sites and infill development

There are brownfield and infill sites in the village (and Hellington, Bramerton, Surlingham, Claxton, Ashby St Mary and Carleton St Peter) that have not been brought forward. These would provide housing in a more sustainable manner retaining the villages form and character and protecting the landscape. This would be a preferred route supported by planning policy and local opinion.

Employment

There is no local employment in Rockland St Mary for this scale of development. It would require most jobs to be in Norwich and require all occupiers to commute through the length of the village (c 1 mile) by car adding little or nothing to the community or the sustainability of the development. Alternative journeys through Claxton and other local villages would be on unsuitable roads.

Listed Buildings and archaeology

The Old Hall is a Grade II listed building adjacent to two other Grade II listed barn buildings. These buildings immediately adjoin the western boundary of the proposed site.

St Andrews Church, Claxton is a Grade I listed building of Saxo-Norman origin to the south.

This site would affect the context and setting of both these buildings.

Rockland has 81 recorded site finds on the Norfolk Heritage Explorer (www.heritage.norfolk.gov.uk). This site would have provided a commanding defence position for early settlements. Recorded finds include "a prehistoric burnt mound and Neolithic flint finds near Claxton Beck" (Grid Reference TG 3268 0415) close to the site.

Ecology and biodiversity

To the immediate south of the site is a conservation area, part of Claxton Manor Estate (see www.claxtonmanor.com and "wildlife and nature"). This is an area where animals, birds and butterflies including raptors (buzzards, falcons, harriers, every native owl, sparrow hawks and goshawk), otters, bats, swans and many other species thrive. Wild and other rare plant species have been documented in the surrounding area. Any development would damage these natural habitats.

There are established trees, including impressive oaks, in two existing fields which may be established "bat highways" from woodlands that are unsuitable for alteration or diversion in this sensitive location.

The impact of light and noise from buildings, people and traffic will affect the biodiversity. As stated on a Claxton Manor Estate on the conservation area "wildlife thrives much better if undisturbed".

Amenity areas and public footpaths

The loss or variation of public footpaths would limit access to the countryside and views in this area.

The public footpath across the proposed site is not marked out and is inconsistent with the existing footpaths on the proposed site. There are additional tracks over which public rights are exercised.

There is a commercial shoot run on adjacent land that may have to close or would become unsustainable if any development occurred.

Public objection and localism

There is little local support for the allocation of this proposed site for housing and most residents are opposed to development of this scale in the village. On the GNLP website for comments there are as at today 30 objections/comments for this site and 3 supporting comments (albeit they mainly suggest much smaller development) indicating the strength of feeling.

Unintended consequences and opening to other local sites

If the site were approved, then this would lead to other adjacent sites coming within the village curtilage and development boundary. This would generate further promotion and applications for planning and infill development on neighbouring sites that SNDC would not be able to oppose. This would lead to an oversupply of housing land in the village, inappropriate and unsustainable development, downward pressure on house values and further pressure on infrastructure.

Relevant additional planning information

Planning decisions on other sites in the vicinity are also important to consider as follows;

Land to west of 1 New Inn Hill, Rockland St Mary - Proposed new house (2017/0638/O). This was refused in May 2017 for the following reasons;

- Outside the development boundary
- Impact on character and landscape of the rural area
- Unsustainable development

Eel Catcher Close off New Inn Hill, Rockland St Mary (2009/00254/F). This planning application was approved as part of a Section 106 Agreement as Affordable Housing after a Local Housing Needs Survey was undertaken and an "Exception Site" was allocated. This was funded by The Homes and Communities Agency and built by Broadland Housing Association offering different types of affordable tenure providing accommodation for local people to live in the village.

Viability

If the site was approved, it would demand extreme sensitivity in siting and landscaping severely reducing the developable site area. It would also require abnormal costs for highway infrastructure, access, archaeology, flood risk alleviation, Section 106/Community Infrastructure Levy charges, an affordable housing provision of 35-50% and extensive utility capacity upgrades particularly for water, electricity, gas, broadband, drainage and sewers. Any development would have to be phased over many years with uncertainty on maintaining values with a large supply of new houses. All of this would question the viability of the scheme and it would only be profitable to a developer if mass scale housing was secured (as has been proposed).

Summary

At every level the proposed site is unsuitable for allocation of a new housing development of any size. It has many potential adverse impacts, risks and uncertainties as follows;

1. Against planning policy - sited outside the village development boundary, contrary to the South Norfolk Local Plan Development Management Policies and national planning policy.
2. Situated in a rural area and isolated from the existing village.
3. The site height of 15 metres is the highest on the eastern side of the village having a detrimental impact on the skyline, rural landscape and views of SSSI/AONB.
4. No need for a development of this scale, out of context with the form and character and with existing planning permissions in the village for 21 additional houses.
5. Risks of pollution to local water courses and adjacent flooding risks from diversion of surface water.
6. Severely limited existing highway infrastructure, access, footpath and National Cycle Network issues.
7. Inadequate services and existing utilities location, capacity and cost of upgrade.
8. There are alternative brownfield and infill sites in the local area.
9. It is not sustainable development - no economic, social or environmental benefits.
10. The impact on views of listed buildings, archaeology, ecology and biodiversity of the area.
11. Loss of local amenity and public footpaths
12. Lacking local support.
13. Site would have the unintended consequence of leading to additional adjacent development
14. This site goes against the precedent of previous planning decisions.
15. The site would have questionable viability unless developed as a mass scale housing site.