March 2018
Dear Sir/Madam,
Greater Norwich Local Plan - Regulation 18 Consultation
Land north of Eaton Gate, Low Road, Keswick
Eaton Gates (Keswick) Management Company Limited is responsible for the management, maintenance, security and safety of all communal elements of the Eaton Gate development, including common boundaries, private road, footways etc.
The Management Company, therefore, has a strong material interest in the adjacent land (ref no. GNLP0214) which has been put forward as a potential housing site (up to 4 dwellings) under the "call for sites" stage of the Greater Norwich Local Plan preparation.
It is understood that sites such as this, which are both less than 0.25ha and 5 dwellings, have not been assessed for the purposes of the Housing and Economic Land Availability Assessment but will be considered as potential settlement boundary extensions through the GNLP.
In accordance with its responsibilities and objectives, the Management Company therefore submits the following comments regarding its opposition to the inclusion of this land for development in the Greater Norwich Local Plan.

Development Boundary
Policy 16 of the adopted Joint Core Strategy (JCS) for Broadland, Norwich and South Norfolk identifies Keswick as an 'Other Village' which has a defined development boundary within which very limited infill development can occur without affecting the form and character of the village.
As a result, the development boundary for Keswick has been drawn tightly around the existing built up area on the south side of Low Road to prevent further extension into the surrounding countryside and to exclude those parts of the village that are at risk from flooding. It is pertinent that the site was previously rejected for residential development as part of the "call for sites" stage of the South Norfolk Local Plan process because of its location in relation to the village development boundary and the flood risk.
Although the allowance of small site windfalls for housing development adjacent to existing development boundaries is a potential option being put forward through the GNLP, the land in question is situated to the north of Low Road and well outside of the designated development boundary. The site is considerably detached from the rest of the village and connectivity is accordingly poor. Any extension of the village's development boundary to include this site would therefore constitute a significant policy change because not only would it necessitate a radical redrawing of the boundary to include the north side of Low Road but it would also be clearly damaging and contrary to the objective of retaining the rural nature of the area.
In this respect, the site in question lies entirely within a "River Valley" landscape character designation and this highlights additional material concerns regarding its suitability for built development - namely, impact on the landscape and flood risk.

Landscape Character
The whole of the 0.25ha site lies within the "River Valley" landscape character designation in the adopted South Norfolk Local Plan. DM Policy 4.5 of the Local Plan relates to the protection of Landscape Character and River Valleys and states that "All development should respect, conserve and where possible, enhance the landscape character of its immediate and wider environment. Development proposals that would cause significant adverse impact on the distinctive landscape characteristics of an area will be refused". The emerging GNLP seeks to maintain the protection and enhancement of recognised and valued landscapes by retaining existing landscape policies.
There is little doubt that development of up to four new dwellings on the land would not conserve or enhance the landscape character of the area. It would instead have a significant adverse impact on the open and unspoilt nature of the river valley and would therefore be counter to the aims of this particular policy.
References to the land being "previously developed" is questionable given its low level former use for the stabling, grazing and exercising of horses - a rural activity suitable for the location - has resulted in a derelict timber stables structure as the only residual remnant of this former use.
In addition, the site lies adjacent to the grounds of Keswick Old Hall - a Grade II Listed Building of considerable merit - the setting of which would be compromised by the development of new housing immediately to the east.

Flood Risk
One of the eight Strategic Principles of the Site Specific Allocations and Policies Document of the adopted South Norfolk Local Plan is "To avoid allocating land in Flood Zones 2 and 3" (SP4). The emerging Local Plan for Greater Norwich also states that new development will be steered away from areas of flood risk.
As a result of its location in the valley of the River Yare, the northerly margins of the site fall within the Environment Agency's defined Flood Zones 2 and 3 - the latter of which indicates the highest probability of flooding. As a result, it would be counter to both national and local planning policy to allow built development to take place on this land with the associated risk of flooding.
This is a particularly significant factor in relation to vehicular access to the site, which is provided via a track off Mill Lane and a field gate to the north end of the site. This existing access runs adjacent to a drainage ditch of the grazing meadows on land which is classified as Flood Zone 3 - ie the highest probability of flooding. This drainage ditch is shown as "High Risk" on the Environment Agency's map showing Flood Risk From Surface Water. As a result, the site is within 20 metres of a high risk source of surface water flooding and in periods of high rainfall (such as the recent Christmas / New Year period), this drain cannot cope with the volume of water and significant flooding results - impacting on the track which provides the sole means of vehicular access to the site.
In addition to this threat from flood water, this narrow track does not provide the standard of access required for built development on the site.

Access
It is considered that some of the information provided in the "call for sites" submission by the owners of the land is misleading. In particular, the landowners do not "enjoy an unencumbered right of access to the site from the public highway via the private road serving the Eaton Gate development". There does not exist, nor has there ever been used, a vehicular point of access into the land from Eaton Gate. This fact is reinforced by the layout of the private estate road - designed to serve the five properties of Eaton Gate - which does not include any drop kerb provision at any point along the section of the Eaton Gate boundary which abuts the neighbouring land in question. Moreover, the point at which the landowners have recently created a potential vehicular access point onto their land from the private estate road lies directly behind the marked spaces provided for Eaton Gate visitor car parking and which also provides the turning head for emergency vehicles. This parking and turning provision, together with suitable boundary treatment to reflect the rustic nature of the location, are examples of the stringent conditions applied to the original planning approval for the barn conversions and creation of Eaton Gate in 1996 and which have been upheld by the residents in all subsequent minor developments.
It is understood that a pedestrian right of access does exist onto the land from Eaton Gate but the fact remains that all vehicular traffic associated with the previous stabling of horses utilised the track off Mill Lane highlighted above. This would have involved very low levels of traffic, however, a substantial increase in vehicle movements (that would result from any housing development) must be of concern to the highways authority - not least since the junction where Mill Lane meets with Low Road does not benefit from good visibility.
In conclusion, therefore, the Management Company objects to any future amendment of Keswick's development boundary to facilitate inclusion of former site number GNLP0214 on the grounds that it would constitute a major, illogical and unnecessary amendment to the boundary. This is borne out by the fact that the land in question is situated in a protected landscape zoning, is partially at risk from flooding and has inadequate means of access.
We trust that for these strong reasons, the site is not considered suitable for built development and, to protect the rural nature of the village and its immediate surroundings, the Keswick development boundary is correspondingly left unaltered.

Yours sincerely,


Jeremy Cocks
For, and on behalf of, Eaton Gates (Keswick) Management Company Limited

Please see attached letter for full rep he has sent in via email