Introduction: This is written in response to the Owner's application for Site 2091 ('the field') to be included in the GNLP. This site comprises 1.24ha of arable land situated to the west of Norwich Road, Stoke Holy Cross, Norwich NR14, opposite Stoke Holy Cross Church and adjacent to 1, Norwich Road. The Owner wants to build '11 Executive Houses' with, or without, prior inclusion of the site in the GNLP, according to their Planning Consultants. The Owner intends to 'jump the gun' by apply for planning permission before Christmas 2018, rather than go through the correct GNLP procedure for making suitable sites available for inclusion in GNLP.

Planning Permission for this site, and an additional strip of land, was rejected in 2011. Although the Owner's Planning Consultants and Architects may think that his current application has been adapted to make allowance for criticisms made in 2011, many (perhaps all?) of these criticisms still stand, and there may, in fact, be new criticisms that are also valid.

In GNLP we are told that:
* 'The vision for Greater Norwich to 2036 is 'To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment'.
* On the 'Home' page, Councils choosing such sites must 'protect and enhance the built and natural environment, make the best use of natural resources, mitigate against and adapt to climate change'.
* Any site to be included in GNLP must be 'Sustainably located', so the Council has to do a 'Sustainability Appraisal' i.e. it must look at the social, environmental and economic impact if a site is developed. (N.B. 'Sustainability' means 'the avoidance of the depletion of natural resources in order to maintain an ecological balance'. 'Ecology' means living creatures, including humans, living in a balanced environment.' It should not be forgotten that natural landscapes are essential to the overall wellbeing of humans, as well as other creatures/plants, and the Council, therefore, has a duty to help preserve them, to avoid their 'depletion'.

The Council has completed a Suitability Assessment regarding Site 2091, though the rather simplistic green, amber and red Flags may belie the reality of things (see later).

Page 1 of Suitability Assessment of Housing and Economic Land Availability Assessment (HELAA) Addendum 2018 says 'Important: The inclusion of a site as potentially suitable for development within the HELAA DOES NOT confer any planning status on that site, or any commitment that it will be brought forward for development'. The owner's wish to make money out of any site could, therefore, be challenged, provided the Council can be persuaded that other factors are more important.

In the case of Site 2091 there are several 'amber flags' against GNLP2091 i.e. 'Significant Landscapes', 'Townscapes', 'Biodiversity and Geodiversity' and 'Historic Environment', (of which more later) and there are also several green flags. These green and amber flags must still be explored further by residents and planners, and not be accepted as being conclusive. They should not be rubber stamps. For example, the people awarding them have, probably, never really used the road in question. The occupants of houses adjacent to Site 2091 have better direct knowledge of the area, as we try to get out of our drives in the morning. Remember, we use Norwich Road during the current rush hour traffic, even before is has been swelled by any new inhabitants of 11 new 'Executive' houses (remember these houses might have 2, or more, cars!) 'Flags' will be discussed in further detail, in due course.

Also, does the 'need' for housing outweigh other factors? Housing targets are exaggerated and out of date, according to the Campaign for Rural England. It says that the 2014 figures for housing targets, that the government insists upon using, are higher than the more recent figures, which should be adopted. As things, stand, the Council needs to find another 7200 houses across Norfolk, whether this target is fair or not. However, there are many existing/already accepted development sites, which could be brought to fruition, within a reasonable time scale, without interfering with precious green field sites, such as Site 2091.

1. Development Boundary: Site 2091 has been put forward by the Owner for inclusion in GNLP and, specifically, for the development of '11 Executive Homes' ('at least', they say). This field is situated to the south of the 'development boundary' for Stoke Holy Cross, after the village sign, and is outside the 'envelope' for the village. This is contrary to the Joint Core Strategy, which is emphatic in its requirements about maintaining the individual character of villages and not allowing creeping infill. Also the edges of the village are supposed to taper, to minimise the impact of its buildings on the landscape. The building of 11 Executive homes on a field at the edge of the village goes against such principles.

2. Significant Landscapes (Amber Flag): Site 2091 ('the field') is situated on the western side of Norwich Road, below the level of Norwich Road itself and below the elevated church car park, both of which are cut into the slope. 'Landscape' means 'all the visible features of an area of land, often considered in terms of their aesthetic appeal'. In this case, the Site in question comprises the following features:
* The site is adjacent to, and arguably, forms part of water meadows (photos of flooding of the two fields below the Site have already been sent to the Council and the Environment Agency). The photographs also show the beginnings of flooding in the field itself. The risk of flooding has to be projected over the next 100 years, and the problems attendant upon global warming and climate change are only likely to increase, if our behaviours do not change.
* There are slopes, several hills (further to the west of the site), the brow of hill by church car park and the hill, upon which, as tradition requires, the Church itself stands. The churchyard and the church car park provide vantage points from which to view the Tas Valley.
* The field itself is arable/grazing land, but it has not been cultivated for several years. Consequently wildlife is flourishing here, as, too is the flora!
* There are various groups of trees surrounding the site or in the distant landscape (see the mention of DEFRA later) and there is also an ancient Oak that must be preserved
* Existing buildings include the Grade II Listed Church. The other oldest building in Stoke Holy Cross is a Grade II Listed Cottage (which dates from 1540). This cottage overlooks Site 2091, looks towards the church car park, across the water meadows and down the valley towards the River Tas. It holds its own place within the landscape. The outlook from this cottage, across the field, should be protected.
* Beyond the field, further to the west, across two more (sometimes flooded fields), flows the ribbon of the River Tas. This river is visible from the road and many houses, and helps to create a magical entrance to the village.
* The village of Stoke Holy Cross and the Caistor Roman Site, (in the nearby village of Caistor St Edmund), are linked by the River Tas, as it flows through, this unspoilt, historic landscape
* Site 2091 is adjacent to the Shotesham SSSI (see later)
* Drivers, pedestrians, inhabitants and photographers alike, benefit from the blood-orange sunsets, as the sun sets over the valley. A series of houses built in front of these sunsets, will prevent everyone from enjoying this dramatic feature within the landscape.
* The site is said to be within the 'River Valley Landscape' designation area. The South Norfolk Landscape Assessment para 5.10 emphasises the 'Visual sensitivities of the Tas Valley to new development...as a result of its open character, wide flat floor...long valley views....valley crests'.
Would the proposed '11 Executive Houses' help to enhance this landscape? It should be remembered, that, once destroyed, landscapes such as GNLP2091, will be gone forever. The Suitability Assessment gaily says that 'the constraints identified would need addressing, but are likely to be within the bounds of mitigation'. How easy it would be for the Council to allow such 'mitigation' and wipe out this 'significant landscape'!

3. Townscapes (Amber Flag): There are many other developments already being built/have been proposed in Stoke Holy Cross:
* It is the general view in the village, that 'Stoke Holy Cross has already 'done its bit' in providing sites for the GNLP.
* The Local Plan p. 30 para 5.6 says 'Throughout the district there are a number of areas of locally significant landscape value. Many of these follow the route of important river valleys, predominantly along the River Wensum and the rivers Waveney, Tiffey,Yare, Tas, Tud and Chet. Additional areas of landscape value also include areas of open land that maintain a separation between certain settlements, and a large landscape protection area around the A47 south of Norwich, which is considered important for preserving the historic setting of the city of Norwich.'
* Over time, will Stoke Holy Cross 'village' just become a suburb of Norwich, as site after site is developed? This would be contrary to the Joint Core Strategy.
* In the 'end' will we any longer be able to call Stoke Holy Cross a 'village' or will it just be linked to other 'villages' by a series of roundabouts, like any other modern estate or small town?
* We must avoid careless and unnecessary infill of precious sites like Site 2091. This proposed development is the 'thin end of the wedge'. It will open the floodgates to development and establish a precedent for building closer to, and along the edge, of the River Tas.
If building on Site 2091 is to be permitted, we begin to lose the character of this this lovely village - a character, which comes from its being set in an unspoilt, historic, natural landscape.

4. Biodiversity and Geodiversity (Amber Flag): Site 2091 is within the 'impact zone' for the Shotesham Site of Special Scientific Interest (SSSI) and is within a DEFRA designated area of 'High Spatial Priority Woodland':
* The site is currently frequented by buzzards, kestrels, barn owls, deer and pheasants (and, no doubt, many other creatures) and the church car park overlooks the field and is frequented by bird watchers
* We should be careful how we play with such areas of our countryside. Humans have wiped out 60% of animals since 1970 https://www.theguardian.com/environment/2018/oct/30/humanity-wiped-out-animals-since-1970-major-report-finds We must conserve precious wild environments, like Site 2091 and its surroundings
* 'Ecology' is 'the study of the relationships between plants, animals, people, and their environment, and the balances between these relationships'. We must be very careful how we manage our habitats/biodiversity/geodiversity, so that a variety of creatures and flora can all thrive and a balance be created.
* We should also respect the need for humans to be able to enjoy unspoilt, quiet spaces (particularly as there is so much building in South Norfolk, at the moment). Quiet, natural spaces are known to be good for our mental and physical well-being, and architects, now, have to take this into consideration in designing their plans. The current habitats of the residents of Stoke Holy Cross should, therefore, also be respected and conserved.

5. Historic Landscape (Amber Flag): Site 2091 forms part of what is undoubtedly a 'historic landscape. 'History' can be interpreted in many ways:
* The landscape contains two lovely, old buildings Stoke Holy Cross Church (Grade II Listed) and the Grade II Listed Cottage across the field. These are situated close to, or are adjacent to, Site 2091.
* The Caistor St Edmund Roman Site, is situated a few miles away, and, like Stoke Holy Cross, stands on the edge of the River Tas. These two villages must have seen much to-ing and fro-ing between them over time. The river would have been a trade link, and many feet would have walked across the fields between Stoke Holy Cross Church, the River Tas and the Roman Site, through the ages.
* Our place in history should not be forgotten. We should be careful not to wipe away our heritage. 'Heritage' means 'a property that is, or may be, inherited'. It also means 'valued objects and qualities such as historic buildings and cultural traditions that have been passed down from previous generations'. Our heritage comes from the past, but also stretches into the future. It is not only what we have inherited, but what we should leave for future generations.
* The current residents of Stoke Holy Cross walk up Norwich Road, towards the church, to visit the church, to walk in the churchyard, to put flowers on the graves or to walk their dogs, as generations have done before them. As they walk, they look across the unspoilt fields towards the River Tas. The sometimes-flooded fields are filled with white, water birds, giving joy to many people. Buzzards cry overhead, reminding us that this is a wild landscape. People park in the church car park, having driven there especially, to photograph the sun setting over the Tas Valley. Some people go there just for a moment's quiet reflection. These are 'cultural traditions', as much as any. They would be destroyed by the intrusion of further building in the landscape.
* If building works were permitted on Site 2091, this would disrupt the visual amenity of this historic landscape. If people look down from the car park, across the field towards the River Tas, they will see the pretty Grade Ii Listed Cottage nestling in the landscape, as it has done for over 500 years. Drivers and walkers can look across the flooded, water meadows towards the distant river, as they enter and leave the village. Such sights are precious and should be conserved. The interruption of 11 buildings between the road and the river should not be permitted.

6. Green Flags: This may not be the place to challenge, in detail, the Green Flags, but it is important to put on record some of the implications of the proposed access point from the proposed development of '11 Executive Homes' onto Norwich Road:
* Although there is a brow of a hill between the village sign (near 1, Norwich Road) and Stoke Holy Cross Church, this appears to have been brushed aside in the allocation of a 'green flag'.
* There is a steep gradient on Norwich Road, leading up to the church, as well as from Site 2091 itself, up onto Norwich Road.
* It is stated by the Owner's representatives that there is a 90m visual splay either way along Norwich Road, from the proposed new access point, but this may not allow for the actual speed with which cars actually pass the church, despite the 30 mph sign. The Council could check this more thoroughly. Inhabitants often hear people speeding through the village.
* Also there are already 2 blind bends for the inhabitants of this section of Norwich Road to deal with, as they drive from their steep drives onto the road.
* Any additional building/fences/hedges along the Norwich Road frontage would further inhibit the visibility of existing inhabitants, when entering onto the road.
* There would be many more cars (perhaps 20 or more) flowing from the new development (or, more likely, trying to get out onto the road in the morning).
* Norwich Road is already too narrow for the existing types of transport that it is currently supposed to cope with. It should be 6m wide, if buses are to travel along it. Without buses, a road should be 5.5m wide. In reality, Norwich Road is only 4.6-4.8m in various places, so is already considerably narrower than it should be.
* Pavements in the village, from the site, are also inadequate. They should be at least 1.5m wide and are in reality 1.2m wide. Our daughter was hit by the wing mirror of a passing vehicle, while walking 2 abreast, on the pavement, with a friend.

I would ask the Council to give careful thought to these arguments. I can provide more, if you would like some, but time is limited for everyone!