A. Local Development Scheme for South Norfolk 2017-18 Revised December 2017 https://www.south-norfolk.gov.uk/sites/default/files/downloads/lds_december_2017_update_adopted_december_2017.pdf
B. Development Management Policies Document https://www.south-norfolk.gov.uk/sites/default/files/Development_Management_Policies_Document_0.pdf
C. Norfolk County Council: Safe, Sustainable Development Aims and Guidance notes for Local Highway Authority requirements in Development Management (revised November 2015) https://www.norfolk.gov.uk/rubbish-recycling-and-planning/planning-applications/highway-guidance-for-development/publications
D. Greater Norwich Plan - Housing and Economic Land Availability Assessment (HELAA) Addendum October 2018 http://www.gnlp.org.uk/assets/Uploads/HELAA-addendum-2018-final.pdf
E. South Norfolk Place-Making Guide Supplementary Planning Document September 2012 - https://www.south-norfolk.gov.uk/sites/default/files/South_Norfolk_Place-Making_Guide_SPD_0.pdf
F. South Norfolk District Council Site Specific Allocations and Policies Document (effective 26 October 2015 and covers the period up to 2026) https://www.south-norfolk.gov.uk/residents/planning/planning-policy/adopted-south-norfolk-local-plan/site-specific-allocations-and
G. Human Rights Act 19998, Article 8 https://www.legislation.gov.uk/ukpga/1998/42/schedule/1/part/I/chapter/7

Comments and Objection to Greater Norwich Local Plan (GNLP) Regulation 18 - New, revised and small sites (2018): GNLP Ref; 2061

Dear Sir or Madam,

We wish to make you aware of a number of strong objections that we have with regard to the proposed development of additional properties beyond the settlement boundaries of Rockland St Mary as set out in the subject Regulation (Call for sites), in particular the proposed site GNLP 2061 and in general the other 4 sites at GNLPs; 2007, 2063, 2064 & 2070. As residents of Rockland St Mary we are of the view that the proposed development will have a serious impact on residents standard of living and wellbeing. Our specific objections are as follows:

1. NON-COMPLIANCE WITH LOCAL PLAN POLICIES. We strongly feel that the proposed access route to/from the site at GNLP2061 will present a significant safety hazard to road users. In particular with regard to the guidelines laid out in Reference C, "Development must have safe vehicular and (where appropriate), pedestrian, cycle, equestrian links to a public highway. New accesses and junctions, (or existing accesses and junctions subject to a material change in traffic or use) must (in terms of geometric layout, visibility and construction) be safe. Importance is placed not only on those using the access, but also on the safety of road users passing the site". Further detail to highlight this point as follows:

a. The proposed access road to GNLP 2061 directly abuts the property at XXX The Street. This property was built circa 1850 (prior to the invention of the motor vehicle) and access to the highway is dangerous due to the very restricted lines of sight to the highway.

b. As defined in Reference C, "New accesses and junctions, (or existing accesses and junctions subject to a material change in traffic or use) must (in terms of geometric layout, visibility and construction) be safe. Importance is placed not only on those using the access, but also on the safety of road users passing the site." A new access point adjacent to XXX The Street would not be safe and it would significantly increase the danger to all road users using that particular section of The Street.

c. The difficulty currently experienced in exiting our property at XXX The Street is such that, because of the very restricted lines of sight we cannot physically see any oncoming traffic going from right to left until the front of our vehicle is almost on the centre line of the highway. We have to rely on winding down both windows to listen for any oncoming motor traffic (the situation with non-motor traffic such as pedestrians, cyclists etc heightens the danger even further) and then exit at a very slow pace.

d. Numerous times we have experienced near misses or irate reactions from other road users who travel through the village at speed. We tried to improve the line of sight to the right about 6 years ago when we landscaped the front of the property by replacing a section of fencing beside the exit and "kicking-back" the new fence at an angle but the line of sight benefit has been negligible.

e. It should also be noted by the planners that when considering this access point that consideration is given to section G 2.2 of Reference C in that "The eye line of drivers can vary from 1.05m above the carriageway in a standard car to approximately 2m in commercial vehicles. For drivers to see and be seen by pedestrians and wheel chair users, unobstructed visibility is required to a point 0.6m above ground level. To enable drivers to see other drivers and road users across summits; around bends; and at junctions; unobstructed visibility is required between the height range 0.6m to 2m". The line of sight from the proposed access to GNLP 2061 is blocked by a solid brick wall that borders the property at XXX The Street which is 1.4m high and runs directly up to and meets the footpath thereby affording road users wishing to exit the new access point even more limited visibility to the highway due to non-existent splay to the highway and extremely poor line of sight visibility making it extremely dangerous to all road users.

f. Further to this when two road users are trying to exit both the property at XXX The Street and another road user from the access to GNLP 2061, then inevitably this will result in a further increase in danger and chance of a collision.

g. Please note the following photographs that illustrates the difficulty in exiting the entrance of XXX The Street adjacent to the entrance to proposed site at GNLP 2061:

Figure 1: Drivers line of sight view when front of vehicle is right up to the edge of the footpath (facing West). N.B. The close proximity of the entrance to XX The Street opposite and, to the left of the wooden fence, the driveway to XX The Street (partially obscured).

Figure 2. Minimum distance the vehicle has to move on to the highway to obtain a safe line of sight when exiting XXX The Street (almost to the centre line of the highway).

Figure 3. Drivers view (west) from vehicle at position shown in Figure 2.
h. Given that the exit from XXX The Street has poor lines of sight particularly to the right where it exits directly in to oncoming traffic, it can be strongly argued that by adding in an additional access to the highway directly adjacent to, it would greatly exacerbate the problem and be unsafe for all road users.

i. Notwithstanding the additional entrance to the proposed site at GNLP 2061 the existing problem is compounded by the close proximity of the two entrances to the properties opposite (XX & XX) and the low-setting sun in the winter months that shines directly down the street which causes even greater reduction in ability to see oncoming traffic which in turn, makes this an extremely dangerous place to position an access point let alone one that would service 25 properties and all the additional traffic that would use the new access. The proposed developments are out of scale with the character of the settlement and are unacceptable and will create conflicts between pedestrians, cyclists and vehicular movements thereby creating a safety hazard.

j. It should be noted that on page 341 of Reference D - The site suitability conclusions for Rockland St Mary GNLP 2061 of the Housing and Economic Land Availability Assessment (HELAA) Addendum October 2018 were that "Access to the site, via what is a narrow field access, from the Street is likely to be difficult. The access is approximately eight metres wide and continues for at least 40 metres before widening to what is a 'backland' site. Initial Highways Authority evidence has indicated concerns about whether an access could be achieved, but as mitigations may be possible it is not categorically ruled out for the purposes of the HELAA". It is not apparently evident at all that any mitigation whatsoever could be effected to physically improve the line of site in such a manner as to make access safe for all road users. This therefore would be a dangerous access point, which would not comply with the specific detailed guidelines namely; G2.1, G2.2 and G2.3 laid out in Reference C concerning Norfolk County Council's Highway Access Standards.

2. DETRIMENTAL AFFECT ON THE TOWNSCAPE. The Rockland St Mary Settlement Policy Document Contained in Reference F clearly states as follows: "The village is set on the Yare Valley, and consequently in close proximity to the Broads, with a smaller tributary valley to the south, which together with good views from within the built-up area of the surrounding landscape and the good tree and hedge planting throughout, give the village a pleasant rural character". We feel strongly that the development GLNP 2061 will be detrimental to this and will not "enhance the pleasant rural character".

a. Development of the village is concentrated along The Street with a small detached cluster of development at Rockland Staithe to the east of the village, and an isolated group of houses to the west at The Oaks, Bramerton Lane. A small number of individual dwellings and farmsteads are widely dispersed throughout the remainder of the parish. The village has developed a linear settlement form based along Rookery Hill and The Street. It has experienced some limited estate development, particularly at the eastern end of the village adjacent to Surlingham Lane together with some infill development.

b. The siting of developments behind the land along the street to the North and South would drastically negatively affect the character of the village and set a precedent for future potential developments, which would further erode the character and charm from the village that has seen very little substantial change over the years.

c. Further non-linear development would be to the detriment of the majority of residents and would lead to "town-cramming" through an increase in residences but scant improvement in local amenities due to the constraints of poor public transport links and the existing transport infrastructure not being conducive to sustainable transport. This would have a detrimental effect of the wellbeing of both the immediate and the wider surrounding communities.

3. LOSS OF PRIVACY AND OVERLOOKING. It is stated at in Reference E, The South Norfolk Place Making Guide that "Where a block of development is proposed to include new housing and other uses, for instance in a new local centre, then careful design is required to provide residents with privacy and security". The proposed site of development at GNLP 2061 is at such that the primary amenity area of our garden containing a summer house and a raised terrace seating area, would be severely overlooked from the top rooms of the new development, resulting in a serious invasion of our privacy and we would ask that the planners consider the following.

a. The location of the proposed development GNLP 2061 does not afford adequate privacy for the occupants of the building or of adjacent existing residential properties, particularly with regard to their right to the quiet enjoyment of garden amenities and would impact severely on the existing privacy that existing residents have. We would urge you to consider the responsibilities of the council under the Human Rights Act as defined in Reference G, in particular Protocol 1, Article 1 which states that 'a person has the right to peaceful enjoyment of all their possessions which includes the home and other land".

b. We believe that the proposed development would have a dominating impact on existing residents and our right to the quiet enjoyment of our property. Article 8 of the Human Rights Act states that a person has the substantive right to respect for their private and family life.

c. In the case of Britton vs SOS, the courts reappraised the purpose of the law and concluded that the protection of the countryside falls within the interests of Article 8. Private and family life therefore encompasses not only the home but also the surroundings.

4. GROUND STABILITY AND TREE PRESERVATION. We have serious concerns about the impact the proposed works could have on the stability of our property. The farm track adjacent to XXX the street is a brick built construction and is approximately 150 years old and the property and boundary wall will run along the new access road. Given the age of the building the foundations, if indeed there are any, will be such that the construction of a new access road will have a detrimental affect on the fabric of the property. Any excavation work could have a serious adverse impact upon the stability of the existing structure. We also have concerns over the impact any construction would have on a large mature Walnut Tree that is on the edge of our property beside the farm track. Furthermore, we would ask that the following points be taken into consideration.

a. Major construction work would be necessary directly next to our home to convert the farm track adjoining our circa-1850s property and construct an access road. We have serious concerns about the impact that such works, including excavations directly next to our home, would have on the stability of the property.

b. Further to this, there is a large (approx. 30m) mature Walnut Tree that stands close to the proposed access approximately 20 metres down the Farm Track. The base of this tree is sited less than 2 metres from where the proposed access road would be constructed. Owls use this tree every year for nesting and it also sustains squirrels and other wildlife. A Tree Preservation Order has been submitted to Norfolk County Council.

c. Excavations and ground works that heavy excavation equipment would cause and the extent of excavation for the development would have on the root system of the tree could lead to the loss of the tree. Notwithstanding this, if any roots survived the excavation, or a new root system regenerated, they would reach beneath the proposed access road, therefore we also have concerns about the effect that the roots could have on the foundations of the access road in the future and requests to remove the tree that might stem from this. One of the council's broad aims set out in the Local Plan is to protect or enhance the local environment including wildlife habitats, trees and woodland. The area concerned is also a wildlife haven for many birds and animals and adds significantly to the amenity of the area.

5. DETRIMENTAL IMPACT UPON THE LOCAL ENVIRONMENT. Rockland St Mary is a linear village that is characterised in the main by detached and semi detached properties that run along either side of the main street which look out onto open fields, marshes and woodlands in an area that directly borders the Broads Authority Area that has similar status to the national parks in England and Wales and the areas of land to the North and South of "The Street" in Rockland St Mary both serve as vital "Wildlife Corridors" that are used by all manner of wildlife which mitigates the harm to the environment caused by Eutrophication from Farming and Sewage. The Broads are Britain's largest protected wetland and are home to a wealth of birdlife. Amongst the species seen are mallard, coot, moorhen, great crested grebe, greylag goose, Canada goose, Egyptian goose, grey heron, marsh harrier, cormorant, kestrel, sparrow hawk and bittern. The habitat surrounding the settlement area of Rockland St Mary is home as well to numerous deer that would be impacted by this development. Ecological constraints relate to the GNLP 2061 site's proximity to habitats in the Broads. The site is 200 metres from the Broads Authority administrative area and within the 3,000 metre buffer distance to SAC (Special Area of Conservation), SPA (Special Protection Area), SSSI (Sites of Special Scientific Importance), Ramsar and National Nature Reserve designations. Any new development of such scale would also negatively impact the environment with regard to increases in noise and light pollution, which would have a detrimental effect on the wellbeing of the existing community

6. IMPACT UPON RESIDENTIAL AMENITIES. The impact of an increase in population would have positive and negative effects on the amenities that serve the settlement. There would be benefits in greater footfall to private businesses that currently serve the village, which would potentially improve the life of residents through small gains in employment and other associated benefits such as enhanced provisions of service.

a. The amenities are limited however, for example the existing medical practice (part of the Heathgate Surgery Practice) operates on a restricted part-time basis (3 days a week) with the provision for cover outside of these times being served by practices located in Poringland, Loddon and beyond.

b. An increase in population would therefore serve to an increase in travel to and from the village, largely in motor vehicles. The nearest supermarkets are 6 miles distant so an increase in population would lead to an increase in motor vehicle traffic through the village either by residents or delivery vans.

c. The settlement has a range of social and community facilities including a primary school, post office, shop, doctors surgery and village hall. Other amenities such as secondary/further education are located in Framingham Earl or Norwich in the main as well as other amenities needed by the village such as dental practices, pharmacies, supermarkets etc. Again this would lead to a marked increase in motor vehicle traffic through the village.

d. Employment opportunities within the settlement are relatively scarce and most residents of working age predominantly work away from the village in the city of Norwich and surrounding service towns, again adding increased load to the traffic flow.

7. IMPACT FROM OVERFLOW TRAFFIC FROM A146 CONGESTION. The village of Rockland St Mary is becoming increasingly impacted by the overflow traffic that re-routes to and from Norwich along the A146 in order to avoid lengthy delays caused both by difficulties in access the highway due to sheer volumes of traffic at peak periods to delays in journey time due to the slow average moving speed of traffic at peak periods. Drivers are increasingly using the route through the surrounding villages including; Langley, Claxton, Rockland St Mary, Bramerton and Kirby Bedon to gain easier access to and from Norwich. The change in routing for a large number of Mini Buses from using the A146 to cutting through Rockland St Mary and the surrounding villages is testament to this. Further to this, the Street in Rockland St Mary has become "dominated" by the motor vehicle and has ceased to become a shared space for the community for all to use safely. Consideration should be given with regard to the following:

a. As the road has become more dominated by motor vehicles, we see fewer children cycling/walking from their homes to the local Primary School with many parents driving to a point near the junction at School Lane where they can safely and easily walk their children to school. Congestion at this junction and inconsiderate parking are commonplace. The addition of a proposed 25 further homes at GNLP 2061 will exacerbate the problem to the detriment of the community, which will be compounded yet further by granting planning permission to the other additional proposed sites at GNLPs; 2007, 2063, 2064 & 2070.

9. IMPACT ON SUSTRANS NATIONAL CYCLE ROUTE 1. Rockland St Mary forms part of Sustrans National Route which enters the village along Surlingham Lane and routes along The Street and through past the New Inn out of the village through the neighbouring villages of Claxton, Langley, Chedgrave, Loddon and beyond. Siting more residential developments in Rockland St Mary will inevitably lead to an increase in Motor Vehicle use which will deter people from using sustainable forms of transport such as the bicycle due to the increase in perceived danger people have as they see our roads get busier. The existing road infrastructure is not suited to creating cycle paths that are physically separated from motor vehicle traffic so this will only deter people from getting out of motor vehicle transport and on to sustainable forms of transport such as the bicycle. This has wider reaching negative effects on people's mental and physical health as well as their wellbeing and also has a negative impact on the environment.

10. SUMMARY. In summary, Rockland St Mary is a settlement of some approximately 325 homes (2001 census) which has seen the addition of the development at Eel Catcher close and a further development of 21 homes currently being constructed behind Bee Orchid Way. Together these two developments will provide an increase of approximately 10% of dwellings in the settlement which I believe is wholly appropriate. Any further increase will drastically alter the character of the village and over-burden the few existing amenities it has. We would be grateful if the council would take our objections into consideration when deciding this application. We would welcome the opportunity to meet with a representative of the planning department at our home to illustrate our objections at first hand. In closing, we object to the five proposed applications in the GNLP call for sites for Rockland St Mary as follows:

a. GNLP 2061. We STRONGLY OBJECT to the proposed application for backfield site for development located at GNLP 2061 for all of the aforementioned reasons cited in paragraphs 1-9 (incl) of this letter.
b. GNLPs 2063 & 2064. We OBJECT to the proposed applications for backfield sites for reasons cited in Paragraphs: 2, 3, 5, 7 & 9 above.
c. GNLPs 2007 & 2071 We OBJECT to the to the proposed application for site for development for the reasons cited in Paragraphs: 2, 5, 6, 7 above.