I OBJECT to the proposed site GNLP 2061 for the following reasons:

1.0 NON-COMPLIANCE WITH NATIONAL PLANNING GUIDANCE/NORFOLK COUNTY COUNCIL PLANNING POLICIES. As defined in Section 5 of the South Norfolk Site Specific Allocations and Policies Document, Policy 15 of the Joint Core Strategy (JCS) identifies Rockland St Mary as "a Service Village in which land will be allocated for small-scale housing growth in the period 1 April 2008 to 31 March 2026, within the range of 10-20 dwellings, subject to form, character and servicing constraints".

1.1 Rockland St Mary has already experienced an increase in dwellings within the village, since 1 April 2008 that have increased the number of dwellings in the village of circa 10% (of the last census figure of 324 homes) on both Eel Catcher close and a current development of 21 dwellings in Bee-Orchid Way.

1.2 Backfill developments behind The Street will be intrusive and significantly alter the linear character of the village and will not be in keeping with what are in the main, single dwellings on relatively large clearly defined individual or shared plots that give the village much of it's charm and character. Any development at the proposed site GNLP 2061 will lead to a loss of privacy and cause overlooking to the existing properties along The Street that are located within the Settlement Boundary. It is likely that like most other modern developments these homes would be large properties situated on relatively small plots and would not be in keeping with the vernacular dwellings.

1.3 The Government's current planning policies on different aspects of land use planning in England are set out in the National Planning Policy Framework13 (NPPF). The NPPF came into effect on 27th March 2012, replacing previously published planning policy statements and guidance in England. This included PPS7 Planning for Sustainable Development in Rural Areas, which included specific policies on LLDs:

a. The importance of landscape character is acknowledged in the NPPF's core planning principles: Section '11. 'Planning should take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it'.

b. Section 11 of the NPPF sets out the Government's
planning policies on conserving and enhancing the natural environment, including the landscape.

c. '109. The planning system should contribute to and
enhance the natural and local environment by protecting and enhancing valued landscapes, geological conservation interests and soils '

1.4 Any development at GNLP 2061 would be to the detriment of the intrinsic character and the beauty of the countryside that surrounds the village and therefore this application should be REFUSED as it would not meet the spirit of the NPPF or Norfolk County Council's planning guidelines and would be outside of the settlement boundary.

1.5 OBJECTION: This application should be REFUSED because of non-compliance with National Planning Guidance/Norfolk County Council Planning Policies due to this site:

a. Not being located within the existing settlement boundary and the intrusive nature of back-field sites leading to loss of privacy and overlooking of existing dwellings and any development would not be in keeping with the linear nature of the village.

b. The detrimental impact such a development would cause to the natural local natural environment and the NPPF core planning principle of "protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it.

c. Not positively contribute to nor enhance the natural valued green field landscape.


2.0 FAILURE TO MEET NORFOLK COUNTY COUNCIL'S SAFE, SUSTAINABLE DEVELOPMENT GUIDELINES FOR LOCAL HIGHWAY AUTHORITY REQUIREMENTS - UNSAFE ACCESS TO THE HIGHWAY. The proposed access to the highway for GNLP 2061 utilising the existing farm track would not meet the guidelines set out by Norfolk County Council for safe sustainable development. The farm track is NOT approximately 8 meters wide despite the assertions of the Housing and Economic Land Availability Assessment (HELAA) Addendum October 2018 "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." and also, the comment to the GNLP in support of GNLP 2061 by Mr Julian Wells (FW Properties) the developer who states: "Our highway engineers have confirmed that the existing 8 metre wide field access to this land would be more than sufficient to provide an adoptable highway and pavement(s) to this new development. In addition, they believe that an appropriate visibility splay could be provided on to the Street". The width of the farm track actually approx. 6.5 metres. This access would not be conducive to a safe access to the public highway with adequate provision of pavements due to width constraints.

2.1 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 Norfolk County Council's Safe, Sustainable Development Guidelines for Local Highway Authority Requirements: "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".

2.2 The proposed access to GNLP 2061 directly abuts the property at 101 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 and lack of adequate visibility splay contravening the council's stopping sight distance (SSD) guidelines.

2.3 As defined in Norfolk County Council's Safe, Sustainable Development Guidelines for Local Highway Authority Requirements: , "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 101 The Street would not be safe and it would significantly increase the danger to all road users using that particular section of The Street.

2.4 The difficulty currently experienced in exiting the property at 101 The Street is such that, because of the very restricted lines of sight it is not possible to physically see any oncoming traffic going from right to left until the front of the 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 and vulnerable road users such as disabled people, pedestrians, cyclists etc heightens the danger even further) and then exit at a very slow pace.

2.5 Experience of numerous near misses or irate reactions from other road users who travel through the village at speed already show the potential for even greater problems and increased risk of a traffic conflict. In an effort to improve the line of sight to the right about 6 years ago when landscaping the front of the 101The Street 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.

2.6 It should also be noted by the planners that when considering this access point that consideration is given to section G 2.2 of Norfolk County Council's Safe, Sustainable Development Guidelines for Local Highway Authority Requirements 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".

2.7 The line of sight from the proposed access to GNLP 2061 is blocked by a solid brick wall that borders the property at 101 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 due to lack of visibility splay making it extremely dangerous to all road users.

2.8 Further to this, when two road users are trying to exit both the property at 101 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. This risk is heightened by the very close proximity of other neighbouring properties with access point to the highway.

2.9 OBJECTION: Due to the unsafe access because of poor lines of sight and inadequate visibility splays leading to increased risk of traffic conflict creating unacceptable risk to all road users particularly vulnerable people it is recommended that this proposed site application should be REFUSED.


3.0 GROUND STABILITY AND TREE PRESERVATION. There are serious concerns about the impact the proposed works could have on the stability of our property. The farm track adjacent to 101 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.

3.1 OBJECTION: Due to the detrimental affect on the existing structure at 101 The Street and the potential for harm to well established mature Walnut Tree it is recommended that this application is REFUSED


4.0 FAILURE TO MEET KEY DESIGN PRINCIPLES. Among the Key design principles of South Norfolk District Council's Place Making Guide https://www.southnorfolk.gov.uk/sites/default/files/South_Norfolk_Place-Making_Guide_SPD_0.pdf are the following Key Principles:

a. "Respect the existing characteristic pattern of linear settlements at The Broads fringe with settlements
dispersed across the landscape elsewhere". The proposed development at GNLP 2061 does NOT respect this principle as it will be an uncharacteristic "back-fill development".

b. "Ensure that the rural quality is maintained including the rural lane network". Development at GNLP 2061 will inevitably lead to an increase in Motor Vehicle traffic that will deteriorate the rural quality of the village.

c. "Consider the impact of development on the skyline of open areas". The proposed development at GNLP 2061 does NOT respect this principle as it will be an uncharacteristic "back-fill development" and will have detrimental impacts on the privacy to existing residents and it will drastically alter the skyline of this open area.

4.1 OBJECTION: As the proposed site does not respect existing characteristic pattern of linear settlements, will not go toward assisting the rural quality of the rural lane network and will impact the skyline of open areas this application should be REFUSED because it FAILS to meet Key Design Principles.

5.0 ROAD SAFETY - INCREASED RISK IN TRAFFIC CONFLICT FROM HIGHER MOTOR VEHICLE USE ON UNSUITABLE ROADS. The villages of Langley, Chedgrave, Claxton, Rockland St Mary, Bramerton and Kirby Bedon have all suffered from a considerable increase in volume of motor traffic due to the intense load on the A146 that runs from Lowestoft to Norwich.

5.1 Drivers are increasingly using the route through these villages to get around the difficulties and dangers of joining the A146 from the many access points along the A146. This can be readily witnessed by the change in route that a large number of mini-buses from Langley School take now to get to and from the city of Norwich and it's environs. In recent times it is noticeable that these vehicles (and others) use the small country roads that wind through the aforementioned villages to avoid lengthy delays and dangerous accesses to the A146.

5.2 OBJECTION: This application should be REFUSED as any development will further increase the risk of traffic conflict from greater motor vehicle traffic on unsuitable roads which will impact vulnerable road users deterring greater use of sustainable transport and increase risks to public safety.


6.0 ROAD SAFETY - EXISTING PERIODICAL HIGHWAY SURFACE WATER FLOOD HAZARDS TO ROAD USERS. It should be noted that this narrow road that makes it's way through these settlements is prone to FLOODING at certain times of the year. Notable road sections that frequently experience partial or complete repeat flooding hazardous to road users that are:

a. The bend leading into Rockland St Mary that regularly floods and becomes a single passing place on a blind bend as drivers habitually drive on the wrong side of the road heading into the village. Flood water often extends beyond the centre line of the road from the inside verge of the bend.

b. In Bramerton, close to the Christadelphinians meeting room, this road habitually experiences flood from agricultural land surface water run-off. Often this flooding covers the entire carriageway and can get quite deep. This flood point is very close to a junction on a bend that leads to Surlingham.

c. Partial flooding often occurs along a section just outside of Rockland St Mary leading into Bramerton.

d. Other problem areas can be regularly experienced in the same road through Claxton past the Village Hall again partially flooding the road to the centre line.

e. The section of road leading from Rockland St Mary toward Norwich in front of the property adjacent to Sallow Lane often floods up to the centre line of the road.

6.1 Any increase in residential developments in these villages would inevitably lead to an increase in volume of motor traffic which will work against Norfolk County Councils stated aim to increase the use of sustainable transport as it will make cycling an even less attractive option to to the heightened risk of Traffic Conflict. Numerous areas that are prone to significant flooding will only add to the increased chance of a traffic conflict and this problem can be worsened further still should there be a significant drop in temperature below zero degrees Celsius, which would likely freeze any standing surface water on the carriageway.

6.2 As defined clearly in the Norfolk County Council Highway Guidance - Advice for Developers: "The development must be served by approach roads with the capacity to cater for the type and level of traffic likely to be generated, without prejudice to highway safety, particularly focusing on the most vulnerable road users"

6.3 Development at GNLP 2061 will be in direct conflict to this guideline and therefore it should be REFUSED on account of PUBLIC SAFETY, in particular with regard to the most vulnerable road users given the existence of Sustrans National Cycle Route Number 1 that traverses through the aforementioned villages in this objection.

6.4 This development along with the other proposed development in Rockland St Mary will all inevitably have a detrimental impact on ROAD SAFETY. Furthermore, the effects would be cumulative should any development be agreed and will have a hugely negative impact on all these communities that would far outweigh any perceived benefits for the reasons stated above. The planners are respectfully asked to take into account the mental and physical wellbeing and health of the existing community as well as the safety of VULNERABLE ROAD USERS and REFUSE this application outright.

6.5 The JCS vision states that 'there will be excellent public open space, sport and recreational facilities and community centres'. Objective 9 states that 'Development must provide environmental gains through green infrastructure...' and Objective 11 states that 'the accessibility of open space, the countryside, sports and recreational facilities will be improved'. JCS Policy 1 requires the development of a multi-functional green network - which provides opportunities for formal and informal recreation, walking and cycling, as well as encouraging and promoting biodiversity and acting to mitigate flood risk and combat the effects of climate change'.

6.6 OBJECTION: The proposed site at GNLP 2061 should be REFUSED as it would not meet the Joint Core Strategy (JCS) for Broadland, Norwich and South Norfolk because of the detrimental impact upon the existing community from increased use of inadequate roads by motor vehicles and the inherent dangers caused by surface water flooding to many areas of the highway and the lack of a creditable sustainable transport plan to protect vulnerable road users and encourage less reliance on motor vehicle transport.


7.0 Ecological Constraints to Site and Detrimental Impact on Biodiversity. Rockland St Mary is classified as a Service Village in the Joint Core Strategy. The village has developed as 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. The village is set in the Yare Valley, close to the Broads Authority area and ecological constraints relate to the site's proximity to habitats in the Broads. The site is 200 metres from the Broads Authority administrative area and within the Joint Nature Conservation Council's 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.

7.1 2016 State of Nature Report. The UK is now one of the "most nature-depleted countries in the world" with more than one in seven species facing extinction and more than half in decline, according to the State of Nature 2016 report. The report, which was produced by more than 50 different organisations including the Royal Society for the Protection of Birds (RSPB), the National Trust, the Marine Conservation Society and the Natural History Museum. Broadcaster and naturalist Sir David Attenborough, who wrote the foreword to the report, said there was a pressing need to take action to help Britain's wildlife. "The natural world is in serious trouble and it needs our help as never before," he said. "The future of nature is under threat and we must work together; Governments, conservationists, businesses and individuals, to help it. "Millions of people in the UK care very passionately about nature and the environment and I believe that we can work together to turn around the fortunes of wildlife". Development of greenfield sites such as GNLP 2061 will be to the detriment of our natural environment.

7.2 Species at risk of extinction include one of the icons of the British countryside: the kingfisher. Other animals in decline include the water vole, curlew, hedgehog, turtle dove and willow tit. The State of Nature report painted a bleak picture. "Between 1970 and 2013, 56 per cent of species declined, with 40 per cent showing strong or moderate declines," it said.
"Of the nearly 8,000 species assessed using modern Red List criteria, 15 per cent are threatened with extinction from Great Britain. "A new measure that assesses how intact a country's biodiversity is, suggests that the UK has lost significantly more nature over the long-term than the global average. The index suggests that we are among the most nature-depleted countries in the world".

7.3 OBJECTION: As this proposed site is situated inside the 3,000-meter buffer distance to SAC (Special Area of Conservation), SPA (Special Protection Area), SSSI (Sites of Special Scientific Importance), Ramsar and National Nature Reserve designations then the application should be REFUSED as it is not within the settlement boundary of the village and would cause harm to the biodiversity of the area by taking up green field sites and greatly impact negatively upon the fragile ecological balance of the location within the buffer-zone.


8.0 SUMMARY: In summary the application for a site at GNLP 2061 should be REFUSED because of the following Objections:

8.1 OBJECTION: This application should be REFUSED because of non-compliance with National Planning Guidance/Norfolk County Council Planning Policies due to this site:

a. Not being located within the existing settlement boundary and the intrusive nature of back-field sites leading to loss of privacy and overlooking of existing dwellings and any development would not be in keeping with the linear nature of the village.

b. The detrimental impact such a development would cause to the natural local natural environment and the NPPF core planning principle of "protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it.

c. Any development in back-field sites will have a negative impact on the skyline of open areas and will contravene the NPPF and NCC Planning Guidelines. The proposed development at GNLP 2061 does NOT respect this principle as it will be an uncharacteristic "back-fill development" and will have detrimental impacts on the privacy to existing residents and it will drastically alter the skyline of this open area.


8.2 OBJECTION: Due to the unsafe access because of poor lines of sight and inadequate visibility splays at the proposed access to GNLP 2061 leading to increased risk of traffic conflict creating unacceptable risk of harm to all road users, particularly vulnerable people, it is recommended that this proposed site application should be REFUSED.

8.3 OBJECTION: Due to the detrimental affect on the existing structure at 101 The Street and the potential for harm to well established mature Walnut Tree it is recommended that this application is REFUSED.

8.4 OBJECTION: As the proposed site does not respect existing characteristic pattern of linear settlements, will not go toward assisting the rural quality of the rural lane network and will impact the skyline of open areas this application should be REFUSED because it FAILS to meet Key Design Principles.

8.5 OBJECTION: This application should be REFUSED as any development will further increase the risk of traffic conflict from greater motor vehicle traffic on unsuitable roads which will impact vulnerable road users deterring greater sue of sustainable transport and increase risks to public safety. The danger to PUBLIC SAFETY from an increased risk in TRAFFIC CONFLICT on both Sustrans National Cycle Route Number 1 and on the road that leads from Loddon to Bixley to VULNERABLE ROAD USERS caused by any development in Rockland St Mary and neighbouring villages would result in a notable increase motor vehicle traffic that would be neither SUSTAINABLE nor SAFE.

8.6 OBJECTION: The proposed site at GNLP 2061 should be REFUSED as it would not meet the Joint Core Strategy (JCS) for Broadland, Norwich and South Norfolk because of the detrimental impact upon the existing community from increased use of inadequate roads by motor vehicles and the inherent dangers caused by surface water flooding to many areas of the highway and the lack of a creditable sustainable transport plan to protect vulnerable road users and encourage less reliance on motor vehicle transport.

8.7 OBJECTION: As this proposed site is situated inside the 3,000-meter buffer distance to SAC (Special Area of Conservation), SPA (Special Protection Area), SSSI (Sites of Special Scientific Importance), Ramsar and National Nature Reserve designations then the application should be REFUSED as it is not within the settlement boundary of the village and would cause harm to the biodiversity of the area by taking up green field sites and greatly impact negatively upon the fragile ecological balance of the location within the buffer-zone.