This is an objection to the proposed site reference GNLP2091 - Land West of Norwich Road, Stoke Holy Cross, in response to the Stage B Regulation 18 Consultation.

Introduction
This is a speculative proposal for a residential housing development of 11 dwellings, located on a prominent site at the edge of the village and within the boundary of the Tas rural river valley.

Planning and policy context

The site is significantly outside the village development boundary identified on map 019 of the adopted Joint Core Strategy.

The "Joint Core Strategy (JCS) identifies Stoke Holy Cross 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". 130 houses have been built or are currently underway on two sites on Long lane in the village of only 670 households. We believe that a 20% increase in the number of houses is significant and that no more should be built.
Under form and character it identifies that "the village has traditionally had a strongly linear form and has developed along the eastern banks of the River Tas away from the older historic part of the settlement around the mill". At the southern end of the village all houses are on large single plots accessed direct from the highway. The only exceptions to the very clear linear form are historic properties 'The Old House' and 'Lime Kiln Farm', which were built lower on the valley floor. Lime Kiln Farm has been converted into a group of houses and 'The Old House remains a single dwelling. Due to the limited width of frontage to the Norwich Road it would not be possible to continue the strong linear form. This would result in a modern estate type of approach with two or even 3 rows of houses accessed from a single estate road. This is clearly against the linear form of the village and against policy.

The Development Boundary and Constraints section identifies that "The boundary allows for additional infill development on Long Lane and elsewhere in the village but has been drawn to protect the more rural character of the village in the southern and northern extremities of development along Norwich Road".

A housing estate at the southern end of the village clearly goes against the policy to protect the more rural and open character of the village. The proposed development would significantly harm the natural and undisturbed beauty of the protected Tas Valley. The existing open landscape character of the southern end of the village, with its far-reaching views of the valley and river, would be lost. The proposed development would neither contribute to nor enhance the natural environment. Again, clearly against both national NPPF and local (JCS) policies.

Planning and appeal decisions on other sites in the vicinity are also relevant. The most recent being 14 Norwich Road - Proposed new dwelling- Outline (2017/1766). This was refused in October 2017 and dismissed at appeal 18/00026/AGREFUon 28th November 2018 for the following reasons:
- "The dwelling would be located outside the settlement boundary for the village where new housing would normally be restricted by LP policy DM1.3".
- The "development would be contrary to South Norfolk Local Plan (LP) policy DM4.5 which requires all development to respect and where possible enhance the landscape character of its immediate and wider setting".
- "Built development also including a substantial area of new access and driveway would harm the rural undeveloped character of the area which has an important aesthetic role in integrating the settlement within the countryside".

Access
The 'Constraints Analysis' section on the GNLP Suitability Assessment scores access 'green' with no apparent constraint. The site is located within the 30mph village speed limit but the approach from the south is restricted by the brow of the hill adjacent to the church. This results in access to the site limited to the centre of the frontage where the width of road is only 4.8m. A minimum of 5.5m is required for two cars to pass in safety at low speed. The land adjoining the road at the midpoint is approximately 2.5 m below road level so the 'access gradient' onto the highway is of great concern. It is clear that access has not been considered in line with the Norfolk County Council's 'Safe, Sustainable Development' (Revised Nov 2015). I am concerned that access to the site is dangerous and does not comply with recognised highway standards.

Accessibility To Services
The 'Constraints Analysis' section on the GNLP Suitability Assessment scores utilities capacity 'green', with no apparent constraint. Due to the east west fall across the site existing properties north of the site run into an unadopted foul sewer. It is highly unlikely that this would have spare capacity for a new housing estate.

Significant Landscape
The site is clearly very sensitive in landscape terms as it is entirely located within 'Character Area A1 Tas Rural River Valley' in the South Norfolk Landscape Assessment dated June 2012 and current specific policy, DM 4.5 ('Landscape Character and River Valleys', South Norfolk Local Plan) as contained within the Development Management Policies Document (October 2015).

SNLA Section 4.10 Sensitivities and Vulnerabilities states that "The principal sensitivities and vulnerabilities of the Tas Valley Rural River Valley Character Area include: visual sensitivities of the Tas Valley to new development/ landscape change as a result of its open character, wide flat floor and long valley views; small scale development pressures (infill, residential extensions) within the valley which could, over time, erode the local rural vernacular and the sense that buildings are well-integrated within the landscape context; "

The undisturbed site currently exhibits a distinctive character; an openness and tranquillity as clearly described in the policy documents, to protect the unique characteristics of the Tas Valley. A development of this site for housing will significantly harm the 'intrinsic character' of the valley, long valley views and beauty of this part of the Tas Valley.

Historic Environment, Listed Buildings and Archaeology
Both Stoke Holy Cross Parish Church (Grade II*) and 'The Old House' (Grade II) immediately adjacent to the site to the rear of properties fronting Norwich Road are located in close proximity to the site. The scale and siting of any development would affect the setting of both listed building by removing the special open landscape character and obscuring the important views of 'The Old House' from the Norwich Road.

The site is of archaeological significance. On the Norfolk Heritage Explorer (www.heritage.norfolk.gov.uk) the site and immediate land surrounding the site are defined as Archaeology areas. Recorded archaeological finds have been found to the south and east of the site.

Biodiversity and Geodiversity
A nationally designated Site of Special Scientific Interest (SSSI) lies to the immediate south east of the site.
In addition, Natural England https://designatedsites.naturalengland.org.uk designates land immediately surrounding the site as Habitat Inventory- Coastal and Floodplain Grazing Marsh, Priority Habitat Inventory - Good quality semi-improved grassland (Non Priority) (England) and Priority Habitat Inventory.

This is an area where animals, birds and butterflies including raptors (buzzards, harriers, every native owl, sparrow hawks and goshawk), 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.

Public Objection and Localism
There is little local support for the allocation of this proposed site for housing and most residents are opposed to any development which impacts on the Tas Valley. On the GNLP website for comments there are, as of today, over 60 objections/comments for this site.

Unintended Consequences and Opening to Other Local Sites
If the site were approved, then this could lead to other sites within the Tas Valley being put forward for development. 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, and further pressure on infrastructure.

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. Located in the protected 'Character Area A1 Tas Rural River Valley'.
3. Adjacent to a SSSI and other important wildlife habitats, which would be affected by the development.
4. No need for further development in the village. 130 dwelling have been or are currently under construction in the village.
5. Highway and access issues.
6. Inadequate services and capacity of existing utilities.
7. It is not sustainable development - no economic, social or environmental benefits.
8. The impact on views of listed buildings, archaeology, ecology and biodiversity of the area.
9. Lacking local support.
10. This site goes against the precedent of previous planning and appeal decisions.

T Powter-Robinson 5 Norwich Road, Stoke Holy Cross, Norwich, NR14 8AB
12th December 2018