Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 23058

Received: 16/03/2020

Respondent: Hingham Town Council

Representation Summary:

Hingham Town Council object to any new sites being allocated for house building in revised local plans to 2038 until all existing allocations in current core strategies have been developed.
Following the GNLP roadshow (Hingham, 25th February), it is clear that there is largescale and vehement objections within the community to Norwich Road being further developed.
Having regard to the comments, concerns and representations made by residents, Hingham Town Council object to site GNLP0520 being allocated as a preferred site and object this site being allocated for further housing development on the Norwich Road.
Many of the concerns raised in relation to the development of GNLP0520 also have regard to the newly built Hops development (ref HIN1) and that development of GNLP0520 would further exacerbate the existing and/or give rise to similar issues.
These issues are predominately surface water and flooding concerns, a lack of adequate pedestrian links to the town centre, road safety and a permanent detrimental visual impact on the approach to the Hingham which is a Historic Town with a substantially sized conservation areas and many listed buildings.
Flooding – residents on The Hops have stated that there is inadequate surface water drainage on the estate and surface water run off from the B1108 is substantial during heavy rainfall. Residents at the southern end of the development have advised that there are issues with damp in their homes and waterlogging of gardens.
Residents on the lower lying Seamere Road and Mill Corner (which is within the conservation area), raised concerns regarding flooding prior to the Hops being built. The surface water drainage system from the Hops development requires the co-operation of three private landowners and two public bodies to co-ordinate and manage its maintenance, the Lead Flood Authority does not consider this to be its responsibility. Surface water from The Hops is attenuated into a pond which then flows into the ditch system. Insufficient time has elapsed to establish if flooding concerns have been mitigated, as overtime the pond and ditch system will become silted and overgrown, and it had already proven difficult to secure any satisfactory maintenance of this drainage system due to multiple responsibilities for maintenance i.e the system is the responsibility of several bodies/individuals (NCC Highways, 3 private landowners and Anglian Water).
Residents south of The Hops were told that the new system would improve the situation in Seamere Road but this has not happened since all water from Norwich Road, Ringers Lane, Bears Lane, Bears Close and Drinkwater Close, together with that from the Hops, ends up in the roadside ditches in Seamere Road between Mill Corner and the bottom of the footpath.
It is also of concern that the agricultural land to the south of The Hops is now becoming waterlogged, low yielding and unfarmable – a resident has commented “the land is very wet, we got flooded last year we lost the surface of the track too, A Resident has dug the ditch out behind us and we have replaced the pipe under the footpath /bridge with a much bigger pipe, A resident in the front row of cottages got flooded too,. Crop is growing in the field but field is very wet”
The site assessment states “GNLP0520: This site is proposed for allocation on a reduced boundary to avoid areas of surface water flood risk and historic environment impacts”. Allocating GNLP0520 on a reduced boundary than initially put forward does not prove mitigation of surface water flooding concerns and/or concerns over the impact of surface water run off on the lower lying Seamere Rd/Mill Corner now and over time. The site assessment, with reference to flooding, advised –“ Mitigation required for heavy constraints”.
Where it is clear that flood mitigation is required – such as with GNLP0520 the GNLP team should actively seek information from residents affected by or potentially affected by flooding in the vicinity of a proposed site allocation for housing development, prior to that site being approved, rather than accepting the submittance from the developers that flooding has been / can be mitigated.
Inadequate pedestrian links to the town centre - It has already been noted in the site assessment that children would have to cross the B1108 to access a footway to enable them to walk to the primary school. When The Hops was built, adequate provision for pedestrians to walk from the development to the Town Centre (the Market Place) and beyond was not achieved and no pedestrian priority crossing point was provided.
A section of footway between The Hops and Bears Lane could not be provided due to land ownership. During the time The Hops was built, the land which could have provided provision of a footpath became available for sale, and has subsequently been sold. The developer of The Hops (and promotor of GNLP0520) did not purchase the land to enable the lack of footway (between The Hops and Bears Lane) to be rectified.
A pedestrian refuge was provided (at the point where the footway ends outside The Hops at the western end), in theory to assist residents of The Hops to cross the B1108, however there is poor visibility (crossing from The Hops) due to the existing hedge between The Hops and Bears Lane and it is often difficult to see if vehicles are approaching on the wrong side of the carriage way, to overtake parked vehicles on the north side of the road in the vicinity of the pedestrian island. The existing danger due to the crossing point not having pedestrian priority and the lack of visibility to the left is more acute for (those such as) wheelchair users, pedestrians with children and pushchairs due to them naturally not being able to stand on the kerb edge to look for oncoming traffic. The Town Council are aware of reports of a child being hit by a van at this location. The Town Council have requested NCC highways provide white H marking on the road to try to prevent parking in the vicinity of the pedestrian refuge, so far NCC have refused.
The lack of a section of footway between The Hops and Bears Lane means that pedestrians have to cross the B1108 to access the footway alongside the B1108 to then walk toward the centre of Hingham. Pedestrians have to cross the B1108 a second time to access the Co-op shop, cross the B1108 3 times to access the Pharmacy/businesses on Bond Street and The Fairland (due to the very narrow footway by Beaconsfield House) and cross the B1108 4 times to access the Lincoln (“village”) Hall and Library. This lack of adequate pedestrian links into the centre of town, may discourage residents at GNLP0520 from walking to and using the small independent businesses within the Town centre. Other sites in Hingham on the B1108, assessed during the GNLP process have been deemed unsuitable due to lack of adequate pedestrian provision (GNLP0298, GNLP0335), yet GNLP0520 has been deemed suitable (and the Hops has been built) without the provision of an adequate pedestrian link into the centre of Hingham. There is a clear inconsistency and contradiction demonstrated in the site assessment process.
There is NO point on the B1108 (or anywhere in Hingham) where priority is given to pedestrians crossing the road, this needs to be rectified. Development of GNLP0520 would be contrary to GNLP policy 2 “1. Access to services and facilities -
Developments are required to provide convenient, safe and sustainable access to new on-site services and facilities or to existing facilities as appropriate. This reduces the need to travel and provides local access to services and facilities, supporting their viability”
GNLP Policy 5 states “Residential proposals should address the need for homes for all sectors of the community having regard to the latest housing evidence, including a variety of homes in terms of tenure and cost. New homes should provide for a good quality of life in mixed and inclusive communities and major development proposals should provide adaptable homes to meet varied and changing needs”. Providing homes to meet “varied and changing needs” in Hingham MUST come with a commitment to provide the infrastructure to support those residents, including pedestrian priority crossing facilities in an appropriate location (locations) to ensure that ALL residents, including those who have mobility issues/slowness and visual impairments are able to cross the increasingly busy B1108 (where adherence to the speed limits is poor) as a priority over vehicles and be able to cross the road in safety.
Hingham has a high percentage of elderly residents, and statistics show that people are living longer, it is therefore essential that, in order to support any development in Hingham, the town receives improvements to the footways and crossing points to allow elderly and very elderly residents to walk around the town without fear of trips and falls on uneven and narrow footways or fear from crossing the busy B1108 due high volumes of vehicles and speeding traffic
Without adequate pedestrian provision, the development of GNLP0520 would be contrary to the GNLP policy 2 “Sustainable Communities” with regard to convenient and safe access to services and facilities, promoting active travel, and minimising pollution, as it would be reasonable to suspect that residents from a development on GNLP0520 would drive to access businesses in the centre of town and facilities such as Library, Village Hall, Sports Centre. There are long held concerns regarding on road and dangerous parking practices in Hingham. Being that there is no public car park and businesses in the Market Place and Fairland have no dedicated parking for staff or customers, it would be unlikely to achieve provision for green travel (outside of that of providing private charging points within a development) such as provision of publicly available vehicle charging points. Parking facilities at the Lincoln Hall/Bowls Club/Library and the Sports Centre are inadequate in size to accommodate visitors to these venues during busy times.
Detrimental visual impact on the town – many residents who attended the GNLP roadshow consider that The Hops has had a detrimental visual impact on the Norwich Road approach to Hingham, with concerns that the development is not in keeping with the town and will not “age well”, it has even been called an “eyesore”. The Town Council consider that further development of the Norwich Road (GNLP0520) in particular with the “active frontage” suggested, would have a further detrimental visual impact on the Town by creating a corridor approach to Hingham which would permanently further alter the aesthetic of a historic town. By developing GNLP0520 and combining the visual impact with that of The Hops would produce the perceived vision of one large new development on the approach to the Historic part of Hingham and it is a concern that this would create a perception of a “separate community” that may not integrate well into the existing community of Hingham
There would be significant loss of views over open countryside. Again there is inconsistencies within the assessment process, included in the reasons that GNLP0502 was considered unsuitable is “development in this location would encroach into open countryside with a resulting impact on form and character.” - however GNLP0520, being much more visible on the approach to Hingham would have a greater impact on form and character and would also encroach on open countryside. The arguments put forward in favour of The Hops development in 2014 maintained that the site’s
sloping nature would cause “minimised visual impact” on the approach to Hingham from the East and “preserve the visual of the tree line with the church tower above”. This argument and necessity seems to have been abandoned.
Because of the topography of the area GNLP0520 is at its highest point where it borders Norwich Road (sloping southwards) it is also situated higher than The Hops development. A development on GNPL-0520 would be visible for some distance, especially to the South and East and would be contrary to GNLP Policy 2 requiring developments to “Respect, protect and enhance landscape character, taking account of landscape character assessments or equivalent documents, and maintain strategic gaps and landscape settings, including river valleys, undeveloped approaches and the character and setting of the Broads;”
Development of GNLP0520 would also be contrary to Policy 3 “The Natural Environment …. Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes” … it is clear from residents objections that the loss of such prominent and valued open landscape by developing GNLP0520 would definitely not “conserve or enhance the natural environment”, but permanently destroy it, on the approach to Hingham via the Norwich Road.
GNLP0520 is documented as being within the 3000m buffer zone to SSSI. In the context of the climate emergency, where several species of wildlife native to Britain are becoming extinct or at risk of extinction the Council are concerned to ensure that housing developments are not built on areas where rare species of wildlife may exist, or indeed, where extension of the urban area will contribute to the depletion of wildlife. Should housing development take place wildlife habitat should be preserved, protected, enhanced and improved.
The houses along Seamere Road/Mill Corner, including listed buildings, will be negatively affected by flooding and decimation of rural situation.
Arable land south of both The Hops and GNLP0520, designed to assist with surface water flooding will be become unusable, inaccessible and waterlogged - as has already occurred with the land south of The Hops.
By developing GNLP0520, the land south of The Hops/GNLP0520 will have no road access for agricultural vehicles.
Development size – “approximately 80 homes, 33% of which will be affordable. More homes may be accommodated, subject to an acceptable design and layout being achieved”.
Hingham Town Council are concerned that the development of 80 houses (with imminent deliverability) (alongside 20 more allocated within the plan, 16 existing commitment and unknown number of “windfall” properties) is not sustainable with regard to the Towns facilities. There are concerns regarding the pressures that will be placed on the Primary School and Dr’s Surgery (without any consideration as to how developments in neighbouring Breckland will also add to the number of people needing to access services in Hingham). Both the Drs surgery and Primary School are located on Hardingham Street, on road parking to access these facilities is a daily occurrence, causing pollution, congestion and parking on pavements. It is reasonable to assume that many parents (due to work, lifestyle) from a new development will take children to and from school by car, parking issues (e.g too many cars and parking on pavements) relating to the primary school drop off and pick up times are already cause for concern and will be exacerbated by future housing development in the town.
It is also unreasonable to suggest (as has been suggested by the developer promoting GNLP0520) that residents from Hingham would be more inclined to work in Norwich/Wymondham and therefore a development on Norwich Road would prevent additional traffic travelling though the town and via the dangerous B1108/Fairland crossroads. It is conceivable to assume that there would be residents that would work in other locations such as Dereham and Attelborough. Dereham would also be likely to be a destination for supermarket shopping, having a large Tesco, Aldi, Lidl, pet store, Halfords, Screwfix, Roys, Homebase, Poundstretcher and a McDonnalds on the Hingham side of the outskirts of Dereham.

Highway access concerns – initially GNLP0520 was put forward for the development of 250-300 homes. Highways comments in the site assessment were: “ Not feasible to achieve safe access due to presence of TPO protected trees. Comments revisited: The ability to provide access visibility splays is limited by the presence of TPO protected trees at the site frontage”.
Prior to The Hops being built, part of the planning design was to include a pedestrian refuge at the eastern end of the development, however this was not deliverable because of the presence of TPO trees, and a compromise was made with the installation of a flashing speed sign (facing east only).
It is of concern that, if the site is allocated for development, when it came to the building phase, the vision splays/safe access to GNLP0520 would not be achievable due to the presence of TPO trees, (as was the case with omitted pedestrian refuge for the eastern end of The Hops, the design worked “on paper” but not in reality).
Highways have also commented that it is thought that compliance with the 30mph speed limit is not particularly good. This gives rise to concerns over safe access onto the B1108 from GNLP0520, in particular as the road to the east has reduced visibility due to a bend. It is not acceptable to assume that changing the environment, by building houses will reduce the instances of speeding (there is no evidence to support this).

In addition to access and speeding concerns, there is also a concern regarding the proximity of the required access to GNLP0520 to the existing industrial area. Already subject to frequent movements of long wheel-base HGVs emerging slowly from a standstill from Ironside Way/A C Bacon Engineering onto the B1108/Norwich Road whilst encountering oncoming domestic traffic within 300metres of a national speed limit and entering from a blind bend. Local residents frequently note near misses between domestic and industrial vehicles at the Ironside Way/A C Bacon Engineering junctions. The allocation (carried forward) of HIN2 as an employment area (stating that the existing access of Ironside Way will be used) means that at some point there will be increased industrial traffic of unknown size and frequency exiting and accessing the industrial/employment area to and from the B1108.

Highways have commented that there would need to be a pedestrian refuge in the vicinity of Ironside Way, however the Town Council question whether this is feasible due to any carriageway widening required/presence of TPO trees and how such a refuge would impinge on the very large HGV vehicles entering/exiting the industrial area.
There are also concerns regarding the inadequacy of pedestrian refuges in providing a safe crossing point for pedestrians. Pedestrian refuge island have numerous disadvantages (in comparison to a pedestrian priority crossing point) such as motor vehicles have priority, pedestrians may have to wait much longer for a gap in vehicle traffic to cross safely, particularly in heavy traffic, compared to a Zebra or Puffin crossing. For the pedestrian to cross safely, they must have good judgement of motor vehicle speeds and gaps in vehicle traffic, which children and older people do not always have. Visually impaired people, or those with other disabilities, may find refuge islands less easy to use compared with a Zebra or Puffin crossing. Some motor vehicle drivers act dangerously near crossing islands if a cyclist is passing through. They may squeeze past the cyclist when passing the crossing island, or swerve dangerously around the cyclist just before the crossing island.

A pedestrian priority crossing point must be provided in a suitable location to support any additional development in the town.

Employment - GNLP-0520 is opposite a mixed industrial estate with current B1-B8 use and future intended use allocated as B1, B2 and B8; B2 being ‘general industrial’ including chemical treatment and incineration, and B1(c) uses could change or be restricted by a higher concentration of residential housing (due to noise and use of acetylene and solvents as restricted under HSE). This could effect the sustainability of this employment.
Although HIN2 is the “designated” employment area in Hingham under the GNLP, there are no timescales for this area being developed to increase employment opportunities. There are many independent businesses in Hingham, the Co-op, agriculture and a small “industrial” area off Dereham Road that could all provide employment opportunities. Other development sites could provide better pedestrian access to the existing employment opportunities within the town
Future development – The site assessment document stated that “GNLP0310 (Approx. 172 dwellings)
is not considered to be suitable for allocation at the current time as it would need to be developed in conjunction with, or following site GNLP0520 otherwise development would be separate from the existing built form of the settlement”. Allowing GNLP0520 to be developed will then open up the potential for GNLP0310 to be developed in the future. A development in this location would further exacerbate all of the issues raised in regard to GNLP0520, Development of GNLP0310 is also vehemently opposed.

Previous consultation responses – During the previous consultation (8 January to 15 March 2018) GNLP0520 received 5 objections from residents and concerns were raised by the Town Council – the only comments in support were made by the developer of the site.

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