GNLP0250/0342/0119/0291

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Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20252

Received: 02/03/2020

Respondent: Diss Town Council

Representation Summary:

The GNLP said this combination of sites is preferred for allocation as they are well related in
form and character terms to the existing built up area of Diss and would enable the provision
of a link road to connect Heywood Road and Shelfanger Road, which may alleviate some
existing traffic problems.
Comments by DTCNP sub-group members:
We agreed with the GNLP especially as this was an area they were already looking at. It
was seen as an option that gives a west to east link road connecting Shelfanger Road to
Heywood Road and that it would help alleviate traffic pressures in the north of the town
especially on roads such as Sunnyside. We were also pleased to see the GNLP recognised
our earlier submissions about the need to expand the cemetery.
Diss Town Council Recommendation: That Diss Town Council support this preferred GNLP option.
(See attached)

Full text:

Thank for giving us the opportunity to consult on your proposals for the sites in the Diss area.

The Town Council has been working with the Diss and District Neighbourhood Plan Steering Group comprising the parishes of Brome and Oakley, Burston and Shimpling, Diss, Palgrave, Roydon, Scole and Stuston on the emerging plan, which we expect to consult on later this year. In addition we have worked with consultants AECOM who have advised and helped us develop our evidence base on Housing Needs, Design and Design Codes and also Site Assessment. It was interesting to note that AECOM considered that all the Diss and Neighbourhood Plan area to be rural in nature, a fact they felt should be fully considered in the site densities we allow.

Whilst we agree with most of your recommendations for the sites in the Diss area, there are a few we would like to consult further on. All the GNLP sites were discussed in Council on 19th February 2020 and our recommendations were approved unanimously.

Please see attachment

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20301

Received: 04/03/2020

Respondent: Julia McCathie

Representation Summary:

Too many houses. Roads already too busy and already used as a rat run. Building on fields at top of town will cause flood risk to lower town. Increase traffic and noise pollution. Not supported with addition doctors/dentists etc. Already struggling to provide good service to current residents. Impact on wildlife and environment that cannot be replaced.

Full text:

Too many houses. Roads already too busy and already used as a rat run. Building on fields at top of town will cause flood risk to lower town. Increase traffic and noise pollution. Not supported with addition doctors/dentists etc. Already struggling to provide good service to current residents. Impact on wildlife and environment that cannot be replaced.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20303

Received: 04/03/2020

Respondent: Julia McCathie

Representation Summary:

Already too many new houses in Diss. Must Protect our countryside. Our environment must be protected. We don’t want more roads and houses. Already too many vehicles in the area causing traffic issues. Local services eg doctors, dentists can’t meet demand now. We don’t want more people in Diss. Houses will be squeezed on, narrow roads and look unsightly like other new developments. Building on fields causes risk of flooding, flood prevention measures don’t work! We can’t build our way out of this problem. I strongly object to this site. Maybe nil cost to council but huge cost to Diss.

Full text:

Already too many new houses in Diss. Must Protect our countryside. Our environment must be protected. We don’t want more roads and houses. Already too many vehicles in the area causing traffic issues. Local services eg doctors, dentists can’t meet demand now. We don’t want more people in Diss. Houses will be squeezed on, narrow roads and look unsightly like other new developments. Building on fields causes risk of flooding, flood prevention measures don’t work! We can’t build our way out of this problem. I strongly object to this site. Maybe nil cost to council but huge cost to Diss.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20486

Received: 08/03/2020

Respondent: Mrs Valerie Keen

Representation Summary:

Diss is already overcrowded with houses causing an environmental, pollution and flooding on all roads where new houses are built. This was never a problem before. This will increase traffic and a strain on all council services eg. having collections fortnightly instead of weekly. Land fill is already heaving so by building it brings more people, rubbish,, cars into a market town. There is no consideration for this once beautiful area by building hoards of Lego type houses, allowing the builders to build rubbish properties then leaving the home owner and insurance to clean up their shoddy work.

Full text:

Diss is already overcrowded with houses causing an environmental, pollution and flooding on all roads where new houses are built. This was never a problem before. This will increase traffic and a strain on all council services eg. having collections fortnightly instead of weekly. Land fill is already heaving so by building it brings more people, rubbish,, cars into a market town. There is no consideration for this once beautiful area by building hoards of Lego type houses, allowing the builders to build rubbish properties then leaving the home owner and insurance to clean up their shoddy work.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20655

Received: 09/03/2020

Respondent: Mr Brian Falk

Representation Summary:

GNLP0342 and 0250
Specific provision should made at the outset to restrict the housing site area so as to identify, allocate and gift
adequate extra land for Diss cemetery and the link road, not leaving these needs contingent on planning
conditions.

Full text:

Please see attached

The GREATER NORWICH Regulation 18 Consultation 2020
PROPOSALS FOR DISS

Whatever the merits of the Greater Norwich Local Plan for Norwich there are few for Diss. The clue is in the name. It may stretch credulity to include Long Stratton in Greater Norwich, but the reasons for doing so cannot include Diss, and do not try. The local plan provisions for Diss are in no way recognisable as a creative and workable plan. They are a recipe for the decline of Diss’s role and regional centre as a historic market town. Consultation 18 divorces Diss from its essential support settlements and, despite the gnlp political introduction, there are no housing-matching specific plan proposals for new jobs, supporting infrastructure, schools, roads, health care, Proposals and consultation are limited to a bureaucratic scatter of housing sites without context, an exercise in allocating housing numbers simply to achieve a total, leading to added settlement girth within restricted boundaries, a kind of planning obesity, creeping encroachment on agricultural land and a lottery allocation of added wealth for selected peripheral land owners.

WHY DOES THE GNLP (particularly Regulation 18 proposals) FAIL TO LIVE UP TO THE TITLE OF A LOCAL PLAN?
It fails to link Diss to its surrounding support villages. It specifically severs proposals for those settlements from its proposals for Diss, which as a market town relies on its surrounding villages as they rely on Diss. No plan for Diss as a market town commercial and social centre can be relevant if it limits its consideration to its parish boundary and treats surrounding settlements in separate categories of ‘Service and ‘Other’. These settlements need planning as an essential element of a Greater Diss.

It fails to grant Diss the same growth zone considerations applied for Norwich. Diss may be far smaller than the County capital, but it has its own integral support and growth zone and no Local Plan should ignore that context. Diss parish of some 7,500 has a population hinterland of 50-70,000 dependant on the commercial or social attraction. A simple mid-distance hinterland virtually fills a ten mile circumference, a weighted gravitational assessment on population (2012) in competing centres reduces that hinterland to the north, west and south of Diss to five miles circumference. The audience support for Diss Corn Hall (2015) shows the ‘reach’ of Diss into the myriad of its surrounding Villages and Hundreds beyond the ten mile circumference. A local plan needs to take this hinterland into consideration and treat it as an integral element of Diss’ future.













Hinterland assessments
By travel, at settlement mid-points By population gravitational weighting By Corn Hall Audience 2015

It fails to acknowledge that Diss, the sole centre in the County other than Norwich, has a rail station providing a swift link direct to the heart of London’s financial centre. This already attracts significant commuter traffic. For 30 years this pattern of home/work commuting has greatly increased, will continue to be a potent urban generator, but has not been built into the parameters guiding the plan.

It claims to relate a confetti allocation of dwelling consents to primary school access, with a child’s pedestrian link to a primary schools set as the criterion for a new housing site. But it fails to assess the need and thus location for new Primary Schools. The plan accepts existing catchment areas and assumes the existing schools can accommodate all children from new housing. Or, indeed for any new social services. It is not a plan, it is a housing numbers game.
It mentions but fails to resolve the traffic difficulties of Park Road and Victoria Road Diss, ignoring the need and potential for a hinterland bypass link between the A143 and A1066. There are no proposals for infrastructure to support the allocated housing sites, nor analysis that road, water, drainage and communication capacity will be available.

It fails to provide any Action plan or proposals for Diss Town Centre. It has no proposals for the linkage of the Diss Park to the proposed Waveney riverine parkland. It fails to mention the town centre and the increasing number of empty commercial properties let alone attempting to adopt plan policies that will help the centre to survive.







Empty properties in the Diss Heritage Triangle and Market
Place. There are further significant vacancies down Mere Street


It still continues retail use amongst those approved for Sites DIS 6 & 7, (Committed Sites up to 2018) despite the rejection of retail warehousing use on appeal for Diss 7 and the accepted deleterious impacts retail development that it would have had have on existing traders and Diss’ historic town centre. The Development Management Committee in refusing consent may have hid behind the fact the site was on the periphery of a conservation area, but the inspector recognised the adverse economic impacts it would have had. This review of the plan should take the opportunity to change the approved uses for committed sites.
















It continues the cult of ‘borderism’ that has plagued all plans in the past, accepting that plan responsibility ceases at the County boundary and thus fails to acknowledge the Diss Town Council and Mid-Suffolk’s efforts to establish a Neighbourhood plan that includes those zones that form part of Diss’ hinterland south of the River Waveney. For planning purposes a ‘Greater Diss Growth Zone’ paralleling the Norwich approach should include the core parishes of the emerging Neighbourhood plan … Diss, Roydon, Burston & Shrimpling, Scole, Palgrave, Stutson and Brome and Oakley. This, at least, would provide some logical context for a comprehensive plan that includes housing as but one of its elements.








A POSSIBLE DIFFERENT APPROACH FOR THE DISS AND EYE SPATIAL REGION.



















These two diagrams compare the planning base for Greater Norwich as set out in the 2010 Key Diagram from the Joint Core Strategy with that for the south of the District and north Mid-Suffolk. That for Greater Norwich seeks to take into account a broad range of plan elements. That for the south of South Norfolk is a collection of parishes each treated separately and has no planning relevance whatsoever.















Rather than using this parish patchwork as a series of boxes within which to allocate peripheral housing additions to each settlement an extension of the JCS Strategy approach for the Norwich Growth Area would be to attempt a similar consideration of the needs of a planned axis between Diss and Eye. This would entail the establishment of a joint South Norfolk-Mid-Suffolk development and implementation unit, difficult but possible, and would provide for a matching basis of plan consideration across the county boundary. It would also permit a more imaginative and attractive solution to housing provision to include, perhaps, a new high-density yet garden village community.

COMMENTS ON REGULATION 18 ‘PROMOTED SITES’
Housing Sites:
GNLP0342 and 0250
Specific provision should made at the outset to restrict the housing site area so as to identify, allocate and gift adequate extra land for Diss cemetery and the link road, not leaving these needs contingent on planning conditions.
GNLP0102, 0185 and 1054
It is inappropriate to squeeze housing into the middle of an employment site and adjacent to a railway. The site should remain in employment use. Diss needs more land designated for employment use and a policy to generate new work opportunities.
GNLP0341 (Parish Fields)
A strictly limited number of dwellings might be permitted provided they were designed specially for the site and, as public benefit for the use of land designated as ‘Important Local Open Space to be retained’, the remainder of Parish Fields were deeded over to Diss Town Council and developed as a public park.
GNLP0599, 1044, 1003
None are currently designated for the next plan period, but should they be considered they need to be designed and built as part of a special Walcot Green village design with its own open surrounds, not treated as added Diss girth.

Site Commitments up to 2018
DIS 3
This critical, if small, site on the edge of the A1066 has high visual impact. It may look convenient on a map to complete zoned residential to a straight line, but this is desk-planning with little regard to the actual look and feel of the land. The site needs to revert back to open space so as to emphasise and not diminish the value of the landscape gap between Diss and Roydon and to avoid allotments butting up against housing. A planted woodland strip along the this edge of housing land would be beneficial to the look and character of the town.
DIS 6
Retail use should be deleted from the sui generis approved uses for this site and compulsory purchase made of the ‘ransom’ strip on the ‘Morrison’s internal roundabout so as to allow traffic to access DIS 6 (and the bus station) from the internal Morrison road approach. Provision should be made for a landscape walk connection from the bus station south to DIS 2, to include a walkway strip alongside the electricity sub-station.
DIS 2 & 7
Retail use should be deleted from the sui generis approved uses for DIS 7 and effort made to help relocate the feather factory and to create a landscape connection between the Diss Town Park and DIS 2.

SUMMARY
The GNLP may or may not deliver a sufficient supply of homes for the next plan period. But it fails to do more than generally acknowledge primary criteria under the JCS for future economic, social or environmental objectives and their impacts on Diss and its surrounds. It fails to identify how the proposed number and location of new homes will relate to the Diss of the future. There are no plan specifics to ensure the vitality of the town centre, nor any consideration of how such housing will promote a healthy and safe community. No proposals deal with the need and provision of sustainable transport or high quality communication. There is no recognition of the importance of the rail link, or proposals for better linkage between station and town. The housing provision, site by site, may have associated provisions affecting their layout (no mention is made of design quality) but these remain subsidiary and ancillary to each housing designation, rather than satisfying broader policies. The Local Plan Consultation 18 restricts itself to sites for new housing, lacks a full and realistic context, is devoid of policies to ensure well-designed places or conservation of natural and historic assets and environment and without these fails to meet the requirements set out in the National Planning Policy Framework.

Attachments:

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20763

Received: 12/03/2020

Respondent: Dr G M Courtier

Representation Summary:

Housing development on this site is unsustainable and would be suicidal for the town. This has already inflated to capacity with recent commitments for residential development. The town is finite, having evolved over centuries with a constrictive road structure.

There is no capacity for road widening, extra health provision and schools for the implied 10% increase in population on these sites. Commitments for development have recently already saturated Diss without increasing facilities. More sites are already committed for over 300 homes, and the town is effectively an island with no justification for increasing numbers up to 2038 to over 700.

Full text:

Housing development on this site is unsustainable and would be suicidal for the town. This has already inflated to capacity with recent commitments for residential development. The town is finite, having evolved over centuries with a constrictive road structure.

There is no capacity for road widening, extra health provision and schools for the implied 10% increase in population on these sites. Commitments for development have recently already saturated Diss without increasing facilities. More sites are already committed for over 300 homes, and the town is effectively an island with no justification for increasing numbers up to 2038 to over 700.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20809

Received: 12/03/2020

Respondent: Mrs Jane Hutton

Representation Summary:

I object for the following reasons:
TRAFFIC ISSUES:
Commuter times are particularly busy as workers avoid the frequently congested A1066 in order to reach the A140. Also congestion caused by cars dropping off and picking up pupils from Diss High School. A sharp bend on the Heywood Road/Burston Road junction has been an accident spot over the years.
WILDLIFE:
The Heywood Road cemetery is a haven for wildlife.
COMMUNITY AMENITY:
The footpaths on this field are extremely well used by local dog owners and Individuals and local walking groups.
CEMETERY EXPANSION:
Allow expansion for 50 years, not the short term.

Full text:

I wish to object to the proposed housing development on Heywood Road Diss.

As a long-term resident I have been able to see the increase in traffic on
this road. Commuter times are particularly busy as workers avoid the
frequently congested A1066 in order to reach the A140. The other very busy
period is School arriving/leaving as we are very close to the Diss High
School. Parents drop off their children to walk in the morning and park and
wait for them in the afternoon. The road has a sharp blind bend at the
junction with Burston Road and over the years there have been several
accidents, especially in the dark.

I am also very concerned about the impact on wildlife. This proposed
development lies right next to our lovely Victorian cemetery, which is a
haven for wildlife, and is supported by Norfolk Wildlife Trust. The mature
trees on the old cemetery are home to many birds, including owls who I hear
every night. Also deer and other small mammals find this a safe place.

The footpaths on this field are extremely well used by local dog owners and
individuals and local walking groups. Therefore it is an area essential for
the Community physical and mental health

As an ageing population we must also allow the Cemetery to expand, not just
thinking about the short term, but allowing space for the next 50 years.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20982

Received: 14/03/2020

Respondent: Mr John Hutton

Representation Summary:

TRAFFIC:
Heywood Road leads to Mount Street & Sunnyside which are too narrow for 2-way traffic, Traffic stops and waits for oncoming traffic to complete 100 & 200 yards stretch. Walcot Road is narrow and busy during entrance and exit to Diss High School.
Also proposed link road from Shelfanger Road to Heywood Road would also increase traffic down Heywood Road and further exacerbate these problems.
NEGATIVE VISUAL IMPACT/BEING OUT OF CHARACTER :
Heywood Road properties are all individual.
HIGHWAY SAFETY: Danger for Diss High School pupils crossing Heywood Road
Too much traffic travelling through Diss to access the A140/A1066/A143

Full text:

As a resident of Heywood Road since 1982, please give due consideration to my comments as they are supported by my local knowledge and experience for the last 38 years.
I object to the proposed developments, for the following reasons:

TRAFFIC:

The route from Heywood Road to Diss Centre leads to Mount Street which is too narrow to accommodate 2-way traffic, so even now, traffic comes to a halt and has to wait for oncoming traffic to complete a 100 yards stretch of road, so it is effectively single file roadway. The proposed development would exacerbate this existing problem, if traffic increased on Heywood Road. At the same junction Heywood Road leads to Sunnyside which is also single file traffic for 200 yards. The 3rd road on the same junction is Walcot Road which is narrow and very busy during entrance and exit times to Diss High School.
Also the proposed link road from Shelfanger Road to Heywood Road would also increase traffic down Heywood Road and further exacerbate the problem outlined above. In summary any increase of traffic in Heywood Road going south in the direction of Diss centre, would make existing problems far worse, and gridlock situations would become even more commonplace. (On occasions, I have literally had to get out of my car to guide other motorists, until a road jam has been unlocked,).

As a constructive comment, I suggest that the GNLP0119 and GNLP0291 development might possibly be viable in purely traffic terms, if the access point for traffic from the development was in Shelfanger Road alone, as this road does not suffer from the same levels of congestion as the Heywood Road route into town. In this scenario GNLP0250 could be allocated to Cemetery expansion, which will be needed given the demographics of an ageing population.

POSSIBILITY OF NEGATIVE VISUAL IMPACT/BEING OUT OF CHARACTER WITH EXISTING PROPERTIES:

The existing properties in Heywood Road are all different in styles and ages. Any development facing Heywood Road would need to take this into account, and present a design and quality of housing that is compatible with the existing properties.

CONSIDERATION OF THE BIGGER PICTURE - HOW DISS WILL EXPAND:

Diss is in need of a bypass, which is supported by the fact that the A1066 as it passes through Diss has increasingly witnessed traffic coming to a standstill. Traffic destined for Thetford uses the A1066 through Diss, as there is no link road from the excellent A143 route to provide access to Thetford. Consideration should be given to where a bypass may be built, as if it uses the A143 route and a new link road to the A1066, there would be no point in further developing land to the North of Diss, and increasing the traffic going through Diss to get to the A143 and A1066.

HIGHWAY SAFETY:

A large volume of Diss High School children cross the road as they come in and out of Walcot Road.
This already is potentially dangerous for the children and causes a problem for the motorists travelling from all 4 directions of the staggered Walcot Road/Sunnyside junction. Again, any increase in the traffic using Heywood Road would increase the existing safety risks.

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 21026

Received: 15/03/2020

Respondent: Ms Aileen Bradley

Representation Summary:

We ask that any development in this part of town, is built with a little more empathy to the surroundings than the current development being built on the eastern side of town. We also ask that the services available in the town, especially medical and educational, are reviewed and resourced before commencing with the GNLP proposed house construction, that could give rise to a 20% population growth in the town.

Full text:

We moved to Diss in 2018 having lived in many parts of England, as well as internationally. We had no previous link to, or even knowledge of, the town but when we visited on a relocation trip, we liked its’ feel and character, and liked that it seemed to have an active community.

We are disappointed to hear that that character may be significantly challenged by the construction of 200 homes off the street, (Heywood Road) that is an extension of Mount Street and the most historical part of town. We understand, however, that the region needs more housing and houses have to be built somewhere.

We would ask that any development in this part of town, is built with a little more empathy to the surroundings than the current development being built on the eastern side of town. We also ask that the services available in the town, especially medical and educational, are reviewed and resourced before commencing with the GNLP proposed house construction, that could give rise to a 20% population growth in the town.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 21138

Received: 15/03/2020

Respondent: Mrs Suzanne WALL

Representation Summary:

Unsuitable site for development of this size. Heywood Road leading to town centre is not suitable for the increased traffic a large development and connecting road from Shelfanger Rd would generate. Combine this with the already dangerous bends on Shelfanger Road and on Heywood Road to the very busy junction with Walcot Rd (with High School)/ Shelfanger Rd/Mount St (single track) and combine this with children crossing/cars for schools this is not a viable option. The varied wildlife in this area would suffer as would peace/calm of the cemetery. Unclear on plans where necessary cemetery extension would be

Full text:

Unsuitable site for development of this size. Heywood Road leading to town centre is not suitable for the increased traffic a large development and connecting road from Shelfanger Rd would generate. Combine this with the already dangerous bends on Shelfanger Road and on Heywood Road to the very busy junction with Walcot Rd (with High School)/ Shelfanger Rd/Mount St (single track) and combine this with children crossing/cars for schools this is not a viable option. The varied wildlife in this area would suffer as would peace/calm of the cemetery. Unclear on plans where necessary cemetery extension would be

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 21147

Received: 15/03/2020

Respondent: Mr NICHOLAS WALL

Representation Summary:

my objection to housing relates to issues relating to the way it will change people, nature and our everyday lives as a retired person I enjoy walking within this area and as Diss has very few walking trails this is one area that we must preserve. Many animals live within this area and Dog walkers will have limited space, and the pressures on Roads and higher emmisions / climate change / greenhouse gases will be increased as well as further pressure on the overstretched Doctors Surgery and other areas of infrastruture.

Full text:

my objection to housing relates to issues relating to the way it will change people, nature and our everyday lives as a retired person I enjoy walking within this area and as Diss has very few walking trails this is one area that we must preserve. Many animals live within this area and Dog walkers will have limited space, and the pressures on Roads and higher emmisions / climate change / greenhouse gases will be increased as well as further pressure on the overstretched Doctors Surgery and other areas of infrastruture.

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 21588

Received: 16/03/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Unlike other allocation policies there is no reference to water efficiency forming part of the design of this student accommodation.

Please also see comments relating to Policy 2 of the Sustainable Communities of the Strategy document.

Full text:

Unlike other allocation policies there is no reference to water efficiency forming part of the design of this student accommodation.

Please also see comments relating to Policy 2 of the Sustainable Communities of the Strategy document.

Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22143

Received: 15/03/2020

Respondent: Mr Jacob Ecclestone

Number of people: 2

Representation Summary:

We agree with the proposals to build 200 homes on sites numbered 0250, 0342, 0119 and 0291 – the land between Heywood Road and Shelfanger Road. Building houses on these four sites seems to us to be entirely reasonable, although it will mean that the northern boundary of the town is extended into open countryside. That, in turn, will have a negative effect on the landscape.

Full text:

Please see attached for full submission

Attachments:

Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22796

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation Summary:

Our client’s site, Land west of Shelfanger Road and East of Heywood Road, Diss has been included within the Draft GNLP Sites document as a preferred option under site references GNLP0291 and GNLP0342 as part of a larger allocation forming Policy GNLP0250/0342/0119/0291 for ‘at least 200 homes, 33% of which will be affordable’ to the north of Diss. Since being submitted to the Call for Sites as only GNLP0342, my client has agreed heads of terms on the site known as West of Shelfanger Road under site reference GNLP0291. They are also actively engaging in discussions with the Landowner for the site known as GNLP0250 and it is their intention to bring forward the three sites as a whole with a joint masterplan.

Full text:

For full representation, please refer to the attached documents.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22797

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation Summary:

my client recommends that site reference GNLP0119 is excluded from the policy and is not put forward as an allocation or part of the wider site. The site has recently changed ownership and would not form a viable portion to bring forward with the wider site given its existing residential use and value. In addition to this, it is not possible to achieve sufficient visibility splays to achieve a separate vehicular access, which further impacts its viability to be brought forward.

Full text:

For full representation, please refer to the attached documents.

Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22798

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation Summary:

We support the requirement for a Masterplan to be provided for the site, showing a co-ordinated approach across the three sites. There is a definite need to ensure that the site comes forward in a deliverable way and that public benefits are realised. Scott Properties are actively engaging with the Landowners of GNLP0250 and have already agreed terms with GNLP0291.

Full text:

For full representation, please refer to the attached documents.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22799

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation Summary:

The Policy requires for ‘at nil cost to the Town Council, safeguard land for an extension to the cemetery’. Obviously there is a value to land for burials and the inclusion of land for this type of community use will need to be off set against the provision of land for other community benefits, such as open space for sport and recreation. The exact location and extent of the cemetery extension will need to be agreed through the development of the Masterplan, but it is understood that there is a preference from the Town Council for this to be located on the east of the Site, to enable a new access from Heywood Road. In terms of current capacity, it has been confirmed that there are currently c. 1,800 plots available, equating to 40 years’ supply at the current rate of 45 burials per year. In February the Town Council resolved “To request that the extension of the Cemetery allows for an additional 60 years of burials/ashes at the current rate of burial”. This would provide a total of 100 years of land supply for the cemetery. We would suggest that the following work should be undertaken by the Town Council to substantiate and justify this request.
a. A Cemetery Risk Assessment – to ensure that the site is suitable in terms of the groundwater conditions.
b. A detailed Population Projection – to compare future death rates with population growth and religious groups.
c. A detailed assessment of future burial practice with reference to the move to a greater number of woodland/natural burials.

In any case, provision of an area of c. 3.4 acres (at 800 burial plots per acre) at nil cost to the Town Council could impact on the viability of the site and the ability of the site to deliver at least 200 dwellings as per the allocation wording. My client would question the extent to which projected future burial needs well into the next century and beyond the Local Plan period should be prioritised over the need to deliver housing to meet the identified needs during the Local Plan period. The Masterplan proposes an area of 1.2 acres which would provide an additional c. 20 years supply (as per the Local Plan period), and we would welcome further discussions with the Town Council and GNLP Team on this subject.

Full text:

For full representation, please refer to the attached documents.

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22800

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation Summary:

A Technical Note has been prepared by Atkins and provides transport and highways information to support this representation, including details on the site schematic plan on the associated road and pedestrian connections as well as the plans to retain and enhance the existing Public Rights of Way (PROW) to the north and west of the site. In conjunction with this Technical Note, a ‘proposed general arrangement and access plan’ and ‘swept-path analysis of proposed highway access’ have also been provided. A Transport Assessment will be prepared to follow on from this note and form part of the planning application at the site. The aim of providing a vehicular connection between Shelfanger Road and Heywood Road is supported, as it will improve connectivity to the north of the Diss and provide a degree of relief to Sunnyside from vehicle users who would otherwise need to take this route.

In addition, a Flood Risk Technical Note has been prepared by Atkins and accompanies this Representation. The Note identifies that the site is located within Flood Zone 1 and as such, flood risk at the site is considered to be low to negligible. However, it is noted that once the proposed development introduces new paved areas, the surface run off will increase and require management. Recommendations have been provided within the Technical Note which will inform future Flood Risk Assessments and Surface Water Drainage Strategies at the site forming part of any planning application.

A Tree Survey has been prepared by Geosphere Environmental and includes a Tree Constraints Plan at Appendix 2. This identifies Category A, B and C trees and root protection areas that will be considered throughout the development and detailed design of any proposed development. In addition to this, a Landscape Constraints and Opportunities Appraisal Plan has been prepared by Lockhart Garratt and provides an indicative landscape plan, outlining the location of retained PROW’s, developable areas within the wider allocation and potential access points.

A Constraints Plan has also been included as part of this representation, showing the location of the high pressure pipeline as referred to within the policy, located adjacent to the northern boundary of the site, and applicable the 14.3m Building Proximity Distance (confirmed by Cadent) where no buildings may be constructed. The Constraints Plan pulls together combined information from the above reports as well as showing the location of the excluded land within GNLP0291 and a water main which runs through the site (which it is proposed would be diverted).

A Concept Masterplan has been provided which shows a net developable area of 6.13ha. As proposed, it would be possible to achieve the target dwelling yield of 200 no. dwellings by applying a net density of 32.6 dph. This is considered achievable and feedback will be sought from Officers at South Norfolk District Council on this subject through the pre-application process.

Full text:

For full representation, please refer to the attached documents.

Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22801

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Representation Summary:

The site can be brought forward through the submission of a joint Masterplan which could accompany an outline application. Initial discussions have taken place with private house builders who have expressed an interest in purchasing the site on either an unconditional (post planning) or subject to planning basis. An updated planning and delivery strategy will be agreed following pre-application advice and public consultation.

Scott Properties are confident that a respective development partner for the site will be identified to bring forward reserved matters applications within two years or less of outline consent being obtained. A significant amount of technical work has already been undertaken which has confirmed there are no overriding physical constraints to development of the site. Scott Properties intend to submit a pre-application advice request in May 2020. The proposals will be amended as required by the pre-application advice and then taken forward for wider public and community consultation. This will centre around a public consultation event planned for Autumn 2020 followed by an online and postal feedback exercise.

Assuming that a planning application is submitted following the Regulation 19 consultation in 2021, it is reasonable to expect that planning permission could be forthcoming before the end of 2021 allowing contractual arrangements to be completed with development partners before the end of the year (if not already concluded). Respective reserve matters applications could then be prepared and submitted in the early part of 2022 meaning that development on site could commence in 2022 via either route. Based on this assessment, it is anticipated that the first houses could be available for occupation in 2024. Assuming completions of 50 family houses per year, as set out in the table below the site could be completed in 2027.

While the site is in multiple ownerships, Scott Properties is working closely with the owners of all three parcels so that the site can be bought forward as one. As such, development of the site is achievable. It is available now and would represent a realistic and deliverable development in the current market conditions. We further support the inclusion of the site within the Local Plan as it is located adjacent to the settlement boundary and as such would represent a logical expansion to the town. Our professional judgement is that this site could come forward with a viable residential housing scheme that is policy compliant.

As outlined within the National Planning Policy Framework 2019, to be considered ‘deliverable’, sites for housing should be ‘available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years.’ In summary, we consider that there is suitable for residential development, available within the next 5 years and achievable.

Full text:

For full representation, please refer to the attached documents.

Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22813

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

Representation Summary:

our client owns the site identified as GNLP0250, which forms part of the preferred allocation identified as policy GNLP0250/0342/0119/0291. Our client supports this allocation and has the following comments to make:

Our client supports the identification of this site for 'at least' 200 homes and is pleased to see this identified as a minimum requirement. Subsequent design work – informed by a masterplan – will confirm the maximum yield across this allocation.

Our client supports the provision of a masterplan across all of the sites within this allocation to ensure an appropriate form of development is delivered. The masterplan process should be a prerequisite for any planning application that comes forward on any part of the allocation site.

The provision of a road through the allocation that links Shelfanger Road with Heywood Road continues to be supported by our client, who will work with the adjoining landowners/developers to deliver such a link.

Our client supports the intention to protect existing Public Rights of Way and provide linkages into these. However, the wording of the policy should allow for the route of the PROW to be determined through the masterplan process so that variations of the existing route can be justified through sound urban design considerations. It should instead refer to the need to maintain a Public Right of Way either along the existing route or close by to reflect the outcome of the masterplan process for this site. This would include the provision of new linkages to this route to ensure appropriate pedestrian permeability through the site.

Full text:

For full representation, please refer to the attached document.

Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22814

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

Representation Summary:

The requirement for 33% affordable housing is not supported by appropriate evidence – for further information, please refer to the response provided to question 27 of the Strategy Document.

Full text:

For full representation, please refer to the attached document.

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22815

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

Representation Summary:

The provision of land to extend the cemetery is not objected to but it is important that this policy requirement is supported by evidence to justify the scale of the requirement. Our client is happy to work with the adjoining landowners to confirm the appropriate location of that extension and notes the potential for this to be delivered on more than one site within the allocation. Our client would support the exact location of this provision to be clarified through the masterplan process.

Our client supports the intention to protect and enhance existing trees and hedgerows around the site but considers that the policy should reflect that the extent of protection will be determined by the masterplan process rather than a blanket protection as is currently worded. The current wording – taken to extreme – would prevent the delivery of road and pedestrian links through the various parcels within the allocation, which is clearly not the intention of this policy.

Full text:

For full representation, please refer to the attached document.

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22816

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

Representation Summary:

Our client is aware that the promoters for the adjoining site have undertaken detailed assessment of highway, arboricultural, ecology, landscape & visual impact and drainage considerations across the entire allocation and understand that this will be included in their representations. Our client understands that this work has not revealed any overriding constraints to the delivery of the application.

Our client is continuing in active discussions with the promoters of the adjoining parcels of this allocation in order to provide further evidence of deliverability of this site. This includes an intention to progress the masterplan discussions as part of the pre-application process. This will be provided during the plan-making process and ahead of the Regulation 19 version of the GNLP. Our client is committed to working constructively with the GNLP team to assist in this regard.

Full text:

For full representation, please refer to the attached document.

Support

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22822

Received: 15/03/2020

Respondent: Diss Town Council

Representation Summary:

We agree with the GNLP conclusion that this is a preferred allocation. The Neighbourhood Plan steering group had already reached the same conclusion that the site was well related to the existing built up area of Diss and would enable the provision of a link road between Heywood Road and Shelfanger Road. This will help alleviate east/west traffic pressure in the north of the town especially on roads such as Sunnyside. It would also afford us the opportunity to extend the cemetery which we requested in our earlier consultation.

Full text:

As you requested at our consultation meeting on 11 March 2020, I have commented on the other sites we did not discuss in detail on the day.

Policy GNLP0250/0342/0119/0291 land north of the cemetery, west of Shelfanger Road and east of Heywood Road. 8.91 ha which will accommodate at least 200 homes.
We agree with the GNLP conclusion that this is a preferred allocation. The Neighbourhood Plan steering group had already reached the same conclusion that the site was well related to the existing built up area of Diss and would enable the provision of a link road between Heywood Road and Shelfanger Road. This will help alleviate east/west traffic pressure in the north of the town especially on roads such as Sunnyside. It would also afford us the opportunity to extend the cemetery which we requested in our earlier consultation.

Policy DIS1 (GNLP0185) Land north of Vince’s Road 1.18 ha and to the south of Prince William Way. This would accommodate approximately 35 homes.
This allocation to be carried forward to the new plan from the local plan in 2015.
This is subject to an acceptable design and layout being achieved including delivering an access to site from Frenze Hall Lane.

Policy DIS2
This allocation is carried forward from the local plan from 2015.
A small number of homes (approx.10) will be built to enable the rest of the site to deliver open space, natural green space and a riverside walk. It will also allow the Neighbourhood plan group to deliver better walking and cycling connectivity between Diss and Palgrave.
Note 1** Combined Policies DIS2, DIS7 and part of DIS6 are currently being assessed by both Norfolk County Council and South Norfolk Council as a possible site for a business hub including a new Leisure Centre plus other mixed use. They are due to report back on the feasibility of this option later this month.
Note 2** We have been given a commitment for a new Leisure Centre in Diss by South Norfolk Council and this is one of three sites being considered as a location.
Note 3** The site of the existing leisure centre 0.32 ha will become available and could be used for housing or possibly apartments
Note 4** Policy DIS7 if not used for a leisure centre should be considered for mixed use including housing.

Policy DIS3 Land off Denmark Lane, Roydon, Diss. 1.6ha allocated for residential development for approximately 42 homes.
This is an existing allocation in the local plan from 2015 and will be carried over into the new plan.
A figure of less than 42 may be more appropriate as there is a requirement for a 10m landscape belt on the western boundary which may limit capacity.


Policy DIS8 Land at Station Road/Nelson Road. 2.89 ha is allocated as employment land.
This is an existing allocation in the local plan from 2015.
The part of the site which was an old coal yard has already been developed as a car park for railway users.
Diss Town Council had pre-planning discussions at the end of last year with a developer wishing to build ‘Extra Care Retirement Homes’ on the remainder of the site. We were supportive of the scheme that was put forward at this meeting.
Since our meeting on 11 March 2020 we have received a planning application 2020/0478 from the developer for an Extra Care building containing 77 apartments (68 x 2-bed and 9 x 1- bed).
This will meet the employment use criteria and as the apartments allow full independent living accommodation should be included as part of the numbers required in the new local plan.

Policy DIS9. Land at Sandy Lane (north of Diss Business Park) 4.22 ha allocated for employment uses - Classes B2 and B8
This is an existing allocation in the local plan from 2015 and will be carried forward into the new plan.

GNLP1045 Land west of Nelson Road and East of Station Road 0.94 ha.
This site is currently allocated for employment as part of DIS8 although the promoter is now suggesting the site for residential use.
As the site is adjacent to the Ensign way estate the proposal could be supported providing the density of development is no more than that on the adjacent estate I.e. 25 to 30 per ha.

GNLP0362 Land at Sturgeons Farm, off Farm Close, Louise Lane. 13.81 ha for residential use approximately 413 dwellings.
We agree with your assessment of unsuitable as any development would extend Diss further into the open countryside and be too far away from the main services.

GNLP0599 Land off Walcot Road/Walcot Green, Diss. 3.29 residential.
We are in full agreement with both the GNLP and AECOM that highway constraints make this site is unsuitable. It is very rural and remote from the existing services and would have a visual impact on the adjacent nursing home. There is restricted visibility with 2 bends on the very narrow road and no pavements. It is unlikely that satisfactory road re-alignment, widening and the provision of pavements could be achieved.
However, we currently have a speculative outline planning application 2019/1555 for this site for 94 dwellings which we are opposing.

GNLP0606 Boundary Farm, Shelfanger Road. 3.00 ha residential.
This site is unsuitable as a large proportion of the site is at risk of flooding.
Development of this site would extend the built-up area of Diss into the open countryside. There is no safe walking route to schools in Diss.

GNLP1003 The Grange, Walcot Green, Diss. 2.02 ha residential.
This site is outside the settlement boundary. It is located in a bend in the road with no safe walking access. We agree with both AECOM and the GNLP that the significant highway constraints make this site unsuitable for development.

GNLP1038 Land North of Brewers Green Lane, Roydon. 1.06 ha for residential development 8-12 dwellings.
Development on this site would close the settlement gap between Diss and Roydon. Roads around this site are all very narrow and there are no safe walking routes to schools in Roydon and Diss. This site is unsuitable for development.

GNLP1044 Land north of Frenze Hall Lane and West of Walcot Green, Diss. 10.95 ha for an unspecified number of residential dwellings.
Site is adjacent to railway line with a narrow road Walcot Green which can’t be widened due to highway constraints including a gas main. Residential development would also extend the built-up area of Diss further into open countryside.
We agree with the GNLP and AECOM assessment that it is unsuitable for allocation.

GNLP2104 West of Shelfanger Road (part in Roydon and part in Heywood) 50.51 ha for an unspecified number of residential dwellings.
This very large site would alter the character of the settlements of Diss and Roydon. It is too large a scale for the development required in Diss. The road network is unsuitable both in terms of junction capacity and also lack of footpaths.

GNLP2067 Victoria Road, Diss. 0.42ha for repair and retail warehouse, business and office
This site is subject to flood risk constraints and there is sufficient employment land at present.