GNLP0312

Own home proximity to site. Our home looks directly over the proposed site and would ruin scenic views from our property. Build site would have noise and traffic pollution directly affecting our property on a constant basis. Large influx of vehicles passing our house. Any entrance would potentially mean light pollution from headlights shining onto our house on a daily basis. Current George Lane site stagnant in build and is a 7 year project alone. This amount of disruption would utterly ruin our home and reasons we chose to buy. Already suffered with expansion of local businesses adjacent to us.

The present industrial site has very limited scope for expansion and this site adjacent to it forms a natural progression. Loddon needs to expand its employment opportunities to accommodate its increase in population/housing. The use of this site for industry would keep all the employment at one end of the village and would give easy access onto the A146. There is land at the back of this site which could be used for housing which is far more suitable and would form a more natural progression of the built area.

Own home proximity to site. Our home looks directly over the proposed site and would ruin scenic views from our property. Build site would have noise and traffic pollution directly affecting our property on a constant basis. Large influx of vehicles passing our house. Any entrance would potentially mean light pollution from headlights shining onto our house on a daily basis. Current George Lane site stagnant in build and is a 7 year project alone. This amount of disruption would utterly ruin our home and reasons we chose to buy. Already suffered with expansion of local businesses adjacent to us.

Environmental impact assessment on surface water run-off needs to be thorough, there will be increased risk of flooding to lower-lying commercial and domestic properties. 180 dwellings equals 180-360 vehicles and 180-720 people; risk assessment on increased traffic turning right onto A146; traffic management plan for journeys through the town and on surrounding roads; cycle path; narrowness and lack of pavements will all need consideration. Have you risk assessed journeys from the site? Effect of increase in demand locally and upon surrounding areas on schools, medical provision and emergency services needs assessment. Can the town accommodate a potential 25% population increase?

I think this site is great in terms of its location and transport links when you consider what it can offer Loddon & Chedgrave. The front of the site adjacent to Beccles Road would lend itself well to commercial/light industrial (more job opportunities) meanwhile the North-Eastern part would be suitable for more high quality housing. Improvements in services should also track new housing provision - for example: if a new dentist were to want to setup in Loddon, where would they go? The only dentists currently in Loddon is adjacent the new George Lane development and is already full.

Loddon Parish Council would like to make the following representations to draft Policy GNLP0312: Land East of Beccles Road.
Loddon Parish recognise and welcome the early engagement undertaken by Hopkins Homes. It is requested that this engagement continues in a proactive and meaningful manner with Loddon Parish Council and the community at key stages of the sites’ promotion, pre-application scheme development, proposed application scheme and during the consideration of any associated planning application.


POLICY GNLP0312 Land to the east of Beccles Road Loddon (approx. 7.70 ha) is allocated for residential development. This site is likely to accommodate at least 180 homes, 33% of which will be affordable.
More homes may be accommodated, subject to an acceptable density, design, layout and onsite open space and soft landscaping being achieved and any onsite and offsite infrastructure issues addressed.
The development will be expected to address the following specific matters:
• Two points of vehicular access to be provided into the site.
• Areas of surface water flooding on the Beccles Road boundary to be addressed:
• Design and layout must address the topography of the site and potential impact on views.
• The trees/hedgerows surrounding the site will be protected, enhanced and incorporated into the scheme.
• The design and layout of the scheme must consider amenity impacts relating to the nearby business area.
• Provision of controlled pedestrian crossing point(s) on Beccles Road
• Highway capacity and safety improvement(s) to the A146/ Beccles Road junction.
• Off-site financial contribution(s), secured by Section 106 Agreement, towards new or improving existing community facilities within Loddon. Such facilities to be identified through discussions and agreement with Loddon Parish Council.

"At least 180' houses, on this Greenfield site, with 2 exits on to Beccles Road will dramatically increase the traffic to the A146 with the outflow from the 82 units from the Express Plastics site also onto the Beccles Road. This will result into a similar existing problem from the George Lane development leading onto the A146.
Large developments in places the size of Loddon suit the economic benefits to the developers at the expense of the local community.

The subject site is proposed in the latest version of the emerging GNLP as an allocation. Hopkins Homes endorse this approach and fully support the allocation of the site in the local plan in due course.

Further work has been undertaken by Hopkins Homes in respect of access to the site and as such, a single access plus emergency access solution is considered appropriate. Hopkins Homes, therefore, respectfully, propose an amendment to the wording of the policy to allow flexibility at the planning application stage in respect of the final access solution.

We object to the inclusion of this site as a proposed residential allocation. Please see submitted file for comments.

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

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

For full representation, please refer to attached documents

Greater Norwich Local Plan (“GNLP”): Future Housing Development in Loddon and Chedgrave
Following earlier correspondence, we are writing to make formal representations on the GNLP and in particular to object to the proposed allocation in Loddon, reference GNLP 0312, in its current form. We object to the allocation of 180 homes. We further object the annotation of “at least” 180 homes and request that wording be removed.
We are not opposed in principle to appropriate part development of the site, with the shortfall made up by one or more additional allocations elsewhere in Loddon and Chedgrave.
Site GNLP 0312 abuts our property, and a number of others. Although the southern part of the site looks suitable for development when viewed from Beccles Road, the ground rises substantially towards the north, reaching some 50ft above the level of Norton Road/Beccles Road junction to the West. Estate scale development on this sloping and high ground would have a dominating effect on the adjoining residential properties and create serious problems of overlooking and loss of amenity. Development on the high ground will also be prominently visible over a very large area. Large estate scale development will by its nature adversely affect the character of the existing properties in Norton Road which consists of long established non-estate development with a variety of plot sizes.
In previous planning rounds when the owner has promoted site 0312, the South Norfolk Council have recognised these facts and argued that any estate scale development should be restricted to the less controversial lower land adjoining Beccles Road to the South.
The GNLP now proposes departing from that position and allocating “at least” 180 dwellings. The supporting documentation simply speaks of the design and layout “addressing the issue of topography” and impact on residential amenity is not even mentioned. This vague statement offers no evidence as to how the impacts will be mitigated.
Reliance on site 0312 to provide for future housing growth is in conflict with the transport and climate change policies in GNLP. The site is inconveniently distant from both the town centre and the bus route serving Norwich, Beccles and Lowestoft. Residents will therefore be motivated to use the car both for shopping in the town and for commuting by car. Other viable locations (see below) on the bus route and/or nearer shops are available and should therefore be more actively considered.
Finally, Loddon and Chedgrave share four junctions onto the very heavily trafficked A146, and there are widespread public concerns about safety and accessibility. Concentrating 90% of future housing growth at site 0312 will place almost all the load onto the single A146-Beccles Road junction.
We have no objection to the principle of allocating 200 additional homes at suitable locations in Loddon and Chedgrave. We believe, however, that there are sound and viable alternative sites which could contribute to the total need alongside a reduced allocation on site 0312.
We submit that promising alternative sites have not been evaluated sufficiently and in some cases have not been evaluated at all. In this connection we have criticisms of both the process adopted to identify sites and the conclusion that there are no reasonable sites aside from those allocated.
Process
1. South Norfolk’s statutory Statement of Community Involvement undertakes that “we will…publish articles in the Council’s Link magazine/ Parish Magazines (as appropriate)”. This inexpensive, simple and very effective step was not taken at any point during the GNLP process. The Link and the local Parish magazine “Contact” are both circulated to every household and would have greatly increased responses from local landowners and the public. It is evident from the patchy local response following the press and website call for sites that opportunities for inclusion in the evaluation of sites are likely to have been missed.

2. The GNLP process to date has strictly limited itself to those sites in Loddon and Chedgrave which landowners or developers have put forward in response to the call for sites. This approach does not comply with the Government Guidance on Housing and Economic land Availability Assessment which specifies the need “to identify all sites…” (Para 3-8) using a “proactive” approach (3-10) and requiring “that plan-makers do not simply rely on sites that they have been informed about, but actively identify sites through the desktop review process”. Para 3-11 lists potential data sources for this proactive process including the very obvious and standard process of studying OS maps and aerial photography.

As indicated below, the above shortcomings have contributed to a failure to identify or correctly define sites with obvious development potential in Loddon and Chedgrave at the HELAA stage or subsequently. We are pleased to note that the GNLP process remains open to new sites.

No alternative “reasonable sites” (see plans attached)

Site 0372 – High Bungay Road, Loddon
This was proposed in the call for sites as suitable for 130 dwellings.
Although acknowledged as “well located” it was deemed an Unreasonable Alternative solely owing to “concerns about vehicular access”. In a very recent email dated 10th March 2020, South Norfolk Council have acknowledged the recent Highway Authority view that a smaller development can overcome this objection, and that you will be notified of this. The email goes on to refer to “fundamental landscape harm” as justifying exclusion of this location. We draw your attention to a communication from Case Officer Christopher Watts dated on 20th November 2019 to developers Larkfleet Homes stating “we would be happy to explore…a revised scheme…subject to the net site area being no more than 1 hectare.” We readily agree that landscape constraints limit the scope here to around 1 ha but it is self-evident from site inspection that such a development adjoining High Bungay Road would be wholly acceptable on landscape terms. We request that this part of site 0372 is objectively and fully re-evaluated in GNLP on that basis and in the light of Mr Watts’ invitation to the developers.
This site is on the bus route. It will also help place some of the local traffic load onto a different junction with the A146.
Site 0313 – High Street, Loddon
The “call for sites” response here proposed 68 dwellings. The site is in the Conservation Area and lies behind the Fire Station site on the High Street. The site has been treated as unreasonable, with lack of a suitable vehicular access cited in GNLP as the “crucial” issue for this. In spite of representations we made in 2018, it does not appear that any appraisal has been made of the scope to overcome this crucial constraint by providing a joint access with the adjoining Fire Station. In their 10th March email South Norfolk Council imply that adopting this approach would require the necessary land to be “promoted”. The Fire Station is owned by the County Council and we respectfully draw your attention to the HELAA guidance which specifies that site identification and evaluation should include assessment of local authority owned land. It does not require a developer or other third party to promote it.
We agree that Conservation Area, landscape and other constraints (amber in the HELAA) would require very careful mitigation and would certainly limit the acceptable scope of development to well below the 68 homes proposed. We are however of the view that a sensitive and well-designed smaller scale development can be achieved within these constraints while offering the prospect of enhancing the Conservation Area and lessening the adverse visual impact of the Fire Station site.
This site clearly fulfils transport and climate change policy since it both provides convenient pedestrian access to town centre services and the bus route.
We therefore request that the GNLP process re-examines the scope here and engages the County Council and the Fire Authority constructively about the options for securing either a site reconfiguration or, more ambitiously, relocation and redevelopment of the unsightly Fire Station site to a site near the George Lane-A146 junction which is owned by the County Council and has previously been earmarked for this purpose.
Site 1014 - Norwich Road, Chedgrave
This isolated site was discounted as not relating well to the existing development. During the course of the GNLP site evaluation process, both site 1014 and the third party land immediately to the west and the east (neither of them having emerged through the call for sites) have together been the subject of a string of planning applications for frontage development totalling 11 dwellings. All have been approved with minimal local objections. This is clear evidence of landowner appetite for development on all three sites which together extend from the settlement along a 300m road frontage and encompass both 1014 and land to the east and west.
The land is on the bus route and a convenient walk from shops in Chedgrave.
In their email of 10th March, South Norfolk Council - while expressing some concerns about estate scale development - suggest that GNLP would need to carry out a “robust and consistent” evaluation. Since all three landowners (site 1014 and land adjoining) have recently independently promoted development, we request that GNLP makes proactive approaches as required.
If the eventual decision is that additional development to that approved already is not appropriate, we request that the 11 consented homes are included towards meeting the 200 homes target in the GNLP.
Site 2055 – Big Back Lane (and nearby land)
It is agreed that this site in isolation related poorly to the existing settlement. We have however noted there are wider development opportunities on the substantial area of land between Norwich Road and Big Back lane, i.e. extending the existing residential estate development eastwards. The existing estate roads are configured to allow further westward expansion, and there is in addition scope for making direct pedestrian or vehicular access to Norwich Road which is on the bus route. We have pointed out that the registered freehold owners (site NK332262, plan attached), who have an address in Essex, may well not have been aware of the call for sites.
In their email of 10th March, South Norfolk Council has highlighted a ransom strip on one of the estate roads as potentially preventing access for future development. The email also refers to higher ground and possible visual/landscape harm and amenity impacts on existing properties.
It is usually the case that ransom strips are retained in order to give the owner financial leverage rather than to inhibit a development. Accordingly it is very likely that access will be negotiable by any developer in exchange for a share in the resulting land value uplift.
It is hard to see why considerations in the Council’s email about higher ground, landscape harm and residential amenity are noted at this location but have not been factored into evaluation of the suitability of site 0312.
We ask that contact is made proactively with the registered owner of the land shown as NK332262 and followed by a full evaluation unless the owners confirm they are unwilling or unable to make the land available within the plan period.