GNLP0313

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Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 20822

Received: 13/03/2020

Respondent: Mr Thomas Goodison-Gates

Representation Summary:

If the heritage and tree conservation issues could be mitigated then I do not object in principle to this proposal, with one big caveat being safe and suitable highway access. Loddon is well served by transport links which in principle add to this site's attractiveness, however the reality is that parked cars and volume of traffic currently using the adjacent High Street already make existing access difficult. It should be observed that the speed limit through Loddon is 20mph and this is as a desperate (and inadequate) attempt to mitigate unsuitably narrow pavements as they pass historic buildings.

Full text:

If the heritage and tree conservation issues could be mitigated then I do not object in principle to this proposal, with one big caveat being safe and suitable highway access. Loddon is well served by transport links which in principle add to this site's attractiveness, however the reality is that parked cars and volume of traffic currently using the adjacent High Street already make existing access difficult. It should be observed that the speed limit through Loddon is 20mph and this is as a desperate (and inadequate) attempt to mitigate unsuitably narrow pavements as they pass historic buildings.

Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22736

Received: 15/03/2020

Respondent: Peter and Valerie Hardy

Number of people: 2

Representation Summary:

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.

Full text:

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.

Attachments:

  • Map (375.85 KB)
  • Map (5.04 MB)