GNLP1001

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.

. Reedham has had several developments over recent years (Station Close, Yare View Close and the one under development - I believe it is called Owl Close) the density and volume of housing is changing the character of the village.

2. Is there a need for more housing in Reedham? I understand that the recently built social housing has not been let to local people and that several of the other properties have not sold.

3. The sewage system cannot cope with present demand (especially in the summer when Pettitts Theme Park is open) with waste being removed by tanker.

4. Although the village does have a railway station trains can only take people to the centre of Norwich or Lowestoft (the service to Gt Yarmouth is either infrequent or non existent and cannot be considered viable - Acle straight here we come) and is expensive. It is difficult to live in Reedham if you do not have a car - it is needed to go work and for any social activities - most households (unless the people are retired) have two cars CONSIDER THE ENVIRONMENTAL IMPACT

5. If one is living in Reedham with limited financial mean and no car (as I was for several years) it is very isolating and can lead to mental health issues.

I realise that most of my concerns are general and that I have not commented on the specifics of the sites (the web site defeated me) and I cannot remember the details from my visit to the roadshow at Acle

GNLP1001 and GNLP 3003
The roads in Reedham are narrow, and ill suited to additional traffic.
This situation is compounded by a lack of pavements, especially to and from the school. Sewage needs require tankers to transit the village. The road network around the village is poor.
This makes Reedham a sub optimal choice for housing development such as GNLP 1001 and 3003.

We see much 'development', mostly middle-income housing.
The 'affordable' housing is little, and nevertheless, well out of reach for those who really need it.....

A plan,- in these times especially, should surely include, as a PRIORITY:

i) Getting cold, pained, and potentially dying young people off the streets of Norwich into small warm dry eco habitations.
ii) Rehousing individuals and families who are suffering in damp squalid rip-off rent conditions,
as a means of staying off the streets, into something similar.

Clearly neither of these will be a cash cow for developers,(as they are in need of being within the Univeral Credit budget!!)
However, it seems obvious that a Greater Plan needs to be Great in some respects, and has little to do with greedy landowners and hungry builders circling to make a killing.


Secondly, more specifically, and with regard to this and Reedham NR13 (GNLP 1001 & 3003):

Reedham often described as 'one of the most picturesque villages in the Broads' has already been partly vandalised with housing estates, the latest being 'Barn Owl Close' -(where the barn owl now does not fly),
and which after 2 years is still ongoing, with dust and noise,-including constant bleeping of machinery.

So is there a benefit to even more housing, bearing in mind the following:

*The primary school will almost certainly be full before these houses are built.
*The Surgery is already fit to burst.
*Potential FLOODING is an issue in Witton Green (1001)
*There is little or no employment in the village,
and as one of the most outlying areas public transport is difficult and expensive,
leading to the alternative of choking all the small access roads with cars (and more delivery vans)

I would urge the planners to seriously consider , by visiting the reality ,
rather than the onscreen virtual reality.

I am writing to express my objections to the proposals to build 66-88 new homes in Reedham as detailed in the GNLP.

There are a number of issues that apply to both proposed sites (GNLP 1001 and GNLP 3003). These are:

1. Housing recently constructed adjacent to the proposed site GNLP 1001 has sold very slowly. Indeed, much is still not sold (see Right Move website where a number of properties are still advertised for sale). The building of these properties has also proceeded increasingly slowly given the relatively small number of properties. Some properties are still to be completed. I believe that this indicates low demand. How then can any further housing be justified at this time.

2. The sewerage system in the village does not adequately support existing housing, let alone the additional dwellings proposed. Tankers take sewerage away from the site in Holly Farm Road virtually every day and have been doing so for an extended period. Tankers can also be seen going to and from the site multiple times on individual days. This is very concerning without the prospect of the proposed new housing and indicates a serious issue with the sewerage system in the village. Additionally, in parts of the village (Wilton Green for example) drains get blocked resulting in flooding. Clearly Anglian Water are likely to be in favour of additional housing in Reedham which will bring additional income from water rates. I do not believe that these issues have been highlighted by or with Anglian Water when they were contacted regarding the proposed developments.

3. The roads to and within the village are not adequate given the amount of additional traffic that will come with these proposed new dwellings. They are windy, narrow country lanes in the most part. This would be clear if it was to be examine ‘on the ground’ rather than just be looking at maps. I do not believe a detailed examination of the roads in the village and surrounding area has been undertaken. I am not suggesting the roads should be widened as this will alter the character of the area. I am saying that additional dwellings should not be built as this will add to the burden on the roads.

4.Public transport serving the village is not adequate for current inhabitants, yet alone the increase in numbers that will come with more housing. The bus service has been reduced over the past year. One bus a day Monday - Friday is hardly adequate. The train service has been very unreliable and continues to be so. The service is also infrequent when it does run during the day, where trains are 2 hours apart. Further housing will add to burdens on the transport system.

5. Facilities were much better in Reedham in the past. Not so good now for current numbers, yet alone increased numbers resulting from proposed housing development. There is currently no cash point in the village. We have a shop, but it in no way does this cater adequately for more than odd items. Main shopping has to be done elsewhere. The doctors surgery only opens 4 half days a week. This recently increased from 3 half days but it is still very difficult to get an appointment due to the numbers of people it serves. With more people living in the village as a result of this proposed new dwellings this situation will undoubtedly become worse.

6. Additional housing threatens to seriously alter the character of the village. Reedham is a beautiful Broadland village popular with tourists. Additional housing could bring demand for street lighting, footpaths and other changes that will seriously alter the character of the village.

7. The GNLP incorrectly states the number of vacancies at the village school. The headmaster corrected the figure, which is considerably less, at the Parish Council meeting on 10th February this year. Over the last year numbers at the school have been boosted. In any case, having more housing in the village does not automatically mean there will be more children, unless there is a condition that housing can only be occupied by families with children of the age that can attend the school! Parents may also chose to send their children to a neighbouring village.

8. Water supply capacity in the village has been shown to be inadequate. I believe that the water main capacity has not been increased for around 20 years despite the increase in the size of the village. With the proposed additional housing this situation would worsen. When the parish church caught fire water had to be pumped from a nearby dyke as the water pressure was insufficient to extinguish the fire. The water supply was also insufficient to extinguish a fire at Pettitts last year.

9. Reedham is an environmentally important and sensitive area. Building more houses could adversely affect this by affecting habitats. This is unacceptable.

10. Set on the River Yare, Reedham is potentially at risk from flooding. While the proposed site are above river level at present, with the likely increase in sea and, consequently, river level going forward, it has been stated that large parts of the village could be under water by 2050 (see Cimate Central map in Norwich Evening News 22 Jan 2020) Therefore I believe it is irresponsible to build the housing proposed for Reedham in the GNLP. There are many other sites outside Reedham more suitable and sensible to take additional housing, if indeed this is required.

11. Reedham is an environmentally sensitive area with wildlife that needs to be protected. Additional housing could diversely affect this with destruction of habitats.

Proposed site GNLP 3003

Access to this plot relies on obtaining third part land given the restricted visibility from this, the only viable vehicular access to the site. Given this I question why this site has been identified as suitable.

Proposed site GNLP 1001

I believe this site was designed as recreational in plans approved for the Barn Owl Close development. How can this be developed now therefore.

General Additional Points

There is nothing in the plan regarding the proposed housing being carbon neutral. If the proposed housing is not to be carbon neutral this will have an adverse effect on this environmentally sensitive area, another reason why the proposed housing should not be built.

Given that a number of houses have been built in the village in recent months I believe these should be deducted from the total number of houses proposed in the GNLP for Reedham. Indeed any further ad hoc housing built going forward should be deducted. Otherwise the village will in fact end up with considerably more houses than those specified in the plan. This means even more substantial adverse effects on the village, environment and burdens on the infrastructure.

Please ensure that my comments are included with others received as part of the consultation on the GNLP.

REEDHAM - GNLP2175, 1001, 3003, 2151
I have a number of concerns regarding the proposed sites in Reedham.
GNLP2175 - WITTON GREEN
.
Specifically about this site - Sewage problems - In the last two years alone I have had to help my neighbour deal with the results of the completely inadequate sewage system in this area. The sewer at the end of the road adjoining Pottles lane regularly gets blocked and my neigbour's entire garden gets covered in raw sewage. All the sewage from 30 or 40 houses ends up on my neigbours lawn. When Anglian Water come they say the sewer was not originally designed for all the extra houses that have gone up over the last 20 years or so and the system can't cope. Anglian Water have had to do major bio-hazard clean up and the lawn has been returfed twice recently.
When I spoke to you about this you have said that Anglian Water have said there isn't a problem! - I don't feel you are getting accurate information about this area from Anglian Water.
The sewage system cannot deal with any more dwellings on this road and the new dwellings on GNLP2175 would be upstream of this problem just making it a lot worse.
WATER PRESSURE - I understand that on one occasion a fire engine was unable to get adequate water pressure to deal with a fire. On Witton Green (where I live) the water pressure often drops to well below an acceptable level and you just get a trickle. The problem has reached the point where many of us have switched back to old style storage tanks to ensure a constant supply and pressure.
OTHER PROPOSED SITES - GNLP2175, 1001, 3003, 2151
ROADS TO REEDHAM - The only Access to Reedham is from the A47 - it is locked in by the River. The main road from the A47 is tiny, winds a lot and goes through various other villages to get to the A47. It's about 8 miles that takes about 15 minutes to just get to the A47 at Acle. The roads are very narrow and very bad.
When we get snow we get locked in - last time (2 yeasr ago) for over a week it was completely unpassable. My partner tried to get home from work and ended up staying in Acle for 5 nights. (This has happened several times since I have lived here).
Recently (4 or 5 times in the last year) we have not been able to get in or out of the village due to roads flooding from rain. On two occasions in the last year the road has been blocked for 12 hours or more and we have been stranded.
A part of the road in Freethorpe (on the way to the A47) floods almost everytime it rains and has done so for years. It floods a nearby house and often remains unpassable.... And this is the main road in and out! It was like this about 10 days ago with only a relatively small amount of rain and has only just soaked away! (The solutiuon this time was to put temporary traffic lights up to make sure drivers didn't drive through the puddle - they have only just removed the lights).
My understanding is the the Highways Authority have told you that the roads are fine and there isn't a problem! - I don't think they are giving you reliable information.
The roads between Reedham and the A47 are no where near good enough to take anymore traffic associated with more development in this area.
OPEN SPACE - I notice in Norwich that the tendency is to leave some open spaces alongside new developments (and/or in between houses) leaving an open airy feel for people to enjoy. So it seems odd that in the villages there is a push to fill every gap with new houses which completely changes the character and feel of the village.
SCHOOL - You can't take into account capacity at the school because many of us choose not to send our children to Reedham School. Reedham School is a very small site, with 2 1/2 teachers - the size of the site means it can't get much bigger. Freethorpe School is much larger, has 6 or 7 teachers along with a wider variety of classrooms, teachers and pupils and so a lot of parents will prefer to send their children there as opposed to Reedham. So if you put more families in Reedham they probably won't use the local School.
Reedham School has always pushed for more children (and the funding that comes with them) but that doesn't mean it makes sense for Reedham parents to send their children there.
FINALLY - If over the coming decades there is going to be an ever increasing need for more housing then we will very quickly reach a point where no more houses can fit in the available boundary of a village. Ultimately the village boundary will have to moved further out.
Rather than ruin the feel and character of the village now perhaps it makes more sense to develop outside the Village (i.e. move the outer boundary) leaving the existing Village as it is.
However, any more development must also come with massive improvement of sewage systems, road drainage and widening and improvements of the road system to the A47 - All these are already not fit for purpose.

Please consider the following objections to the GNLP

Reedham

Although the proposed sites are not currently predicted to be at risk from flooding, large parts of Reedham are within the “Land projected to be below annual flood level in 2050” including the sewerage plant, roads, railway, pubs and other businesses, meaning that well within the lifespan of any new development the village may no longer be viable, I suggest this reason alone makes additional large developments in Reedham unsuitable. It is very surprising that the “Lead Local Flood Authority” has entered a response of “No comments”

The “village clusters” approach does not make sense when the Climate Change Statement is taken into account, the entire principle is flawed, the approach used for the Joint Core Strategy was much more sustainable.

The consultation document states;

“Reedham is not clustered with other settlements as the school catchment does not extend to adjoining villages. The school currently has spare capacity.”

How can Reedham be a “cluster” of one village? The school currently has pupils from Freethorpe, Cantley and Brundall, how does this indicate a catchment of Reedham only? Any reliance on school places as a justification for development should be questioned, there are no guarantees that housing will bring children to the village, the recent 24 dwelling development of a JCS site (Red 1) in the village has so far only resulted in one additional pupil at Reedham school. Parents have a choice of schools in the area. Any benefit is lost in any case after a few years as children grow up and leave the primary school.

The consultation states;

“there is a total of 28 additional dwellings with planning permission on small sites”

For a small rural village developing these dwellings alone would give a sustainable amount of growth, further large developments are not required and indeed risk changing the character of this historic village.
There is an emerging neighbourhood plan which may provide a more suitable proposal for Reedham, no sites should be allocated until the neighbourhood plan has been adopted.

The sewerage system in the village already requires tankers to remove material, sometimes daily.

The narrow roads to and around the village are not suitable for a permanent increase in traffic.


GNLP1001

The farmland to the east of this site will be accessed for large machinery through any residential development on this site.
The site is outside the development boundary.
Contrary to GNLP Policy 2 issue 1
Contrary to GNLP Policy 7.4 347

GNLP3003

The only possible vehicle access to this site is not wide enough with no scope to widen without purchase of private garden land, there is absolutely no reason to believe that this would be possible. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
The site is outside the development boundary.
Contrary to GNLP Policy 2 issue 1
Contrary to GNLP Policy 7.4 347

I am writing with objections to any further development on greenfield sites in Reedham, Norfolk.

I have carried out a lot of reading and research into the proposed development for Reedham and cannot fathom why Reedham has been selected for further development.

Firstly, have you ever visited Reedham?? Reedham is surrounded by marsh land and a river. It is serviced by two narrow roads and a chain link ferry. I understand that one of the roads is classified as a ‘B’ road, but it is narrow and not wide enough for two large vehicles at least 5 points. This is evidenced by the many lay-bys along the route.

Secondly, Reedham’s location is not a prime commuter spot and does not have adequate public transport links. There is only one bus a day and trains run every two hours at points during the day.

Thirdly, I have lived in Reedham for 20 years and it’s a beautiful village, full of history and character. Building new homes ruins the things that makes the village so attractive.

It is attractive for tourism and this would be lost if we ‘commercialised’ the area with 100 unsightly new homes.

The most recent development at Owl Barn Close in Reedham is an example of how unsightly new homes would look in Reedham. I travelled over the chain ferry last week towards Reedham and was horrified to see much those new 4/5 bedroom properties at the front of the development stick out as you look over the village. It’s disheartening to see how the traditional village has already been tarred with modern, characterless buildings.

Please please please do not allow for further housing developments to be built in this picturesque village.

I understand that growth is inevitable, and a few houses here and there is expected. However, the allocation given by GNLP is wholly unacceptable and illogical.

Fourthly, there are much more suitable sites along the new NDR or in the suburbs of Norwich with better road links, public transport, sewerage. Reedham is not equipped with any of those things. Reedham CANNOT cope with more houses.

I know a few other villagers have sent more detailed explanations about the poor amenities that Reedham has to offer and I don’t know enough about the sewerage in the village to make a detailed comment, but I have heard from many people that our systems are unable to cope with the current demand, let alone with loads of extra houses.

I trust you will take my concerns into account and give serious consideration about taking Reedham off the GNLP.

Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making. The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgerg which is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads. Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles. Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.
Another significant issue with the increased road traffic the proposed additional development would cause, is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres. Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections:
GNLP1001
I object to GNLP1001:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. The Highways Authority has confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.
GNLP3003
I object to GNLP3003:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. The Highways Authority has confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
• The single entrance access is too narrow with no scope to widen. The Highways Authority has confirmed it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
• The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.
General Objections:
The GNLP is flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.
The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.
We argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.
One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.. This goal is completely undermined by the proposed policy.
The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so. An ill thought-out strategy/proposal in our opinion.

It has recently come to my attention of the proposals for a considerable number of new of new homes at Reedham. The serious lack of communication regarding these proposals is woeful and I understand that interested parties comments need to be received by 16th March 2020. I obviously have not seen plans for the two sites, but I know that one is situated at the end of my back garden. I will put forward my more ‘subjective responses’, but at an individual level I comment at the loss of the wonderful views that I once had from my garden and over the river valley (a feature included in the original sales literature for the cottage). I have now rewilded the back garden to try and maintain some sense of the natural landscape which is fast disappearing.

To my mind the way that the site fronting Station Road was initially developed was quite an eyesore, making it a fait accompli that the rest of the land would eventually follow the same fate. The village by and large has mainly developed piecemeal and more organically. The planning of new and further proposed development is in my view aesthetically unpleasant and doesn’t fit well in an environment on the margins of an environmentally sensitive area of such international importance. How long will it be before the street lights arrive and change the whole nature of the community environment. Some, however, may enjoy the bird song throughout the night.

At a more practical level Reedham has a very small village school, thriving and full I believe. We have a tiny and very part-time doctors surgery – travel to Acle medical centre is not always practical and possible for many. Reedham has only very small shop/post office facilities. I also understand that the main drainage/sewerage systems are constantly overloaded which is probably not helped by the current obsession to install brick-weave drives; a feature that seems to go hand-in-hand with new housing. Where does all that water go that once filtered into the land?

The main road to Acle is typically challenging in places. Who hasn’t encountered the army of delivery vans, lorries and school buses that use this route, together of course with the usage by farm and domestic traffic? I must assume that as Reedham grows then so will the essential services and infrastructure that supports it. One must follow the other, otherwise the whole development exercise is really a numbers game of achieving housing targets when the octopus-like development around the eastern/north-eastern corridors of Norwich are reaching unpalatable political levels. In addition to all this, is the real possibility with rising sea levels that this whole environment will see a return to the much more watery scene that it once was.

Mythology suggests that Reedham once had a lighthouse! This , of course, may not directly impact on housing development above the flood plan, but what of the village’s connectivity to the roads and railway? Much of our recently ‘modernised’ railway runs across the flood plains of the river. We have only to look at recent weather related events in this country to see how things can develop; we also have an adventurous north see knocking on our back door!

I appreciate that new homes are necessary for development and prosperity, but the rampant urbanisation to the north and east of Norwich is beginning to destroy the very special nature of Broadland that attracts visitors from far and wide. The nature of these development is creating the sort of urban environments that you expect to find in Essex or Hertfordshire. Do you really want the sort of developments that have been built around Blofield and Brundall to creep insidiously across the landscape and into the wonderful river valley? I hope not.

It is so important to be careful of how far you go before you destroy what other people find attractive about the region. To quote from an early environmentalist ‘you don’t know what you’ve got until its gone’. (Big Yellow Taxi, Joni Mitchell) How prophetic were these words on reflection.

I hope that you find these comments and observations useful and will give them due consideration in your efforts to fairly find appropriate housing in the district. I am sure that anybody who has ever tried to find a place to sit by the river in Brundall will endore my sentiments.

Summary of main points

• Some sites in Norwich are on the riverside and we would like them to make the most of their riverside location.
• Reference to the Broads and its various documents would be welcomed in some areas.
• Some policy wording is not defined it seems and it may be useful to do so.
• Improved reference to show on maps and to say that part of the Utilities Site is in the Broads area, but that both LPAs will work together to bring forward East Norwich development sites.
• Consideration relating to peat and carbon rich soils.
• Consistency of wording in some policies.

Main document

General comments:
• Throughout you refer to ‘post-carbon economy’. Is this an obvious enough term? Is it defined well enough? Does it adequately cover climate change, mitigation and adaptation? Also, by referring to ‘carbon’ only, you do not seem to include other greenhouse gases. I wonder if the use of this term, throughout the document, needs checking to see if it is the most appropriate term for what you are trying to say. At the very least, an explanation of what it means would be helpful.
• Throughout you refer to ‘inclusive growth’. I do not know what this is. What is to be included in the growth? The term might be acceptable, but you may want to define it somewhere as what it actually means is not clear or obvious.
• BREEAM references: you refer to single issues of BREAAM (energy and water on their own) in the document. As part of my discussions with BRE, it seems that they do not recognise the use of single issues, but rather a whole scheme needs to meet BREEAM criteria. You may wish to contact BRE about this to ensure any policy approach is deliverable.

Detailed comments:
• Box, page 6, Para 4, last sentence: refers to some aspects being repeated. I don’t understand; what is repeated?
• Page 8, para 1: has the Broads Local Plan and Broads Plan helped influence the document? Should they be mentioned?
• Page 24, para 95: do you mean increases of between the two figures quoted in each bullet point? Adding the word ‘between’ might make it read better.
• Page 28 – you refer to the Broads as a National Character Area, but it has the status equivalent to a National Park and is a Nationally Protected Landscape. Please say those things in this section of the Local Plan.
• Page 29, para 105 – have you thought about addressing peat and other carbon rich soils in the Local Plan?
• Page 32, para 119. You mention houseboats later on in the document, but could that be mentioned here – along the lines of ‘working with the Broads Authority, so too will the needs of houseboats be met’?
Page 34, environment section of the vision – recommend you mention the landscape impact on the Broads and its setting.
• Page 35, Environment objective – what about the setting of these things?
• Page 38, climate change statement – have you thought about carbon rich soils like peat? Have you thought about heat, cooling and extremes of weather (not just the effect of flooding)?
• Page 46, a how does this split fit with what is said at para 132?
• Page 51, Policy 1, bullet 2 – what do you mean when you say ‘local level’?
• Page 51, Policy 1, ‘support vibrant communities’ – do you mean help ensure communities remain or become vibrant?
• Page 52, Policy 1, second para under table: where you refer to negative impact on the character of the settlement, it seems also prudent to refer to the area in general – for example to consider the impact on the Broads and its setting.
• Page 61, policy 2: The first paragraph ends with ‘as appropriate’ – what does that actually mean in terms of applying the policy? What does ‘sustainable access’ actually mean? ‘What are ‘local services’? Point 10 – would that standard be in place until a Government standard is put in place? Is that worth saying in the policy?
• Page 62, footnote 73 – is that policy wording? Or is that policy in the DM documents of the districts? If that is the case, you might want to clarify that.
• Page 66, para 193 – NSPF version 2 is not draft, it is endorsed. The emerging NSPF is version 3.
• Page 72, para 212 – refers to 2019. You might want to update this in the next version of the Local Plan.
• Page 76, policy 4, transport. You talk of non-car developments and high densities in Norwich. Other places like towns have good access to services and public transport – are they going to have non-car developments and high densities?
• Page 79, para 248 – support reference to the Broads Authority and houseboats – please add something like ‘…for residents of houseboats in the area, through policies that enable the delivery of residential moorings.’
• Policy 5 supporting text – is it prudent to say that the Broads Authority will have regard to/defer to the affordable housing policies of the districts and so this policy will also be used, in parts, by the Broads Authority?
• Page 81, Policy 5: The first para uses the term ‘should’ a few times – is that weak wording? Under affordable housing – does it matter that an applicant might say they are sub-dividing a site for another reason and so could do it? Is it more that sub-dividing is not allowed, and that is because some developers may seek to avoid affordable housing obligations? What is ‘good access’?
• Page 81, Policy 5: what is ‘sustainable access’? What are ‘ancillary uses’? Marketed for up to or at least 12 months? How should they be marketed?
• Page 83, para 1: ‘…tenures of homes within…’. Para 3, what are locations with ‘good access’ – we say within a development boundary. Another consideration for location of such facilities is how staff and visitors can access it. Para 5 ‘…encourages new sites…’
• Page 87, policy 6: What are ‘significant residential and commercial developments’?
• Page 95, map 9 – do you include the part of the Utilities Site that is in the Broads – suggest you do and maybe show it in another colour and amend the key accordingly.
• Page 99, para 2 – isn’t office to residential permitted development?
• Page 100 – East Norwich. Is the East Norwich Strategic Growth Area Masterplan SPD in place? How will the Broads Authority be involved in its production? Is that the same thing that is referred to in the next para before the next bullet points? Should you refer to, even if it is as a footnote, that some of the Utilities site is in the Broads and there is a policy in the Local Plan for the Broads for that and that is consistent with this policy and we will work together etc?
• Page 111, Para 346: ‘…as shown in appendix 5…’. What is ‘good access’? What is a ‘safe route’?
• Page 112, policy 7.4, final para above ‘employment’: what about impact on character of the nearby area like the Broads.
• Page 114, policy 7.5 – do you want to say ‘subject to other policies’? Does the approach contradict page 113 ‘..without breaching normal planning criteria and the sustainable site selection process’.
• Page 114 – is another alternative to not allow this approach?

Typo/grammar
• Box, page 6, Para 4, first sentence: ‘documents will be assembled and as part of the next stage…’
• Page 7, para 6: ‘This will ensure that Norwich continues to be both…’
• Page 24, para 91: ‘flood risk in new development, locating development the great majority of development away from…’
• Page 53, end of footnote 62: ‘…based on the feedback and for each site.’
• Page 56, para 173: ‘The Sustainable Communities policy are wide ranging’. ‘Community policies are’ or ‘Community policy is’?
• Page 57, densities row: ‘…for different parts of the area’
• Page 78, para 239 – ‘it also includes minimum…’
• Page 90, para 267, bullet iii: ‘the essential role that of the other parts of the urban area…’
• Page 93, top: ‘…of key city centre..’
• Page 114, para 350: ‘’’through policies other policies in this plan’

Sites Document

General comments
• Suggest bullet points are numbered for ease of reference.
• I have a concern that there is little translation of strategic ecological gain to site policies. For example I could not find any site specific reference to sites that are within the GNLP Green Infrastructure (GI) Corridors, despite some of the sites, for example around Acle, Whitlingham/Trowse etc being in the junction of major adjoining corridors. I would expect that in these major biodiversity intersections opportunities to enhance wildlife corridors would be highlighted on a site basis. When Net Gain requirement is introduced via the Env Bill will this be picked up at this point?
• Some of the allocations/reasonable alternatives are on or close to or on deep peat resource so it is relevant to include the treatment of carbon rich soils and reference to ‘net zero’ targets. Excavation of deep peat is a significant emitter of carbon into the atmosphere and thus should be shown to significantly influence site choice.
• We asked in the past about this, but it is not included in the documents that I can see. We safeguard former rail tracks from development for their potential future use as PROWs. Go to page 211: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0004/1581916/Local-Plan-for-the-Broads.pdf. Here is the map, page 3: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0008/1565837/SSTRACKS_RAILWAYS.pdf. Are you able to/have you included a policy to safeguard the land from development?

GNLP0068
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word ‘should’ seems to weaken the requirement. CC4b for example does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 5 – so will they provide a river side path? Or maybe do it? Part of the bullet says to do it and then the other says potentail future extension – suggest this is clarified. GNLP0401 equivalent bullet points implies the walkway/cycleway will be provided as part of the scheme. Is the scheme expected to provide the walkway/cycleway and to what standard?

GNLP0409R
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Bullet point 7 – so will they provide a river side path? Or maybe do it? Part of the bullet says to do it and then the other says potentail future extension – suggest this is clarified. GNLP0401 equivalent bullet points implies the walkway/cycleway will be provided as part of the scheme. Is the scheme expected to provide the walkway/cycleway and to what standard?
• Page 24, para 2 – so the policy refers to car free or low car usage, but the offices will have a car park; is that contradictory?

GNLP0401
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Where it says ‘respect its riverside location’ what does that mean? Could it make the most of its riverside location?
• Bullet point 2 – so will the development be on the existing car park?
• Bullet point 4 implies the walkway/cycleway/ will be provided as part of the scheme – but other policies are not that clear. Is the scheme expected to provide the walkway/cycleway and to what standard?

R10
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b for example does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 2 - implies the walkway/cycleway will be provided as part of the scheme – but other policies are not that clear. But then it says ‘should’ (which 0068 equivalent bullet point does not include) link to a future extension? This may need clarifying. Is the scheme expected to provide the walkway/cycleway and to what standard?

GNLP0360
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 1 – last part refers to not prejudice future development of or restrict options for the adjoining sites. But the Utilities site is over the river, so not adjoining. Should the policy refer to the Utilities site in this sentence as well?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• There appears to be no mention of protecting and enhancing designated / non-designated heritage assets. There is a listed lime kiln on the site and I think potentially some locally identified HAs.

GNLP3053
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 1 – last part refers to not prejudice future development of or restrict options for the adjoining sites. But the Utilities site is over the river, so not adjoining. Should the policy refer to the Utilities site in this sentence as well?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• There appears to be little mention of designated heritage assets and there are a number on site / immediately adjacent, including the scheduled and highly graded Carrow Priory, listed former industrial buildings and Carrow House on King Street and the site is within the Bracondale CA.

CC7
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Unlike other policies with a waterside frontage, the following wording is missing. Why is that? Could/should it be added?
o A scale and form which respects and takes advantage of its riverside context,
o High quality landscaping, planting and biodiversity enhancements particularly along the river edge;
o Protection of bankside access for maintenance purposes.

CC16
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Where it says ‘respect its riverside location’ what does that mean? Could it make the most of its riverside location?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• Reference is made to the Bracondale Conservation Area but there are Heritage Assets in the vicinity, including the schedule Boom Towers and I think listed buildings on the Carrow Works site / Papermills Yard site.

CC8
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Unlike other policies with a waterside frontage, the following wording is missing. Why is that? Could/should it be added?
o A scale and form which respects and takes advantage of its riverside context,
o High quality landscaping, planting and biodiversity enhancements particularly along the river edge;
o Protection of bankside access for maintenance purposes.

CC4b
• Could it make the most of its riverside location?

GNLP2137
• I note this is a reasonable alternative. If this is taken forward then we would welcome wording that covers the issues addressed above.

GNLP1001
• The site is on higher ground, close to our boundary and potential visual receptors: Wherrymans Way, the river, railway, Ferry Road and Reedham Drainage Mill.
• The site might also be visible from the opposite valley side but against a backdrop of existing settlement.
• There is a risk that new built development/housing, if not sensitively handled could have adverse impacts on the setting of the Broads.
• The possible landscape effects could be mitigated by low ridge heights, reduced scale/massing and screen planting.