GNLP0353

I am dismayed that a site of this size could be considered given the outdated roadway infrastructure. The additional traffic generated would undoubtedly further stress the already over used roads. The additional traffic would have to route through town when travelling to Norwich and it is clear to see that improvements are needed in the highway system before such a development can proceed.

There will also be a generation of increased traffic noise effecting residents of Dereham Road Reepha.

If the town was bypassed then this development would not be a problem, however without such improvement it will reduce the quality of life for the existing residents considerably..

Whether travelling through town or to Bawdeswell the B1145 is not well equipped for today's traffic. Junctions at Townsend Corner, and church Street are very narrow and frequent traffic stand offs occur when HGVs and coaches get stuck. An increas in volume will only exacerbate the present poor situation.

Furthermore the loss of part of Casu Park is a definite loss the natural habitat for plant and wildlife species and the visual outlook for residents of Smugglers Lane with be severely impacted.

I object strongly to the proposal.

This development is too large for Reepham to support given the existing pressure on services and infrastructure - see below for details. Reepham is in one of the most remote and difficult-to-access parts of Broadland. It is in an environmentally sensitive location, has historic protected landscape and townscape with no good access roads, and extremely limited traffic movement in the town itself. The town is disconnected from the major road network, public transport, major shopping, employment & services, and the new infrastructure being developed to support growth north and east of Norwich.

Highways
There has been no assessment of the impact additional car use would have on Reepham. There are 2 major 'pinch points' in relation to traffic. Firstly there is a right angle bend next to the church which is impassable by large vehicles. The only other road through the town has a single track T junction (Townsend Corner) on a small hill, with no pavements. Many of the school buses and other large vehicles have to travel via this junction and there are regular hold-ups and damage to the historic buildings along the narrow roads.

Whitwell road is one of the most direct routes into Norwich but it is not passable by HGVs and other high vehicles because of the 2 low railway bridges. There are also several 'pinch points' along this route where the road is only passable at a single track and blind corners. A significant increase in traffic will make this road much more dangerous as cars get frustrated with large vehicles and the school buses and try to overtake along unsuitable stretches. This road also runs alongside the SSSI and regularly floods.

The concern regarding traffic in Reepham is not primarily that of congestion, rather the additional risks that the congestion will bring. The increased risk will come about as a result of difficult manoeuvers to negotiate right-angle corners and narrow single-track roads with no pavements throughout the town.

Transport
Reepham is served by limited public transport which could not support work based traffic. Travel to work has to be undertaken by car. The nearest 'A' road is 3 miles way and existing B roads are problematic due to being extremely narrow and impossible to negotiate by large vehicles. Although it would be possible to walk or cycle to the primary school the school is already oversubscribed so children will have to be taken out of the town to school. A to B cycling (as opposed to leisure cycling which is popular) is difficult in Reepham because of the narrow roads and lack of footpaths to protect cyclists from large vehicles negotiating the narrow highway.

This site in particular would cause significant problems of congestion as traffic will clog up around any junction on the B1145. The blind bend at the bottom of the hill is a dangerous junction which would be made more risky by the increase in traffic. Traffic will be likely to travel in that direction to Norwich as there are so many difficulties with the roads in all other directions due to single tracks and sharp bends.

As the proposal is a commuter belt estate on the edge of a town with limited public transport in the form of buses and no train station it will have the impact of significantly increasing congestion and car emissions.

NFFP Para 32 - all developments that generate significant amounts of movement should be supported by a Transport Statement of Transport assessment

There has been no transport assessment, or transport statement. In the plan for Reepham, with its existing congestion and road constraints (including no access for HGVs), no account is taken of the need for efficient delivery of goods and supplies. Journey lengths for employment, shopping, and leisure are increased, rather than diminished, by the Reepham allocation. It does nothing to improve the quality of parking (quite the contrary, it will make this longstanding Reepham problem many times worse). The Reepham allocation diminishes, rather than promotes, the growth of sustainable transport in Broadland.

Schools
The primary school is at capacity and many children living in Reepham already have to travel to Cawsten or Bawdswell to attend school. The high school is unlikely to gain funding to expand significantly and while there is some capacity to add extra classes into a school that was originally built for less than half its existing number it is highly unlikely to be able to accommodate the large numbers of places that a large number of extra houses would bring.

Employment
Reepham's Economic Strategy states that:

"Reepham's economy is characterised by the presence of a small number of medium sized businesses (between 50 and 250 employees)and a large number of micro businesses (between 1 and 10 employees) with few small businesses in between.....
The dominance of one or two medium sized employers renders the local economy vulnerable if one of them were to close or move away.

Research and consultation identified that many businesses located in Reepham chose to establish themselves in the town because of the high-quality environment and attractive rural setting. In fact many of the significant constraints of the location such as limited broadband and mobile phone reception were outweighed by this specific consideration which is testament to how strong an appeal these contextual issues can have, particularly when business is not reliant upon daily face-to-face contact with clients or major infrastructure connections present in larger towns and cities.

The supply of high-quality small scale employment space, typified in converted barn schemes, is however, constrained. Planning policy is broadly focussed on undeveloped employment allocations geared towards light manufacturing estates and there is a significant disconnect between the owners of scattered rural premises and demand from prospective owners or tenants."

The strategy outlined in the document goes on to recommend the identification and support for mixed use, high quality developments which could help the micro-business expand when they need to would be the appropriate type of development for the town. The current plans for Reepham do not include any prospect of this type of development. Indeed they are likely to lead to commuter belt (people traveling to Norwich to work) development which will make the town centre vulnerable.

"Reepham has a good range of local retail businesses concentrated in and around the town centre. A number of these have been in Reepham for generations and are an important part of the character and economic base of the town. When asked, the local community have frequently commented that they value these retailers and that they add significantly to the attractiveness of the town.

However, common to many town centre or high streets, a number of the traditional retailers in Reepham are struggling and the situation has become increasingly fragile.

The fragility of the retail sector in Reepham was demonstrated in 2012 when the only bank in the town was closed for a number of months following a robbery. With the loss of this one activity, retailers reported a significant drop in footfall and trade as fewer people came into the town centre to bank and undertake other linked trip activities. The impact of the temporary loss of this one part of the retail mix in Reepham demonstrates how vulnerable the sector is."

The above statement, based on an objective assessment by external consultants, identifies the fragile nature of the town centre's retail sector. Although a large housing estate with increased numbers of residents will increase the footfall to some extent the parallel increase in traffic and associated parking problems, together with a commuter- led development focused towards Norwich is likely in the long-term to have a detrimental impact on the town's shops. Research has shown that the 'donut' model (historic town centres ringed by housing developments) of town planning does not result in a subsequent revival of old town centers.

Character of the town
The quality of the natural environment around Reepham is a key factor in its historic significance. The combination of high value landscape (in terms of wildlife, plant-life and landscape character) and the attractive and notable historic buildings in Reepham town together creates the unusual character and distinctiveness of this ancient market town. As one of the ONLY market towns left in Norfolk which retains this relationship between the town and the countryside this should be something to be cherished, not destroyed.

In his book Norfolk Origins: Exploring the Norfolk Market Town (Poppyland Publishing, 2012), the late Chris Barringer described Reepham's unusual historical profile and remarked that it is one of the LAST Norfolk towns not ringed by modern estate housing.

Environment
The town has rare Norfolk Valley Fens habitats in two locations (Booton and Whitwell) which bridge both ends of the town. These areas should not be seen in isolation but are part of a network of waterways that thread their way along adjacent sides of the town and effectively create a ring around the slightly elevated land on which the town has been built. The quality of this sensitive landscape is threatened by the large housing developments that are proposed at the edges of the town because of the impact on adjacent drainage and water quality. Norfolk valley fens are rare and sensitive lowland habitats that are being eroded throughout the county. They are particularly vulnerable to fragmentation.

If permission is given for further large housing developments in edge of town green field sites, any later assessments by Natural England or Environmental impact studies paid for by developers will only attempt to mitigate rather than prevent detrimental impacts on the environment.

Reepham is currently a good example of how these habitats can be sustained and improved if inappropriate development is not imposed on the landscape (to date). If the needs of Reepham were actually addressed in detail the landscape, built heritage and urban development could be improved in a number of ways but large housing estates on green fields are NOT the way forward. This is a 'one size fits all' approach with little regard for local circumstance.

Sewage
The Stage 2 Water Cycle Study, non-technical planning report, 7.15 RPA 1 Reepham, 7.15.5 states that,
"It is considered that wastewater treatment currently presents an overall constraint to growth and phasing in RPA1." and that

"Water Neutrality is theoretically feasible for the town.................so long as metering is introduced across the town for existing homes and low use fittings (including toilet flushing) are included in existing homes."

The increase in sewage effluent from the sewage works will form a significant risk to water quality and is a high risk to the maintenance of the County Wildlife Site water meadows and Whitwell Common SSSI which are immediately down steam of the sewage works.

As far as I understand, the Reepham sewage plant has had some improvement works because of local flooding and pollution but this has not solved the issue of sewage capacity.

The plant still releases 'water' into the Blackwater stream (and thereby the Wensum) which is at saturation point for certain chemicals. Thus we have a serious issue of water quality, pollution and an additional problem of water pressure.

Secondly, when Broadland CC and developers say the sewage plant can cope with a further 120 households of peak material what they actually mean is that either;
a. the sewage is held in the pipes and processed at a later time, or
b. sewage will be removed by large trucks and processed elsewhere.

The developers and land owners who are pushing for large housing estates to be built around Reepham have suggested that sewage could be dealt with by the use of reed beds. Reed beds are a really good solution as an end of system fine filtration and as part of other drainage schemes. They would have to be used in conjunction with a 'package sewage treatment plant', or part of land discharge or watercourse discharge.

All of these options have severe difficulties for all the proposed sites - unless the overall issue of the sewage plant is solved which would require a large investment from Anglian water (which as far as I am aware is not on their agenda) any future large-scale housing developments outside the settlement area are highly likely to cause severe problems for existing and future local residents.

Housing need
As you can see from the table below (obtained from NCC) the numbers in 2014/15 requesting social housing in Reepham are low and the majority require small dwellings. This is unlikely to have changed significantly since then.

Reepham Housing List Info June 2015

1) Total On Housing List - listing Reepham as one of the preference parishes
Out of a total of 2936 active housing list applications 128

2) Total On Housing List with Local Connection 27

Housing Need for All Applicants
1 bed 81
2 bed 34
3 bed 12
4 bed 1

3) Households for all Applicants
Family 45
Couple 13
Single 27
Elderly Couple 15
Elderly Single 28

Local opinion
Reepham residents have overwhelmingly stated in repeated consultations (cumulative total of 1500 responses over 4 years) that large housing estates will not improve the town, indeed, the negative aspects are so great that anecdotal evidence is that several households are prepared to leave the area rather than live in the town after it has been spoiled by large green field developments. There is no evidence to endorse the view that large housing estates will improve the town for current or prospective residents.

Realistic Reepham carried out a survey during the last consultation exercise;
*376 people responded (∼20% response rate)
*Residents believe in growth appropriate to the scale and character of the town
*Acceptance of the need for more housing appropriate to the healthy development of the town, its micro-businesses and services
*An overwhelming proportion oppose building of large housing estates on the edge of the settlement: Completely out of character with the unique landscape/built environment and unsustainable given our geophysical location

A disproportionate and evil overdevelopment. Overwhelms the services of a so-called "key service centre" that already struggles to maintain. Adding growth of this scale is irresponsible, there is no local need for this. There is just a desire by the council to meet housing quotas, not based on local feeling or need, inspired by population growth - when there is not even a national population strategy. Traffic,medical services, safety, sewerage, schools are all waiting to be overwhelmed by this

Assuming the Broomhill and Station Road sites go ahead I believe 200 more houses is too many for a small market town of under 3000 residents due to infrastructure, doctors surgery and schools. I believe the site next to the surgery as a stand alone would be suitable for smaller affordable housing in particular for the elderly with the proximity of the surgery. Access to Smugglers Lane from Dereham Road could be improved by moving the surgery car park to the other side of the (extended?) surgery and shaving off some of the land on the corner to improve access.

Reepham might look pretty on a postcard but the reality is that it is poorly-served by public transport and remote from employment centres. Any future developments sanctioned in the town will only add to the use of cars. Although it has basic infrastructure, the doctors' surgery and schools are over-stretched with no apparent prospect of expansion in the foreseeable future. It makes no sense to the local community for councillors to be considering allocating additional site for housing estates in the town when there are already two large committed sites which have yet to be progressed in any meaningful way.

Concerns are the lack of safe pedestrian access from the sites to the town centre and the schools. The pavement along the Dereham road (only pedestrian access)is too narrow for pedestrians to pass others safely; neither does it extend to the frontages of the two sites on Dereham Road. Pedestrians leaving the site to the south of Dereham Road would have to cross the main road where visibility is restricted. It is unlikely that the existing pedestrian access could be improved to an acceptable standard. Sites are outside the settlement boundary and would represent an unwelcome and inappropriate development

The scale of development on these greenfield sites to the north and south of Dereham Road would be incompatible with the other built-up areas of the town.
Far too many houses are proposed, whose inevitable suburban appearance
would be an alien feature in what is still a predominantly rural landscape.

We object to GNLP0353; a site with 100 to 200 houses suggested, and lying north and south of Dereham Road.

First, the site needs to be viewed in the context of a small market town with limited services (e.g. public transport). Other sites of perhaps 2 to 20 houses suggested for Reepham seem more appropriate. In particular, there are special highways issues in Reepham; the B1145 crossroads and the Norwich Road past the churches being two well-known examples.

Second, with respect to the site itself, Smugglers Lane lying along the east side of the site and providing access to most of it, tapers to single lane traffic at each end. This already causes difficulties. The thought of construction traffic using the lane for developing this size of site is deeply worrying. In the longer term, access for residents from the site on to Kerdiston Road or Dereham Road is not easy, and in the case of Kerdiston Road there is then the challenging angled junction from that road on to Station Road.

Site Specific Comments on Site GNLP0353 (Land north and south of the B1145 Dereham Road, Reepham - 11.67 hectares)-
It is important to clarify that the proposals for Site GNLP0353 have been updated subsequent to the call for sites submission in Summer 2016. The land north and south of Dereham Road is being promoted as a mixed-use scheme comprising the following elements:-
* Residential development of approximately 120 new homes across the northern and southern land parcels with the mix likely to include a proportion of bungalows and the potential for self-build plots;
* Employment allocation of approximately 4 acres / 1.6ha. This has been identified working with a particular end-user, who is a significant employer within the local area and is looking to expand their existing operation; and
* Reserved land to permit expansion of the doctor's surgery to future-proof healthcare demand going forward including the provision of additional services not currently provided by the surgery.
Drawing Number 0078/102 has been included within the representations and defines the proposed employment allocation together with a potential expansion of the GP Surgery site, with a new access onto Dereham Road, Reepham. The remainder of the land has the potential for residential development and with 2 parcels, there is a flexibility to meeting the need ultimately identified for Reepham. Based on the previous JCS allocation, which has yet to come forward, it is suggested this should be in the region of 120 new dwellings.
Pigeon has reviewed and considered the Settlement Site Summary for Reepham and also the Housing and Economic Land Availability Assessment (HELAA) summary for Site GNLP0353. Pigeon wish to make the following comments.
Reepham Settlement Summary
The Summary's acknowledgement that Site GNLP 0353 (Land north and south of the B1145 Dereham Road) is one of a range of site options available to accommodate development is supported. The recognition of the flexibility around the 2 parcels of land is also welcomed although Pigeon would contend that this flexibility would also permit smaller growth to be accommodated on GNLP0353. However, notwithstanding its Key Service Centre status, Reepham itself is a town with a range of services and facilities including a High School, and has a significant sphere of influence within the local area. Accordingly, we would suggest it is allocated for a level of growth of around 100-120 dwellings consistent with the previous JCS, and particularly as that site has yet to come forward. On that theme, the recognition that development of the southern parcel could facilitate the delivery of the existing allocation (including its provision for the High School) is welcomed.
Comments relating to surface water flood issues are noted but from preliminary investigations we are unaware of any issues. However, the position could be enhanced by sustainable drainage proposals. We would also concur that there is sufficient land for any issues to be avoided or mitigated and similarly there is sufficient land to avoid impacts on the Conservation Area, which would certainly not preclude development, given Pigeon's commitment to high quality, landscape led development.
HELAA Site Suitability Assessment (GNLP0353)
In respect of the Site Suitability analysis, the conclusion that the site is suitable for new homes is welcomed and as set out above, the Pigeon scheme is for a high quality landscape and design led proposal of a scale and form that is entirely appropriate for the town of Reepham.
Addressing the Constraints and Impacts Analysis in detail, we are pleased to see the site score a 'green' rating for the following matters:-
* Access
* Accessibility to Services;
* Utilities Infrastructure;
* Contamination and Ground Stability;
* Market Attractiveness;
* Significant Landscapes
* Biodiversity and Geodiversity;
* Open Space and GI; and
* Compatibility with Neighbouring Uses
Pigeon support the above findings and would emphasise that the site lies within a highly sustainable location with easy access to the town centre and the range of services and facilities contained within it. Indeed, the delivery of new commercial development, including potential expansion of the doctor's surgery on the site will continue to support the town centre and its shops and services in addition to the new homes.
The site is not within a Flood Risk Zone and as detailed above, there is sufficient land to address or avoid surface water drainage issues, with the potential to deliver enhancements through suitable SuDS design.
With regards to townscape and heritage, it is noted that the Reepham Conservation Area extends close to the south-eastern corner of the northern parcel. However, the northern parcel is a well-contained site with strong boundary treatments and therefore any impact upon the townscape and Conservation Area is minimal. In addition, the land in the south-western corner is proposed for potential expansion of the surgery which will limit any potential impact.
The southern parcel similarly has a limited townscape impact and adjoins the existing allocation from the JCS.
With regard to transport and roads, the site is given an amber rating although access raises no concerns and the site suitability conclusions define that any impact on the local roads could be mitigated and this wouldn't prevent development of the site.
In summary, the concept proposals define a high quality, landscape led development that would be delivering a mix of new homes and employment in a highly sustainable location with minimal constraints and certainly none that could not be overcome. It therefore comprises a suitable site for
a mixed use allocation with a range of benefits including local employment in a sustainable location and future-proofing the needs of the local doctor's surgery.