GNLP0504

Wroxham had 653 households at the 2011 Census. with new housing development in Hoveton (North Norfolk) and shared Doctors, schools, transport links and amenities a development of 350 houses is unrealistic and unsustainable.

I strongly object to this proposal.

Whilst we can all recognise the need for local affordable housing to meet local need many of the recent local developments do not fall into the "affordable" category and a number become second holiday homes. This needs to be addressed in approving developments.
Too little also seems to be considered regarding the appropriateness of the local infrastructure. It is already difficult to make an appointment at the local doctors' surgery especially with the developments which have already taken place. We know too that the Norfolk and Norwich hospital is overstretched.
New developments tap into existing drainage systems without real consideration as to the viability of these systems to cope. Has this been considered in the proposed plans to considerably increase the stock of housing in Wroxham? How far the gas, electricity and telephone services can be expanded is also debatable. It is currently impossible to get a mobile phone signal in that area too.
The roads abounding the proposed developments are currently inadequate for the existing flow of traffic. The Avenue is already used as a rat run and as it is narrow and has no pavements any walker is at considerable risk currently, the new Hopkins development has already increased the traffic flow, any further housing will make it intolerable and increase the risk of serious injury.
The Salhouse road too is already inadequate to cope with existing traffic movements.
Infrastructure, the availability of services like schools, doctors and dentists, the pressures on public transport and refuse services all seem to be conveniently forgotten in the planning process. Consideration of sites in isolation often tend to ignore the overall local picture, this is unsustainable and must be readdressed.

Far to large a development for the village which will never be able to fully absorb with the services available. On a dangerous bend with a speeding problem entering the village, large number of vehicles, large small, industrial often speeding. Completely the wrong end of the town for a development which will inevitably have a large number of children housed in it as schools and gp surgery are in Hoveton thus will force children to walk long distances to schools along our already very conjested village road, with all the inherent dangers of road safety and fumes from traffic.

A development on this scale is unsustainable. This would represent a 50% increase in Wroxham properties already with minimal infrastructural support. It would further increase traffic movement on the A1151 measured by our equipment at 5.5 million vehicle movements per year leading to reduced air quality and unacceptable traffic congestion and split the village community in two. It would threaten the iconic nature of Wroxham as the historic capital of the Broads. The location could be better used for public open space giving the local area and the village a much needed amenity.

Amec Foster Wheeler Environment and Infrastructure UK Limited (Amec Foster Wheeler) submitted land in response to the Call for Sites in 2016 as part of the Greater Norwich Local Plan preparation on behalf of Hopkins Homes Limited (hereafter referred to as Hopkins Homes). An L-shaped area of greenfield land extending to approximately 15ha at Salhouse Road, Wroxham was submitted. The Site has been assigned reference number GNLP0504.

A high-level Concept Masterplan was prepared to demonstrate the potential this location and was submitted to the Council. On submitting the site, it was noted that the Concept Masterplan presented was only one possible solution of how the site could be developed and it would be a basis for further testing and discussion. It was noted that within this area there are smaller options to meet a range of development needs. Since submitting the site Hopkins Homes has held further discussions with the land owner, Wroxham Parish Council and the District Council. After further consideration, we wish to amend the site option and replace it with two smaller options for the Council's consideration:
Option 1 - Land east of Wherry Gardens: This is a reduced option comprising part of the land previously submitted under reference GNLP0504. The option has omitted land south of Charles Close and north of The Avenue, along the eastern edge of the site. The reduced option now comprises a rectangular parcel of land south of properties in Keys Drive and abuts Salhouse Road to the west and The Avenue to the south. The site presents a logical and sustainable location for new housing provision and would provide a natural rounding off, of the settlement edge. The site relates well to the existing built form and is viewed within an urban context. Opportunities exist to create a vehicular access from either Salhouse Road or The Avenue subject to further analysis and detailed access design.

Option 2 - Land south of Wherry Gardens: The site comprises a square parcel of land which is bound by Hopkins Homes' Wherry Gardens development to the north and by native hedgerows and mature hedgerow trees to the south. The eastern boundary abuts Salhouse Road whilst the western boundary abuts the railway line. The site presents a natural extension of the Wherry Gardens development. The main estate road through Wherry Gardens can be extended to provide access to this land and there is also potential to create a second access onto Salhouse Road. The landscape framework, including mature hedgerows on the southern boundary present a logical extension to the settlement boundary.
Site submission forms, a location plan and a concept plan for both site options (land East of Salhouse Road and land south of Wherry Gardens) as above have been sent to the council separately.
Both options could be brought forward at any time to assist in maintaining a deliverable supply of housing land in line with the emphasis of the NPPF. High-level Concept Masterplans have been prepared to demonstrate the potential of these sites to assist the Council in meeting its development needs. They have been developed on the basis of some limited initial technical work and desktop analysis. Should the Council identify either of the sites through its emerging Plan, the options would be the basis for further analysis and testing by Hopkins Homes to support their allocation.
These options have significant potential to assist the Council in meeting its substantial development needs. The sites provide a highly deliverable and developable location in line with guidance in the NPPF. In particular, the sites are available now, they offer a suitable location for development and are achievable with a realistic prospect that housing will be delivered within five years. The sites are deliverable because:

They are not covered by any strategic constraints which would prevent development. Unlike many areas within the District, the sites are not at risk of flooding and the area proposed for development is entirely located in Flood Zone 1 (lowest probability of flooding).

The sites present a logical and sustainable location for new housing provision. They can deliver a quality development to assist in meeting the significant development needs in the District and widen housing choice in Wroxham. They also have the ability to deliver development on land free of any overriding constraints. It is likely to be an attractive location for further housing.
Hopkins Homes is willing to bring the sites forward. The sites can deliver quality development to assist in meeting the Local Plan requirement, including a mix of dwellings as well as a proportion of affordable homes to meet local needs. Given the extent of the landholding and the strategic benefits of developing this land it provides significant advantages over other locations and should be a priority for allocation in preparing the Local Plan. The sites provide an important opportunity to plan for longer term needs and provide certainty for local communities.

It should also be recognised that the scenarios identified in the Concept Masterplans are only one possibility of how the sites could be developed. They could work in combination or individually to meet a range of development needs or spatial scenarios. We would welcome the opportunity to discuss such matters further with the Council.

As the UK's leading woodland conservation charity, the Woodland Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved. We own over 1,250 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.
Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost. As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.
We are concerned about a number of site allocations included in the attached table as they could lead to the damage and loss of ancient woodland.
Planning policy
National Planning Policy Framework (NPPF) paragraph 118 states that "planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss."
Natural England's standing advice for Ancient Woodland and Veteran Trees states:
"Trees and woodland classed as 'ancient' or 'veteran' are irreplaceable. Ancient woodland takes hundreds of years to establish and is considered important for its wildlife, soils, recreation, cultural value, history and contribution to landscapes."
The Housing White Paper published on 7th February 2017 further shows the government's intent to improve planning protections for ancient woodland. This revised protection reinforces the approach set out in paragraph 118 (as set out above) to restrict development of ancient woodland as to do so would be contrary to the National Planning Policy Framework presumption in favour of sustainable development (as set out in paragraph 14) and the revised draft NPPF at paragraph 173c states .."development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons and a suitable mitigation strategy exists Where development would involve the loss of individual aged or veteran trees that lie outside ancient woodland, it should be refused unless the need for, and benefits of, development in that location would clearly outweigh the loss";...."

Impacts on ancient woodland
Approximately one quarter of priority UK BAP species are associated with woodland habitats. Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.
Development in ancient woodland can lead to long-term changes in species composition, particularly ground flora and sensitive fauna, i.e. nesting birds, mammals and reptiles. Majorly adverse impacts would occur as a result of the removal of large areas of woodland, much of which contains high quality, valuable trees, to make way for the construction of this proposal.
When land use is changed to a more intensive use such as in this situation plant and animal populations are exposed to environmental impacts from outside of the woodland. In particular, the habitats will become more vulnerable to the outside influences, or edge effects, that result from the adjacent land's change of use. These detrimental edge effects can result in changes to the environmental conditions within the woodland and consequently affecting the wood's stable conditions. Detrimental edge effects have been shown to penetrate woodland causing changes in ancient woodland characteristics that extend up to three times the canopy height in from the forest edges.
Creation of new areas of woodland or buffer zones around semi-natural habitats, and more particularly ancient woodland, will help to reduce and ameliorate the impact of damaging edge effects, serving to improve their sustainability. The size of the buffer is dependent on the intensity of land use in the intervening matrix between ancient woods.
Natural England's standing advice for Ancient Woodland and Veteran Trees states:
"Impacts of development nearby can include these effects on the trees and woodland, and the species they support:
* compacting the soil around tree roots
* breaking up or destroying connections between woodland and other habitats
* reducing the amount of semi-¬natural habitats (like parks) next to ancient woodland
* changing the water table or drainage
* increasing the amount of pollution, including dust
* increasing disturbance to wildlife from additional traffic and visitors
* increasing light pollution
* increasing damaging activities like fly¬tipping and the impact of domestic pets
* changing the landscape character of the area."
Development must be kept as far as possible from ancient woodland, with a buffer area maintained between the ancient woodland and any development boundary. An appropriate buffer area will depend on the local circumstances and Natural England recommend "leaving an appropriate buffer zone of semi-natural habitat between the development and the ancient woodland or tree (depending on the size of development, a minimum buffer should be at least 15 metres)."
The size of a number of the site allocations suggests that large scale development could potentially take place. The minimum 15m buffer recommendation to all development is not effective in ensuring that ancient woodland within and/or adjacent to site allocations is not affected by potential future development. Buffers should be constructed on a case-by-case basis rather than a 'one size fits all' approach.

Conclusion
The Trust is concerned about the potentially adverse impacts that the proposed site allocations will have in relation to areas of ancient woodland within and/or adjacent to site allocations. Ancient woodland should not be included in areas that are allocated for development, whether for residential, leisure or community purposes as this leaves them open to the impacts of development.
The Woodland Trust objects to the inclusion of site allocations in the table attached, as they are likely to cause damage and/or loss to areas of ancient woodland or to ancient trees within or adjacent to their boundaries. For this reason we believe the sites in the table below are unsound and should not be taken forward. Secondary woodland should also be retained to ensure that ecological networks are maintained and enhanced.