GNLP1032

We are concerned that development of this site would have a negative environmental impact, both in terms of the loss of habitat on the site itself but also on the surrounding area. The site is adjacent to woodland and the field forming the northern part of the site is fallow/grassland, providing a habitat for wildlife. The development would also interrupt the transit of species between the woodland and Poringland woods. There is also a watercourse running from the rear of Octagon Farm, along the southern and eastern side of the site. The fall of the land is in the region of 5 metres, south to north, and drainage from the site would therefore tend to flow through these onward to the woodland at Osier Carr and beyond. Surface water run-off from any development would extenuate drainage into this watercourse, carrying with it pollutants from the site. Overall, we consider this site to be in reasonable quality natural environment where it may not be possible to mitigate the impact of growth with the resultant negative impact of the site on the character of the area.

The site is also on Grade II agricultural land which would therefore be lost from production if the site were developed.

The Framingham Earl/Poringland area is known for surface water flooding problems and this site would fall within this water catchment area and likely to be at some risk of surface water flooding. There are several low-lying areas across the site, which experiences standing water during the winter due to the high water table and the nature of the sub-soil type which contributes to poor drainage. The Land slopes down to the North and surface water would therefore drain across the site in this direction with a greater risk of flooding in the Northern part.

The site is also some distance from the local services, recreation and community facilities. There is access to public transport via the bus route on the B1332 which runs adjacent to the site, and to Framingham Earl High School, but it is more remote from the hub of services at the southern end of Poringland.

In terms of traffic management, we consider that access to and from the site could be an issue with regards to traffic turning into or out of the site, across the lane of approaching traffic, particularly at peak times. Traffic-related issues are significant local concern and the development would contribute to this, placing additional pressure on the existing roads. This would not only affect the B1332 but also Arminghall Lane which is increasingly used by commuter traffic to circumvent the congestion on the Trowse bypass/A146.

The immediate area has also experienced problems in the capacity of the waste water treatment network to cope with effluent during periods of heavy rainfall and we would have concerns whether the waste water disposal from this site could be effectively managed. We also understand that there is a gas main running through this site.

We also consider that this site is not appropriate development on the basis that it would extend the linear form of Poringland village and promote further linear growth to the north of the existing urbanized area. The site is not contiguous to the existing built-up area but would compound the ribbon development of the settlement, rather than compact development. This tendency will also contribute to the existing traffic issues referred to above. To allow this site to proceed would not assist in establishing a development boundary for the Poringland urban area and encourage a blurring of the demarcation between the urban and rural landscape.

This development would produce a lot of additional traffic on what is already a very busy road.

Environmentally it would spread the urbanisation further into the country side. The development would take away farm land which could and should be used to produce food.
The housing requirement for the area has already been achieved without the need for further development.

The local infrastructure is not in place to support a development of this size.

As the current District Councillor for this site, I favour Option 1, Development Close to Norwich, but noting that
(a) This excludes South and South East Fringe Sectors, and limits village development to the current baseline.
(b) Windfall sites should not be added to the 7,200 homes required by this Plan,
(c) I favour a new settlement close to Norwich (possibly Mangreen) that would contribute to the 7,200.

On that basis, there is no need for development on this site.

Site Specific Comments (in support of sites to the north of Poringland notably 0321 or 1032)
The villages of Poringland, Framingham Earl, Stoke Holy Cross and Caistor use the facilities of Poringland. The volume, and to a lesser extent the speed, of traffic on the B1332 main road through Poringland is a significant community concern. It passes most of the services and facilities (shops, schools, village hall, dentist, pharmacy etc) and discourages walking and reduces the desirability of such trips. Most traffic is heading to Norwich for work, shopping and leisure. Whilst through traffic cannot be easily mitigated, new development should ideally be placed at the Norwich end of the current facilities.

Site Specifics

GNLP1032 - Favour: Site is to north of the village so would not create traffic through the village. Matches up the other side of the road. Against: Is Grade 2 ag land, and contributes to the linear vision of the village. SUPPORT

GNLP0485 - This huge site would at a stroke integrate Arminghall/Bixley with the Poringland conurbation. It has significant landscape, archaeological and environmental issues. It is far too far from any facilities and would be unsustainably reliant upon cars. OPPOSE

GNLP0131 - This is a smaller site but again unsustainably far from public transport, excessively reliant upon cars with no pavement in the vicinity and little prospect of being able to construct one. OPPOSE

GNLP0491 - This would significantly alter the form and size of Caistor St Edmund on archaeologically important site in open countryside. It is a form of 'backland' development. Access is severely limited. No access to public transport, no pavements to village and schools. OPPOSE

GNLP0494 - The access to this site is significantly constrained. Flood risk, no drainage, comes out very near a junction. OPPOSE

GNLP1047 - Access to this site is severely constrained. It is former RAF site so may well be subject to contamination. Site dominated by the mast towers. Form would consolidate development each side of the Stoke Road leading to further infill development. OPPOSE

GNLP0321 - Site is to north of the village so would not create traffic through the village. Matches up the other side of the road. However is Grade 2 agricultural land, and contributes to the linear vision of the village. SUPPORT

GNLP0589A - This would exacerbate the 'octopus' nature of the conurbation and would detract from an area of scenic value otherwise sadly lacking in this area. OPPOSE

GNLP0589B - Leading on from the development of the Long Road, Hibbett and Key site and the EACH site this would be a logical development. It would mean the loss of significant landscape value in Spur Lane. If it could be developed at a distance from the tree lined Spur Lane it might well be viable. Will have a significant impact upon the subterranean drainage flow towards Long Road and Poringland surface water drainage systems. SUPPORT

GNLP0391A - Flooding issues. Road network not suitable. Semi-detached from the village - contributing to the 'octopus' of development with drainage issues. Intrudes upon an area of landscape value between Framingham Earl and St Andrew's Church. OPPOSE

GNLP0391B - Similar arguments to those against the site south of Burgate Lane. OPPOSE

GNLP0003 - Isolated site in open countryside, contrary to policy, detached from the conurbation should not even be considered as a valid site. OPPOSE

GNLP0223 - Significant access problems with no comfortable access through the Norfolk Homes development. Would alter significantly the 'shape' of the conurbation into the form of an 'octopus'. Would reduce the distinctions between Poringland and Stoke. Would have significant Governance issues between Stoke and Poringland. Would significantly negatively alter the drainage problems of Boundary Way - known surface water, flooding issues.. Isolated. OPPOSE

GNLP0169 - Would contribute to the disjointed form of development of the conurbation. Extends beyond the comfortable walking/ cycling distance to schools, doctors and shopping. Makes the village an 'octopus' with its tentacles extending into open countryside. Dominant over the village approaches from Shotesham. OPPOSE

GNLP0316 - Land North of Bungay Road, east of Rectory Lane and south of White House. This land has significant environmental assets, hedges ponds - it would require a significant environmental audit. Would contribute to the perceived linear vision of the conurbation. Site has significant landscape value as the headwaters of the Well Beck and is one of the few views of landscape available to the road traveller between Poringland and Brooke. OPPOSE

GNLP0280 - Some problems over access, perhaps requiring the demolition of one house. Drainage problems. Disconnected from the built form of the conurbation. Would contribute to the linear form of the conurbation. OPPOSE

GNLP0323 - would be a welcome development if access along the lane can be seen as adequate. OPPOSE

General comments:
All allocations need to be considered in relation to the Greater Norwich GI Strategy and the emerging Norfolk GI maps, in relation to both opportunities and constraints.
As for previous consultations, our comments on site allocations relate to information that we hold. This relates mainly to impacts on CWS. These comments are in addition to previous pre-consultation comments on potential allocations. However, we are not aware of all impacts on priority habitats and species, or on protected species and further constraints may be present on some proposed allocations. Similarly, we have flagged up impacts on GI corridors where this is related to CWS but there should be an assessment of all proposed allocations against the emerging GI maps for Norfolk, which should consider both locations where allocations may fragment GI and areas within allocations that could enhance GI network. As a result, lack of comment on sites does not necessarily mean that these are supported by NWT and we may object to applications on allocated sites, if biodiversity impacts are shown to be present?

We are aware that the GNLP process will be taking place at the same time as Natural England work on licensing with regard to impacts of development on great-crested newt. This work will include establishment of zones where development is more or less likely to impact on great-crested newt. We advise that this ongoing work is considered as part of the evidence base of the GNLP, if practicable to do so in the time scale.

Broadland
Coltishall:
0265 There is a substantial block of mature trees within this proposed allocation which we understand provides nesting site for common buzzard and is part of wooded ridge. Although not protected under schedule 1 of the Wildlife & Countryside Act, in our view this should be seen as a constraint on development and wooded ridge should be protected.

Drayton
0290: In our view development within the Drayton Woods CWS is not acceptable and this site should not be allocated.
We agree with constraints due to proximity to CWS that are assessed for other proposed allocations in Drayton

Frettenham:
0492 we are pleased to see that impact on CWS is recognised as a major constraint and the need for area within CWS to be recognised as GI, if there is any smaller development outside of CWS

Hevingham:
Adjacent CWS represents a potential constraint as has been recognised.

Honingham:
We note that the presence of CWS and river valley are recognised as constraints, although assessment is that impacts on these areas can be avoided by becoming green space in a larger development. If taken forward, plans would need to include a buffer to all CWS and assessment of biodiversity value of each CWS to establish whether they have particular sensitivity. At this stage, NWT take view that 0415 should not be allocated, even if part of a large development.

Horsford:
0469 and 0251 should be recognised as having CWS or priority habitat constraint. There should be no development on CWS and should be a buffer to CWS.

Postwick:
0571 This would be a new settlement and we are pleased to see that a biodiversity constraint is recognised. However, Witton Run is a key GI corridor linking to Broads National Park. It is essential that impacts on GI corridors, such as Witton Run, are recognised even when not made up of designated sites, if the Greater Norwich GI strategy is to have any value.

Reepham:
1007: This is STW expansion. If expansion is necessary at this STW, there will need to be mitigation and/or compensation with regard to impacts on CWS
1006: There are potential impacts on CWS 1365, which need to be considered

Sprowston:
0132 We are pleased to see that GI constraints and opportunities are recognised. However, need to ensure that allocation allows for protection and enhancement of GI corridor.

Taverham:
0563: Recognition of impact on CWS is recognised but need to ensure no development within CWS, plus buffer to the CWS, if this is taken forward.
0337: Buffer to Marriott's Way CWS needs to be recognised

Thorpe St Andrew:
0228 and 0442: Pleased to see that the impact on CWS 2041 and GI corridor seen as a major constraint and that all sites proposed will have an adverse impact. These sites should not be allocated.

Norwich:
Deal ground 0360: Previous permissions allow for protection and enhancement of Carrow Abbey Marsh CWS. There is great potential for restoration of this CWS as a new nature reserve, associated with the development and a key area of GI linking the city with Whitlingham Park. This aim should be retained in any renewal of the allocation and new permissions

0068: Development should not reach up to riverside but allow for creation of narrow area of natural bankside semi-natural vegetation to link with similar between adjacent river and Playhouse. This will help to deliver the (Norwich) River Wensum Environment Strategy

South Norfolk

Barford:
0416: We are pleased to see that biodiversity constraints are recognised but there is a need to mitigate for impacts on adjacent CWS 2216 though provision of buffer.
1013: There are potential biodiversity constraints, with regard to semi-natural habitats
 
Berghapton:
0210: We are pleased to see that impacts on CWS, existing woodland and protected species seen as major constraint.

Bixley:
1032: There may be biodiversity constraint in relation to habitats on site

Bracon Ash:
New settlement 1055: We are pleased to see that affects CWS and priority habitats are recognised. There is potential for significant additional impact on Ashwellthorpe Wood SSSI. This site is open to the public but is sensitive and not suitable for increased recreational impacts, owing to the wet nature of the soils and the presence of rare plants, which are sensitive to trampling. We are also concerned about increased recreational impacts on of a new settlement on Lizard and Silfield CWS and on Oxford Common. These sites are already under heavy pressure owing to new housing in South Wymondham. Unless impacts can be fully mitigated we are likely to object to this allocation if carried forward to the next stage of consultation.

Broome:
0346: We are pleased to see recognition of constraints relating to adjacent Broome Heath CWS

Caistor
0485: see Poringland

Chedgrave:
1014: There may be biodiversity constraints with regard to adjacent stream habitats

Colney
0253: Constraints relating impacts on existing CWS 235 and impacts on floodplain may be significant and should also be recognised as factors potentially making this allocation unsuitable for the proposed development

Costessey
0238: We are pleased to see constraints in relation to CWS and flood risk are recognised.
0266: We are pleased to see constraints recognised. The value of parts of this porposed allocation as a GI corridor need to be considered.
0489: We are pleased to see that constraints relating to river valley CWS recognised. This site should not be allocated

Cringleford
0461: The whole of 0461 consists of semi-natural habitat, woodland and grazed meadow and should not be allocated for development. In addition adjacent land in the valley bottom is highly likely to be of CWS value and should be considered as such when considering constraints
0244: This site is currently plantation woodland and part of the Yare Valley GI corridor. It should not be allocated, for this reason

Diss:
We support the recognition that constraints regarding to biodiversity need to be addressed. Contributions to GI enhancement should be considered. 1004, 1044 & 1045 may cause recreational impact on CWS 2286 (Frenze Brook) and mitigation will be required.

Hethersett
0177: We are concerned that constraints with regard to impacts on CWS 2132 and 233 are not recognised. These two CWS require continued grazing management in order to retain their value and incorporation as green space within amenity green space is not likely to provide this. Development of the large area of 0177 to the south of the Norwich Road would provide an opportunity for habitat creation and restoration

Marlingford:
0415: We are concerned with the biodiversity impacts of development along Yare Valley and on CWS and habitats on the valley slopes (including CWS in Barford parish). If this area is allocated it should only be as a semi-natural green space that is managed as semi-natural habitat

Poringland:
0485: We are pleased to see recognition of constraints relating to CWS. Any country park development should ensure continued management and protection of

Roydon
0526: There is potential for recreational impacts on Roydon Fen CWS. This impact needs to be considered for all proposed allocations in Roydon and if taken forward mitigation measures may be required. We are also concerned about water quality issues arising from surface water run-off to the Fen from adjacent housing allocations and these allocations should only be taken forward if it is certain that mitigation measures can be put in place. Roydon Fen is a Suffolk Wildlife Trust nature reserve and SWT may make more detailed comments, with regard to impacts.
Although appearing to consist mainly of arable fields this 3-part allocation contains areas of woodland and scrub, which may be home to protected species. These areas should be retained if this area is allocated and so will represent a constraint on housing numbers.

Toft Monks:
0103: We are pleased to see that a TPO constraint recognised and value as grassland habitat associated with trees should be considered.

Woodton
0150: Buffer to CWS could be provided by GI within development if this allocation is taken forward.
1009: Impacts on CWS 94 may require mitigation.

Wymondham:
Current allocations in Wymondham have already led to adverse impacts on CWS around the town, through increased recreational pressure. Although proposals for mitigation are being considered via Wymondham GI group, further development south of town is not possible without significant GI provision. This applies particularly to 0402. Similarly, there is very limited accessible green space to the north of the town and any development will require significant new GI. 0354 to north of town includes CWS 215, which needs to be protected and buffered from development impacts and CWS 205 needs to be protected if 0525 is allocated.

Bixley
1. GLNP1032 Site to north of B1332 Boundary Farm: This site would contribute dramatically to the linear vision of the conurbation. Grade 2 agricultural land. Drainage problems However it could offer industrial and employment spaces necessary in this conurbations.

Caistor St Edmund
2. GNLP0485 This huge site would at a stroke integrate Arminghall/Bixley with the Poringland conurbation. It has significant landscape, archaeological and environmental issues . It is far too far from any facilities and would be unsustainably reliant upon cars. Oppose

3. GNLP0131 This is a smaller site but again unsustainably far from public transport, excessively reliant upon cars with no sidewalk in the vicinity and little prospect of being able to construct one. Oppose

4. GNLP0491 This would significantly alter the form and size of Caistor St Edmund on archaeologically important site in open countryside. It is a form of 'backland' development. Access is severely limited. No access to public transport, no sidewalks to village and schools. Oppose

Stoke
5. GNLP0494 The access to this site is significantly constrained. Oppose

6. GNLP1047 Access to this site is severely constrained. It is former RAF site so may well be subject to contamination. Site dominated by the microwave towers. Form would consolidate development each side of the Stoke Road leading to further infill development. Oppose

Framingham Earl/Pigot
7. GNLP0321 To North of B1332 next Boundary Farm - detached from the conurbation by Poringland Wood. Contribute to the linear profile of the conurbation. This could offer employemnt and business opportunities that the conurbation is dramatically short of.

8. GNLP0589-A This would exacerbate the 'octopus' nature of the conurbation and would detract from an area of scenic value otherwise sadly lacking in this area. Favoured by GNLP. Opposed

9. GNLP0589-B Leading on from the development of the Long Road, Hibbett and Key site and the EACH site this would be a logical development. It would mean the loss of significant landscape value in Spur Lane. If it could be developed at a distance from the tree lined Spur Lane it might well be viable. Will have a significant impact upon the subterranean drainage flow towards Long Road and Poringland surface water drainage system. Favoured by GNLP. The overall triangle site has already been intruded upon and there is no reason not to develop the whole Pigot Lane Spur Lane and Long Road area.

10. GNLP0391-A East of Hall Road - semi-detached from the village - contributing to the 'octopus' of development with drainage issues. Intrudes upon an an area of landscape value between Fram Earl and St Andrew's Church. Oppose

11. GNLP0391-B North of Burgate Lane Similar arguments to those against the site south of Burgate Lane Oppose

12. GNLP0003 Isolated site in open countryside, contrary to policy, detached from the conurbation should not even be considered as a valid site. Oppose

Poringland
13. GNLP0223 Significant access problems with no comfortable access through the Norfolk Homes development. Would alter significantly the 'shape' of the conurbation into an form of an 'octopus'. Would reduce the distinctions between Poringland and Stoke. Would have significant Governance issues between Stoke and Poringland. Would significantly negatively alter the drainage problems of Boundary Way - known surface water, flooding issues. Favoured by GNLP doc. Oppose

14. GNLP0169 Would contribute to the disjointed form of development of the conurbation. Extends beyond the comfortable walking/ cycling distance to schools, doctors and shopping. Makes the village an 'octopus' with its tentacles extending into open countryside. Dominant over the village approaches from Shotesham. Favoured by GNLP. Oppose

15. GNLP0316 Land North of Bungay Road, east of Rectory Lane and south of White House. This land has significant environmental assets, hedges ponds - it would require a significant environmental audit. Would contribute to the perceived linear vision of the conurbation. Site has significant landscape value as the headwaters of the Well Beck and is one of the few views of landscape available to the road traveller between Poringland and Brooke. Oppose

16. GNLP0280 Some problems over access, perhaps requiring the demolition of one house. Drainage problems. Disconnected from the built form of the conurbation. Would contribute to the linear form of the conurbation. Oppose

My client has previously put forward three sites for development, although two are adjacent to each other and effectively count as one site: Land at Park Farm, Bungay Road (GNLP 0323) and Land at Octagon Farm (GNLP 0321 and 1032). Further submissions regarding these sites are made below.
Site GNLP 0323 - Land at Park Farm, Bungay Road, Bixley
Site GNLP 0323 was put forward for employment uses and has been assessed as unsuitable for development in the HELAA because of its distance from other facilities and possible access issues. The site is already in use for agricultural purposes and is already served by an existing highway access. My client has sufficient landholdings in the area to ensure that an adequate highway access can be created.
The site provides an opportunity to serve an alternative employment market to that catered for by sites on the edge of Norwich, which typically command higher rents. Furthermore, it enables employment uses to be provided closer to existing settlements to the south of Norwich and will assist in reducing journey times and trip lengths to access such facilities. This benefit is not acknowledged in the HELAA.
It is noted that the site has an amber rating for landscape impact in the HELAA meaning that detrimental impacts are likely but that these could be mitigated. The site is well-screened and surrounded by land within the same ownership. There is significant potential to mitigate any potential landscape impact such that this need not be a barrier to allocation. The proposed site lies in an area of localised lower lying topography, which combines with nearby vegetation helps to limit views of the existing farm buildings from publicly accessible areas. A carefully designed layout would work with this localised topography to limit both short range and long-range views towards the development. The design would also work with the locally characteristic vegetation noted in the published Landscape Character Assessment, such as small areas of woodland and hedgerows with trees, to further limit or mitigate views.
It is noted that the site has an amber rating for townscape impact in the HELAA although it is not clear from the text what aspect of the townscape is likely to be impacted on. As with landscape impact, the HELLA indicates that such impacts could be mitigated and for the reasons identified above in terms of landscape impact, this is certainly the case at this site.
Of further significance is the fact that the site is capable of conversion to alternative uses under the GPDO. This is a valid consideration to take into account when considering the suitability of the site for allocation.
All other matters are considered to be capable of mitigation through the detailed design consideration of the development proposals.
As such, my client objects to the site being deemed unsuitable in the HELAA and requests that it is considered as a possible site allocation for employment uses in the site proposals element of the plan. The precise mix of uses will be the subject of further detailed design work and discussion with the Councils.
Site GNLP 0321 Land adjacent to Octagon Farm, Bungay Road, Framlingham Earl
Site GNLP1032 Land north of Octagon Farm, Bungay Road, Bixley
These sites are immediately adjacent to each other and are separated by an existing gallery and studio. This facility includes a craft shop and a café and has a small visitor car park. It is well-used by the local community and is opposite a site that is currently being developed for housing (LPA ref 2012/0405 and 2017/2485).
It is noted that site GNLP0321 falls within Framlingham Earl and GNLP1032 falls within Bixley. The site as a whole reads as part of Framlingham Earl and therefore should be considered as part of this Key Service Centre and the access to the supporting facilities therein.
My client has put both sites forward for consideration and both are assessed in the HELAA as suitable for development. Site 0321 is proposed for mixed use development involving 60 dwellings, commercial, business and light industrial floorspace. Site 1032 is proposed for mixed use purposes involving commercial business use and 100 dwellings. The sites have a combined area of 8.48ha and provide the potential to deliver c.160 new homes with employment uses. The exact development yield and nature of the commercial uses will be subject to detailed design work and further discussions with the relevant Councils.
Given the proximity of the sites, these further submissions consider the two sites together. To assist the Council in its further assessment of these sites for allocation in the GNLP, the following is provided:
A Transport Technical Note prepared by Royal HaskoningDHV (Appendix 1). This provides a summary of the existing accessibility of the sites for all modes of transport and its connectivity to supporting services. It explains the measures necessary to create a safe and appropriate means of access to the sites. It concludes that it there are no highways access or infrastructure provision issues that should prevent either site for coming forward for allocation of the proposed uses.
The note includes indicative access arrangements for each site, which take into account the location of the access for the consented scheme opposite and indicate sufficient visibility splays. This would be the subject of further discussions with the highway authority following refinement of the proposed development.
The note also includes potential infrastructure improvements within the local highway. These involve potential bus stop enhancements and pedestrian/cycle links. The potential will also exist for providing pedestrian and cycle links through the development sites - either in addition to those along the highway or instead of. This would be a matter for further consideration as the design progresses. For now, it is clear that the potential exists to deliver such improvements.
* A Drainage Note prepared by Royal HaskoningDHV (Appendix 2). This provides a summary of the existing drainage infrastructure and the opportunities arising at this site. It explains the measures necessary to deliver a suitable drainage strategy and concludes that there are not any drainage issues that should prevent either site for coming forward for allocation of the proposed uses.
* A Landscape Technical Note prepared by Pegasus Group (Appendix 3). This identifies that the site is visually contained on three sides by development currently under construction and woodland, such that its visual envelope is largely limited to the immediate vicinity. It concludes that the site is well contained and that it is possible for a development scheme to be prepared that will not materially impact on the landscape character of the immediate area. It also demonstrates that the amber rating in the HELAA of the site GNLP1032 is not justified by the evidence on site. As a consequence, there are no landscape issues that cannot be mitigated and as such landscape impact is not a barrier to the allocation of either site. The Site Proposals document acknowledges that the proposed uses mirror the approved scheme on the opposite side of the road. It goes on to note that the presence of the woodland adjacent to the site means that the development is not contiguous with existing development on that same side of the road. We consider that this does not render the site inappropriate for allocation in light of the extension of built form on the opposite side of the road. The redevelopment of the proposals sites provides the opportunity to provide a new landscape buffer that will form the new edge to the settlement and prevent further linear development.
This additional information provides further evidence to support the allocation of these sites for housing and employment uses. The site is under the control of a landowner that has significant experience in development (as is evidenced by their involvement in the site on the opposite side of the road) and is able to bring the site forward for development in the early years of the plan.