GNLP1055

This application includes, at its centre, the Grade 2* Listed Stanfield Hall and its surrounding grounds of circa 45 acres, non of which is available for inclusion within the proposal which, for clarity, is submitted without the knowledge or consent of the owners of Stanfield Hall, none of whom support this proposal.
The premise that this Application is based on need is wholly without foundation.
This objection should be regarded as a 'holding' objection, if a more detailed objection is deemed necessary then legal counsel will be engaged to submit in due course.

We object on the grounds of:

* Property allocation will already be met by other smaller developments across the county, therefore there would be no need for a development of this magnitude, in this area.

* Too close to Wymondham to have it's own identity, and will be a huge drain on already stretched services and amenities within the community. Whilst the description above paints an idillic picture of a market town, in reality the local schools, GPs and supermarkets are bursting at the seems. That is even before the existing plans for Wymodnham have been completed. The impact on those services whilst any development is taking place will add huge disruption because as with most developments any services and amenities are only built at completion.

* Wymondham High Academy has already had planning permission granted for 2019 to facilitate the new Birchgate development in Silfield, as part of the exiting Greater Norwich Plan. As a result, the high school will be at capacity and any additional housing will result in too many pupils needing to travel long distances, or a totally new high built within the surrounding area will be needed.

* The current road infrastructure is just about fit for purpose, and would mean the total reworking of Bridge Road due to a weight restricted bridge. Within the past six and a half years that we have already noticed a significant increase in vehicles using Silfield Street as a back road onto the A11, towards Mulbarton and into Wymondham. To the extent that we no longer feel that it is safe for our children to use this once quiet road to ride their bike safely as there are no footpaths, or capacity to add them. This will only increase, and whilst the development takes place all the construction traffic would add a huge danger to existing residents. There are a lot of concealed driveways around hidden bends which would again increase the risk of pulling out of or driving onto our driveways.

* Access to Wymondham and the train station via Silfield Road already has traffic bottleneck issue, and flooding. This then means that there is only once access to Wymondham via the Mulbarton Road. Adding in large amounts of additional dwellings would cause huge disruption because all traffic will need to come out via Bridge Road

* We have chosen to live in a rural area because we enjoy a small community away from the town. Although we do not have a right to the view have a purposefully chosen a farming environment to bring our family up in and to live in the future. This choice will be taken away! We also have a concern it will devalue in our property and make it unsellable as it would no longer be in keeping with any new surroundings.

* There are currently no mains sewage or fuel utilities in place.

* The area is susceptible to ground water flooding

The parish council discussed the 5 sites currently put forward within Bracon Ash.
GNLP0549
The site has been put forward for 9 houses but there have already been 3 separate planning applications for this site, all were refused. The last one for 5 houses was turned down for a number of reasons including objections from the highways department due to the inadequacy of the road, the lack of footpaths in Hawkes Lane and the B1113 to Mulbarton, plus the unsuitable exit into the B1113.
The parish council objects to this being included in a local plan because of the inadequate road and lack of footpaths but also because the site is extremely wet and there are no riparian rights to enable surface water drainage.
GNLP0299
This site already has planning permission for 15 houses. There is approved planning permission for 7 houses therefore there are already an additional 8 houses that could be built over and above the 7 approved.
The parish council objects to this being included in a local plan
GNLP0195
This site is on the Bracon Ash and Mulbarton boundary. The access to this site would have to be via the existing housing in Mulbarton.
It would be very separated from Bracon Ash and residents would feel more affiliated to Mulbarton. The parish council agreed that this site should not be included because there should be a strategic gap maintained between the two villages, Mulbarton and Bracon Ash.
The parish council objects to this being included in a local plan
GNLP0026
The parish council does not object to this being included in a local plan.
GNLP1055
The parish council was totally opposed to this site due to the size. It is a huge development on a green field site impacting directly on the grade 2* listed Stanfield Hall. This building is an outstanding landmark and it would be severely impacted by building all around it.
This proposed site would impact on several parishes creating significant traffic on unsuitable country lanes. The B1113 would be unable to cope with the additional traffic throughout its length from Wymondham to Harford Bridge.
There were serious concerns that one of the largest industrial employers, Lotus Cars, had been subject to repeated complaints due to excessive noise pollution from its test track. The environmental health team has been involved on a number of occasions and the people currently affected by the noise nuisance are located much further away from the track than the proposed development. It would be a significant detriment to anyone living so close to either the factory or the test track.
Lotus Cars has many confidential projects and these are tested on their track; the need for privacy and isolation is necessary to protect the company, any intrusion could have a negative effect on the longevity of the company in this location.
The parish council objects to this being included in a local plan
The parish council remains deeply concerned that South Norfolk Council seems to be getting an unacceptable proportion of development and Norwich City Council has very little.
The plan is named the Greater Norwich Local Plan but the reference in the title does not seem to apply to the city of Norwich itself.

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.

[Representation text in respect of specific sites and Sustainability Appraisal as under - see also Growth Options - general comments on plan approach are logged against Q66. The full submission letter is attached]

Honingham Thorpe (site GNLP 0415 A to G)
This site is located to the immediate south of the A47 between the small settlements
of Honingham and Easton.

There do not appear to be any known designated heritage assets within the site
directly but given the scale of the map it is hard distinguish precise boundaries. There are however a number of designated heritage assets near the site which will need to be taken into account as part of the allocation process. These include the Grade I listed Church of St Peter and the Grade II* listed Church of St Andrew. Given the high grading of these two designated heritage assets Historic England will be a statutory consultee in any prospective planning application affecting the setting of the churches. There are also seven Grade II listed buildings surrounding the site. These include Church Farm House, the Barn at Church Farmhouse, Malthouse, The Old Hall, the Barn at The Old Hall, The Old Horse and Groom and Greenacres Farm
House.

The site allocation is largely undeveloped open land, there are also two records
indicating the presence of ring ditches within the site area. As the area has not been
developed before, therefore the relative lack of recorded evidence should not be
interpreted to mean that the site has no heritage interest rather than no one has had to undertake any investigation of the site. Therefore it will be important to consider the possibility that the site may contain undiscovered archaeology and to ensure that the impacts on potential archaeological remains within the site are considered. Consideration may also need to be given to other local designated and undesignated heritage assets, but the local and county conservation/historic environment services will be best placed to provide advice on this. The Site Proposals document makes no reference to the presence of designated heritage assets. We are however pleased to see that the Site Proposals document recognises the need for a very significant amount of further work to be carried out in order to investigate the opportunities and constraints of the site. We agree with this assumption and request that extra work involves the production of a Heritage Impact Assessment (HIA) and an exploration of potentially undesignated or undiscovered heritage in the form of archaeology. The HIA should consider landscape implications, the setting of heritage assets and how they relate to their surroundings. These findings should inform the site allocation process.

West of Hethel, Stanfield Hall Estate (site GNLP 1055)
The site contains the Grade II* listed Stanfield Hall and the associated Grade II listed bridge across the moat east of Stanfield Hall. It is not exactly clear from the maps but it appears that the Grade II listed Limetree Farmhouse also all within the site boundary. There are a number of other Grade II listed buildings around the north and western boundaries of the site which could also be affected; these are generally farm buildings, cottages, a schoolhouse and Browick Hall. The rural setting and relationship of the properties to the surrounding land will therefore be important aspects of these buildings' significance.
The site also contains a number of historic features which have not been designated
but maybe of local importance. A large expanse of land to the east of Stanfield Hall
and between St Thomas' Lane to the north and Wymondham Road to the south is a
former World War Two military airfield, Hethel Airfield. The airfield was used by the
United States Army Air Force as a heavy bomber base. In 1964 part of the site was
taken over as test track and factory for Lotus Cars. Also running through the site to
the south of Hall Farm is the route of the 1881 Wymondham and Forncett Branch
Railway - the track was lifted in 1952.

Given the high grading of Stanfield Hall, Historic England will need to be a statutory
consultee as part of any prospective applications for planning permission. Stanfield
Hall itself dates from 1792, the moat with its Grade II listed bridge is thought to be an 18th century ornamental landscape feature. The abridged version of Norfolk County Council's Historic Environment Record (HER) indicates that Stanfield Hall has
medievl origins with the current structure being built upon the site of an earlier manor.
A great deal of the historic significance of Stanfield Hall is connected with the two
principal phases of building in 1792 and the early years of the 19th century that
resulted in major early gothic interiors and the house's exterior elevation and
landscaping. The latter includes mature planting and incorporates a gate lodge on
the main road. The principle windows of the Hall command views to the south, it is
unclear if the site was actively managed as part of the Hall's designed setting it does
lie within principle views. The allocation site constitutes the wider setting of the
building and makes a particular contribution to its historic significance. The
development of this site will result in harm to the significance of the building's wider
setting and this should be taken into account when considering the allocation of this
site. The site allocation entirely surrounds Stanfield Hall and this is of concern.
The Site Proposals document makes no reference to the presence of designated
heritage assets. We are however pleased to see that the Site Proposals document
recognises the need for a very significant amount of further work to be carried out in
order to investigate the opportunities and constraints of the site. We agree with this
assumption and request that extra work involves the production of a Heritage Impact Assessment (HIA) and an exploration of potentially undesignated or undiscovered heritage in the form of archaeology related to the medieval origins Stanfield Hall as well as more recent archaeological finds associated with the railway and airfield. The HIA should consider landscape implications, the setting of Stanfield Hall and how it relates to its surroundings. These findings should inform the site allocation process.

Comments on Interim Sustainability Appraisal
The historic environment should be considered as part of the sustainability appraisal
process. We recommend that these comments should be read alongside our Advice
Note 8, available here: https://historicengland.org.uk/imagesbooks/
publications/sustainability-appraisal-and-strategic-environmental-assessmentadvice-
note-8/
Key Sustainability Issues
We would suggest that the starting point for considering Key Sustainability Issues for the Historic Environment should include:
- Conserving and enhancing designated and non-designated heritage assets
and the contribution made by their settings
- Heritage assets at risk from neglect, decay, or development pressures;
- Areas where there is likely to be further significant loss or erosion of
landscape/seascape/townscape character or quality, or where development
has had or is likely to have significant impact (direct and or indirect) upon the
historic environment and/or people's enjoyment of it
- Traffic congestion, air quality, noise pollution and other problems affecting the
historic environment
We would expect to see consideration of opportunities. It is considered that the
historic environment can make a significant contribution to the success of
development and there may be opportunities for the enhancement of the historic
environment which comes from sustainable development proposals. It is considered
that the Sustainability Appraisal should highlight these opportunities. Examples of
the sorts of opportunities that can be used can be found in our guidance notes in the
links above.