GNLP2149

Objection:

Area GLNP 2149 development proposal and Blofield Plan development limit extension.

The proposal has been rejected for by both Blofield Parish Council and Broadland Planning Department within the past 6 months. It should therefore be rejected from the GNLP. In addition, the proposed extension to the settlement limit should be returned to its previous boundaries.

Planning Constraints:
Blofield Parish Council highlighted the fact that land supply is calculated <5 years on JCS criteria but at >8 years on the most recent and relevant SHMA criteria so it is no longer possible to maintain that there is not an adequate land supply.
The NPPF principles of sustainable development under the contact of JCS Blofield village stated that the village was to receive 50 or fewer more houses. Currently >500 have been approved for the settlement and the parish as a whole. This represents a 30% increase since 2011 and has Blofied contributing 25% of the 2000 units total for the whole 16 small sites identified in Broadland. There is clearly no justification on planning grounds for further speculative development in a semi-rural village which is suffering from creeping urbanisation.
The proposed extension to the settlement limit and any development should be rejected and refused..

Access:
Contrary to the planning application and submission, the proposed access
is not 4.4 to 4.5m along its whole 100m length. It is 4.1m at the access point from Yarmouth Road. Existing standards for Private Access Roads and Shared Private Drives off approach roads serving not more than 3 properties should be a minimum of 3.65m. The drive has a choke point of 3.6m between two private properties. This is also less than the recommended 4.5m for shared driveways. There is no provision for a safe walkway for pedestrians or vehicle passing bays thus increasing significantly safety issues should the drive be used for further property access.
the drive has also been identified as being of inadequate width for fire engine access thus complicating firefighting provision and significantly increasing safety risks.
The proposed extension to the settlement limit and any development should be rejected and refused.

The Site:

Ecology. The site has been left fallow for over 25 years. In that time trees and shrubs have established and developed in to a mature habitat for a broad range of invertebrates (inc. moths, bees and butterflies), reptiles (inc. lizards, birds (including owls) and both small and medium sized mammals (inc. bats, hedgehogs, foxes and deer).
The Ecology Report, submitted with the planning application, which represented a brief 'snapshot' of the site with limited scope and duration, severely understated what is a thriving diverse habitat.
The proposal presumes destruction of this habitat which is contrary to the NPPF Section 11, Policy EN10 of Broadland Development Management DPD (2015)Biodiversity and Habitats and Blofield Neighbourhood plans. The destruction of a tree, identified in the Ecology report as having potential for bat roost is of notable concern. Thankfully the bats still feed over the area.
The removal of over 80% of the 100+ trees of differing levels of maturity notwithstanding shrubs and other flowering plants is contrary to Policies HOU4 and ENV2 of the Neighbourhood Plan.
The proposed extension to the settlement limit and any development should be rejected and refused.

Noise. Noise from the A47 is significant and intrusive. Noise is, after air pollution, the most harmful environmental stressor according to the World Health Organisation (WHO). Noise monitoring submitted with the planning application for this site was to the most part outside of the proposed area. The one instrument within the proposed development area exceeded the Noise Exposure Category C (BS4142) at levels where there should be a strong presumption against permitting development. Indicative monitoring suggests that within the area proposed for development the noise levels will exceed Category D (BS4142) where planning permission should normally be refused and confirm that noise levels will be Noticeable and Very Disruptive. A WHO report states that levels above LAeqdB(A)55 for outdoor living areas (i.e. spending day in garden) induces, among other effects, serious annoyance, aggressiveness and interference with social behaviour.
Engineered mitigation proposals should be like PPE a last resort and not a justification where development is unnecessary and unwelcome.
The proposed extension to the settlement limit and any development should be rejected and refused.

Pollution. The screen of trees between the A47 and existing properties is recognised by the scientific community as an asset capable of adsorbing harmful pollutants such as CO2 and particulate emissions PM2.5 and PM10 from road traffic. The destruction of this screen will place both existing and proposed residents at significant increased health risk.
This is contrary to Policy 1 of the JCS [failing to contribute to addressing climate change and protecting environmental assets for residents and visitors] and non-compliant with NPPF Section 10 - Meeting the Challenge of Climate Change [development proposes a negative contribution].
The proposed extension to the settlement limit and any development should be rejected and refused.

Site Assessment_GNLP2149 is supported. The site remains available/suitable for development. The assessment shows Access/transport/roads as 'amber'. It should be notated 'green'. NCC Highways (letter: Jonathan Hanner ref:9/5/18/1043-19/7/18) confirms that suitable access can be achieved with minor works: "...In order to cater for the additional traffic generated...widen the access to ensure a minimum width of 5m for the first 10 metres into the site. This can be simply achieved by relocating the kerb and resurfacing the grass verge (to coincide with the existing length of surfacing)." I can confirm the required minor works are in the public highway/landowners control and deliverable.

After much thought and consideration Blofield Parish Council would like to make the following response to the proposals contained in the Greater Norwich Local Plan New, Revised and Small Sites consultation : -
Blofield and neighbouring parishes have already seen a large number of developments built or approved. The local infrastructure cannot cope with what is happening now and the council has specific concerns about:
* The capacity of the access to the A47 (Cucumber Lane roundabout). The existing planning consents have taken forecast flows to the limit of the capacity.
* The provision of essential local services including healthcare and schools. The existing developments have overloaded the services and there is no capacity to cope with the impact of the housing which is being built let alone the significant additional houses that have planning permission. There are no credible proposals to improve the situation.
* The capacity of the Postwick Hub if large housing developments occur in the locality: were these housing proposals factored into the traffic flow forecasts when the junction was designed? We already have tailbacks onto the A47 from the slip road that are as bad as before the improvements to the 'hub'; significant additional flows through that junction as a result of housing growth and the NDR won't improve the problem.
* Loss of Grade 1 or 2 agricultural land at a time when there is concern post-Brexit about food security.
* The ability of the water supply and treatment infrastructure to service the proposed housing developments in and near the parishes.
The current Local Plan allocated 'about' 50 houses to Blofield itself and 'about' 25 to Blofield Heath giving the parish of Blofield growth of, say, 75 - 100. The actual growth under the current Local Plan will be about 500 houses - which is 500% of the planned number, casts serious doubt on the utility and effectiveness of Local Plans, and is crippling local services.
Given the extent of development experienced under the current Local Plan the Parish Council opposes all the proposed sites within the parish put forward in the GNLP New, Revised and Small Sites consultation: the parish needs time to absorb the current developments and for the infrastructure issues to be addressed by bodies such as NCC.