GNLP2162

This site is outside the development plan and is totally disproportionate in size for an "other" village. The surrounding area of Chapel Road and Dumbs Lane have repeated flooding problems with unsolved drainage issues.
The Council doubts whether the existing sewerage system would be able to cope. Local roads are very narrow with no footpaths leading to the school.
Hainford has minimal facilities other than a school and an infrequent bus service. New developments will only increase traffic on the narrow lanes of Hainford as residents access employment or shopping.

The proposed site is unsuitable for many reasons: no viable access to the site which areas are also prone to flooding issues, and development of this type and size would negatively impact on the village and its rural aspect. There are limited ameneties in the village, a limited bus service and the existing school is already oversubscribed.

We have lived in Harvest Close for 8 years and our house backs on to proposed development. We understood at the time of purchase that this land was a green field site for 25 years from the time the house was built in 1999. Therefore we understood there would be no possibility of this land potentially being built upon until 2024. This village has a high water table and the roads frequently flood now, with further development of this village the flooding problems could only worsen. Our back garden, which backs on to proposed development, floods now when there is a prolonged rain or a heavy downfall. Therefore if this development goes ahead we can expect our drainage and flooding problems to worsen and this could affect our house. Dumbs lane is not a suitable access, it is narrow and cars speed along this now, making it dangerous for pedestrians and Chapel road frequently floods in several places now.

We do not have enough amenities fir the people we do have withiut adding more

Hainford is a small village with no amenities , the primary school would not have capacity to cover any increase due to any further residential sites . Access to the site is either from dumbs lane which is only suitable for single file traffic and passing via passing places or via Hainford close which has no street lighting and access is being proposed on a bend .

Hainford's current status within the Planning Policy hierarchy is that of 'Other Village' having only a range of basic services and suitable only for infill and, where there is an accessible primary school, only small scale housing allocation.
It is also consistent with the Parish Plan, set up following consultation with residents, which concluded that a high proportion of residents were opposed to any further development in the village and that if there were to be any development it should be small scale and take the form of single dwellings or conversion of existing buildings. The overwhelming view of parishioners was that the local environment should be protected and preserved. This outcome was based upon a desire to retain the rural aspect and the recognition of the limited infrastructure, limited power supplies, drainage problems, narrow roads (traffic speeding was seen as a problem which is continuing)
Site GNLP 2035 Cromer Road
This site is outside the current development boundary and being remote from the main part of the village is totally disconnected from it with no pavements to access the school. There are no nearby facilities of any kind and any residents would have to rely on motor vehicles or the limited public bus service to access employment or shopping. Access to the development would be from the A140 which is difficult with fast flowing traffic in both directions. The site has a risk of flooding and there are nearby protected woodlands and species.
Site GNLP 2162 Rear of Harvest Close
This site is again outside the current development boundary and is totally disproportionate to the categorisation of "other" village". The surrounding area particularly Chapel Road and Dumbs Lane have repeated flooding problems with unresolved drainage issues. The Council is also doubtful that existing sewerage systems could cope with this size of development.
The local road system is very narrow and has no pavements to access the school making it totally unsuitable for an increase in housing in this area.
In summary Hainford is a village with very few facilities other than a small primary school and an infrequent bus service. It is totally unsuitable for developments of this size.

Proposed Site GNLP2162, Harvest Close, Hainford.

I object to the proposed development.

I am not a planning expert, so I am not sure whether my points on the proposed development plan are relevant, however, I feel that I need to make you aware of the following observations:

May I initially suggest that residents, not just those who live adjacent to or opposite, or living nearby to the the proposed site may not be aware of the proposed development, and would suggest that they need to be personally formally advised by letter. I only became aware of the application when a member of my family mentioned that they were aware of several development applications in the Hainford area, including this very latest proposal.

In respect of the actual development application "plans", I have the following observations:
Although highway access points are shown, these do not actually reflect the very restricted access that they provide, both from Harvest Close and Dumbs Lane.
Why aren't all the roads within the proposed site shown?, as I'm guessing that there will be more required than just the one shown.
Why aren't the positions and orientation of the residences within the proposed site shown?.
Why are the "Open Spaces / Play Areas" sited near to the existing properties rather than away from them. If the development were to go ahead, the new property purchasers would be aware of the fact that the Open Spaces / Play Areas were on the plan, whereas existing residents would have them forced upon them.
There is a "Landscaping Buffer" to open countryside shown on the plan to the north of the development. What will be done to separate the development from the existing properties on Harvest Close to maintain their privacy?
**On the Application document, completed by Geoff Armstrong, page 15, Utilities8(a) it states that there would be a gas supply. As far as I'm aware, this area of Hainford does NOT have access to a mains supply gas**.

Not withstanding the above observations on the proposed development I would like you to consider the following points:
**Some considerable time ago, the residents of Harvest Close adjacent to the field where the development site is proposed, looked at the possibility of purchasing some of the field so that they could extend their back gardens. We were advised by the Council that this would not be possible as it was "prime agricultural land" that had to be retained for agricultural use only and, to add to this, it would extend the gardens beyond the "settlement boundary".
**Approximately six years ago, the field came up for sale, at which point residents had concerns as to what was going to happen with the field. I visited Broadland District Council at the time, and had a very lengthy conversation with a member of staff who was very knowledgeable about the planning process.
He said that the Council would always look to use "brownfield" sites as opposed to "greenfield" agricultural land for housing development, and that the field would remain a field, and emphasised that the Council would more likely support applications inside a "settlement boundary", and that preservation of the countryside outside the "boundary" was always a priority.
The comments that he made included the previous points that we had been told when looking into the possibility of extending our back gardens, in that the land had to continue to be used for agriculture, and the field was outside the "settlement boundary". To add to this, the local road network was already barely satisfactory to handle the existing traffic. Further, he said the village had very few supportive facilities, with no shops, one pub, and a small school. I passed on this message to some of my neighbours, and they were pretty happy that the field would remain as a field.
**The recent application for a housing development has provided a great deal of concern, and I feel that, as a someone who moved to Harvest Close for its quiet and countryside location, I must strongly object to having my outlook impacted upon by a residential site that will overlook mine and other properties. To add to this, I did not move here to be next to "Open Spaces / Play Areas" with all the potential activities and noise that this could create.
**The two proposed access points are completely unsuitable. Although being comparatively small, Harvest Close already has significant daily traffic movements that would be exacerbated by further traffic entering and leaving the Close from Harvest Close. Also, as with the access from Dumbs Lane, and already suggested by the Council on the planning documents, "The local road network to be unsuitable either in terms of road or junction capacity, or lack of footpath provision".
**In respect of the vehicular access from Harvest Close, if I remember correctly, a neighbour, who lived almost opposite the suggested road access point to the proposed development, was looking to put in a second driveway access to his property. However, this was turned down by the Council in that it could present a significant hazard to traffic coming into and leaving the Close. The proposed access roadway would surely present a far greater hazard than a single driveway.
**Local facilities are already very limited, with the village having just a church, a school that I gather is already fully utilised, a pub, and the local doctors surgery is already overburdened.

In summary, I feel that there are many reasons why this development should not be allowed as previously detailed, and hope that the Council stand by their statements:
Site Reference GNLP2162 - THE HIGHWAY AUTHORITY CONSIDER THE LOCAL ROAD NETWORK TO BE UNSUITABLE EITHER IN TERMS OF ROAD OR JUNCTION CAPACITY, OR LACK OF FOOTPATH PROVISION and, in respect of GNLP2162 and GNLP2035 jointly, that "IN CONCLUSION, DUE TO THE HIGHWAYS CONSTRAINTS, THE SITES ARE NOT CONSIDERED TO OFFER FAVOURABLE OPTIONS FOR HOUSING IN COMPARISON WITH SITES PREVIOUSLY SUBMITTED".

On behalf of our client Saltcarr Farms Ltd and Westmere Homes Ltd we wish to make representations to the Greater Norwich Local Plan (GNLP) 'New, Revised and Small Sites' consultation. These comments are made in light of the submission of our client's land at Harvest Close and Dumbs Lane, Hainford as part of the previous consultation in March 2018 - accordingly this land is included as one of the 'new' sites as part of the current consultation.
This representation primarily seeks to reiterate the case for our client's site and confirm their strong intent to promote either the whole site for a development of up to 60 homes to contribute towards the significant housing requirement of the Greater Norwich area or a one-hectare portion of the site to contribute towards the GNLP's small sites requirement. In addition, it also provides an expanded comparison between our clients' land and the full range of competing sites, drawing on the addendum reports accompanying both the HELAA and Site Proposals document.
To this end, this representation essentially seeks to reinforce our clients' previous submission dated 21st March 2018 now that we have the benefit of the updated evidence base documents. It should therefore be read alongside the information previously provided in respect of the site.

Site Promotion to Date
Section 5 of the Growth Options document, made available for consultation between January and March 2018, covered the identification of appropriate sites to meet the housing and development needs of the plan area. It clarified that approximately 600 sites were submitted towards the first 'Call for Sites' exercise held between May and July 2016. However, it also recognised that these sites may not necessarily be the best sites or in the right locations. To this end it confirmed that further sites, not necessarily considered in the HELAA, were sought at this stage.

This led to the submission of our clients' land between Harvest Close and Dumbs Lane, Hainford (now given the reference Site GNLP2162) for the delivery of a residential scheme of up to 60 dwellings. An indication of the extent and location of the site along with its relationship with the village is shown below. A definitive plan showing the precise site boundaries is once again included with this representation.

Following this submission, the site has now been included within, and considered by, the addendum updates to both the Site Proposals document and the Housing and Economic Land Availability Assessment (HELAA). The conclusions of both are reviewed below.
Since the last round of consultation, it has now been confirmed that the site is to be promoted on behalf of Saltcarr Farms Ltd and Westmere Homes Ltd, the latter now holding an interest in the development of the land in the event of its successful promotion.

Addendum to Site Proposals document
Following the assessment of our clients' site the addendum to the Site Proposal document states that the main constraint relates to highways and access. It also concludes that the site lacks footpath provision. In considering the site along with the other 'new site' West of Cromer Road (Site GNLP2035) the addendum to the Site Proposals document concludes that "due to highways constraints, the (new) sites are not considered to offer favourable options for housing in comparison with sites previously submitted". The document then restates that "if Hainford is identified for further growth GNLP0181 or part of it appears to be the least constrained site for residential development".
In respect of highways in particular this conclusion is curious - the Highways and Services Appraisal, prepared by Motion and submitted as part of our client's previous representation, clearly concludes that two alternative suitable vehicular access points can be provided to the site. One exits onto the modern cul-de-sac of Harvest Close with a second / alternative point of access then possible onto Dumbs Lane / Hall Road, the same road that would provide the sole access point to site GNLP0181. In addition, the Highways and Services Appraisal, along with the schematic site plan, demonstrates how the site would directly connect with the local footpath network leading to the core of the village.
To this end it is clear that highways constraints are not on their own an overriding factor that would count against the site. On the contrary there are a multitude of options in respect of how the site may connect with the local highways and footpath network. To this end we urge the Council to review their conclusions set out in the Site Proposals document, suitably drawing on the HELAA analysis assessed below.

Addendum to the HELAA
Firstly, please note that the HELAA currently states that the site is being promoted for 'up to 600 dwellings' - this is of course incorrect. It is being promoted for 'up to 60 dwellings'. Whilst we acknowledge that the 600-dwelling figure is a clear error rather than a misinterpretation of our previous representation it is important that this is both clarified and amended in all future documents.
Otherwise, the update to the HELAA presents a far more comprehensive review of the site than the Site Proposals document and allows for a clear comparison of its sustainability merits alongside the competing sites at the village. A summary of each site is shown in the table below - a green rating represents a lack of any constraint with an amber rating denoting a constraint that may potentially be mitigated.

The conclusions are unequivocal - our clients' land (Site GNLP2162) is substantially the least constrained when judged against the tests of the HELAA. To this end it should be considered the most sustainable. The only three areas where an amber rating is returned are:

Access: As described above and set out in the Highway and Services Appraisal submitted alongside the previous submission this should not be considered a constraint. Sufficient vehicular access can be achieved at two separate points of the site. In addition, it can readily link in with the local footpath network comprising the pavement running along the southern edge of Harvest Close. It is also noted that all sites in Hainford receive an amber rating under this category;
* Townscapes: The impact of the scheme on the rural character of Hainford would be minimal. The site directly abuts the northern edge of the settlement envelope and is of a sufficient size to allow for a generous scheme of landscaping along its northern edge to ensure views of the site from the open countryside and softened and broken up; and
* Transport and Roads: The highways network throughout Hainford is rural in nature, comprising narrow lanes often without pavements. Once again, this constraint effects all sites in the village as demonstrated by the matrix above. Our clients' site, however, is able to provide two vehicular access points, both of which provide almost immediate access to Newton Road to the west, a road which is substantial enough to comprise a local bus route.
Otherwise our clients' site represents an entirely sustainable location for a sensitively designed and proportioned residential development at Hainford.

In comparison Site 0181, considered by the Site Proposals document as representing the most unconstrained site at the village, returns an amber rating in no fewer than nine categories including crucially (in respect of potential housebuilder interest and eventual delivery) market attractiveness and compatibility with surrounding uses. It is assumed that both of these matters are identified as a concern due to the close proximity of the site to a local breakers yard immediately across the road. The market attractiveness of a site now carries enhanced importance in the context of the updated NPPF and the increased imperative on both viability and deliverability. When compared with Site 0181 our clients' site also lies approximately 400m closer to the bus stops located on Newton Road to the west, representing one of the more accessible sites in the village in respect of public transport.
Surface water flooding is raised as a consistent concern across all sites save for our client's land and Site 0190 on the eastern extremity of the village. These concerns are reflected in not only the HELAA but also the high number of neighbour and Parish Council objections in relation to pressures on the local drainage. On review of the Environment Agency's flood mapping we can confirm that the developable area of our clients' site is entirely devoid of risk from surface water flooding. An extract of the mapping is included below.


Indeed, our clients' site is not only unfettered by surface water flooding but is of a size to include a sufficient drainage scheme to ensure that greenfield run-off rates continue to be achieved.
Alternative Scale of Development
Whilst our clients are confident that the site could ably accommodate a new residential development of up to 60 dwellings we also acknowledge that paragraph 68 of the new NPPF presents a requirement for local planning authorities to identify a range of sites of less than one hectare to accommodate the delivery of not less than 10% of their housing requirement. Based on our calculations in respect of the residual housing requirement for the GNLP area this may represent up to 1,170 new homes.
To this end we are pleased to offer a one-hectare portion of the site, the location and orientation of which we would be happy to discuss further with Officers, as an alternative in the event that a smaller development, likely of approximately 25-30 dwellings, is deemed to more directly meet the needs of the Plan. It would still then be possible to deliver a scaled down element of open space, landscape screening and footpath linkages as part of a revised development framework.

Deliverability
Following the publication of the new NPPF in July 2018 the ability for local planning authorities to demonstrate that their plan allocations are deliverable is critical to both the success of the strategy as well as the maintenance of their future housing land supply position. We are therefore pleased to confirm that our clients' land is deliverable in every respect and fully accords with the definition set out in the Glossary of the Framework.
Specifically, we are pleased to conclude that the site is:
* Available: The site is being actively promoted for residential development and is no longer required for the purposes of agriculture as it comprises part of a substantial agricultural holding. As set out elsewhere in this letter the site is made available for either a larger scheme of up to 60 dwellings or a smaller scale development of one hectare or less;
* Suitable: As demonstrated by both our client's previous submission as well as the findings of the HELAA the site is entirely suitable for a residential development at Hainford. In fact, contrary to the recommendation of the Site Proposals document, the combination of the HELAA and the highways evidence submitted as part of our client's representation in March 2018 clearly demonstrates that the site is the single most suitable location for residential development in the village; and Achievable: The site comprises an undeveloped agricultural field directly abutting the settlement boundary of Hainford. It is not subject to any development constraints and is entirely capable of being delivered in full (up to 60 homes) within the first five years of the plan period. To this end we are pleased to confirm that the site is highly marketable and entirely viable as demonstrated by the current joint promotion of the land by an active regional housebuilder, Westmere Homes.
Based on the expectation that Hainford will be required to accommodate a level of growth due to its position as a 'Service Village' in the draft Settlement Hierarchy we are pleased to conclude that our client's site represents a compelling opportunity to deliver new homes at the village in an entirely sustainable manner.
We trust that these comments will be given due consideration and look forward to participating further as the Local Plan preparation progresses. If you feel that a meeting would be appropriate to discuss our clients' proposals, we would be keen to discuss available dates. Alternatively, if you require any further information in respect of the site in the meantime then please do not hesitate to contact either my colleague Alex Munro or myself.

I lived in Hainford for 15 years and know the site well.
It is totally unsuitable for development for the following reasons:
-Access to the site on Dumbs Lane is far too narrow being only wide enough for a single car.
-Dumbs Lane also has high banks and many blind corners with no footpaths for pedestrians. This makes it already dangerous to walk down to the church and school with current levels of traffic and will be made wholly worse if this increases.
-Due to the high water table in Hianford which is always a problem, the site floods at both ends during winter months. This water will flood the surrounding roads if it has nowhere to go due to large areas of paving.
-There are no jobs, shops or amenities within Hainford and with a poor bus services, any future residents will have no choice but to use private cars. This development will increase traffic on already unsuitable, poorly maintained and dangerous roads to pedestrians that were never designed for cars.
-If development is to take place within the village, other sites are better suited such as those proposed on the much wider Hall Road or on the old scrapyard.
-Central government's focus for development is for local authorities to utilize brownfield sites before green field. With Hainford Hall and the former scrap yard grounds empty, surely this must be used first.
-The original neighborhood plan outlined areas that were preferable for development and focused on infilling. This would have not only allowed development to take place and at a more sustainable rate, but preserved the villagescape and the green spaces. What was wrong with this?
-This development will create over density in one area with too much housing all back to back in one area.
-Once these green areas are developed, they are gone forever.

This proposal is totally unsuitable for this village which has very limited amenities and transport access. The only possible access to the proposed site is via Dumbs Lane which is narrow and prone to flooding, or Harvest Close which would impact severely on this small residential community, destroying its rural character. The Brown Field site at Hainford Hall, a former vehicle recycling plant, seems to be a much more environmentally friendly option but would still not answer the question of poor road accessibility and lack of shops, school facilities and general infrastructure. A very poorly thought out proposal.

There seem to be several other proposals that are more viable than this, both in terms of vehicle access and pedestrian safety. In addition, I'd be interested to know if any consideration has been given to rainwater runoff as the rear gardens of those properties bordering the proposal are prone to heavy saturation / flooding which would only be made worse by losing the natural runoff of the field behind. Traffic from the site from either proposed exit point would also expose schoolchildren walking to hainford school to additional risk as there is no footpath or lighting on dumbs lane or newton road. I believe that spreading new development over several smaller sites would relieve the impact on any one area and would be the more sensible option.

This would represent excessive development for the size and amenties of the village. Hainford is a village with a limited road network of primarily narrow lanes, this constrains scope for any significant further development. Access would be through a narrow residential area (Harvest Close) or a narrow country lane (Dumbs Lane) that is prone to flooding.

This would represent excessive development for the size and amenties of the village. Hainford is a village with a limited road network of primarily narrow lanes, this constrains scope for any significant further development. Access would be through a narrow residential area (Harvest Close) or a narrow country lane (Dumbs Lane) that is prone to flooding.

The proposed site is accessed either by a narrow rural road subject to flooding, or via a residential road causing frequent obstructions and environmental noise to current residents. There are no streetlights or pavements, limited bus service and no local ameneties to suppport the exisiting community. The land is prime agricultural land and should be used as such or for conservation to preserve the rural nature of the village.

I would like to object to the GNLP proposed site on harvest close for 60 new homes.
Hainford hasn't got sufficient amenities and would lack that to support new homes, the roads are not suitable for increased traffic and there is a risk of flooding.