Site Proposals document

GNLP 0497
Keswick and Intwood Parish Council believe GNLP 0497 should be refused for reasons already provided in response to Planning Application 2016/0764 and 2017/2794 (currently being considered) both being analogous to GNLP 0214.
Planning Application 2016/0764 was refused because the proposed development would have resulted in a significant adverse impact on the Norwich Southern Bypass Landscape Protection Zone (NSBLPZ), and the landscape setting of Norwich by virtue of the extent of the application site and the identified harm to the openness of the NSBPLZ when viewed from the west. This was deemed to be in conflict with Policy DM4.6 of the South Norfolk Local Plan 2015.
The Parish Council believes (in relation to the existing Application 2017/2794) and therefore identically by association that site GNLP 0214 should be refused for the following reasons:
Landscape Setting of Norwich.
The extent of the site goes well beyond the intention of South Norfolk Council's policy DM 4.6 of the South Norfolk Plan causing significant harm to the NSBLPZ.
Policy DM 4.6 - which was the basis of rejecting the previous Planning Application - states that: all development proposals will not harm and where possible should enhance the landscape setting of Norwich. The policy makes particular reference to any developments: not obstructing Key Views to and from the City; undermining the rural character of Undeveloped Approaches to Norwich; or undermine the Gateways as visual points of the landscape and townscape change marking the 'arrival' at and 'departure' from the city of Norwich.
The proposed development is contained within the boundaries of the A140 and B1113 both of which the Parish Council believes fall within the scope of requirements relating to Undeveloped Approaches to Norwich and Gateways to the City. The previous Application conflicted with this policy and the resubmitted Application destroys the existing nature of the B1113 approach (Gateway) to Norwich.
The additional screening proposed by the Developer to ameliorate damage to the pleasing local vista will, in the Parish Council's opinion: destroy the view from Keswick church; destroy the view from the byway linking the B1113 and Keswick Mill and the view from Marston Marsh.
Transport and Roads.
Overall (even allowing for the proposed junction improvement contained in the latest Planning Application) the proposed Development will have a negative impact on the local highway network and compromise the safety of vulnerable road users. This is contrary to the Inspector's report on the South Norfolk Plan which requires the Development to achieve a positive effect on the local highway network. Moreover, the increase in HGV's already using Low Road is contrary to Council Policy DM 3.13.
Furthermore, the housing developments at Cringleford and modifications to the Thickthorn junction will inevitably mean Low Road (through the village of Keswick) being increasingly used as a "rat run" between the A11 and A140. There are sections of Low Road where pedestrians (some with prams and buggies) must walk on the carriageway where there is already insufficient room for vehicles to comfortably pass. Furthermore, the road is used by horse riders and the wider safety issues for these and other vulnerable road users has long been a concern for the Parish Council.
Already, before any further development takes place, the Parish Council has photographic evidence of HGV's well in excess of the current load restrictions using Low Road thus discrediting assurances previously given that the load constraints would deter heavy vehicles. Arguably, the proposal for a short footpath to address the safety issue actually worsens matters by forcing users to return to walking along the carriageway at one of the most dangerous points.
As part of the first Planning Application the Developer suggested possible arrangements to restrict traffic using Low Road by prohibiting vehicles wishing to access or leave the proposed development. It was stated that such arrangements were in place at some locations around the country. The Parish Council's request for information about these locations was not met by the Developer.
Job Creation.
Keswick and Intwood Parish Council has always maintained there is no need for the additional capacity intended by the proposed site. This view is now supported by clear evidence from the Greater Norwich Local Plan (GNLP) which states: "There is no evidence to justify increasing the overall supply of employment land. Further increasing supply for which there is no demand increases uncertainty, risking investment to bring sites forward. It also increases the risk of encouraging uses that will be damaging to the city and town centres." (GNLP Growth and Options Document para. 6.19.)
The new Planning Application (now up to 12.7 hectares) is substantially larger than the original allocation in KES2 (4.7 hectares). Furthermore, the area is further increased (albeit to provide for additional screening) since the "extent of the site" was a reason for rejecting the original Application. The resubmitted Application is now more than three times the size of the original KES2 plan and the Parish Council has been unable to determine what assessments have been made to justify this scale of space. The Planning and Compulsory Purchase Act 2004 s38 (6) requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. Material considerations for a departure from policy of this scale should be open, transparent and in the public domain.
An absence of a credible viability assessment by the Developer makes it difficult for bodies such as the Parish Council to comment constructively on the submission, which does not meet the requirements of Nolan principles of openness and transparency. The Parish Council is aware of a number of industrial sites nearby with spare capacity. The Developer has patently not demonstrated the need for still more capacity.
Furthermore, the Parish Council has been unable to find evidence of significant current demand for commercial sites in the Norwich area where (it is believed) commercial rents are such that developers generally are not willing to invest in the infrastructure for new commercial estates.
Further clarity has now been brought to this matter by the GNLP, where the evidence base has demonstrated that there are currently around 340 hectares of underdeveloped employment land that is allocated and permitted (which includes the original KES 2 proposal for a B1 development). The Employment, Town Centres and Retail study has concluded that, even to support an advanced level of employment growth, the overall need for land is significantly less at 114 hectares.
Other Villages.
JCS Policy 16 states that Keswick falls within the "Other Villages" description. It therefore has defined development boundaries to accommodate infill or small groups of dwellings and small scale business services, subject to form and character considerations.
Such plans are not deemed suitable for significant new development which would not be supported by the local community. Exceptionally, larger scale development may be permitted where it would bring the facilities up to the level of a "Service Village" and is acceptable having regard to other policies in the JCS or any relevant subordinate plans. To meet the "Service Village" standard would typically mean including a primary school, food shop and improved public transport services.

GNLP 0214
Keswick is identified as an "Other Village" within Policy 16 of the Joint Core Strategy (JCS) for Broadland, Norwich and South Norfolk. The development boundary (in Keswick) has been tightly drawn around the existing built up area along Low Road to prevent further extension of growth into the surrounding countryside and to exclude those areas subject to flooding.
The "call for sites" reference GNLP 0214 has been previously rejected for precisely the reasons of its location in relation to the existing boundary and its being in a flood risk area. Any change in this regard would be a significant policy change necessitating a radical redrawing of the existing boundary and damaging in relation to maintaining the rural nature of the area.
Policy DM 4.5 of the existing Local Plan in relation to the protection of Landscape Character and River Valleys is unequivocal in stating that: "All development should respect, conserve and where possible, enhance the landscape character of its immediate and wider environment. Development proposals that would cause significant adverse impact on the distinctive landscape characteristics of an area will be refused".
Moreover, the emerging GNLP seeks to maintain the protection and enhancement of recognised and valued landscapes by maintaining existing policies. The Keswick and Intwood Parish Council believe GNLP 0214 is contrary to these policies and would have an adverse impact on the unspoiled nature of the river valley.
The emerging Local Plan seeks to maintain the existing Strategic Policies of avoiding allocating land for development in Flood Zones 2 and 3 (SP 4). The northerly margins of the site GNLP 0214 falls within Flood Zones 2 and 3 thus being subject to the highest probability of flooding. Furthermore, vehicular access to the site runs adjacent to a drainage ditch of grazing meadows on land which is classified as Flood Zone 3, the highest possibility of flooding and classified as "high risk" on Environment Agency mapping. The Parish Council believes it would be contrary to national and local policy to allow the development with such a high risk of surface water flooding.
In conclusion, Keswick and Intwood Parish Council therefore object to any redrawing of the existing development boundary to encompass this site.