Site Proposals document

Our client is pleased that the site has been considered, and identified as suitable within the HELAA. We have reviewed the assessment of the site provided within the Site Proposals Document and HELAA, and make the following comments in relation to the site's delivery. [References to NPPF and its consultation, Housing White Paper and NPPG]
Below, the site is considered against the tests within the NPPG, confirming that the site is suitable, available and achievable for development purposes:
Suitable
Development in rural areas is considered vital to the long term sustainability of rural communities.
Encouraging growth in sustainable settlements within rural areas is considered to be in accordance with Paragraph 55 of The Framework, which also notes that residential development in such settlements can make a significant contribution to the maintenance and continuing provision of local services and facilities for community use (Section 3: Supporting a Prosperous Rural Economy).
The site is considered to be a suitable location for residential development. Scole is identified as a 'Service Village' within the adopted Joint Core Strategy (2011), recognising the level of services, facilities and infrastructure available there within. Scole's facilities include public houses/restaurants and a primary school and are within walking distance of the site. The village also benefits from regular bus services to the market town of Diss where further amenities are available.
There are no known physical limitations or constraints on the site which would make development of the site difficult or unacceptable. The site is not located within protected areas such as Greenbelt, AONB or Flood Zones 2 and 3. The site is not subject to any PROW which may be affected by development of the site.
The site benefits from an existing access off of Low Road (30mph) which could be upgraded, if required, as part of any development.
The development of the site for housing would be considered as infill with residential development located on either flank. As such development of the site would not appear out of character with the existing built form, providing a natural extension to this part of the settlement. To the west of the site is the Scole bypass. The site currently appears as rough un-kept pasture of limited to no value within the wider landscape character.
The site could therefore present a suitable location for the managed growth of Scole, particularly given its relationship with the existing village. It is of an appropriate scale in relation to the form of the village, and as such, this site presents an opportunity to create an attractive and sympathetic development within a sustainable settlement.
Available
The site is considered available for development being within the control of a single owner. Should the site be accepted by the Council as a location for housing development, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partner as soon as possible.
Achievable
As noted above, there are no known technical constraints relating to the site and therefore it is considered its development would be economically viable. Services including electricity, mains water, foul sewerage and telecommunications are easily connectable and readily available.
There are no other known factors that mean development of the site would be difficult or unacceptable. Therefore, it is clear that the site presents a deliverable option for housing in Scole and could make a material contribution to the housing targets of the District.
Site Proposals Document Assessment
The site proposal document identifies Land at Rose Farm off Bungay Road, Scole as GNLP0339, and in respect of its deliverability states:
"Site 0339 is opposite the allotment gardens fronting on to Low Road, a narrow country lane with no footpaths and creating suitable access may not be possible. It is also close to the A140 which may affect the site in terms of noise."
Comment: The site benefits from an existing access off of Low Road which connects to Norwich Road, the main route through the village.
The NPPF makes it clear that development should only be prevented on highways grounds where it can be demonstrated that the residual cumulative impacts of development would be severe . A Transport Assessment would be produced, if required, by a qualified Highways Engineer prior to submission of any planning application. However, it is not anticipated at this stage that highway impacts relating to the development of the site would be severe.
In respect of potential noise arising from the sites proximity to the A140. A noise impact assessment with appropriate mitigation measures could be produced as part of any application should the land be successfully allocated for development. Equally, it is pertinent to highlight that the site is approximately 50 metres from the A140 at its closest point with an area of mature woodland located in between.

HELAA Assessment
A HELAA was undertaken and forms part of the evidence base for the site proposals document. Our client's comments on the HELAA are as follows [see scanned document for tables]
Access comment: Access is addressed in our assessment of the site proposals document above.
Landscape comment: The site is located within the Waveney River Valleys, a locally significant landscape area. However, the site is immediately adjacent to the main body of the village and occupies a gap between two areas of residential development, which provide screening. Development of the site would not appear out of character with the existing built form. To the west of the site is the Scole bypass. The site currently appears as rough un-kept pasture of limited to no value within the wider landscape character. Furthermore, appropriate landscaping could be implemented as part of any development of the site.
Historic Environment comments: Comment: In relation to the historic environment, this is addressed within Chapter 12 of the Framework. Paragraph 132 notes:
"When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset's conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification."
Paragraphs 134 set out what the considerations should be when determining an application which impacts designated heritage assets. It states: "134. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use."
The Planning (Listed Buildings and Conservation Areas) Act 1990 in Section 66 adds that:
"In considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority, or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses."
Section 72 adds that it is a duty, with respect to any buildings or land in a conservation area, to pay special attention to the desirability of preserving or enhancing the character or appearance of that area.
It is not considered that development of the site would have a detrimental impact or result in any harm to the setting of any listed buildings or the Scole conservation area. In addition, when assessing the impact on heritage assets, it is considered that the public benefits associated with the development of this site would weigh strongly in favour of its development.
Work and employment would be created for both individuals and businesses involved in the construction elements of the development and sourcing of materials. It is also considered that any construction workers and local trades will make use of local services and facilities during the construction period. In the long-term it is likely trades people will be required to help maintain any properties. Additionally, it is considered that the occupiers of any development would make use of local services and facilities ensuring their vitality, viability and longevity thus contributing to the local economy.
A heritage impact assessment would be produced, if required, prior to submission of any planning application should the site be allocated. Furthermore, appropriate archaeological surveys could be conditioned should planning be pursued on the site.

Conclusion
It is considered that the land at Street Farm off Low Road, Scole (GNLP 0339) is sustainable and deliverable as defined by the NPPF, and a suitable location for residential development. The site, within the ownership of Sir Rupert Mann Bt, represents an attractive option for housing growth within the District.
Should the site be accepted as an allocation within the Local Plan, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partner as soon as possible.

SEE ATTACHED LETTER FOR FULL REPRESENTATION

Our client is pleased that the site has been considered, and identified as suitable within the HELAA. We have reviewed the assessment of the site provided within the Site Proposals Document and HELAA, and make the following comments in relation to the site's delivery. [references to NPPF and its consultation, Housing White Paper, NPPG]
Below, the site is considered against the tests within the NPPG2, confirming that the site is suitable, available and achievable for development purposes:
Suitable
Development in rural areas is considered vital to the long term sustainability of rural communities.
Encouraging growth in sustainable settlements within rural areas is considered to be in accordance with Paragraph 55 of The Framework, which also notes that residential development in such settlements can make a significant contribution to the maintenance and continuing provision of local services and facilities for community use (Section 3: Supporting a Prosperous Rural Economy).
The site is considered to be a suitable location for residential development. Burston is identified as an 'Other Village' within the adopted Joint Core Strategy (2011), whilst it has been upgraded to a 'Service Village' within Appendix 3 of the GNLP recognising the level of services, facilities and infrastructure available there within. These include a public house/restaurant and a primary school within walking distance of the site. The village also benefits from regular bus services to the market town of Diss where further amenities are available.
There are no known physical limitations or constraints on the site which would make development of the site difficult or unacceptable. The site is not located within protected areas such as Greenbelt, AONB or Flood Zones 2 and 3. A PROW runs across the northern boundary of the site.
The site benefits from an existing access off of Gissing Road (30mph) which could be upgraded, if necessary, as part of any development.
The site is immediately adjacent to Burston's settlement boundary. The main body of Burston is located directly to the south of the site whilst frontage development is located to the east. Development of the site would not appear out of character with the existing built form, providing a natural extension to this part of the settlement.
The site is neatly bounded by extensive trees and hedging along its northern and western boundaries which largely screen the site from the surrounding countryside. Whilst having some intrinsic value, due to the site's largely enclosed nature, it is considered that it does not make a significant contribution to the wider landscape character.
The site could therefore present a suitable location for the managed growth of Burston, particularly given its relationship with the existing village. It is of an appropriate scale in relation to the form of the village, and as such, this site presents an opportunity to create an attractive and sympathetic development within a sustainable settlement.
Available
The site is considered available for development being within the control of a single owner. Should the site be accepted by the Council as a location for housing development, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partners as soon as possible.
Achievable
As noted above, there are no known technical constraints relating to the site and therefore it is considered its development would be economically viable.
Services including electricity, mains water, foul sewerage and telecommunications are easily connectable and readily available. It is noted that Burston currently has sewerage infrastructure constraints. This is an issue reflective across the entirety of Burston. It is not considered that foul drainage would prohibit new development from being delivered.
There are no other factors that mean development of the site would be difficult or unacceptable.Therefore, it is clear that the site presents a deliverable option for housing in Burston and would make a material contribution to the housing targets of the District.
Site Proposals Document Assessment
The site proposal document identifies land at Rose Farm off Bungay Road, Scole as GNLP0349, and in respect of its deliverability no obvious constraints are identified.

HELAA Assessment
A HELAA was undertaken in December 2017 and forms part of the evidence base for the site proposals document. [Images of HELAA assessment]. Our clients comments on the HELAA are as follows:

Accessibility Comment: The site benefits from an existing access off of Gissing Road which could be upgraded, if required, as part of any development. There is adequate land within the boundary of the site to form a new access and to widen Gissing Road. Equally there would appear to be land either aside of Gissing Road within the ownership of the Highways Authority which may allow for some widening to occur, should this be necessary. The existing junction to Station Road is considered sufficient with good visibility available. Station Road is a main road through the village with sufficient capacity to accommodate development of the site. Footpaths are available throughout the village which could be connected to as part of the development. The NPPF makes it clear that development should only be prevented on highways grounds where it can be demonstrated that the residual cumulative impacts of development would be severe . A Transport Assessment would be produced, if required, by a qualified Highways Engineer prior to submission of any planning application. However, it is not anticipated at this stage that highway impacts relating to the development of the site would be severe.

Access to services comment: As previously noted, Burston has been upgraded to a 'Service Village' within Appendix 3 of the GNLP recognising the level of services, facilities and infrastructure available there within. These include a public house/restaurant and a primary school within walking distance of the site. The village also benefits from regular bus services to the market town of Diss where further amenities are available.

Flood risk comment: Environment Agency surface water flood mapping indicates that a small section of the site is susceptible to surface water flooding, this being an area of land running north to south towards the centre of the site. There is also an are susceptible to surface water flooding along the western boundary. Further investigation into site specific drainage issues would be undertaken, however there are no known reasons why a Sustainable Urban Drainage System (SUDS) could not be incorporated, thus addressing any pressures on the current drainage network. Development could be designed to incorporate soft edges.

Landscape comment: The site is located within land designated as Waveney tributary farmland, a locally significant landscape area. However, the site is well located to the main body of Burston directly to the south of the site whilst frontage development is located to the east. Development of the site would not appear out of character with the existing built form, providing a natural extension to this part of the settlement. The site is neatly bounded by extensive trees and hedging along its northern and western boundaries which largely screen the site from the surrounding countryside. Whilst having some intrinsic value, due to the site's largely enclosed nature, it is considered that it does not make a significant contribution to the wider landscape character. Furthermore, appropriate landscaping could be implemented as part of any development of the site.

Utilities capacity comment: As previously stated, it is noted that Burston currently has sewerage infrastructure constraints. This is an issue reflective across the entirety of Burrton. It is not considered that foul drainage would prohibit new development from being delivered.

Historic environment comment: In relation to the historic environment, this is addressed within Chapter 12 of the Framework. Paragraph 132 notes:
"When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset's conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification."
Paragraphs 134 set out what the considerations should be when determining an application which impacts designated heritage assets. It states:
"134. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use."
The Planning (Listed Buildings and Conservation Areas) Act 1990 in Section 66 adds that:
"In considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority, or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses."
Section 72 adds that it is a duty, with respect to any buildings or land in a conservation area, to pay special attention to the desirability of preserving or enhancing the character or appearance of that area.
It is not considered that the proposal would have a detrimental impact or result in any harm to the setting of any listed buildings or the Burston conservation area. In addition, when considering the impact on heritage assets, it is considered that the public benefits associated with the development of this site would weigh strongly in favour of its development..
Work and employment would be created for both individuals and businesses involved in the construction elements of the development and sourcing of materials. It is also considered that any construction workers and local trades will make use of local services and facilities during the construction period. In the long-term it is likely trades people will be required to help maintain any properties. Additionally, it is considered that the occupiers of any development would make use of local services and facilities ensuring their vitality, viability and longevity thus contributing to the local economy.
A heritage impact assessment would be produced, if required, prior to submission of any planning application should the site be allocated. Furthermore, appropriate archaeological surveys could be conditioned should planning be pursued on the site.

Biodiversity/geodiversity comment: In respect of any potential impact upon the SSSI. This would be addressed by way of appropriate protected species surveys and the implementation of appropriate mitigation, undertaken and produced by a CIEEM registered ecology consultants. Where possible, biodiversity net gains would be sought in line with the NPPF.

Conclusion
It is considered that the land to the west of Gissing Road (GNLP 0349) is sustainable and deliverable as defined by the NPPF, and a suitable location for residential development. The site, within the ownership of Sir Rupert Mann Bt, represents an attractive option for housing growth within the District.
Should the site be accepted as an allocation within the Local Plan, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partner as soon as possible.

SEE ATTACHED LETTER FOR FULL REPRESENTATION

Our client is pleased that the site has been considered, and identified as suitable within the HELAA. We have reviewed the assessment of the site provided within the Site Proposals Document and HELAA, and make the following comments in relation to the site's delivery. [comments regarding NPPF and its consultation, Housing White Paper and NPPG]
Below, the site is considered against the tests within the NPPG2, confirming that the site is suitable, available and achievable for development purposes:
Suitable
Development in rural areas is considered vital to the long term sustainability of rural communities.
Encouraging growth in sustainable settlements within rural areas is considered to be in accordance with Paragraph 55 of The Framework, which also notes that residential development in such settlements can make a significant contribution to the maintenance and continuing provision of local services and facilities for community use (Section 3: Supporting a Prosperous Rural Economy).
The site is considered to be a suitable location for residential development. Dickleburgh is identified as a 'Service Village' within the adopted Joint Core Strategy (2011), recognising the level of services, facilities and infrastructure available there within. These include a public house, village store and a primary school which are within walking distance of the site. The village also benefits from regular bus services to the market town of Diss where a plethora of services and facilities are available.
There are no known physical limitations or constraints on the site which would make development of the site difficult or unacceptable. The site is not located within protected areas such as Greenbelt, AONB or Flood Zones 2 and 3. The site is not subject to any PROW which may be affected by development of the site.
The site benefits from good access to Ipswich Road. Ipswich Road is the main road running through Dickleburgh and appears to have sufficient capacity at this point to accommodate development of the site. A footpath runs along the length of the site. It is anticipated that an access with sufficient visibility could be installed as part of any development.
The site is immediately adjacent to Dickleburgh's settlement boundary. The main body of Dickleburgh is located directly to the north of the site whilst there is some sporadic housing to the south. Visually the site would appear as infill being flanked by residential development to the north and south. Development of the site would not appear out of character with the existing built form, providing a natural extension to this part of the settlement.
The site is neatly bounded by extensive trees and hedging along its northern and southern boundaries. The site is open to the east, and whilst having some intrinsic value, it is considered that it does not make a significant contribution to the wider landscape character.
The site can therefore present a suitable location for the managed growth of Dickleburgh, particularly given its relationship with the existing village. It is of an appropriate scale in relation to the form of the village, and as such, this site presents an opportunity to create an attractive and sympathetic development within a sustainable settlement.

Available
The site is considered available for development being within the control of a single owner. Should the site be accepted by the Council as a location for housing development, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partner as soon as possible.
Achievable
As noted above, there are no known technical constraints relating to the site and therefore it is considered its development would be economically viable.
Services including electricity, mains water, foul sewerage and telecommunications are easily connectable and readily available.
There are no other factors that mean development of the site would be difficult or unacceptable.Therefore, it is clear that the site presents a deliverable option for housing in Dickleburgh and would make a material contribution to the housing targets of the District.
Site Proposals Document Assessment
The site proposal document identifies Land to the west of Ipswich Road, Dickleburgh as GNLP0350, and in respect of its deliverability no obvious constraints are identified.

HELAA Assessment
A HELAA was undertaken in December 2017 and forms part of the evidence base for the site proposals document [several images of HELAA tables]. Our clients comments on the HELAA are as follows:

Accessibility comment: As stated previously, the site benefits from good access to Ipswich Road. Ipswich Road is the main road running through Dickleburgh and is of sufficient capacity at this point to accommodate development of the site. A footpath runs along the length of the site. An access with sufficient visibility could be installed as part of any development.
The NPPF makes it clear that development should only be prevented on highways grounds where it can be demonstrated that the residual cumulative impacts of development would be severe . A Transport Assessment would be produced, if required, by a qualified Highways Engineer prior to submission of any planning application. However, it is not anticipated at this stage that highway impacts relating to the development of the site would be severe.

Townscape comment: As stated previously, the site is immediately adjacent to Dickleburgh's settlement boundary. The main body of Dickleburgh is located directly to the north of the site whilst there is some sporadic housing to the south. Visually the site would appear as infill. Development of the site would not appear out of character with the existing built form, providing a natural extension to this part of the settlement.

Historic environment comment: In relation to the historic environment, this is addressed within Chapter 12 of the Framework. Paragraph 132 notes:
"When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset's conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification."
Paragraphs 134 set out what the considerations should be when determining an application which impacts designated heritage assets. It states:
"134. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use."
The Planning (Listed Buildings and Conservation Areas) Act 1990 in Section 66 adds that:
"In considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority, or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses."
Section 72 adds that it is a duty, with respect to any buildings or land in a conservation area, to pay special attention to the desirability of preserving or enhancing the character or appearance of that area.
It is not considered that the proposal would have a detrimental impact or result in any harm to the setting of any listed buildings or the Dickleburgh conservation area. In addition, when considering the impact on heritage assets, it is considered that the public benefits associated with the development of this site would weigh strongly in favour of its development..
Work and employment would be created for both individuals and businesses involved in the construction elements of the development and sourcing of materials. It is also considered that any construction workers and local trades will make use of local services and facilities during the construction period. In the long-term it is likely trades people will be required to help maintain any properties. Additionally, it is considered that the occupiers of any development would make use of local services and facilities ensuring their vitality, viability and longevity thus contributing to the local economy.
A heritage impact assessment would be produced, if required, prior to submission of any planning application should the site be allocated. Furthermore, appropriate archaeological surveys could be conditioned should planning be pursued on the site.

Conclusion
It is considered that the land to the west of Ipswich Road, Dickleburgh (GNLP 0350) is sustainable and deliverable as defined by the NPPF, and a suitable location for residential development. The site, within the ownership of Sir Rupert Mann Bt, represents an attractive option for housing growth within the District.
Should the site be accepted as an allocation within the Local Plan, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partner as soon as possible.

SEE ATTACHED LETTER FOR FULL REPRESENTATION

Savills UK Ltd (Rural, Energy & Projects), is instructed by our client, Sir Rupert Mann Bt, to submit a Call for Sites submission (submitted via GNDP online portal) and supporting representation in response to the Greater Norwich Local Plan (GNLP) Consultation. The submission and representation are made in respect of the same land holding as GNLP0338 previously submitted to the GNLP Call for Sites in 2016. However, the submission has been revised to reflect a smaller land area being reduced from 1.45ha to 0.60ha. It is considered that the reduced land area would result in a more sympathetic development, having a lesser impact on the existing village and surrounding landscape.
Our client is pleased that the previous submission was considered, and identified as suitable within the HELAA. It is thought that the reduction in site area would further contribute towards making this land a suitable allocation within the Emerging Local Plan.
Given that this call for sites submission reflects the same land holding, we have reviewed the assessment of the site (GNLP0338) provided within the Site Proposals Document and HELAA, and make the following comments in relation to the site's delivery.
Firstly though, it is pertinent to refer to national planning policy and guidance, namely that set out in the National Planning Policy Framework (NPPF), National Planning Practice Guidance (NPPG) and Housing White Paper February 2017. [various comments about NPPF and its consultation, Housing White Paper and NPPF]

Below, the site is considered against the tests within the NPPG2, confirming that the site is suitable, available and achievable for development purposes:

Suitable
Development in rural areas is considered vital to the long term sustainability of rural communities.
Encouraging growth in sustainable settlements within rural areas is considered to be in accordance with Paragraph 55 of The Framework, which also notes that residential development in such settlements can make a significant contribution to the maintenance and continuing provision of local services and facilities for community use (Section 3: Supporting a Prosperous Rural Economy).
The site is considered to be a suitable location for residential development. Scole is identified as a 'Service Village' within the adopted Joint Core Strategy (2011), recognising the level of services, facilities and infrastructure available there within. Scole's facilities include public houses/restaurants and a primary school and are within walking distance of the site. The village also benefits from regular bus services to the market town of Diss where further amenities are available.
There are no known physical limitations or constraints on the site which would make development of the site difficult or unacceptable. The site is not located within protected areas such as Greenbelt, AONB or Flood Zones 2 and 3. Nor does it impact upon any designated heritage assets. The site is not subject to any PROW which may be affected by development of the site.
The site benefits from an existing access off of Bungay Road (30mph) which could be upgraded, if required, as part of any development.
The site is immediately adjacent to Scole's settlement boundary. An existing residential estate is located directly to the west and there is frontage development to the north. Allocating the site for housing would not appear out of character with the existing built form, providing a natural extension to this part of the settlement.
To the north of the site are a number of agricultural buildings which could be demolished upon the site coming forward for development.
The site is neatly bounded by extensive mature trees and hedging along its eastern boundary which largely screens the site from the surrounding countryside. Whilst having some intrinsic value, due to the site's largely enclosed nature, it is considered that it does not make a significant contribution to the wider landscape character. Furthermore, the primary area put forward within the revised submission is an existing farmyard with agricultural buildings in situ. As such, any potential impact is lessened.
The site can therefore present a suitable location for the managed growth of Scole, particularly given its relationship with the existing village. It is of an appropriate scale in relation to the form of the village, and as such, this site presents an opportunity to create an attractive and sympathetic development within a sustainable settlement.

Available
The site is considered available for development being within the control of a single owner. Should the site be accepted by the Council as a location for housing development, Savills would be able to act on our client's behalf to take the sites forward with a view to identifying a suitable development partners as soon as possible.

Achievable
As noted above, there are no known technical constraints relating to the site and therefore it is considered its development would be economically viable.
Services including electricity, mains water, foul sewerage and telecommunications are easily connectable and readily available.
There are no other known factors that mean development of the site would be difficult or unacceptable. Therefore, it is clear that this site presents a deliverable option for housing in Scole and could make a material contribution to the housing targets of the District.

Site Proposals Document Assessment
The Site Proposal Document refers to the 1.45 hectare site (GNLP0338) submitted through the Call for Sites in 2016. However, the points raised are equally applicable to the revised submission.
In respect of the sites deliverability, the site proposal document states:
"...the site fronts onto Bungay Road where there are no footpaths and has access issues."
Comment: The site benefits from an existing access off of Bungay Road which could be upgraded, if required, as part of any development. There is adequate land within the boundary of the site to form a new access with sufficient visibility. The existing red brick buildings fronting the street would be removed as part of any redevelopment. Bungay Road is a main road through the village which appears to have sufficient capacity to accommodate development of the site. A public footpath exists on the opposite side of Bungay Road which could be connected to as part of the redevelopment of the site by way of a crossing.
The NPPF makes it clear that development should only be prevented on highways grounds where it can be demonstrated that the residual cumulative impacts of development would be severe . A Transport Assessment would be produced, if required, by a qualified Highways Engineer prior to submission of any planning application. However, it is not anticipated at this stage that highway impacts relating to the development of the site would be severe.

HELAA Assessment [several images of site assessment tables]

A HELAA was undertaken in December 2017 and forms part of the evidence base for the Site Proposals Document. The HELAA refers to the 1.45 hectare site (GNLP0338) submitted through the Call for Sites in 2016. However, the points raised are equally applicable to the revised submission. Our clients comments on the HELAA are as follows:

Access comments: Access is addressed in our assessment of the Site Proposals Document above.

Surface water flooding comment: Environment Agency surface water flood mapping indicates that a small section of the site is susceptible to surface water flooding, this being the area of land immediately surrounding the pond to the north west of the site. Further investigation into site specific drainage issues will be undertaken, however there are no known reasons why a Sustainable Urban Drainage System (SUDS) could not be incorporated, thus addressing any pressures on the current drainage network. Development could be designed to incorporate soft edges around the pond.

Landscape comment: Comment: The site is located within the Waveney River Valleys, a locally significant landscape area. However, the site is immediately adjacent to an existing residential estate to the west and so development of the site would not appear out of character with the existing built form. The site is neatly bounded by extensive mature trees and hedging along its eastern boundary which largely screen the site from the surrounding countryside. The site, whilst having some intrinsic value, is not considered to make a significant contribution to the wider landscape character due to the site's largely enclosed nature. Appropriate landscaping could be implemented as part of any development of the site. Furthermore, the primary area put forward within the revised submission is an existing farmyard with agricultural buildings in situ. As such, any potential impact is lessened.

Biodiversity comment: In respect of any potential impact upon protected species. This would be addressed by way of appropriate protected species surveys and the implementation of appropriate mitigation, undertaken and produced by a CIEEM registered ecology consultants. Where possible, biodiversity net gains would be sought in line with the NPPF3.
Conclusion
It is considered that the revised submission on land at Rose Farm off Bungay Road, Scole is sustainable and deliverable as defined by the NPPF, and a suitable location for residential development. The site, within the ownership of Sir Rupert Mann Bt, represents an attractive option for housing growth within the village and wider District.
The revised submission reflects a land area of 0.60ha, being reduced from 1.45ha. It is considered that the reduced land area would result in a more sympathetic development, having a lesser impact on the existing village and surrounding landscape.

Should the site be accepted as an allocation within the Local Plan, Savills would be able to act on our client's behalf to take the site forward with a view to identifying a suitable development partner as soon as possible.

SEE ATTACHED LETTER FOR FULL RESPONSE