Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 21815

Received: 12/03/2020

Respondent: Barford Parish Council

•This consultation exercise seems to be repeating much of what was done not more than a year or two ago. Yet sites considered for development around Barford and Wramplingham are being considered again. This makes a mockery of previous consultations.
•Fourteen potential sites were previously consulted on in early 2018. The Regulation 18 Site Proposals document concluded: "the sites proposed offer the potential for significant growth, with the necessary inclusion of supporting services and infrastructure provided alongside housing within GNLP0006, GNLP0032, GNLP0320, most of GNLP0515,GNLP0525. However, without provision of infrastructure such as relief roads and high school provision, Wymondham is likely to be able to accommodate fewer dwellings potentially on the smaller sites such as GNLP0092/ part of GNLP0525, GNLP0032 andGNLP0355."
•The complexity of the whole process, the information than needs to be assimilated, and the expertise required to make a useful response means that many members of the public are likely to be put off trying to comment. In this respect, the Consultation Documentation and response procedures are of low quality.
•Of direct concern to Barford and Wramplingham Parish Council is the policy by South Norfolk District Council to draw up its own Village Clusters Housing Site Allocations document. There are four very significant sites around Barford and Wramplingham asfollows:
oGNLP0416: land off Barnham Broom Road
oGNLP1013: Church Lane
oGNLP0552: Land off Watton Road
oGNLP0014: Turnpike Field
•Furthermore, recent correspondence with District Councillor Richard Elliot indicates that consultation concerning these is not going to happen until September/October 2020.
•This means that the allocation of these clusters is
oNOT being considered within the scope of the whole GNLP Regulation 18 Draft Plan
oNOT being considered within the consultation exercise•In addition, the new Northern Bypass (NDR) and the foreseen extension to link it to the A47 in the West of Norwich, was, as we understand it, intended to facilitate development of housing close to Norwich in the north. This should therefore reduce the need for fragmentary and environmentally damaging rural development elsewhere. However, the GNLP seems to be ignoring this, and continuing to promote building on green-belt land in Broadland and South Norfolk where the Village Cluster sites are NOT OPEN FOR CONSIDERATION.
• Our further concerns about the South Norfolk lack of transparency in this exercise are heightened by our understanding that:
o the Village Cluster approach will permit housing developments of significant size to be built outside the local Development Boundaries.
o there is apparently no maximum allocation, just a minimum allocation above and beyond the existing commitment.
• Barford and Wramplingham Parish Council consider that the lack of inclusion of all the Village Cluster proposed sites in the South Norfolk ward:
o Excludes the Parish Council from making a meaningful contribution relating to the land in and around the villages at this important time.
o Is not consistent with a true and fair consultation approach.
o Demonstrates that the consultation exercise is incomplete.
• Barford and Wramplingham Parish Council also wish to endorse the comprehensive response by CPRE to this consultation exercise.

Object

Representation ID: 21816

Received: 12/03/2020

Respondent: Barford Parish Council

• The use by Government of the outdated 2014 National Household Projections is leading to unnecessary land allocation for housebuilding, as highlighted by the CPRE response.
• Quoting from the CPRE response, “If the most recent ONS statistics had been used, current commitments are sufficient to cover housing needs to 2038”.
• The use of outdated statistical data by Government is very poor practice.

Object

Representation ID: 21817

Received: 12/03/2020

Respondent: Barford Parish Council

• Barford and Wramplingham PC consider that:
o the environmental sustainability vision (Para 135 subset Environment) which includes reducing impact of travel through concentrating activities close to centres of population (Para 125) and reducing the necessity for transport, and
o Para 120 which highlights the need for good access to services and facilities… are inconsistent with developing village cluster sites in relatively remote locations and where local services are sparse as is the case with Barford and Wramplingham. Wramplingham has no services. Barford has a small primary school and an intermittent, subsidized bus route.
• The increasing pressure on water availability in the Eastern Counties is inconsistent with building more and more houses (particularly in numbers greater than needed).
• The claim that new quality development will be located to minimise the loss of green-field land (Para 132) directly contradicts the policy of allocating and developing Village Cluster Sites, particularly around Honingham and Colton as well as around Barford and Wramplingham at GNLP0552 & GNLP1013 & GNLP0416, as well as the proposed locations of many other proposed sites such as GNLP0006, GNLP0545R, GNLP21255, GNLP0285, GNLP2150 North of Wymondham.
• In addition, these Wymondham sites and the proposed village cluster sites at GNLP0415R-A-G. GNLP0415R-A, GNLP0415R-B, GNLP0415R-C, GNLP0415R-D, GNLP0415R-E, GNLP0415R-F and GNLP0415R-G around Honingham and Colton, and on those around Wramplingham and Barford GNLP0552 & GNLP1013 & GNLP0416, will increase the water drainage pressure on the local rivers Tiffey and Tud, and increase the likelihood of flooding in Barford and Wramplingham.
• The plethora of sites could result in a very large and completely disproportionate number of houses around our villages. • Barford and Wramplingham PC consider that brownfield sites already allocated should be used first (as has happened in Barford), and that there should be a phased approach to new housing so that existing allocations and any brownfield sites are developed before permitting or allocating additional sites to be built on.
• The delivery statement on economic development is remarkably weak, lacking any focus or vision. Maybe house building is seen to be the (circular) economic driver for the local economy rather than stimulation of Industries!

Object

Representation ID: 21818

Received: 12/03/2020

Respondent: Barford Parish Council

Why do the architects of the GNLP vision believe the continued building of clay-brick-built houses is compatible with environmentally sustainability given the high carbon footprint of such technology?

Object

Representation ID: 21819

Received: 12/03/2020

Respondent: Barford Parish Council

• Barford and Wramplingham Parish Council consider that the opaque policy on village cluster sites is inconsistent with the Climate Change statement in Table 5: “reduce the need to travel, particularly by private car;”. • Note There is no bus service for Wramplingham, and there are only intermittent services through Barford, serving the bus stops shown near the Village Hall. One is only weekly. All are subsidised and vulnerable to cost cutting by NCC. The hourly day-time service along the B1108 is also a subsided route. There are no bus services in the evening, nor connecting the two villages to their designated GP surgery in Hethersett.
• It is difficult to understand how the drive to build more houses rectifies the current situation, let alone providing services for new houses

Object

Representation ID: 21820

Received: 12/03/2020

Respondent: Barford Parish Council

The claim that the GNLP plan aims to address climate change (Para 140-141 and policy statement) directly contradicts the policy of allocating and developing Village Cluster Sites (and the building on many other areas) in relation to transport requirements, loss of green field sites etc.

Object

Representation ID: 21821

Received: 12/03/2020

Respondent: Barford Parish Council

Barford and Wramplingham Parish Council do not agree with the proposed hierarchy and distribution of housing: the village cluster site allocations and development are inconsistent with the more centralised location of industrial development e.g. on the Norwich Research Park and in Norwich. Furthermore, continued expansion of villages and therefore the village cluster approach just puts more and more strain on the limited local amenities and services if and where they exist. The village cluster policy seems to be an environmentally deleterious, but local authority-backed policy to the benefit of landowners, developers and house builders.

Object

Representation ID: 21823

Received: 12/03/2020

Respondent: Barford Parish Council

• As said above (see attached for full submission), and as highlighted by the CPRE response, the use by Government of the outdated 2014 National Household Projections is leading to unnecessary land allocation for housebuilding.
• Barford and Wramplingham Parish Council wish to see land already allocated for house building used up before any new allocated land is used, with a focus on brownfield sites first – we are pleased to see this has recently happened in Barford.
• Barford and Wramplingham Parish Council do not understand why more land is set to be allocated when the 2016 projections of housing need to 2038 will be met by the area of sites currently allocated as stipulated in the CPRE response.

Object

Representation ID: 21824

Received: 12/03/2020

Respondent: Barford Parish Council

• Barford and Wramplingham Parish Council object to the policy of Village Clusters on the basis that it contradicts the key environmental criteria for sustainability regarding the excessive and unnecessary use of green belt, the unsustainability of adding to villages thereby stretching the use of their already stretched and often minimal services.
• Barford and Wramplingham Parish Council would like to point out that key village cluster site in the Tiffey and Tud valleys around Barford and Wramplingham at GNLP0552 is in the flood plain which regularly floods and is therefore highly unsuitable for house building. This has been highlighted previously but seems to be ignored. It gives the impression that the Authorities are unaware of the increase in rainfall that now occurs as a result of global warming. The area is also an important green infrastructure corridor as highlighted in Figure 8.
• Complementing points made in response to Question 6, the large area of possible developments north of Wymondham (GNLP0525R and thereabouts) and the proposed village cluster sites at GNLP0415R-A-G. GNLP0415R-A, GNLP0415R-B, GNLP0415R-C, GNLP0415R-D, GNLP0415R-E, GNLP0415R-F and GNLP0415R-G around Honingham and Colton, and on those around Wramplingham and Barford GNLP0552 & GNLP1013 & GNLP0416, will result in a massive additional run-off into the local rivers Tiffey and Tud, and increase the likelihood of flooding in Barford and Wramplingham. Barford in particular suffers considerably from high water levels, and additional housing north of Wymondham and around Honingham will exacerbate this. Development in these areas will also ruin the landscape value of the areas.
• Please be fully aware that proposed sites on northern & southern water catchment areas of River Tiffey and River Tud, the confluence of which forms the extreme western tip of our Parish Boundaries, will increase drainage into the rivers so that flooding/increased water flow upstream of the confluence will affect both villages.

Object

Representation ID: 21825

Received: 12/03/2020

Respondent: Barford Parish Council

• Please see many of the points made above (See attached for full submission) which are not being repeated here other than to re-iterate the following:
• Barford and Wramplingham Parish Council STRONGLY OBJECT to
o the lack of consideration of the village cluster locations in South Norfolk district in this GNLP consultation process with special reference to those areas around Barford and Wramplingham.
o The fact that many of the proposed village cluster locations are on green belt and outside the current development areas, and in our case often in flood plain and GI corridor areas.
o The lack of transparency in the consideration of these village clusters.
o The way village clusters seem to be a route to getting around normal planning conditions. We fully agree with the comment made in the CPRE response: ““Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside.”