Policy VC MUL1: Land east of Bluebell Road and north of The Rosery

Dear Sir/Madam,

Re: proposal for construction of 35 dwellings on Site VCMUL1.

To be validated as sound, I understand that the proposed plan should be compliant with the criteria set out in Paragraph 35 of the National Planning Policy Framework, namely that it is positively prepared, justified, effective and consistent with national policy. ‘Justified’ is defined as being an appropriate strategy taking into account the reasonable alternatives and based on proportionate evidence.

After reviewing the VCHA plan updated site assessment (January 2023) for the area South of Rectory Lane in Mulbarton, (site Reference SN2038/VCMUL1) I wish to object to the proposal on the grounds that the plans are not justified due to insufficient evidence presented regarding decisions about access to the site and hence should not be considered sound.

Referring to the suitability assessment for VCMUL1 on page 262 of the updated Site Assessment (2023) I note that access to the site initially received an Amber HELAA score and subsequently a Red Site score. NCC Highways comment that “Bluebell Road [is] not of a suitable standard to accommodate development over and above existing”, whilst alterative access routes of Rectory Land and The Rosery are also deemed unsuitable for access.

This comment is consistent with observations and policies set out in the Mulbarton Neighbourhood Plan 2015-2030 which states that “the main transport improvement should be to reduce…traffic through the village” and that “a key concern from the Consultation is the traffic generated by new development and its potential adverse impacts, especially in relation to the Heart of the Village around the Common”. The Common referred to is located approximately 350 yards from the entrance to Bluebell Road and the road, also named ‘The Common’, would serve as the main approach to traffic reaching the proposed development approaching from Norwich.

Knowing the area well, my subjective observations support the concerns identified by NCC Highways in the Site Assessment and the concerns highlighted in the Mulbarton Neighbourhood Plan. Specifically, my observations are that Bluebell Road is densely populated and already provides access to a large number of cul de sacs, resulting in significant traffic flow. Many dwellings have insufficient off street parking, resulting in cars parking on the road and subsequent congestion. There is heavy pedestrian usage of Bluebell Road, particularly by children due to the close proximity of Mulbarton School as well as three local nurseries or playgroups with variable opening hours. There is frequent congestion at the entrance to Bluebell Road and on the approach to this entrance from both directions, especially at peak times due to large numbers of parked cars accessing the school entrance which is nearly opposite Bluebell Road. The approach from Long Lane to the South of Bluebell Road features a very narrow pavement which is already hazardous when used by young children walking in close proximity to commuter traffic and buses. The approach to the North frequently necessitates single file traffic due to parked cars, with large numbers of children crossing the road in between parked cars to access the school. The addition of construction traffic during the building of additional housing, as well as increased vehicle numbers from these houses once populated, would considerably exacerbate these dangers and increase congestion, most significantly as construction vehicles would essentially be channelled directly past a school entrance.

I note from the Suitability Assessment (Jan 2023, p 262) that despite the judgement of Bluebell Road as unsuitable for access, it was later decided at the NCC Highways meeting that Bluebell Road could in fact provide access for construction of 25 dwellings although there does not appear to be any further evidence or site inspection that took place to result in this change of conclusion. A later meeting appears to have resulted in an increase of the proposal to 35 dwellings, based on discussions with the landowner and Hopkins Homes rather than any further consideration of evidence to the suitability of access via Bluebell Road.

As well as lacking credible, transparent supporting evidence, the decision to increase the number of proposed dwellings is counter to evidence cited in the Mulbarton Neighbourhood Plan 2015-2030. This states, citing the Joint Core Strategy Policy 15, that “small scale housing growth of 10-20 dwellings is the most suitable and appropriate scale of housing development for a Service Village such as Mulbarton”.

I would like therefore to draw attention in this representation to the lack of an evidence-based approach to the decision firstly to overturn NCC Highways’ decision based on site inspection that Bluebell Road is unsuitable for access to the site and secondly to increase the number of proposed dwellings from 25 to 35. As no additional evidence appears to have been presented to validate these decisions, and indeed the latter appears to have been a commercial decision between the landowner and developer, I would propose that the plan is not justified and therefore unsound as defined by Paragraph 35 of the NPPF.

I would propose that the postulated VCMUL1 site be considered unsuitable for development on grounds of inadequate safe access according to current evidence. Should re-examination of the evidence such as a further site inspection be undertaken and indicate that limited development may be possible then I would propose that the development is capped at 10-20 dwellings in accordance with the Mulbarton Neighbourhood Plan. To reduce danger to pedestrians along Bluebell Road and along the Northern and Southern approaches to Bluebell Road should development of any size take place, I would propose that an approach for construction traffic directly from the A140 to the site via the Eastern end of The Rosery be considered, which would limit the channelling of construction vehicles through the centre of Mulbarton.

Many thanks for your time in considering the above.

Yours faithfully,

Neil Thomas