QUESTION 10a: Do you agree with the proposed allocation VC GIL1 REV, South of Geldeston Road and Daisy Way, Gillingham, on 2.92ha, for approximately 40 dwellings. Please explain your response.

This submission is made by Landmark Associates on behalf of Todhunter Ltd. The company is the owner of the land at Gillingham, which is subject to the South Norfolk Council ‘consultation on alternative sites and focused changes’, concerning the emerging Village Clusters Housing Allocations Plan (Regulation 18).
The reason for the changes and the Regulation 18 consultation are set out in the contextual material. It is noted that the Council is seeking to ensure that the boundaries of the land for the local plan allocation coincide with the boundaries of the land submitted as part of the planning application.
In response to question 10a, Todhunter Ltd fully supports the variation of the allocation boundaries to reflect the boundaries of the planning application. The company has a proven ‘track record’ and actively seeks the development of land allocated for housing as demonstrated by the residences constructed on the land originally allocated in the Local Plan. It is submitted that the additional five dwellings will make a positive contribution to the housing needs of the Local Plan as established by the appropriate policies and the needs of the local community. The additional dwellings will not have a demonstrable adverse planning impact on the environment. In addition, the allocation will offer an opportunity for the school to expand. The expansion of the commercial area to the North will provide facilities and employment opportunities to some of the residents of the dwellings.
The Council’s attention is raised to the fact that in connection with the land to the north of The Street, submissions have been made at the Regulation 18 and Regulation 19 stages that this should be allocated for residential development as part of the Local Plan.it is argued that this is even more critical given the adverse impact on residential development caused by the moratorium resulting from the declaration by Natural England on nutrient neutrality.

See attachment for full representation.

See attachments for full representation.

See attachment for full representation.

1. According to the latest Housing Land Supply Assessment, the District has a supply of 5.87 years. This assessment demonstrates that objectively assessed needs are already exceeded. The benefit in providing additional housing including affordable housing is significantly and demonstrably outweighed by the adverse impacts identified below.
2. The proposal is a large-scale development outside the defined village boundary, resulting in an incursion in to open countryside, out of character with the form and character of the village, and to the detriment of the wider landscape setting including the setting of the Broads. The Council considers that the open, rural setting is an important characteristic of the village. In the Regulation 18 consultation on the Village Clusters Plan, the Council states: “The village is set in the Waveney Valley and adjacent to the Broads, and open views out from the village make an important contribution to its rural character.” The proposal would result in a drastic change from rural to urban views out from the village, to the detriment of its rural character, contrary to DM1.4 and DM3.8.
3. The site is in close proximity to the Broads (King’s Dam). National policy provides the highest level of protection to these areas, and notes that development within their setting needs to be sensitively designed to avoid harm to the designated area. Paragraph 176 of the NPPF states “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and AONBs, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” The spread of urban development across open countryside towards the Broads would adversely affect the environment, tranquillity, setting and visual amenity of the nationally protected landscape, contrary to Policy 18 of the Core Strategy and paragraph 176 of the NPPF. It should also be noted that the previously approved developments of Daisy Way and the Services placed great weight on promised landscaping and planting schemes to protect visual amenity of The Broads. The promised landscaping not taken place to the standards required in the planning approvals, and this would be significantly exacerbated by further development to south. 4. The level of increased use of The Street generated by the proposal could not safely be accommodated, despite the proposed road-widening in places, given its limited capacity and blind bends, which already present difficulties for users and which would inevitably be exacerbated by the proposal. It is noted that in assessing the suitability of sites for the draft Village Clusters plan, the ‘acute blind bend’ and ‘on-street parking’ at The Street were both cited as reasons for the site to the north of The Street not to score highly. Exactly the same highway constraints presented by the acute blind bend and on- street parking at The Street apply to this south site and the same highway objections should therefore arise.
5. The proposed 44 houses would each be likely to have 2 cars and 2 parking spaces per dwelling are proposed. Daily car movements would therefore be likely to increase by at least 176 movements (88 cars leaving and returning per day) and could be considerably more. It is currently a cul-de-sac and residents enjoy a peaceful environment with no through traffic. Such increased use of Daisy Way would significantly adversely affect amenities of residents by reason of the resulting traffic noise and disturbance. Future residents would be dependent on private car journeys for day-to-day needs and the proposal does not enable sustainable transport patterns. Daisy Way is a private road and the legality of its use to access the site is not established.
6. It would be partially within flood zones 2 and 3. Environment Agency flood maps indicate that access through Daisy Way is within flood zones and the additional flood information submitted still shows that part of the attenuation pond and emergency access route shown on the proposed access strategy drawing, would fall within high flood risk areas. Consent of the Internal Drainage Board is required for several drainage elements and the Board points out potential conflict between the planning process and their regulatory regime. The Board therefore strongly advises that their consent is sought prior to determination of this planning application. The proposal would be at risk of flooding and increasing flood risk elsewhere, contrary to national requirements and Core Strategy Policy 1.The proposal therefore does not represent sustainable development.
7. Within the reasoned justification statement given for this revision, it is stated that “Whilst, at the time of writing, some technical issues on application 2022/1993 remain unresolved”, this statement is factually incorrect. There are not just “some technical issues unresolved”, this planning application has not yet made it to committee and there is a groundswell of objections against in the local community. This statement appears to indicate that due legal process in the planning application is not being followed, that
there is undue and unfair bias to the planning applicant to the detriment of objecting parties to the application.
In summary:
The District already has a sufficient supply housing land at 5.87years (Housing Land Supply Assessment).
This large-scale development is outside the defined village boundary, it’s an incursion in to open countryside, out of character/form of the village and to the detriment of the wider Broads.
There’s an unacceptable impact on highway safety from the acute blind bend and on- street parking at The Street. Daisy Way is a private road and the legality of its use to access the site is not established.
Sustainable transport patterns are not met as future residents would be dependent on car journeys for day-to-day needs.
The development would be at risk of flooding and increasing flood risk elsewhere. The proposal therefore does not represent sustainable development
There is demonstrable unfair bias in favour of the planning applicant to the detriment of objecting parties.

We strongly object to the proposed development. The risk of flooding created by the proposed developments will heighten the problem that already exists. The amount of proposed houses would also put more strain on the local treatment works which would result in more “not sufficiently treated” effluent being released into the River Waveney. The village cannot cope with the flow of traffic, especially at the Z bends on the street and this will be treacherous should new homes be built. We have at least 2 species of bats that roost in the mature oak trees. FULLY OBJECT

See attachment for full representation.

1. According to the latest Housing Land Supply Assessment, the District has a supply of 5.87 years. This assessment demonstrates that objectively assessed needs are already exceeded. The benefit in providing additional housing including affordable housing is significantly and demonstrably outweighed by the adverse impacts identified below.
2. The proposal is a large-scale development outside the defined village boundary, resulting in an incursion in to open countryside, out of character with the form and character of the village, and to the detriment of the wider landscape setting including the setting of the Broads. The Council considers that the open, rural setting is an important characteristic of the village. In the Regulation 18 consultation on the Village Clusters Plan, the Council states: “The village is set in the Waveney Valley and adjacent to the Broads, and open views out from the village make an important contribution to its rural character.” The proposal would result in a drastic change from rural to urban views out from the village, to the detriment of its rural character, contrary to DM1.4 and DM3.8.
3. The site is in close proximity to the Broads (King’s Dam). National policy provides the highest level of protection to these areas, and notes that development within their setting needs to be sensitively designed to avoid harm to the designated area. Paragraph 176 of the NPPF states “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and AONBs, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” The spread of urban development across open countryside towards the Broads would adversely affect the environment, tranquillity, setting and visual amenity of the nationally protected landscape, contrary to Policy 18 of the Core Strategy and paragraph 176 of the NPPF. It should also be noted that the previously approved developments of Daisy Way and the Services placed great weight on promised landscaping and planting schemes to protect visual amenity of The Broads. The promised landscaping not taken place to the standards required in the planning approvals, and this would be significantly exacerbated by further development to south.
4. The level of increased use of The Street generated by the proposal could not safely be accommodated, despite the proposed road-widening in places, given its limited capacity and blind bends, which already present difficulties for users and which would inevitably be exacerbated by the proposal. It is noted that in assessing the suitability of sites for the draft Village Clusters plan, the ‘acute blind bend’ and ‘on-street parking’ at The Street were both cited as reasons for the site to the north of The Street not to score highly. Exactly the same highway constraints presented by the acute blind bend and on-street parking at The Street apply to this south site and the same highway objections should therefore arise.
5. The proposed 44 houses would each be likely to have 2 cars and 2 parking spaces per dwelling are proposed. Daily car movements would therefore be likely to increase by at least 176 movements (88 cars leaving and returning per day) and could be considerably more. It is currently a cul-de-sac and residents enjoy a peaceful environment with no through traffic. Such increased use of Daisy Way would significantly adversely affect amenities of residents by reason of the resulting traffic noise and disturbance. Future residents would be dependent on private car journeys for day-to-day needs and the proposal does not enable sustainable transport patterns. Daisy Way is a private road and the legality of its use to access the site is not established.
6. It would be partially within flood zones 2 and 3. Environment Agency flood maps indicate that access through Daisy Way is within flood zones and the additional flood information submitted still shows that part of the attenuation pond and emergency access route shown on the proposed access strategy drawing, would fall within high flood risk areas. Consent of the Internal Drainage Board is required for several drainage elements and the Board points out potential conflict between the planning process and their regulatory regime. The Board therefore strongly advises that their consent is sought prior to determination of this planning application. The proposal would be at risk of flooding and increasing flood risk elsewhere, contrary to national requirements and Core Strategy Policy 1.The proposal therefore does not represent sustainable development.
7. Within the reasoned justification statement given for this revision, it is stated that “Whilst, at the time of writing, some technical issues on application 2022/1993 remain unresolved”, this statement is factually incorrect. There are not just “some technical issues unresolved”, this planning application has not yet made it to committee and there is a groundswell of objections against in the local community. This statement appears to indicate that due legal process in the planning application is not being followed, that there is undue and unfair bias to the planning applicant to the detriment of objecting parties to the application.
In summary:
The District already has a sufficient supply housing land at 5.87years (Housing Land Supply Assessment).
This large-scale development is outside the defined village boundary, it’s an incursion in to open countryside, out of character/form of the village and to the detriment of the wider Broads.
There’s an unacceptable impact on highway safety from the acute blind bend and on-street parking at The Street. Daisy Way is a private road and the legality of its use to access the site is not established.
Sustainable transport patterns are not met as future residents would be dependent on car journeys for day-to-day needs.
The development would be at risk of flooding and increasing flood risk elsewhere. The proposal therefore does not represent sustainable development
There is demonstrable unfair bias in favour of the planning applicant to the detriment of objecting parties.

Question 1) - The Village Clusters Plan needs to ensure the allocation of 1,200 dwellings on new sites, for delivery in the period up to 2038. In terms of the overall number to be allocated, which of the three options above do you consider the most appropriate?

It is noted that as a result of a review of the selected housing allocations, some sites have been removed from the proposed Plan or the number of dwellings proposed to be allocated have been reduced. We therefore feel that it is sensible to include a healthy buffer to ensure that the Plan delivers sufficient dwellings, as some further sites may be rejected by the inspector or can’t be delivered for other reasons. Option (ii) therefore represents the most appropriate approach. It should also be noted that there are other shortlisted sites that have not been allocated and one in particular ref: SN0274REVA /B which was regarded as a ‘shortlisted site’ which represents an available and sustainable location for additional housing located outside of the Nutrient Neutrality catchment zone.

Question 10a) - Do you agree with the proposed allocation VC GIL1 REV, South of Geldeston Road and Daisy Way, Gillingham, on 2.92ha, for approximately 40 dwellings. Please explain your response.

Yes, this is fully supported, the site can easily accommodate approximately 40 dwellings as evidenced by the illustrative site layout submitted with planning application ref: 2022/1993. The site is very well located, as it is adjacent to the school and can offer the school expansion land, public open space, affordable housing and suitable access connections to the village and the commercial development to the north-east. As the planning agents for this planning application, we are working with all agencies to ensure that all aspects of the development comply with Council policy. It should also be noted that the site is located outside of the Nutrient Neutrality catchment zone. The Flood Risk Assessment which has been undertaken shows that the site of the proposed revised allocation, and the land to the east is outside of the Environment Agency’s projected flood zone, and so additional dwellings can be considered there too, either as part of the proposed revised allocation or otherwise.

Question 10b) - Do you think there are any specific requirements that should be added to the allocation policy to accommodate the extra 5 dwellings?

None

This is a flagrant example of a money grabbing landowner - there is no requirement for this amount of extra homes in this area. Beccles has already got a huge area ready for development on the other side of town but it has not been undertaken because there simply isn't the need for it. The land is already prone to flooding as anyone who lives near the proposed area can tell you. It doesn't matter what the flood zones reports say - you only have to go a look at it with your own eyes after a light rain shower. The roads in Gillingham are also not suitable for this amount of extra traffic.

According to the latest Housing Land Supply Assessment, the District has a supply of 5.87 years. This assessment demonstrates that objectively assessed, the housing needs for Gillingham are already exceeded.

Within the draft VCP, the ‘acute blind bend’ and ‘on-street parking’ at The Street were cited as reasons for the site to the north of The Street not to score highly. The same highway constraints apply to the south site and, therefore, it is not clear how the south site can score highly on these points. Daisy Way is also a private road and is unadopted and the legality of its use to access the site is not established for 35 or 40 houses.

At its closes point the boundary of the south site lies circa 100 m from the Broads National Park and with direct line of sight. The Council considers that the open, rural setting is an important characteristic of the village. In the Regulation 18 consultation on the Village Clusters Plan, the Council states: “The village is set in the Waveney Valley and adjacent to the Broads, and open views out from the village make an important contribution to its rural character". The Broads also have statutory protection under the Norfolk and Suffolk Broads Act 1988 and are to be treated in the same way as a National Park for the purposes of national planning policy. Paragraph 176 of the NPPF states “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and AONBs, which have the highest status of protection in relation to these issues". Therefore the south sites is in a highly sensitive location and will have significant adverse landscape and visual impacts on a National Park. It is not clear how the south site can be seen as preferred within the draft VCP and further expansion of the south site should not be considered. The nature and scale of the development is inappropriate in such a sensitive landscape environment and will impact upon the character and setting of the Broads National Park.

While the land allocated for the proposed development lies in Flood Zone 1, it is almost entirely encircled by Flood Zone 3 (Environment Agency Flood Risk maps). This is a key issue for safe access and egress. In line with EA data, flood risk will only increase into the future and therefore a housing development in this location is not sustainable.

The provision of land for expansion of the primary school is cited as a key reason for the south site to be selected as preferred, however, this land could be provided by the Applicant alongside development of the north site. There is no planning reason why the school expansion should be tied to the development of houses in this location.

Within the reasoned justification statement given for this revision, it is stated that “Whilst, at the time of writing, some technical issues on application 2022/1993 remain unresolved, it is considered that the site boundary could be extended east to allow for a slightly larger allocation of 40 dwellings”, this statement is factually incorrect. This planning application has not yet made it to committee and currently it is over a year since the application for the land south of the site was submitted. The south site presents some key challenges in relation to highways which are not yet resolved. The application has also received an overwhelming number of objections from local residents who are concerned about the impact of the proposed development on the environment and the community in which they live. The proposal to expand the south site in favour of the north site suggests that due legal process in the planning application is not being followed.

The north site which is not currently allocated as preferred presents a more suitable location as access issues can be resolved through the provision of an access road via the existing services. The site is a greater distance from the Broads National Park and is not in direct line of site, reducing potential impacts on a National Park. Land for the primary school expansion can be provided separately to the development of the south site and therefore there is no clear planning reason why the south site is preferred over the north site, given the Highways, landscape and flooding issues this presents.

This 'public consultation' is a total farce. SNC have ignored the villages desire to use the North site in their quest to create as many homes as possible no matter what the risk to others homes. This site floods and will further exacerbate an already dangerous road. This site goes against NPP as it is in the 'wide open countryside' and will see the destruction of valuable agricultural land.

1) Traffic issues along The Street. The bend is very dangerous and the amount of parked cars from the bend to the give way (Loddon road) is very excessive.
2) Encroachment on the countryside would be massive, and the distance to the Norfolk broads National park is very small.
3) The flooding in the area over the last 18 months has been very high, even in the field that has been proposed. Building in this field will mean other houses in Gillingham will flood in the future.

We note the proposal to increase the site boundary and an allocate an additional 5 dwellings to the site at “VC GIL1 REV Land south of Geldeston Road and Daisy Way”. The reasoned justification for the proposed change to this site relates to planning application 2022/1993, for which the Environment Agency have objected to on flood risk grounds.

We note that policy “VC GIL1: South of Geldeston Road and Daisy Way” requires developers to submit “A site-specific Flood Risk Assessment (FRA) and strategy that has regard to the issues identified in the Stage 2 VC Strategic Flood Risk Assessment (SFRA), to inform proposals for the site and preparation of a Flood Warning and Evacuation Plan”. As such, the proposed increase to the site boundary and the additional five dwellings does not currently change our objection position on flood risk grounds to planning application 2022/1993. Detailed review of any updated FRA will take place under any future re-consultation or application for the proposed site.

We do wish to highlight that there is a risk on the deliverability of this site allocation for housing until our flood risk objections are resolved.

This development is significantly out of scale with a village of less than 300 dwellings, is outside the defined village boundary, it’s an incursion into open countryside and a detriment to the wider Broads amenity.
There’s significant opposition to the development following the previously developed VCHAP site of 10 dwellings being 'overdeveloped' with 22 houses built (Daisy Way/Tulip Close).
Gillingham primary school is over-subscribed and funding is unlikely to be provided for any expansion.
Sustainable transport requirements are not met, future residents would be dependent on car journeys.
Development is at risk of flooding and increasing flood risk elsewhere.

The land is subject to flooding. Before any development is approved investigations should be made into the cost of building flood resistant properties and additional flood prevention measures. This would make the development very expensive and the cost would have to be put onto the homebuyers, thus preventing the construction of affordable housing as set out in the plan. There would also be the issue of insuring the completed buildings against flooding which would be difficult to source, prohibitively expensive and uneconomical to buyers. The result would be an estate of unwanted and uninhabited houses