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

The agents acting on behalf of Todhunter Ltd are working with the Council’s planning department and other agencies to ensure that all aspects of the total site (including the extra five dwellings) are in accordance with planning policy and good planning practice. It is envisaged that the Council will attach appropriately worded conditions setting out any additional requirements, which will need to be approved by the Council at the detailed application stage.

See attachment for full response.

Please see attachment for full representation.

See attachment for full representation.

See attachment for full representation.

No extra dwellings are required.

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 site would remove access to the only Public Footpath with year-round accessibility and which is widely used by residents of the village for recreation and exercise.
5. 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.
6. 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.
7. 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.
8. 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

An extra 5 dwellings to the 35 is not required as it will only make matters worse

Daisy Way is a private road and is unadopted and the legality of its use is not established. A separate access from the street should therefore be provided.

landscaping provision at the Daisy Way and the services expansion development is completely insufficient The VCP accepts that there will be significant localised impacts and therefore a more detailed landscaping strategy should be provided.

The 0.5ha of land for the Primary School expansion should not be tied to development of the south site.

Clear flood risk issues will need to be addressed.

See also detailed comments at 10a above.

If these additional homes are approved then a larger proportion needs to be made 'affordable'. We have spoken to developers who have confirmed that the land requires so much prep that it will only be suitable for 'executive' homes in order to recoup these costs. This means more emphasis needs to be placed on affordable homes.

The site is within Geldeston Meadows SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England. Geldeston Meadows SSSI is a floodplain grazing marsh which is currently in an ‘unfavourable condition’ and a small part of which is in an ‘unfavourable declining’ condition. It is also a component of the Broads SAC/Broadland SPA and within the Impact Risk Zone.
National Planning Policy Framework (NPPF) 180 states ‘When determining planning applications, local planning authorities should apply the following principles: ….b) development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted…..’
In light of the above policy, we recommend that policy wording in VC GIL1 should reflect this. Any applications should review any potential indirect disturbances to this site in an ecological assessment, in particular with respect to potential visitor pressure impacts.
This site is also noted as being amber for great crested newts, a protected species. We therefore recommend that any policy wording also includes reference to the need for an appropriate great crested newt assessment prior to determination, in order to ensure that the allocation is supported by the appropriate ecological evidence.

Unless they are for affordable houses. Most houses in the village are bungalows or terraced houses, and so extra houses should be in keeping with what’s already here !

This proposed development is out of scale with the size of the village and increasing the proposed allocation makes it worse. There is no capacity at the local school (which served Geldeston also). Gillingham had an allocation of 10 new homes in the VCHAP Reg18, and 22 were built on that site. Gillingham is therefore 'in credit' by 12 houses and should certainly not be increased. All local medical and dentistry services in Beccles are saturated from existing and new development in the area served, creating a health crisis where people will significantly suffer or die.

The reason for my objection above will also apply to any further development on the site