The plan does say what is required in the way of forward planning for housing in South Norfolk but it doesn't then say no more after that.
It needs to include a date at which further planning approval can be applied for in the future so at least residents know where they stand.
Forward planning doesn't mean short term planning which in this case it is short term, it upsets everyone.
The residents of Daisy Way Gillingham were informed when they purchased their home that there would be NO more properties built on their small estate, now there will be 35 more and years of disruption, the houses in Daisy Way being built on the 2015 approval the next 35 on this application, just a few years later. I'm sure they might not have purchased (some at £600.00) had they known.

It seems totally crazy that the previous Cluster plan approved in 2015 ( with 22 properties having been built and only just finished) hasn't been taken into account when allocating extra housing in Gillingham. does this now mean that in a few years time another Cluster pan will be put forward with more housing.
Surely a plan is exactly that, planning for the future and not in this case just a few years. The needs of the housing community hasn't changed that much in just 7 years.

The plan to develop further houses on this flood plain needs to be scrapped. If houses are still to built against all the concrete evidence against it, there should at least be access from a different point i.e. not through The Street and thus not through Daisy Way.

- Within the site assessments of the Village Clusters Plan, sites SN0274 REVA and REVB were seemingly discounted on grounds of flood risk, but also safe access with the assessment stating:
‘Highway safety concern due to adjacent acute blind bend and on-street parking at The Street’
This is also an issue for homes developed on VC GIL1, as the site will require use of the same road to access the wider transport network. It is unclear how these same criteria can be used to discount other sites but result in VC GIL1 as preferred when it has exactly the same issues in terms of safe access and egress. For these reasons this site (VC GIL1) should also be discounted.
- The Environment Agency (EA) recently responded to consultation on an opportunistic planning application for the land south of The Street (2022/1993)- site GIL1- to provide a holding objection on flood risk grounds. EA maps show the site is located in fluvial and tidal Flood Zone 3, the high probability zone.

No more building in Gillingham leave it to the countryside as it is meant to be. We are depriving nature of its home like foreign countries are doing and animals are becoming endangered, like hedgehogs are here on the red endangered list hence the protection acts

Noise 24 hours 7 days a week more brighter as more lights, traffic on roads that can't cope now. Roundabout is Already an accident hotspot. Being built on a flood plain, when planning was supposed to be for houses. Effect it will have on wildlife, with badgers hedgehogs (an endangered species) with various protection acts, birds bats field mice water voles, also it's a lovely quiet place to walk round. Who wants that industrial estate on there doorstep not me would you. Depriving nature of a home you wouldn't want to be kicked out of your home

The traffic problem through the street would have to be addressed in some way as to aliviate the problem that already
exists with vehicles parked on the roadside
this at the moment causes a major risk for some people exiting their property onto the road
Also the risk of flooding
on the site would have
to solved in a
satisfactory way .

My main concern would be the increased volume of traffic through the street in Gillingham which this proposal would effect.
My other concern is to the risk of flooding on the development site being a resident in the village for over fifty years I have witnessed this site flooding annually.

VC Site GIL 1 is not appropriate for development and should not be allocated for the reasons given above. In addition, recent development has taken place in the village with the addition of 22 new houses at Fieldgate Reach which was only completed in 2022. The impacts of this site on the environment and community are not yet understood and the proposed allocation of VC GIL 1 is not considered cumulatively with the recent Fieldgate Reach development. This is a clear short fall of the plan and the cumulative effects of these developments should be considered. Development at this location would also have a number of significant impacts which are not in line with national policy or with the core objectives of the Village Clusters Plan itself. For these reasons the plan should be reviewed and this site should not be allocated for development.

This site is inappropriate for development and should not be allocated. Reasons include:
- Lack of services within Gillingham (dental, doctors, social care) and lack of capacity in Beccles
- Large scale development in Beccles (c.450 homes) not considered in this plan
- Clear issues of flood risk, safe access and egress (see EA's holding objection to (2022/1993)
- Clear issues with safe access along The Street and the acute blind bend (see NCC highways response to 2022/1993)
- Local significant adverse impacts on rural character and on nationally designated sites including Broadlands SPA and Broads SAC

The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.

South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)

1.1. The following submissions consist of firstly comments on section 16 “Gillingham, Geldeston, and Stockton” of the Regulation 19 Pre-submission Draft of the South Norfolk Village Cluster Allocations Plan with specific comments on Gillingham.

1.2. The second set of submissions relates to the non-allocation of an area of land to the north of the street reference (SN0274) and the impact that this has on the soundness of the plan in relation to the residential allocations.

16. Gillingham, Geldeston, and Stockton
Form and Character
Gillingham

16.1.
NO COMMENTS

16.2.
NO COMMENTS

Services and Community Facilities
16.5. The cluster has a range of social and community facilities comprising a primary school, village hall and motel in Gillingham and a village hall and pub in Geldeston. Gillingham has a regular bus service to all local towns. There is a more limited bus service in Geldeston, to Diss, Bungay, Beccles and Yarmouth. There is a petrol station, with a convenience store, and fast-food restaurants to the north at the A146/A143 roundabout, which have a direct pedestrian/cycle link from the village.
COMMENT: It is submitted that the facilities at the A146/A143 should be described in greater detail in relation to planning application 2020/0491 which includes a farm shop and application 2023/0187 (still to be determined) which seeks to provide an electric vehicle charging hub and associated shop, a drive-thru cafe/restaurant/sandwich shop/bakery and two buildings for use within Class E (g) (iii), B2 and B8 including trade counters and ancillary showrooms. The area provides both services to the residents of the village as well as job opportunities. The ongoing expansion of the area can help to support the housing increase.

Settlement Limit
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
Gillingham
16.6. The Settlement Limit is in two parts. The first includes the main built form of the settlement. The second part is around the school and adjoining housing, an area which has been extended to include the recent development at Daisy Way, which was allocated in the 2015 Local Plan.
COMMENTS: The boundary of the Settlement Limit (red line) around Daisy Way and Tulip Close does not encompass all of the dwellings which have been approved and built. A strange ‘gap’ has been created between the boundary of the proposed allocation and the proposed settlement boundary.

VC GIL1
16.8. The site lies to the south of a detached area of existing residential development and Gillingham St Michael's Primary School, south of Geldeston Road/The Street, at the western end of the village. The site is well located for the local services, including a newly created pedestrian and cycle route to services at the A143/A146 junction, and buses on the main Norwich/Beccles route. Main facilities in Beccles are also within a reasonable cycling distance of the site.
COMMENT It is submitted that in addition to the reference to ‘services,’ there should be a reference to local employment opportunities offered by the facilities.

16.9.
NO COMMENTS

16.10.
NO COMMENTS

16.11. At the Regulation 18 stage of the VCHAP the site boundaries were drawn further to the east and included areas within Flood Risk Zones 2 and 3a and tidal flooding. Following the outputs of the Stage 2 Strategic Flood Risk Assessment (SFRA), the site boundaries were moved further east. However, this also incorporates areas at both surface and fluvial (Zones 2 and 3a) flood risk in the south-western corner and a remaining small area of tidal flooding in the southeast corner, which it is recommended are left undeveloped. Development of the site will require a site-specific Flood Risk Assessment (FRA) and strategy, to inform the layout of the site.
COMMENT The need for a full FRA is noted.

16.12. The site is immediately south of Gillingham St Michael's Primary School and would landlock the school if developed out in its entirety. The VCHAP currently proposes 35 dwellings on this site and a further 20 within the school catchment at Geldeston (VC GEL1), which would add a modest
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
number of pupils to the school. As both villages also experienced growth under the 2015 Local Plan and Gillingham has other sites that were shortlisted in the VCHAP Regulation 18, which are still being actively promoted, it would be reasonable to expect that there will continue to be growth in the future. As such, the County Council has requested that 0.5ha of land be safeguarded for the expansion of the Primary School, that would facilitate integration with remainder of the site when brought forward.
COMMENT The land requirement is noted.

16.13. The site is noted as being amber for great crested newt, due to the pond adjacent to the school. The site is also within an SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England.
COMMENT The need is noted

16.14. Although the site is 2.36ha, the allocation is for approximately 35 dwellings, reflecting the need to safeguard 0.5ha of land for F1(a) use for the Primary School and the need to address flood risk issues.

Policy VC GIL1: South of Geldeston Road and Daisy Way
2.36 ha of land is allocated for approximately 35 dwellings.
The developer of the site will be required to ensure:
 Vehicular and pedestrian access via Daisy Way;
 Pedestrian links to footpaths Geldeston FP8 and FP9 to the west of the site;
 Facilitation of the formal diversion of footpath Gillingham FP12, or the incorporation of the formal route into the layout of the site;
 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;
 A full Landscape Assessment to inform the scale, form and density of the development, as well as the extent of the protection and enhancement of the existing vegetated boundaries;
 0.5ha of land set aside for Use Class F1(a), for future expansion of Gillingham St Michael's Primary School.
COMMENT The overarching requirements as set out in section 16.4 are noted

1.3. During the call for sites stage of the VCHAP two sites were put forward for Gillingham.
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
1.4. The land to the south of The Street is a proposed allocation in the plan. The land to the north of The Street has not been included as an allocation.
1.5. It is submitted, for the reasons set out below, that the uncertainty surrounding the implementation of the plan as a result of the impact of Nutrient Neutrality undermines the overall aims of achieving a proscribed number of dwellings.
1.6. The land to the north (SN0274) was shortlisted as a potential allocation. While the exact extent of the Flood Zone would need to be established in detail it was noted that there were few other planning constraints. It was also noted that the site would help to provide good connections to the service/employment land to the north.
1.7. The allocation of the northern site could provide much-needed amenities like a proper playground and a Multi-Use Games Area as shown in the proposed application. An all-weather area that can be used as a coloured playground and can be designed to accommodate a wide range of sports, training and games. A MUGA pitch would be an important community asset for the village.
1.8. The need for affordable housing within Gillingham could be increased by the construction of a greater number of units than would normally arise from the Local Plan percentages.
1.9. The allocation of the site would enable a continuous flow of housing development to take place rather than the ‘feast and famine’ which results from the plan-making cycle of the Local Plan process.
1.10. The VCHAP both in the main report and the Viability Appraisal document details, as far as possible, the impact of Nutrient Neutrality.
1.11. The Viability Appraisal seeks to determine if “a ‘surplus’ is generated to enable either a Nutrient Neutrality Tariff to be levied for ‘off-site mitigation, that a proposed development has sufficient capacity to cover any increase in ‘on-site mitigation costs, or, a combination of both ‘on’ and ‘off-site costs”. The final details have yet to be modelled and resolved and this introduces a degree of uncertainty in meeting the aims of the plan.
1.12. At present, there appears to be no time frame available as to when the issues associated with Nutrient Neutrality and possible ‘Tariff’ will; be resolved. In
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)
addition, it is uncertain if the developers of the sites will be able to comply with any tariff requirements.
1.13. Residential land allocations in some settlements are located within Nutrient Neutrality Zones. This means that while the VCHAP process can move forward there is a strong possibility that the construction of dwellings will be delayed for a yet unknown time. The table, taken from the VCHAP documentation shows those settlements, including the site allocations which are being ‘brought forward’ from the previous plan are currently subject to ‘Nutrient Neutrality constraints.
1.14. The table shows that of the 1122 dwellings shown as allocations 413 (37%) are subject to nutrient Neutrality constraints. Of the 173 dwellings carried forward from 2015 145 (84%) are subject to Nutrient Neutrality constraints
1.15. The land to the north of The Street is not subject to Nutrient Neutrality constraints and if allocated could be developed in a short time and make a contribution to the housing provisions of the plan.
1.16. It is submitted that the plan is over-optimistic regarding the impact of Nutrient Neutrality on the allocations. As a result, it fails the test of soundness.

G D Smith
Landmark Associates
South Norfolk Village Clusters Housing Allocations Plan
(Regulation 19 Pre-submission Draft)

At a time when the demand is for us all to “go green” - use our open spaces and walk, South Norfolk is proposing an extensive build, to swallow up acres of land and green space, commandeering Public Footpaths and in general polluting a rural landscape.
With no consideration to the impact this will have on the local residents and the destruction of their local landscape.

The light pollution will have an enormous detrimental effect on humans and wildlife.

The increase in traffic through small village streets is nearly at breaking point and with a further increase will be intolerable.

There are no plans for extra school or health facilities - which are now at a premium.

With all this is mind, as a resident I am extremely worried and alarmed by this extensive planning proposal. This will not be an extension to a village, but a plan to create a town on a flood plain.

Construct a new road through the McDonald's site onto The Street. Or develop SN0274 Rev B instead of SN4078 taking access again through the McDonald's site instead of onto The Street. The land in question is under the same ownership for both sites and also the land required for a link to McDonald's

The road through Gillingham is restricted by parked cars, leading to single track working which is dangerous. The parked cars have nowhere else to go as they are in-front of houses. Surveys carried out of residents by Gillingham Parish Council rejected any option to introduce no waiting restrictions. (I have the survey results in my possession)The road is therefore unsuitable for any increased traffic on it, particularly with the 2 z-bends.
The proposals involve an overlong cul de sac as it gains access through the existing Daisy Way.

The 5th bullet point needs to mention assessing potential impact on the Broads, as is written in para 16.10.

Where it says in 5th bullet point there is a need for a fill Landscape Assessment, is that a LVIA? Does it need to mention the term LVIA to make it clear what is required? For example, this policy talks about a Landscape Assessment whereas policy VC ROC1 talks about a Landscape and Visual Impact Appraisal. Why the difference?

This site is included in the LVA which considers Broads issues and notes: 'Landscape caution. Previous issues experienced with the existing allocation GIL1 and significant work was undertaken to agree a suitable landscape scheme given the landscape sensitivities of the site. The site is in close proximity to the Broads (King’s Dam) and footpaths run parallel to the south and west of the site. A landscape assessment would need to be undertaken to ensure that neither the Broads nor the public routes were adversely impacted. GIL1 has a landscape scheme to the south to ensure the impact of views from these areas are mitigated – this would need to be carried forward if this site did progress'. This assessment is supported.

However, the policy does not mention anything about this and this is an issue.

In light of the NPPF policy quoted above, we recommend that policy wording in VC GIL1 should reflect this. The policy wording should be revised to clearly signpost the need for any application to 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.

This allocation is in relatively close proximity to Geldeston Meadows SSSI, a floodplain grazing marsh and component of the Broads SAC/Broadland SPA which is currently in an ‘unfavourable condition’ with a small part in an ‘unfavourable declining’ condition.

National Planning Policy Framework (NPPF) 180: ‘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…..’

The North site should be properly considered with an exit onto the roundabout via Hearts services.

- Has not responded to the previous consultation therefore due process has not been followed.
- Paragraph 79 of The NPPF states that 'To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. ’ The allocation of the site for up to 35 dwellings, would represent gross over-development of a Service Village, particularly when taken alongside the previous development 2022/1897 at Fieldgate Reach (Daisy Way and Tulip Close) which was completed only in summer 2022. It will result in the loss of a vital footpath and the only open green space the village has.
- - Paragraph 69 of the NPPF notes ‘the importance of small and medium sized sites, up to 1 hectare in size, in contributing to meeting housing needs, particularly in terms of the ability to deliver those sites quickly’
The proposed site VC GIL1 is c.2.36 hectares in size and therefore more than double than the size of sites identified within the NPPF. The number of houses proposed (c.35) in addition to the recently developed Fieldgate Reach Site (22 houses) is disproportionate to the size of the village and far in excess of that which was set out in the Joint Core Strategy (Policy 15). This identifies Gillingham as a Service Village in which land will be allocated for small-scale housing growth between 1 April 2008 to 31 March 2026, within the range of 10-20 dwellings, subject to form, character and servicing constraints. Development of an additional 35 dwellings in addition to the recently completed Fieldgate Reach site is clearly out of scale for this proposed level of development, resulting in between 220% and 440% of the planned growth for Gillingham.
- It is unclear how the aims and objectives of the Joint Core Strategy can have changed so much in such a short space of time. This level of growth is not in keeping with the Village Clusters Plan key Objective SNVC 3 – to protect the character of villages and their setting.
- It is also unclear why Gillingham is being subjected to such high levels of development which are out of keeping with the rural character of the village. Alongside the village clusters plan, recent opportunistic planning applications have been submitted for the same site (2022/1993) and for the site north of the Street (2022/1897), as well as proposed extensions to the services at Gillingham (2023/0187) which includes an out of town retail park, the size of which is grossly disportionate to the size of the village. These applications have all been submitted in a matter of months and it is unclear how Gillingham can be the focus of multiple large scale development which will severely impact the rural character of the village and its surrounds.
Flood Risk
- Within the settlement description for Gillingham (GIL1) the site is also identified as having constraints in relation to flooding, and the description states:
‘The extent of the new housing allocation is limited to land that is within Flood Risk Zone 1. It is not appropriate to allocate a larger site due to the surrounding land being at a higher risk of flooding. Within the land allocated, an allocation of approximately 10 dwellings is considered appropriate to reflect the form and character of existing built development to the west of the site’
- It should also be noted that the Environment Agency (EA) recently responded to consultation on an opportunistic planning application for the land south of the Street (2022/1993) to provide a holding objection on flood risk grounds. The reasons for the objection is that the EA maps show the site is located in fluvial and tidal Flood Zone 3, the high probability zone. This high flood risk and the EA comments should be referred to when considering the allocation of site GIL1 as a preferred site for future development.
Environmental Impacts
- The consultation documents for the Village Clusters Plan state that this site is noted as being amber for great crested newt, due to the pond adjacent to the school. The site is also within an SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England.
- It is highlighted that Natural England have returned comments to a recent opportunistic planning application on the same site ((2022/1993)) to highlight that the application could have potential significant impacts on a number of protected sites and features including the Broadland Ramsar, Broadland Special Protection Area (SPA), The Broads Special Area of Conservation (SAC) as well as Barnby Broad and Marshes Site of Special Scientific Interest (SSSI), Geldeston Meadows SSSI and Stanley an Alder Carrs Aldeby SSSI.
- The Sustainability Appraisal Report prepared by AECOM and provided in support of the Village Clusters Plan identifies that Village clusters at the north and east of the District stand out as having the greatest sensitivity in terms of proximity to designated sites of international biodiversity significance associated with the Broads. This includes GIL1 which is within 1km of the Broadland Special Protection Area (SPA) and the Broads Special Area of Conservation (SAC). This is considered a distance within which new development could generate additional pressure on designated sites.
- The Sustainability Appraisal also identifies VC GIL1 as having potential landscape impacts on the setting and character of the Broads National Park. Reasons given are that that the allocation is large in scale, departs notably from the existing settlement pattern and has clear lines of sight through the National Park, only 200m to the south, without any screening. It is also noted that footpaths run parallel to the south and west of the site with associated visual impacts and impacts on public amenity and access to green spaces.
- The proposed preferred site (VC GIL1) is allocated in addition to the 22 homes recently completed at Fieldgate Reach. The sites cannot be assessed in isolation as VC GIL1 would be viewed as an extension to the now constructed Fieldgate Reach site which would only serve to increase potential landscape impacts. The impacts of the homes under construction on designated sites and the Broads National park, are not yet understood. The combination of the proposed sites will form a development of up to 57 houses which will add considerable pressure and impacts to sensitive environments, including protected sites and features.
- It is noted that the Village Clusters Plan states it seeks to protect the countryside and takes care to protect important landscapes, plants and wildlife. Given the potential environmental and landscape character impacts associated with VC GIL1, this appears to contradict the core objectives of the Plan and the site should not be allocated as preferred.
- Development on open greenfield sites should be avoided while other solutions less harmful to the environment and countryside are investigated. It is clear that there are sufficient allocated sites for housing within the existing Joint Core Strategy without the need to consider developing unallocated sites. This appears to call into question South Norfolk District Council’s decision making process when promoting development under national planning policy.
Access
- A singular point of access to VC GIL1 via Daisy Way is unacceptable. The entire area lies in Flood Risk Zone 3 as confirmed by the EA and safe access and egress can not be provided in times of flooding.
- The local road network and acute blind bend along The Street can not cope with the level of additional traffic this development would bring and Highways improvements would need to be made. It is noted that Highways Agency have confirmed this within its response to a recent opportunistic planning application submitted (2022/1993). This should be referred to when considering VC GIL1 as appropriate for development.
- Within the site assessments of the Village Clusters Plan, sites SN0274 REVA and REVB were seemingly discounted on grounds of flood risk, but also safe access with the assessment stating:
‘Highway safety concern due to adjacent acute blind bend and onstreet parking at The Street’
The assumption within the site assessment for VC GIL1 appears to be that safe access can be provided through the recently constructed Fieldgate Reach development. This is very misleading, as the acute blind bend and on street parking at The Street will also be an issue for homes developed on VC GIL1, as the site will require use of the same road to access the wider transport network. It is unclear how this same criteria can be used to discount other sites but result in VC GIL1 as preferred when it has exactly the same issues in terms of safe access and egress. For these reasons this site (VC GIL1 should also be discounted).