The access arrangement to the proposed dwellings to be made more robust and safer, given the existing flow of traffic in this area.

The access proposed is not sufficient for the amount of development proposed, in reality houses are likely to be a 'two car households'. Turning right out of the development will mean a hard right turn made more difficult with the existing on road parking for those attending the local shop and post office. The proposed access point will not allow for two way traffic and pedestrian access therefore making it an accident risk.

FW Properties consider Site VC ROC2 to be a suitable and deliverable location for new homes within the village. Development in this location, which is in close proximity to an established community, would represent sustainable development as defined within the National Planning Policy Framework. With its current provision of services and amenities, including the doctors surgery, village shop and primary school, Rockland St Mary is an appropriate location for growth.

Site VC ROC2, which is owned by one landowner, is immediately available. FW Properties, who have previously developed 23 new houses in Rockland St Mary in 2020, consider the development of Site VC ROC2 for 25 new homes to be viable and deliverable. The scheme will provide a mix of dwelling types and sizes to meet local needs.

Vehicular and pedestrian access from The Street to VC ROC2, together with the connections to services, will be provided by way of a new adopted road to be constructed on the existing field access between 24 and 26 The Street. A new pedestrian footway will also be provided along the southern edge of the Street to connect into existing footways outside 34 The Street.

We believe the site is not subject to any delivery constraints which would prevent its development for new homes and FW Properties believe that the site specific requirements attached to this draft allocation can all be fulfilled. In addition to the vehicular and pedestrian access requirements outlined above, the mature trees and hedging along the boundaries of the site will be retained as part of the overall landscaping and screening of the development.

On this basis, FW Properties believe that Site VC ROC2 should be taken forward for allocation as it will make a valuable contribution to the planned housing growth in South Norfolk in the period up to 2041. It is FW Properties’ intention to progress the development of these new homes as soon as possible but the timing is likely to be dictated by our discussions with Anglian Water and their proposed improvement works to the Whitlingham Water Recycling Centre.

Change the plan to reject all the sites to the south of The Street and New Inn Hill since they constitute a danger to school-children, the elderly and disabled, and environmental pollution through increased traffic, joining and using the Street, whilst irrevocably destroying a far more beautiful long-view than any of the northern sites, which have been rejected on such grounds. Southern sites will destroy natural habitats which promote biodiversity, including the Common Spotted Orchid which grows wild in this southern valley but not on land adjoining northern sites. If northern sites have been rejected on panoramic/environmental grounds, then the plan must be changed to reject all proposed and revised southern sites too.

Resultant increased traffic joining/using the Street is detrimental to safe crossing for school-children, the elderly and disabled. Traffic-flow at school entry and exit times is already beyond safe and environmentally-friendly limits due to the Langley School 8 vehicle-long minibus train twice daily, local commuter traffic from Claxton/Hardley/Loddon and cut-through usage avoiding the A146. This site encourages further site SN5039 the exit road from which constitutes direct danger to life and limb for school-children, the elderly and disabled crossing at the blind junction to School Lane. Secondly, if northern sites rejected then southern sites must too since long-view also impaired.

Additional to my previous Objection ID 2395 evidence of Common Spotted Orchid in valley directly adjoining Sites south of the Street https://www.inaturalist.org/observations/50984746

Additional to my previous Objection ID 2395 evidence of Common Spotted Orchid in valley directly adjoining Sites south of the Street https://www.inaturalist.org/observations/50984746

Refuse them, village highway infrastructure unsuitable size of vehicles and volume of traffic, public transport inadequate for commuters to Business parks and only for 09:00 to 17:00 workers, negatively impacting on pollution as would increase car usage. Our Hospital and Doctors surgery's cannot cope with our local population now.

Narrow road, parking, traffic, HGVs road is narrow to the point that two large vehicles cannot pass safely.
The single footpath that runs through the village is narrow less than the guidance in The Highways Act 1980 which states the min 1m, Disability Act (DDA) recommends that a minimum of 1.2m is provided, outside the revised settlement limit The central area of the village is linear and creating a site in this location would destroy this historic feature and (regardless of assurances) would set a precedent. negative impact on Climate and wildlife (lots more than you allow, why).

The entrance is close to the Post Office/shop and Pearls pool, where throughout the day parking is constant with HGVs and LCVs parking to deliver stock and users of the Pool, the road is narrow to the point that two large vehicles cannot pass without one having to drive on the footpath causing risk to pedestrians as do the frequent parking on the footpath by some. The footpath is very narrow in places (less than 700 in places) a safety post installed by NCC recently to protect pedestrians from the Flats opposite the shop, was recently knocked over by a passing vehicle (this was not replaced due to the risk of being hit again) the safety railings have also been hit. The road is frequently used by maximum size HGVs (44t) and exceptionally large farm machinery/equipment this coupled with parking make the area high risk, this would increase if the proposed development were to proceed as the exit would be opposite or close to parked cars, with traffic on the wrong side of the road when passing.
Although there is a single footpath that runs through the village this is narrow in places less than the guidance in The Highways Act 1980 which states the minimum is 1m, The Disability Act (DDA) recommends that a minimum of 1.2m is provided, the village has parishioners with mobility needs, Mothers with pushchairs etc. The footpath provides a walking route to the primary school, but now many parents prefer to drive and park closer to the school where it is necessary to cross the road at a particularly dangerous bend to get to the school.
There would be an increase in delivery vehicles (supermarket, DPD, Hermes etc. etc.) also a negative impact on climate change through increase in traffic, etc. and loss of arable land. I am genuinely concerned on the impact on climate and our valued wildlife habitat. The current bus service is not commuter friendly resulting in additional vehicles for commuting to and from work, also more self-employed utilising Vans for their trade. The Village is already a A146 escape route especially during frequent A146 issues and is becoming a rat run for avoiding the congestion on the A146. Currently Langley School uses the Village route (12 to 15 minibuses per evening) to avoid turning right on the A146, also a number driving through the village in the mornings.
The development would not necessarily increase attendance at the village primary school as there are parents who take their children to other schools out of the village where driving is a necessity, also evidence suggested by CPRE indicates that the likely persons to purchase properties are likely to have children of High school age.
South Norfolk needs to take a lead on the utilisation of existing brown field sites instead of trying/promoting development of the countryside. The bigger picture seems to be ignored.

1. Find alternative safe access points before plan can proceed.
2. Reduce significantly the number of proposed dwellings.
3. Village infrastructure not capable of accommodating additional traffic, parking and footfall thus damaging the character of the historic village.

The plan for 25 dwellings will adversely affect the long view aspect and visual appearance of the village. To be sound, the authorities are required to protect the historic character of the village, and this proposal, in terms of position and proposed dwelling density is not compliant with this requirement. The promoter has failed to satisfy any reasonable test that increased traffic flow and increased pedestrian volume would be safe given the existing road width of The Street, the proposed access points, the narrowness of existing footway (note only on single side of The Street), limited on street parking and congestion around the post office and school-run traffic. The Street becomes a cut through to general traffic from the A146 whenever there is a traffic incident.

No consideration appears to have been made about the continuing need for agricultural machinery access to the remaining farmland. Combine harvesters can only use the track between houses numbered 24 and 26 The Street at the moment. If this access is eventually made available to the promoter, how would machinery pass through 25 dwellings safely?

We particularly welcome the clear and robust policy wording with respect to hedgerows/trees in Policy VC ROC: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ and Policy VC LMI: ‘Protection and enhancement of the ecological/biodiversity features of the site, including the established trees, hedgerows…’

We recommend that similar policy wording is applied to the policies listed below to ensure that the Local Plan consistently provides robust protection for all hedgerows/trees on these allocated sites, as appropriate. Where removal of any part of a hedgerow or a tree/s is absolutely unavoidable, we recommend that policy wording should also include reference to mitigation measures and ideally reflect the updated biodiversity duty required in the 2021 Environment Act to have regard to the enhancement of biodiversity.

VC BB1 (Barnham Broom), VC BRE1 (Bressingham), VC HAL2 (Hales and Heckingham), VC SWA2 (Swardeston), VC NEE1 (Needham), VC WOR2 (Wortwell), VC NEW2 (Newton Flotman), VC SPO3 (Spooner Row), VC TAS1 (Tasburgh), VC BUR1 (Burgh St Peter), VC WIN1 (Winfarthing)
Hedgerows (Priority Habitat)

Local Authorities have a duty under the NERC Act 2006 and the Environment Act 2021 to have regard to the conservation and enhancement of Priority Habitats in their decision making. Hedgerows are listed as a Priority Habitat under the requirements of section 41 of the NERC Act.
Also of relevance is: National Planning Policy Framework, (NPPF), 179: ‘-To protect and enhance biodiversity and geodiversity, plans should…62 b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.’

Trees
Trees are given some protection in legislation, for example, from the National Planning Policy Framework (NPPF). However, we strongly recommend that the Local Plan provides fuller, more detailed and comprehensive protection as described above.
National Planning Policy Framework (NPPF), 131: Trees make an important contribution to the character and quality of urban environments, and can also help mitigate and adapt to climate change. Planning policies and decisions should ensure that……. appropriate measures are in place to secure the long-term maintenance of newly-planted trees, and that existing trees are retained wherever possible.

Access to this site needs significantly rethinking - I have no idea what the residents themselves think of access from the currently proposed route it sounds pretty odd?

I wish I had an easy answer?

I have answered no to legally compliant however that is beyond my knowledge.

I have lived in the village for over twenty five years and am aware of traffic flow and pedestrian usage though. The site proposed for access is just before the access to both the village shop on the left hand side of the road, opposite the proposed opening, and just before the turning to the local surgery on the same side of the road. Traffic flow at the village shop and the surgery is the area where cars stop for very short periods, turn around etc. During school pick up and drop off times the traffic flow is particularly congested. The pavement is heavily used by pedestrians and in these peak times particularly parents, buggies and children. If you add a further junction with a further flow of traffic I believe you will significantly increase the risk of accident and injury and likely cause an accident black spot to the village.

I also raise concern for the new dwellers of the enclave and the ‘road’ being wide enough for a road, pavements and cycle lane in the existing width between the properties being discussed - though I have not measured it so I have to leave you to the sums.

My biggest concern is for the increase in traffic in the 200 meter zone from the new junction to the village shop and GP surgery and the increase in cars turning, etc and thus accident blackspot risk increasing.

Fewer houses would be acceptable for this site more than 10 would be disproportionate

To protect the character of the village. 25 Dwellings on this site is too high a number for such a small village, surely a smaller number would be more appropriate for the village of this size.

Affordable/social housing must be the most important addition to the village, not large expensive houses.

I do not believe this is a suitable site for development.

Access to the proposed site would cause even more congestion around this area of The Street already over-used with people parking for the shop/post office located nearby. Pavements are narrow and unsafe. You can only walk in single file. Pedestrians whether young or elderly will be at more risk of accident.
How will the existing pond be retained, it is located in the proposed access splay.
It will destroy the linear development of the Village and have a detrimental impact on the exsiting footpaths and rural landscape to the rear.

The scale of development and impact on the landscape needs to be reconsidered to meet Objective 3.

The site would be outside the current settlement limits, take up prime agricultural land, put increased pressure on road safety (blind bends, accident hot spot), and impact on the natural beauty of the landscape from the public rights of way (SNVC Objective 3 - Protect the character of villages and their settings), as well as loss of prime hedgerows, green space and habitat.

The proposed density of housing is likely to increase surface water flood risk and increase flows into Hellington Beck. Changes to groundwater and surface water flows could adversely affect downstream ecosystems and designated sites.

Certainly far fewer houses.
Better consideration with regards traffic in and out of the development and the increased volume of traffic in the village as a whole.

My main concern is the substantial increase in traffic through the village as a result of the building of 25 new homes.
The village simply cannot cope with this increase and the risk to life or serious injury should not be overlooked.
The negative impact of raised fume and noise pollution is equally concerning.
The entrance to the new housing development looks far from safe and thoroughly thought through and this will impact pedestrians using the shop and surgery too.
25 new homes in this development is far too many.
Please reconsider your plans here.
Best regards.

The proposed dwellings are desperatly required in the village due to the shortage of affordable housing stock buyers (such as myself), are facing at present.

The villige lacks homes up to the £300K mark which prices local people out of the area, who have grown up in the village and looking for a 1st time property.

The council need to ensure the development contains a mixture of affordable housing (not shared owenerhip), allongside the higher priced homes to help combat this issue.

Landscape and heritage concerns should consider not just the primary linear development - The Street and housing along it - but the pathways, walks, views and enjoyment for residents and visitors of vistas from the valley and paths up to the proposed sites.
Concrete information about requirements vis Highways and vehicle access and safety still need to be addressed (as raised in Reg 18 and watered down for Reg 19 without resolution)
The plan should address NPPF Annex 2 requirements on affordable housing - directly and clearly. Will there be affordable housing, what is the ratio to housing?
The sites encourage car centric and reliance living; planning in a climate crisis MUST be designed to ensure transition to carbon neutral and lowering carbon footprints - this plan shows problems in walking and footpath connectivity that cannot be resolved. It is vital residents can walk to key services and can cycle safely. Extra cars on these roads will discourage cycling for those who can and would if felt safe.
There is no information about low impact energy provision and eco building credentials - again a must as per NPPF undertaking on Climate mitigation
Developers should set out plans for green infrastructure and landscaping mitigation at this early stage - planting of trees, cycle and walking friendly infrastructure, drought tolerant planting, local community food growing allocations for localism plans and food security
Developers should be obliged to set out specifically how they will engage with third parties for access, pathways, disabled access etc.
The NPPF guidance suggests 1 hectare maximum for a site for small scale rural housing development. The sites should not exceed this guide amount.

Rural landscapes are undermined. Site assessment focuses unduly on landscape from ‘The Street’ but not from other vantage points in the village, fields and valley.
Highways compliance: unworkable and recommended Type 6 for compliance not achievable; also relies on third party land to provide new, safe pathways.
Inclusivity: disabled mobility access unachievable.
Climate change: depart from stated NPPF re working to transitioning to a low carbon future.
Utilities - at capacity in terms of drainage; and questions re sewerage. health hazards, ncreased flooding
Affordability, housing need – no evidence re affordable, social housing.
Sites size exceeds 1 ha (NPPF)

Development not to proceed

1) The proposed development of the site would intrude into open landscape to the south of The Street and is not in keeping with the historical linear pattern.

2) Access to the proposed site is opposite the local shop and the only access to the Doctors Surgery, a congested area with cars parked on or around the entrance to the shop car.
It also sits just passed a sharp bend when entering the village from the direction of Norwich.

The increase in traffic needing access to the site coupled with existing congestion in the area exasperates the existing safety issues,

A different location not on prime arable farm land in keeping with linear village.

The proposed allocation is above and beyond the identified level of sustainable growth for Rockland St Mary and pose a clear risk to the identified character of the area and the and quality of life of those current inhabit the village
Extra pressure on the roads are likely to compromise highway safety.
Access proposed is insufficient & not wide enough for two way traffic.
This would add extra parking outside the shop & down the street which would be extremely hazardous.
The allocation constitutes a deviation from the existing linear pattern of development & would have a negative impact on the existing footpaths & rural landscape.

Reduction in dwellings.
Unfortunately I cannot see a solution for the access to this site.

Access to the development is unsafe for a development of this size. It is off a bend, not enough view splay and often has cars parked opposite for Post Office and Pearl's Pool. The road is narrow at this point. A development of 25 homes with a minimum of 50 vehicles which is likely to be more as young people not leaving home. There are no footpaths on site side or footpaths to connect to it. This size development will not integrate into the landscape and the linear style of the village. What infrastructure is there for the sewage/water drainage of the site.

Plan needs to be rejected . Wrong location for the village

Concerns on parking around shop & the Street . The situation of cars parking on the street is already hazardous & proposed access to this site would increase the risk of accidents.
Access to the site is insufficient being not wide enough for 2 way traffic.
Footpaths are not wide enough & in some cases there are no footpaths.
Proposed allocation of 25 homes is way above the identified level of sustainable growth for Rockland St Mary , is a clear risk of the identified character of the area & quality of life of those who currently inhabit the village.
The proposed area will destroy the linear pattern of the village and will be built on good arable farm land .

Not to proceed at all due to fears of turning our landscape to townscape!

Access is unsafe, it does not have the vision splay and is on the most congested part of the street due to Post Office, Drs Surgery and Bus Stop. No footpaths on site side of the road and no access to create any. It is not in keeping with the linear shape of the village and protrudes out behind existing properties. It will create a precedent for backland areas and open up access to continue to build behind properties creating townscape concerns. Highway infrastructure not there for extra 50 plus vehicles. Sewage and surface water concerns

Not to build there at all as there is not a suitable access.

No suitable access from The Street. Too tight to turn into and out of especially at peak times when cars are Aparked opposite for the Shop/Post Office. The road on that corner is tight and is difficult to pass farm vehicles and the bus. The increase of traffic of anywhere of 25 to over 50 vehicles will impact our straight road through the village which can be difficult to negotiate with cars parked on the street. It is not in keeping with the linear character which Rockland is known for. It will create a precedent for development of backland areas.

Rockland St Mary’s current location density average is 0.0, this would increase to an average of 0.3/0.4 just purely based on this proposed site.

This site is felt unsuitable and unachievable for 25 dwellings. There will be a detrimental effect on traffic flow and road safety with the unsatisfactory proposed vehicular access. There are already safety concerns for residents and accidents have occurred.
The Street is a major thoroughfare with a regular local private bus service to Norwich city which adds to traffic flows at peak times. Traffic mitigation could be achieved by reducing number of housing units to 8-10 but highway access and new footpath requirements remain unachievable as they cross significant third party private property and road signage, telegraph poles.

Given the harm identified and the fundamental access constraints it is clear this proposed allocation is unsound and alternative sites should be considered in place of this site, which respect the existing character of development within Rockland St Mary.

This objection has been prepared by One Planning Consultant on behalf of the owners of No.10, 12, 18, 19, 20, 22, 24, 26, 38, 42 and 43 The Street and 3 School Lane in response to the Village Clusters Housing Allocations Plan – Reg 19 Pre-submission draft consultation. This representation considers the proposed site allocation reference VC ROC2, land South of The Street proposed to be allocated for up to 25 dwellings. The following Statement evidences significant harm that would arise as part of the proposed allocation and demonstrates it would have a significant effect on the local environment, highway safety, biodiversity, flood risk and amenity and therefore should be rejected as a proposed allocation.

It is noted since the previous consultation, as part of the Regulation 18 consultation, the site layout and proposed access has been amended. This is the first opportunity the neighbours have been given a chance to review this and comment. The developer has only undertaken informal discussions with two neighbouring properties – no formal consultation has been undertaken with the neighbouring properties.

Impact upon Character and Townscape

Section 2 of the NPPF defines sustainable development and outlines how the goal of achieving sustainable development entails balancing the mutually supportive objectives – the economic, social and environmental objectives. Whilst there is a clear commitment to deliver housing to meet identified needs, this needs to be balanced against all the objectives and the need to preserve the natural and built environment. Within the emerging Greater Norwich Local Plan (GNLP) Rockland St Mary is proposed as a village cluster with Hellington and Holverston. The village clusters are proposed to provide approximately 9% of the identified demand for new housing for Greater Norwich in the plan period, which equates to 4,220 homes.

Section 12 of the NPPF ‘Achieving well-designed places’ outlines that ‘the creation of high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve’. Paragraph 130 of the NPPF goes on to outline that planning policies and decisions should ensure that developments, amongst other things, will function well and add to the overall quality of the area, and are sympathetic to local character, including the surrounding built environment and landscape setting.

In terms of landscape character, there are landscape assessments for South Norfolk, originally produced in 2001 and updated in 2012. The landscape assessment identifies Rockland St Mary as falling within the Tributary Farmland character area, which is characterised by linear villages such as Rockland St Mary and outlines how one of the key development considerations relevant to the area it to respect the existing characteristic pattern of linear settlements and to maintain the peaceful rural quality. It is evident from this assessment that the need to respect and maintain the existing settlement pattern is paramount to the protection of the landscape character and setting.

The Council’s Landscape Visual Appraisal for the site, published as part of the Regulation 19 consultation, concludes how the site ‘intrudes into the open landscape to the south of the village, away from the linear pattern of development’ and its development would ‘change the landscape and does not respect the existing linear development of this Broads village. It will be visible to the south of the site.’

Such comments are reiterated by the Heritage and Design Officer as within the townscape impact section of the site assessment, the site scores ‘amber’ and the Officer states ‘There are two established clusters to the east end and west end of the village – with this central area still very linear in its grain of development without backland development. Consequently there are not that many accesses in the centre of the village, and with gaps in housing it retains a rural scale. Introduction of a third central clustered area would create more of a precedent for other backland areas to be developed in the same vain [vein], fundamentally changing character of the village. I therefore have townscape concerns.’

Such concerns have also been raised for sites which were put forward for allocation to the north of The Street. In particular, reference SN2063 and SN2061REV and these sites were rejected as they would be out of character with the linear pattern of development. It is evident that the development of this proposed allocation would not respect the linear character of the settlement and although the site adjoins development to the north it would have a poor relationship with the existing form and character of settlement. No detailed justification has been provided as to why the Council have taken a different stance on this site, which clearly would result in the same nature of development which has been rejected to the north of The Street. The proposed allocation is therefore based on unsound reasoning and therefore should be rejected.

To date, developments have been permitted at either end of the village, which are not directly comparable to this site as they have not resulted in backland development and have produced dwellings which front onto the highway and respect the linear pattern of development. The proposed allocation of this site would result in backland development at the centre of the village which would entirely change the character and pattern of the village and would result in significant harm to the landscape setting.

Whilst it is acknowledged that land is required to meet the need for housing within South Norfolk, it is not appropriate that this is addressed through inappropriate development which would result in significant detrimental harm to the character and landscape of the area. The proposal does not relate well to the existing built environment and does not represent a logical extension to the settlement. To allow the proposed development in this location could be seen to set a precedent for future development of a similar nature within Rockland St Mary. This would significantly harm the rural character and appearance of the area and therefore should be rejected.

Highway issues

Paragraph 110 of the NPPF makes it clear that when assessing sites for allocation in plans, it should be ensured that, amongst other things, safe and suitable access to the site can be achieved for all users and any significant impacts from the development on the transport network or on highway safety can be mitigated to an acceptable degree.

It is noted the site access has been revised since the previous consultation as previously site access was proposed via The Surgery. Access is now proposed via an existing agricultural field access between two residential properties, no.24 and no.26, from The Street.

The Regulation 19 Consultation includes a site assessment form completed by the Council for the site and in terms of access the score is ‘amber’ and it is stated ‘solution proposed by FW Properties has the same issues for NCC as access via The Surgery site would - concern about the need for third party land, including ponds to both the east and west, to create pedestrian footpaths, particularly to connect with existing provision to the east (the land appears to be in the ownership of multiple landowners). Visibility splays would need to be appropriate to the prevailing traffic speeds.’ The site assessment concludes that ‘Ongoing discussions with the promoter of the site have confirmed that they have continued to seek a resolution to achieving a suitable access and visibility splays to this site. The Highways Authority has advised that it is likely that any solution will require the addition of third-party land. The site continues to be considered as a preferred option for development in the settlement, for up to 25 dwellings, subject to an appropriate access into the site, with adequate visibility, being achieved.’

The existing agricultural access track passes between two existing residential properties and measures approximately 5.48m in width for the majority of its length and is bounded on each side by residential properties and their associated amenity spaces. It is clear the developer does not own sufficient land to provide the required access and visibility splay to serve such a development with some of this required land being within the ownership of our clients as well as other neighbouring properties. This is also clearly insufficient to provide a safe and suitable access that would meet highway requirements to serve a major development such as this. Typically, a development of this level would need to be served by a minimum Norfolk County Council Type 6 Access Rd with an overall width of approximately 7.8metres, including margins for kerbing, public utility strips and pedestrian access. We can confirm our clients are not willing to sell and therefore the required access and visibility splays cannot be achieved and therefore the site is not deliverable or developable.

It is also clear from the site assessment that these issues would arise if the proposed access reverted back to the previously proposed one via The Surgery. Given that third party land is required, and this is yet to be secured and clearly cannot be fully secured as our clients have confirmed they are unwilling to sell their respective land, it is clear the site cannot achieve a satisfactory and safe highway access to serve the development. Taking into account the fundamental access constraints it is clear this proposed allocation is unsound and therefore should no longer be proposed for allocation.

Such concerns have also been raised for sites which were put forward for allocation to the north of The Street, in particular reference SN2063 and SN2061REV and whether a suitable access could be formed. These both proposed accesses between existing residential properties and the Council stated it was not known if accesses could be provided to adoptable standards and an acceptable width. It has clearly been evidenced that the proposed allocation raises the same issues, and no detailed justification has been provided as to why the Council have taken a different stance on this site, which clearly cannot achieve a suitable and safe access and therefore cannot be delivered, and it’s allocation is unsound.

Also, it is noted the promoter has not provided any evidence of viability. The purchase of additional land to facilitate the required access and visibility splay would impact on the viability of such a scheme and whether critical elements of such a scheme, such as affordable housing requirements are deliverable as part of the development. The fact no viability assessment has been undertaken to date based on the concerns outlined in this Statement is also considered to justify the rejection of this proposed allocation.

Amenity Impact

Section 12 of the NPPF relates to achieving well-designed places and paragraph 130 is clear that planning policies should ensure that developments, amongst other matters, create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users. The proposed allocation, both during construction and once developed, would result in significant disturbance to amenity in terms of associated noise and disturbance and would have a significant impact upon neighbouring residential properties, including our client’s properties.

The existing agricultural access track passes between two existing residential properties and measures approximately 5.48m in width for the majority of its length. The proposed access would pass by, and substantially along, the side and rear of the dwellings and their private amenity spaces, and there would undoubtedly be significant noise and disturbance arising from the movement of vehicles, which would have an impact upon the residential amenities of the occupiers and the enjoyment they currently benefit from. Further to this, it is unclear how the access would be constructed and what materials would be utilised for its entire length. Depending on its type of construction, this could lead to further noise generation by moving vehicles, which would further impact upon amenity.

It is clear the access is not wide enough to allow two vehicles to pass along its entire length and it is apparent the developer does not own sufficient land to widen the proposed access to facilitate this. If passing places are proposed (it is still unclear how these would be achieved given the limited width) these would result in further noise and disturbance to neighbouring properties, when vehicles have to wait when encountering vehicles from either direction. This would result in additional engine noise which would have a significant effect on the living conditions of the adjoining properties. Such a relationship and access arrangements are clearly unsatisfactory for a major development, such as this, and it is clear from the above that the developer is relying on third party land, outside of their control, to attempt to demonstrate that a satisfactory access can be achieved. In reality, it is not deliverable and therefore the site is not developable and should be rejected.

Once again, such concerns were raised by the Council for the sites which were put forward for allocation to the north of The Street, in particular reference SN2063 and SN2061REV. Concerns were raised as the proposed accesses would pass within close proximity to existing dwellings resulting in residential amenity issues. Again, no detailed justification has been provided by the Council as to why the Council have taken a different view on this site when it is evident the same issues would arise. The proposed allocation would result in a severely substandard access which would have a significant effect on the living conditions of the adjoining properties. It is therefore considered on these reasons alone the site should be rejected and its developability is clearly unsound.

A further point to note is the impact of the construction works on neighbouring amenity. The required construction works to develop a scheme of upto 25 dwellings, which would utilise the agricultural track, would have a significant and devastating impact upon the nearby residential properties in terms of noise and disturbance. It would also have the potential to result in damage to the properties given they are immediately adjacent to the access which is narrow in width and it is unclear whether it is adequate for construction traffic. It is considered this should have been fully explored prior to any proposed allocation.

Biodiversity

Paragraph 179 of the NPPF is clear that to protect and enhance biodiversity, plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including wildlife corridors and stepping stones that connect them.

The site forms part of a larger agricultural field and the site and its boundaries provide valuable habitats for a number of species, including Protected Species. Our clients have confirmed that the following species have been seen using the habitats on the site: bats, hedgehogs, badgers, barn owl, short eared owl, water vole, Chinese water deer, muntjac, partridge, pheasants, hare, finches (gold, green, yellow) and tits, green woodpecker, great spotted woodpecker, common snipe, merlin and foxes.

Within the site assessment the site scores ‘amber’ and the comments highlight how the site is close to the Broads and within 3km buffer distance to SAC, SPA, SSSI Ramsar site and National Nature Reserve. Norfolk County Ecology go on to state the site is adjacent to a priority habitat.

The NPPF is clear that improving biodiversity is one of the main elements of the environmental objective of achieving sustainable development. As no ecological information has been published to date regarding the development of the site, it remains unclear whether the proposal would have an unacceptable impact upon important ecological features within the site and whether the proposal would impact upon existing green networks for wildlife within the immediate vicinity, which are used by a number of species, including Protected Species. It is therefore unclear whether the site is developable and deliverable without resulting in a significant impact upon biodiversity through the fragmentation of networks and corridors currently used by species and Protected Species and therefore its proposed allocation is unsound.

Flood Risk

Whilst it is noted the Environment Agency (EA) map does not show any surface water flood risk on the site it should be noted that the EA mapping data for surface water flooding was produced back in 2013 and is highly inaccurate and cannot be used at individual site level. The EA have confirmed this to be the case and how the mapping estimates flood risk for areas of land and should not be used on a site-by-site basis. On this basis, as per EA advice, the Council cannot rely on this mapping data in its assessment of the potential flood risk of the site and it can in no way be inferred with any degree of accuracy or legitimacy, that the site is not subject to surface water flooding. Our clients are aware of surface water flooding on the site, in particular along the farm track which is proposed to serve the site and the northwest corner of the site, behind no.20 The Street. These areas have consistent surface water flood risk problems, which have currently not been fully considered and the development of the site would exacerbate this. Surface water is evident on the site currently after a period of relative drought, which clearly evidences the issue. It is therefore considered on the basis of the information currently available, that it remains that the proposed development of the site would have an unacceptable impact upon flood risk and would increase flood risk elsewhere and therefore does not accord with the NPPF.

Other Matters

Within the site assessment form published as part of the Regulation 19 consultation, in regard to utilities capacity, it is rated ‘amber’ and it is stated ‘wastewater capacity to be confirmed AW advise sewers crossing the site’. Our clients confirm there are sewers crossing the site which are likely to have protective easement zones either side. This may impact on the developability of the site and the numbers of dwellings that could be achievable on the site. It is therefore considered that based on the information submitted to date that it has not been demonstrated that the number of units is deliverable or achievable or that there is sufficient capacity to accommodate the development.

Within the site assessment form, it is noted under the comments for overall landscape assessment it is stated ‘agricultural soil classification unclear’. It is considered imperative that the classification of the land is confirmed prior to any formal recommendation of allocation. The site clearly forms part of a larger agricultural field, which is currently utilised for farming and has historically been used as such. The proposal would result in a portion of this existing field being lost. It’s loss as agricultural land, especially when considering the constraints outlined in this objection, is not justifiable, especially when the need for agricultural production has intensified. The fact that its classification has not been confirmed, when it is clearly high quality given it is in agricultural production, is unjustifiable and should be explored further and its classification provided and subject to a further assessment.

Summary

It is considered the harm identified within this representation demonstrates that the proposed allocation would have a significant effect on the local environment, highway safety, biodiversity, flood risk and amenity and therefore should be rejected as a proposed allocation. We trust you will consider the above matters and agree the proposed allocation is not deliverable nor developable for the reasons highlighted and therefore is clearly unsound and should be rejected as a proposed allocation.

Philippa & Chris Tusting – No. 10 The Street
John & Caroline Ringwood – No. 12 The Street
Malcolm & Jackie Robinson – No. 18 The Street
Ashley & Lisa Reynolds – The Well House, No. 19 The Street
Liz Pither – No. 20 The Street
Adrian & Anne Rayner – No. 22 The Street
Ross & Muriel Wylie – No. 24 The Street
Martin, Heather & Sophie Allinson – No. 26 The Street
Charlotte Hilton & Steven Lewis – No. 38 The Street
Caroline, James & Jem Pritchard – No. 42 The Street
Jason & Nicola Davey – No. 43 The Street
Stuart Ellison & Sheila Axworthy – No. 3 School Lane

Given the harm identified and the fundamental access constraints it is clear this proposed allocation is unsound and alternative sites should be considered in place of this site, which respect the existing character of development within Rockland St Mary.

It is considered the harm identified within this representation demonstrates that the proposed allocation would have a significant effect on the local environment, highway safety, biodiversity, flood risk and amenity and therefore should be rejected as a proposed allocation. With this evidence, I hope you can see that the proposed allocation is not deliverable nor developable for the reasons highlighted and therefore is clearly unsound and should be rejected as a proposed allocation.

Reject this Proposal

1. Site does not maintain linear pattern, compromising character and rural quality of village.
2. Proposed access is unsafe, unsuitable and unviable.
3. Increase in vehicles will increase parking congestion between the shop and School Lane. Already congested, this will increase the dangers and compromise both the village character the residents amenities.
4. Impact the habitats of the field, boundaries, Hellington Common and beck.
5. Requires loss of Grade 2 agricultural land.
6. Sewers and water supply already stretched.
7. Negative impact on residents of The Street and School Lane who have always enjoyed an open landscape to the south.

Unable to see where a suitable access can be achieved on The Street.

Access unsafe and unsuitable for that part of The Street as it is on a bend with current congestion from the Shop/Post Office, Drs Surgery and Bus Stop. There are often cars parked on that part of the street. There are no current footpaths or way to connect to any. It is out of character for the linear village and is not the same as School Lane or St Margarets Way as these are not behind properties on the front of The Street. Road infrastructure could not cope with 50 plus vehicles making it unsafe for the popular cycle routes.

The middle of the village where all the amenities are located is no place for a development like this in a linear village which is why there are no suitable access ways for it.

Access is unsafe with no other suitable options available.

The site would set a precedent and create access for backland area to be used further along The Street which would change the landscape and character of the linear village. This would cause a townscape concern. There has already been additional housing recently built at Eel Catcher Close and Bee Orchid Way. Both of these have seen further development or potential for development.

Extra vehicles on an already busy road is a worry for children and elderly in the village. Current footpaths are insufficient and more parking on the street unsafe.

decline the proposal

The site is not in keeping with the linear nature of the village.
The access is unsafe and will add to the congestion around the shop, surgery etc and relies on 3rd party land for splay!
The number of vehicles linked to and servicing the new development will result in a huge increase in congestion, pollution and danger to residents - contrary to SNDC policy of reducing car use this will surely fuel it! The road is already at a dangerous capacity.
The land is good for agriculture with a great level of diversity, it should remain so

SN5039 was identified as a reasonable alternative for allocation, subject to achieving satisfactory access with sufficient visibility.

These comments have been noted and the original proposal has been amended to address the issues highlighted regarding scale, access and visibility, so it can be revaluated and allocated as an alternative preferred site to VC ROC2 (SN2064REV).

The revised plans for SN5039 provide a more accessible and appropriately positioned alternative to VC ROC2.
• SN5039 neatly forms a natural, complementary extension, to the east and south respectively, of existing development on School Lane and The Street. This means the site has less impact on open countryside than VC ROC2, which would also introduce an additional third clustered area to the village, spoiling its historical linear characteristic.
• SN5039 will have road frontage of 46 metres to provide excellent access and visibility.
• SN5039 will provide direct pedestrian access from the site onto School Lane.

I wish to protest against planning permission to build on this PRIME farmland in Rockland St Mary, It produces TWO crops per year. There are other concerns about wildlife as well. Running alongside this field there is an owl sanctuary, new houses built in its vicinity won’t help owls or the wildlife and birds, which are already at risk from other causes. We are not seeing any hedgehogs, butterflies even cabbage whites, honey bees and very few bumble bees. These all used to be plentiful.

Teresa Coffey Secretary for state and environment, food and rural affairs. Said thiS week that we should eat food grown and produced in Britain. How do you think this can do this if you insist on building on prime land, or any farmland for that matter. There are lots of brown fill sites.

It looks to me that the houses are of out the price range for local people and are geared towards Londoners who wish to move into the country or people with money looking for second homes or Holiday let’s.

This morning Facebook posters are asking the government to use brown fill sites to be used for housing.

I hope you will keep my concerns in mind when making your decision.

In its present form, and particularly in view access problems VCR0C2 with the requirements to deliver a Type6 Road, the application seems tentative at best. However, this application should be refused, in doing so the authority would be taking account of the various concerns and issues raised by residents and also bring the situation more in line with NPPF policy.

In considering my submission in 2021 concerning the South Norfolk Village Cluster Housing Allocation Plan (SNVCHAP) it seemed to me that the housing allocation to the Rockland St Mary, Hellington & Holverston Village Cluster (RSM) was disproportionate. To help consider this issue by referring to the “Extent of Village Cluster Areas” map I ranked the 48 village clusters by area shown on the map, largest first and then in order to the smallest. I also allocated each village cluster a number indicating how much larger/smaller it is in relation to RSM (for example a village cluster one and a half times the size of RSM would be allocated number 1.5). I then divided the village clusters into four groups of 12. The first group (Q1) having the 12 largest, the second group (Q2) having the 12 next largest, the third group (Q3) having the 12 next largest, and the fourth group (Q4) having the 12 smallest village clusters.
From considering the figures from the above analysis I found
1) RSM fits into Q4 group of smallest village clusters, towards the top this group.
2) I calculated that the average (mean) village cluster size is a little over 1.6 times the size of RSM. & would fit about 4tth or 5th in Q2.
3) I calculated that if housing allocation was made proportionately in relation to village cluster size (area) RSM would expect to receive a total of 15 or 16 houses.
I must stress that all of the above is based on figures that are estimates of the village cluster sizes based looking at a quite small map. For example, there are five or six clusters which are about the same size as RSM, this made RSM difficult to place. So, what is being said above must only be regarded as giving a “good idea” of the situation.
In the original plan there were 48 village clusters to be allocated 1200 houses this gives an average (mean) of 25 houses per village cluster. The National Planning Policy Framework says:
Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any need that cannot be met within the neighbouring areas) can be met over the plan period. Within the overall requirement, policy should also set out housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations…… NPPF para 66 (my bolding)
As the RSM is one of the smallest villages with double the average housing allocation it cannot be seen as reflecting the pattern and scale of the overall plan and so does not comply with the policy of the National Planning Policy Framework in this case.
In my 2021 submission (related to SN2064REV/VCROC2) I give a fuller account and explanation of the above analysis but in this case relating it to failing scale issues in SNVC Objective 3. In these 2021 submission I also express sympathy with the Senior Heritage and Design Officer’s concerns about townscape; In relation to biodiversity I express concern that it is in this area of the village hedgerows still exist allowing the passage of deer across the street; Consider adverse concern and figures on location and density, in relation to “Protecting the character of the village” relating to SNVC Objective 3; & Express concern about potential modification of the settlement limits.

In its present form, and particularly in view access problems VCR0C2 with the requirements to deliver a Type6 Road, the application seems tentative at best. However, this application should be refused, in doing so the authority would be taking account of the various concerns and issues raised by residents and also bring the situation more in line with NPPF policy.