A substantial drainage system must be included in SPO3 to prevent excess water running off the site onto the road.
We are on the lowest part of the road, opposite the site, and our property needs to be protected.
The attenuation pond needs to be moved to the corner of the site where there are no properties opposite.
The pipe at the corner end of the ditch needs to be unblocked. This pipe is currently on private land.

The policy for this development was originally SP02, which states that a substantial urban drainage system must be included on the site, to stop excess water draining off the site onto the road. This has been omitted from the new SP03. This causes me a great deal of concern, as my property is directly opposite this site. To make matters worse, the attenuation pond is to be placed directly opposite our driveway, on the lowest point of the road, overflowing into a ditch that is blocked, so the water has nowhere to go.

Restore the omitted safeguarding SPO2 policy wording on what was considered sound and legal for School Lane under the existing Local Plan. SPO3 will not be sound without this wording carried over. The existing legal policy wording for both the footpath and sustainable drainage system provides the vital safety protections to residents and the public especially as these safety issues remain current and cannot be omitted because they are now inconvenient. SNC has a duty of care.

Strongly Object and very concerned that the new policy wording for SPO3 has omitted two essential safeguarding conditions that are currently an important part of the policy wording in the existing Local Plan. These important safety policy requirements are to provide a pedestrian refuge (footpath) and a sustainable drainage scheme. There has been no material change to School Lane. The problems are still current; the flooding of the highway is worse as the surface water drainage network to the river is continuously blocked on third party land and should at the very least have received a Level 2 SFRA Outputs assessment in the circumstances. On what grounds have these two safeguarding necessities been removed? Over the years, throughout the many public consultations and planning applications with variations, at all stages the public and residents have engaged and submitted their serious concerns on these two issues. If the footpath cannot be delivered because the road is to narrow, then it is questionable that the SPO2 site was ever sound and fit for purpose in the first place. An off-site pedestrian area at the site does not provide safety for on-road walking to the school.

The planning allows for an attenuation pond which may help to mitigate the increased surface water run off but unless the rate of flow from the under road culvert downstream to the river is improved the current flooding situation is going to worsen. Any future development would exacerbate this further so would need to look at additional downstream capacity, as well as protecting the current drainage ditches and keeping access to them for maintenance (I yearly have a tractor clear vegetation in the ditch and it was needed to be dug deeper after past flooding).

The current situation is that the water leaving the ditches along School Lane and the ditch running along the other edge of the field for development, merge to go under the road via a culvert and drain in the ditches in the far field and down to the river. At times of significant rainfall especially in winter the drainage from under the road onwards already cannot cope and the road floods significantly. Developing the field will increase the surface water run off and with no provision to improve the downstream drainage the flooding is will worsen.

The current policy wording for both the footpath and the drainage scheme were there for a reason and must continue to be included in SPO3 for public safety.

With the adoption of SPO3, all new planning applications would comply to the new policy wording. I am concerned that the provision of improved pedestrian access (footpath) from the site to the school has been removed despite the increased safety risks to pedestrians walking on the highway amongst moving vehicles.
The SPO3 wording for a sustainable drainage scheme has also been removed. The current network of surface water ditches and drains have little flow, retain water and flood onto the highway and surrounding land. It is essential that the wording is not removed in recognition of the flood hazard.

Restore SPO2 for School Lane under the agreed existing local plan. The plan needs to be fit for purpose.

Inclusive of the summary of comments.

Martyn Lemon. Planning Lead on behalf of Spooner Row Community Council the following is asked for your consideration

SPO3 has omitted two conditions that are currently an important part of the policy wording in the existing Local Plan. These important safety policy requirements are to provide a pedestrian refuge (footpath) and a sustainable drainage scheme. There is a real question mark as to whether the site was ever suitable for development. There has been no movement on site to suggest this maybe the case. The protection of pedestrians particularly children walking to school is a concern. There is an omission of flooding issues raised in SP02. Despite the fact the road often floods after a downpour.

The Highway Authority would request that site reference SPO 3 is removed from the draft plan

Please see attached for full submission.

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.