Object

Representation ID: 3903

Received: 19/09/2024

Respondent: Evolution Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Please see attached Report E1057.C1.Rep02 - This submission Objects to the Allocation of Site VCBROM1, located on the north eastern periphery of Broome, on the basis that it is not justified (in view of a more sustainable alternative) and, on the basis that there is a more sustainable alternative, the allocation is not consistent with national planning policy which sets a presumption in favour of sustainable development. We also have concerns that certain elements of the policy will not be effective. As such, we consider that the policy and the allocation will not meet the ‘test of soundness’.

Support

Representation ID: 3941

Received: 05/09/2024

Respondent: NHS Norfolk and Waveney Integrated Care System

There are 4 villages whereby the most local GP practice that covers those villages within its catchment area is located across the local authority border in East Suffolk. Two GP practices will be affected by any population increases. These practices are either currently working through a planning application for an extension funded by CIL or are in early discussions about a potential premises scheme via a potential application for CIL funding.

The ambulance service, EEAST, are in a unique position that intersects health, transport and community safety and does not have capacity to accommodate the additional growth resulting from the proposed development combined with other developments in the vicinity. This development is likely to increase demand upon existing constrained ambulance services and nationally set blue light response times. The capital required through developer contribution would form a proportion of the required funding for the provision of capacity to absorb the patient growth and demand generated by this development. Any funding would be used towards the capital cost of providing new additional ambulances and/or new additional medical equipment, which for an ambulance service is their physical infrastructure, and/or new additional parking space(s) for ambulances at existing ambulance stations.

Object

Representation ID: 3959

Received: 26/09/2024

Respondent: Norfolk Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? No

This allocation is in close proximity to Broome Heath County Wildlife Site (CWS)/Broome Heath Pit Site of Special Scientific Interest (SSSI and as such could have an impact on these site. Impacts on these sites will need to be adequately mitigated. We recommend that text similar to that inserted at paragraph 3.19 are included in this policy.

Object

Representation ID: 3976

Received: 19/09/2024

Respondent: Ditchingham Farms Partnership

Agent: Evolution Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The allocation is an extension to the eastern most houses, and extends well beyond any continuous line of homes into the countryside. The development could be characterised as ‘ribbon development’ which has traditionally been avoided by the planning system so that the character of the countryside is protected.

The character of the countryside to the east of Broome is of an undeveloped rural area with scattered buildings. Extending a line of homes into this area would harm that rural character.

The proposed policy acknowledges the difficulty of developing in this area and requires the development to be ‘integrated’ into the countryside. However the site already has limited boundary features, any proposed development will have a significant visual impact, such that ‘integration into the wider countryside’ is not possible. It is clear that development in this location will have a significant visual impact and that the policy is written to be ineffective since it will require a landscape outcome which cannot be achieved in this location.

Public views are available toward the proposed allocation site from PROW Broome FP5, and since the landscape is flat, with no existing vegetation, it is unclear how the LPA propose any application could effectively mitigate the impact of development on this landscape.

Site VCBROM1 would also not meet the requirements of NPPF Paragraph 180(b). By proposing a linear form of ribbon development into open countryside with little scope for meaningful landscaping, the development will appear out of character with the local area.

Object

Representation ID: 3977

Received: 19/09/2024

Respondent: Ditchingham Farms Partnership

Agent: Evolution Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Proposed allocation site is a long distance from facilities compared to alternative development opportunities, so is not sustainable. This is inconsistent with the NPPF paragraphs 11 and 74.

Broome has a pub but no other facilities. Ditchingham to the west, has a convenience store, primary school, and bus services. A good range of facilities are available to the south in Bungay. The proposed allocation is as far as it could be from the facilities in Ditchingham and Bungay. This will not encourage sustainable forms of travel such as walking, cycling and public transport and will not ensure that the village extension complies with Paragraph 74 of the NPPF.

Paragraph 104 of the NPPF states ‘transport issues should be considered from the earliest stages of plan-making and development proposals, so that opportunities to promote walking, cycling and public transport use are identified and pursued’. If taking opportunities for walking, cycling, and public transport was considered, then sites to the west of Broome, which are closer to facilities, would be favoured over the proposed allocation site.

Object

Representation ID: 3978

Received: 19/09/2024

Respondent: Ditchingham Farms Partnership

Agent: Evolution Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site SN0346 is approximately 1.8 hectares in size, meaning that it offers greater opportunities for landscaping, biodiversity net gain and (if required) a larger number of houses. The site comprises five areas of land, being three areas of arable land at the eastern and western ends, and centrally in the site. Between these are two areas of recently planted woodland which would be retained to provide advanced landscaping within the development.

To the south of the site are homes which stretch along the Old Yarmouth Road. There is a footway along the south side of Old Yarmouth Road which runs the length of the site and extends east and west to the rest of the village. To the east of the site is a small open yard with houses further east. To the west of the site is the access to Broome Pits which are fishing lakes. To the east of this is a small area of trees with new houses beyond. To the north of the site is Broome Pits fishing lakes.

The site is well related to the built-up area of the village. There is continuous housing to the south, east, and west. New homes in this area will be seen in the context of a large number of existing homes and the development would therefore not harm the character of the built-up area.

The site is flat and free from constraints and has a straight road frontage along the Old Yarmouth Road. There is good visibility along the road in either direction, so appropriate vehicular and pedestrian accesses could be provided along the road frontage.

The site is sustainably located within the village. The main facilities in the area are in Ditchingham to the north and west, and in Bungay to the south. These services include a convenience store and bus services (half mile away) and a primary school (three quarters of a mile away) in Ditchingham. These are the principal services in the immediate area and are accessible by walking and cycling. A wider range of services is available in Bungay a short distance to the south.

The CrashMap website shows that there have been no accidents along the site frontage which would constrain development.

There are no Listed Buildings or Conservation Areas in the vicinity of the site. There are Two Scheduled Ancient Monuments north of the site, and any development can be preceded by an archaeological investigation if required. There are no trees subject to Tree Preservation Orders on the site.

The site is fully within the Environment Agency Flood Zone 1 so is suitable for housing.

The site is adjacent to the village’s settlement boundary, but not at an extremity. It will offer an infill development which is well related to the rest of the settlement. Development on the site would complement the linear village character of Broome.

A housing allocation was developed in a similar location to the north of Old Yarmouth Road, to the west of this site (2016/2689). Similar small scale housing developments could be developed on some, or all, of the three parcels of land making up this site, between the two areas of new woodland planting.

Although site SN0346 is part of a designated Local Nature Reserve, we do not consider that this presents any constraint to development. The three parcels of land which could be allocated are actually in arable use so this designation does not significantly contribute to local ecology. The allocation as a nature reserve actually relates to the wider part of the nature reserve, and not this peripheral area (which actually offers no ecological value). As such, this strip of land can be designed to deliver a biodiversity net gain, with new tree and hedge planting and other appropriate measures, leading to an enhancement of the nature reserve, based on the current use of the land.

Supported by NPPF paragraphs 70, 82 and 86.

Allocating site SN0346 will improve the ‘soundness’ of the overall plan by accommodating some of the likely increased housing requirements that will result from anticipated changes to planning policy that are expected to be set by the new Government.

Object

Representation ID: 3988

Received: 30/09/2024

Respondent: Historic England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We welcome the preparation of the HIA. The HIA recommends that archaeological investigation should be required prior to development commencing. The recommendations of the HIA in relation to archaeology should be included in the policy requirements.

The current reference to archaeology at criterion 6 is insufficient. We suggest that the wording is slightly amended to read:

Norfolk’s Historic Environment Service is consulted prior to application to determine the need for any archaeological assessments.

Support

Representation ID: 4109

Received: 02/10/2024

Respondent: Water Management Alliance

Major development - Byelaw 3 applies to any proposed discharge of surface water from the proposed site. All other Board Byelaws will also apply to this development.

Object

Representation ID: 4124

Received: 07/10/2024

Respondent: Rainier Developments and Strategic Land

Agent: Ceres Property

Legally compliant? No

Sound? No

Duty to co-operate? No

At paragraph 3.18 there is reference to a potential constraint to development of this proposed allocation, as Anglian Water infrastructure crosses the site. It states that “the developer is encouraged to enter into earlier engagement with AW”. We note the objection from the Broads Authority (representation ID 3900) stating that wording should be strengthened such that a developer ‘must’ enter into early engagement with Anglian Water over this matter. Regardless, whether text states ‘should’ or ‘must’ it is unclear at this juncture from the Regulation 19 Addendum whether the proposed allocation is deliverable.

Separately, we note an objection from Norfolk Wildlife Trust (representation ID 3959) in relation to the proposed allocation’s proximity to Broome Heath County Wildlife Site (CWS) and Broome Heath Pit Site of Special Scientific Interest (SSSI), and the potential impact of development on these.

Whilst Norfolk Wildlife Trust recommend additional policy text is added to require mitigation of any impact, it is again not clear if development of the site as the current draft policy envisages and incorporating the requisite mitigation is deliverable.

Support

Representation ID: 4160

Received: 07/10/2024

Respondent: W R Church

Agent: Durrants

On behalf of the landowner, Durrants can confirm that the land required to deliver VCBRM1 remains available. The site represents a sustainable location for development in Broome, following the recent completion of the properties adjacent. Importantly, it is positioned away from Broome Heath, a SSSI and County Wildlife Site, as well as benefiting from an existing footpath connection and traffic calming measures which are already in place. The allocation can be readily delivered, and the landowner remains committed to bringing the site forward for development.

Object

Representation ID: 4164

Received: 04/10/2024

Respondent: Broome Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The response of Broome Parish Council to the Yarmouth Road for 12+ houses plan is to REJECT the proposal for the following reasons as it has previously.
1. Erodes remaining countryside between Broome and Ellingham.
2. Means loss of arable farm land.
3. Is building in open landscape.
4. Sets no maximum number of houses.
5. There is other land available within the developed area of Broome.

Object

Representation ID: 4167

Received: 07/10/2024

Respondent: Rainier Developments and Strategic Land

Agent: Ceres Property

Legally compliant? No

Sound? No

Duty to co-operate? No

At paragraph 3.18 there is reference to a potential constraint to development of this proposed allocation, as Anglian Water infrastructure crosses the site. It states that “the developer is encouraged to enter into earlier engagement with AW”. We note the objection from the Broads Authority (representation ID 3900) stating that wording should be strengthened such that a developer ‘must’ enter into early engagement with Anglian Water over this matter. Regardless, whether text states ‘should’ or ‘must’ it is unclear at this juncture from the Regulation 19 Addendum whether the proposed allocation is deliverable.

Separately, we note an objection from Norfolk Wildlife Trust (representation ID 3959) in relation to the proposed allocation’s proximity to Broome Heath County Wildlife Site (CWS) and Broome Heath Pit Site of Special Scientific Interest (SSSI), and the potential impact of development on these.

Whilst Norfolk Wildlife Trust recommend additional policy text is added to require mitigation of any impact, it is again not clear if development of the site as the current draft policy envisages and incorporating the requisite mitigation is deliverable.

Support

Representation ID: 4174

Received: 07/10/2024

Respondent: Anglian Water Services

Anglian Water supports the policy requirement for early engagement for development at this site.There is limited dry weather flow permit headroom at the WRC to accommodate future growth in the catchment. As a result, this additional site, together with VC DIT1REV and any additional windfall development coming forward, may cumulatively result in insufficient headroom being available at the WRC. Ditchingham WRC does not have an identified growth scheme for AMP8 (2025-2030) in our PR24 Business Plan. Therefore, should a growth scheme be required it would not be delivered until beyond 2030, and development would need to be phased accordingly.

Object

Representation ID: 4194

Received: 13/09/2024

Respondent: Broads Authority

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Light pollution
Most of the proposed sites are on the edge of settlements. Particular care and attention need to be given to any proposals for external lighting as well as any design that has a lot of glazing. Lighting in such edge of settlement areas needs to be fully justified, serve a specific purpose, be of the right design and intensity so as to not affect dark skies, such as the intrinsic dark skies of the Broads. Reference to lighting being only needed if fully justified and well designed needs to be made in relevant policies, especially the following as they are close to, albeit separated from, the Broads. Also, design with lots of glazing need to be avoided unless there is going to be automated shades incorporated into the design.