Village Clusters Housing Allocations Plan - Alternative Sites & Focused Changes (Reg. 18)

1. According to the latest Housing Land Supply Assessment, the District has a supply of 5.87 years. This assessment demonstrates that objectively assessed needs are already exceeded. The benefit in providing additional housing including affordable housing is significantly and demonstrably outweighed by the adverse impacts identified below.
2. The proposal is a large-scale development outside the defined village boundary, resulting in an incursion in to open countryside, out of character with the form and character of the village, and to the detriment of the wider landscape setting including the setting of the Broads. The Council considers that the open, rural setting is an important characteristic of the village. In the Regulation 18 consultation on the Village Clusters Plan, the Council states: “The village is set in the Waveney Valley and adjacent to the Broads, and open views out from the village make an important contribution to its rural character.” The proposal would result in a drastic change from rural to urban views out from the village, to the detriment of its rural character, contrary to DM1.4 and DM3.8.
3. The site is in close proximity to the Broads (King’s Dam). National policy provides the highest level of protection to these areas, and notes that development within their setting needs to be sensitively designed to avoid harm to the designated area. Paragraph 176 of the NPPF states “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and AONBs, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” The spread of urban development across open countryside towards the Broads would adversely affect the environment, tranquillity, setting and visual amenity of the nationally protected landscape, contrary to Policy 18 of the Core Strategy and paragraph 176 of the NPPF. It should also be noted that the previously approved developments of Daisy Way and the Services placed great weight on promised landscaping and planting schemes to protect visual amenity of The Broads. The promised landscaping not taken place to the standards required in the planning approvals, and this would be significantly exacerbated by further development to south. 4. The level of increased use of The Street generated by the proposal could not safely be accommodated, despite the proposed road-widening in places, given its limited capacity and blind bends, which already present difficulties for users and which would inevitably be exacerbated by the proposal. It is noted that in assessing the suitability of sites for the draft Village Clusters plan, the ‘acute blind bend’ and ‘on-street parking’ at The Street were both cited as reasons for the site to the north of The Street not to score highly. Exactly the same highway constraints presented by the acute blind bend and on- street parking at The Street apply to this south site and the same highway objections should therefore arise.
5. The proposed 44 houses would each be likely to have 2 cars and 2 parking spaces per dwelling are proposed. Daily car movements would therefore be likely to increase by at least 176 movements (88 cars leaving and returning per day) and could be considerably more. It is currently a cul-de-sac and residents enjoy a peaceful environment with no through traffic. Such increased use of Daisy Way would significantly adversely affect amenities of residents by reason of the resulting traffic noise and disturbance. Future residents would be dependent on private car journeys for day-to-day needs and the proposal does not enable sustainable transport patterns. Daisy Way is a private road and the legality of its use to access the site is not established.
6. It would be partially within flood zones 2 and 3. Environment Agency flood maps indicate that access through Daisy Way is within flood zones and the additional flood information submitted still shows that part of the attenuation pond and emergency access route shown on the proposed access strategy drawing, would fall within high flood risk areas. Consent of the Internal Drainage Board is required for several drainage elements and the Board points out potential conflict between the planning process and their regulatory regime. The Board therefore strongly advises that their consent is sought prior to determination of this planning application. The proposal would be at risk of flooding and increasing flood risk elsewhere, contrary to national requirements and Core Strategy Policy 1.The proposal therefore does not represent sustainable development.
7. Within the reasoned justification statement given for this revision, it is stated that “Whilst, at the time of writing, some technical issues on application 2022/1993 remain unresolved”, this statement is factually incorrect. There are not just “some technical issues unresolved”, this planning application has not yet made it to committee and there is a groundswell of objections against in the local community. This statement appears to indicate that due legal process in the planning application is not being followed, that
there is undue and unfair bias to the planning applicant to the detriment of objecting parties to the application.
In summary:
The District already has a sufficient supply housing land at 5.87years (Housing Land Supply Assessment).
This large-scale development is outside the defined village boundary, it’s an incursion in to open countryside, out of character/form of the village and to the detriment of the wider Broads.
There’s an unacceptable impact on highway safety from the acute blind bend and on- street parking at The Street. Daisy Way is a private road and the legality of its use to access the site is not established.
Sustainable transport patterns are not met as future residents would be dependent on car journeys for day-to-day needs.
The development would be at risk of flooding and increasing flood risk elsewhere. The proposal therefore does not represent sustainable development
There is demonstrable unfair bias in favour of the planning applicant to the detriment of objecting parties.

No extra dwellings are required.