Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Object

Representation ID: 3974

Received: 19/09/2024

Respondent: Ditchingham Farms Partnership

Agent: Evolution Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The supporting text to the draft policy references an LVA submitted with the proposed allocation, without suggesting how the landscape impact of the proposal could actually be mitigated.

It is not clear what is meant by a 'gateway' means or if this is appropriate in this landscape context for a settlement of this size. The development is unlikely to be more than one house deep fronting the road and we maintain that this creates difficulty in creating a built gateway feature as the scope for development is limited.

We do not consider that a landscape buffer is appropriate, because the introduction of new landscaping itself would represent a significant change in this open landscape. Practically, the scope for landscaping is also very limited. Landscaping is likely to be the responsibility of, or in the control of, individual householders making it more difficult to maintain landscaping in the long term. On smaller sites small areas of landscaping will have less impact and be more prone to removal. The most recent addition to Broome (adjacent to allocation) to see that the landscape visual impacts are likely to be significant, with limited opportunities for landscaping to provide any meaningful ‘integration’.

Consider that the landscaping clause (necessary to
make this allocation acceptable) will be ineffective and in the long term any solution will be likely to fail.

Object

Representation ID: 3975

Received: 19/09/2024

Respondent: Ditchingham Farms Partnership

Agent: Evolution Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is stated that the development would be required to deliver additional traffic calming features. These are unnecessary as traffic calming is already in place in the road next to the allocation. There are two traffic islands which force traffic onto a single carriageway road as shown in the photograph (see attachment). More traffic calming in the locality would be unnecessary and ineffective.

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.