REP1 Policy

We support the inclusion of a requirement in the policy to ensure any application evaluates the potential indirect impacts of development on the adjacent Broomhill Meadows CWS.

Please see the section addressing the Sites Plan in the attached representations submitted on behalf of Michael and Jackie Buxton and Pigeon Capital Management 2 Ltd in support of the allocation of Land at Dereham Road, Reepham.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Dereham Road, Reepham (Site GNLP0353R). Please find attached response forms, the representations and a Delivery Statement.

The Local Plan should be modified by making REP1 null and void and siting housing on brownfield sites closer to public transport and employment, such as Norwich Airport Industrial Estate at Hurricane Way in Hellesdon, where dozens of industrial units are unused and falling into disrepair.

There has been inadequate consultation with residents due to the pandemic. There is currently an application for 141 houses (PA 20200847) and an offsite sports hall on unallocated land outside the development area (PA20201183). Had the public known at the time site allocations were originally considered that agreeing to REP1 could lead to planning applications of this scale, there would have been far more robust objections at the time. The site is stated by the current appliants to be unviable for the number of houses, the on-site sports hall and the amount of social housing stipulated in REP1.
The brought forward allocation of REP1 is not justified as the original allocation was not based on proportionate evidence regarding the lack of infrastructure (inadequate sewerage capacity for that number of new homes, minimal public transport and employment opportunities, and poor roads out of the town). The allocation includes one road into the estate, which exits on a narrow, congested road beside the High School. This road already becomes grid-locked every morning and afternoon. All routes from this road are unable to support more traffic. Improvements are required to Broomhill Lane but it is not confirmed whether the land needed to provide the necessary junction splay is available for adoption - this will need to be agreed by the Secretary of State. Roughly a third of the REP1 housing site is currently used as a school playing field which has been opposed by Sport England and also requires approval by the Secretary of State.
The location of REP1 is not sustainable due to the infrastructure concerns above, its proximity to an important watermeadow (50m away) and two nearby SSSIs. It is a green field site outside the town development boundary and encroaches into open countryside.

Minor alterations to the scope of the allocation and the policy wording are required to ensure its soundness.

See Attachment for details including revised policy wording.

Introduction
On behalf of Lovell Partnerships Limited (Lovell), Reepham High School and the landowner (Robert & Rita
Buxton), we strongly support carrying forward the existing allocation of REP1, Land off Broomhill Lane,
Reepham, subject to various amendments. The site is, subject to the changes sought, entirely deliverable,
and capable of making a significant contribution towards satisfying the Councils’ housing needs during the
period to 2038.
Whilst in principle Policy REP 1 is considered to be sound, in accordance with the tests set out in paragraph
35 of the NPPF, the detailed wording is unsound as elements are not effective or justified. More specifically,
the red line boundary of the allocation, and the quantum of development envisaged, does not represent
the optimum development solution for the site, which is reflected in the live planning applications that have
been submitted on the site and are currently awaiting determination – see below for further detail.
Minor alterations to Policy REP1 are therefore sought, to ensure its soundness.

See attachment for full representation

Inclusion of this site in the emerging GNLP is considered unsound, therefore no modifications are suggested.
All Local Planning Authorities are currently demonstrating at least a 5 year supply of land for housing. This site should no be included in the GNLP.

The are a number of adverse impacts on Reepham that would result from the development of REP1

The 2 green field sites would be lost, outside the town settlement boundary.
The form of residential development would be incongruous with the character of the surrounding countryside
The single access road is not compatible with the existing congested movement of traffic in Reepham.
The sloping form of the site, away from existing services will require a pumped
drainage installation, and surface water is at risk of draining into the nearby SSSI.
Constraints around road access will require the loss of carbon-reducing hedgerows, trees, biodiversity and wildlife.
Local infrastructure, including schools, GP surgery, drainage treament are insufficient to cope with a 100 dwelling development

The allocated site REP1 is carried forward in the emerging GNLP. the undetermined PA 20200847 was contrary to the 2015 development plan. The contraventions to policy were that community facilities were not provided on the site, and also that the provision of the 141 dwellings were outside the Reepham Settlement Boundary. The GNLP still proposes 100 dwellings outside the existing boundary, and as such is unsound.
Section 38(6) of the PCPA (2004) states that applications must be determined in accordance with the Development Plan. Development, outside of a settlement limit, will be permitted, provided it does not result in any adverse impacts. Development on REP1 has obvious adverse impacts on the character of Reepham, and on its surrounding countryside. These negative impacts are the loss of two greenfield sites which will impact on biodiversity, and wildlife, including nearby protected badger setts.The creation of a suburban estate near to the Broomhill Meadows CWS, and in close proximity to a designated SSSI at Whitwell Common will have an incongruous visual impact on this rural area. The site slopes down to this area of special conservation and would require the installation of a pumped foul drainage system, up to the mains drain in Broomhill Lane. This would be a 24/7 pumped non-gravity system which will only add to the creation of carbon emissions.
Development of this site will be in conflict with the NPPF definition of sustainability. The GNLP does not place enough emphasis on climate change and fails to acknowledge how public livestyles have changed since covid -19. This greenfield site is much used by walkers and cyclists. Access would require a new suburban road, separate new footpaths and a cycle track. In the process, trees and hedges would be removed. Landscape mitigation by using saplings is of little help, but established trees and hedgerows play in important role in reducing harmful carbon emissions.

The 2016 REP2 site was allocated for a mixed development of residential and employment.
It was suggested that it would accommodate approximately 20 homes, B1 and B2 employment uses.

Paragraph 5.57 in the emerging GNLP has changed this figure to 35 homes. Planning Permission Ref no.20180963 in fact shows 16 assisted flats and 15 assisted bungalows, together with a 60 bed carehome. The occupancy figure, incuding the carehome would be 122 persons, which would put added pressure on the local infrastructure, particularly on the GP surgery.

Together with the recommended 100 dwellings on REP1 in the GNLP, the combined total of homes in REP1 and REP2 is 131. This figure excludes accomodation in the proposed care home on REP2.

The figure of 155 dwellings for Reepham between 2018 and 2038 is increased to 166, made up of 100 dwellings on REP1, 31 dwellings on REP2, and 35 dwellings, taking account of existing planning permissions.

Clearly , the proposed 141 dwellings on REP1 are unacceptable under PA 20200847 and the 100 dwellings on the emerging GNLP REP1 site must also be considered unsound.

Site REP2 is being developed at the moment, but not in accordance with Policy REP2 which still states approximately 20 homes. The GNLP for REP2 is unsound as paragraph 5.57 is at variance with the actual Policy REP2
The existing town infrastructure would be unable to cope, if development on REP1 is also taken into account.