MM157 - Wymondham GNLP5028 A/B

Thank you for consulting Historic England about the Proposed Modifications to the Greater Norwich Local Plan. We have the following comments to make on the suggested changes to the Plan:

We welcome many of the proposed Main Modifications. Our detailed comments on the proposed Main Modifications to the Plan are set out in Appendix A.

MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
The key outstanding issue relates to East Norwich. We remain particularly concerned about the location of development around the Abbey. We have suggested revised policy wording in Appendix A, reflecting our earlier advice in our hearing statement and at EiP. We have raised these concerns in relation to the emerging SPD too.

Other policies
There are a number of other more minor issues relating to wording for the following policies/sites:
MM8 Policy 2 Sustainable Communities
MM13 Policy 7.1The Norwich Urban Area including the Fringe - East Norwich
MM22 GNLP0360/3053/R10 East Norwich Strategic Regeneration Area
MM33 GNLP1061R Norwich Airport
MM43 CC8 King Street Stores
MM92 GNLP0596R Land at Norwich Road, Aylsham
MM100 Hethel2 Land south and south west of Lotus Cars, Hethel
Our concerns in relation to the above sites set out in Appendix A reflect the proposed wording set out in our SOCG with the Council.

Archaeology Criterion
In a number of policies in the Local Plan, there have been amendments made to a policy criterion relating to archaeology. The criterion previously read 'Historic Environment Record to be consulted to determine any need for archaeological surveys prior to development' and now reads, 'An archaeological assessment will be required prior to development'.

Whilst this is an improvement on the previous wording, we suggested that the policy would be even better is it read, 'Planning applications should be supported by a desk based archaeological assessment and, where necessary, the results of a field evaluation as advised by the LPAs archaeological advisors'. This is accordance with para 194 of NPPF.

Finally, we would like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

The Highway Authority has been consistent in objecting to greenfield allocation at Strayground Lane, Wymondham and objects to the modification to the policy and the site remaining in the Greater Norwich Local Plan.

Site GNLP5028A, promoted for 10 Gypsy and Traveller pitches would be accessed from the B1172 London Road via Wharton's Lane and Strayground Lane. The access route presents a number of highway safety concerns:

Both Wharton's Lane and Strayground Lane are narrow with limited opportunity to pass opposing vehicles. Some informal passing places are available where the verge has been overrun and at private accesses. The only formal passing place is immediately north of the existing Household Waste Recycling Centre. Those limited existing passing locations are not inter-visible; consequently, opposing vehicles may need to reverse along highway presenting a road safety concern.

The junction of Wharton's Lane and Strayground Lane is a right-angle bend with significantly substandard forward-visibility. The severity of the bend is likely to result in long/towing vehicles having to utilise the whole carriageway at a location where visibility if constrained.

The verges at Wharton's Lane and Strayground Lane are narrow and steep, they offer pedestrians only very limited refuge from passing vehicles. There is no prospect of creating footway. Pedestrians from/to the proposed site would need to walk within carriageway in conflict with vehicles.

At the junction of Wharton's Lane/B1172 London Road, a stop-line/sign are present. This arrangement may only be used with authorisation of the Secretary of State when it is not possible to secure/provide visibility to an acceptable standard.

It should also be noted that Wharton's Lane passes through an area designated by the Environment Agency as Flood Zone 2/3, presenting the risk that the site could be cut-off by flooding.

If the Household Waste Recycling Centre located at GNLP5028B should cease to operate, the resultant reduction in traffic movements at Strayground Lane/Wharton's Lane would be viewed by the Highway Authority as a road safety benefit.

Should a development application come forward at GNLP5028B with similar trips to the existing use, it might be challenging for the Highway Authority to resist regardless of the proposed allocation. Allocation of the greenfield site GNLP5028A introduces risk of increased traffic use of an unsuitable route. This is unacceptable, a reduction of trips at Strayground Lane/ Wharton's Lane that would accommodate GNLP5028A cannot be assumed.

The site promoter seeks to argue that visibility from Wharton's Road to B1172 London Road meets the requirements of Manual for Streets. The Highway Authority is of the view that the B1172 is a corridor of movement and as a road rather than a street, visibility must be provided in accordance with the Design Manual for Roads and Bridges (DMRB). It does not appear possible to improve visibility at the junction to accord with DMRB because of a rail bridge parapet to the east of the junction, hence presence of the stop line and sign.

The promoter suggests that the access route could be improved with provision of two passing places. They would not result in a system of intervisible passing places covering the whole route. Accordingly, the proposed passing places would not be sufficient to ameliorate the Highway Authority concerns, it also is highly doubtful they could be constructed; one would require excavation of a high bank that supports boundary hedging & trees, the other would possible need a retaining feature as the ground falls away from the rear of the proposed construction.

In summary, the Highway Authority has considered the provided evidence and remains of the view that Strayground Lane/ Wharton's Lane cannot be sufficiently improved to satisfactorily accommodate development at GNLP5028A. It is the view of the Highway Authority that it is not possible to make meaningful improvements to the junction Wharton's Lane with the B1172. Furthermore, the passing bay improvements suggested for Strayground Lane and Whartons Lane do not overcome the fundamental issues of a lack of footway or insufficient width. A development application at the site would be likely to attract a Highway Authority objection, in line with NPPF Paragraph 111 on highway safety grounds.

The Highway Authority objects to the proposed allocation reference GNLP5028A on grounds of unacceptable impact to highway safety and concludes that the proposed allocation is not sound as it will not be deliverable and therefore this policy will not be effective.

Member Comments

Councillor Graham Plant - Cabinet Member for Highways, Infrastructure and Transport
I have no comments to make regarding the Highways position on this proposal, other than to agree the objection.

Councillor Robert Savage - Wymondham Division
I am very familiar with Wharton's Lane/Strayground Lane and its junction with the B1172, London Road, Wymondham. I am in complete agreement with the objection of the Highway Authority to the proposed inclusion of site GNLP5028A/B in the GNLP plan.