New, Revised and Small Sites

GNLP REGULATION 18 CONSULTATION - STAGE B

RESPONSE BY HEMPNALL PARISH COUNCIL


Hempnall Parish Council understands that while the focus of this consultation is in regard to sites submitted during the Regulation 18 Stage additional comments relevant to sites put forward during the Call for Sites can also be submitted. We have also been told that comments of a more general nature relating to the emerging GNLP can also be included.

Sites in Hempnall submitted during the Regulation 18 stage

1) GNLP 2046 - 1.51 hectares at Pear Tree Farm - Residential development of an unspecified number of houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."




B) It is unsuitable for development because of the unsuitability of the local road network and because the site is considered remote and if developed would result in an increased use of unsustainable transport modes. In this regard Hempnall Parish Council agrees with the following statements noted in the HELAA assessment: "Initial highway evidence suggests that the local road network is considered to be unsuitable either in terms of road or junction capacity and lack of footpath provision." And "the site is considered to be remote so development here would be likely to result in an increased use of unsustainable transport modes."

C) The site is near numerous Grade 2 listed buildings.

D) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall

E) Part of the site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

F) The site is located in an area that experiences severe drainage problems. While the constraint analysis in the HELAA assessment gives the green light in regard to Contamination the reality is very different. The flat terrain here prevents drainage away from this area and numerous properties close to this site have had problems with foul water, and sometimes sewage, polluting ditches. The problem is so severe that SNC has refused planning permission on relatively small house extensions that might exacerbate the problem.

2) GNLP 2081 - 2.39 hectares west of Field Lane - Residential Development (40 houses proposed)

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a large scale estate it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is unsuitable for development because of the unsuitability of the local road network and this is confirmed in the HELAA assessment which states: "Initial highway evidence suggests that the local road network is considered to be unsuitable either in terms of road or junction capacity and lack of footpath provision" This could only be mitigated through road widening and hedge removal and such action would severely compromise the attractive and rural nature of Field Lane.


C) The site is near numerous Grade 2 listed buildings

D) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

E) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.


Sites in Hempnall submitted during the Call for Sites

1) GNLP 1016 - 1.3 hectares - Land at Bussey's Loke - Residential development of approximately 50 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a large scale estate it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is unsuitable for development because of the unsuitability of the access road (Bussey's Loke) which is a narrow country lane. The HELAA assessment states: "there is a query over vehicular access, which is presumed to be via the narrow country lane of Bussey's Loke. Initial highway evidence has highlighted concerns that the possibility of creating suitable access to the site is severely constrained." The site therefore receives a red warning in the assessment in regard to Transport and Roads. Hempnall Parish Council agrees fully with this analysis.

C) It is unsuitable for development because of the potential impact on St Margaret's Church a Grade 1 listed building. The HELAA assessment states: "The site is also just 50 metres from the Grade I Church of St Margaret and poses the possibility of causing substantial harm to undeveloped views of this important local heritage asset." The site therefore receives a red warning in the assessment in regard to impact on the historic environment. Hempnall Parish Council agrees fully with this analysis. We would also like to point out that when a proposal for wind turbines in Hempnall was refused by the Secretary of State the impact of the turbines (at a distance of about 1 mile from church yard) on the setting of the church was a significant factor in the Minister's decision. This housing estate would be alongside the churchyard and church and the impact it would have on these heritage assets is absolutely unacceptable to the parish council.

D) South Norfolk Council's Senior Conservation Officer Stephen Beckett has discussed with Hempnall Parish Council the possibility of extending the village Conservation Area to include Bussey's Loke and the neighbouring farm buildings. If the conservation area was extended eastwards along Bussey's Loke this would be a further reason for not including this site in the GNLP as the construction of a large housing estate in such a location would most certainly not be appropriate.

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).


G) The southern end of the site is subject to flooding and the HELAA assessment notes that the flood risk constraint analysis produces an amber delineation.

2) GNLP 1017 - 0.9 hectares Land at Broaden Lane - Residential development of approximately 20 / 25 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be an estate style development it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."


B) It is unsuitable for development because of access unsuitability The HELAA assessment states: "there is a query over vehicular access, which is presumed to be via a new junction off Broad(en) Lane. Initial highway evidence has highlighted concerns that the possibility of creating suitable access to the site is severely constrained." The site therefore receives a red warning in the assessment in regard to Transport and Roads. Hempnall Parish Council agrees fully with this analysis.

C) The potential impact on nearby high quality Rural River Valley landscape also renders the site unsuitable. We note that the HELAA assessment warns about "possible landscape intrusion into the Tas River Valley".

D) The site is also not suitable because of the possible impact on the Grade II listed Fairstead Lane Farmhouse which is 100 metres to the west.

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed. The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).

3) GNLP 1018 - 3.0 hectares - Land south of Millfields - Residential development of approximately 75 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a very large housing estate it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

This is precisely the type of large scale estate development that Hempnall Parish Council most strongly opposes. It would alter the character of the village enormously and is not needed. Under current plan arrangements plus windfalls and the Rural Exception site we are negotiating with Saffron Housing Hempnall already has the right amount of new housing planned (see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall). This amount allows the village to grow at a rate that can be assimilated and includes the right type of housing that the village needs (i.e. affordable houses).

B) It is unsuitable for development because of access unsuitability The HELAA assessment states: "there is a query over vehicular access, which is presumed to be via a narrow track to Field Lane. Initial highway evidence has highlighted concerns that the possibility of creating suitable access to the site is severely constrained." 75 new houses would mean at least 100 extra cars using the Field Lane access on a regular basis - this would create big problems in relation to traffic flow.

C) The potential impact on nearby high quality Rural River Valley landscape also renders the site unsuitable. We note that the HELAA assessment warns about "possible landscape intrusion into the Tas River Valley". It should be noted that although the Rural River Valley landscape definition applies to the valley north of the B 1527 the character of the valley landscape south of the B 1527 is the same (water meadows enclosed in a charming valley with a public right of way) and the presence of a large housing estate on the crest of the eastern valley side immediately above this most serene valley would have a very negative impact on landscape character and rural tranquillity and most certainly should carry a red warning delineation.

D) The site is also not suitable because of the potential impact on the Grade II listed disused windmill which is 75 metres to the north. This windmill is a notable feature of the Hempnall skyline and the presence of another 75 rooftops in close proximity would seriously diminish its significance in the landscape.

E) The impact of 75 houses on the tranquillity of Millfields - a residential development of low rise bungalows for the elderly - would be most unwelcome

F) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

G) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed. The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).

4) GNLP 1015 - 1.6 hectares - Land adjacent to Hempnall Primary School - approximately 50 dwellings (according to the HELAA doc.)

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be an estate style development it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is unsuitable for development because of access unsuitability The HELAA assessment states: "there is a query over vehicular access, which would be off The Street and next to the primary school. Initial highway evidence has indicated that the creation of a suitable access may be difficult but could be overcome through development." Unfortunately development to improve access would inevitably have a degrading impact on the Conservation Area along Hempnall Street because access would be directly on to the Street at the heart of the conservation area.

C) There would be many other impacts on the Conservation Area along Hempnall Street which is only 150 to 200 metres south of the site. Views out from the conservation area would be seriously degraded and views in to the conservation area from the Public Right Of Way to the north east of the site would be blocked. It is highly regrettable that the HELAA assessment does not take in to account these impacts on the historic conservation area in Hempnall - was it just a desk top study?

Why is impact on the historic environment given a green classification? When Hempnall was presented with a wind turbine application impacts on the conservation area of The Street were a major reason why SNC and ultimately the Secretary of State rejected the application. The turbine site was at a much greater distance from The Street than this development.

Hempnall Parish Council considers that the impacts on the conservation area along Hempnall Street make this site unsuitable for inclusion in the GNLP.

D) Hempnall Parish Council is aware of the fact that the lower parts of this site are subject to flloding and this is another reason why this site is unsuitable. The HELAA assessment notes this flood risk and states "some areas of the site are vulnerable to surface water flooding".

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed. The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).


5) GNLP 0147 - 13.17 hectares - Land around Alburgh Road and Silver Green - 300 houses mentioned the HELAA assessment together with light industrial use and small office units.

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a very large estate style development it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

An estate development of this size would represent an unprecedented change to the character of Hempnall and Hempnall Greens in particular. This is precisely the type of large scale estate development that Hempnall Parish Council most strongly opposes. It would alter the character of the village enormously and is not needed. Under current plan arrangements plus windfalls and the Rural Exception site we are negotiating with Saffron Housing Hempnall already has the right amount of new housing planned (see our comments under point 3 on page 12 detailing how current commitments adequately address housing need in Hempnall). This amount allows the village to grow at a rate that can be assimilated and includes the right type of housing that the village needs (i.e. affordable houses).

B) The impact of this development on transport and roads would be absolutely unacceptable to Hempnall residents and the Parish Council. The HELAA assessment refers to constraints relating to vehicular access but problems would be far greater than this. 300 houses plus office and industrial use would dramatically increase the number of vehicle movements. According to the RAC the average number of cars per household is 1.2 and therefore the houses alone would cause an expansion in car numbers of 360. Local roads could not deal with this dramatic increase. The HELAA assessment acknowledges "the limited capacity of the surrounding highway".

C) The site is remote from the village and its services and the HELAA assessment acknowledges this. This is another reason why this site is not suitable for development.

D) The HELAA assessment also points out problems that would be created in terms of "utilities capacity, possible contaminated land, flood risk and the townscape consequences of a disconnected form of development, possible impact on nearby County Wildlife Sites, and network." Hempnall Parish Council agrees with this analysis and all of these constraints and impacts are valid reasons as to why this site should not be included as an allocation in the GNLP.

The site is located in an area that experiences severe drainage problems. The flat terrain here prevents drainage away from this area and numerous properties close to this site have had problems with foul water, and sometimes sewage, polluting ditches. The problem is so severe that SNC has refused planning permission on relatively small house extensions that might exacerbate the problem.

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.


6) GNLP 0178 - 0.4 hectares adjacent to Tween Oaks, Alburgh Road - 4 dwellings

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is also unsuitable for inclusion in the GNLP because of the constraints and impacts listed in the HELAA assessment, namely: "The site is not particularly well-related to services and would lead to further sporadic development in a countryside location. Initial highway evidence has indicated that there are potential access constraints" And "other constraints are to do with nearby designated ecological assets and Grade II listed buildings"

C) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

D) The site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

7) GNLP 0580 - 0.94 hectares - Land at Home Farm, Alburgh Road, Hempnall Green - 5 to 6 dwellings

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates.
B) The HELAA assessment lists a number of reasons why this site is not suitable for development, namely: "the site is not particularly well related to services and would lead to a disconnected form of development. Initial highway evidence has indicated that there are potential access constraints". And "Other constraints are nearby designated ecological assets and Grade II listed buildings." Hempnall Parish Council considers these impacts and constraints to be valid reasons why this site should not be allocated for development in the GNLP.

C) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

D) The site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

8) GNLP 0220 - 0.48 hectares - Land at Millfields, Hempnall - 15 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as an allocated site for housing because it is currently actively pursuing, in partnership with Saffron Housing, the delineation of this site as a Rural Exception Site in accordance with NPPF paragraphs 71 and 77 (see footnote below).

Hempnall does not need large private housing estates but it does need affordable housing of 10 to 20 units. The need for affordable housing in the village was established in a needs survey carried out by Saffron Housing in conjunction with the Parish Council. The Parish Council has identified this site as the only practical option for an exception site. Attempts have been made in the past to secure land from local landowners for this purpose without success. As this site is adjacent to the development boundary it fulfils the criteria for definition as an exception site and only in this instance has Hempnall Parish Council waived the appliance of its Policy 2C.

The site is owned by South Norfolk Council and negotiations are currently being undertaken by Sam Watts of Saffron Housing and Big Sky Developments (SNC) to secure this site as an exception site. When the Millfield bungalows for the elderly were originally built this site was earmarked for Millfields Phase 2 - i.e. additional social housing. Millfields Phase 2 has never been built but it seems entirely appropriate that this site is now used for social housing purposes as there is a real need for affordable homes in the village which would be addressed through development of this site as an exception site.

Footnote - Relevant NPPF paragraphs

71. Local planning authorities should support the development of entry-level exception sites, suitable for first time buyers (or those looking to rent their first home), unless the need for such homes is already being met within the authority's area. These sites should be on land which is not already allocated for housing and should: a) comprise of entry-level homes that offer one or more types of affordable housing as defined in Annex 2 of this Framework; and b) be adjacent to existing settlements, proportionate in size to them33, not compromise the protection given to areas or assets of particular importance in this Framework34, and comply with any local design policies and standards

77. In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this.

Comments on the progress and process of the GNLP that relate directly or indirectly to the parish of Hempnall and the actions and policies of Hempnall Parish Council

Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

Hempnall Parish Council endorses the content of the CPRE Norfolk Regulation 18 Stage B Consultation Response and in particular would like to highlight the following aspects of the case put forward by CPRE to which the Parish Council has added some comments

1. The real level of demand in the housing market will accord with the evidence supplied by the latest ONS statistics on household creation, even though the Government has chosen to ignore this data in its calculations and is requiring housing targets to be based on older 2014 statistics. The actual level of demand that will occur reinforces the CPRE Norfolk case for new housing to be phased.

Hempnall Parish Council shares CPRE disappointment that the Government has not accepted the most recent ONS statistics on household creation which show a reduction of 51,000 in the number of households created annually - down from 210,000 to 159,000. If the government had accepted this evidence, it is quite clear that current housing commitments in the Joint Core Strategy would have addressed housing need up to 2036 without the need for additional housing to be incorporated in the GNLP. Hempnall's green fields would then not be threatened with estate style developments that we have commented on in this submission.

Only by phasing new development, so that existing sites are developed first, can the issue of land-banking be effectively addressed, especially against this backdrop of reducing housing demand.

2) Increased land banking and the potential for the "cherry picking" of new sites included in the GNLP (if they are not placed on a Reserve List) endangers the soundness of the Plan-Led approach and strategy of the JCS and risks undermining the validity of large-scale infrastructure projects included in the JCS. These infrastructure projects, whose purpose is to facilitate new housing delivery on already allocated sites, could become expensive irrelevancies if the existing allocated sites are not built out. Phasing is the best way to ensure that these infrastructure backed sites are developed first.
Hempnall Parish Council is acutely aware that many of the sites proposed for inclusion in the GNLP are dispersed widely throughout the more rural parts of the plan area and are not located in areas related to the JCS infrastructure. Given that the Joint Core Strategy makes a distinction between the Rural Policy Area and the Norwich Policy Area, and is essentially a plan for the concentration of development closer to Norwich, if the proposed new sites are not phased and are developed ahead of land-banked sites, this would indicate a very different spatial strategy that contradicts the rigorous, Inspector approved, plan-led strategy envisaged in the JCS.

We are especially concerned that without phasing more rural sites will be cherry picked first for development and sites already allocated that have better access to current and planned infrastructure will remain land banked.

The retention of the distinction between the Rural Policy area and the Norwich Policy Area along current boundaries and with a continuation of the protection currently on offer to those parishes in the Rural Policy Area (e.g. Hempnall) would help steer development towards already allocated sites and aid the phasing process. In this context the following Hempnall Parish Council policy is relevant:

Hempnall Parish Council Policy 2a) Norwich Policy Area

Hempnall Parish Council supports retaining the Norwich Policy Area (NPA) with its current boundaries (as defined in the Joint Core Strategy to 2026) for inclusion in the emerging GNLP to 2036. The distinction between the Norwich Policy Area and the Rural Policy Area (RPA) should not be abolished in the new local plan and the area covered by the NPA should not be extended.

Hempnall Parish Council wishes to remain within the Rural Policy Area and asks that current JCS policies that protect the rural parts of Broadland and South Norfolk from excessive development (i.e. all places outside the NPA including Hempnall) should be retained in the GNLP to 2036. New development proposed for inclusion in the 2036 plan should be concentrated in the already suburbanised parts of the NPA.


3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP.

Hempnall Parish Council wants to see some new housing in the village - an amount appropriate to the current size of the settlement. Hempnall, a Service Village in the JCS, already has a Joint Core Strategy site for 20 houses that is still not developed (HEM 1), and, as already mentioned the Parish Council is negotiating with Saffron Housing for up to 20 social houses to be built on an exception site. When these numbers are added to windfalls, Hempnall, under current plan arrangements, could receive approximately 50 new houses. Given that there are presently about 430 houses in the village this represents a greater than 10% increase in the housing stock. This amount of new housing can be assimilated without producing a dramatic and unwelcome change to the society and nature of the settlement and demonstrates how legitimate requests for some new housing can be met under the existing plan (JCS) without requiring new site allocations for inclusion in the GNLP.

The Hempnall scenario, whereby the desire of many residents and parish councils to have some new houses is already addressed via current allocations, exception sites and windfalls, is replicated in many Service and other villages throughout South Norfolk and Broadland. The dispersal option in the GNLP is therefore not needed to address legitimate calls for some housing in villages.

If fully implemented, the Dispersal Option(s) would swamp many Service Villages with excessive numbers of extra houses additional to existing and adequate current allocations. These large numbers could not be assimilated into the existing community, but would become large commuter-based estates, which would be unwelcome and disruptive to the society and form of such settlements.

The proposals for large housing estates for Hempnall would swamp our village with over development and are most certainly not needed as under current plans we already have the realistic possibility of acquiring 50 new houses.

4. CPRE Norfolk supports a continuation of the existing Settlement Hierarchy and opposes the Village Groups' approach to development. We believe that environmental concerns are best addressed through concentrating development close to Norwich and wherever possible by using Brownfield sites.

Hempnall Parish Council strongly supports the CPRE Norfolk desire to retain the existing settlement hierarchy of six separate tiers, and does not support the "village groups" approach. As already stated most villages already have, under existing arrangements, adequate allocations of new housing that has yet yet to be developed and therefore the Village Groups' approach, which would increase dispersal of housing, is not needed, and in fact could have some very unfortunate consequences. Not only does it contradict the plan-led more sustainable concentration approach of the JCS, it also contradicts other existing policy e.g. the Norfolk County Council Safe-Routes to school policy, which discourages development in places that do not have safe footway connections to a school in a neighbouring village. The housing sites proposed for Hempnall Greens for inclusion in the GNLP lack these connections

CPRE point out that it is quite clear from the table on page 80 of the GNDP papers of 23rd June 2017 which summarises a range of factors, including environmental impacts, relevant to each spatial option, that the Urban Concentration option is the least damaging in terms of environmental impacts, whilst the Dispersal Option, into which the Village Groups' approach would presumably be integrated, is the most damaging and least sustainable.

Many of the new sites proposed for inclusion in the GNLP are located in rural locations and these sites should not be approved for inclusion because of some artificial construction of Village Groups or Clusters. In most instances these locations are not supported by infrastructure and the increase in car journeys and pollution attendant upon adopting the Dispersal Option(s) would be most undesirable.

Hempnall does not want to be classified as the centre of a cluster of villages and we support a continuation of the existing settlement hierarchy and the concentration of new development in and around Norwich.

The Hempnall Parish Council Policy 2b) Settlement Hierarchy
states:

HPC considers that the existing Settlement Hierarchy (as defined in the JCS) should be retained in the GNLP to 2036 and re-states its resolve to remain a Service Village and to resist any attempt to be elevated up the hierarchy in the new plan, e.g. to the next level currently known as Key Service Centre.
5) CPRE Norfolk supports the provision of Affordable (Social) housing on Exception sites adjacent to development boundaries in villages where there is a proven need and where the size of the site is in keeping with the size of the settlement

Hempnall Parish Council fully supports CPRE in this aim and has, as already detailed, taken steps to instigate an affordable housing scheme on land at Millfields.


Conclusion

Hempnall Parish Council is fully aware that this is a lengthy submission but this is a crucial time in the development of Norfolk and unnecessary and excessive housing targets, without the phasing of development, will result in extensive areas of attractive countryside being built on.

CPRE make the point that: "Realistically, before 2036 the end date for the GNLP, there are likely to be at least two more revisions of the Plan, which would lead to even more houses being added to the targets, in addition to the 7,200 planned for the GNLP. It is therefore probable that before 2036 over 21,000 extra houses could be added to the existing JCS current commitment (not yet built) of around 35,000 dwellings. This scenario would apply if the two extra revisions increased targets by 7,000 each time. The total number of new houses that could be built (2018-2036) might therefore exceed 56,000 (35,000 + 7,200 + 7,000 + 7,000.)

In reality the delivery of new houses will probably continue at its historic average (since 2001) of around 1,500 per year and therefore there will only be around 27,000 houses built over the 18 year period 2018-2036 (18 x 1,500). The current commitment of 35,000 houses clearly covers this and there is therefore no need for the 200+ sites that are the subject of this consultation or for the 550+ sites already submitted. With the predicted decline in the number of households being created, it is highly unlikely that the rate of house building will increase.

Without a requirement to phase development the new GNLP allocation together with the subsequent allocations, all of which will enter the targets at further plan revisions before 2036 and could be cherry-picked for development, could conceivably cover most of the development that will occur between 2018-2036 (21,200 houses could be added in and the total likely to be built is 27,000). If a phased approach prioritizing existing sites is not employed the land-banking of JCS sites will become a chronic problem and expensive infrastructure projects will be wasted. This clearly would not be a logical Plan Led outcome."

Hempnall Parish Council is shocked by the prospect that 21,000 extra houses (approximately) could be added to the 35,000 current commitments as the GNLP is revised in years to come. The precious countryside of Broadland and South Norfolk (including Hempnall) would not survive such an onslaught of development.

Hempnall residents share the concerns of the Parish Council and they turn out in considerable numbers when new sites are discussed at Parish Council meetings. They fully support our opposition to new sites being included in the GNLP and support our request for development to be phased.

Because of the lengthy and detailed nature of our responses it was not appropriate to use the on-line submission system hence they are fully included within this email. We do not object to the publication of this submission.

GNLP REGULATION 18 CONSULTATION - STAGE B

RESPONSE BY HEMPNALL PARISH COUNCIL


Hempnall Parish Council understands that while the focus of this consultation is in regard to sites submitted during the Regulation 18 Stage additional comments relevant to sites put forward during the Call for Sites can also be submitted. We have also been told that comments of a more general nature relating to the emerging GNLP can also be included.

Sites in Hempnall submitted during the Regulation 18 stage

1) GNLP 2046 - 1.51 hectares at Pear Tree Farm - Residential development of an unspecified number of houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."




B) It is unsuitable for development because of the unsuitability of the local road network and because the site is considered remote and if developed would result in an increased use of unsustainable transport modes. In this regard Hempnall Parish Council agrees with the following statements noted in the HELAA assessment: "Initial highway evidence suggests that the local road network is considered to be unsuitable either in terms of road or junction capacity and lack of footpath provision." And "the site is considered to be remote so development here would be likely to result in an increased use of unsustainable transport modes."

C) The site is near numerous Grade 2 listed buildings.

D) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall

E) Part of the site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

F) The site is located in an area that experiences severe drainage problems. While the constraint analysis in the HELAA assessment gives the green light in regard to Contamination the reality is very different. The flat terrain here prevents drainage away from this area and numerous properties close to this site have had problems with foul water, and sometimes sewage, polluting ditches. The problem is so severe that SNC has refused planning permission on relatively small house extensions that might exacerbate the problem.

2) GNLP 2081 - 2.39 hectares west of Field Lane - Residential Development (40 houses proposed)

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a large scale estate it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is unsuitable for development because of the unsuitability of the local road network and this is confirmed in the HELAA assessment which states: "Initial highway evidence suggests that the local road network is considered to be unsuitable either in terms of road or junction capacity and lack of footpath provision" This could only be mitigated through road widening and hedge removal and such action would severely compromise the attractive and rural nature of Field Lane.


C) The site is near numerous Grade 2 listed buildings

D) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

E) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.


Sites in Hempnall submitted during the Call for Sites

1) GNLP 1016 - 1.3 hectares - Land at Bussey's Loke - Residential development of approximately 50 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a large scale estate it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is unsuitable for development because of the unsuitability of the access road (Bussey's Loke) which is a narrow country lane. The HELAA assessment states: "there is a query over vehicular access, which is presumed to be via the narrow country lane of Bussey's Loke. Initial highway evidence has highlighted concerns that the possibility of creating suitable access to the site is severely constrained." The site therefore receives a red warning in the assessment in regard to Transport and Roads. Hempnall Parish Council agrees fully with this analysis.

C) It is unsuitable for development because of the potential impact on St Margaret's Church a Grade 1 listed building. The HELAA assessment states: "The site is also just 50 metres from the Grade I Church of St Margaret and poses the possibility of causing substantial harm to undeveloped views of this important local heritage asset." The site therefore receives a red warning in the assessment in regard to impact on the historic environment. Hempnall Parish Council agrees fully with this analysis. We would also like to point out that when a proposal for wind turbines in Hempnall was refused by the Secretary of State the impact of the turbines (at a distance of about 1 mile from church yard) on the setting of the church was a significant factor in the Minister's decision. This housing estate would be alongside the churchyard and church and the impact it would have on these heritage assets is absolutely unacceptable to the parish council.

D) South Norfolk Council's Senior Conservation Officer Stephen Beckett has discussed with Hempnall Parish Council the possibility of extending the village Conservation Area to include Bussey's Loke and the neighbouring farm buildings. If the conservation area was extended eastwards along Bussey's Loke this would be a further reason for not including this site in the GNLP as the construction of a large housing estate in such a location would most certainly not be appropriate.

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).


G) The southern end of the site is subject to flooding and the HELAA assessment notes that the flood risk constraint analysis produces an amber delineation.

2) GNLP 1017 - 0.9 hectares Land at Broaden Lane - Residential development of approximately 20 / 25 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be an estate style development it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."


B) It is unsuitable for development because of access unsuitability The HELAA assessment states: "there is a query over vehicular access, which is presumed to be via a new junction off Broad(en) Lane. Initial highway evidence has highlighted concerns that the possibility of creating suitable access to the site is severely constrained." The site therefore receives a red warning in the assessment in regard to Transport and Roads. Hempnall Parish Council agrees fully with this analysis.

C) The potential impact on nearby high quality Rural River Valley landscape also renders the site unsuitable. We note that the HELAA assessment warns about "possible landscape intrusion into the Tas River Valley".

D) The site is also not suitable because of the possible impact on the Grade II listed Fairstead Lane Farmhouse which is 100 metres to the west.

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed. The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).

3) GNLP 1018 - 3.0 hectares - Land south of Millfields - Residential development of approximately 75 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a very large housing estate it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

This is precisely the type of large scale estate development that Hempnall Parish Council most strongly opposes. It would alter the character of the village enormously and is not needed. Under current plan arrangements plus windfalls and the Rural Exception site we are negotiating with Saffron Housing Hempnall already has the right amount of new housing planned (see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall). This amount allows the village to grow at a rate that can be assimilated and includes the right type of housing that the village needs (i.e. affordable houses).

B) It is unsuitable for development because of access unsuitability The HELAA assessment states: "there is a query over vehicular access, which is presumed to be via a narrow track to Field Lane. Initial highway evidence has highlighted concerns that the possibility of creating suitable access to the site is severely constrained." 75 new houses would mean at least 100 extra cars using the Field Lane access on a regular basis - this would create big problems in relation to traffic flow.

C) The potential impact on nearby high quality Rural River Valley landscape also renders the site unsuitable. We note that the HELAA assessment warns about "possible landscape intrusion into the Tas River Valley". It should be noted that although the Rural River Valley landscape definition applies to the valley north of the B 1527 the character of the valley landscape south of the B 1527 is the same (water meadows enclosed in a charming valley with a public right of way) and the presence of a large housing estate on the crest of the eastern valley side immediately above this most serene valley would have a very negative impact on landscape character and rural tranquillity and most certainly should carry a red warning delineation.

D) The site is also not suitable because of the potential impact on the Grade II listed disused windmill which is 75 metres to the north. This windmill is a notable feature of the Hempnall skyline and the presence of another 75 rooftops in close proximity would seriously diminish its significance in the landscape.

E) The impact of 75 houses on the tranquillity of Millfields - a residential development of low rise bungalows for the elderly - would be most unwelcome

F) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

G) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed. The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).

4) GNLP 1015 - 1.6 hectares - Land adjacent to Hempnall Primary School - approximately 50 dwellings (according to the HELAA doc.)

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be an estate style development it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is unsuitable for development because of access unsuitability The HELAA assessment states: "there is a query over vehicular access, which would be off The Street and next to the primary school. Initial highway evidence has indicated that the creation of a suitable access may be difficult but could be overcome through development." Unfortunately development to improve access would inevitably have a degrading impact on the Conservation Area along Hempnall Street because access would be directly on to the Street at the heart of the conservation area.

C) There would be many other impacts on the Conservation Area along Hempnall Street which is only 150 to 200 metres south of the site. Views out from the conservation area would be seriously degraded and views in to the conservation area from the Public Right Of Way to the north east of the site would be blocked. It is highly regrettable that the HELAA assessment does not take in to account these impacts on the historic conservation area in Hempnall - was it just a desk top study?

Why is impact on the historic environment given a green classification? When Hempnall was presented with a wind turbine application impacts on the conservation area of The Street were a major reason why SNC and ultimately the Secretary of State rejected the application. The turbine site was at a much greater distance from The Street than this development.

Hempnall Parish Council considers that the impacts on the conservation area along Hempnall Street make this site unsuitable for inclusion in the GNLP.

D) Hempnall Parish Council is aware of the fact that the lower parts of this site are subject to flloding and this is another reason why this site is unsuitable. The HELAA assessment notes this flood risk and states "some areas of the site are vulnerable to surface water flooding".

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is a Greenfield site and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed. The landowner proposing this development has not specified a timescale for development and has so far not developed an allocation granted in the Joint Core Strategy for 20 houses on land east of Roland Drive (site HEM 1).


5) GNLP 0147 - 13.17 hectares - Land around Alburgh Road and Silver Green - 300 houses mentioned the HELAA assessment together with light industrial use and small office units.

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would be a very large estate style development it therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

An estate development of this size would represent an unprecedented change to the character of Hempnall and Hempnall Greens in particular. This is precisely the type of large scale estate development that Hempnall Parish Council most strongly opposes. It would alter the character of the village enormously and is not needed. Under current plan arrangements plus windfalls and the Rural Exception site we are negotiating with Saffron Housing Hempnall already has the right amount of new housing planned (see our comments under point 3 on page 12 detailing how current commitments adequately address housing need in Hempnall). This amount allows the village to grow at a rate that can be assimilated and includes the right type of housing that the village needs (i.e. affordable houses).

B) The impact of this development on transport and roads would be absolutely unacceptable to Hempnall residents and the Parish Council. The HELAA assessment refers to constraints relating to vehicular access but problems would be far greater than this. 300 houses plus office and industrial use would dramatically increase the number of vehicle movements. According to the RAC the average number of cars per household is 1.2 and therefore the houses alone would cause an expansion in car numbers of 360. Local roads could not deal with this dramatic increase. The HELAA assessment acknowledges "the limited capacity of the surrounding highway".

C) The site is remote from the village and its services and the HELAA assessment acknowledges this. This is another reason why this site is not suitable for development.

D) The HELAA assessment also points out problems that would be created in terms of "utilities capacity, possible contaminated land, flood risk and the townscape consequences of a disconnected form of development, possible impact on nearby County Wildlife Sites, and network." Hempnall Parish Council agrees with this analysis and all of these constraints and impacts are valid reasons as to why this site should not be included as an allocation in the GNLP.

The site is located in an area that experiences severe drainage problems. The flat terrain here prevents drainage away from this area and numerous properties close to this site have had problems with foul water, and sometimes sewage, polluting ditches. The problem is so severe that SNC has refused planning permission on relatively small house extensions that might exacerbate the problem.

E) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

F) The site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.


6) GNLP 0178 - 0.4 hectares adjacent to Tween Oaks, Alburgh Road - 4 dwellings

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and would therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates."

B) It is also unsuitable for inclusion in the GNLP because of the constraints and impacts listed in the HELAA assessment, namely: "The site is not particularly well-related to services and would lead to further sporadic development in a countryside location. Initial highway evidence has indicated that there are potential access constraints" And "other constraints are to do with nearby designated ecological assets and Grade II listed buildings"

C) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

D) The site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

7) GNLP 0580 - 0.94 hectares - Land at Home Farm, Alburgh Road, Hempnall Green - 5 to 6 dwellings

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as a site for housing for the following reasons:

A) It is located outside the current development boundary and therefore contradicts Hempnall Parish Council Policy 2c) Development Area Boundary which states:

"HPC opposes any development of the village outside the currently defined development boundary. We support infill of small groups of dwellings and small scale businesses and services inside the development area demarcated by this boundary but oppose large scale housing estates.
B) The HELAA assessment lists a number of reasons why this site is not suitable for development, namely: "the site is not particularly well related to services and would lead to a disconnected form of development. Initial highway evidence has indicated that there are potential access constraints". And "Other constraints are nearby designated ecological assets and Grade II listed buildings." Hempnall Parish Council considers these impacts and constraints to be valid reasons why this site should not be allocated for development in the GNLP.

C) If developed the site would contribute an expansion in housing numbers that the parish council considers inappropriate for the village of Hempnall - see our comments under point 3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP detailing how current commitments adequately address housing need in Hempnall.

D) The site is currently "Greenfield" and given the high number of already allocated sites that have not yet been built out (approximately 35,000 existing commitments in the current plan - the Joint Core Strategy) new Green field sites should not be brought forward for development until existing "land banked" sites have been used up. Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

8) GNLP 0220 - 0.48 hectares - Land at Millfields, Hempnall - 15 houses

The HELAA Capacity Assessment concludes that this site is appropriate for the land availability assessment.

Hempnall Parish Council objects to this site being included in the GNLP as an allocated site for housing because it is currently actively pursuing, in partnership with Saffron Housing, the delineation of this site as a Rural Exception Site in accordance with NPPF paragraphs 71 and 77 (see footnote below).

Hempnall does not need large private housing estates but it does need affordable housing of 10 to 20 units. The need for affordable housing in the village was established in a needs survey carried out by Saffron Housing in conjunction with the Parish Council. The Parish Council has identified this site as the only practical option for an exception site. Attempts have been made in the past to secure land from local landowners for this purpose without success. As this site is adjacent to the development boundary it fulfils the criteria for definition as an exception site and only in this instance has Hempnall Parish Council waived the appliance of its Policy 2C.

The site is owned by South Norfolk Council and negotiations are currently being undertaken by Sam Watts of Saffron Housing and Big Sky Developments (SNC) to secure this site as an exception site. When the Millfield bungalows for the elderly were originally built this site was earmarked for Millfields Phase 2 - i.e. additional social housing. Millfields Phase 2 has never been built but it seems entirely appropriate that this site is now used for social housing purposes as there is a real need for affordable homes in the village which would be addressed through development of this site as an exception site.

Footnote - Relevant NPPF paragraphs

71. Local planning authorities should support the development of entry-level exception sites, suitable for first time buyers (or those looking to rent their first home), unless the need for such homes is already being met within the authority's area. These sites should be on land which is not already allocated for housing and should: a) comprise of entry-level homes that offer one or more types of affordable housing as defined in Annex 2 of this Framework; and b) be adjacent to existing settlements, proportionate in size to them33, not compromise the protection given to areas or assets of particular importance in this Framework34, and comply with any local design policies and standards

77. In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this.

Comments on the progress and process of the GNLP that relate directly or indirectly to the parish of Hempnall and the actions and policies of Hempnall Parish Council

Hempnall Parish Council is a member of the CPRE Norfolk Alliance which is campaigning for phased development so that existing sites, already allocated in the JCS, are built out before any new sites under consideration for inclusion in the GNLP can be developed.

Hempnall Parish Council endorses the content of the CPRE Norfolk Regulation 18 Stage B Consultation Response and in particular would like to highlight the following aspects of the case put forward by CPRE to which the Parish Council has added some comments

1. The real level of demand in the housing market will accord with the evidence supplied by the latest ONS statistics on household creation, even though the Government has chosen to ignore this data in its calculations and is requiring housing targets to be based on older 2014 statistics. The actual level of demand that will occur reinforces the CPRE Norfolk case for new housing to be phased.

Hempnall Parish Council shares CPRE disappointment that the Government has not accepted the most recent ONS statistics on household creation which show a reduction of 51,000 in the number of households created annually - down from 210,000 to 159,000. If the government had accepted this evidence, it is quite clear that current housing commitments in the Joint Core Strategy would have addressed housing need up to 2036 without the need for additional housing to be incorporated in the GNLP. Hempnall's green fields would then not be threatened with estate style developments that we have commented on in this submission.

Only by phasing new development, so that existing sites are developed first, can the issue of land-banking be effectively addressed, especially against this backdrop of reducing housing demand.

2) Increased land banking and the potential for the "cherry picking" of new sites included in the GNLP (if they are not placed on a Reserve List) endangers the soundness of the Plan-Led approach and strategy of the JCS and risks undermining the validity of large-scale infrastructure projects included in the JCS. These infrastructure projects, whose purpose is to facilitate new housing delivery on already allocated sites, could become expensive irrelevancies if the existing allocated sites are not built out. Phasing is the best way to ensure that these infrastructure backed sites are developed first.
Hempnall Parish Council is acutely aware that many of the sites proposed for inclusion in the GNLP are dispersed widely throughout the more rural parts of the plan area and are not located in areas related to the JCS infrastructure. Given that the Joint Core Strategy makes a distinction between the Rural Policy Area and the Norwich Policy Area, and is essentially a plan for the concentration of development closer to Norwich, if the proposed new sites are not phased and are developed ahead of land-banked sites, this would indicate a very different spatial strategy that contradicts the rigorous, Inspector approved, plan-led strategy envisaged in the JCS.

We are especially concerned that without phasing more rural sites will be cherry picked first for development and sites already allocated that have better access to current and planned infrastructure will remain land banked.

The retention of the distinction between the Rural Policy area and the Norwich Policy Area along current boundaries and with a continuation of the protection currently on offer to those parishes in the Rural Policy Area (e.g. Hempnall) would help steer development towards already allocated sites and aid the phasing process. In this context the following Hempnall Parish Council policy is relevant:

Hempnall Parish Council Policy 2a) Norwich Policy Area

Hempnall Parish Council supports retaining the Norwich Policy Area (NPA) with its current boundaries (as defined in the Joint Core Strategy to 2026) for inclusion in the emerging GNLP to 2036. The distinction between the Norwich Policy Area and the Rural Policy Area (RPA) should not be abolished in the new local plan and the area covered by the NPA should not be extended.

Hempnall Parish Council wishes to remain within the Rural Policy Area and asks that current JCS policies that protect the rural parts of Broadland and South Norfolk from excessive development (i.e. all places outside the NPA including Hempnall) should be retained in the GNLP to 2036. New development proposed for inclusion in the 2036 plan should be concentrated in the already suburbanised parts of the NPA.


3) Support for some new housing does not equate to support for the Dispersal Option(s) for development in the GNLP.

Hempnall Parish Council wants to see some new housing in the village - an amount appropriate to the current size of the settlement. Hempnall, a Service Village in the JCS, already has a Joint Core Strategy site for 20 houses that is still not developed (HEM 1), and, as already mentioned the Parish Council is negotiating with Saffron Housing for up to 20 social houses to be built on an exception site. When these numbers are added to windfalls, Hempnall, under current plan arrangements, could receive approximately 50 new houses. Given that there are presently about 430 houses in the village this represents a greater than 10% increase in the housing stock. This amount of new housing can be assimilated without producing a dramatic and unwelcome change to the society and nature of the settlement and demonstrates how legitimate requests for some new housing can be met under the existing plan (JCS) without requiring new site allocations for inclusion in the GNLP.

The Hempnall scenario, whereby the desire of many residents and parish councils to have some new houses is already addressed via current allocations, exception sites and windfalls, is replicated in many Service and other villages throughout South Norfolk and Broadland. The dispersal option in the GNLP is therefore not needed to address legitimate calls for some housing in villages.

If fully implemented, the Dispersal Option(s) would swamp many Service Villages with excessive numbers of extra houses additional to existing and adequate current allocations. These large numbers could not be assimilated into the existing community, but would become large commuter-based estates, which would be unwelcome and disruptive to the society and form of such settlements.

The proposals for large housing estates for Hempnall would swamp our village with over development and are most certainly not needed as under current plans we already have the realistic possibility of acquiring 50 new houses.

4. CPRE Norfolk supports a continuation of the existing Settlement Hierarchy and opposes the Village Groups' approach to development. We believe that environmental concerns are best addressed through concentrating development close to Norwich and wherever possible by using Brownfield sites.

Hempnall Parish Council strongly supports the CPRE Norfolk desire to retain the existing settlement hierarchy of six separate tiers, and does not support the "village groups" approach. As already stated most villages already have, under existing arrangements, adequate allocations of new housing that has yet yet to be developed and therefore the Village Groups' approach, which would increase dispersal of housing, is not needed, and in fact could have some very unfortunate consequences. Not only does it contradict the plan-led more sustainable concentration approach of the JCS, it also contradicts other existing policy e.g. the Norfolk County Council Safe-Routes to school policy, which discourages development in places that do not have safe footway connections to a school in a neighbouring village. The housing sites proposed for Hempnall Greens for inclusion in the GNLP lack these connections

CPRE point out that it is quite clear from the table on page 80 of the GNDP papers of 23rd June 2017 which summarises a range of factors, including environmental impacts, relevant to each spatial option, that the Urban Concentration option is the least damaging in terms of environmental impacts, whilst the Dispersal Option, into which the Village Groups' approach would presumably be integrated, is the most damaging and least sustainable.

Many of the new sites proposed for inclusion in the GNLP are located in rural locations and these sites should not be approved for inclusion because of some artificial construction of Village Groups or Clusters. In most instances these locations are not supported by infrastructure and the increase in car journeys and pollution attendant upon adopting the Dispersal Option(s) would be most undesirable.

Hempnall does not want to be classified as the centre of a cluster of villages and we support a continuation of the existing settlement hierarchy and the concentration of new development in and around Norwich.

The Hempnall Parish Council Policy 2b) Settlement Hierarchy
states:

HPC considers that the existing Settlement Hierarchy (as defined in the JCS) should be retained in the GNLP to 2036 and re-states its resolve to remain a Service Village and to resist any attempt to be elevated up the hierarchy in the new plan, e.g. to the next level currently known as Key Service Centre.
5) CPRE Norfolk supports the provision of Affordable (Social) housing on Exception sites adjacent to development boundaries in villages where there is a proven need and where the size of the site is in keeping with the size of the settlement

Hempnall Parish Council fully supports CPRE in this aim and has, as already detailed, taken steps to instigate an affordable housing scheme on land at Millfields.


Conclusion

Hempnall Parish Council is fully aware that this is a lengthy submission but this is a crucial time in the development of Norfolk and unnecessary and excessive housing targets, without the phasing of development, will result in extensive areas of attractive countryside being built on.

CPRE make the point that: "Realistically, before 2036 the end date for the GNLP, there are likely to be at least two more revisions of the Plan, which would lead to even more houses being added to the targets, in addition to the 7,200 planned for the GNLP. It is therefore probable that before 2036 over 21,000 extra houses could be added to the existing JCS current commitment (not yet built) of around 35,000 dwellings. This scenario would apply if the two extra revisions increased targets by 7,000 each time. The total number of new houses that could be built (2018-2036) might therefore exceed 56,000 (35,000 + 7,200 + 7,000 + 7,000.)

In reality the delivery of new houses will probably continue at its historic average (since 2001) of around 1,500 per year and therefore there will only be around 27,000 houses built over the 18 year period 2018-2036 (18 x 1,500). The current commitment of 35,000 houses clearly covers this and there is therefore no need for the 200+ sites that are the subject of this consultation or for the 550+ sites already submitted. With the predicted decline in the number of households being created, it is highly unlikely that the rate of house building will increase.

Without a requirement to phase development the new GNLP allocation together with the subsequent allocations, all of which will enter the targets at further plan revisions before 2036 and could be cherry-picked for development, could conceivably cover most of the development that will occur between 2018-2036 (21,200 houses could be added in and the total likely to be built is 27,000). If a phased approach prioritizing existing sites is not employed the land-banking of JCS sites will become a chronic problem and expensive infrastructure projects will be wasted. This clearly would not be a logical Plan Led outcome."

Hempnall Parish Council is shocked by the prospect that 21,000 extra houses (approximately) could be added to the 35,000 current commitments as the GNLP is revised in years to come. The precious countryside of Broadland and South Norfolk (including Hempnall) would not survive such an onslaught of development.

Hempnall residents share the concerns of the Parish Council and they turn out in considerable numbers when new sites are discussed at Parish Council meetings. They fully support our opposition to new sites being included in the GNLP and support our request for development to be phased.

Because of the lengthy and detailed nature of our responses it was not appropriate to use the on-line submission system hence they are fully included within this email. We do not object to the publication of this submission.