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Object

Publication

0503 Policy

Representation ID: 24254

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

GNLP0503 was submitted during the call for sites 2016. The landowners wish to withdraw the land from the plan (please see representation made by Hall Farm (Hingham Ltd) for details). Therefore, this site is undeliverable. Policies relating to the inclusion of GNLP0503 for development and the proposed 20 dwellings for this site are unsound.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

Full text:

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence
Representation 1 -
Site specific – relating to GNLP0503
Representation regarding the inclusion in the GNLP of (Land north of Springfield Way and west of Dereham
Road) GNLP0503, for develop of approximately 20 homes
Representations 2
Site specific GNLP0520
Representation regarding the inclusion in the GNLP of “Land south of Norwich Road, Hingham GNLP0520”
Representation 3
With regard to the site selection process:
The rejection of sites as reasonable alternatives, therefore no reasonable alternatives were put forward for the Regulation 18c consultation.
Representation 4
Regarding the plan making process
Representation 5
Policy 5.36. Two sites are allocated providing for at least 100 new homes in the key service centre (one for 80 homes, one for 20 homes). There are no carried forward residential allocations and a total of 20 additional dwellings with planning permission on small sites. This gives a total deliverable housing commitment for the key service centre of 120 homes between 2018 – 2038.
Representation 6 - Infrastructure requirements
Representation 7 - Settlement map
Representation 8 - Green Infrastructure Study
Representation 9 - Equality Impact Assessment

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

0520 Policy

Representation ID: 24255

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Representation regarding the inclusion of site GNLP0520 with reference to:
- Surface water flood risk
- Pedestrian Safety
- Detrimental impact on valued landscapes
- TPO trees and Highway access
- Pedestrian links to the Towns facilities
- Close proximity to the industrial area

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

GNLP SHOULD NOT BE ADOPTED
Proper regard should be given to the representations made in opposition to GNLP0520 being allocated for development, especially with regard to flooding issues, potential impact on historical heritage, the protection of valued landscape, the adequacy of footway links and proximity to ALL of the town’s facilities.
GNLP0520 should be removed from the plan.
Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an alternative site to come forward and for representations to be made.
Consideration MUST be given to if a site would provide a benefit alongside the proposed housing development, and if it would enable opportunity to achieve the aspirations of the community/town council for “future proofing” Hingham to be able to provide facilities to a growing community.
Allocations of any sites should be based on firm evidence that proposals made in order to mitigate, are actually feasible and achievable.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

Equalities Impact Assessment

Representation ID: 24256

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Equality Impact Assessment
, Policy Assessment Table (page 15) returned a Not Applicable result in the site-specific policies GNLP0520 and GNLP0503, in relation
to the impact on the protected group including those with disabilities.

The allocation of GNLP0520 is unsound it does not provide safe access to shops and services and is therefore contrary to NPPF 8. Promoting healthy and safe
communities, para 91c

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

GNLP SHOULD NOT BE ADOPTED
Proper regard should be given to the representations made in opposition to GNLP0520 being allocated for development, especially with regard to flooding issues,
potential impact on historical heritage, the protection of valued landscape, the adequacy of footway links and proximity to ALL of the towns facilities.
GNLP0520 should be removed from the plan. Regard should be given to the submissions of residents of The Hops (Survey Appendix B) who are currently affected by
the poor footway links to the Towns shops and facilities.
Reconsider the housing numbers allocated for Hingham/Reconsult to allow for alternative sites to come forward and for representations to be made
Consideration MUST be given to if a site would provide a benefit alongside the proposed housing development, and if it would enable opportunity to achieve the
aspirations of the community/town council for “future proofing” Hingham to be able to provide facilities to a growing community.
Allocations of any sites should be based on firm evidence that proposals made in order to mitigate, are actually feasible and achievable.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

Green Infrastructure Study

Representation ID: 24257

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Detail of the conservation area are incorrect and therefore unsound as an evidence base.
This is reference to the maps for Hingham, other maps may also be incorrect.
Any decision based on location and extent of the conservation area would therefore be unsound

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

Review evidence base to ensure all maps showing conservation areas are correct. Review all decisions taken on the basis of the location and extent of a
conservation area.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

Settlement Maps

Representation ID: 24258

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The GNLP settlement map does not include the defined town centre area. This has led to the misinterpretation and misinterpretation that the Co-op being the
“centre” of Hingham and to the negligence of the town’s small independent businesses. The Co-op is placed outside of the Town Centre ad defined in the SNC
Local Plan Development Management Policies Document 2015 (Maps) DM.2.4 & 2.5(4) Hingham Town Centre Area - Policies DM.2.4 & 2.5
53, no reference is made in the GNLP to the defined Town Centre, showing an inconsistent approach to the significance of areas within a settlement and making the plan inconsistent with the SNC Local Plan Development Management Policies Document (2015) which is to be retained.
Neglect of the significance of the defined Town Centre is contrary to NPPF 7. Ensuring the vitality of town centres – para 85d and 85f. and

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

Include a defined Town Centre in the (relevant) GNLP settlement maps.
Review decisions based on location for development in relation to shops and services

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

5.36

Representation ID: 24259

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The plan is unsound as the landowner of site GNLP0503 has requested that is be withdrawn from the GNLP therefore the site and its allocated housing commitment
is undeliverable.

During the Regulation 18C consultation there were concerns raised regarding the numbers of housing proposed for Hingham and push to deliver housing
development “en masse” which could potentially overwhelm the town’s facilities and infrastructure. Housing figures are not discussed in line with actual need
within the community or taking into account the number of vacant properties already in existence.
The GNLP runs until 2038 and the Town Council are of the opinion that a phased approach to delivering smaller developments, as and when needed, with a higher
focus on affordability for local people would be a more acceptable and appropriate approach, these concerns have not been addressed.

The policy wording for GNLP0520 states “Land south of Norwich Road, Hingham (approx. 6.92 ha) is allocated for residential development. This will accommodate
approximately 80 homes. More homes may be accommodated, subject to an acceptable design and layout being achieved, and any infrastructure issues
addressed”.
Policy wording states “5.36 Two sites are allocated providing for at least 100 new homes in the key service centre (one for 80 homes, one for 20 homes)”

Aside from GNLP0520 being objected to as being included in the plan, the policy wording itself is unsound and allows for more homes, without a maximum number
being stipulated. If GNLP0503 were to remain in the plan, this would have the effect of potentially increasing the number of homes built and increasing density
beyond that portrayed during public consultations, to enable absorption of undelivered housing numbers through other sites. This could lead to inappropriate
housing numbers and densities arising, contrary to the recommendations made by “Authorities” such as Highways etc during the consultation process.

It is concerning to read that in the Bidwells submission for GNLP052050 the developer is already suggesting that the site can accommodate more than the suggested
80 homes and indeed above the housing numbers allocated for Hingham in the GNLP, and is anticipating GNLP0520 accommodating the 20 homes allocated to
GNLP0503.
“3.11 …… it is evident that the site can comfortably accommodate the minimum number of units identified by the proposed allocation, it has the potential, if
required, to accommodate all of the growth proposed for Hingham (i.e. 100 dwellings). This is particularly relevant given that, as detailed in the Note to Policy
GNLP0503, the second site in Hingham has potential access and amenity constraints. Given the suitability of the GNLP0520, as is demonstrated by this and previous
Representations, it is recommended that, if GNLP0503 cannot demonstrate that it is deliverable, all of the growth afforded to Hingham is allocated on the site.
3.12 In addition, the site could accommodate additional growth, above the 100 dwellings allocated to Hingham, should it become evident that other sites across
the GNLP area are undeliverable”.

There has been no consideration to the cumulative impact of housing numbers delivered in Hingham over the past decades, during which time no infrastructure
improvements have been made. The housing numbers in excess of 100 will dramatically increase the population of Hingham, with no investment in infrastructure
or services to support the growing community. The impact on vital services such as the Doctors Surgery is of particular concern. See Representation 6

The allocation of GNLP0520 (along with the inference that it will deliver more than the 100 homes allocated to Hingham), adjacent to The Hops removes the
element of choice for potential new residents wishing to purchase a new build home, being that the development allocations in 2 successive local plans are in the
same location, provided by the same developer and will be (it is assumed) to the same style. Resulting in an over prominent overbearing large development not
in keeping with the overall character of the town.
This is contrary to NPPF 12 Achieving well-designed places para 127

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

GNLP SHOULD NOT BE ADOPTED IN ITS CURRENT FORM
Removal of site GNLP0503 from the GNLP in accordance with the landowners wishes.
Removal of GNLP0503 due to undeliverability of the site due to the caveat ….” subject to provision of a safe access and a continuous footway at the west side of
Dereham Road from the site access to Pottles Alley”.
Removal of the 20 dwellings from the housing numbers specified for Hingham/Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an
alternative site to come forward.

AND
GNLP SHOULD NOT BE ADOPTED
Proper regard should be given to the representations made in opposition to GNLP0520 being allocated for development, especially with regard to flooding issues,
potential impact on historical heritage, the protection of valued landscape, the adequacy of footway links and proximity to ALL of the towns facilities.
GNLP0520 should be removed from the plan.
Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an alternative site to come forward and for representations to be made.
Consideration MUST be given to if a site would provide a benefit alongside the proposed housing development, and if it would enable opportunity to achieve the
aspirations of the community/town council for “future proofing” Hingham to be able to provide facilities to a growing community.
Allocations of any sites should be based on firm evidence that proposals made in order to mitigate, are actually feasible and achievable.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

Key Service Centres Assessment Booklets

Representation ID: 24260

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

During the regulation 18C consultation a comprehensive submission was made by Hingham Town Council raising objection some sites being deemed as unsuitable
for development and not being put forward for consultation as reasonable alternatives. With specific reference to the site assessments, the Town Council consider that there are a number of contradictions within the site assessments, the conclusion of sites put forward for housing development and the decisions on some
sites to be deemed unsuitable, are extremely flawed and not based on proportionate evidence.

Of the sites consulted on during the Regulation 18C consultation, as previously stated the Town Council and residents consider GNLP0520 unsuitable for
development and objections were made against the site as a preferred option. Objections were also made against the following sites being deemed unsuitable
and not being put forward for consultation as “reasonable alternatives”: GNLP0298 and GNLP 0335, GNLP0501 and GNLP0502.

The Town Council in their regulation 18C representation expressed that these options should be further explored. With regard to GNLP0501 and 0502 there was
a potential for community benefit, if additional land for the sports centre could have been incorporated with highway access being achievable via land owned by the Town Council. It is understood that the landowner is not pursuing development of GNLP0501 and GNLP0502 at this time, therefore this representation will not
make further reference to these sites.

With regard to GNLP0298 and GNLP0335 (the same developer is promoting both sites), although housing numbers proposed are a concern, the development of
these sites would offer the future community benefit of a community woodland and the access link to land which could have a potential to help achieve the
aspirations of the community and Town Council by providing an area of land (GNLP0395) which could be utilised for improving Hingham’s infrastructure/facilities.
It is recognised that any development on agricultural land will have an initial negative impact on biodiversity and wildlife. NPPF 174b states plans should “pursue
opportunities for securing measurable net gains for biodiversity”. The allocation of GNLP0520 and GNLP0503, when judged against the proposal of delivering a community woodland in conjunction with GNLP0298 and GNLP0335, is contrary to NPPF para 174b.

As already demonstrated the Town Council consider the allocation of GNLP0520 and GNLP0503 in the GNLP to be unsound, and therefore the GNLP should not be
adopted with the inclusion of either site.

Due to the GNLP rejection of other sites promoted, no other sites in Hingham have been subject to public consultation as reasonable alternatives/sites with the
potential for being developed. Therefore, residents have not made their views known via the consultation process in relation to the potential of GNLP0298 and
GNLP0335 as housing allocation. Of the sites submitted (and remaining available) GNLP0298 and GNLP0335 would appear to offer an alternative to GNLP0520,
however residents views, such as submitted to the Town Council (evidence 3a) should be sought.
The GNLP is not justified, it has not fully taken into taking into account reasonable alternatives and the decisions to include GNLP0520 /GNLP0503 and reject
alternatives sites is not based on proportionate evidence.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

GNLP SHOULD NOT BE ADOPTED IN ITS CURRENT FORM
Removal of site GNLP0503 from the GNLP in accordance with the landowners wishes.
Removal of GNLP0503 due to undeliverability of the site due to the caveat ….” subject to provision of a safe access and a continuous footway at the west side of
Dereham Road from the site access to Pottles Alley”.
Removal of the 20 dwellings from the housing numbers specified for Hingham/Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an
alternative site to come forward.
AND
GNLP SHOULD NOT BE ADOPTED
Proper regard should be given to the representations made in opposition to GNLP0520 being allocated for development, especially with regard to flooding issues,
potential impact on historical heritage, the protection of valued landscape, the adequacy of footway links and proximity to ALL of the town’s facilities.
GNLP0520 should be removed from the plan.
Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an alternative site to come forward and for representations to be made.44
Consideration MUST be given to if a site would provide a benefit alongside the proposed housing development, and if it would enable opportunity to achieve the
aspirations of the community/town council for “future proofing” Hingham to be able to provide facilities to a growing community.

Allocations of any sites should be based on firm evidence that proposals made in order to mitigate, are actually feasible and achievable.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

Statement of Consultation

Representation ID: 24400

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The GNLP process has not been a platform for local people to shape their surroundings and effective engagement between plan-makers and communities has not taken place (effective engagement should surely result in proper consideration of representations and measures undertaken to effect resolution of issues raised).
This is contrary to NPPF 3 – Plan Making
The South Norfolk Council Statement of Community Involvement has not been adhered to, therefore the GNLP is not legally compliant.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

GNLP SHOULD NOT BE ADOPTED IN ITS CURRENT FORM
Removal of site GNLP0503 from the GNLP in accordance with the landowners wishes.
Removal of GNLP0503 due to undeliverability of the site due to the caveat ….” subject to provision of a safe access and a continuous footway at the west side of
Dereham Road from the site access to Pottles Alley”.
Removal of the 20 dwellings from the housing numbers specified for Hingham/Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an
alternative site to come forward.
AND
GNLP SHOULD NOT BE ADOPTED
Proper regard should be given to the representations made in opposition to GNLP0520 being allocated for development, especially with regard to flooding issues,
potential impact on historical heritage, the protection of valued landscape, the adequacy of footway links and proximity to ALL of the towns facilities.
GNLP0520 should be removed from the plan.
Reconsider the housing numbers allocated for Hingham/Reconsult to allow for an alternative site to come forward and for representations to be made.
Consideration MUST be given to if a site would provide a benefit alongside the proposed housing development, and if it would enable opportunity to achieve the
aspirations of the community/town council for “future proofing” Hingham to be able to provide facilities to a growing community.
Allocations of any sites should be based on firm evidence that proposals made in order to mitigate, are actually feasible and achievable.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

Object

Publication

Appendix 1 Infrastructure Requirements

Representation ID: 24401

Received: 22/03/2021

Respondent: Hingham Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

GNLP Part 1 The Strategy Appendix 1 – Infrastructure Requirements is in general very limited in its commitment to provide infrastructure to support the housing
numbers allocated, with NO commitment to Hingham stipulated.

During the Regulation 18C consultation Hingham Town Council submitted representations to POLICY 4 - STRATEGIC INFRASTRUCTURE (see evidence 6a), There is no evidence to show that these representations have been given consideration.

With specific reference to Hingham, no infrastructure needs have been identified within the GNLP, despite the cumulative impact of development within the town
over the past decades and the extensive development in the nearby Breckland area.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Change suggested by respondent:

Duty to Co-operate needs to be fulfilled in terms of a full and proper appraisal of Hingham to enable sustainable development, including improvements to
infrastructure and services. This should include a commitment to improving the Library and inclusion of any results of the NCC Parish Partnership Scheme study,
that identifies a feasible solution to improving junction safety at the Attenborough Rd/Dereham Rd/B1108 Fairland crossroads and the inclusion of a pedestrian
priority crossing point that will best serve all residents of Hingham, therefore giving value to the £10,000 investment already made (50/50 Hingham Town
Council and NCC)

With regard to housing numbers a maximum housing allocation should be set for each allocated site, to ensure aggressive development doesn’t take place and
appropriate densities are not disregarded.

Please see the document :
HTC Greater Norwich Local Plan Regulation 19 Consultation Response
for detailed representations and evidence

Full text:

Attachments:

HTC Greater Norwich Local Plan Regulation 19 Consultation Response.pdf (3.33 MB)

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