Publication

Object

Representation ID: 24090

Received: 19/03/2021

Respondent: Diss Town Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Thank you for the opportunity to submit a representation on the Regulation 19 version of the emerging
GNLP.
Our representation concerns Policy GNLP0102 – the land allocated for residential development at Frontier
Agriculture Ltd, Sandy Lane, Diss. As you know, it was our intention to allocate this site in the Diss and
District Neighbourhood Plan as part of the DDNP’s aim to meet fully the indicative housing requirement of
400. Although we feel that Planning Practice Guidance supports its inclusion in the DDNP, we have
accepted the GNDP explanation that the GNLP needs to include the allocation by virtue of it being brownfield
land and adjacent to the railway station.
Diss Town Council is, however, concerned that there is no provision for the necessary footway although it
was included in your first draft policy issued in December 2019 but not in the later document dated January
2021.
The connection of these footways is essential for the safety of pedestrians going to the town centre or taking
children to schools as all alternative routes are much further. The town council’s support for this site has
always been and remains contingent on the provision of a footway connecting the frontage of the Frontier
site to Frenze Hall Lane.
We are aware of the argument that you cannot expect a developer to provide a facility that is on 3rd party
land, but this has happened regularly over the last 20 years in Diss. In fact, the provision of a footway from
Frenze Hall Lane under the railway bridge and onto Sandy Lane was conditioned as part of the ongoing
development by the Persimmons Orchard Croft development and is well outside the site frontage and on 3rd
party land. This is confirmed on the two plans we have attached.
The improvements adding a footway from Frenze Hall Lane under the railway bridge and onto Sandy Lane
are as shown on the Persimmons plans FHL-PL101 and conceptual traffic management FHL CIV 002 and
were intended as the first step to connecting to a foot/cycleway when the Frontier site is developed.
In addition, this route along Sandy Lane is part of the walking and cycling corridor in the Strategic Network
review put forward by Norfolk County Council in 2020 and should be improved for this reason alone.
We have enclosed an attachment which shows the 40/50m of footway link required to give a safe route to
the schools in Diss. Also attached are 3 further diagrams which compare the shortest safe routes to the
Infant/Nursery school, the Junior school and High school if the footway in front of the Frontier site is
connected to the Frenze Hall Lane footway compared to the shortest alternative route. We are aware that
the agent for this site says that the pedestrian route over the railway bridge is a shorter route than the
alternative routes we have shown but this does not take account of all the people they are expecting to use
the route. Whilst it may be suitable for some high school children it is a completely unacceptable route for
younger children, mothers with push chairs and those less abled.
You will see with the much longer distances involved in following a safe route to schools from housing on the
Frontier site, unescorted children and mothers with young children will almost certainly opt to walk in the road
where there is no footpath.
We also think it is important to point out that the Sandy Lane employment area is the largest in Diss and if
we are to discourage the use of motor vehicles that this link is also essential for residents living to the west of
the railway bridge to be able to walk to work.
As a responsible Town Council, we cannot support or condone any planning application that does not
mitigate for the safety of pedestrians. The Government’s www.nidirect.gov.uk website contains a caveat
which we fully support,
‘’Walking to school is a great method of transportation for children whose schools are located within
a reasonable distance. It improves children's health and allows them to travel independently - but
their safety and security is vital’’. This sums up the Diss Town Council concerns.
In this area this is particularly relevant for child pedestrians, wheelchair users, push chair users and the
elderly who might normally find it difficult to move out of the way of approaching vehicles on this narrow road
without a footway.
There is rough verge between the fenced off railway line and the road that is between 1.3m and 1.4m wide
so there is absolutely no reason why the 1.5m footway under the railway bridge could not be extended for
the 40/50m to the frontage of the Frontier site as a minimum.
It is also worth bearing in mind that if Government is serious about reducing the use of motor vehicles for
people travelling relatively short distances to employment sites, it is critical that this footway is available to
encourage workers to walk or cycle to work.
It also offers the shortest route to commuters in the Frenze Hall Lane area of Diss wishing to make use of the
railway station.
This appears contrary to national policy on sustainable transport in the NPPF. This requires that,
“opportunities to promote walking, cycling and public transport use are identified and pursued and that
appropriate opportunities to promote sustainable transport modes can be taken up”. The need for the
footway has been clearly identified but is not being pursued, or the opportunity taken up, in Policy
GNLP0102. The omission of the footway described above fails to take advantage of, “opportunities to
maximise sustainable transport solutions” and fails to meet the NPPF requirements to provide for high quality
walking and cycling networks and give priority to pedestrian movements both within a development site and
with its neighbouring areas.
Diss Town Council believes that, in the absence of a requirement to provide for the footway described
above, Policy GNLP0102 is unsound because it does not enable the delivery of sustainable development in
accordance with the policies in the NPPF.