Farmland Road Planning Application
2016/2430/O: Mrs K Kozersky – Land north of Farmland Road – OUTLINE application with access and landscaping (all other matters reserved) for 83 dwellings (including 27 affordable dwellings) with areas of public open space sustainable drainage systems & associated infrastructure.
COSTESSEY TC RECOMMENDS REFUSAL ON THE FOLLOWING GROUNDS: pdf version clickhere ctc-refusal-2016-2430-08-11-16
THE PROPOSAL WOULD CAUSE DEMONSTRABLE HARM TO THE LOCAL AREA. THE HARM SIGNIFICANTLY OUTWEIGHS THE BENEFITS, THEREFORE THE PROPOSAL DOES NOT FALL WITHIN THE NPPF’S DEFINITION OF “SUSTAINABLE DEVELOPMENT”.
SUMMARY – SEE FULLER EXPLANATION OF MATERIAL REASONS BELOW:
- Outside the newly agreed settlement development boundary:
- Site History:
- 5 Year Land Supply:
- Unsuitable land:
- Impact on Landscape:
- River Valley:
- Wildlife & Sensitive landscape
- Preservation of the strategic gap between Old & New Costessey:
- Surface Water Flooding:
- Drainage & SuDS:
- Existing water pipeline and sewage pipes:
- Water Pollution:
- Air Pollution:
- Geology of surrounding area:
- Infrastructure: Roads:
- Access, Traffic & Parking:
- Misleading Traffic predictions:
- Infrastructure: Schools:
- Infrastructure: Medical facilities:
- Deficiencies in the plans:
- Management & Safety of Open Spaces:
- Outside the newly agreed settlement development boundary: The Joint Core Strategy (JCS) has been recently adopted and therefore carries more weight than previously. The settlement boundaries have been designed to limit development in unsuitable locations, while allowing for the amount of development required based on population & dwelling number projections. Costessey has already welcomed thousands of new dwellings and opportunistic development should not be allowed outside the new settlement boundary.
- Site History: The site had previously been considered for development under the Site Specifics document and rejected as unsuitable for development
- 5 Year Land Supply: Although members may believe that the 5 year land supply outweighs all other considerations, this is not the case – as proved by the Planning Inspector’s decision at the appeal against development at the Paddocks in Hethersett. (2014/2429). Many of the Inspector’s comments regarding the value of the open space (10), the contribution of the site to the landscape character and sense of space in the locality (11), the urbanising effect on the remaining undeveloped green space (12), and how the proposed scheme would significantly reduce the open character and appearance of the site and fail to respect the open contribution which site makes to the form and character of the settlement (17), apply equally to Farmhouse Road. The Inspector’s conclusion (33) at Hethersett was that the proposal would materially harm the character and appearance of the site and the surrounding area and that the level of harm would run contrary to the environmental dimension of sustainable development, and therefore “would not be a form of sustainable development for which there was a presumption in favour as set out by Paragraphs 14 & 49 of the NPPF”. The Inspector’s comments regarding the 5 year land supply were that the benefits of the scheme did not outweigh the significant harm that would arise from the proposal and dismissed the appeal as per NPPF Para 14: Decision Making – bullet point 2. The same principles apply in the case of Farmland Road.
- Precedent: The site is one of a series of agricultural fields in different ownership running along the river valley towards Longwater Lane. This opportunistic application has already prompted other landowners to offer their land for future development in the River valley and if it is passed it will allow other landowners to develop and destroy the sensitive landscape around the River Tud. Another landowner has recently had a replacement dwelling turned down on landscape grounds (2016/1350) that could have been taken from this list of objections. The Planning Authority should be consistent.
- Unsuitable land: The land is the natural lowest point in Costessey and has always been known locally as “The Marshes”; it is naturally boggy (knee deep in mud) and acts as the flood plain for the River Tud. It is subject to both surface water flooding and large differences in river depth and river bank height depending on the amount of rainfall. Some of the existing Farmland Road dwellings are moving down the hill and new buildings would be liable to subsidence too. This site is not suitable for building.
- Impact on Landscape: the new application does not address the reason for refusal; it is a re-hash of the previous application with a few dwellings on the Eastern edge reduced to 1.5 storeys, which will be almost as high as the previous proposals. It does nothing to alter the proposed urbanisation of the open landscape of the green river valley, which is the strategic gap between Old and New Costessey and the proposal would ruin the landscape character forever.
- River Valley: The local plan has designated the river valley, so that only part of the site falls within the designation. The local plan river valley classification does not follow the contours of the landscape, Whereas current development is sited (just above the 20m contour); Costessey TC considers the whole of the site to lie within the natural river valley and should be dealt with accordingly (hence the request for a site visit). The aspects of the rural river valley will be affected on both sides of the R Tud. Policy DM 4.5 Landscape Character and River Valleys states “All development should respect, conserve and where possible, enhance the landscape character of its immediate and wider environment. Development proposals that would cause significant adverse impact on the distinctive landscape characteristics of an area will be refused. Particular regard will be had to protecting the distinctive characteristics, special qualities and geographical extents of the identified Rural River Valleys and Valley Urban Fringe landscape character types”.
- Wildlife & Sensitive landscape: The site is adjacent to a County Wildlife site. Residents have recorded a variety of wildlife on the site. Development would have an adverse impact on the Environment – see related points regarding pollution and protected species
- Preservation of the strategic gap between Old & New Costessey: The site lies within the strategic gap of open space between the two differing types of settlement in Old & New Costessey. The site should not be built on and the strategic gap should be preserved to comply with Joint Core Strategy Objective 9 which seeks to protect rural character and environment, and with Policy 2 which specifically requires the landscape setting of settlements and the urban/rural transition be carefully managed. This is a semi-rural area with adjoining landowners keeping livestock. The application is contrary to Policy DM 4.7 Strategic Gaps between settlements within the Norwich Policy Area and the landscape. See also SNC’s strategic Gaps Review: http://www.south-norfolk.gov.uk/planning/media/11115104R_Strategic_Gaps_Review_FINAL_SK_28-09-2012.pdf sections 6.1.6, 6.1.7 and 6.2.1, Key Characteristics of the A3: Tud River Valley LCA included in the section Eastern Costessey Strategic Gap section 6 page 24-25
- Surface Water Flooding: The site is at the bottom of a steep hill where the river valley floor opens out slightly. Water currently flows down the road in rainstorms as the drains cannot cope. There is a risk of adjacent landowners being flooded. Surplus surface water is also likely to discharge towards the R Tud which is an Ark habitat for protected local species and water quality could be compromised if untreated water is allowed to drain into the river. The site is liable to flooding and building would exacerbate this contrary to DM Policy 4.2 Sustainable drainage and water management (3). a) Should include a sewerage capacity assessment and must have a neutral or positive impact on reducing surface water flooding and should include drainage features that will slow the movement of water through the drainage system;& b) Must not cause any deterioration in water quality and measures to treat surface water runoff must be included within the design of the drainage system;
- Drainage & SuDS: There appears to be difference of opinion as to whether two or three levels of SuDS treatment are required (Planning Officers: 3 tier, developers 1 or 2 tiers only). This needs to be clarified urgently to avoid the same scenario as at Townhouse Road where SuDS were promised, but not delivered and water will be piped directly into the River Tud. Evidence should be provided by the applicant that the underlying geology is capable of infiltration by SUDS. This was initially claimed by the developers at Townhouse Road and subsequently proved to be not feasible. The geology of this site is likely to be similar to that on the opposite side of the valley. Evidence MUST be produced that SuDS are a viable option for these ground conditions. The route from Farmland Road to the R Tud appears on the pluvial flooding plans as a high risk area. How will SuDS work in an area which regularly floods anyway? It appears likely that the ditch has been provided as water pipes would be too low to feed into the existing piped systems. Swales and lagoons are referred to, but not necessarily shown on the plans and it is likely that the ditch will overflow into the River Tud, affecting water quality. Council are concerned that the high costs of providing a SuDS scheme will lead to a review of viability and the SuDS train being dropped to the detriment of water quality in the R Tud.
- Existing water pipeline and sewage pipes: There is an existing Anglian Water pipeline which runs along the curve of the track between the proposed dwellings and wetland area, which is the back-up water supply for Norwich. The sewage pipe runs through the development and has been liable to overflow causing pollution to the fields and preventing crops being grown for three years.
- Water Pollution: Policy DM 3.14 Pollution, health and safety a) states that “All development should minimise and where possible reduce the adverse impact of all forms of emissions and other forms of pollution, and ensure that there is no deterioration in water quality or water courses”. Given the proximity of the River Tud and the slope of the land in the river valley Costessey TC is concerned that the sensitive areas on the river valley and the water quality in the R Tud which is an “ark” site for white clawed crayfish and is home to other protected native species.
- Air Pollution: Air quality will suffer, especially around the school,
- Geology of surrounding area: Costessey has vast areas of moving sand and gravel and the roads do not have firm foundations. Grove Avenue subsides and is repeatedly repaired to no avail because of the fluid sub-strata in the area. Roads could not cope with the construction traffic nor the extra traffic generated by the development. A late resident of Farmland Road had his site surveyed annually as it was moving down the hill several centimetres per year. Retaining walls are slipping down the hill. Three Mile Lane (school location) has sunk under the weight of buses and there are frequent reports of gas mains and water main leaks.
- Infrastructure: Roads: The roads in the surrounding area of New Costessey were originally gravel tracks which were simply tarred and chipped over, without any substructure. They cannot withstand heavy vehicles. The extremely steep gradient of Farmland Road is not obvious from the plans, but it causes difficulties in bad weather when residents leave their vehicles at the top of the hill. An extra 83 dwellings could result in a further 160 vehicles being parked on a busy through route in bad weather, causing a danger to residents and pedestrians. The junction with Grove Avenue at the top of the hill will become even more dangerous contrary to Policy DM 3.11 Road Safety and the free flow of traffic.
- Access, Traffic & Parking: Better access would be required to cater for the additional vehicles encouraged to use and park for the amenity land. While the road is wide enough, it is extremely steep and accidents are likely to occur with vehicles emerging onto neighbouring roads from the steep hill in wintry conditions. School traffic is already bad and would be exacerbated by new residents trying to access the Dereham Road and wider road network at peak times, It appears the developers wish to make this a “destination” amenity. In modern developments there is little in the way of parking for residents and their visitors, let alone extra parking for incomers who wish to access the amenity land. IF PASSED, this application will attract many more people to the development, affecting traffic flows and parking, and blocking access for residents’, refuse & emergency vehicles.
- Misleading Traffic predictions: It is unrealistic to presume that 83 new dwellings will only lead to 27 extra journeys in peak traffic times. Generally, these days, households have two cars and two adults travel to work by car as workplaces are not necessarily in the city centre. The traffic survey also reports that two journeys will be made from the site by train. As there is no nearby station this appears fanciful. (See also the comprehensive comments regarding the quality of the report from an engineer, Mr Dunleavy).
- Infrastructure: Schools: The local schools infrastructure has great pressure on it, the Beaumont Road Infant School has relocate to the Junior School site at Three Mile Lane and is full. See NCC Education Dept’s comments that speculative housing outside local plan allocations creates problems in areas earmarked for expansion as ad hoc planning applications outside the local plans envelope put too much strain on existing schools. In terms of future-planning for educational places it makes planning places for children very difficult.
- Infrastructure: Medical facilities: The Roundwell Medical practice is already struggling to recruit the doctors and support staff it needs; residents often wait three weeks to see their GP. Beechcroft surgery cannot sustain ownership, or retain staff. Although CIL payments are not often used for extra healthcare provision this should be considered as imperative.
- Crime: Costessey is a low crime area, but crime is likely to increase as more densely populated developments are built, thus destroying social cohesion and possibly increasing mental health issues. (See report)
- Deficiencies in the plans: why has land in the marshes been shown as blue line when it is clearly part of the overall red line development?
- Management & Safety of Open Spaces: There is no indication as to how new wetlands would be managed and there is a question over safety, especially with new banks and ditches. The proposed changes to river banks, creation of wet reed beds and ditches plus the installation of decking to allow human access will alter the ecology and habitats for ever. IF PASSED, who would manage these areas? Would a Management Plan be conditioned? Would there be a commuted sum attached? At the newly created Taverham Mill Visitors’ Centre the board walks are flooded in wet weather and are closed by staff on safety grounds; who would monitor safety at the development? How would the management arrangements be paid for? Would the arrangements be sustainable in the long term future? A Management Plan MUST be provided if the application is passed and subsequently enforced.
- Viability: The more facilities / amenities the developers offer to make the scheme attractive, the more costs they will incur in actually providing them. While a viability study has been undertaken for affordable housing, there does not appear to be anything similar for SuDS or additional amenities provided. It is possible that the developers will build the houses and not be able to provide the amenity land as the costs will be too great to make the development viable. Will the Planning Authority require the developers to provide a viability assessment, especially on the costs of SuDS and all the amenities offered?
- Phasing: IF PASSED, there is no information as to when the footpaths would be installed. Access to create the wetland area might be cut off if the houses are built before the footpaths / wetland. What trigger point would be required to ensure the wet lands had to be completed?
- Sustainability: The site is not sustainable with regard to the environment and the application is contrary to the NPPF’s sustainability criteria.
This development would cause demonstrable harm to the environment, the local habitats, water quality, the river valley, and the landscape character.
THE LEVEL OF HARM WOULD BE COMPLETELY CONTRARY TO THE ENVIRONMENTAL DIMENSION OF SUSTAINABLE DEVELOPMENT, and therefore WOULD NOT BE “A FORM OF SUSTAINABLE DEVELOPMENT as per the NPPF, THEREFORE THERE CANNOT BE A PRESUMPTION IN FAVOUR OF DEVELOPMENT” ON THIS SITE
Costessey TC respectfully requests, indeed urges, South Norfolk Development Management Committee members and planning officers to make a site visit BEFORE the DCM Committee Meeting, given the specific topography of the landscape & access to the site, plus the sensitive nature of the river valley where the site is located. The access is incredibly steep, giving the lie to the mantra that “Norfolk is flat” (Costessey has 53 grit bins), and the site itself is flood plain and very boggy, with frequent surface water flooding over this high risk flood site.
If possible this visit should also include Valley View Crescent, West Road, West Close, Townhouse Road by Myrtle Avenue, Nursery Lane and Longwater Lane by the bridge over the River Tud as viewing points, as the site is visible from all these locations and the extent of the river valley and the level of potential harm will need to be assessed.