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Arnold, Katie

From: [email protected] Sent: 21 April 2015 00:08 To: [email protected]; Planning Subject: For the attention of Mr Nick Moys. Your ref. 3PL/2015/0384/F Attachments: +objection+letter+-+April+2015.doc

For the attention of Mr Nick Moys: Case Officer

Your ref. 3PL/2015/0384/F

Dear Sir,

Land to the rear of 'Fredena', Chapel Street, NR17 1UJ Rocklands Erection of 17 dwellings, drainage infrastructure, public open space and associated access

I have attended my objection letter.

Yours faithfully,

Richard A. Golke

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22/04/2015

Chapel Cottage Chapel Street Rocklands NR17 1UJ

20 April 2015

For the attention of Mr Nick Moys: Case Officer

Your ref. 3PL/2015/0384/F

Dear Sir,

Land to the rear of 'Fredena', Chapel Street, NR17 1UJ Rocklands Erection of 17 dwellings, drainage infrastructure, public open space and associated access

I am writing in response to your recent letter dated 07 April 2015 relating to the above- referenced planning application, to register my very strong objection to the proposed housing development on Chapel Street.

My objection is made on the basis of a number of apparent conflictions with existing planning policy recommendations – both local and national - and I will also highlight various anomalies, omissions, contradictions and misrepresentations relating to technical data that is presented in support of the planning application itself.

At the same time, I will bring to your attention specific matters of local concern relating to the proposed development that are either ignored or not given appropriate emphasis in the supporting submissions.

In presenting my objection, I will reference the following documents:

1) Breckland Council 'Application for Planning Permission' (Planning application ref. 3PL/2015/0384/F) in the name of Mr N. Paske / Bowbridge Land Limited – dated 30/03/2015 2) 'Planning Statement submitted on behalf of Bowbridge Land Limited' prepared by EJW Planning Ltd., , Norfolk – dated March 2015 3) 'Design and Access Statement, Chapel Street, Rocklands' prepared by RDC Development Consultants, Creaton, Northants. – dated March 2014 4) 'Phase I Habitat and Protected Species Survey for Proposed Residential Development on Arable Land off Chapel Street, Rocklands, Norfolk, NR17 1UJ' prepared by Eco-Check Consultancy Ltd., Oulton, Norfolk – dated March 2015 5) 'Land at Chapel Street, Rocklands: Foul and Surface Water Drainage Strategy' prepared by Create Consulting Engineers Ltd., Norwich, Norfolk – dated March 2015 6) 'Land at Chapel Street, Rocklands: Transport Statement' prepared by Create Consulting Engineers Ltd., Norwich, Norfolk – dated March 2015 7) 'Archaeological Desk-based Assessment: Land at Chapel Street, Rockland St. Peter, Norfolk' prepared by CgMs Consulting, Newark, Notts. – dated April 2014

Also, where they are quoted in the context of the above-listed reports, the 'National Planning Policy Framework' (March 2012) and the Breckland 'Core Strategy and Development Control Policies' (adopted December 2009). Other technical publications will be referenced in the text as appropriate to the specific issue under discussion; please note that all added emphasis is my own.

Firstly, I would like to deal with the data presented in the actual planning application itself. A cursory Internet search reveals that ‘Mr. Paske’ and ‘Bowbridge Land’ are synonymous with ‘Mintridge Consulting Ltd.’ – a Northamptonshire-based firm of Chartered Surveyors. ‘Mr. Norman Charles Paske’ is listed as a Director (Source: ‘Companycheck.co.uk’ - 14/04 2015): He is also listed (as from 25/03/2013) as a Director of Bowbridge Land Ltd. and is additionally described in the ‘Director Overview’ as holding ‘…48 appointments at 46 active companies, has resigned from 14 companies and held 23 appointments at 19 dissolved companies’.

On its company website, Mintridge Consulting describes itself as '…a firm of chartered surveyors offering specialist advice and services to developers, landowners and investors, specifically strategic development opportunities and ground rent transactions. We represent several of the UK's largest housebuilders and our investment clients have an active ground rent acquisition fund. If you are a landowner needing advice on development, a housebuilder wanting land, or an investor seeking opportunities in the planning and development sector, then we shall be pleased to speak to you'.

The reason I mention this is to underscore one of the primary concerns in the minds of the Rocklands village community (both in St. Peter and in All Saints) and one of the primary reasons why this application should be rejected: Despite all of the usual flowery allusions made in the supplementary documentation describing the supposed care and attention that has been expended in developing this scheme (‘…a high quality development in a sustainable location which will enhance the appearance and setting of the village’; ‘…a low-density development of traditional character and style with external materials reflecting the vernacular of Norfolk’; ‘…a development that is sympathetic to its location and the rural character of the area’) the bottom line, I would suggest, is that Mr. Paske and/or Bowbridge Land care little for the hopes, fears and aspirations of Rocklands, Breckland and – very probably – Norfolk people, except in the context of potential financial enrichment for themselves and their clients.

This planning application is being orchestrated by a very experienced, professional property developer and seeks to capitalise on the current, unspoiled charm of the Rocklands village community. At the same time, I would suggest, it is being advanced as a means to determine Breckland Council’s resolve (or otherwise) to uphold local and national planning policy guidelines. Village residents are very much aware that Rocklands is surrounded by open agricultural land, some areas of which have already been the object of previous planning speculation. If this application is approved, it sets a dangerous precedent that will likely open the floodgates for similar development schemes being launched in the future, potentially putting Breckland Council into the unenviable position where such applications are increasingly more difficult to reject (in this respect, I would draw your attention to the proposed road layout within the submitted development area: To me, this clearly suggests a future intent to additionally expand the development to the west and south in the general direction of the B1077 and St. Peter's church).

Under such circumstances, the local Parish Council becomes little more than an instrument of toothless compliance with no real say or effective power in the matter of planning issues affecting the local people it represents. As will be discussed later, this outlook directly contravenes core Ministerial statements made in the Foreword to the National Planning Policy Framework.

Beyond this initial – and, I would suggest, extremely important consideration – I would draw your attention to Section 9 of the submitted planning application: ‘Foul sewage’. In summary, the application indicates that foul sewage will be disposed of by means of a ‘package treatment plant’ that does not connect either to a ‘mains sewer’ or to ‘the existing drainage system’.

This conflicts directly with statements made in the previously referenced Drainage Strategy Report that make no mention whatsoever of onsite treatment; neither does the report provide any details in terms of an outline specification for an appropriate treatment plant. Under the heading 'Proposed Foul Water Drainage Strategy' the report confirms the need only for a pumping station (para. 4.4) 'Based on an assessment of the anticipated site drainage levels and the invert level of Manhole 2001 it is envisaged that a pumped connection will be required' – and this feature is detailed on the associated plan drawing included as part of the attachments to the report. Subsequently, para. 4.6 of the report states that 'Foul flows will then be pumped via the Site access road, along Chapel Street to the east and south and then further south along The Street to the connection point'.

As well – and in spite of assurances given by Anglian Water that '...there is capacity in the local network for foul flows from the development' - local residents in All Saints will attest to the fact that the present foul water system cannot reliably deal 24/7 with the output from existing properties that are already connected. A few years ago, this issue formed the basis of several objections to a previous planning application submitted relative to a proposed housing development adjacent to The Street. To quote from an email from one of the residents who lodged an objection: 'I have personally seen the foul water system fail on a number of occasions, causing sewerage to flow into residents' gardens and houses'. From memory, this reflects the situation back in 2007; as far as I am aware, the foul water system has not been modified or upgraded in any way during the interim period. Consequently – and quite rightly - there are obvious concerns on the part of All Saints residents at the prospect of a significant increase in the volume flow that an additional 17 properties will generate.

In Section 12 of the submitted planning application - 'Assessment of flood risk' – confirmation is provided (by means of checked boxes) that surface water will be disposed of by means of soakaways and that the proposal will not increase the flood risk elsewhere. I would suggest that, at the very least, this is a problematical assumption given the recorded sub-soil conditions across the proposed development site; the overall topography of the land (falling generally in the direction of All Saints to the south and with the site access falling towards Chapel Street to the north) and the documented history of flooding and of groundwater-related problems experienced by the village in general. The Drainage Strategy Report includes the results of a series of infiltration tests performed in four test pits excavated to a stated depth of 2.0 mbgl representing the full extent of the proposed development area. The report records the encountered soil types as follows (para. 3.10): 'Two trial pits on the western side of the site found sandy clays whilst clayey sand was found in the north east and sandy gravelly clay in the south east' and goes on to describe the results of the infiltration tests as follows: 'Infiltration testing was successful in the north east and south west quadrants of the site…' and 'Although successful testing to the scope of BRE 365 was completed in these trial pits the infiltration rates are marginal. Testing in the north west and south east quadrants of the site was not successful'.

In the context of surface water drainage, the report records the presence of a '…private, 150mm surface water sewer… passing along the southern side of Chapel Street with a manhole chamber located within the site access (para. 3.16) and subsequently suggests that this is considered to be a more viable option of discharging surface water runoff that will be investigated further. Adopting this option would apparently route the flow via the identified 150mm diameter pipe outfalling into an existing drainage ditch system, eventually leading the water to discharge into Rocklands Mere. Currently, this must be considered as being a hypothetical solution and in this respect, the planning application itself is predicated on the use of a soakaway system, as further described in the drainage strategy report.

Aspects of the data presented in the Drainage Strategy Report raise a number of potential concerns that I will try to summarise as briefly as possible below. Firstly, the report identifies clay as apparently underlying much of the proposed development site. Without appropriate particle size distribution and Atterberg Limit tests, it is not possible to properly classify the engineering properties of such soils: Accordingly, some of what follows is 'informed speculation' but nonetheless relevant to the current situation. It also assumes that the soil classification descriptions provided in the body of the report are accurate.

Clearly, the clay is a barrier to water infiltration and because of this, the report proposes to construct a communal-type soakaway (para. 4.7) '…to drain all adoptable roads along with plots 4-7 and 13-17 (i.e. buildings in the area which did not yield viable infiltration rates). This is to be placed below the public open space in the south west of the site where infiltration rates are suitable' (note the use of the word 'suitable' here versus the term 'marginal' used earlier in the report to describe the actual recorded infiltration rates). The report goes on to say that 'All roof areas from the remaining plots (1-3 and 8-12) will drain to individual soakaways in rear gardens'; and additionally, 'All private driveways will drain via permeable paving as per the existing scenario'.

From this description, it can be directly inferred that nine of the proposed 17 properties will be founded on soil where clay is indicated as being the major engineering component and yet this does not seem to justify any further comment or investigation in the report (even though, in para. 3.11, it is acknowledged that '…due to the presence of interbedded sands and clays there is potential for perched water to be present'). Soil is not a homogeneous material and groundwater follows a path of least resistance through the various strata. Hence water does not just migrate directly downwards; it can also move laterally - through less permeable layers that act as conduits – and become locally trapped in isolated pockets (the meaning of the term ‘perched’ – see above) with potentially dire consequences for any structures situated directly above.

Almost all clays are subject to volume change according to their moisture state (which can vary considerably with time); also a potential reduction in bearing capacity if the moisture content increases significantly. In extreme periods of hot weather or drought, clay soils dry out and tend to shrink. These occurrences can result in ground movement underneath a conventional shallow strip foundation (shrink/swell) that in turn can lead to structural problems (i.e. cracks) and/or permanent subsidence.

In terms of the geological characteristics of the proposed development site, the drainage strategy report (para. 3.7) refers to current British Geological Society (BGS) maps thus: 'BGS mapping for the site shows that bedrock geology is comprised of the Norwich Crag Formation (sands) overlying chalk whilst superficial deposits are formed of Diamicton (Boulder Clay)’. Boulder clay – or glacial till – covers a large part of Norfolk but its component materials (gravel / sand / silt / clay) vary greatly. The precise mix of these ingredients determines the soil engineering properties and its ability or otherwise to support load and suitability to act as a foundation.

To put this into some sort of context, I would refer you to a recent report 'Soil movement in the UK – Effects on Critical Infrastructure' published by the National Soil Resources Institute (2013). There is much useful information in the report but I will limit myself to quoting only those passages that I think are particularly relevant to the situation under consideration here:

From the 'Executive Summary' (page 6) – 'Almost all of the soil [ground movement] processes discussed are somewhat or wholly dependent upon the soil moisture regime, fundamentally soil strength is determined by its water content, water suction and their change upon loading generally being weaker on wetting';

Section 1 'Introduction' (page 8) – 'Swelling and shrinkage of clay soils arguably results in the highest losses of any know (sic) ground/soil condition within the UK (Culshaw and Harrison, 2010), during 2002 it was estimated that subsidence related ground movement resulted in costs of ₤300-500 million';

Section 1.1 'Ground movement and legality in the UK' (page 9) – 'The UK Government formulated the Planning Policy Guidance 14 (PPG 14), regarding the development on unstable land (Department for Transport, Local Government and the Regions, 2002), to identify the responsibility of the developer to consider land instability issues during the design and construction phase';

And - 'Building regulations also advise on control to prevent the impact of ground stability (Anon 2004), whereby 'the building shall be constructed so that ground movement caused by': 'Swelling, shrinkage or freezing of the subsoil'; 'Landslip or subsidence (other than subsidence arising from shrinkage), in so far as the risk can reasonably foreseen, (sic) will not impair the stability of any part of the building';

And – 'It is generally only subsidence, i.e. that caused by the 'downward movement of a site' that insurance policies will cover' (in other words, damage found to be caused by shrink/swell mechanisms is not necessarily covered);

Section 2.5 'Testing methods for shrink/swell soils' (page 25) – 'Glacial tills show extreme variability in their plasticity indices, as shown by Denness (1974), where within 1m2 of soil, liquid limits varied between 50 and >35% and plastic limits between 22 and >16%. Trenter (1999) states that caution should be taken in using plasticity indices of glacial tills to interpret strength and compressibility' (so not necessarily a straightforward process to determine the precise element of risk);

Section 2.7 'Shrink/swell impacts on critical infrastructure': Sub-section 2.7.1 'Structures' (page 27) – 'Much damage that results from shrink swell processes are apparent on light brittle structures such as 1-2 storey buildings (Gourley et al. 1993) with most research aimed at the domestic property market…';

And – 'Farewell et al. (2012) identify the following infrastructural buildings being at risk of shrink swell processes, including; 'pumping stations, sewage treatment works, recycling facilities, substations and telephone exchanges';

And – 'Hawkins (2013) also states differential movement caused by shrink-swell clays can exert large stresses where buried utilities enter buildings. This is likely to result in failure of the utility with cast iron pipes being most susceptible, however plastic pipes can eventually weaken and fail due to this process'.

As a side issue to this, but still relevant to the subject of groundwater, the report also highlights potential problems associated with landscaping (i.e. planting) and porous paving – both of which feature in the plans for the proposed development.

In terms of the former, the report states that 'Vegetation, in particular trees, can have a direct and indirect action on infrastructure assets. Indirectly they induce shrinking of clay soils as a result of their additional uptake of water, often regarded as being the most damaging effect (Forster and Culshaw, 2004), Driscoll and Skinner (2007) have suggested that 70% of domestic subsidence claims are as a result of vegetation induced clay shrinkage' (note the use of the word 'vegetation' in this context; not only trees).

Regarding the use of permeable pavement – which, seemingly, is being proposed for all vehicle parking areas: 'Permeable paving allows higher rates of groundwater recharge, a method that is being used in new developments, which could have the positive effect of not overloading drainage systems which could result in flash flooding, and preventing differential movement as a result of shrink-swell processes. However it does allow contamination resulting from the output of automobiles including hydrocarbons and polycyclic aromatic hydrocarbons (PAH's) to more readily enter the soil and therefore groundwaters'.

I would suggest that this discussion of factors potentially affecting surface water run-off, soil infiltration rates and the subsequent wider dispersal of groundwater raises several potential concerns about the suitability of the site for building development in terms of:

a) The actual engineering properties of the underlying soils – understood to consist predominantly of glacial till clays – upon which at least half of the proposed new building foundations will bear; b) What immediate and long-term effects (if any) the various soakaway discharges will have on these soils and the consequent effects on the proposed new buildings themselves in terms of shrink/swell and/or ground subsidence and/or perched water; c) A similar question in terms of the various soakaway and septic tank discharges arising from existing buildings bordering the proposed development site; d) How will groundwater flows towards All Saints be affected and is it likely that the existing proclivity for flooding in that part of the community will be exacerbated??? e) A similar question again in terms of groundwater flow towards existing properties on Chapel Street; f) What effects (if any) will trees and vegetation have on the engineering properties of the clay soils??? g) What measures will be introduced to mitigate/eliminate the potential pollution risk arising from the adoption of porous paving hard-standings??? h) Will the developer be compelled to undertake a more comprehensive site investigation in order to better quantify the potential risks that might be associated with the issues raised in this objection letter (and if not, why not)???

Occupants of traditional, clay lump cottages (and this includes myself), both in St. Peter and more especially in All Saints, will also be concerned about the possible increased prospect of rising damp – again, because of potential changes to existing groundwater seepage patterns and flow rates. Many such cottages do not have a modern damp-proof course and rely only on a foundation course of bound flints to resist/restrict capillary moisture flow.

Under Section 13 of the submitted planning application ‘Biodiversity and Geological Conversation’) the application answers a resounding ‘no’ (not altogether unsurprisingly) to the three questions dealing with ‘Protected and priority species’; ‘Designated sites, important habitats or other biodiversity features’ and ‘Features of geological conservation importance’. Fortunately for the Rocklands community, we have an eminent ornithologist living almost opposite the entrance to the proposed development site in Chapel Street. He records the fact that there are many more important bird, mammal, reptile and amphibian species habitually found in close proximity to the identified field area than are described in the Phase I Habitat and Protected Species Survey referenced above (and will, I am sure, proceed to list them all in his own objection letter).

And while we are on the subject of the environment, I have a few other pertinent observations to make. In setting aside this particular area of land, the local owner appears not to have given any consideration to the idea that - other than for housing development - it might possibly be employed to the benefit of the local community in some alternative (and certainly less controversial) way. One such – potentially – would be to develop it as a valuable habitat for many of those under-threat animal species mentioned above. In fact, this planning application seems to be the culmination of a deliberate, long-term scheme to build on the land regardless of what anyone else in the village might think or want. Contrast this landowner’s actions with those of another, apparently more enlightened gentleman in All Saints, who recently donated land to the community so that the local playing field facilities could be extended.

Under Section 14 of the submitted planning application, the ‘Existing use’ is given as being ‘Agricultural land’. Reference to Agricultural Land Classification maps for the east of confirms that this particular field is of Class 3 quality and – since it abuts directly onto a designated Class 2 area – is actually likely to be Class 3a; in other words, in agricultural terms it is considered to carry ‘best and most versatile‘ status. At both a local and national level, planning policy recommends that, wherever possible, development on agricultural land classified as 1, 2 or 3a should be discouraged (e.g. National Planning Policy Framework para. 112 ‘Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality’. In Breckland’s own ‘Core Strategy and Development Control Policies Submission Sustainability Appraisal Report’ this is acknowledged as a baseline problem, the ‘Possible Response in DPD’ being to ‘Ensure that development makes the most efficient use of stocks of land of all quality to reduce the quantity of greenfield land, especially if the land has a high agricultural (productive) value’.

Under Section 15 of the submitted planning application ‘Trees and hedges’, yet another resounding ‘no’ to the two questions ‘Are there trees or hedges on the proposed development site?’ and/or ‘Are there trees or hedges on land adjacent to the proposed development site that could influence the development or that might be important as part of the local landscape character?’.

Reference to the Phase I Habitat and Protected Species Survey suggests differently: ‘The marginal habitats are of greater ecological value and in particular the mature trees and hedgerows. The majority of the boundary trees are situated with (sic) gardens of neighbouring properties and so should be retained and suitably protected. There should be no direct lighting of these mature trees (or the hedgerows) as bats may be using these as foraging and commuting routes': Hence, another mis-statement on the part of the applicant.

Turning now more directly to the question of how and why this proposed development will transgress local and national planning policy recommendations, I propose to discuss these issues in terms of particular comparisons made in the above-referenced Planning Statement accompanying the submitted planning application. I would like to start by quoting, what I consider to be, a couple of key paragraphs directly from that document thus:

‘The National Planning Policy Framework (NPPF) which was published in March 2012 now forms a key part of the Government’s reforms of the Planning System and provides a single policy framework, replacing almost all of the Planning Policy Guidance Notes, Planning Policy Statements together with related circulars and letters, which were immediately superseded.’

And:

‘At the heart of the NPPF is a presumption in favour of ‘sustainable development’. This is seen as the ‘golden thread’ running through both plan making and decision-making. The overarching intention of the NPPF is to promote development and introduce a more positive approach to planning decision’.

Now this might be the developer’s take on the situation – and of course, it is very much in their interests to have you believe that – but I would refer you to the ‘Ministerial foreword’ that prefaces the NPPF and four fundamental pronouncements of intent made by the Minister for Planning that underscore the Government’s idea of what sustainable development is really all about (and I make no apologies for the added emphasis I place on these words):

‘In order to fulfil its purpose of helping achieve sustainable development, planning must not simply be about scrutiny. Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.

This should be a collective enterprise. Yet, in recent years, planning has tended to exclude, rather than to include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling the unaccountable regional apparatus and introducing neighbourhood planning addresses this.

In part, people have been put off from getting involved because planning policy itself has become so elaborate and forbidding – the preserve of specialists, rather than people in communities.

This National Planning Policy Framework changes that. By replacing over a thousand pages of national policy with around fifty, written simply and clearly, we are allowing people and communities back into planning’.

If there is any sort of ‘golden thread’ running through the NPPF, then it is embodied in those few sentences: Sustainable development – certainly; but in the context that local people and local communities must be respected and their thoughts and feelings given due consideration. As well, Breckland has itself expended much time, money and effort in determining where and how best to optimise local resources in the context of supporting sustainable rural communities – much more so, I would suggest, than a Northamptonshire-based property developer.

Once you accept the premise of the Minister’s statements, then what might be considered to be one of the developer's primary arguments (the Planning Statement actually refers to this as ‘The starting point for the consideration of this application…’) can be discounted. That is the repeated emphasis concerning Breckland’s need to identify a 5-year supply of housing plus a 20% buffer ‘…to provide a realistic prospect of achieving the planned supply' and harks back to the specific point about unwarranted development being driven by targets. I would suggest that this is no longer considered to be an inherently valid argument.

There are numerous other references in the Planning Statement to the many and varied benefits that this development seemingly will bring to Rocklands – amost all of which I would contest. Some particular ones that stand out:

On Page 2 under ‘Site and surroundings’ – ‘The village provides a range of services to meet the everyday needs of the local community, including a Post Office, village store (actually one and the same thing; now owned and operated by the Rocklands community since it was almost forced to close due to a lack of trade) Public House (recently reopened after having been forced to close because of a similar downturn in trade and also the subject of an intended community buyout; at this point in time, the pub has a questionable future that, in common with many others throughout the country, will not be solved simply by increasing the population of the village) community hall, Church (actually two – but not exactly packed to the rafters every weekend, again due to changing social habits so I would question the significance of mentioning them) sports fields and a primary school’ (currently oversubscribed so that any new children of primary school age would likely have to be accommodated at ).

On page 3 – ‘There are frequent bus services providing access to Watton, Norwich and Attleborough’. In that case, why does the accompanying Transport Statement say 'There are no scheduled bus services in the vicinity of the Site’ ??? The only public transport serving the village is a pre-bookable Flexibus service and this operates on weekdays between the hours of 09:00 and 14:30 for those – usually elderly residents with no other transport options – wishing to journey either to Attleborough or Watton. Various commercial bus operators have attempted to connect to Rocklands over the years; ultimately, there has never been enough sustainable business to make the effort worthwhile. And while we are on the subject of the Transport Statement, I would draw your attention to the apparent fact (para. 2.7) that ‘The development proposals accord with the NPPF by providing homes on an allocated development site, which in turn should contribute positively to the local economy within Caister-on-Sea town centre and at Ormesby’. Also (para. 2.9) that ‘The Site is located in a sustainable edge-of-town location, offering walking, cycling and public transport links for employment, retail and leisure trips’. So now Rocklands is a town (or perhaps that is just future wishful thinking on the part of the developer)???

On page 6 – ‘…and finally, the development contributes environmentally, by the removal of a pig rearing unit from a predominantly residential area’. In all of the other studies carried out relative to the submitted planning application, not one mention is made of this alleged pig rearing unit so where has it suddenly appeared from? My wife did actually ask one of our neighbours who is a long-standing, Chapel Street resident. He could not recall that there had ever been any pigs on this particular field; only – and maybe 20 years ago – some sheep. So that pretty much discounts the token environmental benefit!!!

And – ‘The delivery of 25 new homes and associated benefits including the provision of 10 affordable homes…’ - so where have these additional eight new houses suddenly come from? (I should record that, by the time we get to pages 15 and 16, the proposed number of dwellings is restored once more to 17 but, since the developer himself doesn’t seem entirely sure on this point, I did actually count the number of designated plots on the drawing).

And – ‘Careful consideration has been given to the design of the development, which will comprise a low-density development of a traditional character and style with external materials reflecting the vernacular of Norfolk. Consequently, the application proposals will achieve a high quality development appropriate to its setting’. Alternatively, you could say that this is an ugly, squat, nuclear, housing estate-type development in what is an essentially an attractive, linear village setting, and that it will introduce a disproportionate number of hideous, mock-rural, red brick, shoe boxes contrasting directly with the existing eclectic mix of traditional Norfolk cottages, houses and bungalows that currently make up the Chapel Street community. I suppose it all depends on your point of view doesn’t it???

And – ‘Furthermore, there are no adverse impacts for the proposed development that would demonstrably outweigh the benefits of the development’. If that’s the case, then we must be an extremely thick lot in Rocklands!!! Would you believe that, at the recent Parish Council meeting where this planning application was discussed in front of eighty residents, not one person in the room found a good thing to say about the development? And a show of hands at the end confirmed that fact – not one person!!! (and that included the local publican). Not even the landowner or the nominated local agent for the developer bothered to show up to try to convince us concerning all of these alleged ‘benefits’. Yes, it was discussed and accepted that some additional business might accrue to the local shop; but against this was concern expressed about additional pressure on the drainage and sewerage systems, flooding, traffic congestion, pedestrian safety – so the overwhelming consensus was that actually, as far as the local community is concerned (and please, just skip back a couple of pages to remind yourself of those very bold, big words written there) the adverse impacts actually outweigh the benefits – thank you very much!!!

On page 7, referencing Breckland Policy CP1 ‘Housing’ – Again, the arguments put forward by the developer in this respect are primarily target-based.

On page 8, referencing Breckland Policy SS1 ‘Spatial Strategy’ – Here the Planning Statement tries to make a case for considering Rocklands as being a ‘Local Service Village Centre’ with the intention of being able to better justify the proposed development. The fact of the matter is that, in the context of Policy SS1, Rocklands is not one of the 14 named villages included on that list, the stated criteria being based on the ‘…the amount of key facilities that these villages possessed. These key facilities were defined as a primary school, healthcare facility, local employment opportunities, available public transport to an appropriate standard and a convenience store for the supply of day-to-day goods’. Consequently, the reason that Rocklands is not classified as a Local Service Village Centre is because it does not tick enough of those particular boxes (my count is two out of five; the developer cites ‘post office, Public House, community hall’ in this context but these do not figure in Breckland’s own criteria). Thus, by default (and in the absence of any other definition) it falls under the classification of ‘rural settlement’ described as follows: ‘The District of Breckland contains a number of small rural villages that have few, or in some cases no, local services. These settlements are not capable of sustaining consequential growth as many are completely reliant on higher order settlements for services and facilities. The Sustainability Appraisal has identified that these settlements do not represent a sustainable option for significant expansion’.

By Breckland’s own definition, Rocklands does not ‘represent a sustainable option for significant expansion’, directly contradicting all of the arguments advanced by the developer in support of this being a sustainable scheme in a sustainable environment. Such an outlook is further endorsed in the Breckland Core Strategy document by the statements made in para. 2.36: ‘Examination of the baseline evidence has identified that the large majority of key services and facilities, employment opportunities and public transport facilities are centred on the market towns and larger villages of the District. When this evidence is considered against key issues for the District it is clear that if more sustainable patterns of living are to be promoted then the large majority of development in the District must be focused on the market towns and larger villages’.

Bottom of page 8 / top of page 9: At this point in the Planning Statement, there is a passing and suspiciously perfunctory reference to CP 14 ‘Sustainable Rural Communities’ (and, from the developer’s viewpoint, it is easy to understand why this is given short shrift). Specifically, under ‘Housing’ the policy states that ‘In villages not identified for a specific level of growth in the settlement hierarchy (i.e. the situation pertaining to Rocklands) residential development will only be permitted where: a. There are suitable sites available inside the limits of a defined settlement boundary; or b. It is an affordable housing scheme for local needs in accordance with the ‘exceptions site policy’; or c. It involves the appropriate re-use of a rural building; or d. It provides a site for gypsy and travellers or travelling showpeople; or e. It is a dwelling required in association with existing rural enterprises where it complies with the requirements of national guidance in relation to new dwelling houses in the countryside; or f. It is a replacement of an existing dwelling'.

Of those five options, only the one provided for under ‘option a’ could possibly apply in the case of this planning application i.e. inside the limits of a defined settlement boundary.

Subsequently, the policy document defines precisely what this means as follows: ‘Settlement boundaries will be defined for rural communities as shown on the Proposals Map. The settlement boundaries will be reviewed as part of the Site Specifics Policies and Proposals Development Plan Document. The basis of the review process will be the rationalisation of settlement boundaries to result in more logical and defensible boundaries by addressing the following: g. To focus new development to sustainable locations where there are key local services; and h. To protect the form and character of a settlement from inappropriate proposals including backland development; and i. To facilitate the inclusion of adjoining brownfield sites and small-scale sites (5 units); and j. To facilitate the removal of boundaries within the Stone Curlew buffer'.

First of all, I can confirm that the proposed development site is most definitely not within the defined settlement boundary for Rockland St. Peter (a fact that the developer is well aware of and freely acknowledges); furthermore, in terms of the official Government-defined term, this does actually constitute a ‘back-land’ area – that definition, in full, being ‘Development of ‘landlocked’ sites behind existing buildings, such as rear gardens and private open space, usually within predominantly residential areas. Such sites often have no street frontages’.

The Development Statement already considers this site to be situated in a 'predominantly residential' area in the context of removing the mythical pig rearing unit (cited earlier) and the previously-referenced Design and Access Statement refers to the location as an ‘infill’ site; more evidence - in terms of current planning policy – as to why this application should be rejected.

On Page 9 also there is a reference made to Policy DC2 ‘New Housing’ tries to advance forward an extremely specious argument as to why – again – this development should be allowed to proceed on area of land that is situated outside of the defined Rockland St. Peter settlement boundary and that somehow – because this should be considered as being a ‘windfall’ site – suddenly all of Breckland’s relevant policy statements and conditions no longer apply. Policy DC2 clearly, unequivocally and unambiguously states that ‘Within the settlement boundaries as defined on the proposals map, new housing development will be permitted’. Not unsurprisingly in this instance, the developer is again trying to verbally manipulate the tenets of Breckland planning policy in order to justify approval of the submitted planning application.

Beyond page 9, I will not consider the Planning Statement any further since it deals more with building design specifics and there is more repetition of previously identified arguments purporting to support the developer’s point of view. I feel that I have already demonstrated sufficient discrepancies with the submitted planning application and the supporting documentation to invalidate the Declaration that ‘…any facts stated are true and accurate’: Also sufficient breaches of both local and national planning policy as it should be applied to Rockland St. Peter.

Briefly, since I have already expended too much time and effort on this objection letter, I should like to touch on some of the other specifically local concerns that the community has relative to this proposed development as follows:

a) Increased vehicular traffic volume arising from the 17 new houses in terms of noise; light pollution; increased risk to pedestrians both in St. Peter and All Saints since there is no continuous pedestrian pavement; increased congestion at peak times outside the village shop and school; increased danger of traffic accidents from vehicles attempting either to access or cross the B1077 (already a well-documented issue in the village).

b) Surface-water run-off and soakaway discharge; changes to existing groundwater migration patterns - all of which could potentially increase the risk of flooding (already a recurring problem in All Saints) and exacerbate existing damp problems in particularly vulnerable clay lump cottages; increased pressure on the existing foul water system (where, again, there are well-documented issues).

c) The existing Broadband connection options are extremely poor with no prospect whatsoever of any immediate improvement; there are ongoing problems with mains water pressure in the summer and periodic power outages all year round but more especially in windy weather when overhead power lines are affected.

I know that my wife will be writing separately and that her objection letter will deal more with personal issues since our house – Chapel Cottage – sits directly opposite the proposed site entrance. It goes without saying that I wholeheartedly endorse any and all objection issues that she might raise in her letter to you; similarly any and all of those raised by my fellow Rocklands residents.

For your additional, and more general information, I first moved to Rockland All Saints in 1986 and lived in a cottage fronting right onto The Street (so I am acutely aware of the problems affecting that part of village also); after marrying in Hong Kong in 1996, my wife relocated to the village and would not, I think, now live anywhere else. We transferred to Chapel Cottage a few years ago but still retain our old house in The Street which is currently rented out. We are very active in the community, owning shares in the village shop and pledging funds in support of the recent attempt to acquire the White Hart Public House. Both of our children attended the local primary school and are involved with the local football and cricket teams.

We all feel that Rocklands is a village to be proud of - in part because the Parish Council and a core team of concerned residents have consistently opposed thoughtless and insensitive development. At the same time, rehabilitation or reconstruction of existing buildings and carefully considered construction of individual new homes has been supported. Because of this community involvement, our village has managed to maintain its traditional 'rural Breckland' feel - still with its own Post Office, school and pub and with a good, friendly mix of people from all sorts of backgrounds who genuinely enjoy the quality of life here.

The proposal to undertake this disproportionate and insensitive development is, in my opinion, motivated purely by financial considerations and not with the best interests of the village in mind. It very clearly and very obviosly contradicts many local and national planning policy recommendations and requirements and creates an extremely dangerous precedent that could subsequently see a piecemeal transformation of our village by numerous other small, estate- type developments of this kind. This sort of thoughtlessness has irreparably damaged so many other Norfolk villages; I urge you not to let it happen to Rocklands.

There is a distinct groundswell of opinion against this particular scheme as evidenced by the opinions expressed by over 80 local members of the community at the recent Parish Council Meeting mentioned above. A clear message was sent to all of the councillors present that Rocklands does not want or need a development of this type.

For the many and varied reasons expounded in this objection letter, I would urge you to unceremoniously dismiss the submitted planning application: In my opinion, it is poorly conceived, badly researched, tardily presented and clearly contravenes current planning policy as it is meant to be applied to a rural community like ours.

Thank you for your consideration in this matter.

Yours faithfully,

Richard A. Golke