Breckland Local Plan Consultation response – North Elmham Parish Council, 8th July 2024
This response is being submitted by email as the online option is impractical to use for a group.
We will use the headings and questions as used in the online version, despite the questions being extremely restrictive. Therefore, our responses will expand on the questions asked, as this exercise purports to want views on the whole draft Local Plan.
Preferred Options Report survey
1a) Do you agree with the vision for Breckland
Answer: Yes
1b) Explanation
The draft strategic vision begins by stating that: ‘Breckland’s settlements and its wider rural area will have developed in a sustainable manner appropriate for the rural nature of the District”. We agree with this important opening statement. Unfortunately, we feel that much of the draft Plan does not fulfil this vision, through encouraging over-development which does not reflect sustainable growth.
2a) Do you agree with the general development principles in Chapter 4?
Answer: No
2b) Explanation
Text at 4.14 in the draft Plan talks of seeking to prioritise potential brownfield allocations. However, the one brownfield site which was put forward in the call for sites for North Elmham (Station Yard) has not been included as a preferred site in the draft Plan. Instead, a greenfield site (other than for a small part where demolition of an existing property would be needed for access) is preferred instead (NEL 02 for 30 houses south of Eastgate Street.) Therefore, it is acceptable to have GEN 01 which at point f states ‘make the most effective and efficient use of available land, prioritising development of brownfield land’, but such a statement is worthless if it is not carried through in the site allocations.
We strongly disagree with the text at 4.29 attempting to justify a criteria-based approach instead of settlement boundaries. Although it is claimed that this ‘has the potential to protect the character of settlements and the countryside’ it is difficult to see how this would be more effective than the tried and tested policy of having settlement boundaries. Instead, this appears to be a way to enable more development through criteria which would allow developers to exploit. We are particularly concerned that this policy has been included in the draft Plan despite being rejected in two previous consultations. In the first consultation in 2023, 53% of those responding to the question about settlement boundaries said they wanted them to remain, with 21% wanting them to be removed. In the consultation in early 2024, question 2 asked whether Breckland should ‘continue with a settlement boundary approach or develop a criteria-based policy’, with 69% of the respondents to that question saying they that settlement boundaries should be continued, with 26% in favour of developing a criteria-based policy. At two consultation events for Parish and Town councillors attended by North Elmham Parish Council, there was overwhelming if not unanimous support for the retention of settlement boundaries, along with disbelief at the attempted justification for abandoning settlement boundaries for a criteria-based approach. Given this clear preference it makes one wonder what is the purpose of consultations if a criteria-based policy is to be included. In addition, now that there is no specific question regarding this issue in the current consultation, it cannot be expected that many respondents will comment on it. This potential lack of comments should not be taken as justification for the criteria-based approach, but instead the earlier consultation responses should be re-visited and settlement boundaries reinstated in the next version of the Plan.
The text at 4.29 claims that ‘a criteria-based approach has been implemented in Local Plans across the country.’ In earlier documentation two Local Plans were cited: Hambleton, North Yorkshire; Central Lincolnshire. We wonder how widespread such policies are. These two examples of Local Plans were adopted in February 2022, and in April 2023 respectively. It is far too early for the effectiveness of policies within these plans to be judged or analysed. A criteria-based policy is unlikely to protect the character of settlements and the countryside more effectively than the existing policy of having settlement boundaries.
Housing
3) Please share your views on the proposed strategy for housing and the issues that need to be considered for proposed sites to achieve sustainable growth.
We are dismayed that this one question covers 25 separate housing policies. We would expect different questions relating to each draft policy if this is to be a meaningful consultation, where respondents are genuinely asked for their views across the wide range of issues to do with this important topic. In particular it is difficult to understand why there is no specific question regarding the abandonment of settlement boundaries and the inclusion of a criteria-based approach, when the latter has been dismissed in two previous consultations.
We are disappointed that under the heading in the text of ‘Prioritising Brownfield Land’, the only reference is to the Abbey Estate, with nothing about the prioritisation of other (smaller) brownfield sites across the District.
Policy SDP 03: Robertson Barracks, Swanton Morley and Hoe/Worthing. The key to this being acceptable is included in point a) of the draft policy, where access and transportation is dealt with. If the site is to be developed for housing, it is essential that the connectivity and permeability within and between the site and beyond, including north-south links with Swanton Morley, Dereham and the A47 and east to Norwich are delivered before the occupation of any housing. If this is not carried out development should not be permitted.
HOU 04: Preferred housing allocations. We disagree with the inclusion of NEL 2 (205) Land South of Eastgate. Instead, we want the brownfield site at Station Yard to be included. We will provide further details of this below, suffice to say that it is regrettable that there has been no opportunity in this or previous consultations to comment on the desirability or otherwise of any individual sites put forward under the call for sites process, other than those which have now been deemed to be ‘preferred.’
HOU 06: Windfall Housing Development. As outlined above, North Elmham Parish Council is strongly opposed to this policy, and instead wishes to see the continuation of settlement boundaries. This is for the following reasons.
- Any change to a criteria-based approach is likely to lead to increased development in the countryside as settlements expand beyond their current boundaries. Moreover, the draft Local Plan has loopholes in the criteria which would then be exploited by developers to allow development, some of which would be unsuitable and unwelcome, particularly given the system of appeal for applicants of planning applications which are initially refused permission. The relevant policies in the draft Local Plan (particularly draft policy HOU 06: Windfall Housing Development), as well as those in the Hambleton and Central Lincolnshire Local Plans are, in our opinion, too subjective and open to interpretation, thus providing the potential for loopholes as outlined. They may well result in having unintended consequences.
- By abolishing settlement boundaries, it is likely that sites for much-needed affordable housing schemes in rural exception sites are less likely to come forward than at present. This is because once land on the edges of settlements has the potential for other development, land values will increase, and landowners will understandably keep these sites for more profitable market housing. The opinion has been given that this is unlikely to happen, and that there’s no evidence of this occurring from other local plans with similar policies. However, given the short time since such polices were adopted in other local plans such as Hambleton and Central Lincolnshire, this is hardly surprising. Given the desperate need for affordable housing, any policy which could jeopardise delivery of affordables should be resisted.
- Settlements are able to expand with the current system of allocated sites and rural exception sites, which usually leads to an extension of the settlement boundary. Windfall development may be restricted, but as this is unplanned growth, it is better to keep it to a clearly defined area i.e. within a known settlement boundary.
- The most certain way to protect the character of settlements and the countryside is to retain the tried and tested settlement boundary approach.
- A more important policy development for the Breckland Plan, which would be effective in delivering more much-needed rural affordable housing would be to designate all rural parishes across Breckland as ‘rural’ for the purposes of Section 157 of the Housing Act 1985. This would then enable the Local Plan to lower the threshold for housing developments whereby affordable housing has to be included. This is currently set at 10 units or higher (or 0.5 hectares or greater), whereas it could be at 5 units or lower as laid out in paragraph 65 of the NPPF. A designation as ‘rural’ would also help to prevent the selling off of former council homes bought under the Right to Buy scheme, to anyone other than those who have worked/lived in Breckland for at least three years.
The environment, climate change and managing resources.
6a) Do you agree with the approach to the environment, climate change and managing resources in chapter 8? Yes
6b) Explanation.
We support the inclusion of the following new Local Green Space designations:
039 / 040: Cathedral Meadows, Church Lane, North Elmham. The Cathedral Meadows. The Cathedral Meadows are a perfect place to enjoy the countryside. They consist of hay and wildflower meadows and pasture for sheep grazing on the north side of Church Lane and between the English Heritage chapel ruins to the west and the disused railway line to the east. They can be accessed from Church Lane, or through the chapel ruins or from the disused railway line, and offer lovely views across the River Wensum valley. The meadows were purchased by North Elmham Parish Council in 1995 with the help of a grant from Breckland Council and a long-term loan. Former hedgerows were reinstated, and re-seeding took place with funding from the Wensum Valley Project. The newly created fields are run under the Natural England Higher Level Stewardship Scheme, and through an agreement with English Heritage the meadows are run together with the Chapel ruins as a single countryside access scheme.
The meadows provide a great habitat for wildlife as well as for the enjoyment of residents and visitors. The wildflower meadow (the small field on the left at the bottom of the Chapel Lane track just before the disused railway is crossed by a bridge) is one of the best locations for seeing the rich variety of flora in the meadows.
The beauty of the Meadows is clear to any visitor, from the close views of varied individual plants and insects, to the thriving hedgerows and beyond these to the wider vistas across the Wensum valley and Bintree Woods to the east and the historic core of the village of North Elmham to the west.
The restoration of the Meadows in the 1990s deliberately replanted hedgerows on the lines of former boundaries as shown on historic maps of the village. This gives the application area historic authenticity in terms of its boundaries and land-use, which compliments the Chapel (or Cathedral) ruins, St. Mary’s parish church and the conservation area of the village. Part of the scheduled ancient monument lies within the north-western part of the Meadows. The Meadows provide an appropriate setting for these heritage assets, and any protection of this setting through designation as a Local Green Space should be welcomed.
The Meadows provide an exceptional and unusual recreational space which is enjoyed by residents and visitors alike. The closeness of the Meadows to the heart of the village ensures they are well used, while their relatively large area gives the feeling of space, openness and rurality. They are used on a daily basis by dog-walkers, walkers and those seeking tranquillity. Older children find spaces where they can play and socialise safely. During the recent lockdowns and periods of social distancing and isolation the Meadows have been absolutely vital to bolstering mental and physical health.
There can be few villages which are fortunate enough to have a number of fields under open access arrangements, with a range of habitats including wildflower meadows, sheep grazing and open pasture, lined by wide hedgerows with an abundance of wildlife and other biodiversity. When combined with the spectacular long-views across the Wensum valley to Bintree Woods they provide space and tranquillity. This can be savoured further by sitting on one of the well-placed benches.
The rich and varied biodiversity is recorded by residents, with recent sightings and news appearing on a well-used Twitter account, Cathedral Meadows, North Elmham. These are also reported every month in the free ‘Elmham News’, as well as on the webpage: www.elmham.org.uk/cathedral-
Millennium and Jubilee Woods. The land on which the Millennium Wood now stands was purchased by the Parish Council in 1915 and was used as allotments until about 1978. By then all the allotments had closed in favour of a more convenient location near the King’s Head public house which had piped running water. The field was then just let for sheep grazing until the Parish Council planted this new wood in January 2000 to celebrate the Millennium. Contractors planted all the trees except for about 170 in the north east corner which were planted by the children of North Elmham Primary School and by the local Scouts and Guides. A plan showing which child planted each tree has been deposited by the Parish Council in the Norfolk Record Office.
In 2012, the year of H.M. The Queen’s Golden Jubilee, the Parish Council organised a community tree planting day on additional land which had been part of a County Council smallholding. This was to extend the wood to join it up with Church Lane, a public right of way. Included in this new area was an oak purchased from The Queen’s Sandringham Estate as a part of our Jubilee celebrations. This second planting brought the total area of community woodland up to about 8 acres (3.25 hectares).
The two joined areas provide established and evolving woodland, with paths and a central clearing.
Beauty is provided by the range of species and the layout and setting of the site.
The Millennium and Jubilee Woods serve to provide a rich and visually appealing backdrop to the setting of St. Mary’s parish church and the east side of the North Elmham conservation area.
The Woods are well visited by residents. The peacefulness and tranquillity provided by woodland is well-known, and to have these assets so close to the residential area of the village makes them all the more attractive and accessible. They are to become even better-connected to the village through the creation of a new footpath and access point from the Brookside Farm development, which is currently under construction. During the recent lockdowns and periods of social distancing and isolation these woods have been absolutely vital to bolstering mental and physical health.
The tranquillity can be enjoyed further through the siting of various benches on the site.
Wildlife is rich and varied, as would be expected in a sizeable area of well-established woodland.
041: Prince William Wood, Orchard Close, North Elmham.
Prince William Wood. A relatively small area of open woodland screening Orchard Close from Back Lane, which provides a recreation space particularly for residents of this part of the village.
Prince William Wood is a small area of open woodland, owned and maintained by North Elmham Parish Council. As such, it provides a space of dappled shade and beauty.
The Wood is used primarily by residents of Orchard Close, Station Road and Eastgate Street, as it is more conveniently situated for them than the other open access green spaces in the village. The recent provision of secure fencing along the Back Lane boundary has made the Wood a safer space for children.
It is a small, valued haven of tranquillity between the housing of Orchard Close and the busy Back Lane, which is subject to the national speed limit. The woodland helps to muffle noise from this road, and provides a safe space for local residents including children. During the recent lockdowns and periods of social distancing and isolation Prince William Wood has been absolutely vital to bolstering mental and physical health.
As the woodland becomes better established so its range of wildlife expands.
Site Specific Policies – Housing
Proposal NEL 1: Back Lane
Ideally, North Elmham Parish Council would prefer to see just the site at Station Yard (ref. LPR/CS4/DEV/215 in the call for sites) allocated for North Elmham in the Local Plan. However, if the housing requirement for North Elmham remains as in the draft Plan, this site should be included along with the Station Yard site, but not NEL 2. It would also make sense to take the 15 affordable house scheme the Parish Council is pursuing with Broadland Homes and Breckland District Council when considering how many new houses should be allocated to North Elmham in the Local Plan. We are of the firm opinion that the type of homes which is really needed is affordables, as evidenced by the recent local housing needs survey for North Elmham. Given this proposal for a rural exception site in the village, with its provision of needed affordable housing, it seems wrong to over-allocate market housing. As we know that is unlikely to deliver much if any affordable housing, given the likelihood of revised economic viability assessments once planning permission has been granted.
The relationship of the proposed site to the built form of North Elmham and the existing settlement boundary is poor. NEL 1 would be essentially separated from the rest of the village, in a location which ‘looks’ southwards, away from the rest of the settlement.
If NEL 1 is allocated it would require a footpath from the site access on Back Lane to the junction of Back Lane with Eastgate Street, including a section along Eastgate Street to enable a safe crossing point to the east side of the road where there is an existing footpath.
Also, if this site is allocated and then permitted following a planning application, it will be essential to extend the 30mph limit significantly further west up Back Lane, to ensure access to and from the site is safe. There are also concerns about visibility issues for the access.
Proposal NEL 2: South of Eastgate Street
North Elmham Parish Council is strongly against this site being allocated in the Local Plan. Instead, we wish to see the site at Station Yard (LPR/CS4/DEV/215 in the call for sites) allocated.
Allocation of site NEL 2 would lead to an unacceptable number of new traffic movements on Eastgate Street, where traffic is already causing concern to residents. Given the narrow street, the lack of footpaths in significant parts of the street, including to the east before it is possible to walk onto the safe route to the primary school across the Village Green, and the 30mph speed limit, the addition of 30 houses with their associated traffic movements is unacceptable.
Development of NEL 2 would lead to an unacceptable loss of greenfield in a key part of the village. This would harm the character of the village. Access to the proposed site requires the demolishing of 80 Eastgate Street, which would harm the character of Eastgate Street.
We are concerned about the increase in flood risk due to the potential for surface run-off from a developed NEL 2. This is due to it being uphill from the properties currently to the south of Eastgate Street. Some of these properties and parts of Eastgate Street experienced flooding in 1981 and in 1998, with the former resulting in surface water running down Orchard Close and into properties. Any addition of hard surfaces uphill from existing properties represents an unacceptable risk.
There would also be issues regarding light pollution from what is a visible site in a prominent location. This would have harmful impacts on wildlife, the amenity of nearby residents and the current dark sky.
Instead, we wish to see the allocation of Station Yard, primarily because it is brownfield, and the draft Local Plan seeks to prioritise such sites. This is one of the rare brownfield rural sites and should be developed before valued greenfield sites. The Station Yard site is suitable for development, given that it has previously been given planning permission (3PL/2013/1045/O.)
The Station Yard site also received a more positive assessment than NEL 2 in Breckland’s site assessment phase 1. Station Yard is brownfield whereas NEL 2 is ‘mostly’ (in fact almost entirely) greenfield. Station Yard would only require a short section of footpath to be provided for pedestrian access. The lack of this section of footpath has not been seen as an issue for the delivery of other properties along Station Road, particularly those on the north side. Development of the Station Yard site would bring a benefit to all other residents of Station Road, through provision of this short section of footpath. NEL 2 would require significant improvements for pedestrian access, leading to a red flag on the site assessment.
Kevin J. Webb A.C.I.B.
Clerk to North Elmham Parish Council
Update June 2024
Breckland Draft Local Plan – New Consultation
Breckland District Council has announced the latest consultation for their emerging Local Plan, which will give residents their first opportunity to comment on sites which have been suggested for housing. Unfortunately, this opportunity has only been given after Breckland has decided which of the proposed sites to put into the draft Plan as their “preferred” ones.
Two sites have been "preferred" for North Elmham: one for 10 houses off (lower) Back Lane, and one for 30 houses behind and to the south of (lower) Eastgate. Further details of these and of the other sites put forward in the Call for Sites can be viewed on Breckland’s Commonplace website for the Local Plan at: brecklandlocalplan.commonplace.is . Although these two sites have been preferred at this stage, they are not yet set in stone, so comments on these and the other potential sites can be made, as well as comments on other aspects of the draft Local Plan. If residents feel strongly about any of the sites, make these thoughts known through the consultation.
North Elmham as a designated Local Service Centre will have to have some new housing during the period of the new Local Plan, with thinking currently being that most growth will be focussed in the market towns, which will receive about 75% of the new housing across the District. This figure for new housing in North Elmham is 40 new houses over the Plan period to 2046.
The consultation has been announced to run from 3rd June to 15th July, with a local drop-in event at Dereham Leisure Centre on 3rd June, with additional events on Zoom on 5th (12.30pm – 2.00pm) and 17th June (6.30pm – 8.00pm) and 3rd July (6.30pm – 8.00pm.)
Residents will also be able to comment on other aspects of the draft Local Plan, one of these being on the proposal to remove settlement boundaries, to allow some new development outside existing boundaries, subject to a range of criteria, which would be in addition to any allocated sites covered above. The Parish Council and many others were concerned about this proposal and commented accordingly in earlier consultations. In the first consultation in 2023, 53% of those responding to the question about settlement boundaries said they wanted them to remain, with 21% wanting them removed. In the consultation earlier this year, question 2 asked whether Breckland should “continue with a settlement boundary approach or develop a criteria-based policy”, with 69% of the respondents to that question saying that settlement boundaries should be continued, with 26% in favour of developing a criteria-based policy. Despite these clear majorities in favour of keeping settlement boundaries, Breckland has decided to remove them and adopt a criteria-based approach in the draft Local Plan: it makes one wonder what is the purpose of consultations?!
One positive to come out of previous consultations is that the proposal for a new town in Bintree, Billingford and North Elmham has not been put into the draft Local Plan: good news indeed!
The Parish Council will discuss its response to the new consultation at their meeting on 3rd June, with this being finalised at the July meeting.
Michael Rayner, Councillor & Planning Lead, North Elmham Parish Council
Update June 2023
With Breckland Council's initial Issues & Options consultation now closed, we await the results. There has been overwhelming opposition to the concept of a new settlement, particularly one in the North Elmham/Billingford/Bintree area. Huge thanks go to everyone who has answered the call to submit responses. North Elmham Parish Council has requested a further round of consultation on Breckland's emerging Local Plan, so that everyone has an opportunity to comment on specific sites which have been put forward as potential sites for development. This would be before the currently planned next consultation on the sites which Breckland prefers at that point. In the meantime, we all need to remain vigilant - a role which has been taken on with great energy and effectiveness by John Hoskins, co-ordinator of CANT (Campaign Against the New Town.)
North Elmham Parish Council
CAMPAIGN AGAINST the NEW TOWN (CANT) between Bintree, Billingford and North Elmham
Breckland Council are updating their planning policy. The first step is a public consultation to get the community’s views on the housing that the district needs over the next 20 years.
A key question in their document is: “Should there be a new settlement Garden Town/Village within Breckland?
The only ‘new settlement’ that is being considered, in the short term, is a site for 5,000 houses in a remote area of fertile agricultural land between Bintree, Billingford and North Elmham. Should this go ahead the very nature of mid Norfolk, and what attracts people to it, would change forever. It would impact a wide area due to the immense infrastructure changes required, along with decades of construction and associated traffic. Those villages, and maybe others, would simply cease to exist as they were absorbed into this development. The site lies adjacent to the highly valued and protected River Wensum and sits above a large chalk aquifer, so the environmental impacts for Norfolk could be considerable and irreversible, when food security, pollution issues and water resources are all major concerns at a time of uncertainty and climate change.
We need to focus the Council’s attention on developing affordable homes for local people, close to existing employment, public transport and facilities. Development should support our towns and villages, not use land vital for food production.
PLEASE HELP! Assuming it won’t happen is not enough.
Go online to: https://www.breckland.gov.uk/article/19942/Local-Plan-Full-Update and go to the ‘Issues & Options Response form’.
All you need to do is fill in your details on page 2 (which will not be used or published) and simply say NO to Question 13 on page 8. If you want to fill in more answers, that’s great, but our key concern is simply to reject the idea of the new town.
Alternatively, you can simply copy and paste the text below into a new email and return it to this address – campaignagainstnewtown@gmail.com and feel free to add as much extra text as you would like.
To Breckland Council
"Issues and Options" Consultation 2023
In response to Q.13: Should there be a new settlement Garden Town/Village developed within Breckland?
My answer is:
My name:
My address:
My e-mail:
If not a Breckland resident, my interest in this issue is:
If you have received a paper version of this form through your letter box it can also be returned to the Elmham Tea Post who have a box to collect responses and you can also pick up a form there to complete (during Post Office opening hours).
Please pass this on to all your friends, relations and contacts. Every individual can send a response, whoever they are, wherever they live.
Follow CANT on Instagram @campaignagainstnewtown – and ‘like’ and comment on as many pictures as you can, we need the message to be loud and clear.
CANT is fully endorsed by North Elmham Parish Council