Protecting the distinctiveness of this very special coast

 

KL and WN Local Plan Review consultation

 

The consultation for the local plan in the Borough ends on 29^thApril 2019 and there are significant changes which will affect development pressures in the rural areas of North Norfolk. The information set out below summarises a few points which may have the largest impacts but it is important for all persons to look at the review document which can be seen at

http://west-norfolk.objective.co.uk/portal/lpr2019/lpr2019,

Don’t be put off by the seeming requirement to ‘register’ to respond to the consultation – this is only if you want to do so online. Frankly we found this impossible and gave up so we would urge people not to bother and simply email (lpr@west-norfolk.gov.uk) or post a response (Planning Policy – Local Plan Review, KL&WN Borough Council, Kings Court, Chapel St, King’s Lynn PE30 1EX)in to the Council. The important things are to state reasons for the issues you raise and link (give the reference) them back to the specific section of the Local Plan document that you are commenting on.

 

The key points we feel may be important are;

 

1. The allocation of a site for housing in Burnham Market (BM1 site in the local Plan) on the basis that this will also provide space for a new doctors surgery. The site allocation in BM1 gives a suggested housing number of 29 to pay for the new surgery. The site is located on open greenfield land opposite the garage on Creake Road. It also incorporates the Farm and farmyard there too. Some may remember this field being put forward for housing 30 years or so ago where the development was intended to reach up to Joan Shorts Lane and consist of 60+ houses. Some may also recall the original stated intention of the development of the new Car Park in Burnham Market was supported by an allowance in the then Local Plan for 12 houses – but a lot more than that became ‘necessary’ to make it ‘viable’ to provide the car park when it actually came to the planning application. Its probably not unreasonable to say that 29 houses is probably very much at the lowest possible level to justify developing a new doctors surgery and that 2 or even 3 times as many (needing land up to Joan Shorts Lane possibly??) may come to be ‘necessary’.

 

2. The question of whether or not a new surgery is needed or justified has not been made in the Local Plan review and it seems that this is a fundamental element of the justification for suggesting that a very large development be allowed when the village has a determined allocation need of just 5 houses in the next local plan period. The existing surgery dates from the 1980s and is a purpose built building standing on a large plot with a bus stop outside the entrance. The location is entirely sustainable and well positioned, the new location would not be on a bus route and would be less sustainable. The existing surgery could be enlarged, as could the car parking provision on the site if either were necessary. One would also have to ask if a new surgery would be significantly larger / have a definitely larger number of GPs and nurses and undertake significantly more procedures – which are clearly justified and necessary and not able to be done from the existing site (with enlargement if necessary of the existing facilities) – if not then why would there be a need for a new surgery?

 

3. Phasing of housing – It would seem sensible to put a policy in the local plan to ensure that the new sites which have been identified in this new Local Plan would only be considered to be built on if and when the existing sites which were allocated in the previous Plans have been completed. This would ensure that valuable countryside is protected and that ‘ad hoc’ speculative development doesn’t take over causing some ‘less favoured’ brownfield sites to be overlooked whilst nice, more lucrative and easy to develop open countryside sites are spoil because there is more money to be made more easily.

 

4. Brownfield First. From the statement above, we would suggest that there be a policy to favour the use of brownfield sites before taking in any new Greenfield sites. The Council’s Brownfield Register contains 51 sites totalling 87 hectares with the potential for 2,085 homes – which is more than the 1376 needing to be allocated during this local plan review period.

 

5. The Council have sought to take away the previous policy in the 2016 Local Plan (which repeated other policies in the local plan of 1998) which did NOT allocate a development boundary to the settlements designated as ‘Smaller Villages and Hamlets’ – of which the Borough has a lot. The policy in the 2016 Local Plan (DM3) stated the reason for this was because ‘development in Smaller Villages and Hamlets will be limited to specific identified needs only and development boundaries would be likely to result in amounts and types of development beyond this’.

 

6. The new policy (Section 15 of the Draft 2019 Local Plan) now only states ‘Modest levels of development can still take place (within the smaller villages and hamlets) as each has a development boundary’. There is no indication of how this very significant about face of policy has been arrived at or why if it wasn’t considered appropriate for more than 20 years, development (of presumably any sort as it’s not specified to ‘specific identified needs only’ or any other sustainable type criteria) is now considered appropriate for these settlements (some areas consisting of a pair of houses only as at the outlying bit of Burnham Norton).

 

7. In tandem with this significant policy change and further increasing the likely random and unsuitable development which may be likely to be allowed by this Local Plan is the provision of Policy 26. This appears to give the opportunity for development outside the development boundaries of settlements – including smaller villages and hamlets. There does not appear to be any justification for this policy and its wording and intent would seem likely to give rise to significant speculative development applications. I would suggest that this policy is deleted and that no revision or alteration of it is necessary as it does not perform a useful or needful function. Where exception sites may come forward for social housing, they would not require this policy – or one like it – to support them.

 

8. Overall, the changes to the KL & WN Local Plan now give significantly less protection to the environment of the Borough and to the amenity, character and communities that it is supposed to serve. They will encourage significantly more speculative ‘ad hoc’ and unstructured development in the form of random applications which bear no relationship to a well-structured and designed planning process which seeks to deliver good development where it is required to sustain the society, environment and economy of the Borough. And for these reasons the policies do not appear to tie in well with the housing allocation either. It is notable that the local plan review in North Norfolk does not propose policies of similarly large and wide ranging easy development opportunities in and around small villages. I am not sure why these changes have been made to what appeared to be a well-functioning Plan.