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Proposed Local Development Order (Egmere) ‐ Consultation Responses The proposed Local Development Order (Egmere) was published for 6 weeks public consultation from 21 January to 15 March 2013. A total of 43 responses were received during that period and this document is a complete record of those responses. The column stating the comment type; ‘support, object or comment’ was not requested as part of the consultation, but is an officer’s interpretation of the comment. Thereafter the comments received are detailed in full, together with a final column indicating a proposed response / action by the District Council. Where appropriate, amendments or revisions to the proposed Local Development Order are suggested, as is the need for some further work to be undertaken in support of the evidence base in support of the Local Development Order. The District Council is grateful for all the comments made during the consultation process and will include these as part of the evidence base submitted in support of any application for the designation of a Local Development Order at Egmere made to the Secretary of State for Communities and Local Government. The comments received and the Council’s proposed response at this stage are considered to be a public document and will be available for viewing on the Council’s website northnorfolk.org or in hard copy format on request. North Norfolk District Council Planning Policy Team Telephone: 01263 516318 E‐Mail: planningpolicy@north‐norfolk.gov.uk Write to: Planning Policy Manager, All documents can be made available in North Norfolk District Council, Holt Road, Cromer, NR27 9EN Braille, audio, large print or in other languages. www.northnorfolk.org/ldf Please contact 01263 516318 to discuss your requirements. Page 2 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response LDO1 Mr Matt Walsh Support Excellent. Large developments should not be tied up with No response / action required. endless planning applications. It is hard to know how a large project will evolve. Allowing flexibility, within the confines of an order, provides companies with a great incentive to invest in North Norfolk. North Norfolk can benefit tremendously from offshore wind and generate much needed employment. The speed of projects will be enhanced and therefore the flow of jobs. All residents of North Norfolk should welcome the approach of the Council.
LDO2 Miss Julie Upton Comment I do believe that this LDO will be all together better, as the state of the buildings and surrounding area could be used more effectively. But my main concern is that of a resident at Bunkers Hill and living right on the end (no 1) of Mr Lomax's site, I’m a bit worried about being built in and over looked by buildings which will be up to 12m high! I know there is already a building there that height, but only the one! My question would be on how much of a say would we have as residents on where the buildings will be placed? Also the strip of Lomax land that runs down the bottom of our garden all the way to ABN, how high and how big are they expected to go, i know the land/strip there isn’t very big, so maybe just kept for storage. Propose amendment of the area to be included within the LDO to exclude the North Creake Business Park site, meaning that any further development of that site will require planning consent to be obtained through the usual processes. Proposed omission from this site from the LDO based on three grounds •
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I can probably vouch for all of us residents that’s land backs •
onto the bottom of lomax strip, is that we would love to take over that piece, buy it back to us. As we will be losing so much with the Solar panels and Bio‐plant, it has been talked about that a nice meadow area for birds. Just our Highway concerns about access into the site. Concerns of residents of adjoining residential properties about impact of development on their amenity. No response received from the landowner about the inclusion or exclusion of the site within the LDO. Page 3 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response little piece of countryside, which unfortunately seems to be being swallowed up rapidly! LDO4 Mr Stephen Chadd Director Kiss Works Ltd Support As a company involved in providing engineering and maintenance support to the Sheringham Shoal, Lynn and Inner Dowsing wind farms, and already operating from the proposed development, I feel this would be of great benefit to the local economy which would provide a golden opportunity to train young people wanting to be involved in this new industry. Due to its proposed location on an existing industrial area with good road access to the "port" of Wells and Wells harbour, good road links to Kings Lynn, and with consideration for the offshore developments in the near future, I would say that this would be an ideal site for such a development. At present there is a serious lack of technical employment opportunities for young people in the North Norfolk area; this leads to our bright young minds needing to move away from the area to find gainful employment which has many effects on the local community and economy, none of which are beneficial. We, as a company, have realised that without providing local skills to support the growing industry that is already here and will continue to grow, it will give the developers and operators no choice but to keep shipping in the skills they need, adding to the cost and carbon footprint of the wind farm sites. The other issue with bringing in outside labour is that any money earned here is taken out of the county or country and is not benefiting the local economy. As a company already training young engineers for the No response / action required. Comment about improving information about airfield history of site noted and will seek to consider relocation of memorial to more appropriate site / setting in conjunction with the recently approved solar farm development. Page 4 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response industry, I have been in contact with the College of West Anglia regarding tailoring the education modules they provide so that they are more suited to what is required within this, soon to be, very large industry. This has resulted in the College Principal meeting his local MP to discuss the issue. If we are going to train people for the industry it stands to reason that we need to provide a range of employers to employ them, and the site here at Egmere would provide a good location for renewable energy biased businesses to establish themselves in North Norfolk. I would, however, like to propose one matter for consideration. This is the site of a famous WWII air field where a small (almost hidden) plaque exists on the proposed new development area relating to its use and importance during the war. I would like to suggest that this be placed in its own memorial area in plain sight. "Lest we forget." LDO3 Mr Robert Smith Harbour Master Wells Harbour Commissioners Support Wells Harbour Commissioners fully support this proposal on No response / action required. social, economic and environment grounds. The existing wind farm development at Sheringham Shoal has already produced enormous benefits for the local community and economy here at Wells and in North Norfolk and this proposal will assist in the continuation of this success. There have been 50+ jobs created as a result of the existing development and in 2012 alone an estimate of £7.5m spent within the local economy in addition to the £7m invested by Scira on the project. The LDO would assist with further growth of the area as an Operations and Maintenance base for the renewable sector Page 5 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response providing the infrastructure needed to promote the Port and Town and attract other wind farm developers and inward investment. In January, the Port of Wells Executive met with Centrica about the possibility of using Wells for the Race Bank wind farm. Centrica showed a great deal of interest in the proposed LDO and stated that had this infrastructure been in place for the Wash and Inner Dowsing they would have considered Wells as a viable option. Unfortunately at that time the infrastructure was not in place and Centrica chose Grimsby for investment. However if the LDO goes ahead they stated that it makes the Outer Harbour at Wells more attractive for use on the construction phase of the Race Bank. LDO5 Mr Simon Edwards Director EDS Contractors Ltd Support No response / action required. I think that this development would be a great asset for local business. As a small locally based construction / civil engineering company (North Creake) working within the renewable energy market, we would love the opportunity to expand to a permanent base close by in the local area. There are very few opportunities in this area for business expansion and feel this would be a great one. I'm sure this would help like‐minded businesses within a similar industry to help each other progress their business further, as well as providing opportunities for many young local people with a good long‐term career for themselves. LDO6 Miss Juliet Allen Support I believe the LDO Egmere proposal is a very positive No response / action required. one. The Sheringham Shoal Offshore Wind Farm, along with others around this coastline, have brought about a whole new industry to the area which will bring about much needed employment for local residents as well as boosting Proprietor Olive Branch Services Page 6 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response the local economy. There are increasingly more renewable energy and offshore support companies in the North and West Norfolk area who would welcome the opportunity to set up new (or larger) premises and work alongside other similar companies in a local business community. It also encourages businesses to trade with each other rather than buying equipment or services from outside of the region. It is paramount that youngsters and local residents in the area are given the best possible opportunities to gain skills in this business to allow them to enter the industry and sustain their careers; therefore, I hope that training providers are also consulted with as part of this proposal. As a local administrative support company to a previous offshore wind farm and now a marine engineer and boat builder, I also hope that the provision of services (such as improved infrastructure and high speed fibre optic broadband) is given serious consideration as part of this proposal to ensure that local businesses can trade consistently and efficiently 24 hours a day. LDO7 Claire Nugent Comment I agree with opportunity for jobs but issues with: 1) speed limit of road with additional traffic. 2) development that respects the airfield heritage. 3) development that does not 'swamp' the residents in Egmere. My concerns are: 1) Traffic 1) Traffic issues ‐ In proposing the LDO at Egmere the District Council did suggest to the Highway Authority that a speed limit of 40mph be introduced along the length of the B1105 road through Bunkers Hill, Egmere. The Council understands the Page 7 of 92
ID Name Organisation Support / Object or Comment Comments 2) Large scale and tall developments 3) Airfield buildings 4) Pedestrian routes if access points closed 5) Buffer for residential properties (COMMENTS SUBMITTED VIA EXHIBITION FEEDBACK FORMS) NNDC Response need for any LDO to be supported by an Access Strategy approved by the Highway Authority and will continue to press for the introduction of a speed limit at this location which appears to have significant support of local residents and the wider community, irrespective of their views on the proposed LDO. Whilst I am supportive of generating skilled jobs in the area there are a number of concerns I have and wish to have addressed: 2) Large scale and tall buildings:‐ Based on consultation comments 1) The speed limit in the development area. With additional received about the potential scale traffic for this development, the construction and operation and height of buildings within the of the approved AD plant; the construction phase of the area proposed for designation as approved Solar Power Plant, alongside the existing use of an LDO, it is proposed to make this area by the existing businesses and additional use by some amendment to the the Sheringham Shoal Wind Farm HQ in combination with boundaries of the LDO, the characteristics of the road. I believe keeping it at 60mph particularly in relation to the is excessive and should be reduced to 40 mph. Or people residential properties at Bunkers will die on this stretch of road. Hill, so as to protect the amenity of local residents. 2) The impact on residents of Bunkers Hill will be significant. I would like it considered that a buffer be agreed around the residential properties which will not be built on. In particular the land between our houses and Holkham land on the west of the residential area (this is a thin strip that 3) Airfield buildings – the wish for currently has development up to 12 metres earmarked for historic airfield buildings to be it). I want this strip of land removed from the development retained is noted – please see plan and a sufficient development‐free buffer to surround further comments made under our homes to the North and South. This is a mixed representation LDO31 below. development area of both industry and housing. The needs of both need to be considered. Page 8 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response The North Creake Airfield heritage is very important and I am pleased that this has been identified in the heritage 4)
report for this development. I feel the history of the site should be considered in all development proposals and that existing airfield buildings are preserved wherever possible and any artefacts found during any construction phase be conserved and made available for public viewing. (COMMENTS SUBMITTED POST‐EXHIBITION) Pedestrian access from the residential properties to Edgar Road, avoiding the need for residents to walk in or along the B1105 road is noted; however there is no permitted right of way across / through this site and this is a matter for the Walsingham Estate to consider in detail. Further consideration can however be given to the issue in the further development of any Access Strategy. 5) Buffer for residential properties: ‐ Proposed amendment to the LDO boundary to exclude the North Creake Business Park site as commented upon at representation LD02 above. LDO8 Mr Seb Moore Comment Concerns noted – please see In general agree with the proposal ‐ only concerns with traffic speed along this road (B1105) especially with regard comments made at representation to entry / exit to site and also the crossroad to the south LD07 above. (C336* crossing the B1105). This junction has poor visibility both ways. Any limit which might be imposed along by the LDO area might usefully be extended to the south of this Page 9 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response junction. *C336 ‐ Egmere Road gaining access to the Walsingham Road from North Creake to Walsingham. (COMMENTS SUBMITTED VIA EXHIBITION FEEDBACK FORM)
LDO9 Mr Nigel Morter Comment Whilst we're supportive of generating skilled jobs in the area there are a number of concerns we have and wish to have addressed: See comments made in respect of representations LDO2 and LD07 above. 1) The speed limit ‐ with additional traffic and the characteristics of the road, 60 is excessive and should be reduced to 40[mph]. 2) The impact on residents. It must be ensured that the impact on residents properties are greatly controlled ‐ we would wish to see the land between us and Holkham land removed and a sufficient development‐free buffer to surround us. 3) Heritage ‐ as identified in the heritage report, we feel the history of the site is considered in all development proposals and that existing airfield buildings are preserved wherever possible. (COMMENTS SUBMITTED VIA EXHIBITION FEEDBACK FORM)
LDO10 Fletcher Object 1) Comments re highway and traffic We have major concerns with regards to the increase of speed noted – please see traffic on this road (B1105) our child crosses this road to get response made at representation home from his school bus (he is 13 years old). LD07 above. 12m high buildings in the orange zone would have a major 2) Building height – please see impact on our lives and privacy. comments made at representations LD02 and LD07 There is consideration to close off access routes across the Page 10 of 92
ID Name Organisation Support / Object or Comment Comments road which would also then give the school bus nowhere to pull‐in to drop‐off the children other than on the road. This all feels like over‐development in an otherwise picturesque area. NNDC Response above. (COMMENTS SUBMITTED VIA EXHIBITION FEEDBACK FORM)
LDO11 Ms Pauline Catton Comment Consideration needs to be given to speed of traffic using the dry road. There have been many serious accidents in the past. Concerns over speed of traffic acknowledged. Please see comments made at representation LD07 above. LDO12 Ms Jan Perfect Town Clerk Fakenham Town Council Support At a recent Development Meeting, Councillors supported the above proposals as it would provide employment and bring increased income to businesses in the area. No response / action required. LDO13 Mr Ray Millard Object I want to object to the proposed industrial development at Egmere. I object to it because it is in an essentially rural area; because of the visual impact; because of the increased traffic on rural roads during and after construction; because of the environmental cost to the surrounding area; and because if permission is given for this development it will send the wrong signals to developers. In proposing to designate an LDO at Egmere the District Council has identified why this location was chosen – being well‐related to Wells, on the principal access road to the town from the south and outside of the Area of Outstanding Natural Beauty. Interestingly the comments seem to mostly be in favour of this eyesore, and seem to be from those who may have potential to gain from it. Does nobody care about a tranquil and unspoilt North Norfolk? Does "Progress" and Economic Growth have to be at the expense of the peace and quiet of the dwindling countryside? More jobs? For whom? And what about the associated housing? Ah yes, it all falls into place now! They want to Consideration has been given to the siting and height of buildings within the area covered by the LDO which will also be supported by the preparation of a Design Guide and Landscaping Plan. As a result of the consultation responses received some amendments are proposed to Page 11 of 92
ID Name Organisation Support / Object or Comment Comments ruin Wells by tacking on a big housing estate. The developers will be rubbing their hands! NNDC Response the LDO boundary and height of buildings, in an attempt to minimise the impact of any development within the wider landscape. Issue of traffic generation – the County Council in its capacity as Highway Authority has advised that the B1105 road serving Egmere has capacity to serve any development taken forward under the proposed LDO in principle, subject to the preparation of an Access Strategy, which will be prepared if the District Council resolves to proceed with seeking endorsement of an LDO at this location. The Egmere site is not close to any protected or designated sites of nature conservation value and the land is already in either commercial or agricultural use and it is therefore considered that the environmental impact of the proposed development will be minimal and any adverse impacts can be mitigated through structural landscaping. However, the Council is mindful that a number of comments received during the consultation process have raised concerns about the landscape Page 12 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response / visual impact of development at this location and it is therefore proposed to commission a Landscape Visual Impact Assessment to consider this issue further and identify whether any adverse impacts can be contained / mitigated through appropriate measures – eg planting, restricting building heights, design, use of materials etc. LDO14 Mr Patrick Peal Support I support the purpose of this proposed LDO. The offshore No response / action required. wind energy industry is already bringing good skilled long‐
term jobs to the area, led by Scira already at Egmere. The proposed LDO will encourage more businesses in the sector to set up in Egmere. LDO15 Mr Greg Hewitt Wells‐next‐the‐
Sea Town Council Support At the meeting of Wells Town Council on Monday 4th No response / action required. February 2013, the council received a presentation from Cllr. Tom Fitzpatrick and Steve Blatch of NNDC concerning the proposed LDO. Wells Town Council resolved to fully support the Local Development Order. Some councillors did have concerns about increased traffic on the B1105 and thought that improvements would be needed at the junction of the B1105 and A148 at Fakenham, where it was suggested a roundabout may be beneficial; a letter has been sent to the highways authority. Submitted on behalf of Wells Town Council, Mr G Hewitt (Town Clerk). LDO16 Mrs Joanna Otte Walsingham Parish Council Support with Conditions Thank you for the presentation regarding the proposed LDO at Egmere to Walsingham Parish Council last week. It was useful and informative. Support for principle of LDO noted; in respect of the three issues raised under the bullet points please see comments made under Page 13 of 92
ID Name Organisation Support / Object or Comment Comments Walsingham Parish Council has agreed to support the proposed LDO if the District Council accommodates the requests from the residents at Egmere: •
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NNDC Response representations LDO2 and LD07 above. Agreed that if LDO is to be pursued Speed limit of 40mph in the development zone due that the draft Design Guide will be shared with the Bunkers Hill residents to the increased traffic and Walsingham Parish Council. Heritage of airfield incorporated into design of planned buildings A larger buffer for residential properties – in particular the thin strip of land behind Bunkers Hill residential properties (to the west of the site) be taken out (currently earmarked for development up to 12m). Walsingham Parish Council would also like to be consulted prior to the adoption of the Design Guide etc. LDO17 Mr P & Mrs D Smalley Object Objections noted, but the reasons for the Council proposing the LDO at Egmere are detailed in the consultation material – ie site chosen We wish to object in the strongest possible way to the proposed development at Egmere. This is on the grounds of beyond Wells and the Norfolk Coast increased traffic, light pollution and general unsuitability of AONB so as to achieve a balance with the tourism attraction of the town the entire project. The AONB at Wells and surrounding and wider North Norfolk coast, whilst areas must be preserved, and any further development seeking to accommodate investment locally must be avoided. and jobs associated with a new economic sector, which will serve to North Norfolk does not lend itself to projects of this sort, diversify and strengthen the District’s and we hope that any such plans will be rejected. economy. Concerns about traffic and highway issues acknowledged and addressed Page 14 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response at representation LD07 above. Further consideration will be given to the issue of light pollution which has been raised by a number of respondents to the consultation process. LDO18 Mr Michael Oldfield LDO19 Mrs Jacqueline Williams Object Object We would like to formally object to the proposed development of a 74‐acre industrial estate at Egmere which is just a few miles from our home, on the basis that such a development should not be located in open countryside literally miles from any significant population, therefore it would result in huge traffic increases on roads that are totally unsuitable. Also such a development would attract further building applications in an area which is completely rural and un‐spoilt. And we do not need this as a job creation scheme! I should like to object to the proposal to create a new industrial estate on the following grounds: •
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Not sure where the reference to a 74 acre industrial estate has come from as this terminology was not used in the consultation material, but has featured in a number of the later representations received. The reasons for the Council proposing such development at Egmere were clearly explained in the consultation materials. A development of an industrial estate in the middle Reasons for site being proposed as of high quality countryside – visible from miles around (to the east specifically) located on some of location for an LDO clearly detailed in the highest ground in the district, is an affront to the consultation material. logic and reason – in planning terms it is illiterate. The development will be excessively prominent within the open landscape. The site is close to the Proposed LDO is supported by North Norfolk Coast AONB and is well within sight proposals for structural landscaping of it. The new development will therefore adversely at the boundaries of the site to Page 15 of 92
ID Name Organisation Support / Object or Comment Comments affect this feature. NNDC Response mitigate the impact of development from long‐distance views and if to be pursued further will be supported by a Landscape Plan. Whilst the northern plots / areas of the proposed LDO area surrounding the existing large grain store (former hangar) building can be seen from viewpoints from the east, much of the area proposed for LDO designation will not be visible from long‐distance views due to existing wooded areas and the lie of the land. The relationship of the site to the Norfolk Coast AONB is acknowledged in the consultation material and whilst a matter for consideration, the District Council believes that against the backdrop of existing development at Egmere including a number of large agricultural and manufacturing buildings, and supported by structural planting, development permitted through any LDO can be satisfactorily accommodated in the landscape, without any significant detrimental impact on the AONB designation. Indeed, whilst expressing some concerns about the proposed LDO the Norfolk Coast Partnership Page 16 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Manager (representation reference LDO28) stated:‐ “However, having visited the surrounding area for the purpose of assessing potential visual impacts from the Norfolk Coast AONB, I do not consider that these impacts would necessarily be significant. There might be some visibility of new buildings from the B1105 and the minor road running east off this (via Crabb Castle Farm) which demarks the AONB boundary and from the track E of Gallow Hill to the north, at least initially, but I consider that this would be of minor significance and mitigated further in time by the proposed planting, and which would also help to screen the tall existing buildings to the west of the B1105. Visibility from public highways and paths further to the north east appears to be limited and distant.” Notwithstanding the above, the Council is mindful that a number of comments received during the consultation process have raised concerns about the landscape / visual impact of development at this location and it is therefore proposed Page 17 of 92
ID Name Organisation Support / Object or Comment Comments •
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The site appearance and form will be uncontrolled and lighting, building size, colour and design will be unfettered and likely to be totally inappropriate – the lighting to the existing SCIRA offices now adversely affects the appearance of the area as seen from the high quality landscape to the east of the site and is actually visible from near Hindringham. The site will damage the dark skies of North Norfolk. It is contrary to the Councils own Landscape Character Assessment and its LDF policies as it will massively damage both statutorily and Council NNDC Response to commission a Landscape Visual Impact Assessment to consider this issue further and identify whether any adverse impacts can be contained / mitigated through appropriate measures – eg planting, restricting building heights, design, use of materials etc. Development delivered through any LDO would not be “uncontrolled or unfettered” as it would be supported by a Design Guide which would provide guidance on the scale, massing, height, design and colour of any buildings, as well as providing guidance on lighting, signage, boundary treatment and landscaping. Concern about the level of lighting has been raised in a number of consultation responses, based upon the impact of lighting at the recently developed SCIRA facilities and it would be proposed that further consideration be given to this matter to establish if low level lighting or PIR lighting would be more appropriate in minimising the impact of development on dark skies. The landscape impact of any development has been considered Page 18 of 92
ID Name Organisation Support / Object or Comment Comments designated landscapes. •
It will damage the setting of a Grade 1 listed parkland (Holkham), a scheduled ancient monument (Egmere deserted village) and the historic airfield. NNDC Response and is not considered to be significant. However in light of the representations received, the District Council is proposing to commission a Landscape Visual Impact Assessment to consider this issue further and identify whether any adverse impacts can be contained / mitigated through appropriate measures – eg planting, restricting building heights, design, use of materials etc. It is not considered that the development will have any greater impact on the Egmere “lost village” than existing and recently approved developments to the west of the B1105 – ie the anaerobic digestion plant and solar pv farm; or that it would have any detrimental impact on the Grade 1 Listed Holkham Hall and Parkland. The request for any development to respect the historic use of parts of the site as a World War II airfield is acknowledged and advice sought from the County Historic Environment Team (representation reference LDO31) which has suggested that if any proposals are Page 19 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response developed which involve the conversion or demolition of airfield buildings or structures that a photographic record be taken. Based on the comments received from the consultation process some amendments have been proposed to the area covered by the LDO where there is a concentration of old airfield structures – particularly to the south of the Edgar Road junction with the B1105 where there are a number of nissen hut type buildings. •
It will massively increase traffic along an inadequate roadway network – one which is currently overloaded at peak times in the holiday season. Everything will have to be transported into and out of the area from great distances away by road – to locate an industrial estate in this location for this reason alone is madness and shows a complete lack of understanding of transport infrastructure issues. •
There are insufficient people with the correct skills in the area to staff this new estate so commuter traffic will be massively increased as well with people commuting from Lynn, Fakenham and The Highway Authority has advised that the B1105 road has the capacity to support the scale of development proposed through the LDO, subject to their agreeing a detailed Access Strategy. The reasons why this location has been identified for future development in terms of its location / accessibility is detailed in the consultation material. It is acknowledged that during the development of any major civils / construction contracts that workers with specialist skills will be utilised, often from a national / international pool of companies. However, in the Page 20 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response operational and maintenance phases of business operations there will be recruitment of increasing numbers of local people and this is already being seen with the SCIRA operations. SCIRA has established strong links with local high schools and colleges and wishes to recruit local people to support their operations over the next thirty plus years. It is believed that similar opportunities will exist in respect of the Dudgeon and Race Bank schemes. Further an increasingly large number of business support contracts are being let by SCIRA to local Norfolk businesses which are then recruiting additional staff to support this new business and the LDO seeks to position the Wells / Fakenham area positively in attracting new jobs and investment associated with this growing sector of the national and regional economy. There is no evidence to support the Housing costs and pressures will be increased by claims that “housing costs and the wealthy manager class who will move into the pressures will be increased by the area further displacing local families (as has wealthy manager class moving into happened over the wind farm already). Jobs will be the area, further displacing local given to those with connections to the key people families.” The local housing market with power and influence in the area or with the in and around Wells already operates companies concerned or those with ‘key ready in a way which disadvantages local skills’ – just as has happened over the wind farm so people through the high value of Norwich – probably Great Yarmouth. •
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ID Name Organisation Support / Object or Comment Comments NNDC Response there will be no benefit to local jobseekers. properties given over to second and holiday home use which are unaffordable to local people on average wages employed in the tourism and agricultural sectors. It would be expected that people employed in the offshore wind energy sector will be paid above current local average rates of pay, allowing them to compete more effectively in the local housing market. The Wells Harbour Master / Commissioners have publicly stated that there are no plans / proposals to enlarge the existing outer harbour at Wells in connection with the proposed LDO and that the existing facility has the capacity to serve further offshore developments. Any proposals to enlarge or extend the Outer Harbour facility would require separate consultation and approval processes involving the Marine Management Organisation / Natural England and the Environment Agency amongst other bodies. Identifying a location outside of the town of Wells and the Norfolk Coast •
Pressure will be increased to enlarge the outer harbour at Wells – regardless of the assurances to the contrary – after all who would believe those who were involved with this original development when all the statements made prior to its development were ‘forgotten’ when the development actually went ahead. •
Traffic congestion and hazard will be increased in Wells and the surrounding villages as commuters, Page 22 of 92
ID Name Organisation Support / Object or Comment Comments materials, staff etc, are based to and from the harbour area – there is no other purpose in having an industrial estate at the end of a B‐Road in the outer reaches of Norfolk if this location is not to be used for the harbour? No doubt unfounded and misleading statements will be used to suggest that there is a need to be close to the harbour so that the boats don’t have so far to go to the wind farms – well logic would suggest that it would be far better to have many fewer long distance commuters and transportation of goods by road than a few efficient boats (which are one of the most carbon efficient forms of transport) do it for you from Lynn or Great Yarmouth. NNDC Response AONB for the development of facilities (offices and warehousing) in support of the offshore wind energy developments, served by the principal access road serving the town – ie the B1105, with direct connections on to the A148, A1065 and A1067 roads from Fakenham, is intended to minimise the volumes of traffic – ie staff, deliveries and visitors associated with such businesses, entering the town / high tourist areas. However, there are operational requirements and cost pressures faced by offshore wind energy companies which require an ability to service and maintain the offshore turbines from accessible locations. The average journey time to offshore wind developments off the North Norfolk Coast by boat from Great Yarmouth, Kings Lynn or Grimsby would be at least twice that as providing support from Wells, meaning that alternative support arrangements would have to be deployed (eg helicopter transfer, hotel ships or accommodation platforms) in the routine operations and maintenance of the developments. This provides a Page 23 of 92
ID Name Organisation Support / Object or Comment Comments •
NNDC Response locational advantage / opportunity for North Norfolk through Wells which the District Council wishes to accommodate as part of its wider corporate priorities of strengthening and diversifying the district’s economy. The District Council does not believe the proposed designation of an LDO The site will damage the tourist industry as the development will be prominent on one of the main at Egmere will negatively impact upon the tourist industry or visitor gateways to the North Norfolk Coast – what will perceptions of the area. The peoples reaction be to seeing the area treated like any other edge of town industrial dumping ground? proposal seeks to accommodate new job‐creating development outside of They do not come to North Norfolk to see what they are trying to get away from in their own areas. the AONB and Wells and in a location where there are established business operations / uses, largely in poor quality buildings / sites. Any LDO will be supported by a Design Guide to guide future development, based upon the principles and template established by the SCIRA development. This establishes a much higher quality form of development than that which currently exists at Egmere and will hopefully generate confidence in the improvement of the wider area. See comments made in response to representation LDO7 above re the Page 24 of 92
ID Name Organisation Support / Object or Comment Comments •
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NNDC Response No traffic management assessment has been done. position of the Highway Authority and the need for any LDO to be supported by a Access Strategy, as well as the proposal promoted by the District Council for a 40mph speed limit to be adopted for the length of the B1105 road through Bunkers Hill / Egmere. The adopted Landscape Character No environmental assessment has been done. Assessment comments that the ecological value of the area is “fairly low” and as the site is some distance from the North Norfolk Coast Special Protection Area / RAMSAR sites, initial comments made by the Council’s Landscape Officers is that an Appropriate Assessment or Environmental Impact Assessment is not required. However, in light of comments received through the consultation process it is proposed that the Council should commission a Stage 1 Habitat Survey and Landscape Visual Impact Assessment, in order that these issues can be considered further. Alternative locations / options have No alternatives have been considered. been considered, including the potential of a number of existing sites Page 25 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response and buildings in and around Wells – ie the Lime Pit on Stiffkey Road; the Radio Mast site off the Walsingham Road and future development / re‐
use of existing buildings in / around Maryland – all of which would result in increasing volumes of traffic being introduced into the town / AONB. Further there were concerns about the cumulative impact of such developments in a number of locations both within and adjoining the town. Consideration was also given to such developments being accommodated at Fakenham, but operationally this was seen as being too far from the port facilities at Wells involving businesses in significant additional costs and not realising the potential indirect economic benefits of such investments – in terms of spend on meeting venues, hotels, meals, temporary accommodation for the Norfolk Coast area – which extends beyond Wells, particularly providing an opportunity to strengthen the economy / performance of businesses in Walsingham, which for much of the year has under‐
occupancy of bedspaces, limited demand for food and drink offering etc.. Page 26 of 92
ID Name Organisation Support / Object or Comment Comments •
No implications for local people or the tourist industry have been considered. •
The development should be sited in a more suitable location where people, infrastructure and existing urban uses are already present. There are many suitable locations in Fakenham, Lynn, Norwich and Yarmouth – all of which would be more appropriate than this location. •
Once this estate is constructed it will never be removed, and will only get larger and demand more and more people. It’s a totally inappropriate location, the mechanism of a LDO is designed to be used for derelict, contaminated and deprived areas of former industrial areas, so this is entirely inappropriate too, and overall idea has clearly one objective which has overridden all others – make a lot of money for a very few people at any cost to the environment and society. NNDC Response The implications of establishing an LDO on local people and the tourist industry have been carefully assessed in the development of the proposal which seeks to respect the tourist economy and development pressures faced by the community in Wells associated with offshore wind energy developments, by positively identifying a location where such investment can be accommodated beyond the town and the AONB. See comments made above. Legislation granting power to local planning authorities to establish Local Development Orders dates from the Planning and Compulsory Purchase Act 2004; however they were not widely used until after the election of the Coalition Government in 2010 where the opportunities of such Orders to encourage and facilitate Page 27 of 92
ID Name Organisation Support / Object or Comment Comments LDO20 Mrs Sandra Wood Comment NNDC Response new job‐creating investment was recognised as part of the Government’s wider agenda of wanting to support the economic growth. In this respect a number of locations designated as Enterprise Zones have adopted Local Development Orders as well as offering business rate relief in an attempt to attract new investment. However, it is incorrect to state that LDOs are a mechanism “to be used for derelict, contaminated and deprived areas of former industrial areas” – they are a tool by which through agreeing a simplified planning regime new investment for clearly defined purposes can be facilitated / encouraged. North Norfolk District Council believes that for defined business uses associated with support for offshore wind energy developments an LDO is an appropriate mechanism by which new investment can be accommodated in the district in an expanding sector of the national and regional economy and has consulted on such a proposal on this basis. I am concerned that the proposed development at Egmere Issue of traffic generation – the will cause a considerable increase in traffic, on roads which County Council in its capacity as Page 28 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Highway Authority has advised that the B1105 road serving Egmere has capacity to serve any development A roundabout at the junction of the A148 and B1105 should taken forward under the proposed LDO in principle, subject to the be a prerequisite; in reality this is already required. A preparation of an Access Strategy, roundabout, or other suitable change of layout of the which will be prepared if the District junction of B1105 with the East Barsham and Walsingham Council resolves to proceed with road would also be needed. seeking endorsement of an LDO at These changes would need to be considered in conjunction this location. with the proposed development of Fakenham's Rudham Stile Lane area, but they would clearly need to be implemented as the first stage of the first development to take place. are already struggling to cope; particularly in the summertime. LDO21 Mr Keith Leesmith Holkham Parish Council Support I am pleased to advise that Holkham Parish Council are in favour of the proposed LDO. No response / action required. LDO22 Mr David Horton‐
Fawkes Support The Holkham Estate owns a part of the land under consideration. We submit the following comments: Landscape No response / action required. The Area of Outstanding Natural Beauty, the National Nature Reserve and the Heritage Coast are protected by legislation and are the consequence of generations of careful management. But these features are only viable as part of a mixed of economy which includes farming, tourism, property development, forestry, manufacturing and sustainable energy generation. The landscape and the local economy will not be sustained by tourism alone. Page 29 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Economy Tourism generates low‐skilled, seasonal work and the main beneficiaries are visitors, second‐home owners and retirees. People who have lived and worked in the area for generations need well‐paid, year round employment. The off shore wind farms are already employing local people and this development should create more local jobs, but many more are needed if young people are going to be able to live and work in the area where they have grown up. Scale The scale of the proposed development is small in comparison to the existing infrastructure at Egmere which is dated or redundant. Since the demise of Dalgety much of the site has fallen into disrepair. The area needs investment to attract businesses and to improve the sense of arrival for visitors. The LDO proposal is limited to development linked to the offshore wind farms and is therefore likely to be of a similar scale to the SCIRA building (not on Holkham land) on the eastern side of the "dry" road. This new building is more attractive and appropriate than the existing buildings. The local economy and the wider landscape will benefit from a rejuvenated Egmere. Traffic The SCIRA building appears to have had no negative impact on the "dry" road or the landscape. If, for example, 20 people were employed at another facility, this might create 40 ‐ 60 more vehicle movements per day. This level of traffic increase would be imperceptible in comparison to Page 30 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response the number of vehicles already using the road. LDO23 Mr Howard Partridge LDO24 Mr Christopher Yardley Comment Object While I support initiatives that will create skilled & well‐paid employment in the area and I applaud the focus on supporting the renewable energy industry, there are a number of issues that I would like to see addressed: 1) The speed limit ‐ with additional traffic arriving and departing, 60mph is excessive and should be reduced to 40mph. 2) The impact on residents ‐ should be considered and controlled. There should be an adequate development‐free area around residential properties, the LDO‐zone should not cut the properties off from the airfield and Holkham Estate, and access to and along the footpath should be maintained or even improved. 3) Heritage ‐ as identified in the heritage report, the history of the site should be considered in all development proposals and existing airfield buildings and other features should be preserved and celebrated wherever possible. [N.B. These are my personal views and do not represent those of my employer(s).] I would like to comment on the proposals to create a new industrial estate at Egmere under a Local Development Order. Fundamentally I consider that it is inappropriate to site a new industrial estate in open countryside, a long distance from other urban areas, infrastructure and people and to do it in such a manner that it removes the opportunity for Concerns noted – please see comments in response made at representation LD07 above. The background context to the District Council proposing to designate land at Egmere as an LDO is clearly detailed in the consultation Page 31 of 92
ID Name Organisation Support / Object or Comment Comments the public to comment on the design, size and nature of the development to any significant extent thereafter. This is a denial of Localism under the Localism legislation and contrary to the democratic principles of the Planning system which have operated since the War. NNDC Response material. The Council believes the positive designation of land for development by businesses in support of offshore wind developments off the North Norfolk coast will serve to direct such investment to a key location, well served by local highway infrastructure and alongside other commercial developments, rather than for such businesses to make unco‐ordinated approaches / proposals for facilities on sites within the AONB. In this respect the District Council believes that the accommodation of such investment / development on a site beyond the AONB would serve to attract new job‐creating investment to an area of the district with a narrow economy which is over‐reliant upon low paid jobs in the tourism sector resulting in large numbers of young people leaving the area in search of better employment prospects and affordable housing. The support for the proposed LDO from many local town and parish councils suggests that the proposal is not, as is implied, a “denial of Localism.” Page 32 of 92
ID Name Organisation Support / Object or Comment Comments Specifically I would consider the following items to be of relevance to my basic objection to the principle and practice of the proposals; 1. Siting of the Estate in Relation to Existing Infrastructure with consequential carbon costs The aspects that I would refer to are with regard to the efficiency of siting of the estate at Egmere (rather than as you say, competitively, the Humber ports or even Lynn or Gt Yarmouth) are detailed below. These locations already have established port facilities, good infrastructure and communications, a ready source of well trained and experienced workers who have the necessary engineering, electrical and offshore qualifications and experience, and have a landscape which is already industrial and developed. North Norfolk does not have any of these advantages. The shorter sea distance from the port of Wells to the new offshore locations does favour the companies who are proposing to develop at Wells as it reduces one element of their cost basis, but in carbon terms (which surely is what the whole exercise is about) it is the least efficient location. Effectively the development allows companies to offload their transport costs (and carbon footprint) onto their staff and delivery / supply companies ‐ this is entirely wrong and inappropriate. Everything will have to be transported to Wells from much further distances than would be the case in any of the other locations mentioned, the necessity of improving NNDC Response See comments made in response to representation LD019 above. The proposed LDO is not seeking to compete with either the established port facilities at Great Yarmouth, Lowestoft or The Humber Ports in terms of the supply of specialist vessels and large components in the construction of the Dudgeon and Race Bank schemes, but rather seeks to complement such locations through the Port of Wells being able to fulfil the role as a base for personnel during the survey, project management and operations and maintenance phases of the developments through the use of small support craft from an accessible location relative to the siting of the offshore wind farm developments off the North Norfolk coast. It is considered that comparison of Wells relative to Great Yarmouth / Grimsby in terms of access for personnel and supply of small parts / supplies in terms of carbon footprint Page 33 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response infrastructure (which will certainly mean a larger outer harbour at Wells whatever the indications to the contrary ‐ after all there were lots of statements about the extend and damage that the harbour would cause to the AONB before it was constructed, most of which turned out to be ‘forgotten’ when the thing actually materialised), constructing the industrial estate and buildings, shipping in all materials by road, almost certainly presenting the majority of workers with long commute distances from other parts of the County, will all require the expenditure of carbon vastly in excess of that which would be the case in the other locations where all these elements are either already in place or are close by and more than offsetting any additional carbon ‘expenditure’ in a longer sea journey. After all sea travel is one of the most efficient transport methods in carbon terms, and road is one of the least efficient. 2. Employment The employment aspect that you refer to are important, but I would challenge the perception that it will do much to provide significant high paid employment for existing residents. Experience of the windfarm companies so far has (in my anecdotal experience of knowing people who have tried to get employment / know those who have) indicated that most well‐paid jobs are going to already qualified and experienced persons brought in from outside the area ‐ the much vaunted ‘training provided’ for new applicants is based upon them being already well qualified and trained, not people from low skill / educational backgrounds. ‐ Parachuting new people into an area is fine in overall GDP figures, but it does not solve the underlying problem of is academic as all of these towns by virtue of their coastal locations occupy peripheral locations in terms of connection to the strategic road network serving the East Coast. Certainly Wells via the A1065 and B1105 is slightly closer to the A11 at Barton Mills than Great Yarmouth via the A47 and A11, and is similarly a lesser distance to the A47 and A17 at Kings Lynn than Great Yarmouth. It is acknowledged that during the development of any major civils / construction contracts that workers with specialist skills will be utilised, often from a national / international pool of companies. However, in the operational and maintenance phases of business operations there will be recruitment of increasing numbers of local people and this is already being seen with the SCIRA operations. SCIRA has established strong links with local high schools and colleges Page 34 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response existing low skill / low pay in some sectors of the community ‐ in fact it exacerbates it further by increasing demand for housing by well‐paid persons, and pushing this cost up still further, so displacing more local people. and wishes to recruit local people to support their operations over the next thirty plus years. It is believed that similar opportunities will exist in respect of the Dudgeon and Race Bank schemes. Further an increasingly large number of business support contracts are being let by SCIRA to local Norfolk businesses which are then recruiting additional staff to support this new business and the LDO seeks to position the Wells / Fakenham area positively in attracting new jobs and investment associated with this growing sector of the national and regional economy. The District Council is not aware of any evidence to support the claims that “demand for housing will be exacerbated by well‐paid persons brought in from outside the area”. The local housing market in and around Wells has operated over many years (certainly pre‐dating any investment by offshore wind energy companies) in a way which disadvantages local people through the high value of properties given over to retirement, second and holiday home use which are unaffordable to local people on average wages employed in the Page 35 of 92
ID Name Organisation Support / Object or Comment Comments 3. Landscape The site is located on one of the highest points on the North Norfolk Coast and can be seen from several miles away to the east. Also, large structures will be clearly visible from and dominate the entrance to the North Norfolk Coast AONB. No controls over the appearance of the buildings, lighting or any other aspects will be present. The size and mass of the development will dominate and completely alter the character of the landscape for a very considerable distance around the site and will give the impression to visitors to the area that North Norfolk simply cares nothing for its landscape or its environment. The proposed landscaping around the site would provide no meaningful screening or softening value for at least 30 years due to the size of the buildings (10m+) and the exposed and open location together with the high position within the landscape of the proposed buildings. In effect, the proposed landscaping is misleading and more or less pointless since building lifespans are of around 30 years. For most people, they would never actually experience any significant improvement in the domineering visual intrusions of the buildings during their lifetimes. NNDC Response tourism and agricultural sectors. It would be expected that people employed in the offshore wind energy sector will be paid above current local average rates of pay, allowing them to compete more effectively in the local housing market. Consideration has been given to the siting and height of buildings within the area covered by the LDO which will also be supported by the preparation of a Design Guide and Landscaping Plan. As a result of the consultation responses received some amendments are proposed to the LDO boundary and height of buildings, in an attempt to minimise the impact of any development within the wider landscape. Further it is proposed to commission a Landscape Visual Impact Assessment to identify whether any adverse impacts can be contained / mitigated through appropriate measures – eg planting, restricting building heights, design, use of materials etc. Development delivered through any Page 36 of 92
ID Name Organisation Support / Object or Comment Comments 4. Design and Light Pollution The lack of controls over the size, colour or design and location / setting of the structures within the estate (allowed by the LDO) will be likely to give rise to the use of totally inappropriate and highly visually intrusive / conflicting designs, forms, scales and colours which will exacerbate the damage to the wider landscape setting of the AONB and surrounding countryside. The site is located within a dark skies environment ‐ one which is renowned in the Country and which is actively marketed as a tourist attraction by among others Kelling Heath Holiday Park. The existing Scira offices already have undermined the appearance of the site to the east and this development would place a large, uncontrolled source of light pollution on the edge of one of the few locations in North Norfolk away from other towns etc. 5. Traffic NNDC Response LDO would be supported by a Design Guide which would provide guidance on the scale, massing, height, design and colour of any buildings, as well as providing guidance on lighting, signage, boundary treatment and landscaping. Concern about the level of lighting has been raised in a number of consultation responses, based upon the impact of lighting at the recently developed SCIRA facilities and it would be proposed that further consideration be given to this matter to establish of low level lighting or PIR lighting would be more appropriate in minimising the impact of development on dark skies. The County Council in its capacity as Highway Authority has advised that the B1105 road serving Egmere has Page 37 of 92
ID Name Organisation Support / Object or Comment Comments The site is located at the end of a minor, bumpy B road, in one of the more inaccessible parts of East Anglia. There are no duel (sic) carriageway connections for approximately 35 miles in any direction and the site has no access to any significant public transport links for workers (the occasional bus to Fakenham). All materials, supplies and staff will be moved to and from the site by roads which are inadequate to accommodate the volumes and sizes of vehicles. Rat runs will be created in the network of minor roads through the villages of Walsingham, Wighton, The Creakes, The Burnhams and Thursford which will be totally inappropriate to these minor roadways and very detrimental to the many people who live in these communities. Safety will be compromised and accidents will occur as a direct result of the massively increased volumes of commuter and van type delivery operations cutting across country ‐ the responsibility for all such accidents will lie with the Local Authority and Members. Traffic chaos will be caused in Wells at the junction of Beach Road and Freeman Street if yet more traffic tries to get to the outer harbour NNDC Response capacity to serve any development taken forward under the proposed LDO in principle, subject to the preparation of an Access Strategy, which will be prepared if the District Council resolves to proceed with seeking endorsement of an LDO at this location. It is envisaged that most traffic accessing the development will originate from the south ie from the A148 Fakenham bypass using the B1105 road; limiting the amounts of traffic serving such businesses which might otherwise locate in and around Wells. There is no evidence to suggest that vehicles accessing the site will do so via “rat‐runs” through local villages and minor roads as implied. Any development of the LDO at Egmere will seek to limit the number of vehicle movements associated with access to the port and outer harbour through freight consolidation arrangements and staff mini‐buses operating from the Egmere site. Page 38 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response The adopted Landscape Character Assessment comments that the ecological value of the area is “fairly low” and as the site is some distance from the North Norfolk Coast Special Protection Area / RAMSAR sites, initial comments made by the Council’s Landscape Officers is that an Appropriate Assessment or Environmental Impact Assessment is not required. This conclusion was also reached in respect of the recently approved proposals for an anaerobic digestion plant and solar pv farm development on sites adjoining the proposed LDO. However, in light of comments received through the consultation process it is proposed that the Council should commission a Stage 1 Habitat Survey and Landscape Visual Impact Assessment, in order that these issues can be considered further. 7. Agricultural Land Loss Limited site area – approx. 14 The site occupies Grade 2 agricultural land in an area where hectares on agricultural land. Loss of significant arable cropping takes place. The Council have land considered acceptable in terms 6. Ecology The area contains large over wintering populations of Pink Footed Geese of international importance. No assessment of the impact of the development on ecology has been made Page 39 of 92
ID Name Organisation Support / Object or Comment Comments already supported farmers who opposed the wind turbine cable route on the basis that this would damage and remove good quality agricultural land which is essential for food production in an increasingly uncertain world environment. It would be inappropriate to remove this resource from production. 8. Adverse impact on the setting of historic features The development will have an adverse impact on the setting of a Grade 1 listed parkland (Holkham) and will significantly affect the southern and eastern views of and settings for this wonderful and uniquely intact landscape NNDC Response of wider scale of development and farming land uses. It is not considered that the development will have any detrimental impact on the Grade 1 Listed Holkham Hall and Parkland, but this issue can be considered further as part of the proposed Landscape Visual Impact Assessment. The development will have an adverse impact on the setting of the Egmere deserted village Scheduled Ancient Monument ‐ destroying its sense and character of solitude and setting. It is not considered that the development will have any greater impact on the Egmere “lost village” than existing and recently approved developments to the west of the B1105 – ie the anaerobic digestion plant and solar pv farm. The Wells Harbour Master / 9. Pressure to Develop the Outer Harbour Commissioners have publicly stated that there are no plans / proposals to Regardless of assurances to the contrary, it seems totally enlarge the existing outer harbour at improbable that the already nearly full outer harbour will Wells in connection with the be adequate for a massively enlarged windfarm support role supplied from a 74 acre site. Therefore, just as with the proposed LDO and that the existing Page 40 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response original development of the outer harbour, assurances will be forgotten in the rush to develop and cash in on the subsidies. facility has the capacity to serve further offshore developments. Any such proposals would require separate consultation and approval processes involving the Marine Management Organisation / Natural England and the Environment Agency amongst other bodies. As explained in response to point 1 10. Sequential Test above, the LDO is not intended to A development of this scale and type which is intended to compete with or take development compete with and take development from established port from established port and industrial areas. It is proposed to meet a clear and industrial areas such as the Humber ports should be and expressed business need for sites subject to a sequential test in the interests of the wider and premises in the Wells area to economy of the Country ‐ not just of North Norfolk attempting to grab a rich source of subsidised income. No support the development and operation and maintenance of such test has been applied as far as I am aware and this is offshore wind energy schemes off the contrary to good Planning and the spirit of the National North Norfolk coast from a cost‐
Planning Policy Framework (NPPF). efficient location. The District Council recognises the demand for such sites / premises and has given careful consideration to how such demand might be accommodated locally realising the investment and job‐
creation benefits which will be realised locally as a key plank of the Council’s objectives of seeking to strengthen and diversify the local economy, whilst seeking to minimise the impact on designated landscapes Page 41 of 92
ID Name Organisation Support / Object or Comment Comments 11. Policy Context Overall the development appears to fail to accord with the Council Landscape Character Assessment, has no support from the Council LDF and has biased its proposals towards economic development without any relevant weight being given to social or environmental elements. The NPPF has given clear guidance that all three elements; economic, social and environment are to be given equal weighting and that no one can be said to override the others ‐ particularly where there are strong constraints in the form of high quality landscapes and other environmental considerations such as excessive carbon usage to achieve aims that can be better met in other locations with lower carbon costs NNDC Response and the tourism economy through directing such investment to a single strategic location rather than the development of unco‐ordinated investment in less well suited sites / premises in the immediate area of the town. The District Council has acknowledged in the public exhibition material promoting the LDO that the demand for sites / premises in support of developments of offshore wind energy schemes was expressed following adoption of the LDF Core Strategy and therefore the proposal to establish an LDO in support of such investment is considered to be a reasonable policy response / position for the authority to adopt in seeking to positively plan to accommodate such investment in the District. The Council recognises the statements made in relation to the Egmere site within the Rolling Open Farmland Landscape Character Type and believes that the structural landscaping proposed as part of the LDO seeks to reflect the predominant type of woodland arrangement in the Page 42 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response LCA – ie blocks of mixed deciduous woodland and strong linear hedgerows in mitigating the impact of the proposed development within the wider landscape. Local Development Order Appropriateness I feel that the use of a Local Development Order is inappropriate for a development of this nature in this location. My understanding of this mechanism is that it is primarily intended to encourage development of ‘difficult’ sites such as former industrial land in deprived areas. To use it in an area of high quality landscape, next to an AONB with implications for landscape and social / economic impacts seems entirely wrong and to be intended to circumvent normal democratic scrutiny by the public of factors which are likely to be of great importance to them. Limited Public Consultation / Request for matter to be decided by Independent Inspector Furthermore, I am concerned that the consultation process has only at the 11th hour (resulting from concerned residents requests) included parishes adjacent to the development (North and South Creake, Burnham Market and Thorpe) which are likely to be greatly affected by rat run traffic through their villages, but who are within the Borough of Kings Lynn and WN and were not part of any planned consultation process. The consultation period has not, I understand been extended, although 10 days is hardly Please see comments made at representation LD019 above which address this issue. The District Council does not accept the comments made that there has been limited public consultation in respect of the proposed LDO. The issue has been reported through the EDP and Fakenham and Wells Times on at least three occasions. Further the proposal was the subject of public exhibitions and explanations at meetings of Wells Town Council and Walsingham Parish Council during Page 43 of 92
ID Name Organisation Support / Object or Comment Comments likely to be enough for any reasonable expectation that these authorities could publicise / meet and respond within this timeframe. The publicity and promotion of the proposals has been very limited, and in my extensive discussions with many people, only around 1 in 10 appear to have heard of the proposals. This does not suggest that the consultation has been sufficient or appropriate. Letters which I am aware several people have sent to the local press have not been published, and this gives rise for concern over the openness of the publicity and debate process, not via NNDC, but in a wider context. I feel that it would be helpful to the transparency of the process and would give greater publicity / opportunity for the public to be aware of and contribute to the diverse issues, as well as for the promoters and objectors to present and examine the relative merits and demerits of the proposals, if the matter were to be considered by an independent Government Inspector. I feel that the site is sufficiently large and the impacts / strategic elements sufficiently great to warrant such an approach. NNDC Response February. When the representation was received from a resident of Burnham Thorpe via the office of Henry Bellingham MP, rather than to the District Council direct, on 4th March, details of the proposal and consultation process was immediately sent to the offices of the Borough Council of Kings Lynn and West Norfolk and the parish councils of North and South Creake and Burnham Market, Overy and Staithe with comments invited. To date one parish council has responded in writing offering no objection to the proposal and a second has expressed similar views verbally to the District Council. The District Council does not accept that the proposal is likely to have any significant impact upon communities in West Norfolk or understand why it is felt that there will be rat‐running to/from any development through villages in West Norfolk. The District Council is not able to comment on whether or not letters raising concerns / objections to the proposal have been sent to the press Page 44 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response or why these have not been published. This statement does however contradict previous statements made that knowledge of the proposals was “very limited”. If mindful to pursue the proposal to establish a Local Development Order at Egmere, the Council understands that endorsement of the proposal will be required from the Secretary of State for Communities and Local Government and a statement to this effect is included within the consultation leaflet. The District Council does not believe the proposal for an LDO at Egmere would establish “a massive industrial estate overlooking the AONB” as suggested by this respondent to the consultation process. In my wildest dreams, I would not have considered that it would ever be acceptable to develop a massive industrial estate overlooking the AONB in North Norfolk. Of course it’s only possible because there is a vast artificial subsidy for offshore wind power provided by the public, but I wonder if they would feel that this subsidy is being well spent when it appears to be so inefficient in carbon terms, and damaging in landscape / environment terms? There are clearly much better locations for such an industrial estate which would have minimal detrimental impacts on the environment and much more positive impacts on social / economic factors ‐ The Council believes that the proposal seeks to positively plan for future investment by companies associated with offshore wind energy developments in a location outside of the AONB and which is set against a background of existing (relatively poor quality) industrial development. Page 45 of 92
ID Name Organisation Support / Object or Comment Comments these are Fakenham, Kings Lynn, Gt Yarmouth or the Humber ports ‐ I would urge NNDC to consider the wider regional and national perspective and value of this proposal, and not just concentrate upon trying to annex a source of funds at any cost to local residents, the environment and the wider community by siting it in such an inappropriate location as Egmere. NNDC Response The Council sees the proposal as a positive policy tool directing investment to a single strategic location, supported by a Design Guide which will promote good quality development which takes reference from the recently developed SCIRA facility on Edgar Road. The respondent’s concern over the extent to which offshore wind energy is subsidised is not a policy issue for the local planning authority relevant to any decision to designate a Local Development Order. LDO25 Ms Janet Hill Object LDO26 D J Brown Object Makes exactly the same representation as ID reference LD024 above. I would like to add my name as being in agreement with comment 'LDO 24'. Please see comments made in response to representation LD024 above. Please see comments made in response to representation LD024 above. It is a complete nonsense to even consider this proposal as having any realistic substance. There are plenty of other Norfolk industrial sites or designated land especially in King's Lynn and Saddlebow which would be entirely suitable for this purpose. So why plonk 74 acres of industrial land in the middle of the Norfolk Countryside. I hope your Council will see common sense and reject this matter. Page 46 of 92
ID Name LDO27 Mr Colin Amos Organisation Support / Object or Comment Comments NNDC Response Comments noted and largely addressed in detail in responses to representations LD019 and LD024 above. Object As an avid supporter of NNDC I am in considerable shock and disbelief at the development plans my Council is proposing for Egmere. As noted elsewhere, the District Council does not believe that the proposal will have a detrimental Whilst extensively lauded in your proposal it is unbelievable impact on tourism in that the that no recognition is given to the problems such a majority of vehicle movements development would make including: associated with businesses operating from any LDO at Egmere will not • Use of greenfield land ‐ our greatest asset need to enter the AONB. Further the Development of a site in an area renowned for its proposal seeks to accommodate new natural beauty. job‐creating investment in support of • Detrimental effect on tourist trade. the Council’s stated aims and • Thereby detrimental effect on local economy ‐ as objectives in wanting to strengthen established and proven. and diversify the local economy • Increased pollution through attracting investment in an • Increased traffic on minor roads emerging economic sector at a • Likely increase of road traffic accidents national and regional level; a sector where the average rates of pay These are but some of the objections in bullet points due to exceed current averages in the district associated with the tourism, the fact the consultation closes tomorrow. agricultural, manufacturing and care sectors which make up much of the I wish to make my objection clear to this planning proposal.
district’s economy. The traffic impact of any development has been the subject of discussion with the County Council as Highway Authority who have advised that the B1105 route is capable of Page 47 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response accommodating any volume of traffic likely to be generated by any development taken forward under any LDO, subject to approval of an Access Strategy. LDO28 Tim Venes Norfolk Coast Partnership Comment In planning policy terms, I would not normally expect a development order to be appropriate in this rural location. Fakenham is identified in the LDF / Local Plan as a Principal Settlement and I would expect that this location would be more appropriate. There may be good reasons why Egmere is considered more appropriate than Fakenham, but these are not explained in the leaflet. Although Fakenham is further from Wells, which would mean vehicles from the support facilities had further to travel to Wells outer harbour, I don’t see this as a significant constraint. I appreciate that the Wells Harbour Commissioners may wish to see the employment opportunities provided as close to Wells as possible but locating the LDO area in Fakenham would not preclude people in Wells and other coastal settlements from employment at the LDO site; indeed Fakenham is connected to Wells by public transport, which Egmere is not. This would still retain the job opportunities created within NNDC. The reasons for the District Council proposing to establish a Local Development Order at Egmere in support of investment by companies associated with offshore wind developments off the North Norfolk coast is explained within the consultation leaflet; however with specific regard to why Fakenham is not considered suitable for such development, this is due to the additional costs which would be involved for companies moving staff and supplies from Fakenham to Wells, meaning that enquiries received for sites and premises from companies supporting offshore wind developments have focussed on Wells town and it is understood that Fakenham is considered too far south to be a viable location for such investment over the anticipated minimum thirty year lifetime of such developments. The comment made in respect of public transport provision not serving Page 48 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response the Egmere site is acknowledged and it would be hoped that if the LDO is approved and a number of businesses establish operations at the site that improved public transport services between Wells and Fakenham via Egmere and Walsingham could be established. I note that policy SS2 Development in the Countryside in the LDF provides for ‘renewable energy projects’ to be located in the Countryside, but I understand this to mean projects generating renewable energy, such as wind farms and solar PV arrays, which generally have to be located there because of the space required, rather than buildings to support offshore wind farms, which do not have to be located in the Countryside. And although the Egmere proposal would involve a significant area of ‘brownfield’ it would also involve a larger area of ‘greenfield’ development. Locating the LDO at Egmere therefore appears to be inconsistent with the LDF / Local Plan. If there are sound reasons for preferring Egmere to Fakenham that would over‐ride the LDF / Local Plan, of which I am currently unaware, it becomes necessary to consider potential impacts on the AONB. This policy position is understood by the District Council but preparation of the LDF Core Strategy in 2006/07 pre‐dated licensing approval being granted for offshore wind energy developments off the North Norfolk coast and therefore no allocation of land to accommodate such investment in or around Wells was made. This was because historically there was a very low level of demand for industrial / commercial premises in Wells / the AONB due to the town’s peripheral location. In the context of offshore wind energy developments the town now has an opportunity to exploit its locational advantage in supporting job‐creating investment in a new economic sector over the next thirty years, thereby supporting a Page 49 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response strengthening and diversification of the local economy. The District Council therefore believes that for defined business uses associated with support for offshore wind energy developments an LDO is an appropriate mechanism by which new investment can be accommodated in the district in an expanding sector of the national and regional economy and has consulted on such a proposal on this basis. In proposing the LDO at Egmere, the I note that the proposed LDO area is about 350m south of District Council has given careful consideration to the relationship of the AONB boundary at its nearest point. There are some the site to the Norfolk Coast AONB existing plantations, which help to screen existing and this is acknowledged in the development at Egmere. consultation material, believing that The proposals include provision for buildings up to 18m in making a positive allocation of land height, masts and other structures up to 25m in height plus outside the AONB will reduce the pressure from wind energy further planting. companies and their contractors to seek sites and premises within or New planting would take some time to grow to a height adjoining the town resulting in where it became effective, would be unlikely to screen the higher structures completely and would potentially be less increased traffic within the AONB. effective in winter. Although the addition of new The comments made about the development would be less noticeable than on a purely possible height of buildings which greenfield site because of the existing buildings and plantations at Egmere, there would still be potential for the might be allowed within any LDO is new buildings to be visible from a considerable distance to noted and this issue will be reviewed. The original proposals made the west and north in this open, rolling landscape. Page 50 of 92
ID Name LDO29 Cllr. Peter Terrington Organisation North Norfolk District Council Support / Object or Comment Comment Comments NNDC Response However, having visited the surrounding area for the purpose of assessing potential visual impacts from the Norfolk Coast AONB, I do not consider that these impacts would necessarily be significant. There might be some visibility of new buildings from the B1105 and the minor road running east off this (via Crabb Castle Farm) which demarks the AONB boundary and from the track E of Gallow Hill to the north, at least initially, but I consider that this would be of minor significance and mitigated further in time by the proposed planting, and which would also help to screen the tall existing buildings to the west of the B1105. Visibility from public highways and paths further to the north east appears to be limited and distant. Conditions that would help to mitigate the visual impact of the proposed development include a suitable mix of locally appropriate species for planting schemes, to maximise its screening ability at all seasons, limiting the number and aggregation of taller structures such as masts, and strict conditions on lighting to avoid light spillage and use for longer than necessary. reference to the height of existing buildings at the Bunkers Hill site and this issue will be considered further so as to try and minimise the impact of any development within the wider landscape; although it is noted that the Norfolk Coast Project Officer has commented that as drafted the proposals would not necessarily have a significant visual impact to/from/on the AONB. Whilst I welcome any economic advantages and employment opportunities that will derive from the proposal, I am concerned regarding the level of impact this proposal will have on the surrounding area. There is a danger that the proposal, at Egmere, for the designation of a “local development order”, to accommodate onshore support facilities for offshore wind A Design Guide and detailed Landscaping Plan would seek to promote good quality development. The issue of light pollution has been raised by a number of respondents to the consultation process and will be the subject of further consideration. Comments noted, but in general terms the issues raised have been given careful consideration by the District council in the development of the LDO proposal. The District Council accepts that there will be some direct impacts of Page 51 of 92
ID Name Organisation Support / Object or Comment Comments energy developments, is being considered in isolation. Clearly, the implications of this proposal extend way beyond the parish of Walsingham, in which LDO is located. It is a classic example of “Coastal Zone” development, incorporating both marine and terrestrial elements, which require a more holistic approach to management and regulation of impacts of the proposal. The knock on effects of any development at Egmere are likely to be greatest in Wells, as any development for the wind energy industry, is directly related to the capacity of Wells Harbour to support offshore wind energy developments. NNDC Response the development of an LDO at Egmere on Wells and did consider alternative options for accommodating the demand for sites / premises by offshore wind energy companies and their contractors / suppliers before making the Egmere proposal. This included considering the potential of a number of existing sites and buildings in and around Wells – ie the Lime Pit on Stiffkey Road; the Radio Mast site off the Walsingham Road and future development / re‐
use of existing buildings in / around Maryland – all of which it was felt would result in increasing volumes of traffic being introduced into the town / AONB. Further it was believed that such developments would have had a cumulative impact both within and adjoining the town, which it might have been difficult to assess / manage on an adhoc basis. Consideration was also given to such developments being accommodated at Fakenham, but operationally this was seen as being too far from the port facilities at Wells involving businesses in significant additional costs and not realising the potential Page 52 of 92
ID Name Organisation Support / Object or Comment Comments The Wells Outer Harbour was stretched beyond its design capacity to accommodate construction work vessels associated with the Sheringham Shoal wind farm. The present harbour does not have the capacity to support the construction of the two, much larger, wind farms of Race Bank and Dudgeon Shoal without a level of expansion, which would have unacceptable consequences. Any impacts on the European Marine Site and marine SSI, resulting from the creation of the LDO, would require an Appropriate Assessment to be carried out, prior to development taking place. NNDC Response indirect economic benefits of such investments – in terms of spend on meeting venues, hotels, meals, temporary accommodation for the Norfolk Coast area – which extends beyond Wells, particularly providing an opportunity to strengthen the economy / performance of businesses in Walsingham, which for much of the year has under‐
occupancy of bedspaces, limited demand for food and drink offering etc.. This is primarily a matter for the Wells Harbour Commissioners to consider. Discussions with the Commissioners and a public statement made by the Harbour Master at the meeting of Wells Town Council held on 4th February 2013 indicated that the existing outer harbour facility would have the capacity to service the development of the Dudgeon and Race Bank proposals, whilst continuing to support the operation and maintenance of the Sheringham Shoal scheme, without the need for any further development / expansion. Any such proposals would however require further, separate Page 53 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response consultation and approval processes involving the Marine Management Organisation / Natural England and the Environment Agency amongst other bodies. Corporately the District Council will seek to have discussions with any major offshore wind energy companies about the community The impacts, arising from the construction of the current impacts / benefits of their Wells Outer Harbour, are well documented but do not investments off the North Norfolk feature in the report. They include pressure on available housing stock, holiday accommodation and activities within Coast / in the District. SCIRA already the Marine Recreation Area. Any further development will operate a £100,000 per annum have the effect of enhancing these negative impacts. If this Community Investment Fund and it is understood that Dudgeon Offshore proposal goes ahead, there must be mitigating measures, Wind propose operating a similar through Section 106 contributions, from the wind energy fund the details of which it has companies, to fund new affordable accommodation and marine area leisure facilities in Wells. Contributions should advised it will seek to discuss with the District Council in the coming reflect the potential annual income, for offshore wind months. farms, a large proportion of which is derived from consumer subsidy, in the form of Renewable Energy Certificates (ROCs) Potential Annual Income: Sheringham Shoal (SS) ‐ £348 million. Dudgeon Shoal (DS) ‐ £615 million. Race Bank (RB) ‐ £637 million. Licencing and planning issues, relating to the current Outer Harbour development, are still unresolved and highlight the This is an issue between the Wells Harbour Commissioners and the Marine Management Organisation, rather than the District Council. The District Council is not aware of any Page 54 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response dangers of trying to give preferential treatment to the wind outstanding matters as they relate to energy industry, by fast tracking developments. The Council the outer harbour development. could in danger of repeating this mistake through this proposal to establish an LDO. It has to be questioned, why the wind energy industry is being given preferential treatment? The B1105 corridor is envisaged as a hub for all renewable energy developments. Indeed, approval has been granted for a Solar Farm (48ha) and a Biogas, Anaerobic Digestion Plant (.55ha) on adjacent sites at Egmere. Why is it deemed necessary for these proposals to go through the current planning regime, whereas a less stringent planning regime is being proposed for wind energy development? The LDO proposal covers a further(33ha). The cumulative impact of these three developments comprises over (80ha) and it has to be questioned if an “Industrial Development” of this magnitude is appropriate in the “Countryside”. Furthermore, there are currently no safeguards or restrictions limiting the further development of such developments along the renewable Energy Corridor. Despite wind energy development tourism remains the most important economic activity in North Norfolk. The success of Wells, as a tourist destination, depends to a large extent on its unspoilt Heritage Coastline. Overdevelopment of the port, resulting from development pressure, created by formation of an LDO at Egmere, risks destroying the very things that attract visitors to Wells. It has to be recognised that Wells is the only port in North The District Council does not believe that the proposal to establish an LDO at Egmere in support of developments by offshore wind energy companies necessarily provides preferential treatment to such companies in the way that it suggested, whilst other renewable energy proposals need to have their proposals considered through the established planning processes. The proposed types of development which would be covered by any LDO are offices and warehouses and ancillary telecommunications infrastructure which are considered to be relatively benign developments if supported by a Design Guide which promotes good quality development. This is very different to seeking to provide Permitted Development Rights to more complex applications such as anaerobic digestion plants, biomass proposals, solar pv farms and onshore wind turbines; all of which raise a much wider range of policy issues about which the District Council feels local communities Page 55 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response should have the right to comment through the established planning processes. The types of development proposed to be allowed under the LDO are not considered to raise significant policy issues in their own right, subject to issues of design, landscape impact, highway access etc being addressed upfront through an open public consultation process. Finally, it has to be recognised that an LDO is a devise solely for speeding up the planning process. This is acceptable as The District Council does not believe long as it does not result in a “Democratic Deficit”. Any process which reduces the ability of the public to express approval of an LDO removes the right views in an open, transparent and equitable way has to be of the public to have its say or creates viewed with suspicion. An LDO removes the right of the a democratic deficit. Such Orders public to have its say on planning issues. instead promote early discussion and consideration of such issues by the community and then if approved, allow a simplified planning framework to be operated which creates a more certain and streamlined environment for investment. Norfolk capable of providing support facilities for the offshore wind energy industry, but account has to be taken of all the other activities carried out by various interest groups in the inter‐tidal zone. Port activities are not the only function of this zone: fishing, marine recreation activities at high water, walking, bird watching etc, at low water all compete for space and conflicts have already arisen between wind energy interests and other users. LDO30 D Houghton Object I am a resident along Edgar Road and have recently experienced the 100 fold increase in traffic along this road.......i have already objected and supposedly been reassured about the traffic increase and speed...ITS ALL BEEN LIES......all the various authorities have ignored and continued to IGNORE the existing speed limit and any person/local walking/biking along this road to school or to In proposing the LDO at Egmere the District Council did suggest to the Highway Authority that a speed limit of 40mph be introduced along the length of the B1105 road through Bunkers Hill, Egmere. Page 56 of 92
ID Name LDO31 Ken Hamilton Organisation Norfolk Historic Environment Service Support / Object or Comment Comment Comments NNDC Response work risks THEIR OWN LIFE and this is not acceptable!!!!!!!!!!!!!!!!!!!!!! I/WE are OBJECTING most strongly as our fears have already been ignored. WE HAVE BEEN IN TOUCH WITH ALL THE LOCAL AUTHOURITIES, BUT HAVE BEEN FOBBED OFF WITH RHETORIC AND RUBBISH. I have emails to prove it....... SO NO TO THE PROPOSED DEVELOPEMENT. I am objecting to it because we have two red kites and a rare buzzard, plus marsh harriers and further rare birds that use this region......... the RSPB will be notified....this a place of refuge for these birds and others such as the barn owls etc...../.....do not spoil what is precious. The Council understands the need for any LDO to be supported by an Access Strategy approved by the Highway Authority and will continue to press for the introduction of a speed limit at this location which appears to have significant support of local residents and the wider community, irrespective of their views on the proposed LDO. PLEASE NOTE: THIS IS A RE‐STATEMENT OF COMMENTS MADE DURING PRE‐CONSULTATION ENGAGEMENT WITH NORFOLK HISTORIC ENVIRONMENT SERVICE The proposed development area is described as "miscellaneous buildings associated with a Second World War airfield to the west of the B1105 road, but more recently has seen development of facilities supporting the wider agricultural economy". The proposed development area in fact covers the largely intact technical area of the former airfield (marked as "Brownfield Area"), together with parts of the dispersal areas and land separating the technical area and accommodation blocks. Please see comments made at LDO19 above regarding the proposed commissioning of a Stage 1 Habitat Survey which will assess these issues. Page 57 of 92
ID Name Organisation Support / Object or Comment Comments Surviving buildings include the watch office/control tower (now converted to a private house), two T.2 hangars, one B.1 hangar and a number of Romney and Nissen huts on both sides of the B1105. Despite the addition of a number of agricultural buildings, the site maintains its integrity and character as a former airbase. NNDC Response RAF North Creake was unusual as an airfield ‐ it was built as a decoy site for RAF Docking, then converted into a Heavy Bomber Station. 171 Squadron and 199 Squadron were based at the airfield. Both squadrons were involved in electronic counter measures, and operated both "Mandrel" radar jamming equipment, and dropping "Window" (an early form of anti‐radar chaff). Over 1600 staff were employed at the base at its peak between mid‐1944 and mid‐1945. Following the end of the war, the site was used to store and scrap de Havilland Mosquitoes. Although the base was only operational for a year, it is significant for the work carried out there on electronic counter measures (modern derivatives of which are carried on most modern military aircraft), and for the fact that the airfield was converted from a decoy site to a heavy bomber station. We recommend, therefore, that new build, particularly in the Brownfield Area, respects the airfield layout and the existing airfield buildings through a detailed design guide. We also recommend that the site should be recorded in its current state as a baseline, existing military buildings be retained where possible, and recorded prior their demolition, if retention is not possible. The recording of the site in its current state should be carried out by an Comments noted and proposal now amended to identify area of airfield buildings to the south of Edgar Road for retention within the context of the wider area of LDO development and/or for a photographic record of any other airfield buildings or structures to be carried out in Page 58 of 92
ID Name Organisation Support / Object or Comment Comments individual or organisation with specialist expertise in the recording and interpretation of military aviation heritage. NNDC Response advance of any development which might compromise their futures. The Historic Environment Service are happy to work with the Design and Landscape team in the drafting of the design guide for the LDO to maintain the integrity of the former airfield technical area. LDO32 Mr A & Mrs S Bodill Object Not sure where the reference to a 74 acre industrial estate has come from With reference to the new 74 Acre ‐ EGMERE we wish to as this terminology was not used in put in writing our protest in siting this 74 Acre Industrial the consultation material, but has Estate at EGMERE, we feel the consequence of this action will impact on our village, Burnham Thorpe in a detrimental featured in a number of the later representations received. manner. As you must be aware, Burnham Thorpe is in a conservation North Norfolk District Council does area and a village of outstanding natural beauty. The not share the concerns of residents possibility of industrial buildings along the skyline, and from Burnham Thorpe that the heavy lorries having to use the main road through the designation of an LDO at Egmere will village would destroy the peace and tranquillity of village have any direct impact on their life. village – there will not be buildings “visible on the skyline” from the There must be other sites nearer larger towns that would village or that there would be any be more suitable. reason for heavy lorries serving any development at Egmere to travel through Burnham Thorpe. LDO33 Mrs Margaret Bunting Object I wish to object to the proposal to allow the building of an industrial site at Egmere, which I understand is mainly to serve the Sheringham Shoal Wind Farm and its extensions, for the following substantial reasons: Much of the promised employment will be taken up by Page 59 of 92
ID Name Organisation Support / Object or Comment Comments outside specialists, and by people living in Fakenham, other towns and villages, or even King’s Lynn. This will lead to a large increase in daily traffic at times when the road is normally busy, even so during the tourism and holiday seasons. The road is not suitable for this extra traffic. The geographical position of the site means it would be visible for miles along the coast from the Holkham Estate one of the much publicised charms of this area in the lack of such visual intrusion. NNDC Response Comment is made in response to representations LDO19 and LDO24 above that as offshore wind energy developments move into the operational and maintenance phase there will be increased opportunities for local people to gain employment with companies engaged in this sector. Norfolk County Council in its capacity as Highway Authority was consulted on the proposal to establish an LDO at Egmere and advised that the B1105 road was capable of accommodating the level of development proposed through the LDO, subject to the preparation of an Access Strategy. It is accepted that parts of the site proposed for inclusion within the LDO will be visible from long‐distance views from the east – Binham and Hindringham and from the north, albeit that when viewed from this direction the existing industrial buildings at Bunkers Hill are very prominent in the landscape. The Design Guide and Landscape Plan proposed in support of any LDO will seek to minimise the impact of both existing and any new development in Page 60 of 92
ID Name Organisation Support / Object or Comment Comments The “light loom” at night will be appalling, especially in winter. It is still possible to see the skies here and with the recent concerns about light pollution and “dark skies”, it seems decidedly strange to be promoting the opposite, especially linked to “renewable energy” etc. It would seem far more practical and simpler, to locate this business in Fakenham, which is near enough to Wells, and already has land scheduled for light industrial development.
The vaguely proposed “renewable” businesses on the Egmere site would presumably be connected to the proposed solar power plant? What else is envisaged? All very vague, we’d like to know what there is to know. LDO34 GG & AA Reed Object I find it incomprehensible that there has been no previous notification of this proposition. NNDC Response the wider landscape and it is not believed that the development would have any direct impact on the setting or views from the Holkham Estate. The issue of light pollution has been raised by a number of respondents to the consultation process and will be the subject of further consideration. The proposed LDO seeks to accommodate developments which directly support the operational and maintenance requirements of the offshore wind energy sector – ie offices, warehouses, ancillary facilities and electronic communications equipment to a maximum height of 25 metres; it is not intended that any development on the site will be connected to the development of the solar farm on land to the east of the B1105 and Bunkers Hill. Comments noted and addressed in response to a number of the issues raised above. I most thoroughly object to the proposal. My main concern The proposal has been widely being a large, ugly site should not be put in a rural setting publicised to communities which Page 61 of 92
ID Name Organisation Support / Object or Comment Comments on the route to a small, attractive coastal resort ‐ Wells‐
next‐the‐sea. Also, the local small roads are unsuitable for increased traffic. NNDC Response might be directly affected – ie those in the B1105 corridor between Fakenham and Wells and reported on a number of occasions through the EDP and Fakenham and Wells Times. The proposed site points to a greedy land owner I am sure. LDO35 I. M. Witham Open Spaces Society Object On behalf of the Open Spaces Society I write to object to the proposed Local Development Order [LDO]. We feel that any future development here should continue to be subject to, and thus protected by, the existing planning process, in view of the sensitivity of the location. The location is very rural and, notwithstanding the existing industrial activities located at the site, very largely unspoilt. The North Norfolk District Council states that it has selected this site in view of what it calls "its location outside of the Norfolk Coast Area of Outstanding Natural Beauty, which respects the quality of the landscape and environment around Wells and its importance in supporting the local tourism economy." The relationship of the site to the Norfolk Coast AONB is acknowledged in the consultation material and whilst a matter for consideration, the District Council believes that against the backdrop of existing This is wholly misleading, suggesting that siting the development at Egmere, including a proposed LDO here would somehow "respect the quality of number of large agricultural and the landscape and environment around Wells and its manufacturing buildings, and importance in supporting the local tourism economy." But supported by structural planting, this totally ignores the fact that the proposed LDO is sited development permitted through any within a landscape which is itself largely unspoilt, and of LDO can be satisfactorily much amenity value. In fact, the location falls only barely accommodated in the landscape, outside of the Area of Outstanding Natural Beauty [AONB], without any significant detrimental and the landscape here has a strong relationship with that impact on the AONB designation. Page 62 of 92
ID Name Organisation Support / Object or Comment Comments within the adjacent AONB, including the near‐by Holkham Park. NNDC Response Indeed, whilst expressing some concerns about the proposed LDO the Norfolk Coast Partnership Manager (representation reference LDO28) stated:‐ “However, having visited the surrounding area for the purpose of assessing potential visual impacts from the Norfolk Coast AONB, I do not consider that these impacts would necessarily be significant. There might be some visibility of new buildings from the B1105 and the minor road running east off this (via Crabb Castle Farm) which demarks the AONB boundary and from the track E of Gallow Hill to the north, at least initially, but I consider that this would be of minor significance and mitigated further in time by the proposed planting, and which would also help to screen the tall existing buildings to the west of the B1105. Visibility from public highways and paths further to the north east appears to be limited and distant.” The contribution of the site of the proposed LDO, including established Page 63 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response uses, and the surrounding landscape need to be considered in the context of their value to tourism and The site of the proposed LDO and surrounding landscape recreation alongside their potential are of considerable value for recreation and tourism. A value in supporting new job‐creating rural public path ‐ Great Walsingham Footpath No. 9 ‐ passes through the site, and across fields to the west. The investment, and the District Council considered such matters in making path offers outstanding views in all directions, and these the proposal for an LDO at Egmere, necessarily involve the site of the proposed LDO. The amenity value of this path would be severely compromised relative to such developments in by further large‐scale development over the enlarged area support of investment by offshore proposed for the LDO, especially if individual developments wind energy companies being promoted elsewhere within the local were not subject to the existing planning application area – including immediately process. adjacent to Wells‐next‐the‐Sea and The retention of the existing planning process here would within the AONB. mean that each development proposal would continue to be carefully assessed on its own merits, individually, by the The Great Walsingham Footpath No.9 already passes through the ABN feed local planning authority, with the public having the opportunity to comment on each and every proposal. This mill site between an HGV yard and weigh bridge, staff car park and long‐
would much better safeguard the amenities of the public, term vacant offices and is therefore into the future. unlikely to be compromised or further impacted upon negatively by the LDO proposals. Indeed the proposals would seek to bring about an improvement in the overall quality of the built and natural environment of Bunkers Hill through improvements being made to existing sites and buildings and new / improved structural landscaping being implemented. Page 64 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Please see further comments made at LDO13, LDO19 and LDO24 above regarding the proposed commissioning of a Landscape Visual Impact Assessment which will further consider these issues. LDO36 Mrs Mary Simpson Object In proposing the LDO at Egmere, prior consultation was held with Norfolk County Council in its role as Highway Authority about the traffic impact of any LDO proposal. Agreement was reached that the vast majority of all traffic, but certainly heavy traffic, serving any development at Egmere would access the site via the B1105 Fakenham to Wells road, rather than My house is a listed building and frequently shakes as these placing additional pressure on other large vehicles go close to the house. I am almost frightened local communities. The issues described in Walsingham as they to walk my small grandchildren down the road as the relate to pilgrimage and agricultural vehicles come so close when two are passing and there is traffic exist currently and will not NO footpath. This is only Knight Street but the chaos is everywhere. I realise this objection is dealing only with the have any direct relationship with or traffic in Walsingham but whatever you many plan in traffic relevance to the proposed LDO. routes it WILL affect Walsingham significantly as Egmere is so close. I agree with all the other objections put forward but there is no point in duplicating them here. LDO37 Mr Martin Barrell Comment Thank you for consulting us on the proposed Local Development Order at Egmere. We understand that the Environment Agency I believe that this is an absolutely crazy and irresponsible proposal. Anybody who has the slightest idea of the traffic situation in Little Walsingham will know that it is absolute chaos in the summer and in fact 9/10 months of the year owing to the thousands of pilgrims who come to the Shrines of Our Lady. I live in Knight Street where feed lorries, tractors, coaches you name it use it daily, and often as in the feed lorries quite unnecessarily as a short cut to and from Creake. Comments and proposed draft conditions received appreciated and Page 65 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response will be considered for incorporation designation of an LDO has the effect of granting at least within any Order / Design Guide as outline planning permission for development proposals within the defined area that meet the prescribed definition. appropriate. Based on a review of the information submitted, and considering the nature of the site at Egmere, we currently have no reason to suggest that we would object in principle to development of the type proposed at this location. However, it is likely that we would request that proposals complied with the conditions below, and had regard to the informatives and further information given: Flood risk and surface water drainage Future developments within the proposed LDO area would need to include an appropriate surface water drainage scheme, designed to prevent an increase in flood risk either to the proposed development itself or elsewhere. Each surface water drainage scheme should include the following: • According to the SUDS Manual (CIRIA C697), to mimic the natural processes as closely as possible the SUDS management train is required. This concept is fundamental to designing successful SUDS. It uses drainage techniques in series to incrementally reduce flow rate, volume and pollutants. The hierarchy of techniques that should be considered in developing the management train are prevention, source control, site control, regional control. Prevention can be achieved by the use of good site design and good housekeeping. Page 66 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Source control can be achieved by controlling of runoff at or very near its source (e.g., soakaways, other infiltration methods, green roofs, pervious pavements). Site control can be achieved by management of water in a local area or site (e.g., routing water from building roofs and car parks to a large soakaway or infiltration and detention basin). Regional control can be achieved by management of runoff from a site and several sites (e.g., in a balancing pond). •
An assessment of the potential for the use of infiltration on site. The infiltration rate for the site should be determined through the test pit method outlined in BRE Digest 365. If the infiltration rate is good enough then infiltration drainage SUDS such as soakaways, infiltration trenches, permeable pavements and grassed swales should be used wherever possible (in accordance with the priority given to it in Approved Document Part H of the Building Regulations 2000). SUDS offer significant advantages over conventional piped drainage systems in reducing flood risk by attenuating the rate and quantity of surface water run‐off from a site, promoting groundwater recharge, and improving water quality and amenity. •
If infiltration is not possible then the surface water should be contained in flow balancing SuDS methods which involve the retention and controlled release of surface water from a site. The FRA should show that for a range of rainfall events, from the 1 in 1 year up to and including the 1 in 100 year event Page 67 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response (plus allowances for climate change), the developed rate of runoff to a watercourse can be restricted to the undeveloped (existing/greenfield) runoff rate in the 1 in 1 year rainfall event (calculated using an appropriate method such as IH124). •
If it is not possible to use infiltration techniques or discharge to a watercourse then it may be acceptable to discharge surface water from the new development into an existing sewage system. Anglian Water will need to agree that there is capacity in the sewer network for the proposed runoff rate, which should ideally be restricted to the existing / Greenfield runoff rate. However, our records show that there is no Anglian Water sewer serving this location. •
Sufficient volume of attenuation storage to be provided on the site in order to contain the 100 year critical storm duration with climate change (see Annex B table B.2 of PPS 25 for appropriate climate change allowances) taking into account the infiltration rate and/or the allowable discharge rate. •
It should be ensured that the SUDS scheme is designed so that there is no above ground flooding in the peak duration 1 in 30 year rainfall event and that there is no flooding of buildings in the peak duration 1 in 100 year rainfall event including climate change. •
Climate change will need to be taken into account Page 68 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response by increasing the peak rainfall intensity in line with the guidelines given in Table 5 in NPPF Technical Guidance. •
Plans, drawings and calculations relating to surface water on the proposed site should be provided. •
The surface water scheme should be maintained for the lifetime of the proposed development, and a maintenance schedule developed which is in line with the requirements in the SUDS Manual. If applicable, a condition or recommendation for a surface water drainage scheme could be applied. Suggested wording is as follows: Condition No development shall take place until a surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the local planning authority. The scheme shall subsequently be implemented in accordance with the approved details before the development is completed. The drainage strategy should demonstrate that: • Infiltration drainage is used where site‐specific BRE365 infiltration tests show it to be appropriate. • If infiltration drainage is not appropriate then the rate of surface water run‐off into a watercourse or surface water sewer (with Anglian Water approval) Page 69 of 92
ID Name Organisation Support / Object or Comment Comments •
•
•
•
NNDC Response will not exceed the run‐off from the undeveloped site following the corresponding rainfall event, up to and including the 1 in 100 years critical storm, Sufficient surface water storage volume is provided to contain the 100 years critical storm including climate change over the lifetime of the development in accordance with Table 5 of NPPF Technical Guidance. Plans drawings and calculations of each aspect of the surface water drainage scheme. Modelling to demonstrate that there will be no above ground flooding in the 1 in 30 year rainfall event and no hazardous flooding or flooding of buildings or offsite flows in the 1 in 100 year rainfall event including climate change. Details of the adoption and maintenance of the surface water drainage scheme over the lifetime of the development, in accordance with the requirements in the SUDS Manual. Reason To prevent the increased risk of flooding over the lifetime of the development, both on and off site. Groundwater and land contamination: The majority of the site is located on superficial deposits of sand & gravel, designated as Secondary “A” Aquifer, overlying the Chalk Bedrock, designated as Principal Aquifer, and the southernmost part of the site is situated within a Groundwater Source Protection Zone 3. Any proposed development of this site must therefore have Page 70 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response due consideration of the potential impacts of the development on groundwater and surface water quality during its construction and operation, including from the potential mobilisation of any contaminants that may be associated with the site and the disposal of any potentially contaminated surface water from the development. Land Contamination: It is noted that part of the site is designated as “Brownfield”, including being identified as part of a former airfield, and “works”. Also, according to our records, historic landfill sites are located on site at NGR TF90672 38530 and adjacent to the eastern site boundary at NGR TF 90633 38181. Any land proposed for development that may have been affected by contamination as a result of its previous use or that of the surrounding land, must be subject to a Preliminary Risk Assessment (including a desk study, conceptual model and initial assessment of risk). This is to ensure that the risks to controlled waters are fully understood and can be addressed through appropriate measures, with subsequent investigation, assessment and remediation as necessary. We are satisfied that there are generic remedial options available to deal with the risks to controlled waters posed by contamination at this location. However, further details will be required in order to ensure that risks are appropriately addressed prior to development commencing. Page 71 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response When responding to consultations for individual planning proposals, we would therefore usually suggest that the development should be subject to the following conditions, and informatives/advice. However, in this case you may wish to consider some of these requirements in advance: Condition Prior to each phase of development approved by this planning permission no development / No development approved by this planning permission> (or such other date or stage in development as may be agreed in writing with the Local Planning Authority), shall take place until a scheme that includes the following components to deal with the risks associated with contamination of the site shall each be submitted to and approved, in writing, by the local planning authority: 1) A preliminary risk assessment which has identified: • all previous uses • potential contaminants associated with those uses • a conceptual model of the site indicating sources, pathways and receptors • potentially unacceptable risks arising from contamination at the site. 2) A site investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site. 3) The results of the site investigation and detailed risk assessment referred to in (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation Page 72 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response measures required and how they are to be undertaken. 4) A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in the remediation strategy in (3) are complete and identifying any requirements for longer‐term monitoring of pollutant linkages, maintenance and arrangements for contingency action. Any changes to these components require the express written consent of the local planning authority. The scheme shall be implemented as approved. Condition No occupation <of any part of the permitted development / of each phase of development> shall take place until a verification report demonstrating completion of works set out in the approved remediation strategy and the effectiveness of the remediation shall be submitted to and approved, in writing, by the local planning authority. The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It shall also include any plan (a “long‐term monitoring and maintenance plan”) for longer‐term monitoring of pollutant linkages, maintenance and arrangements for contingency action, as identified in the verification plan. The long‐term monitoring and maintenance plan shall be implemented as approved. Condition No development should take place until a long‐term Page 73 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response monitoring and maintenance plan in respect of contamination including a timetable of monitoring and submission of reports to the Local Planning Authority, shall be submitted to and approved in writing by the Local Planning Authority. Reports as specified in the approved plan, including details of any necessary contingency action arising from the monitoring, shall be submitted to and approved in writing by the Local Planning Authority. Any necessary contingency measures shall be carried out in accordance with the details in the approved reports. On completion of the monitoring specified in the plan a final report demonstrating that all long‐term remediation works have been carried out and confirming that remedial targets have been achieved shall be submitted to and approved in writing by the Local Planning Authority. Condition If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the local planning authority) shall be carried out until the developer has submitted a remediation strategy to the local planning authority detailing how this unsuspected contamination shall be dealt with and obtained written approval from the local planning authority. The remediation strategy shall be implemented as approved. These conditions are to protect and prevent the pollution of controlled waters (particularly groundwater associated with the Secondary and Principal Aquifers underlying the site from potential pollutants associated with current and previous land uses) in line with National Planning Policy Framework (NPPF; paragraphs 109 and 121), EU Water Page 74 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Framework Directive, Anglian River Basin Management Plan and Environment Agency Groundwater protection: Principles and practice (GP3) 2012 position statements. Surface water Infiltration Systems: Informative/advice to applicant: Where soakaways or other infiltration systems are proposed for the disposal of surface water, our general requirements are as follows: 1) Soakaways or other infiltration systems shall only be used in areas on site where they will not present a risk to groundwater, with the depth of soakaway kept to a minimum to ensure that the maximum possible depth of unsaturated material remains between the base of the soakaway and the top of the water table, ensuring that a direct discharge of surface water into groundwater is prevented. 2) Soakaways shall not be constructed in land affected by contamination, where they may promote the mobilisation of contaminants and give rise to contamination of groundwater. 3) Only clean water from roofs shall be directly discharged to soakaway. 4) Systems for the discharge of surface water from associated hard‐standing, roads and impermeable vehicle parking areas shall incorporate appropriate pollution prevention measures. Drainage to soakaway from car parking areas for >50 spaces Page 75 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response should be passed through an oil interceptor before discharging to ground, as should drainage from parking areas that will discharge to a surface watercourse. Further information on the discharge of surface water is available at: http://www.environment‐
agency.gov.uk/business/topics/water/111878.aspx 5) Subject to the approval of the Local Authority, percolation tests should be undertaken to ensure that soakaways will work adequately in adverse conditions. If, after tests, it is found that soakaways do not work satisfactorily, alternative proposals should be submitted. Pollution prevention: In addition to the above, included below are a range of informatives that we would offer in response to proposals for general industrial type development. Some or all of these may apply to development at Egmere: The Environmental Permitting Regulations 2010 make it an offence to cause or knowingly permit a groundwater activity unless authorised by an Environmental Permit which we will issue. A groundwater activity includes any discharge that will result in the input of pollutants to groundwater. All industrial sites have the potential to cause pollution of the water environment, therefore due consideration should be given to the prevention of pollution as early as possible in the design process. Page 76 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Where it is not possible to connect foul drainage to the main sewer and it is proposed to discharge treated effluent to ground or to a surface watercourse, the applicant may require an Environmental Permit from us under the Environmental Permitting Regulations 2010. A permit will only be granted where the risk to the environment is acceptable. Additional ‘Environmental Permitting Guidance’, including when a permit is required, can be accessed via our main website http://www.environment‐
agency.gov.uk/business/topics/water/32038.aspx Proposals involving non‐mains drainage should be considered with regard to the advice in DETR Circular 3/99. Regarding oil storage, in England, the storage of oil (except waste oils) is regulated under the Control of Pollution (Oil Storage) (England) Regulations 2001. The regulations apply to industrial, commercial and institutional sites storing more than 200 litres of oil and private dwellings storing more than 3,500 litres. The regulations require that any facilities for the storage of <oils, fuels or chemicals> shall be provided with secondary containment that is impermeable to both the <oil, fuel or chemical> and water, for example a bund, details of which shall be submitted to the local planning authority for approval. The minimum volume of the secondary containment should be at least equivalent to the capacity of the tank plus 10%. If there is more than one tank in the secondary containment the capacity of the containment Page 77 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response should be at least the capacity of the largest tank plus 10% or 25% of the total tank capacity, whichever is greatest. All fill points, vents, gauges and sight gauge must be located within the secondary containment. The secondary containment shall have no opening used to drain the system. Associated above ground pipe work should be protected from accidental damage. Below ground pipe work should have no mechanical joints, except at inspection hatches and either leak detection equipment installed or regular leak checks. All fill points and tank vent pipe outlets should be detailed to discharge downwards into the bund. More information on the minimum legal requirements is available in ‘Above ground oil storage: PPG 2’. Additional general information, including advice contained our all Pollution Prevention Guidance notes (PPGs), is available at: http://www.environment‐
agency.gov.uk/business/topics/pollution/39083.aspx We would also recommend that developers follow the advice within our publication “Pollution Prevention Pays: Getting Your Site Right” which is available for free from our website at: http://www.environment‐
agency.gov.uk/business/topics/pollution/36641.aspx LDO38 Mr John Downing Walsingham Estate Support We have been pleased to provide Scira Offshore Energy Ltd No response / action required. with land on which to develop their new headquarters adjacent to our existing light industrial site at Bunkers Hill. It is hoped that the inspirational but sympathetic design of Page 78 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response the office building and layout of the site will be a springboard from which further sites within the LDO may be developed for the use of others associated with the Offshore Wind Energy Sector securing new jobs creating investment in this part of the District. Furthermore, we feel that the LDO will stimulate interest in the existing buildings within the area resulting in a much improved environment for users, neighbours and those passing through. We have some concern over the shape and location of the proposed tree planting along the eastern and south‐eastern boundaries of the proposed LDO, which we feel could be adjusted to achieve both a more natural belt and also the minimum effect on the adjacent agricultural land. LDO39 Mr Godfrey Sayers Wiveton Parish Council Object It does seem that whenever large and potentially damaging proposals associated with wind energy come along the public are excluded from any democratic debate. This flies in the face of Localism and is contrary to the democratic principles of the Planning system, which have kept this coast special for so long. The following are issues I wish NNDC to examine. 1. Location There other sites that are far better suited for such development and which offer far more long‐term security. Yarmouth for example is just as convenient for the future development of offshore energy as Wells and unlike Wells has a new outer harbour and established facilities; Wells The comments made in this representation reflect very closely those made in representations LDO19 and LDO24. Please therefore see comments made in response to these representations above. Page 79 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response offers a very limited and insecure future in comparison. At the moment it requires constant dredging to keep an entrance open for relatively small vessels, and is constantly threatened with closure from big storms. Its future development in this direction is also seriously limited by environmental constraints as ‘Environmental Impact Assessments’ have shown. NNDC really do need to talk with Natural England about the future of Wells in this respect. Wells Harbour is also site at the mid‐point of the ‘North Norfolk Cost Area of Outstanding Natural Beauty’, one wonders just how much more wildlife and landscape beauty can be sacrificed at the alter of alternative energy? Wells is also unsuitable logistically as everything will have to be transported to Wells from much greater distances than would be the case in any of the other locations mentioned, constructing the industrial estate and buildings, shipping in all materials by road, almost certainly presenting the majority of workers with long commute distances from other parts of the County, will all require the expenditure of carbon vastly in excess of that which would be the case in the other locations where all these elements are either already in place or are close by and more than offsetting any additional carbon ‘expenditure’ in a longer sea journey. After all sea travel is one of the most efficient transport methods in carbon terms, and road is one of the least efficient. 2. Employment The arguments in respect of employment are the same as those put forward by most developers pushing Page 80 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response inappropriate applications and never hold water. Most of the work will be skilled and will require expertise that does not exist locally and so will have to be brought in, this could also create a need for more housing. The jobs that ‘may’ be created may well be needed as industrialisation reduces the attraction of Wells and this coast as a holiday destination and damages the tourist industry. 3. Landscape The site is located on one of the highest points on the North Norfolk Coast and can be seen from several miles away to the east. Also, large structures will be clearly visible from and dominate the entrance to the North Norfolk Coast AONB. No controls over the appearance of the buildings, lighting or any other aspects will be present. The size and mass of the development will dominate and completely alter the character of the landscape for a very considerable distance around the site and will give the impression to visitors to the area that North Norfolk simply cares nothing for its landscape or its environment. North Norfolk could well qualifying as a Dark sky Reserve which would serve to bring more people to supplement our existing and very successful tourism industry which this proposal threatens in so many ways. 4. Traffic The site is located at the end of a minor, bumpy B road, in one of the more inaccessible parts of East Anglia. There are no duel (sic) carriageway connections for approximately 35 miles in any direction and the site has no access to any Page 81 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response significant public transport links for workers (the occasional bus to Fakenham). All materials, supplies and staff will be moved to and from the site by roads which are inadequate to accommodate the volumes and sizes of vehicles. Traffic chaos will be caused in Wells at the junction of Beach Road and Freeman Street if yet more traffic tries to get to the outer harbour 5. Policy Context Overall the development appears to fail to accord with the Council Landscape Character Assessment, has no support from the Council LDF and has biased its proposals towards economic development without any relevant weight being given to social or environmental elements. The NPPF has given clear guidance that all three elements; economic, social and environment are to be given equal weighting and that no one can be said to override the others ‐ particularly where there are strong constraints in the form of high quality landscapes and other environmental considerations such as excessive carbon usage to achieve aims that can be better met in other locations with lower carbon costs Local Development Order Appropriateness I feel that the use of a Local Development Order is inappropriate for a development of this nature in this location. My understanding of this mechanism is that it is primarily intended to encourage development of ‘difficult’ sites such as former industrial land in deprived areas. To use it in an area of high quality landscape, next to an AONB with implications for landscape and social / economic Page 82 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response impacts seems entirely wrong and to be intended to circumvent normal democratic scrutiny by the public of factors which are likely to be of great importance to them. In a democratic society a development of this scale with such a potential to damage the local environment should be considered by an independent Government Inspector. LDO40 Ms Janet Nuttall Natural England Comment Natural England is a non‐departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Designated Sites The application site is located approximately 5km from the North Norfolk Coast Site of Special Scientific Interest (SSSI). This SSSI is part of the North Norfolk Coast Special Protection Area (SPA). European sites (including SPAs) fall within the scope of the Conservation of Habitats and Species Regulations 2010. Under Regulation 61 of the Conservation of Habitats and Species Regulations 2010 an appropriate assessment needs to be undertaken in respect of any plan or project which is: (a) likely to have a significant effect on a European site (either alone or in combination with other plans or projects); and (b) not directly connected with or necessary to the management of the site Should a Likely Significant Effect on a European / In light of the comments made by Natural England and other respondents regarding the possible visual and environmental impact of designating a Local Development Order at Egmere, the District Council proposes commissioning a Landscape Visual Impact Assessment and Stage 1 Habitat Survey in order that these issues and any potential mitigation measures can be considered in further detail. Page 83 of 92
ID Name Organisation Support / Object or Comment Comments Internationally designated site be identified or be uncertain, the competent authority (in this case the Local Planning Authority) may need to prepare an Appropriate Assessment, in addition to consideration of impacts through the EIA process. Reg 78 of The Habitats & Species Regulations 2010 refers to Local Development Orders: Local development orders 78. A local development order may not grant planning permission for development which— (a)is likely to have a significant effect on a European site or a European offshore marine site (either alone or in combination with other plans or projects); and (b)is not directly connected with or necessary to the management of the site. Therefore any LDO which will result in a likely significant effect will not be compliant with the Habitat Regulations. This requirement is also outlined in Circular 1/06 (Guidance on changes to the Development Control System): “LDOs are restricted from permitting development that is likely to have a significant effect on a European site. This restriction of the power to make an LDO covers potential development not only on such a European site, but also development in the vicinity that might affect the site.” (Para 18, Circular 1/06) Therefore is it vital to understand how the LDO may affect European sites before it is progressed further in order to ensure that the LDO only contains development that is appropriate in the context of the relevant legislation. Development listed in Schedule 1 of the Environmental NNDC Response Page 84 of 92
ID Name Organisation Support / Object or Comment Comments Impact Assessment Regulations 2011 is not permitted through an LDO and Schedule 2 development can only be permitted subject to compliance with the EIA regulations. The LPA should ensure they are compliant with the requirements of the Habitats Directive and Regulations before adopting an LDO. Natural England expects a screening process to be carried out if a Local Authority intend to submit an LDO, in order to accord with the EIA regulations and Habitats Regulations. Some LPAs have carried out an “Integrated Impact Assessment” to accompany a draft LDO using existing evidence covering not only our requirements but those from other statutory bodies such as the Environment Agency and English Heritage. Whilst we believe it unlikely that the development proposed will have an adverse effect on the special interest features of the North Norfolk Coast SPA, it is difficult to know this for certain given the limited information currently available. We would expect sufficient information to be provided to demonstrate that proposals will not have a significant effect on the European site, in accordance with the above. Landscape The site is within 300m of the Norfolk Coast Area of Outstanding Natural Beauty (AONB). Natural England considers that this development is likely to affect landscape character in this locality. We would advise that a landscape and visual impact assessment should be undertaken. Such an assessment should be based on good practice guidelines NNDC Response Page 85 of 92
ID Name Organisation Support / Object or Comment Comments such as those produced jointly by the Landscape Institute/Institute of Environmental Assessment 2002 (Landscape Institute and Institute of Environmental Management and Assessment (2002, 2nd edition): Guidelines for Landscape and Visual Impact Assessment‐ Guidance for England and Scotland). Soil and Agricultural Land Quality Soil is a finite resource that fulfils many important functions and services (ecosystem services) for society, for example as a growing medium for food, timber and other crops, as a store for carbon and water, as a reservoir of biodiversity and as a buffer against pollution. It is therefore important that the soil resources are protected and used sustainably. The applicant should consider the following issues as part of environmental assessment: 1. The degree to which soils are going to be disturbed/harmed as part of this development and whether „best and most versatile‟ agricultural land is involved. This may require a detailed survey if one is not already available. For further information on the availability of existing agricultural land classification (ALC) information see www.magic.gov.uk. Natural England Technical Information Note 049 ‐ Agricultural Land Classification: protecting the best and most versatile agricultural land also contains useful background information. 2. If required, an agricultural land classification and NNDC Response Page 86 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response soil survey of the land should be undertaken. This should normally be at a detailed level, eg one auger boring per hectare, (or more detailed for a small site) supported by pits dug in each main soil type to confirm the physical characteristics of the full depth of the soil resource, ie 1.2 metres. 3. The assessment should provided details of how any adverse impacts on soils can be minimised. Further guidance is contained in the Defra Construction Code of Practice for the Sustainable Use of Soil on Development Sites. If however you consider the proposal has significant implications for further loss of „best and most versatile‟ agricultural land, or if you advise us of any specific points on which you need advice, we would be pleased to discuss the matter further. Protected species The Local Planning Authority (LPA) in exercising their functions „must have regard to the requirements of the Habitats Directive so far as they may be affected by the exercise of those functions‟ (Regulation 9(5) of the Habitats Regulations). In order to comply with this duty the LPA can only grant planning permission for development that would affect a European Protected Species on the basis that: •
•
The proposed development is in accordance with Article 12(1) of the Habitats Directive, which relates to the protection of species. The proposal would be likely to receive a Protected Page 87 of 92
ID Name Organisation Support / Object or Comment Comments Species license from Natural England, if required. If the site of the proposed LDO contains habitats that suggests protected species may be present or there is existing information that suggests particular protected species may be present on site; then Natural England recommends that further survey work should be undertaken, before formal adoption of the LDO, with respect to the protected species identified. This would ensure that appropriate mitigation can be incorporated into the LDO and where necessary conditions can be applied to ensure no detrimental harm to protected species. Other advice We would expect the Local Planning Authority (LPA) to assess and consider the other possible impacts resulting from this proposal on the following when determining this application: •
•
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local sites (biodiversity and geodiversity); local landscape character; local or national biodiversity priority habitats and species. Biodiversity enhancements This application may provide opportunities to incorporate features into the design which are beneficial to wildlife, such as the incorporation of roosting opportunities for bats or the installation of bird nest boxes. The authority should consider securing measures to enhance the biodiversity of the site from the applicant, if it is minded to grant NNDC Response The issues raised through these comments can be incorporated into Page 88 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response the Design Guide and Landscaping permission for this application. This is in accordance with Paragraph 118 of the NPPF. Additionally, we would draw Plan, as appropriate. your attention to Section 40 of the Natural Environment and Rural Communities Act (2006) which states that 'Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity'. Section 40(3) of the same Act also states that 'conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat'. We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us. LDO41 Mrs Su Hamilton Burnham Overy Parish Council Comment Thank you for the opportunity to comment on the proposal No response / action required. for a local development order on land at Egmere. Burnham Overy Parish Council have no objections to the proposals. LDO42 Will Fletcher English Heritage Comment We are grateful for the opportunity to comment at this early stage in relation to the proposed Local Development Order (LDO) on land at Egmere, Norfolk, as described in your Public Consultation document and letter. English Heritage does not object to the overarching principle of designating areas of land for specific development under a LDO. In this case however, we would like to raise a number of concerns in relation to this location. Please see English Heritage Advice below. English Heritage Advice It is important to recognise that there are important historic environment assets in the vicinity of the LDO including the The concerns of English Heritage as to any impact the proposed LDO might have upon designated heritage assets at Holkham Hall and Park and the Egmere “lost village” can be considered further through the commissioning of the Landscape Visual Impact Assessment. Page 89 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response Scheduled Monument of Egmere village, a deserted medieval village which includes the ruined Grade II* listed church and the Grade I registered Park and Garden at Holkham Hall estate. This is an important landscape, with specific designed views, avenues and vistas. The park also includes a number of highly valued listed assets within it, including amongst others, the Grade I listed Triumphal Arch. It is important to recognise that part of the significance of these assets is derived from their setting, and in particular from the landscape in which they are seen and experienced. Any development which impacts upon the setting of the assets would therefore bring a degree of harm to those assets. In policy terms, we would like to draw the local authority’s attention to the planning policies in the NPPF which relate to the historic environment. In our view, any policies developed for the LDO will need to take into account these policies. In particular, the presumption in favour of sustainable development (paragraph 14) and the core planning principle, which states the importance of seeking to ‘ conserve heritage assets in a manner appropriate to their significance, so that that they can be enjoyed for their contribution to the quality of life of this and future generations ;’ (NPPF pp6). In addition, we would also draw attention to paragraph 132, where ‘great weight’ is given to the conservation of assets. In relation to this specific case, I do not think we are in a position at this stage to accept, or object to the principle of this proposal, as there is insufficient information in relation Page 90 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response to the kinds of development that are being proposed here and their likely impacts. We recognise that the proposal could have a negative impact upon designated heritage assets and we would be extremely concerned about impacts through height, e.g. masts, chimneys, turbines, fencing or tall buildings. Or from large or massed development that are visible from the assets or within direct lines of sight. We note therefore with concern building heights up to 18m are proposed. These buildings and any ancillary associated structures such as fencing or masts could cause further harm to the setting of the assets. We would welcome the opportunity to work with the LPA to better understand the nature of the proposed development and to develop an approach which will ensure there is no harm to the setting of heritage assets. In our view however, the LDO should not be granted unless a full impact assessment is undertaken. This will be needed to demonstrate that any proposed development within the area designated under the LDO will not have a harmful impact upon the setting of heritage assets. Elements of the proposals for associated infrastructure may also need to be restricted in order to ensure harm is reduced. The council will also need to take full account of the principles and tests established for the historic environment within the NPPF and ensure this is implemented in the policies for this LDO. We would also like to bring to the attention of the council the importance of the historic landscape in this part of Norfolk and note that there are also a number of important Grade II listed buildings within the vicinity of the proposal that will need to be considered. We would also ask that undesignated archaeological assets taken into account and Page 91 of 92
ID Name Organisation Support / Object or Comment Comments NNDC Response that the local authority’s archaeological advisors are consulted to ensure an appropriate mitigation strategy is developed. LDO43 John Clements Borough Council of Kings Lynn and West Norfolk Support with conditions The Borough Council supports the proposed Local Development Order, subject to 1) Careful control of building and telecommunications structure heights; lighting; landscape / screen planting; and building colour; and 2) Limiting the height of external storage; in order to ensure no adverse impact on the landscape in the locality, including that within West Norfolk, and on the landscape, scenic beauty and views from the Norfolk Coast AONB. These comments are noted and which it would be proposed would be controlled through the wording of the Local Development Order’s Schedule of Development and the Design Guide. Page 92 of 92