Planning Policy & Built Heritage
Working Party
Please Contact: Linda Yarham
Please email: linda.yarham@north-norfolk.gov.uk
Please Direct Dial on: 01263 516019
7 January 2015
A meeting of Planning Policy & Built Heritage Working Party will be held in the Council Chamber at
the Council Offices, Holt Road, Cromer on Monday 19 January 2015 at 10.00am.
At the discretion of the Chairman, a short break will be taken after the meeting has been running for
approximately one and a half hours.
Members of the public who wish to ask a question or speak on an agenda item are requested to arrive at
least 15 minutes before the start of the meeting. It will not always be possible to accommodate requests
after that time. This is to allow time for the Committee Chair to rearrange the order of items on the
agenda for the convenience of members of the public. Further information on the procedure for public
speaking can be obtained from Democratic Services, Tel: 01263 516010, Email:
democraticservices@north-norfolk.gov.uk
Anyone attending this meeting may take photographs, film or audio-record the proceedings and report
on the meeting. Anyone wishing to do so must inform the Chairman. If you are a member of the public
and you wish to speak on an item on the agenda, please be aware that you may be filmed or
photographed.
Sheila Oxtoby
Chief Executive
To: Mrs S Arnold, Mr M Baker, Mr B Cabbell Manners, Mr N Dixon, Mrs A Green, Mrs P Grove-Jones,
Mr P High, Miss B Palmer, Mr R Reynolds, Mr P Williams, Mr D Young
All other Members of the Council for information.
Members of the Management Team, appropriate Officers, Press and Public
If you have any special requirements in order to attend this meeting, please
let us know in advance
If you would like any document in large print, audio, Braille, alternative format or in
a different language please contact us
Chief Executive: Sheila Oxtoby
Corporate Directors: Nick Baker and Steve Blatch
Tel 01263 513811 Fax 01263 515042 Minicom 01263 516005
Email districtcouncil@north-norfolk.gov.uk Web site northnorfolk.org
AGENDA
1.
APOLOGIES FOR ABSENCE
To receive apologies for absence, if any.
2.
PUBLIC QUESTIONS
3.
MINUTES
(attached – p.1)
To approve as a correct record the Minutes of a meeting of the Working Party held on 22
September 2014.
4.
ITEMS OF URGENT BUSINESS
To determine any other items of business which the Chairman decides should be considered
as a matter of urgency pursuant to Section 100B(4)(b) of the Local Government Act 1972.
5.
DECLARATIONS OF INTEREST
Members are asked at this stage to declare any interests that they may have in any of the
following items on the agenda. The Code of Conduct for Members requires that declarations
include the nature of the interest and whether it is a disclosable pecuniary interest.
6.
NATIONAL CHANGES TO AFFORDABLE HOUSING AND OTHER PLANNING
OBLIGATIONS.
(Report attached – page 5)
This report outlines the changes that government has made to the process for requiring
affordable housing and other ‘planning gain’ via Section 106 Agreements when determining
applications for planning permission.
7.
ROLL FORWARD OF AONB MANAGEMENT PLAN
(Report attached – page 9; Appendix 1 – page 12)
Outlines the content of the Norfolk Coast Area of Outstanding Natural Beauty Management
Plan 2014-2019 and recommends its approval.
8.
FAKENHAM DEVELOPMENT BRIEF
(Report attached – page 22; Appendix 2 – page 25)
This report summarises the responses to a consultation relating to a Development Brief for
the allocated development site at Fakenham and recommends that an amended Brief is
approved as a basis for determining future planning applications on the site.
9.
EXCLUSION OF PRESS AND PUBLIC
To pass the following resolution (if necessary):“That under Section 100A(4) of the Local Government Act 1972 the press and public be
excluded from the meeting for the following items of business on the grounds that they
involve the likely disclosure of exempt information as defined in Part I of Schedule 12A (as
amended) to the Act.”
10.
TO CONSIDER ANY EXEMPT MATTERS ARISING FROM CONSIDERATION OF THE
PUBLIC BUSINESS OF THE AGENDA
22 SEPTEMBER 2014
Minutes of a meeting of the PLANNING POLICY & BUILT HERITAGE WORKING PARTY
held in the Council Chamber, Council Offices, Holt Road, Cromer at 10.00 am when there
were present:
Councillors
B Cabbell Manners (Chairman)
Mrs A R Green
Mrs P Grove-Jones
D Young
R Reynolds
P Williams
Officers
Mr M Ashwell – Planning Policy Manager
(21)
APOLOGIES FOR ABSENCE
Apologies absence were received from Councillors Mrs S A Arnold, M J M Baker, N
D Dixon, P W High and Miss B Palmer.
(22)
MINUTES
The Minutes of the meeting held on 19 May 2014 were approved as a correct record
and signed by the Chairman.
(23)
ITEMS OF URGENT BUSINESS
The Chairman stated that there were no items of urgent business which he wished to
bring before the Working Party.
(24)
DECLARATIONS OF INTEREST
No interests were declared.
(25)
DUTY TO CO-OPERATE
The Planning Policy Manager explained that the Regional Spatial Strategy had now
been replaced by the Duty to Co-operate on strategic issues when preparing Local
Plans. This was a formal duty which applied to all public authorities at both Officer
and Member level and would be subject to a legal and soundness test when plans
were examined by an Inspector.
A Working Group of Officers and Members from authorities and other bodies across
Norfolk had been set up to consider the matter.
All local authorities in the County were at different stages of post-2004 plan-making,
with North Norfolk being the only authority with a fully adopted Core Strategy and
Site Allocations Development Plan. However, it was likely that each authority would
be reviewing their plan documents for the period 2016-2036. The Working Party had
developed a schedule which set out a number of elements where co-operation could
be desirable and a timetable was being considered.
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19 January 2015
A Member Forum had also been set up, which had no executive powers but would
report to each Authority’s Executive. Reports were likely to come through the
Planning Policy & Built Heritage Working Party for consideration prior to submission
to Cabinet.
The Working Party noted the report.
(26)
STRATEGIC HOUSING MARKET ASSESSMENT
The Planning Policy Manager stated that a Strategic Housing Market Assessment
(SHMA) had been commissioned by five of the Norfolk District Councils. The
preparation of a SHMA was a requirement of the National Planning Policy
Framework, and formed part of the evidence which would inform the review of the
Local Plan in terms of housing allocations.
The Planning Policy Manager explained that it was anticipated that housing delivery
would be back on target during 2018. Development of the large allocations was likely
to take place over the next 3 to 5 years, following which housing delivery would
reduce. It was therefore necessary to review the Local Plan to allocate more sites.
Councillor P Williams requested a graph showing the developments which had been
commenced and the development which was known to be coming forward. The
Planning Policy Manager stated that he would prepare a detailed forecast for the
allocated sites.
The Planning Policy Manager presented the emerging findings from the Strategic
Housing Market Assessment (SHMA).
The Working Party raised concerns regarding the functional relationship between
settlements as assessed by the consultants. Members considered that there were
omissions with regard to commuter links between the towns and Norwich, and that
some of the links shown did not reflect the true picture. The Planning Policy
Manager stated these were preliminary findings and that there would be more clarity
as to the basis of the findings when the final document was published.
The Working Party also questioned the housing market area boundaries. Members
considered that Cromer, Sheringham and Holt were better connected to Norwich
than North Walsham, and that Fakenham was an important commuter town for
Norwich, Kings Lynn and Dereham.
The Planning Policy Manager explained that evidence had shown that many people
commuted from North Walsham to Norwich. The diagrams in the presentation
reflected the evidence, rather than the perception of what the evidence should show.
The Planning Policy Manager stated that the demographic projections had been
made by an agreed national methodology which had been tested and any necessary
changes would be made at the end of the process. They were a snapshot of a point
in time and the starting point had to be revisited regularly to ensure that they were as
accurate as possible.
Councillor P Williams considered that the shortfall should be factored in and two
graphs produced to include the numbers on the housing list.
The Planning Policy Manager stated that much of the growth was in-migration,
without which there would be negative growth.
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19 January 2015
The Working Party questioned whether there was a typographical error in the report
in respect of the average annual growth figure.
Councillor P Williams referred to proposals by some authorities to require planning
permission to be sought for second homes. The Planning Policy Manager explained
that they were seeking a change to the Use Classes Order to enable them to be
controlled. It was unlikely that the Government would make such a change, but if
they did so it would enable Councils to set their own policies. The Working Party
discussed the advantages and disadvantages of second homes to the District. The
Planning Policy Manager stated that placing restrictions on the use of new dwellings
as second homes would only increase the demand for existing, unrestricted dwellings
as second homes and would be difficult to enforce.
The Working Party noted the report and requested more information and clarity
around the methodology used when the final report was submitted for consideration.
(27)
GROWTH STRATEGY BEYOND 2016
PROCESS AND TIMETABLE FOR LOCAL PLAN REVIEW
The Planning Policy Manager stated that it was necessary to consider reviewing the
Local Plan and suggested that the review commence in May 2015 following the
elections. He requested that the Working Party resolve to recommend to Cabinet the
approach suggested in the report.
The Chairman referred to proposed new Government legislation on barn
conversions.
The Planning Policy Manager stated that the Government had already made a
number of amendments to planning legislation and more changes were under
consultation in order to streamline the process and reduce the amount of
development which required planning permission. The proposed changes in respect
of barn conversions related only to barns on agricultural holdings which were
registered at the time the announcement was made, and would allow 450 m2 to be
converted to no more than three dwellings. This would be done through the prior
notification process and there would be limited circumstances to refuse. He
expressed concern that this approach would allow very poor agricultural buildings to
become dwellings, whereas buildings which were not on agricultural holdings would
be subject to the ‘worthy of retention’ test.
At the request of Councillor P Williams, the Planning Policy Manager outlined the
possible cost implications of the plan review. A detailed Project Plan including
budgetary information would be prepared.
Councillor Mrs P Grove-Jones questioned why there was a need to demonstrate a
five-year housing land supply.
The Planning Policy Manager stated that without a five-year land supply the
development industry would be unable to plan to meet development need.
Developers were taking options on land for 10-15 years and it was the Local
Planning Authority’s role to give them certainty that they would be able to build. It
also helped utility suppliers to plan for the future.
In answer to a question by Councillor Mrs A R Green, the Planning Policy Manager
stated that most of the demand for new housing was from inward migration. .
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It was proposed by Councillor R Reynolds, duly seconded and
RESOLVED unanimously
1.
That a recommendation be made to Cabinet that the Local Plan review
should commence in May 2015.
2.
That a detailed Project Plan, including detailed budgetary information, is
prepared for consideration by the Working Party
The meeting closed at 11.14 am.
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Agenda item __6__
PUBLIC BUSINESS – ITEM FOR DECISION
NATIONAL CHANGES TO AFFORDABLE HOUSING AND OTHER PLANNING
OBLIGATIONS.
This report outlines the changes that government has made to the process for requiring
affordable housing and other ‘planning gain’ via Section 106 Agreements when determining
applications for planning permission.
1. Introduction
1.1 The grant of planning permission for the development of land is often subject to conditions
or formal legal agreements which are necessary to make a particular development proposal
acceptable in planning terms. What is required to make a development acceptable is usually
prescribed in locally adopted planning policies which may require, for example, a particular
proportion of affordable housing or a financial contribution towards the funding of additional
school places. Many Authorities will require such contributions from relatively small scale
developments with those that have opted to introduce the Community Infrastructure Levy (not
North Norfolk) requiring tariff payments for each new dwelling built.
1.2 Government has made changes to the National Planning Practice Guidance in relation to
affordable housing and other obligations secured through the planning application process.
These have already come into effect and should be taken into account in relation to all new and
undetermined planning applications. The Guidance introduces new nationally applied
thresholds to the size of developments that can be required to contribute towards such
contributions including the introduction of a new development size threshold below which
affordable housing contributions should no longer be required. The effect of these changes is
that many smaller scale development proposals will now be exempt from affordable housing
contributions notwithstanding that such contributions may be required by adopted planning
policies. Furthermore for some medium sized developments (6-11 dwellings) any contribution
towards affordable housing can only be made in the form of a financial contribution rather than
provision of affordable units on the development site itself. The guidance states:
‘There are specific circumstances where contributions for affordable housing and tariff style
planning obligations (section 106 planning obligations) should not be sought from small scale
and self-build development.
•
contributions should not be sought from developments of 10-units or less, and which have a
maximum combined gross floorspace of no more than 1000sqm.
•
in designated rural areas, local planning authorities may choose to apply a lower threshold
of 5-units or less. No affordable housing or tariff-style contributions should then be sought
from these developments. In addition, in a rural area where the lower 5-unit or less threshold
is applied, affordable housing and tariff style contributions should be sought from
developments of between 6 and 10-units in the form of cash payments which are commuted
until after completion of units within the development. This applies to rural areas described
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under section 157(1) of the Housing Act 1985, which includes National Parks and Areas of
Outstanding Natural Beauty’.
2. Impact in North Norfolk
2.1 Adopted planning policy currently seeks to secure affordable housing contributions from all
schemes of 10 dwellings or more in towns and 2 dwellings or more in villages. For a temporary
period (until Dec 2015) the Housing Incentive Scheme raises the site size threshold in villages
to 10 dwellings provided quicker commencement of development is secured. In the main the
Council aims to secure on-site provision of affordable dwellings but in some limited
circumstances will accept the payment of a commuted sum. Other types of contribution, such as
provision of public open space, are not usually required on schemes of less than 10 dwellings
(Core Strategy Policy CT2 applies)
2.2 Outside of the towns much of North Norfolk is either within the AONB or is designated as a
Rural Area under Section 157 of the Housing Act. The Council may therefore choose to adopt
the lower unit number threshold of 5 dwellings, or apply the national threshold of 10 dwellings. If
the 5 dwelling threshold is adopted, for schemes of 6-11 dwellings, the Council may only secure
affordable housing in the form of a commuted sum payment rather than via on site provision.
(See Table 1 for further clarification)
Table 1 –Existing local and new national obligation thresholds.
Location
Adopted Policy requirement
Housing Incentive
Scheme requirement
until December 2015
New National Standard
requirement.
45% affordable housing on
all schemes of 10 or more
dwellings.
No affordable housing
on schemes of 9 or
fewer units.
No affordable housing
on schemes of 10 units
or less.
No affordable housing on
schemes of 9 or fewer
units.
20% affordable housing
on all schemes of 10 or
more dwellings in
defined parts of the
district subject to quick
completion. 45%
affordable housing if
quick completion not
achieved.
45% affordable housing
or 20% under Incentive
Scheme on all
proposals of 11 or more
dwellings.
50% affordable housing on
all proposals of 2 or more
dwellings
No affordable housing
on schemes of 9 or
fewer units.
North Norfolk may
choose to adopt a
policy of requiring a %
of affordable housing
on schemes of 6 or
more units otherwise
the national dwelling
AFFORDABLE HOUSING OBLIGATIONS
All Towns
Selected
Service
Villages
20% affordable housing
on all schemes of 10 or
more dwellings in
defined parts of the
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19 January 2015
district subject to quick
completion. 50%
affordable housing if
quick completion not
achieved.
number threshold of 11
or more units should be
applied. The % of
affordable housing that
can be required is not
specified in the
guidance but is
assumed to be that
included in adopted
local authority policies
ie 50% in the case of
North Norfolk.
In the case of schemes
of 6 -11 dwellings
contributions may only
be collected in the form
of commuted sum
payments. Schemes of
11 plus may continue to
require on site
provision.
Countryside
Policy Area
New build market housing
not permitted unless shown
to be necessary to fund
rural exceptions
development of affordable
dwellings and a small
number of other
exceptions.
Market housing not
permitted unless shown
to be necessary to fund
rural exceptions
development of
affordable dwellings and
a small number of other
exceptions.
Market housing not
permitted unless shown
to be necessary to fund
rural exceptions
development of
affordable dwellings
and a small number of
other exceptions.
Building conversion
schemes are subject to a
50% affordable housing
requirement on schemes of
two or more units
Building conversions
need not contribute
towards affordable
housing if nine or fewer
units are proposed and
quick commencement is
secured.
New threshold of 5
units would apply if the
Council chooses to
adopt the lower site
size threshold.
OTHER OBLIGATIONS
Adopted Core Strategy policy CT2 allows for contributions towards a wide range of physical and
social infrastructure including public open space, off site road improvements, funding of school
places and libraries and other community facilities which are necessary to make a development
acceptable. The policy is only applicable to proposals for 10 or more dwellings so the new
national threshold, also 10 dwellings, will not impact on the District Councils approach.
Note: None of the revised national thresholds restrict the option open to applicants to make a
case that any given proportion of affordable housing is not viable.
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19 January 2015
3. Decision Required.
3.1 Does the Council wish to adopt the lower threshold of five dwellings in the rural area or opt
for the national threshold of more than 10 dwellings?
3.2 The national exemptions to the new threshold of ten dwellings below which affordable
housing should not be required recognizes the particular pressures associated with the
provision of affordable housing in National Parks, Areas of Outstanding Natural Beauty and
some specifically designated rural areas (high house prices, lower wages, and policies of
development constraint which limit the opportunity to address need). In North Norfolk the need
for affordable housing in the rural parts of the District is high and this was influential in the
adoption of current policies that require half of all housing on schemes of two or more units to
comprise affordable homes.
3.3 Currently setting the threshold for affordable housing at 5 dwellings would be at odds with
the recently extended Housing Incentive Scheme which already raises this particular threshold
to 10 dwellings. Logically any decision concerning revised affordable housing thresholds should
be considered as part of the next review of the Housing Incentive Scheme.
4. Recommendation to Cabinet
That the Council indicates that it will not currently introduce a threshold of five dwellings in those
parts of the District designated as AONB or defined as a Rural Area under Section 157 of the
Housing Act and will reconsider the position as part of the review of the Housing Incentive
Scheme in December 2015.
(Source: Mark Ashwell, Planning Policy & Property Information Manager, 01263 516325)
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19 January 2015
Agenda item __7__
PUBLIC BUSINESS – ITEM FOR DECISION
ROLL FORWARD OF AONB MANAGEMENT PLAN
Outlines the content of the Norfolk Coast Area of Outstanding Natural Beauty
Management Plan 2014-2019 and recommends its approval.
1. Introduction
1.1 The Norfolk Coast Area of Outstanding Natural Beauty (AONB) was designated in
1968. The current 5-year Norfolk Coast AONB Management Plan, published in 2009, is
being reviewed and updated to produce the next 5-year plan, as required by the
Countryside and Rights of Way (CRoW) Act. The draft Management Plan 2014-19 sets
out background information together with a 20-year vision and 5-year objectives and
policies for the management of the area. It is recommended by a Management Group
for the AONB which includes representatives of the local authorities covering the Project
Area.
1.2 The Management Plan is not part of the statutory Development Plan for the area
and its preparation is not subject to independent examination but it is ‘tied-in’ to the
Development Plan which requires that development proposals do not detract from the
special qualities of the area and seek to facilitate delivery of the Norfolk Coast
Management Plan objectives. (Adopted Policy EN1 of the North Norfolk Core Strategy).
2. The AONB Management Plan
2.1 The Management Plan is the framework for all organisations with a role in
management of the AONB. All Partners have worked together to produce and agree the
contents of this Management Plan and are committed to its delivery.
2.2 The relevant local authorities (Norfolk County Council, North Norfolk District
Council, Borough Council of King’s Lynn and West Norfolk, Great Yarmouth Borough
Council, Broads Authority) have previously agreed that the Norfolk Coast Partnership
should undertake the requirement of Section 89 of the Countryside and Rights of Way
Act 2000 on their behalf. Although the legislation requires these local authorities ‘to act
jointly to prepare and publish a plan which formulates their policy for the management of
the AONB and for carrying out their functions in relation to it’ in practice, the plan
extends to a much wider group of partners who also have important management
functions. The Partners act through the mechanism of a ‘Memorandum of Agreement’
(MOA).
Planning Policy & Built Heritage Working Party
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19 January 2015
3. Statutory duties for the Council in relation to the AONB Management Plan
3.1 Section 89 of the CRoW Act gives relevant local authorities (i.e. those whose area
wholly or partly includes an AONB) a duty to:
“…prepare and publish a plan which formulates their policy for the management of the
area of outstanding natural beauty and for the carrying out of their functions in relation
to it”
and to review the plan at
“…intervals of not more than five years”.
3.2 A later paragraph stipulates that where the AONB is not entirely within one local
authority area the plan should be prepared by:
“…the local authorities for all the principal areas wholly or partly comprised in the area
of outstanding natural beauty, acting jointly”
4. Content of the new document
The 2014 -19 Norfolk Coast Area of Outstanding Natural Beauty Management Plan is a
working document which sets out the approach of the Norfolk Coast Partnership to the
management of the area. The strategy has a lifetime of five years and aims to:
•
•
•
•
•
Highlight the special qualities and enduring significance of the area and identify
those that are vulnerable to change;
Identify the key pressures for change on these special qualities
Present an integrated vision for the future of the AONB as a whole, in the light
of national, regional and local priorities;
Set out agreed objectives and policies which will help secure that vision; and
Identify the means by which objectives, actions and overall management will be
monitored and reviewed.
4.1 This revised document is the third Management Plan produced by the Norfolk
Coast Partnership for management of the Norfolk Coast AONB under the CRoW Act. It
builds on the previous 2009 -14 Management Plan and has undergone a thorough
review to update it, but in the event there are relatively minor changes from the previous
strategy plan in terms of structure and content. The draft management plan 2014-19
sets out background information together with a 20-year vision and 5-year objectives
and policies for the management of the area.
4.2 A summary of the visions, objectives and policies in the revised draft is attached as
Appendix 1.
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19 January 2015
4.3 The draft Plan and its associated Action Plan were subject to a round of
consultation earlier this year. All comments were considered carefully in finalising the
plan. A record of this consideration and the changes made to the draft to produce the
final plan is available on the Norfolk Coast Project website at:
http://www.norfolkcoastaonb.org.uk/pages/pspage.php?PageID=1000
4.4 The Management Plan is primarily for use by the members of the Norfolk Coast
Partnership to inform, guide and influence their activities within the area, although it is
hoped that other individuals and organisations may also find it of interest and use. A
separate action plan, to be reviewed annually, will detail specific actions that the
Partnership will take forward.
5. Recommendation to Cabinet.
1. That the Norfolk Coast Area of Outstanding Natural Beauty Management Plan
2014 -2019 is approved.
(Source: Mark Ashwell, Planning Policy & Property Information Manager, 01263 516325)
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19 January 2015
Appendix 1
INTRODUCTION AND SUMMARY OF THE STRUCTURE AND KEY
FEATURES OF THE PLAN
1.0.1 The Norfolk Coast Area of Outstanding Natural Beauty covers inter-tidal, coastal and
agricultural land with a total area of over 450 square kilometres. Stretching from the silt
expanses of the Wash in the west through the coastal marshes, soft cliffs and hinterland of
north Norfolk, to the dune system at Winterton in the east, it is an area of remarkable beauty,
diversity and scientific importance.
1.0.2 Although ‘Area of Outstanding Natural Beauty’ is essentially a landscape designation,
natural beauty includes wildlife and historic and cultural heritage as well as scenery, and all of
these are closely linked.
1.0.3 The Norfolk Coast today is the result of a complex interaction between people and their
environment. The basic shape and contours of the land and the coast are the product of natural
processes, linked to long term climate changes acting influence on the underlying geology,
particularly the action of ice sheets and water.
1.0.4 The action of the sea, both eroding and building, produces an ever-changing coastline.
Geology and landforms influence land use, and many of the smaller scale features which give
the area its unique character are the result of the actions of people, who have lived in and used
the area for thousands of years. The action of the sea, both eroding and building, produces an
ever changing coastline. Geology and landforms influence land use, and many much of the
larger scale landscape character as well as smaller scale features which give the area its
unique character are the result of have been influenced by the actions of people, who have lived
in and used the area for thousands of years.
1.0.5 Even the present ‘wild’ coastline is a product of a combination of natural processes and
human activities, in that enclosure of saltmarsh by protective banks to provide agricultural land
has influenced coastal processes over a much wider area. Connections between people and the
landscape remain important. Employment in 'traditional' industries such as agriculture and
fishing has declined but these still have a key role to play in the area's character. This special
character makes the area a unique regional and national landscape resource.
1.0.6 The Norfolk Coast Partnership aims to ensure that the natural beauty and special
character of the Norfolk Coast are conserved and enhanced through the work of the
Partnership; a group of stakeholders, including the community, who manage a range of issues
affecting the natural beauty of the area.
1.0.7 The Management Plan is primarily for use by the members of the Norfolk Coast
Partnership to inform, guide and influence their activities within the area, though it is
hoped that other individuals and organisations may also find it of interest and use.
1.0.8 This, the Strategy Plan for the 2014 -19 Norfolk Coast AONB Management Plan, presents
the background and the approach of the Norfolk Coast Partnership to management of the area.
A separate action plan, to be reviewed annually, details specific actions that the partnership will
take forward.
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Table 1: Norfolk Coast AONB - some facts and figures
Statistics
Date of designation confirmation: 8th April 1968
Total area; 453 square kilometres
Local Authorities:
• Norfolk County Council (AONB is entirely within the county)
• North Norfolk District Council (245.5 sq km in AONB)
• Borough Council of King’s Lynn and West Norfolk (203.6 sq km in AONB)
• Great Yarmouth Borough Council (6.9 sq. km in AONB)
• Broads Authority (7.2 sq. km in AONB) – the only example of an AONB overlapping with a
national park / equivalent designation
No of parishes partly or wholly in the area: 69
Length of coastline for AONB – 90.8 km
• 44.8 km in NNDC
• 42.8 km in BCKLWN
• 3.2 km in GYBC
Highest point 102 metres above sea level at Roman Camp, on the Cromer Ridge between Sheringham
and Cromer (also the highest point in Norfolk)
Length of Public Rights of Way 287 kms
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19 January 2015
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19 January 2015
Vision, objectives and policies:
(combined from section 4 of the full document – reflected in paragraph numbering)
Landscape, biodiversity and geodiversity
Vision for the Norfolk Coast in 2034:
(4.1.17) The Norfolk Coast will be richly diverse, with distinctive landscapes, wildlife,
settlements, geological features, building styles and materials, communities, history and culture.
(4.1.18) Necessary development, including outside the area and in the marine environment, will
have been managed so that the area will still be essentially unspoilt with a strong feeling of
remoteness, peace and tranquillity, with wide sky-scapes, seascapes and dark night skies that
show the richness and detail of constellations. The marine environment will be sustainably
managed in a way that takes full account of the area’s important links with the sea.
(4.1.19) The coast will retain a strong feeling of wilderness and of being exposed to and shaped
by the elements. In general, there will have been a managed approach to achieving a more
naturally functioning coastline, which will be increasingly valuable for its habitats and the
species they support, including breeding, migrating and wintering birds. Where it has been
deemed necessary to maintain coastal defences, this will have been done in the most sensitive
way possible in terms of sustainability and visual and wildlife impacts.
(4.1.20) Habitats will have been improved, increased and linked to enable adaptation of the
area’s biodiversity to climate change. The area’s rivers and estuaries will be in good ecological
condition, providing a passage for migratory species. All parts of the area, not just designated
sites, will support a rich diversity of characteristic wildlife and habitats associated with local
environmental variations and management, including species and habitats of national and
international importance, although these will not necessarily be exactly the same as in 2014.
Where coastal habitats have been lost through realignment they will have been replaced
elsewhere, and plans for managing future loss will have been developed.
(4.1.21) The landscape will show many links with history, with features and patterns created by
past cultures and land use, and with its geological past through large scale features and
individual sites. The value of the landscape and the story it tells will be widely understood.
5-Year Objectives - by 2019:
Landscape:
OL1 The integrity and diversity of the area’s landscapes and seascapes will have been
maintained and preferably enhanced, assessed with reference to the Integrated Landscape
Guidance for the AONB
Biodiversity:
OL2 Internationally and nationally designated sites for wildlife will be in favourable condition and
under effective management
OL3 Locally designated sites for wildlife will be under positive management
OL4 A local expression of Biodiversity 2020 targets for the area will have been developed and a
programme for their achievement nearing completion
OL5 The area’s rivers and estuaries will be approaching in good ecological condition or
approaching this state
Geodiversity:
OL6 Large scale geodiversity features, including dynamic coastal features will have been
conserved so that their integrity and their influence on the landscape remains apparent
OL7 Significant local geodiversity sites will be in positive management
Planning Policy & Built Heritage Working Party
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19 January 2015
OL8 The area’s geodiversity will be better understood and appreciated by decision-makers and
the public, and public access and information for a range of sites will be available
Policies - members of the Norfolk Coast Partnership, including the staff team will, cooperating
where necessary:
PL1 Refer to and use the Integrated Landscape Character Guidance for the AONB to guide
decision making and delivery of conservation objectives across the area
PL2 Continue to promote understanding of the area’s key qualities of natural beauty, particularly
those less understood and valued at present and including seascapes and the marine
environment, and take account of these in decision-making
PL3 Continue to improve understanding of changes to landscape and biodiversity arising from
climate change (including sea level rise and other effects) and other drivers, and plan to adapt
to and mitigate these changes
PL4 Work together on a landscape scale to improve resilience to change for key habitats and
species through development of ecological networks that increase, extend, link and buffer key
habitat areas
PL5 Be proactive to reduce and manage adverse impacts on the key qualities of natural beauty
from past development and activities, as well as resist and mitigate damaging new impacts and
influence decisions by organisations outside the Partnership
PL6 Protect the area’s distinctive native biodiversity from the impacts of invasive non-native
species where possible by restricting pathways of introduction and carrying out targeted
eradications
PL7 Plan and prepare for implementation of coastal realignment where necessary to allow
maximum ability to adapt and maintain active coastal geomorphology, landscape and seascape
character including ecological links between land and sea, taking into account conservation
objectives for coastal sites and the interests of coastal communities (see also policy PC7)
PL8 Identify and implement opportunities for the relocation of key habitats that are threatened
by coastal change
PL9 Take into account in plans and decision-making the services to society that habitats in the
AONB provide (eco-systems services)
PL10 Work with landowners to bring Sites of Special Scientific Interest, County Wildlife
Sites and other Biodiversity Action Plan habitats and non-statutory geodiversity sites into
positive management where this is required
Built and historic environment
Vision for the Norfolk Coast in 2034:
(4.2.7) The quality and locally distinct character of the historic environment, including settlement
form, character and patterns and in the marine environment, will be evident and valued. It will be
understood, recorded, maintained and conserved as far as possible.
(4.2.8) Archaeology and historic ruins will have been well conserved and managed, or where
this is not feasible will have been recorded. Traditional buildings that contribute to the character
of the area will have been well maintained and conserved, including through appropriate
productive use where possible. New buildings will have been located and designed to conserve
and enhance landscape and settlement character.
(4.2.9) Buildings will have been sensitively adapted where necessary to incorporate features
that enhance their performance in terms of both local and global environmental sustainability.
New buildings, including those using innovative design, will also have these features as well as
complementing their surroundings.
(4.2.10) Within the constraints of rising sea levels and storm activity the area will retain
characteristic coastal settlements and road networks. Coastal settlements will be adapting to
change, with new buildings and roads located where they are sustainable in the long term in
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respect of coastal erosion and flood risk from rivers and the sea while retaining local
distinctiveness.
5-Year Objectives - by 2019:
OB1 The area’s designated heritage assets will be under positive management
OB2 Measures to improve understanding and conservation of the area’s historic and
archaeological heritage amongst partners and public will have been implemented
OB3 The area’s key historic environment sites most at risk from climate change-related and
other impacts will be known and where appropriate mitigating measures investigated and in
progress
Policies - members of the Norfolk Coast Partnership, including the staff team will, cooperating
where necessary:
PB1 Ensure that historic and archaeological heritage assets within their responsibility ownership
or powers of regulation, particularly heritage assets at risk, are recorded, conserved and
enhanced
PB2 Provide opportunities for public understanding and appropriate access to historic
environment sites within their responsibility ownership and promote this elsewhere, where
consistent with conservation objectives
PB3 Ensure that new development, including changes to existing buildings and infrastructure,
within their responsibility ownership or powers of regulation are consistent with the special
qualities and of the area and relevant conservation objectives
PB4 Demonstrate good practice and provide examples of how to incorporate measures for
energy, water use, and resource reduction and biodiversity enhancements sensitively into new,
vernacular and historic buildings and structures
PB5 Support new development and conversion that is consistent with local and national
planning policy and the principles above, in order to retain and develop residential and
employment opportunities that support natural beauty
Farming, forestry and fishing
Vision for the Norfolk Coast in 2034:
(4.3.6) Agriculture will still be the prime means of maintaining the natural beauty of the majority
of the area’s countryside. Farming and forestry will provide an economically sustainable
livelihood through producing crops for a wide range of uses including food and biofuels as well
as providing recreational opportunities and habitats for wildlife. Economic sustainability will be
assisted where necessary through environmental grants to enable farmers and land managers
to maintain and enhance specific landscape features, habitats and species and heritage assets,
and use of this support will be actively encouraged.
(4.3.7) Farming, the management of woodland and food production in general, including some
new crops that are being grown in response to climate change and market demand, will be in
tune with the local climate and soil characteristics.
(4.3.8) Crop and animal production methods will not impact adversely on water resources and
quality, soil structure and local eco-systems and at least maintain, and often enhance,
landscape character, local distinctiveness, and biodiversity and heritage assets through a
mixture of smaller tenant and family owned farms sitting alongside larger estate-based
businesses. Farm businesses in the area will be considered to demonstrate good practice and
to be at the vanguard of sustainable agricultural management.
Planning Policy & Built Heritage Working Party
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(4.3.9) Fishing will be an environmentally sustainable and economically viable economic activity,
at least in combination with other economic activities, and will continue to contribute positively to
the distinctive character of the area.
5-Year Objectives - by 2019:
OF1 High take-up of a revised agri-environment scheme, which is appropriate to the area and
supports AONB objectives, delivering landscape, and biodiversity and historic environment
enhancements and supporting sustainable agricultural enterprises, will be in place in the area
OF2 Improved efficiency of water use and storage, and management of soil and nutrient run-off
by agriculture in the area will be in development, reducing impacts on ground water, rivers and
other water dependent features, and respecting landscape character and contributing to Water
Framework Directive and biodiversity objectives
OF3 Changes to new types of crops, such as energy crops, will have taken landscape and
ecological character and the historic environment into account
OF4 There will be increased and improved management of woodland in the area with benefits
for biodiversity, businesses and recreation, and development of local supply chains for
woodland products
OF5 The local fishing industry will have remained viable economically and as a way of life and
measures / initiatives to support adaptation, if necessary, and sustainability of the local fishing
industry will have been continued
Policies - members of the Norfolk Coast Partnership, including the staff team will, cooperating
where necessary:
PF1 Aim to develop and maintain understanding of the key issues affecting local farming,
farmland habitats and wildlife under changing circumstances within the framework of the new
Common Agricultural Policy and influence the new agri-environment schemes and proposed
“greening” measures development and implementation of the new Environmental
Land Management Scheme in the area to benefit farming in the AONB and farmland
landscapes, habitats and wildlife and its historic environment features
PF2 Continue to develop support for grazing infrastructure and local grazing networks as a
means of maintaining specific areas of distinctive agricultural landscapes and habitats, including
historic environment features, and meeting conservation objectives
PF3 Support development and diversification associated with farming, forestry, fishing and other
marine industries which respects, and ideally contributes to, conserving the special qualities of
the area, including their enjoyment and understanding
PF4 Promote and support the development of sustainable practice in farming, forestry and
fishing, including through promotion of appropriate grant schemes and advice, and support for
cooperation to develop local initiatives and marketing of sustainable local products
PF5 Promote and implement an integrated catchment-based approach to all aspects of water
management throughout the area to achieve benefits for landscape, biodiversity, the historic
environment and the economy
Sustainable communities
Vision for the Norfolk Coast in 2034:
(4.4.8) The Norfolk Coast will be a living, working area with individuals and communities working
together where necessary for the benefit of the whole community or a wider area.
(4.4.9) The economy will be broadly based, with a range of environmentally sustainable
economic activities, including opportunities to earn a living through ‘traditional’ activities for the
area as well as activities based on new technology and communications, and others that draw
Planning Policy & Built Heritage Working Party
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on and support the area’s distinctive and special features. Tourism will remain an important part
of the local economy, generating money that benefits a wide section of the local community.
(4.4.10) Appropriate tenures of housing, including affordable housing will be available for people
working locally. Although diverse in terms of age, income and occupation, communities will
include people with family ties to the area and people will share an understanding and
appreciation of the area’s special qualities.
(4.4.11) The area will be widely recognised as leading in environmentally sustainable practice,
including mitigating climate change. While adapting to climate and coastal change, the area will
be maintaining characteristic and viable coastal settlements and infrastructure. Various forms of
renewable energy will be produced and used in locations and in ways that are consistent with
the key qualities that give the area its special character. Effective local food and products
networks will be in operation, with local producers working together to promote their products
and the links to the area. Networks and services providing alternative low-impact forms of
transport to the car, reducing congestion and the need for additional car parking, will be
available and widely used by both visitors and residents.
(4.4.12) All forms of pollution will be low. Pollution from all local sources will be avoided or its
impacts minimised. Water quality will be high and water will be used and managed efficiently
with maximum benefits to the local environment. Generation of waste will have been minimised
and waste will be used as a resource wherever possible.
5-Year Objectives - by 2019:
OC1 The area will be improving as an environment for local businesses and availability of local
jobs, assessed against regional averages
OC2 Public transport and other alternatives to car travel in the area will have been maintained
and improved as a service for both local residents and visitors
OC3 Pupils in all schools in the area will have been involved in learning about its special
qualities
OC4 Further understanding and means of supporting coastal communities in adapting to coastal
change will have been developed
Policies - members of the Norfolk Coast Partnership, including the staff team will, cooperating
where necessary:
PC1 Support opportunities for economic growth that this invests in the natural capital and
sustainable management of the special qualities of the AONB
PC2 Promote and support services and products from the local area and use these whenever
possible, especially those that are sustainable and high quality, and which contribute to
maintaining natural beauty in some way, in order to support the local economy and jobs and to
reduce ‘supply miles’
PC3 Continue to develop understanding amongst second home owners to enable them to
contribute to maintaining sustainable local communities and natural beauty
PC4 Continue to involve and develop communication and cooperation with local people and
communities in the work of the Norfolk Coast Partnership
PC5 Support the development of renewable energy in the area in ways and locations that
contribute to the area’s local economy and jobs and maintain its natural beauty
PC6 Continue to investigate and develop ways of securing a mix of different housing tenures
which will enable local people or those with local connections to live and work in the AONB, in
ways that maintain the area’s natural beauty
PC7 Manage traffic and transport issues, including car parking and provision and promotion of
effective public transport and other non-car means of travel, to reduce traffic congestion at peak
times, conserve tranquillity and manage pressures on sensitive sites in the area
(transferred from PR8 in section 4.5)
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19 January 2015
PC8 Involve local communities in the development of plans and projects that may affect them,
for example Shoreline Management Plans, and inform them of progress on plans and
programmes
PC9 Support the provision of necessary facilities and new development to meet proven needs
of local communities and businesses, in ways that maintain the area’s natural beauty, including
the provision of fast broadband throughout the area
PC10 Seek to maintain support for community projects in the area that contribute to
AONB objectives and sustainable development, including through availability of grants
Access and recreation
Vision for the Norfolk Coast in 2034:
(4.5.8) The Norfolk Coast will be a place where people can refresh both body and soul. Tourism,
recreation and enjoyment of the area will provide benefits to both its communities and
landscape.
(4.5.9) Tourism businesses, visitors and residents will understand the area’s special qualities of
landscape, wildlife and cultural and historic heritage and their and wildlife sensitivities and
support their conservation through how they use, and promote use of, the area. Tourism
businesses will understand the value of the natural capital that underpins their businesses and
be actively contributing to initiatives that conserve and enhance natural beauty and support local
communities.
(4.5.10) Recreation by both visitors and local residents, including long-standing traditional
activities for the area, will be managed in a way that provides opportunities for all users to
experience and enjoy the special qualities of the area without conflicting with those qualities or
with other people’s enjoyment of them.
(4.5.11) Public access routes and areas, both statutory and discretionary, together with non-car
forms of transport, will form an integrated network which is widely used by both local residents
and visitors. Information on these, and on areas suitable for a variety of recreational activities,
will be easily and freely available to the public.
5-Year Objectives - by 2019:
OR1 Information on current and future visitor site user numbers, behaviours, visit profiles and
recreational activities, particularly those that may affect coastal Natura 2000 sites, will have
been further improved and used to develop information for the tourism sector, visitors and
recreational users, and management of pressures on sensitive sites
OR2 Cooperation will have been further developed between the tourism sector, conservation
organisations and local communities to develop understanding and more sustainable enjoyment
of the area by visitors and local residents, and to manage pressures on key species and
habitats sites, particularly for coastal Natura 2000 sites, by providing clear and consistent
information and guidance
Policies - members of the Norfolk Coast Partnership, including the staff team will cooperate and
share information to:
PR1 Continue to develop improve communication of the area’s special qualities, including
seascapes
PR2 Continue to develop improve understanding about current and future visitor numbers,
behaviours, visit profiles and recreational activities, particularly for coastal Natura 2000 sites
PR3 Investigate and seek to develop secure funding contributions from new housing
development, both within and outside the area, that are likely to provideing sources of visitor
recreational pressures on Natura 2000 sites, to enable their mitigation
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19 January 2015
PR4 Develop consistent messages with the tourism sector and local communities about
promotion of the area that takes into account sensitivity to visitor and recreational pressures and
capacity to manage these
PR5 Work with tourism businesses to develop and promote ways for visitors to contribute to
conserving and enhancing the features and qualities that bring them to the area, and to
maximise benefits and minimise impacts from visitors to communities and maintaining its
services
PR6 Develop integrated and holistic management of recreation activities along the area’s coast
to provide opportunities that do not impact on sensitive habitats and wildlife sites, including
especially coastal Natura 2000 sites
PR7 Ensure that opportunities, information and incentives for visitors to enjoy the area without
using the car, including new public access links, are easily available and developed as
increased where appropriate
PR8 Manage traffic and transport issues, including car parking and provision and promotion of
effective public transport and other non-car means of travel, to reduce traffic congestion at peak
times, conserve tranquillity and manage pressures on sensitive sites in the area (transferred to
section 4.4 as policy PC7)
PR9 Provide appropriate levels and types of visitor facilities and information at key sites,
including public lavatories and facilities for visitors with restricted mobility, together with
information that promotes the aims of the AONB management plan in a coordinated way,
including for visitors with restricted mobility, and ensure that opportunities and information are
easily available for all actual and potential users to enable enjoyment of the range of the area’s
natural beauty sensitively and encourage suitable activities away from sensitive areas
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Agenda item
8__
PUBLIC BUSINESS – ITEM FOR DECISION
FAKENHAM DEVELOPMENT BRIEF
This report summarises the responses to a consultation relating to a Development Brief
for the allocated development site at Fakenham and recommends that an amended
Brief is approved as a basis for determining future planning applications on the site.
1. Introduction
1.1 The adopted Site Allocations Development Plan makes proposals for a substantial
mixed use urban expansion on land to the north of Fakenham. Policy F01 of the
Allocations document requires the approval of a Development Brief before
development commences and states that it should include details of site access,
sustainable transport, layout, landscaping, phasing (including the provision of
employment land), and conceptual appearance.
1.2 A draft Development Brief was published for a period of public/stakeholder
consultation, commencing 26 March and closing 21 May in 2012. Following
consideration of the responses, a report was prepared for the Planning Policy & Built
Heritage Working Party meeting on 23 July 2012. At that meeting it was decided not to
approve the Development Brief in order to consider further the traffic circulation
impacts of the proposed development on the existing highway network and the
strategy for green infrastructure.
1.3 A revised Development Brief has now been prepared and the Council has invited
further comments from the public and a range of consultees. The consultation period
ran from Monday 6 October until Monday 27 October 2014. The revised Brief can be
viewed on the Council’s website.
2. Status and Purpose of Briefs
2.1 Development Briefs do not grant planning permission for development, neither are
they formal policy documents, rather they provide a framework, or guide, which later
planning applications should have regard to. They should include sufficient detail to
guide the decision making process on subsequent planning applications and ensure
that the potential adverse consequences of piecemeal development do not occur.
2.2 Planning applications for each phase of development on the allocated site will still
be required and these will need to include sufficient information to address issues such
as traffic circulation (including the need or otherwise for local highway improvements),
provision of supporting infrastructure, building design and layout of development and
should do so in a manner which takes account of the Brief. In addition to taking
account of the Brief, applications will need to demonstrate compliance with adopted
planning policies. Whilst the presumption would be that proposals which do not comply
with the Brief should not be supported, the Brief should also be sufficiently flexible to
allow for variations where the evidence produced in support of individual planning
applications justifies.
Planning Policy & Built Heritage Working Party
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19 January 2015
3. Representations
3.1 The representations received together with an Officer response/recommendation
are appended to this report.
3.2 The representations which have been made broadly fall in to three categories:
•
Those that maintain an in principle objection to development. - The
development of this site has been agreed for many years, it is included in both
the adopted Core Strategy and the Site Allocations Development Plans
approved in 2008 and 2011 respectively. As the site is allocated for
development in these adopted Development Plans, in principle objections,
should not be considered further at this stage.
•
Those that suggest textual amendments to the document to strengthen or
clarify its content - These can be made as appropriate before the Brief is
approved (see appended recommendations).
•
Those that don’t agree with the content of the Brief – A small number of issues
are raised, some of which can be addressed through the planning application
process. The most notable remaining area of concern relates to the proposals
for vehicular access and this is discussed further below.
4. Access Strategy
4.1 Access arrangements remain one of the main areas of public objection and, in
particular, the potential for adverse highway conditions in Rudham Stile Lane during
and following construction of the development.
4.2 The Brief recognises that neither Rudham Stile Lane nor many of the adjacent
roads are suitable routes for significant increases in traffic and that limiting traffic using
these routes, as is proposed in the Brief, is a desirable objective. Certainly the road
network is entirely unsuitable as a means of access for up to 900 dwellings and direct
vehicular connections between the new development and existing should be
minimised.
4.3 In recognition of this, the Brief currently states that vehicular access to and from
the site, (other than by public transport and direct access to any possible frontage
development), should not be permitted via the existing adjacent residential road
network. Instead, vehicles should use the A148 to the north of the allocation to access
Fakenham and beyond, via a more suitable road network. To deliver this, it may be
necessary to shut Water Moor Lane (which runs from Rudham Stile Lane to the A148)
to all traffic other than public transport, or possibly, limit access to a northerly (out of
town) direction only. The potential closure of Water Moor Lane would in itself introduce
additional traffic to the local highway network, including Rudham Stile Lane/ Thorpland
Road as a consequence of the alternative Water Moor Lane route, no longer being
available. This may necessitate local highway improvements prior to road closure.
4.4 Overall, it is considered that the access strategy included in the Brief is sound and
represents the most appropriate solution to development of the site. It is not however
considered that there is sufficient evidence at this stage to definitively state in the Brief
that no access will be allowed to Rudham Stile Lane. For example, a small cul-de-sac
development or a limited amount of frontage development may prove to be acceptable,
particularly if supported by any necessary highway improvements.
Planning Policy & Built Heritage Working Party
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19 January 2015
4.5 The Brief’s proposal to only allow frontage development on to Rudham Stile Lane
has been challenged by one of the land owners within the allocated area, who argues
that his land could, and should, be accessed from Rudham Stile Lane in order to avoid
long delays in the site coming forward and potential adverse impacts on development
viability. Furthermore, it is argued that Rudham Stile Lane and adjacent roads could
accommodate a limited amount of development and that this possibility should not be
prevented via approval of the Brief. This land owner has therefore submitted an outline
planning application proposing access to Rudham Stile Lane for a scheme of around
80 dwellings, but at the time of writing a definitive view from the highway authority had
not been received in relation to the acceptability of this. It should be recognised,
however, that unless the Highway Authority object to this current application, it is
considered that there would be insufficient grounds to refuse it on highways safety
reasons.
4.6 The suitability of the existing highway network to support development and the
need or otherwise to improve it can be considered through the planning application
process when detailed Traffic Impact Assessments can be required (if necessary) in
relation to individual proposals. It is therefore recommended that the wording of the
Brief is amended accordingly to allow sufficient flexibility. Nevertheless the Brief should
continue to make clear the inadequacies of the existing roads to the south and the
need for individual planning applications to comprehensively assess their suitability as
part of the planning application process.
5. Delivery
5.1 One of the main reasons for preparing Development Briefs is to provide a logical
framework for comprehensive development of sometimes large areas in multiple
ownerships. Where there is no agreement between landowners, who may have very
different ideas about how land should be developed, a Brief is one of the few tools
available to the planning authority to ensure that this is achieved. A clear delivery
strategy including phasing of development and the expected mechanism to ensure
‘joined up’ planning is therefore essential. In this regard the following addition to the
brief is recommended:
‘The Council’s preferred approach is that development of the allocated area is brought
forward via the submission of a single outline or full planning application supported by
an appropriate unilateral or multilateral legal agreement. In the event of separate
applications being made for parts of the allocated site each application will be
expected to clearly demonstrate how it makes a proportionate and equitable
contribution to the comprehensive and viable delivery of the entire allocation including
the delivery of all proposed land uses and the physical and social infrastructure
necessary to deliver sustainable development in accordance with this Brief.’
5.2 In all other respects subject to the incorporation of the further changes suggested
in the Appendix it is recommended that the Brief is approved as a guide to the
determination of future planning applications within the allocated area.
6. Recommendation
That the amendments outlined above and in Appendix 2 are incorporated into the Brief
and that it is recommended to Cabinet for approval.
(Source: Mark Ashwell, Planning Policy & Property Information Manager, 01263
516325)
Planning Policy & Built Heritage Working Party
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19 January 2015
APPENDIX 2
Consultation on a Revised Development Brief
Land North of Rudham Stile Lane, Fakenham
Responses to Public Consultation
6 October - 27 October 2014
Planning Policy & Built Heritage Working Party
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19 January 2015
Report of Representations
Consultation on a Revised Development Brief - Land North of Rudham Stile Lane, Fakenham
The Revised Development Brief for Land North of Rudham Stile Lane, Fakenham was published for 21 days public consultation from 6 October
to 27 October 2014 in order to consider any final comments on the document. A total of 21 representations were received during this period. 5
additional representations were submitted after this period and these comments are accepted and also included in this report. This document is
a complete report of all representations received.
The tables in this document display the content of each representation, showing the representation number and the name of the person or
organisation making the comment. It shows the nature of their representation (support, comment or object). Please note that this is an officer‟s
interpretation of the representation. In addition, an officer response has been provided where required.
Planning Policy Team
North Norfolk District Council,
Holt Road, Cromer, NR27 9EN
01263 516318
planningpolicy@north-norfolk.gov.uk
www.northnorfolk.org/FDBenhamdevbrief
Planning Policy & Built Heritage Working Party
All documents can be made available in
Braille, audio, large print or in other languages.
Please contact 01263 516318 to discuss your requirements.
26
Page 2 of 36
19 January 2015
Report of Representations
Consultation on a Revised Development Brief - Land North of Rudham Stile Lane, Fakenham
Comment
ID
Name
Organisation
Object/
Support/
Comment
FDB001
Mr John Tillbrook
Member of the Public
Comment
Comments
1. Why is this development on green belt area,
when so many areas of existing surrounding
areas require development to enhance look
of a small town.
2. Why is the site to be 45% social housing,
normal projects only build 10-15%, surely
building house for sale will bring people into
the town willing to spend money and again
enhance the town.
3. Will any roads exit onto Rudham Stile Lane,
not clear only shows main route going
through development.
4. Who will purchase this amount of houses,
has survey been carried out to see if this
amount is required.
5. How will town resources including parking
cater for this large volume of people 2000+
once completed.
6. When will appeals been seen?
7. When is development due to start
construction?
Planning Policy & Built Heritage Working Party
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NNDC Response
1. The scale of new growth
and its location has been
agreed via the preparation
of Development Plans
which were adopted in
2008 and 2011. The
current consultation relates
to how the site should be
developed rather than
should the site be
developed. The scale of
growth that is needed in the
District will require both
existing sites and
previously developed sites
to be developed in addition
to providing significant new
housing on green field
sites. The Local Plan for
the area takes account of
all potential sources of new
development when
deciding how much
greenfield land is required.
2. Adopted policies require
the provision of 45%
affordable housing where it
is viable to provide.
3. See comments in main
report.
4. The need for new housing
is established via the
Page 3 of 36
19 January 2015
Comment
ID
Name
Organisation
Object/
Support/
Comment
Comments
NNDC Response
evidence prepared to
support the preparation of
the Development Plan. The
specific evidence in relation
to housing need and
demand is published in a
Strategic Housing Market
Assessment.
5. Improvements in a range of
services and facilities will
be required to support the
planned level of growth.
Where such improvements
are necessary to make the
proposed development
acceptable the Authority
can consider requiring such
improvements to be funded
by the developer.
6/7. Development is likely to
proceed over the next ten year
period.
FDB002
Mr Ken Hamilton
Norfolk Landscape
Archaeology
Comment
We commented on this brief in March 2012, and our
comments were noted in the Planning Policy and
rd
Built heritage Working Party report of 23 July, 2012
(p8, Main Issue 6), which noted that these would be
addressed in the text, following consultation with the
Historic Environment Service.
Recommendation: that the text of
the brief is amended to reflect
the need for archaeological field
evaluation along with planning
applications (in accordance with
paragraph 128 of the NPPF).
We have not received any further consultation, and I
note that the historic environment section of the
updated brief remains unchanged from its 2011 form.
Our original comments, therefore, also remain largely
unchanged:
Planning Policy & Built Heritage Working Party
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Page 4 of 36
19 January 2015
Comment
ID
Name
Organisation
Object/
Support/
Comment
Comments
NNDC Response
The archaeological desk based assessment should
be updated to take into account changes in the level
of knowledge about the site, and to incorporate
changes brought about from the differences between
PPG 15 and 16 and the NPPF.
It is difficult to comment on the brief in detail, as the
Historic Environment Service have not seen the desk
based assessment prepared for this development
brief. However, it is an issue of concern that the
summary of the desk based assessment in the
development brief describes the potential for Roman
and post-Roman archaeology as “Negligible” – the
HER lists two brick kilns and a windmill within the
proposed development area. In addition, the lack of
records in the area is likely to be a result of a lack of
study, rather than a lack of heritage assets (absence
of evidence is not evidence of absence). It is difficult
to say without seeing the desk based assessment in
detail, but it appears that the desk based assessment
has discussed the state of knowledge of the site (in
August 2006), rather than discussing the potential for
heritage assets within the site.
I recommend that a copy of the updated desk based
assessment be sent to the Historic Environment
Service for comment and detailed advice on its
impact on the Development Brief.
We further recommend that the Brief advises that for
areas of unknown archaeological potential,
developers are likely to be required to submit the
results of an archaeological field evaluation along
with their planning application (in accordance with
paragraph 128 of the NPPF). Applicants should
contact the Historic Environment Service well in
advance of submitting their application for advice on
the nature and scope of such works. Similarly, in
Planning Policy & Built Heritage Working Party
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areas of known archaeological potential, developers
should contact the Historic Environment Service well
in advance of submitting their planning application,
for advice on the scope of any works required.
FDB003
Ms Wendy Buchanan
Member of the Public
Object
I write in relation to your Development Brief/August
2014 - Land at Rudham Stile Lane, Fakenham and
my recent correspondence with Chris Brown at
NNDC.
Please find attached the correspondence that has
passed between myself and Chris Brown, together
with copies of page 24 and page 27 of your above
mentioned Development Brief/August 2014
(hereinafter referred to as „the Development Brief‟)
and a copy of the leaflet that I (and the owners of
properties along Rudham Stile Lane) have received
from Lanpro Services.
See comments relating to access in
main report.
Recommendation: The plans
included within the Brief which
suggest direct access to
Rudham Stile Lane from a
number of points should be
amended.
As you will see, there appears to be and in Chris
Brown‟s words ‘a simple error – but one which has
rather important ramifications’ between the wording
at 6.2.6 on page 24 and the amended plan on page
27 of the Development Brief.
The error being that, 6.2.6 on page 24 of the
Development Brief advises, and I quote, that „There
will be no direct access to Rudham Stile Lane from
the site except for the proposed dwellings that will
benefit from a frontage to the Lane (mirroring the
existing development to the south) and will have a
direct private access from it‟. However, the amended
plan on page 27 of the Development Brief clearly
shows that the road (shown highlighted pink on the
copy of this amended plan attached to this e-mail)
will provide a link from the whole of the development
onto Rudham Stile Lane. Meaning, that all 900
Planning Policy & Built Heritage Working Party
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proposed dwellings will have direct vehicular access
onto Rudham Stile Lane. Therefore, the statement
within 6.2.6 on page 24 of the Development Brief
clearly contradicts the information provided on your
amended plan.
This error is further compounded by that fact that the
leaflet I recently received from Lanpro shows exactly
the same vehicular access (again highlighted pink on
the attached Lanpro leaflet) as that shown on the
amended plan on page 27 of the Development Brief.
As you will be aware, Lanpro have applied for outline
planning permission for 84 dwellings at the Brick Kiln
Farm site, Rudham Stile Lane, Fakenham. Should
this outline planning permission be passed with their
plan remaining as it is, this will give all proposed 84
dwellings vehicular access directly onto Rudham
Stile Lane.
As you will see within the e-mail correspondence
attached, Chris Brown thanked me for making this
known to him and asked if I wanted to contact the
consultation to make them aware that the illustrative
masterplan needs to be updated to reflect the text at
6.2.6 on page 24 of the Development Brief, hence
this e-mail.
Chris also advised me that he is happy to record this
discordance between the text and the illustrative plan
and ensure it is considered after the consultation
closes.
I understand from Chris Brown that the results of the
consultation are scheduled for discussion at a future
committee meeting (Planning Policy & Built Heritage
Working Party, 17 November @ 10:00am) and that
although he is reluctant to make any confirmation to
Planning Policy & Built Heritage Working Party
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me, it is logical to assume that the issue relating to
the map on page 27 should be addressed (access to
Rudham Stile Lane removed from the plan) while the
text on page 24 should remain as it is.
If this is the case then the outline planning
permission submitted by Lanpro should be refused
because, as mentioned above, their plan provides
vehicular access from their proposed development
directly into Rudham Stile Lane.
FDB004
Mr Norman Wilson
Member of the Public
Comment
It was good to have a look at your revised plans for
the development of land approx:2,00 north of
Ruddenham Stile Lane. My main concerns are traffic. Am I correct in assuming that all construction
traffic will have access direct from the Bypass and
not through the town.
What new sewerage and water arrangements have
been made?
Fakenham Medical Centre is very stretched at the
moment - have you included for additional facilities?
By closing access from North Park to Wood moor
Lane and the Bypass it will greatly increase the traffic
on
Claypit Lane and cause queues at the traffic lights at
Highfield Road.
See comments relating to access in
main report
Issues relating to the adequacy of
sewers, water and other essential
infrastructure were considered as
part of the preparation of the
adopted development plans and will
be addressed as part of individual
planning applications on the site.
With 900 proposed houses, approximately 2,000 +
people, how is the town going to cope with 1,000 +
cars.
FDB005
Mr Richard Smith
Richard Smith Architects
Ltd
Planning Policy & Built Heritage Working Party
Comment
1. For the safety and wellbeing of the existing
residents of Rudham Stile Lane, it is
imperative, before any development takes
place within any areas of the red line zone,
that the infrastructure works to create/ adapt
32
1. See comments in relation
to access in the report.
2. The application referred to
relates to the proposed
health care facilities on
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highways, as well as sewer upgrades are
complete.
It is essential that no additional traffic uses
Thorpland Road. The reason is that the
existing junction where Thorpland Road
meets Greenway Lane/Holt Road is already
extremely dangerous. Furthermore, the
junction at the bridge at the end of Water
Moor Lane is also already extremely
dangerous. Any additional traffic will add to
the hazards which already exist.
We would need reassurance that the detailed
highway plan will not push more traffic onto
these junctions.
2. We understand that the section of land to the
far south east corner of the development site
already has full planning permission. The
planning reference for this site is 13/0953.
Please can you confirm if this is the case, as
this is not mentioned in the Development
Brief? As this area of the site is directly
adjacent to our property (5 Rudham Stile
Lane), along with support from District
Councillors R & A Reynolds, we had
provided detailed comments on this proposal,
which were accepted by the developers. We
understand that full planning approval was
subsequently agreed.
NNDC Response
land to the rear of the
existing health centre. The
agreed measures referred
to remain part of the
approved scheme.
3. See comments concerning
access in the attached
report.
4. Agreed. It would be useful
if the Brief could make
reference to the need to
consider secondary school
provision and the possible
need for financial
contributions.
Recommendation: That the Brief
is amended to make reference to
the possible need for secondary
school improvement.
3. There is currently an outline planning
application submitted to build 84 houses
within part of the overall development site.
This is also not mentioned in the
Development Brief. Please can you explain
why? For the safety of existing residents, and
Planning Policy & Built Heritage Working Party
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road users, it is essential that these houses
are not built before the road infrastructure
issues are addressed.
4. We are concerned that there is no
investment proposed to increase the size of
the existing high school. It is good that a
primary school is planned, but there is
insufficient capacity in the existing high
school to accommodate the additional
children. Will the developers fund the
required expansion?
5. How are the developers intending to
contribute to other core infrastructure in
Fakenham? For example, the surgery is
already at capacity.
FDB006
Mr & Mrs Bunn
Members of the Public
Comment
My wife and I have very strong concerns regarding
the development opposite to where we live. Our
home for 42 years at Rudham Stile Lane.
1) The increased traffic on Rudham Stile Lane a
narrow road.
2) The major concern is jobs for those people
living opposite. This would mean a minimum
of 1600 jobs. When we have insufficient jobs
for the community we already have in
Fakenham.
Yes this development will provide some jobs
especially in the building trade to begin with
(will it be local builders) but this is only short
term.
There will be some jobs obviously for the
Planning Policy & Built Heritage Working Party
34
1. See comments relating to
site access in main report
2. The Brief includes the
provision of employment
land, potential hotel site, a
small district centre, and
primary school site reserve
which will provide local
employment opportunities.
3. The adopted development
plan includes policies and
proposals which support
inward investment in
Fakenham Town centre
and the extent of any retail
development within the
allocated site is intended to
be limited to that needed to
serve the immediate needs
Page 10 of 36
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school and shop maybe, but where are the
rest of the people going to get work?
You say that businesses in Fakenham should
be able to expand but it does not help the
factories, It might help the shops and it might
make other firms move to the area, but it is
still a big gamble which I would not be
prepared to back.
NNDC Response
of the proposed
development rather than
compete with the town
centre.
I would prefer to make Fakenham Town Centre a
more attractive place for people to visit and free
parking to draw people into the town to help the
businesses already here.
FDB007
Mrs Susan Howell
Member of the Public
Comment
While I agree that a foot path is needed along the
length of Thorpland Road, to enable easy and safe
access to Fakenham Medical Centre. I am concerned
about the amount of extra vehicles that will be using
Thorpland Road (most houses have more than 1 car
within the household nowadays) when the new
development is up and running and also any site
traffic before any an additional road links to the first
phase are constructed.
See comments on access in main
report
My friend has now bought a bungalow at 1 Thorpland
Road because he likes the area, but due to residents
of Baxter‟s Close parking their cars on Thorpland
Road, he would find it impossible to enter and exit his
property when he needs to go out with his touring
caravan. The parking restricts the width of the road
making it a single track which in turn leads to
congestion at the junction with Greenway Lane.
I feel the only solution to this is for Thorpland Road to
be a no parking at zone at any time and for extra
parking be sought for residents of Baxter‟s Close.
Planning Policy & Built Heritage Working Party
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A footpath would also cut the width of Thorpland
Road as it would have to wide enough for all foot fall
especially mobility scooters and parents with push
chairs, so if nothing is done about the residents of
Baxter‟s Close parking then this could cause an
accident in the future.
FDB008
Zoe Tebbutt
Norfolk County Council
Green Infrastructure
Comment
Thank you for your consultation on the above site
allocation development brief. The Norfolk County
Council (NCC) Natural Environment team would like
to make the following comments;
The Development Brief has frequent references to
sustainability, innovation, Green Infrastructure (GI)
and identity while also noting the potential issues
relating to foul water treatment. However, there is no
mention of potential exploration into uses of a
sustainable drainage system for the treatment of foul
water, even for part of the site. Equally, there is a
large amount of public space proposed on this
development and yet the Sustainable Urban
Drainage System (SUDS) for run-off alone consists
of an engineered approach with balancing
ponds/attenuation basins that have no visual
relationship with the sauce of water. Whether SUDS
are for foul, run-off or grey water treatment, storage,
conveyance or discharge, they have the potential to
perform more functions and achieve greater benefits
than those proposed in the brief. It is disappointing to
see that these features have not been shown to be
integrated into the overall outline scheme of
landscaping as they could provide huge benefits in
terms of GI, biodiversity, sustainability and identity,
as well as improving peoples connections with their
environment, and potentially helping to reduce
pressure, in an innovative way, on the local foul
Planning Policy & Built Heritage Working Party
36
Agreed.
Recommendation: The text of the
Brief should be amended to
encourage the wider application
of Sustainable Urban Drainage
systems and to reference the
potential for access to the
adjacent countryside for informal
recreation.
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water infrastructure.
Neighbourhood Equipped Areas of Play (NEAP) have
been referenced within the text of the document
however it was not made apparent as to where the
general location of this was to be on the plans. Local
Equipped Areas of Play (LEAP) are all labelled. It is
suggested that natural play opportunities should be
explored, this approach is supported, as many
natural play features can have a dual purpose and
contribute toward GI. Drawing on earlier comments,
the use of SUDS could also be explored in both
natural and equipped play provision, for example,
see Eagle Walk Recreation Ground, Off Newmarket
Road, Norwich.
It would be expected that high qualities of
architecture and landscape architecture will be
required at the entrances to the development through
the employment area and via the new roundabout,
past the proposed hotel, to ensure that the transition
from employment to residential is seemly.
Paragraph 6.14.2 states that the site will be
„…assimilated into the wider landscape north of
Fakenham…‟ , this may be true in terms of landscape
character, however GI provision for the site does not
look outside of the allocation boundary, or seek to
enhance connections to the near, yet currently
inaccessible countryside for people or wildlife. GI
beyond the allocation boundaries may have been
considered, however this is not communicated within
the brief. If/when applications within this site come
forward, NCC Natural Environment Team would look
for opportunities to be explored for countryside
recreation to the north of the allocation site, and may
seek contributions, by way of s106, for strategic GI to
improve linkages between Fakenham Town, F01,
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and the surrounding countryside.
NCC are the Highway Authority, and will be
consulted at later stages on proposed landscaping in
the Highway; tree planting to act as nodes and
landmarks is supported, but arrangement of the
streetscapes will need to be well thought out at the
detailed stage to ensure tree planting does not
become an ill-planned accessory to parking areas.
The semi-formal character of „Lime Tree Avenue‟ is
anticipated to also be reflected in the tree
specification and planting pattern to ensure
robustness and sustainability into future years.
FDB009
Sarah Price
Norfolk County Council
Public Rights of Way
Comment
Looking through this brief, there is provision for
pedestrian and cyclists. However, the information
provided gives a type of surface treatment that
makes these routes more akin to adopted routes
rather than public rights of way. Additionally as the
proposed 'greenway's' are shared use surface routes,
there is no public right of way status that fits to
provide legal access for both user types unless they
became bridleways and then the proposed surface
would not be acceptable for horse use.
Grove Lane is not a public right of way, but is an
unclassified county road. The vehicular right would
need to be stopped up as part of the planning
process and then the appropriate legislative steps
taken to create a shared use facility. Alternatively
bridleway rights could be retained which would mean
that it could be used by horses, cycles and
pedestrians although the level of maintenance may
not meet the local expectation. It would also end up
in effect as a 'dead ended route' as far as equestrian
traffic is concerned as there are no adjoining
bridleways.
Planning Policy & Built Heritage Working Party
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There is a very small section of existing footway on
the south west side of the A148/A1067 roundabout,
leading towards the north end of Thorpland Road.
Showing on the OS base map is a path running from
this footway westwards (parallel to the A148) across
the north of the development site. If this was
upgraded to cycleway and with a safe crossing of the
A148 provided, it would make a good cycle link onto
the quiet lanes to the north of the roundabout, and
support GI connections outwards of Fakenham.
Notes for future proposals within the allocation site,
not included in this brief; a pedestrian/cycle link from
Water Moor Lane towards Trap Lane which could
then link to Trap Lane to the north (with appropriate
highway crossing) and to RB 11 to the south could
create a wider cycle loop into town via the riverside
cycleway.
FDB010
John Lewis
Member of the Public
Comment
Norfolk has the lowest rainfall in the country, most of
our water coming from Aquifers. The area designated
used to have two ponds, which fed the aquifers
below, they have now gone, which means that the
water table is now much lower, and the proposed
development can only add to less water draining
naturally into the aquifers.
Anglian Water has previously
confirmed there are no issues in
relation to water supply at
Fakenham
My concern is the water suppliers will gloss over this,
because more customers means more income, and I
think an independent Impact Assessment of the
water supply is essential to ensure that the plan is
sustainable, and can support a planned population
increase of 30%.
FDB011
Mr Roy Gibson
Member of the Public
Planning Policy & Built Heritage Working Party
Comment
Both the applications should be viewed in tandem,
not as individual developments.
39
See comments relating to access in
main report.
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The plans as shown, in my opinion, address only the
site area, not an overall vision of the area and
consequential impact on Fakenham. To achieve this
objective the redundant railway bridge should be
removed, thus allowing Watermoor Lane to become
a double carriageway and up-grading of Rudham
Stile Lane to the school.
Watermoor Lane should be left as a straight road to
the by-pass, with a suitable R /About at the junction,
with Norwich Long Lane, altered to suit, in years to
come N.L.L. will become vital to re-leave the traffic
pressure on Cherry Tree corner, with the increased
traffic flow on the Wells/Walsingham road.
Rudham Stile Lane at the western end must be upgraded before ANY development is allowed; this
needs to be a double carriageway. The
developments should be Fakenham inclusive, not
exclusive. Concerns must also be addressed in
respect of sewage, water supply & rainwater outfall,
along with school facilities etc.
FDB012
Alan & June Townsend
Members of the Public
Object
There are several points within this proposal that give
serious cause for concern as follows,
Traffic.
The volume of traffic which is already high within this
area is unsuitable for Rudham Stile Lane, especially
when you take into account the narrow bottlenecks.
Issues relating to the adequacy of
sewers, water and other essential
infrastructure were considered as
part of the preparation of the
adopted development plans and will
be addressed as part of individual
planning applications on the site.
When this development is completed large numbers
of cars, cycles, pedestrians will be leaving the High
School and their only way to get out to the bypass
will be to:
1) down to the traffic lights and out ,
2) up over a totally inadequate, dangerous little
Planning Policy & Built Heritage Working Party
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bridge and along Rudham Stile Lane.
These two roads will NOT cope with the volume and
public safety will be severely compromised.
Our understanding is that the Bypass was originally
built to take the heavy holiday traffic away from
populated areas of Fakenham, but now suddenly you
wish to take the population to the traffic!
Other points:
 This development will cause the
disappearance of green fields and associated
wildlife.
 Why not develop already existing Brown field
sites?
 The impact 900 houses will have on local
amenities and resources is totally unknown,
 Schools – already full,
 Doctors – already long waiting for routine
appointments,
 Transport links – currently very poor,
 Water – can the supply be maintained, what
about sewage?
 Telephones – Can the old Fakenham
exchange cope with all these extra
residents?
 Employment – Where within the locality are
all these extra people going to work?
 Road networks – Main routes out of
Fakenham to places like Norwich and Kings
Lynn will become even slower and
congested.
 Parking – Where in town will all these extra
vehicles generated by this development
park?
Planning Policy & Built Heritage Working Party
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FDB013
Mr Nigel Savory
Member of the Public
Comment
There should be adequate screening between the
development and the bypass to the North of the
proposed area. No screening is marked on the area
proposed for industrial and commercial development.
Such screening would benefit both users of the road
and the impact of the development on the rural area
to the North which remains undeveloped. This leads
down into the Stiffkey valley which is a beautiful and
unspoilt area of North Norfolk and should be saved.
Agreed.
Recommendation: The Brief
should be amended to include
further screen planting to the
proposed employment area.
Similarly we are concerned about pollution from the
site....whether through light, noise or water run-off.
Please can these points be taken into account.
FDB014
Ian Shepherd
Campaign to Protect
Rural England (CPRE)
Norfolk
Comment
We note that the key matters to be revised in the
Development Brief are set at paragraph 1.2.2 We
commend the effort that has clearly gone into the
review of the first seven of these, but wish to make
some comment on the last, which is 'infrastructure
provision, notably the foul waste network'.
The AWS report of October 2011 has provided
further information as set out at paragraph 3.8.5.
Statements are made to the effect that the Fakenham
Sewage Treatment works has the capacity to
accommodate the development, but a drainage
strategy is required to determine how the
development should connect to the STW; and
surface water should be to a Sustainable Urban
Drainage System.
Anglian Water has confirmed that
capacity is available at the sewage
treatment Works.(see comments
below).
Adopted policy requires the
provision of 45% affordable housing
where it is viable. The final
proportion of affordable housing will
be considered as part of the
application process and take
account of economic conditions at
that time.
Our concerns are two-fold, bearing in mind both the
proximity of the town to the River Wensum, and into
which the STW discharges waste water; and the
claims that the STW has 'the capacity'. These are:
Planning Policy & Built Heritage Working Party
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1. Will the overall sewage network and STW
really have the 'capacity' to deal with periods
of high water table when in combination of
heavy rain events; both as regards surface
water flooding and the capacity of the STW
2. Will the processing of the effluent meet the
necessary constraints for the effluent
discharge as regards nutrients and bacterial
loading when the new development is in
place; and again in the more extreme
weather conditions as above.
In our view this should not only be monitored, but
access to data be made available to the public; this
would be particularly the case if both the
Environment Agency and Natural England are put
under any further resource constraints.
The above is both a specific issue in relation to this
Development Brief, but a wider local and national
issue. We add, looking ahead to 2021 and beyond, in
this category is the level of affordable housing to be
attained through 'planning gain'. The present system
is discredited, in that it was never in reality viable,
clearly less so in a recession. It was used by
national, and some County politicians, as a means to
justify high housing (minimum) target numbers as a
requirement necessary to satisfy local need. It is an
issue which will have to seek to take into account
locally when the review of the Core Strategy takes
place, whether or not there is any change in the
position of national Government.
FDB015
Sue Bull
Planning Liaison
Manager
Anglian Water
Planning Policy & Built Heritage Working Party
Comment
Responding to paragraphs 3.8.4. & 3.8.5:
Noted.
Wastewater Treatment
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I can confirm the potential constraint at Fakenham
wastewater treatment works no longer exists and
there is currently sufficient capacity to serve this
development within environmental permits.
Foul Network
The Pre Development Report October 2011 referred
to in the draft document advised that „Development
will lead to an unacceptable risk of flooding
downstream. A drainage strategy will need to be
prepared in consultation with Anglian Water to
determine mitigation measures‟. This has not been
completed and as three years has passed since the
pre development report it is recommended the
applicant resubmits a pre-planning enquiry so that a
drainage solution can be found and mitigation
measures identified.
Surface Water
I note the reference to Policy EN10 and use of SuDS
(6.16.6). It is important that details of the overall
surface water management strategy should be
determined and agreed as early as possible.
FDB016
Mr Philip Atkinson
Lanpro
(Planning Consultancy)
Object
My client Mr Picken as owner of land off Rudham
Stile Lane objects in the strongest possible terms to
the emerging For Approval version of the
Development Brief prepared by Trinity College,
Cambridge.
See comments relating to access in
main report.
My client objects to the two main vehicular access
points into the FO1 site being under the ownership
and control of Trinity College, Cambridge (as your
Council‟s preferred landowner and author of the
emerging For Approval version of the Development
Brief). Adopting the current consultation version of
Development Brief unchanged will (1) create a
Planning Policy & Built Heritage Working Party
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ransom situation that will cause financial harm to my
client and other landowners; and (2) constitute State
Aid assistance by North Norfolk District Council to
Trinity College, Cambridge. The emerging
Development Brief does not explain to how this
financial and competitive advantage being gifted to
Trinity College can be avoided/is justified. To be very
clear my client will not allow your Council to engineer
a situation that delivers selective advantage to Trinity
College to the detriment of other land
owners/Fakenham residents in housing need.
Furthermore the emerging For Approval version of
the Development Brief is also contrary to
Government guidance contained in paragraph 182 of
the National Planning Policy Framework. The
emerging Development Brief is clearly unsound as it
has not been positively prepared by Trinity College
as a private developer and the access strategy is
neither justified nor effective due to the ransom
situation created.
I therefore request that North Norfolk District Council
re-write the access strategy advocated in the
emerging Development Brief document prior to its
adoption. This is because the implications of state
aid infringements are very serious.
FDB017
Mr & Mrs J Spencer
Ashworth
Members of the Public
Planning Policy & Built Heritage Working Party
Comment
We wish to make representation regarding the
proposed Amended Development Brief for Land at
Rudham Stile Lane. We live at Thorpland Lodge
Farm and farm the majority of the land immediately to
the north of the proposed development and are
therefore very aware of the potential environmental
impact. Inevitably, because the development sits on
high ground overlooking all the beautiful countryside
lying to the north [see fig 4 and paras 3.4, 3.5]any
45
1. Agreed.
Recommendation: The Brief
should be amended to include
further screen planting to the
proposed employment area.
2. Lighting – The District
Council is not the street
Page 21 of 36
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changes will have a disproportionately large effect on
it and the flora and fauna that are dependent upon it;
therefore particular care needs to be taken to
mitigate the impact.
1.
Screening - the area to the far north-west
of the site which is proposed to be an
industrial area is shown as coming right up
to the A148. In the site context plan (fig 1)
this land is correctly shown as „open
countryside‟, however in the Landscape
and Ecology plan (fig 4) it is rather
conveniently omitted from having any
designation.
Paragraph 5.43 includes reference to policy
ENV4. Building an industrial park right up to
the edge of the development land is in
contravention of several of the bullet points
clearly set out under this policy.
NNDC Response
lighting authority. The
need/desirability of
including street lighting
within the proposal should
be considered at planning
application stage.
It is also in direct contravention of
paragraph 6.14.2 which states “the northern
edge of the site will be designed to ensure
it is assimilated into the wider landscape to
the north of Fakenham and conforms to the
landscape character type it is located
within. The NNDC landscape character
assessment suggests that this should
include woodland planting and allotments
close to the A148.”
Historically, when the supermarket [now
Morrison‟s] and the existing industrial
estate to the east of the new development
was granted planning permission, it was
stipulated that a dense woodland screen be
planted on the northern perimeter - the
existing woodland screening that resulted is
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Page 22 of 36
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shown quite clearly on the site context plan
[Fig 1]. We were given to understand by the
planning officers at the time that this would
be the case in all and any future
development along the A148 corridor.
The proposed landscaping and allotment
areas adjacent to the A148 are a step in the
right direction. However, whilst the
proposed industrial area is the most blatant
abuse of the above promises and policies,
the whole A148 boundary falls far short of
showing adequate woodland planting.
We therefore suggest that the proposed
industrial estate is withdrawn back from the
road and that the entire length of the
development is planted to screening
woodland as it has been next to the Clip
Bush/A148 roundabout.
2.
Lighting - there is very little reference to
lighting in the plan. One of the biggest
impacts of any modern development is light
pollution and being right next to open mixed
countryside there will be a particularly
marked effect on the adjacent wildlife and
its ability to survive [e.g. nesting habits,
night time predation etc.].
When the Clipbush Lane roundabouts were
built all the street lighting along the northern
section of the road were of the screened
type to take account of these points.
We propose that it should be stipulated that
all outside lights, whether civic, business or
industrial, should not only be kept to the
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Page 23 of 36
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minimum legally required but also properly
shielded throughout. Likewise external
domestic lights should not be allowed to
cause light pollution. Taking this action
regarding lighting will not only help save
wildlife and the general amenity of the
countryside for all, but will also be more
energy efficient.
FDB018
Stephen Faulkner
Principal Planner
Norfolk County Council
(Planning Obligations,
Education & Local
Member Comments)
Comment
1.
Introduction
The officer-level comments are made on a
without prejudice basis and the County
Council reserves the right to make further
comments on the emerging Brief. The
County Council welcomes the opportunity
to comment on the Brief and supports the
sustainable aims and objectives of the
Brief.
2.
Infrastructure Delivery
*Attached to this response is the County
Council‟s comments made in April 2012.
With regard to infrastructure delivery the
County Council‟s previous comments still
stand and it is felt that further clarity is
needed in the Brief to explain how
infrastructure will be provided and funded.
3.
Education
The following detailed comments are
made:
1. Noted
2. Agreed. The brief could make
clearer the need to deliver
comprehensive development within
the designated area and the
expectation that each phase of
development makes equitable
contributions to the delivery of the
entire development.
3. Agreed. The suggested
amended should be incorporated.
Paragraph 2.2.2 - the reference to the
primary school site being reserved should,
for clarity, refer to a site needing to be
safeguarded for up to 2 ha (NB it is
acknowledged that the site size is referred
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to later in the Brief);
Paragraph 3.9.3 - this paragraph, for
clarity, should indicate that the safeguarded
Primary School site of 2 ha could
potentially accommodate a 2 form entry
school;
Paragraph 5.3.3 - this paragraph should
refer to a potential new primary sector
school being located in this central location.
Section 6.6 - welcome reference in this
section to the table which sets out the need
for a 2 ha site for a school. However, this
section would benefit in terms of clarity if
reference could be made to how the
proposed infrastructure would be funded
i.e. developer funded through either S106
and/or a Community Infrastructure Levy
(CIL).
Under any Infrastructure Delivery section it
would be helpful if there was reference to
the potential need for improvements to the
local high school arising as a consequence
of the proposed housing site.
4.
Planning Policy & Built Heritage Working Party
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Local Member’s View
The Local County Council Member (Tom
FitzPatrick) has indicated that he has some
concerns about the a slight increase in the
volume of traffic in Rudham Stile Lane
once the projected additional development
takes place on the rest of the area. He
feels that there will be a need for a proper
traffic management scheme as any
additional development takes place.
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5.
NNDC Response
Other Comments
The County Council will respond separately
on detailed highway and transport issues.
The attached* County Council comments
from April 2012 should, it is felt, also be
taken into account when taking forward the
Development Brief.
*ATTACHMENT (1) REFERRED TO ABOVE IS
AVAILABLE AT THE END OF THIS DOCUMENT
FDB019
Mr W P Shelton
Member of the Public
Object
I have to have my voice heard as I live on the Water
Moor Lane end of Rudham Stile Lane and I am
extremely concerned on the following issues.
1. How can the road cope with any more traffic?
Outside my property is a bottle neck into single file
road and at best poor visibility over the old railway
bridge which already gets congested at peak times. It
cannot be widened as it is between my boundary and
the allotment boundary, so the noise and access to
my property is going to be badly affected.
1. See comments relating to
access in main report
2. This site has been
earmarked for development
since 2008. In the first
instance any issues with
the search should be taken
up with the conveyance.
Potential loss of property
value is not a planning
consideration.
2. We purchased the property seven years ago
because of the quiet location with views over open
countryside and none of this planning was mentioned
in the land search so we invested in the house with
the thoughts of being in an ideal spot for many years
to come.
With the idea of a further development on the chicken
farm, with yet another road feeding onto Rudham
Stile Lane it seems no thought is being given to the
impact of the existing homeowners and the way this
will surely decrease the value of our properties losing the peace and quiet and the views. I have to
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Page 26 of 36
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ask - is there a compensation plan in place, as I
cannot see why residents should lose for developers
to make money?
This whole matter is causing anxiety and worry and is
making us feel pressured to sell our home!
Should we make the decision to move in the near
future, the value of our home and its appeal to
purchasers will definitely be affected by these
looming plans. I therefore must place my objection to
the planned development.
FDB020
Mr D L Scott
Member of the Public
Object
Environment
This is a green space which acts as a buffer between
the A148 and north Fakenham. We are constantly
reminded of the effect of climate change, and carbon
footprints, what will be the consequences of 900
homes, anything from between 2,000 and 3,000
people, plus possibly over 1,000 vehicles on this
areas environment? It is no argument to claim the
properties will be built to be environmentally friendly,
the fact remain the increase in pollution will be
substantial!
Housing Needs
Are there actually 900 local families in the Fakenham
area waiting to be housed? If not presumably the
houses will be purchased by new people to the area,
including the „buy to rent‟ group. The social housing
will go to families with the highest number of points
which may not benefit local people? There is very
little if virtually no employment in Fakenham so this
development could become a commuter satellite
estate for say Norwich or King‟s Lynn. The price of
the properties will in general be too high for the local
residents to get onto the housing ladder, and if rented
the rents will be far too high!
Planning Policy & Built Heritage Working Party
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Environment – The scale of
growth required in the District
necessitates the development of
some greenfield sites. This site was
carefully selected and is not subject
to any specific environmental
constraints being primarily in use
for agriculture.
Housing Need – There are high
levels of both Housing need and
housing demand in North Norfolk
and Fakenham. Planning
Authorities are required to meet all
needs for housing in their areas.
The scale and distribution of
housing growth in the District has
been independent examined via the
preparation of the Local
Development Framework. There
are more jobs in Fakenham than
there are working people and the
town acts as an employment centre
for wide area beyond the town. The
allocation includes provision for
significant new employment
Page 27 of 36
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Services
With so many properties crowded into a small area it
is quite possible as with other developments the
water, sewage, electricity etc services will not be able
to cope, leaving in mind much of Fakenham‟s
systems are quite old!
opportunities.
Health
Whilst we have an excellent group of doctors, nurses
etc at Fakenham Medical Practice they cannot even
currently cope with the volume of patients! Waiting
times for a normal appointment is 2 to 3 weeks! We
have a high proportion of pensioners, though they
are not entirely the reason for the high number of
patients! No doubt the claim will be more doctors,
nurses etc will be recruited. The question is where
from? We could become like Watton where
longstanding residents are removed without warning
from doctors lists!
Schools
It appears the schools in the area are fully subscribed
so how can they cope with new pupils. If a new
school is to be built where will the new staff come
from?
Services, Health, Schools – The
adequacy of a range of services
has been considered as part of the
process of allocating this site for
development. A number of
improvement will be necessary and
these are highlighted in the brief.
Specific development proposals
can be required to contribute
towards the enhancement of
supporting services and facilities as
part of the planning application
process.
Business- The town centre and
many local businesses are likely to
benefit both from the construction
stage of the development and the
increase in population.
Traffic – See comments relating
to access in main report
Business
It is unlikely local businesses will gain in any way
from this development (except from the
supermarkets!). Parking in Fakenham is already very
limited. It is very bad on market day! How can the
town cope with 1,000 plus more vehicles?
Local Traffic
The amended plan still fails to deal with the local
traffic problems! It does not appear enough research
at the actual location has been undertaken? Rudham
Stile Lane cannot currently cope adequately with the
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volume of traffic which uses it! This is a particular
problem at school run time! It, at times, resembles a
race track with numerous high speeding cars (many
trying to avoid the traffic lights at the bottom of
Claypit Lane!)! Drivers forget it is a lane! In Claypit
Lane 90% of drivers totally ignore the 20mph speed
limit, despite the number of school children passing
through it! The real problem is the small bridge which
links Claypit Lane, Water Moor Lane and Rudham
Stile Lane! An accident waiting to happen!! Despite
the danger drivers approach what should be classed
as a „black spot‟ at great speed, and without any
caution! It is again used by numerous children, and
local pedestrians!
As I have stated in the local media, there should be a
20mph limit on this bridge, and in Rudham Stile Lane
plus speed bumps! The speed limit should vigorously
enforced in Claypit Lane. Water Moor Lane should be
one-way, exit only from Fakenham. On no account
should there be any new entrances to Rudham Stile
Lane, or Water Moor Lane, and I cannot comprehend
how anyone can suggest a bus route! There will be a
serious accident unless changes are made!!!
General
I feel the whole scheme needs to be reviewed, with a
full public enquiry, and a poll amongst all local
residents.
FDB021
Chris Young
NNDC
(Conservation & Design)
Comment /
Support
Having read through the latest version of the brief, it
appears to have addressed the most important
issues previously raised by Conservation & Design;
namely the lack of any reference to design quality
and the village square arrangements.
Noted. No further action required
Whilst it hasn‟t taken on board some of the other less
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substantive concerns (i.e. it still refers to the use of
raised tables and it still does not seem to refer to the
provision of single-storey buildings), these are not
matters which should prevent us adopting the brief.
FDB022
Cathy Batchelar
Kerys Witton
NNDC
(Landscape)
Comment /
Support
Thank you for consulting „Landscape‟ regarding the
final version of the Development Brief for Rudham
Stile Lane. Further to our comments in the
memorandum dated 8th February 2012, we welcome
the changes incorporated into the amended brief.
Improvements have been made with respect to the
cycling/pedestrian focus within the layout, the village
square and green space provision. There remain
some elements of concern however it is considered
that these may be addressed at the detailed design
stage with scope within the Brief to allow for this.
Noted. No further action required.
FDB023
Michael Cook
Member of the Public
Comment
My greatest concern is that with more traffic going
down Rudham Stile Lane it will be even more
dangerous trying to get across Thorpland Road into
Holt Road. This crossroad has been crying out for a
roundabout ever since the old BP site was
developed. You cannot see far enough to the left and
quite a few times I and many others who I speak to
say the same thing.
I have been told that the development of houses on
the junction should have been possibly for 22 houses
but actually they built (I'm not 100 per cent sure here)
28 houses - so they crammed them right up to the
junction. You should go there yourself and try
crossing from Thorpland Road into Holt Road. If
more traffic is going to have to cross there it can only
get worse. The strange thing is that there is ample
road to put in a roundabout.
The Brief indicates that Rudham
Stile Lane is unsuitable for any
significant increase in traffic and
any applications for planning
permission will need to fully assess
and address the traffic issues
associated with individual
proposals. The access strategy
included within the Brief aims to
minimise the use of unsuitable
roads unless they are improved to
an acceptable standard.
Planning Policy & Built Heritage Working Party
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FDB024
David Higgins
Principal Engineer
Major and Estate
Developments Team
Norfolk County Council
(Highways)
Comment
Below are the Highway Authority comments on the
Development Brief August 2014. Attached* is a
drawing showing some of the suggested changes:-
The development plan allocates a
large area of land including land
west of Water Moor Lane for future
development but it stipulates that
only 800-900 dwellings will be
permitted during the current plan
period up to 2021. Following this
the further release of land for
development will be tested to
establish if it is suitable for further
development. The development
brief should not be required to plan
for further development which may
not be acceptable but should be
mindful of the long term
development potential. This has
been considered, for example, the
location of the „village centre‟ and
potential school site are towards
the western end of the development
where they would conveniently
service both the proposed and
potential future development.
It is considered that the Development Brief should
encompass all the land being allocated not just the
Trinity College controlled land and include the land
west of Water Moor Lane even if this is limited to
calling the land strategic reserve and showing basic
necessary road infrastructure.
Whilst it is accepted that a transport assessment has
been done this was only considered by the Highway
Authority in the context of deciding if the scale of
allocation could in principle be accepted in this
location. It is not considered that a definitive TA has
been produced that identifies all the development
impacts and mitigation measures.
Page 17 Figure 6
B1105 Barsham Road should be labelled as should
Wells Road from the A148 and Barsham Road.
Page 24 para 6.2.2
First Sentence - delete additional word - 'junction'.
Second sentence - replace 'therefore supported' with
'acceptable to'.
Page 24 para 6.2.3
Replace 'the lane access to the north with vehicles
using the new improved access' with ' the Wells
Road junction with the A148'.
Page 25 Figure 9
The land west of Water Moor Lane should be
identified as Strategic Reserve land that will be the
subject of future consultation and should show
Planning Policy & Built Heritage Working Party
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It is agreed that detailed Traffic
Impact Assessments will be
required in order to identify and
mitigate the impacts of specific
development proposals and the
Brief should make this clear. The
further textual changes suggested
by the Highway Authority are
agreed.
Recommendation: Amend the
Brief to incorporate the
suggested changes.
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indicatively the access road from the new spine road
to the A149 and the A149/B1105 junction which will
need to be up-graded to a roundabout.
Page 27 Figure 10
The plan gives the impression of multiple road links
to Rudham Stile Lane when the principle is only
frontage development.
Page 28 Figure 11
 Remove blue arrow on Wells Road and add
road closed sign just north of A148 or if not upgrade Wells Road to a 'B' road, change the
junction priority at the B1105 Barsham Road
junction with Wells Road and reclassify
Barsham Road from 'B' road to 'C' road between
the A149 and Wells Road
 Identify HGV ban location on Lime Tree Avenue
between housing and employment.
 Reflect comments on figures 6, 9 and 10 on this
plan.
 Improve Rudham Stile Road between Grove
Lane to Claypit Lane to cater for traffic that used
to use Water Moor Lane and consider junction
improvement of Thorpland Road Holt road and
Greenway Lane.
Page 31 Figure 13
Rudham Stile road should not be characterised as a
'Lane'. A separate' frontage development' character
is needed that has a minimum width of carriageway
of 4.8m and a 2m frontage footway on the north side
with frontage development behind
Page 32 Lime Tree Avenue
Access and movement; Remove reference to traffic
signals that would not be appropriate in this
development.
Planning Policy & Built Heritage Working Party
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Page 34 Streets
It would be acceptable to have a narrower
carriageway of 4.8m
Page 35 Lanes
Remove all references to Rudham Stile Lane. See
comments on figure 13.
Page 36 Mews
7.5m is considered too wide and 5.8m would be more
appropriate in line with current advice.
Page 44 Implementation - phasing- residential
development - para 7.2.3
It should be made clear that the only discrete
development that can come forward separately will
be limited to frontage development along Rudham
Stile Road and that no estate scale development will
be allowed that was not accessed off the new estate
spine road. A Transport Assessment that identifies all
the impacts of the allocation and the application site
will be required so that the appropriate share of
mitigation measures are provided by each application
as they come forward.
*ATTACHMENT (2) REFERRED TO ABOVE IS
AVAILABLE AT THE END OF THIS DOCUMENT
FDB025
Philip Raiswell
Sport England
Planning Policy & Built Heritage Working Party
Comment
From Sport England‟s perspective I note it is not
intended to re-allocate the formal recreational space
to land adjoining the rugby club/leisure centre as
suggested in our earlier representations, but we
appreciate that this option was at least given
consideration. We note that the allocation remains
broadly the same as previously proposed in terms of
location and quantity of provision (2.81 hectares).
57
Comments Noted. It is agreed that
the proposed textual changes in
relation to sports pitch provision
should be incorporated.
Recommendation: Amend the
Brief to incorporate the
suggested changes
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Sport England does not object to this approach but
would add the following comments to supplement the
guidance given in Para‟s 6.5 and 6.11 of the
document:
 Any new formal sports pitches will need to be
serviced with car parking and changing
accommodation/pavilion (depending on sports
to be provided) to meet Sport England/NGB
technical guidance. In particular, guidance and
standards within Sport England design guidance
„Pavilions and Clubhouses‟ (1999) should be
adhered to. This document can be downloaded
here: http://www.sportengland.org/facilitiesplanning/tools-guidance/design-and-costguidance/pavilions-and-clubhouses
 New playing pitches need to be provided in
accordance with Sport England technical
guidance contained within our document
„Natural Turf for Sport‟ (2011), which can be
downloaded here:
http://www.sportengland.org/facilitiesplanning/tools-guidance/design-and-costguidance/natural-turf-for-sport
Sport England would therefore request that the
document is amended to reflect the above
requirements, in order to ensure that new sports
pitches and ancillary facilities are provided to meet
adopted quality standards and guidelines.
I hope these comments can be given full
consideration when the document is finalised and we
would welcome confirmation of this in due course.
Planning Policy & Built Heritage Working Party
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FDB026
Linda Jennings
Fakenham Town
Council
Planning Policy & Built Heritage Working Party
Object/
Support/
Comment
Comment
Comments
1. That Trinity donate a strip of land to either
the District or County Council to enable the
widening of Rudham Stile Lane in the future.
If Water Moor Lane is blocked off, Trinity
must be required to upgrade Rudham Stile
Lane at its narrowest point.
2. Improvements to the junction of Thorpland
Road and Greenway Lane would be a
necessity. School traffic that uses Water
Moor Lane, if closed would use Rudham Stile
Lane.
3. Norwich Long Lane, the road leading from
Wells Dry Road to the new roundabout is
inadequate. To close this would put even
more traffic onto Wells Road where the
existing junction is potentially dangerous
especially in summer and on Sundays with
the car boot traffic. A decision to develop this
road now would obviate the need for a
second Wells Road roundabout when the
western end of the site is eventually
developed.
4. NNDC should liaise with the local Doctors
and Schools.
5. The Developer should have a duty to the
existing Town as well as the new Residents
when amenities are planned.
59
NNDC Response
1. Agreed. It is recognised that
any closure of Water Moor
Lane is likely to necessitate
improvements to Rudham
Stile Lane/ Thorpelend
Road and the Brief identifies
this. The precise extent of
any works will need to be
agreed through the planning
application process.
2. Agreed. Any closure of
Water Moor Lane, in either
direction is likely to require a
package of highway
improvements to
accommodate changes in
traffic conditions on adjacent
roads.
3. Long Lane – The Highway
Authority have indicated that
the most likely option will be
the closure of Long Lane to
through traffic when the
proposed new roundabout
on the A148 is formed. Such
closure is unlikely to
necessitate improvements
to the Wells Road/A148
junction.
4. Agreed. Allocation of the
site for development was
subject to consultation with
both Education and Health
Care providers and further
consultation in relation to
individual proposals will be
required.
5. The development should
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provide amenities which are
necessary in order to make
the new development
acceptable and this will
necessitate additional
facilities such as open
space, allotments,
employment land and
potentially a new primary
school which are included
within the brief. Other
„planning gain‟ may be
required provided that this is
shown to be necessary to
support the proposed
development.
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