Appendix 4 - Development excluded from safeaguarding provisions

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Comment

Initial Consultation document

Representation ID: 92542

Received: 10/08/2018

Respondent: Bourne Leisure Ltd

Agent: Lichfields

Representation Summary:

Appendix 4 - Development excluded from safeguarding provisions
Bourne Leisure considers it necessary that development relating to caravans, chalets and touring pitches be added to the table at Appendix 4. There is no reason why this sort of development would inhibit the use of a site for sand and gravel extraction in the future any differently than other development listed in the table, including for example, the minor infilling of development in towns and villages and the extension to existing settlements of no more than 2ha. The inclusion of caravan, chalet and touring pitch development in this table would also give Bourne Leisure and any other holiday park operators confidence that any future planning applications for the four holiday parks across the Plan area would be determined as efficiently and effectively as possible Bourne Leisure therefore suggest that the table at Appendix 4 is amended to also include "Caravans (static and touring), tents and chalets and any other caravan park development that is 'minor'" as development excluded from safeguarding provisions.

Full text:

On behalf of our client, Bourne Leisure Ltd., please find below representations on the Norfolk Minerals and Waste Local Plan Review Initial Consultation (May 2018), published for consultation until 13 August 2018.
Background
Bourne Leisure operates more than 50 holiday sites in the form of holiday parks, family entertainment resorts and hotels in Great Britain and is therefore a significant contributor to the national tourist economy, as well as local visitor economies. The sites are managed by a number of subsidiary companies which include Haven, Butlins and Warner Leisure Hotels. Within Norfolk, Bourne Leisure operates four Haven holiday parks: Caister-on-Sea Holiday Park, Seashore Holiday Park, Wild Duck Holiday Village and Hopton Holiday Village. All four of these parks are located within the local planning authority area of Great Yarmouth.
Many of the Company's hotels and holiday sites are located in rural and/or coastal areas and these environments are one of the key draws for these holidays. The Company's operations are also major contributors to local and regional economies, both directly and indirectly. It is therefore vitally important to Bourne Leisure that both the environments within which their sites are located are protected and enhanced, to help the Company to continue to attract customers, and that planning policies also support their regular investment to provide new and improved facilities. This investment is also required to respond to changing market conditions. For many of the Company's holiday locations, improvements may necessitate the expansion of sites in order to improve the quality of accommodation, decrease densities, or increase the range of facilities in order to respond to visitors' requirements and to extend the holiday season.

Response to Policy Approaches
Minerals and Waste Local Plan Vision to 2036
Bourne Leisure considers that in order to set out a comprehensive and robust vision for the future of minerals and waste in Norfolk, it is important to recognise the role of Norfolk's local economy and how sectors outside minerals and waste may be affected by the proposals in the Plan. Paragraph 80 of the National Planning Policy Framework (NPPF, July 2018) requires planning policies to "help create conditions in which businesses can invest, expand and adapt". It goes on to state that both local business needs and wider development opportunities should be taken into account in supporting economic growth and productivity.
Bourne Leisure therefore considers that an amendment to the Plan's vision is necessary so that the potential impacts are recognised of the location, design and operation of minerals development and waste management facilities, in terms of the effects they could have on the local economy, including, for example, on tourism accommodation and related visitor facilities. The inclusion of this amendment within the vision of the emerging Plan would also ensure that it better aligns with its draft policies, such as Policy MW2, where there is greater consideration of the role of the local economy.
Bourne Leisure suggests that the Plan's vision is amended to include additional text as follows (new text in CAPITALS):
"Minerals development and waste management facilities will be located, designed and operated without adverse impacts on the amenity of local communities, the natural, built and historic environment, THE LOCAL ECONOMY OR the landscape and townscape of Norfolk."

Policy MW2 - Development Management Criteria
Bourne Leisure owns and operates four holiday parks in Norfolk and as set out above, it is important for the Company to ensure these Parks have the ability to continue to attract customers and therefore bring wider economic and social benefits to Norfolk. Bourne Leisure therefore endorses draft Policy MW2 as it requires development proposals to demonstrate that there are no unacceptable impacts against a number of criteria including local amenity, the visual/landscape environment and the character and quality of the area. These are all key considerations that would affect holiday parks and their ability to continue to operate effectively.

This approach is consistent with national policy, namely part (f) of paragraph 204 of the NPPF which requires planning policies to set out criteria to ensure permitted and proposed developments do not have unacceptable adverse impacts on the natural and historic environment or human health.
Bourne Leisure does not suggest any amendments to this draft policy.

Policy MW3 - Transport
Bourne Leisure endorses draft Policy MW3 for the requirement that proposals do not result in unacceptable traffic impacts, including in relation to pedestrians, other road users and air quality. The NPPF requires consideration of transport issues early in the plan-making and development proposals process so that, among other things, the potential impacts of development on transport networks can be addressed and any adverse environmental impacts of traffic and transport infrastructure can be avoided and mitigated (paragraph 102).
The proposed policy approach is therefore consistent with national policy, as it aims to ensure that any mineral or waste development proposals will not have any adverse traffic impacts that could affect customers at Bourne Leisure's holiday parks in Norfolk. This is particularly important in relation to highway safety for guests and the air quality at and near to the Company's holiday parks.
Bourne Leisure does not suggest any amendments to this draft policy.

Policy MP2 - Spatial Strategy for Minerals Extraction
Bourne Leisure considers it is necessary that when establishing a spatial strategy for the extraction of minerals, all land uses are considered so that consideration is given to making environmental improvements and ensuring safe and healthy living conditions while endeavouring to make efficient use of land (NPPF, paragraph 117). The Company therefore considers that draft Policy MP2 should be amended so that tourism development is considered as a sensitive receptor to amenity impacts. The New Anglia Local Enterprise Partnership (LEP) identifies the visitor economy as a key sector for Norfolk's economy, as identified in their Economic Strategy (November 2017). As a result, it is key that any minerals and waste development does not have an adverse impact on tourism developments, as this would in turn impact on the sector's contribution to the local and wider economy. This is particularly important in relation to tourism accommodation, as it increasingly supports longer stays; if not considered appropriately in relation to the impacts of proposed minerals and waste development, harmful effects could result in a number of direct impacts - and critically, indirect impacts such as the loss of local jobs and reduced spend in local businesses.
Bourne Leisure therefore suggests the following amendments to part (h) of the draft policy (new text in CAPITALS):
"h. Sensitive receptors to amenity impacts (residential dwellings, educational facilities, workplaces, healthcare and TOURISM AND leisure facilities) and 250 metres around each sensitive receptor."

Appendix 4 - Development excluded from safeguarding provisions
Bourne Leisure considers it necessary that development relating to caravans, chalets and touring pitches be added to the table at Appendix 4. There is no reason why this sort of development would inhibit the use of a site for sand and gravel extraction in the future any differently than other development listed in the table, including for example, the minor infilling of development in towns and villages and the extension to existing settlements of no more than 2ha. The inclusion of caravan, chalet and touring pitch development in this table would also give Bourne Leisure and any other holiday park operators confidence that any future planning applications for the four holiday parks across the Plan area would be determined as efficiently and effectively as possible Bourne Leisure therefore suggest that the table at Appendix 4 is amended to also include "Caravans (static and touring), tents and chalets and any other caravan park development that is 'minor'" as development excluded from safeguarding provisions.

Comment

Initial Consultation document

Representation ID: 93169

Received: 20/07/2018

Respondent: Broads Authority

Representation Summary:

What about moorings and river bank stabilisation and other such applications that occur in the Broads but probably not elsewhere in Norfolk?

Full text:

Today Planning Committee endorsed the response below to the Norfolk Minerals and Waste Local Plan Issues and Options consultation.

I hope this is helpful and I am happy to clarify any points if needed.


Main document
* The Broads has been identified by Historic England as an area with exceptional potential for waterlogged archaeology. Any excavation within or close to the executive area will require particularly robust archaeological evaluation prior to consenting and not rely on a brief desk based evaluation and conditions.
* For the avoidance of doubt, perhaps say that this covers the entire county of Norfolk.
* Perhaps something about how it fits with our Local Plans? Something about how Authorities consulted if application in or near to area? We would like to understand how our special qualities and our policies that could be of relevance would be considered in decision making.
* Page 16, 28 - the Broads has a status equivalent to a national park.
* Page 23 - suggest A3 landscape.
* Page 28: Typographical error: 'Landscape Character Assessments have been carried by the Local Planning Authorities in for Norfolk and they consider where locally designated landscapes of importance are situated'.
* Page 39: Typographical error: 'and/or the volumes of waste in each area so low that it would be unviable for a full range of waste management facilities to exist in every area'.
* Page 41: Typographical error: 'end-of-live vehicles' - should this be 'life'?
* Page 46: Typographical error: '...have similar locational requirements due to their potential to impact on local amenity and the environmental'.
* Page 49: Typographical error: 'of waste electronic electrical and electronic equipment (WEEE)'
* WP17 and MP10 and MP11 - will you provide GIS layers of these facilities and consultation zones?
* Page 61: Typographical error: 'the most recently available date'
* The areas on page 67 - the Broads is not mentioned. Presumably this is because silica sand only occurs in West Norfolk Borough?
* Page 77: Typographical error: 'will be made by on a case by case basis'.
* Page 78: Typographical error: 'Carstone is also a scare resource in Norfolk and therefore it is appropriate for the entire carstone resource to be safeguarded as part of the MSA'
* Page 78 - reference to peat. Whilst extraction is not supported in the NPPF, what about the removal of peat as part of the development related to minerals and waste? Peat has many important qualities and the Authority has a policy relating to peat. How will this be used in determining applications in the Broads? As well as that, you may wish to look at policies relating to peat in terms of its removal and how it is to be treated in relation to its properties.
* Page 81 - are there any areas in Norfolk that could be investigated for unconventional hydrocarbons/fracking?
* Appendix 4: What about moorings and river bank stabilisation and other such applications that occur in the Broads but probably not elsewhere in Norfolk?
* General comment: headers and paragraph numbering would make the document easier to read - pages of text with no breaks was difficult to read.

Question 5: MW2
* Page 26, MW2 could mention dark skies. You could refer to the CPRE Night Blight data as well as our dark skies policy and zones.
* Page 27: Dark skies are important in the Broads and elsewhere. Perhaps more could be said about lighting: directing lighting downwards and away from properties and only lighting if needed and temporary versus permanent illumination.
* Page 27: 'A baseline ecological survey will be necessary where biodiversity features are present on a proposed site. Such surveys are essential in identifying what exists on a proposed mineral or waste management site and establishing whether such features should be retained and managed'. This is a bit confusing and seems to say that a survey would be needed to see if there are biodiversity features on a proposed site to then need a survey? We recommend that all sites would require baseline ecological survey and assessment of the presence of rare and protected species.
* Page 28: 'Local recreation assets, including Public Open Space and other outdoor facilities such as country parks, are protected in District, Borough and City Local Plans'. Also protected in the Local Plan for the Broads.
* Page 29: 'whilst others designated at a local level are subject to protection through District, Borough and City Local Plans'. Also mention the Local Plan for the Broads.

Question 6: MW3
* Page 33: 'All proposals for minerals development or waste management facilities must assess and consider positively the potential for non-HGV transportation of materials to and from the facilities, principally by rail or water'. Perhaps you might want to require an assessment that looks into this and shows their considerations? As written, an applicant does not seem to be required to do anything other than think about it.
* Page 33: 'The County Council will consider minerals and waste development proposals to be satisfactory in terms of access where anticipated HGV movements, taking into account any mitigation measures proposed, do not generate'. Wonder if this could be worded in a more simple way?

Question 7: MW4
* Uses the word 'should' which is quite weak term. A stronger term similar to that uses in other policies (like will need to, must, is required to) might be better.
* Some aspects repeat MW2 - does that matter?

Question 9: MW6
* Does MW6 repeats MW2?
* See previous comment about peat. Should peat be mentioned in this policy?

Question 11: WP2
* Page 45: what is 'appropriate transport infrastructure'?
* Page 45: is the five mile requirement as the crow flies or by road/path etc?

Question 12: WP3
* Page 46: 'Policy WP3: Land uses potentially suitable for waste management facilities'. This does not seem an ideal title for the policy; the policy seems to be more about where waste management facilities can go. Not all of the areas listed in the criteria are land uses in the typical sense; they are areas to which such facilities are directed towards.
* Page 46, do criteria d, e, f apply even if the proposal is not within 5 miles of a town as talked about in the previous policy? How do WP2 and WP3 work together?

Question 16: WP7
* WP7: regarding the location, these could be away from urban areas according to some criteria in WP3. Should these be located near to larger urban areas (i.e. near to the source of the waste)?

Question 22: WP13
* Are the areas of these landfills identified and are any in the Broads?

Question 25: WP16
* Should this include reference to MW2? That seems to have relevant and detailed criteria.

Question 28: Policy MP2
* The Broads, which has a status equivalent to a national park, may need to be listed as a planning constraint

Question 29: MP3
* There is no mention of the requirement for restoration.
* In other policies you cross refer to a more detailed policy, but not in this policy. Presumably policy MW2 is of relevance and could be cross referred to?

Question 31: MP5
* Who does the assessment? Does that need to be handed in with the planning application? How will you liaise with the Broads Authority if proposals come forward in the river valleys in the Broads rather than just consult? Why is the Broads not included in the core river valleys? Is a separate policy on the Broads required? Or is it the case that the Broads is not covered by this policy as the Broads Authority Executive Area is shown on the policies map as a landscape designation and so rivers and broads within the BEA not included under core river valleys policy, potentially affording greater protection i.e. development could be acceptable in Core River Valleys? This could usefully be clarified.
* In other policies you cross refer to a more detailed policy, but not in this policy. Presumably policy MW2 is of relevance and could be cross referred to?
Question 32: MP6
* What are the criteria or is there a checklist that helps ascertain if cumulative impacts are unacceptable?

Question 33: MP7
* As well as GI, ecological networks? There is ecological network work underway for the entire county which could be of relevance.
* The last part says 'The Green infrastructure Strategy' - which strategy is this? The strategy of the district in which the proposal is located?
* There is also a Norfolk-wide habitats map that could be of relevance.

Question 34: Policy MP8
* To gain the ecological benefits outlined for many of the sites an outline aftercare strategy for a minimum of ten years, rather than five years is required prior to the determination of the planning application

Question 35: MP9
* It is not clear if the works then need to be removed and form part of the restoration works or are moth-balled. This could usefully be clarified.

Sites Document
* MIN 38 - land at Waveney Forest, Fritton - the Authority supports the conclusion that this should not be allocated for the reasons as set out in the assessment. Page 169 - the landscape character assessment is also relevant: http://www.broads-authority.gov.uk/news-and-publications/publications-and-reports/planning-publications-and-reports/landscape-character-assessments. Broads Landscape Character Assessment 2016; Land considered as heathland Landscape Character Type (LCT) within the St Olaves to Burgh Castle Landscape Character Area (LCA). Land to the north and west considered to be estuarine marshland LCT within the same LCA. Haddiscoe Island LCA beyond river. The Authority strongly requests that Norfolk County Council liaise with us regarding this site and any future policy prior to the next version of the Local Plan. Strongly support this conclusion and the reasons for it. The current commercial forest operation, whilst not ideal in terms of the HE features within it, offers a degree of continued protection to those features. Page 169 Typographical error: "although food practice for tree felling" presumably should read good practice.

* MIN65; support submission of Heritage statement

* MIN 209, 210, 211; For information, the Broads Landscape Character Assessment 2016 says that this area is LCA Outney Common and Bath Hills, Industrial / Early post-industrial LCT boarders MIN 211. The Authority strongly requests that Norfolk County Council liaise with us regarding this site and the policy prior to the next version of the Local Plan. Support removal of plant site from BA executive area. What will go in its place?

* MIN 25; Broads Landscape Character Assessment 2016; Norton Marshes to Haddiscoe Dismantled Railway LCA immediately NE. Adjacent LCT is settlement fringe which would be covered in time by the Broads settlement fringe policy. Support submission of Heritage statement.Whilst this is not within the Broads, the Authority strongly requests that Norfolk County Council liaise with us regarding this site and the policy prior to the next version of the Local Plan.

MIN 92; Broads Landscape Character Assessment 2016; Chet Valley LCA, Carr woodland LCT to west and upland LCT to the north and south. Recommended not to support this site going forward (in terms of landscape) for reasons as set out in the supporting text under 'landscape'.