Proposed Main Modifications

Main Modification number: MM68, 69, 70
Policy reference: NPPF 8
Not sound because it is not justified, effective, positively prepared or consistent with national policy
Does not comply with duty to cooperate

NCC M&WP development methodology is significantly flawed, as it relies exclusively on Developers to propose sites. Where sites are proven to be unsuitable or have even been rejected by the Councils own Planning Committee, NCC continue to be developer led and inflexible in the identification of other sites. Other Councils (e.g. Suffolk and Essex County Council) seek landowners directly to propose sites at the start of their planning process, proactively seek out potential sites and therefore cast the net wider in the identification of potential sites.
MIN 25 is unsuitable as it is on the boundary of the Broadlands National Park and causes substantial harm to two Grade 1 listed National Treasure (St Mary’s and St Matthias Churches). It also sits on the North East boundary of the settlement of Haddiscoe and is too close to residents houses. Heritage England have raised significant concerns with the development of this site. The Broads Authority have stated “Although just outside the BA boundary, the proximity, scale and nature of the proposals in the context of a sensitive landscape mean that there would be some adverse effects on the Broads …..”
At the NCC Planning Meeting on the 24th May, members of the committee unanimously rejected the site and request that the site be declared as “unsuitable”. They were advised not to by the NCC Planning Officer. Given at least 3 other sites were declared unsuitable, given the significant issues with MIN25, these should now be revisited, and other potential sites reviewed by NCC.

Main Modification number: MM68, 69, 70
Policy reference: NPPF 8
Not sound because it is not justified, effective, positively prepared or consistent with national policy
Does not comply with duty to cooperate

NCC M&WP development methodology is significantly flawed, as it relies exclusively on Developers to propose sites. Where sites are proven to be unsuitable or have even been rejected by the Councils own Planning Committee, NCC continue to be developer led and inflexible in the identification of other sites. Other Councils (e.g. Suffolk and Essex County Council) seek landowners directly to propose sites at the start of their planning process, proactively seek out potential sites and therefore cast the net wider in the identification of potential sites.
MIN 25 is unsuitable as it is on the boundary of the Broadlands National Park and causes substantial harm to two Grade 1 listed National Treasure (St Mary’s and St Matthias Churches). It also sits on the North East boundary of the settlement of Haddiscoe and is too close to residents houses. Heritage England have raised significant concerns with the development of this site. The Broads Authority have stated “Although just outside the BA boundary, the proximity, scale and nature of the proposals in the context of a sensitive landscape mean that there would be some adverse effects on the Broads …..”
At the NCC Planning Meeting on the 24th May, members of the committee unanimously rejected the site and request that the site be declared as “unsuitable”. They were advised not to by the NCC Planning Officer. Given at least 3 other sites were declared unsuitable, given the significant issues with MIN25, these should now be revisited, and other potential sites reviewed by NCC.

Main Modification number: MM68, 69, 70
Policy reference: NPPF 8
Not sound because it is not justified, effective, positively prepared or consistent with national policy
Does not comply with duty to cooperate

NCC M&WP development methodology is significantly flawed, as it relies exclusively on Developers to propose sites. Where sites are proven to be unsuitable or have even been rejected by the Councils own Planning Committee, NCC continue to be developer led and inflexible in the identification of other sites. Other Councils (e.g. Suffolk and Essex County Council) seek landowners directly to propose sites at the start of their planning process, proactively seek out potential sites and therefore cast the net wider in the identification of potential sites.
MIN 25 is unsuitable as it is on the boundary of the Broadlands National Park and causes substantial harm to two Grade 1 listed National Treasure (St Mary’s and St Matthias Churches). It also sits on the North East boundary of the settlement of Haddiscoe and is too close to residents houses. Heritage England have raised significant concerns with the development of this site. The Broads Authority have stated “Although just outside the BA boundary, the proximity, scale and nature of the proposals in the context of a sensitive landscape mean that there would be some adverse effects on the Broads …..”
At the NCC Planning Meeting on the 24th May, members of the committee unanimously rejected the site and request that the site be declared as “unsuitable”. They were advised not to by the NCC Planning Officer. Given at least 3 other sites were declared unsuitable, given the significant issues with MIN25, these should now be revisited, and other potential sites reviewed by NCC.

Main Modification number: MM70
Policy reference NPPF 96c
The Main Modification is not sound because it is not justified or consistent with national policy.
NPPF (para 96c) states that planning decisions should support healthy lifestyles, especially where this would address identified local health and wellbeing needs.
MIN25/Crab Apple Lane site is on the boundary of the village of Haddiscoe and of all the sites proposed has the highest residential impact. NCC MIN25 Policies included a 100m stand-off area in recognition of this residential impact.
There are large uncertainties with dust assessments. The 100m buffer zone provides the residents with at least a definite level of protection, whereas a site-specific distance would be based on an assessment with a large amount of uncertainty attached to it.
IAQM guidance on the assessment of dust from demolition and construction (January 2024: Version 2.2 para 4.2.2), “according to MRl (2006) the overall fraction of PM2.5 in PM10 of construction emissions varies between 5% and 15%.
Given the settlement by the UK Government to Ella Adoo-Kissi-Debrah PM2.5 is a real issue and residents should be appropriately protected by a minimum of a 100m buffer to the curtilage/boundary of their properties as a matter of policy (which has been removed under the MM), not just to residential receptor buildings as stated in MM68